EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 4.12.2008 
SEC(2008) 2938 
Draft (15 October 2008) 
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
PROPOSAL FROM THE COMMISSION TO  
THE EUROPEAN PARLIAMENT AND COUNCIL 
 
for a directive proposal for stage II petr ol vapour recovery during the refuelling of 
petrol cars at service stations  
 
Executive Summary - Impact Assessment 
  
{COM(2008) 812 final} 
{SEC(2008) 2937} 
 
EN 2   EN EXECUTIVE SUMMARY  
This impact assessment accompanies a legislative proposal aimed at recovering petrol vapour 
which is emitted to the atmosphere during the re fuelling of passenger cars at service stations 
(Stage II Petrol Vapour Recovery or PVR). Th ese emissions contribute to local and regional 
air quality problems (benzene and ozone) for which there exist Community air quality standards and objectives. Ground le vel ozone is a pollutant wh ich crosses national borders 
and is also the third most important greenhous e gas. Benzene is a human carcinogen with no 
known safe threshold. 
Air pollution problems with a transboundary dimension like ozone must be tackled 
collectively by the Member States together in or der for action to be effective. The current air 
quality objective for ground level ozone in Co mmunity law is widely exceeded and such 
execeedences are very likely to persist despit e the emission reductions of ozone precursor 
gases in the national emissions ceilings direc tive 2001/81/EC and the aims of the Thematic 
Strategy on Air Pollution. 
The proposal has been prepared following commitments made by the Commission in: 
– the Thematic Strategy on Air Pollution
1;  
– the Commission's proposal to amend Directiv e 98/70/EC on petrol and diesel quality2 
which aims to facilitate a greater uptake of biofuels (and bioethanol in particular) by 
relaxing the vapour pressure requirements of petrol. The fuel quality directive is based 
upon Article 95 of the Treaty a nd its specifications apply uniformly across the EU. The 
Commission recognised that any relaxation of vapour pressure li mits could lead to greater 
emissions of volatile organic compounds from refuelling and evaporative emissions from 
vehicles' fuel systems even in countries wher e Stage II petrol vapour recovery is already 
implemented. As such, the Commission indicated that recovery of petrol vapour during the 
refuelling of cars would be proposed to offset  the increased emissions of volatile organic 
compounds across the EU. 
– a statement accompanying the adoption at second  reading of a new directive on ambient air 
quality3 in which (i) the Commission recognised th e importance of tackling air pollution at 
source in order to improve air quality; and ( ii) signalled several new Community source-
based measures including recovery of petrol vapour at service stations. 
The analysis of impacts draws upon information from two separate consultancy reports from 
ENTEC and COWI4 as well recent regulatory impact assessments accompanying national 
measures on Stage II petrol vapour recovery. The assessment has investigated the costs, costs effectiveness and benefits of introducing Stage II controls in a consistent manner across the 
EU whilst being consistent with existing Comm unity legislation on Stage I petrol vapour 
recovery (covering the storage a nd distribution of petrol from terminals to service stations) 
and recognising the fact that ove r half of the Member States already have national Stage II 
                                                
 
1 Section 4.2.1.2 on page 9 of COM(2005) 446 of 21 September 2005. 
2 Section 3(4) on pages 7 & 8 of COM(2007) 18 of 31 January 2007. 
3 Directive 2008/50/EC on ambient air quality and cleaner air for Europe, OJ L152, 11.6.2008, p. 1 – 43. 
4 http://ec.europa.eu/environment/air/transport/petrol.htm   
 
EN 3   EN PVR measures in place. Stage II PVR is also a re quirement of an intern ational protocol that 
the Community has signed but not ratified. 
Several options have been c onsidered including "conventional" petrol  vapour recovery 
systems which capture escaping petrol vapour vi a a vacuum pump and redirect it to the 
underground storage tanks at serv ice stations. This vapour is ul timately returned to the oil 
refinery when the service station's underground tanks are themselves replenished. A newer "at 
pump" Stage II PVR system has also been analysed which captures escaping vapour, cools it and recycles it directly to the dispenser where it  is re-dispensed as liquid petrol. This latter 
system does not require any refurbishment of unde rground tanks or pipewo rk and so is less 
disruptive to the service sta tion operator particularly wher e an unscheduled retrofit is 
necessary. 
The costs of installing Stage II have been calc ulated taking into account,  numbers of stations, 
the size of stations, the cost of Stage II equi pment (and its installatio n cost), the economic 
lifetime of the equipment and the economic valu e of the recovered petrol vapour excluding 
tax. Only those costs directly associated with Stage II PVR have been considered (i.e. which 
go beyond a normal new build or refurbishment and that would in any event require new fuel 
dispensing equipment). The bene fits of reduced emissions have  been estimated using simple 
damage costs per tonne of petrol vapour emitte d and take into account the impacts of ozone 
on health and crops but ignore the impacts of ozone on the natural environment and benzene 
on health. 
The Policy options considered are: (1) Do nothing. 
(2) Install Onboard Refuelling Vapour Recovery  (ORVR) in passenger cars and light 
commercial vehicles. 
(3) Install PVR Stage II equipment at  
(a) All new and substantially refurbished se rvice stations with  a throughput greater 
than 500 m
3 of petrol per annum. 
(b) At all new and substantially refurbis hed service stations  with a throughput 
greater than 500 m3 of petrol per annum and larger  existing stations (i.e. with a 
throughput in excess of 3000 m3 per annum). 
(c) Option (b) together with service stations situated  in or under residential 
accommodation irrespective of size 
(d) Automatic monitoring of all stage II equipm ent that would restrict petrol sales 
if the equipment is not functioning correc tly (to be applied in conjunction with 
all above options). 
Options (1) and (2) were discarded at an early stage, whilst 3(c) represents the preferred 
option. Option 3(d) was rejected because of th e uncertainty over costs and adverse impact on 
cost-effectiveness particularly as  other cheaper means may be av ailable to guarantee reliable 
in-service operation of Stage II PVR equipment. 
 
EN 4   EN The table below presents a summary of the cost s and cost-effectiveness of the various options 
where this is possible. 
Cost effectiveness 
(€/tonne) Option Total cost 
€m Emissions 
abated 
(tonnes) 
Excluding 
recovered 
petrol Including 
retail value 
of recovered 
petrol Annualised Costs*  
[& benefits ] in 2020 
€m 
3a (At pump) 179.5 12 141 1540 915 11.1 [ 11.5-34.0 ] 
3a (Conventional) 209.5 12 141 1760 1140 13.8[ 11.5-34.0 ] 
3b (At pump) 317.4 17 769 1798 1171 20.8 [ 16.9-49.7 ] 
3b (conventional) 389 17 769 2160 1533 27.2 [ 16.9-49.7 ] 
3c (At pump) not calc. not calc.  Est. 1500 Est. 960 not calc. 
3c (conventional) not calc. not calc. Est. 1890 Est. 1340 not calc. 
3d Limited information available 
a – Stage II controls at new and subst antially refurbished service stations 
b – option (a) plus existing stations  with throughput greater than 3000 m3 per annum by 2020 
c – option (b) plus all stations situated in re sidential accommodation irre spective of size/throughput 
d – option (c) plus installation of  automatic monitoring equipment 
*-includes economic value of the recovered petrol (retail price) 
Limited information exists on the numbers of serv ice stations situated under residential 
accommodation so it is not possible to calculat e the total costs etc. However, the cost 
implications for a small service st ation with a thr oughput of around 500 m3 have been 
estimated and the costs and cost effectiveness for a scheduled refurbishment are similar to the average figures associated with  options 3(a) and 3(b) above. 
The total costs and annualised costs in 2020 (between €20-30m) annually are modest. The 
cost effectiveness compares favourably with ot her available measures to reduce emissions of 
volatile organic compounds. 
The Commission invited key stakeholders to res pond directly to a series of questions about 
the possible introduction of Stage II PVR on 28 February. This invitati on was also posted to 
the Europa web site so that the general public  could also be consu lted. The consultation was 
also publicised by "ENDS Daily" on 17 Marc h 2008. Sixteen responses were received 
spanning Member State regions, environmental agencies, NGOs, equipment suppliers, service 
station operators, oil industry associations a nd vehicle manufacturers. A summary of these 
responses is available on line
5. The responses spanned issues on health impacts of petrol 
vapour, the efficiency of Stage II equipment, the merits of automatic monitoring equipment 
and the cost effectiveness of the various opti ons for installing stage II PVR equipment. These 
responses have been taken directly into account in drafting the key elements of the 
accompanying proposal notably in relation to service stations under residential 
                                                 
5 http://ec.europa.eu/environment/air/transport/petrol.htm   
 
EN 5   EN accommodation, the lower cut-off for affected serv ice stations and the automatic monitoring 
of in-service performance of equipment.