EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 4.12.2008 
SEC(2008) 2937 
  
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  
 
Impact Assessment 
  
{COM(2008) 812 final} 
{SEC(2008) 2938} 
 
EN 2   EN 1. PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES  
1.1. Introduction & context 
This impact assessment accompanies a legislative proposal that would, if adopted by 
the Council and European Parliament, bri ng about a more complete application of 
controls in the EU to reduce the amount of petrol vapour emitted during the refuelling of cars at service stations.  
The proposal has been prepared followi ng commitments made by the Commission 
in: 
– the Thematic Strategy on Air Pollution
1;  
– the Commission's proposal to amend Dire ctive 98/70/EC on petrol and diesel 
quality2 which aims to facilitate a greater uptake of biofuels and bioethanol in 
particular by relaxing th e vapour pressure requir ements of petrol. The 
Commission recognised that this could lead to grea ter emissions of volatile 
organic compounds and indicated that r ecovery of petrol vapour during the 
refuelling of cars would be proposed in or der to offset these additional emissions. 
– a statement accompanying the adoption at second reading of a new directive on 
ambient air quality3 in which (i) the Commission recognised the importance of 
tackling air pollution at source in order to  improve air quality; and (ii) signalled 
several new Community source-based meas ures including recovery of petrol 
vapour at service stations. 
The proposal is listed in the Commission Legislative Work Programme for 2008 with 
reference 2008/ENV/006. The preparation of th e impact assessment was assisted by 
an interservice group created on 14 November 2007 to which all DGs were invited to participate. 
1.2. Consultation 
Consultation of interested  parties was undertaken by di rect written request for 
information from identified parties and also  by a wider internet based invitation. The 
period of consultation was open for 8 weeks ending on 25 April 2008. 
– The Commission invited key stakeholders to respond directly to a series of 
questions about the possibl e introduction of Stage II PVR on 28 February. This 
invitation was also posted to the Europa web site so th at the general public could 
also be consulted. The consultation wa s also publicised by "ENDS Daily" on 17 
March 2008. Sixteen responses were rece ived spanning Member State regions, 
environmental agencies, NGOs, equipment s uppliers, service station operators, oil 
                                                
 
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. 
 
EN 3   EN industry associations and ve hicle manufacturers. A summar y of these responses is 
available on line4. 
– Those involved in the manufacture and supply of Stage II equipment supported 
the introduction of harmonised specificati ons as did environmental agencies and 
NGOs. Independent petrol reta ilers expressed the view th at Member States should 
be allowed to decide for themselves whet her to proceed with Stage II PVR. Those 
who supported Stage II PVR preferred an a pproach that tackle d existing stations 
progressively so that the larger stations were tackled first as this was more cost 
effective. Whilst the independent petrol retailers denied any link between benzene 
exposure (via petrol vapour) and advers e health impacts (leukaemia), the 
mainstream European downstream oil i ndustry supported the view that service 
stations built under residential accommoda tion presented the greatest potential 
risk and that these stations should be asse ssed for their suitabil ity to install Stage 
II controls irrespectiv e of their throughput. 
This impact assessment has relied heavily  upon two consultancy reports completed 
on behalf of the European Commission by ENTEC UK Limited5 and COWI6 as well 
as public consultation documents/regulat ory impact assessments published in the 
UK7 and Western Australia8 in addition to information from the open literature. 
1.3. Impact Assessment Board 
The draft impact assessment was submitted to the Impact Assessment Board for its 
opinion. The Board raised three main issues for which it asked for clarification in the draft text. These are: 
– An enhanced explanation as to why EU  action was appropriate and necessary; 
– Clarification of certain methodological as pects including a treatment of taxation, 
assumptions used; 
– Clarification of the combinations of opti ons particularly in relation to automatic 
monitoring of petr ol vapour recovery equipment and in-service compliance and 
also further explain comparisons to  vehicular measures in the USA. 
                                                
 
4 http://ec.europa.eu/environment/air/transport/petrol.htm   
5 Stage II Petrol Vapour Recovery – Final Report from contract 070501/2004/379928/MAR/C1, prepared 
by ENTEC UK Limited on behalf of the European Commission, 17 May 2005. http://ec.europa.eu/environment/air/pdf/entec_report.pdf
  
6 Analysis of costs associated with the mandatory deployment of Stage 2 Petrol Vapour Recovery, Final 
report from contract 070307/2007469854/FRA/C3, prepared by COWI on behalf of the European Commission, February 2008. http://ec.europa.eu/environment/air/p df/cowi_report_stage2_feb08.pdf
  
7 Final Regulatory Impact Assessment on Petrol Vapour Recovery stage II controls (PVR II), Air and 
Environment Quality Division, Department for Envi ronment, Food and Rural Affairs, November 2005. 
http://circa.europa.eu/Members/irc/env/stage2 /library?l=/background_documents/pvrstage2-
riapdf/_EN_1.0_&a=d   
8 Discussion Paper: Action for Air – Improving air quality through vapour recovery at service stations , 
Department of Environment & Climate Change NSW, August 2007. 
http://circa.europa.eu/Members/irc/env/st age2/library?l=/background_documents/aus-
nsw_vapourrecovery/_EN_1.0_&a=d   
 
EN 4   EN The draft text has been amended in seve ral areas to take account of the Board's 
opinion, notably in sections 1.1 ( Introduction & context ); 2.4 ( Subsidiarity & 
proportionality ); 4 ( Policy options ); 4.1.2 ( Option 2 – ORVR ) and 5.1 ( Assumptions 
& methodology to estimate costs for Stage II PVR costs ). 
2. PROBLEM CHARACTERIZATION AND BASELINE  
Volatile Organic Compounds (VOCs) are carbon-based chemicals which evaporate 
readily into the atmosphere. Once emitted in to the air, they are associated with 
several health and environmental problems: 
– poor local air quality (benzene in air); 
– formation of ozone and photochemical smog; and 
– atmospheric warming and climate change. 
Various Community instruments have been  developed and implemented to limit 
VOC emissions. For example, national limits apply on Member States' total emissions of VOCs as embodied in directive 2001/81/EC on national emissions ceilings
9. There is also legislation to reduce the emissions of VOCs from the use of 
solvents in industrial installations10 and to reduce the use of solvents in paints and 
varnishes11, to limit the benzene content of petrol (1% v/v)12 and to restrict the 
emissions of hydrocarbons from road vehicles13. 
Despite these measures, the impacts of air pollution as assessed by the Thematic 
Strategy are still significant and the l ong term objectives fo r health and the 
environment, as established in the 6th Environmental Action Programme and the 
national emissions ceilings directive 2001/81/ EC, will not be attain ed on the basis of 
current policies even by 2020. The Strate gy proposed several measures to help 
deliver further progress towards the long term objectives including additional controls on the refuelling of pe trol cars at service stations. 
Petrol vapour emitted during the refuelling of passenger cars is currently unregulated 
at the Community level although a significant number of Member States have Stage 
II PVR controls in place. These national re gulations vary in sc ope particularly in 
terms of the minimum size of petrol sta tion captured, the require d vapour collection 
efficiency and the post-installation compliance regime. 
                                                
 
9 Directive 2001/81/EC on national emission ceilings for certain atmospheric pollutants: OJ L 309, 
27.11.2001, p.22. 
10 Directive 1999/13/EC on the limitation of emissions of volatile organic compounds due to the use of 
organic solvents in certain activities and installations: OJ L 85, 29.3.199, p. 1. 
11 Directive 2004/42/EC on the limitation of emissions of volatile organic compounds due to the use of 
organic solvents in certain activities and installations: OJ L 143, 30.4.2004, p. 87. 
12 Directive 98/70/EC relating to the quality of petrol and diesel fuels: OJ L 350, 28.12.1998, p. 58. 
13 Regulation (EC) N° 715/2007 on the type approval of motor vehicles with respect to emissions from 
light passenger and commercial vehicles (Euro 5 & Euro 6) and on access to vehicle repair and 
maintenance information, OJ L 171, 29.6.2007, p. 1. 
 
EN 5   EN Since the Thematic Strategy was adopted, the College has also decided to facilitate a 
greater take-up of biofuels such as bioe thanol in the road transport sector. The 
Commission acknowledged, howev er, that the blending of some bio-components into 
petrol can lead to greater emissions of VOCs unless compensating measures are 
undertaken such as Stage II PVR2. Any controls on petrol refuelling must, however, 
be compatible with the existing Community legislation which regulates the VOC emissions associated with the storage and distribution of petrol from terminals to service stations (so-called "S tage I petrol vapour recovery")
14. 
2.1. Health & environmental problems 
2.1.1.  Benzene in ambient air 
Benzene is a VOC and a component of pe trol. It is also a known human genotoxic 
carcinogen and is associated with a heighten ed risk of illnesses such as leukaemia. A 
Community air quality sta ndard exists for the pr otection of public health15 but there 
is no known safe level of exposure. Huma n exposure comes mainly from tobacco 
smoke, petrol vapour and from vehicle exhaust emissions. The air quality limit value for benzene is expressed as an a nnual average concen tration of 5µg/m
3 that must be 
met by 1 January 2010.  
Given the restrictions on the benzene content of petrol and stricter exhaust limits for 
road vehicles, there has been an observed decrease in ambient levels of benzene. Moreover, it is likely that most places w ill comply with the ai r quality limit value by 
2010. However, there may remain problems at heavily trafficked locations and residential areas in the immediate vici nity of petrol service stations.  
A recent study from Western Australia undertook personalised monitoring of 
peoples' exposure to benzene. It showed  that time spent commuting and vehicle 
refuelling represent the highest non-industr ial exposure to ben zene in non-smokers. 
Vehicle refuelling comprised between 75-85 % of total exposure in the winter and 
summer respectively
16 even though the benzene conten t of petrol is only 1% by 
volume (as in the EU) and i ndividuals were assumed only to spend a few minutes 
refuelling their vehicles. Similar conclusions  have been reached in European studies 
where individuals had similar time/activit y diaries and where individuals spent 
approximately 60% of their time indoors at home17.  
The French petroleum indus tries association reporte d in 2006 on a wide-ranging 
measurement campaign of benzene concentr ations at and around 43 service stations 
in France18. For those service stations constr ucted under apartment buildings, the 
                                                 
14 Directive 94/63/EC on the control of volatile or ganic compound (VOC) emi ssions resulting from the 
storage of petrol and its distribution from terminals to service stations: OJ L365, 31.12.1994, p. 24. 
15 Directive 2000/69/EC relating to limit values for benzene and carbon monoxide in ambient air: OJ L 
313, 13.12.2000, p. 12. 
16 A. Horton et al; Personal monitoring of benzene in Perth, Western Australia: The contribution of 
sources to non-industrial personal exposure ; Atmospheric Environment 40 (2006) p. 2596-2606. 
17 R. Edwards, M. Jantunen, Benzene exposure in Helsinki, Finland . Atmospheric Environment 35(8) 
2001 p. 1411-1420 (part of the EXPOLIS project). 
18 L'Union Française des Industries Pétrolières publie  une étude relative au bezèn e mesuré en périphérie 
des stations services à la demande du Ministère de l'Ecologie et du Développement Durable. March 
2006, www.ufip.fr/_fichiers/03_04_2006_%20resume_etude_Bz_limite_prop_stations.pdf   
 
EN 6   EN observed concentrations at the petrol dispenser were in the range 10 – 85.7 µg/m3 
(with an average of 31.3 µg/m3), whilst those at the perimeter of the service station 
lay in the range 2 – 30.8 µg/m3 (average equal to 8.2 µg/m3). Similar measurements 
made in Malta19 and Greece20 also showed that concentrations of benzene can be 7 
to10 times the limit value of 5 µg/m3 at service stations.  
Whilst current policies and improved emissions  performance of the vehicle fleet may 
ensure compliance with the benzene air qua lity limit at most places, there are likely 
to be elevated concentrations in the immedi ate vicinity of service stations. This is 
problematic where residential accommodation is  co-located or is situated in close 
proximity to these stations. In California, where most service stations are fitted with 
controls to limit petrol vapour emissions  during refuelling, the Air Resources Board 
and the Environmental Protection Agency  advise against locating residential 
accommodation within approximately 90 metres of a service station21. 
2.1.2.  Ozone 
Once released into the atmosphere VOCs react in the presence of sunlight with 
nitrogen oxides emitted from combustion pr ocesses to form ground level ozone and 
other components of photochemical smog. Ozone  is a transboundary pollutant so that 
precursors emitted in one country are disper sed and transported in the atmosphere 
and contribute to the observed ozone in other Member States. Short-term studies 
show that ozone has adverse effects on pulmonary function, lung inflammation, lung 
permeability, respiratory symptoms, increased medication usage, morbidity and mortality. There are Community air quality targets
22 to protect against exposure to 
ozone.  
The World Health Organisation recomm ends a daily maximum 8-hour mean 
concentration as the principal benchmark for assessing the impact on mortality, with 
assessment over a full year. Current evidence is  insufficient to derive a level for this 
8-hour mean below which ozone has no e ffect on mortality. The ozone directive 
established a target valu e for the protection of human health of 120 µg/m3 as a daily 
maximum concentration measured over an 8-hour period which is not to be exceeded more than 25 times per calendar year. Member States are obliged to comply as far as possible with this target. 
The European Environment Agency undertakes  periodic reviews of air quality based 
upon air quality monitoring data collected and reported to the Commission and the 
EEA
23. Although reductions in emissions of oz one precursors appear to have led to 
lower peak concentrations of  ozone in the troposphere, th e current target level is 
frequently exceeded for a substantial part  of the urban populati on of the EEA-32. In 
                                                 
19 M. Zamitt and A.J. Vella; Influence of service stations on air quality ; Xjenza 2003, vol. 8, p. 3. 
20 P. Spyros et al; Contribution to ambient benzene concentrations in the vicinity of petrol stations: 
estimation of the associated health risk ; Atmospheric Environment 41 (2007) p. 1889-1902. 
21 Air Quality and Land Use Handbook: A community health perspective; California Environmental 
Protection Agency & California Air Resources Board, 2005, p. 30. 
(http://www.arb.ca.gov/ch/landuse.htm )  
22 Directive 2002/3/EC relating to ozone in ambient air: OJ L 67, 9.3.2002, p. 14. 
23 Air Pollution in Europe 1990-2004, Steinar Larssen et al, European Environment Agency, Copenhagen 
2007. 
 
EN 7   EN 2004, 94% of the urban population experienced exceedances of the 120 µg/m3 level 
(the long-term objective for protection of human health),  while about 20% of the 
urban population was exposed to concentrations above the 120 µg/m3 level for more 
than 25 days. The target level was exceed ed over a wide area and by a large margin. 
Several studies have shown that ozone p eak values have tended to decrease during 
the first half of the nineties. However, available data available over the period 1996-
2001 shows hardly any variation for the 26th highest maximum daily 8-hour mean. 
Ozone concentrations in 2004 were reported by 1886 stations  across 32 countries and 
when, in accordance with the ozone direct ive, concentrations are averaged over 3 
years it is clear that the ta rget value was not met in larg e parts of continental Europe 
(see Fig 1).  
0 days
0- 25 days
25- 50 days
> 50 days
source: ETC/A CC- AIRBASE                                                                                              June -2006ozone
exceedance days (>120 µg/m3)
2002-2004
all stations, data coverage > 75%
 
Figure 1: Days exceeding the target value as 3- year average 2002-4. In  2004 urban/suburban 
background areas provided 44% of  stations, rural background ar eas 24%, traffic sites 18%, 
9%, industrial, and 5% not pr operly classified. [Reproduced by permission of the European 
Environment Agency] 
The reductions in ozone precur sor emissions that should re sult from enforcement of 
the national emissions ceilings directive 2001/81/EC and international agreements 
are unlikely to reduce ozone concentrations  to below the current target value and 
long-term objective over the whole of the EEA area. In north-west Europe about 25 
exceedance days of the 120 µg/m3 level are still expected in 2010. 
2.1.3.  Ozone as a greenhouse gas 
The calculated global mean radiative fo rcing of ground level ozone since 1750 is 
+0.35 Wm-2 and ozone is the third most im portant greenhouse gas after carbon 
 
EN 8   EN dioxide (+1.66 Wm-2) and methane (+0.48 Wm-2)24. Although ozone precursor 
emissions are not directly controlled  under the UNFCCC and the Kyoto Protocol, 
Parties must report on their emissi ons of VOCs, NOx and carbon monoxide. 
2.2. Mixtures of ethanol and petrol 
The vapour pressure of a part icular liquid VOC is a measur e of how easily molecules 
evaporate and reflects the type and strength of the intermolecular interactions. Where 
chemically very different compounds are mixed, the intermolecular forces of the 
pure liquids are disrupted and there is an  increased tendency for molecules in the 
mixture to evaporate. This is calle d a positive deviation from Raoult's law25 and is 
observed when ethanol is mixed with petrol. In fact, the increase in vapour pressure 
is roughly constant at ~ 7 kP a for ethanol contents in pe trol of between 2% and 10% 
by volume26. This compares to the current legislated limit of 60 kPa for the Summer 
time vapour pressure of petrol sold in the EU. 
An increased vapour pressure of petrol will increase the emi ssions of hydrocarbons 
during refuelling but it will also increase th e evaporative emissions whilst the vehicle 
is at rest (so called "diurnal" emissions)  and those whilst the vehicle is moving (so 
called "running losses"). These emissions derive from fuel permeation through the 
plastic and rubber components of the fuel system and breathing losses where petrol 
vapour is vented from the tank as a function of temperature. Diurnal emissions are captured by the European type approval procedure for passenger cars and light 
commercial vehicles whilst "running losses" are currently unregulated. Both increase 
as a function of fuel volatility.  
2.3. The baseline 
2.3.1.  PVR Stage I 
Petrol is a complex mixtur e of hydrocarbons some of which evaporate at ambient 
temperatures. When petrol is stored at terminals or in underground storage tanks at 
service stations, petrol vapour fills the h ead space above the li quid. Petrol vapour is 
displaced when additional liquid is added to  the storage tank. Without any technical 
intervention, this displaced vapour would be vented directly to the atmosphere. 
The Stage I PVR directive 94/63/EC addresses both the storage of petrol at terminals 
and its distribution by road, rail and inland waterway vessel to service stations. When 
service stations are refuelled by tanke r, the vapour that is displaced from 
underground storage tanks is returned to the tanker which in turn delivers the petrol 
vapour back to the refinery or terminal wher e it can be re-incorporated into the petrol 
pool and re-supplied to service station operators. Stage I PVR requires certain 
                                                
 
24 P. Forster , V. Ramaswamy, P. Artaxo, T. Bernsten , R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. 
Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland, 2007: Changes in Atmospheric Constituents and in Radiative Forcing. In: Climate Change 2007: The Physical Science 
Basis. Contribution of Working group I to the Fourth Assessment Report of the Intergovernmental 
Panel on Climate Change . Cambridge University Press, Cambridge, United Kingdom & New York. 
25 Basic Physical Chemistry , Walter J. Moore, Prentice Hall In ternational, London 1983, pp 213 
26 Joint EUCAR/JRC/CONCAWE Study on: Effects of gasoline vapour pressure and ethanol content on 
evaporative emissions from modern cars, edited by G. Martini, JRC 2007 (ISBN 978-92-79-05249-1). 
 
EN 9   EN underground pipe work to be installed in or der that vapour can be returned safely to 
the tanker.  
The smallest petrol service stations with a volumetric th roughput of petrol of less 
than 100 cubic metres (m3) per annum are exempt from the directive's provisions. 
Moreover, Member States may also deroga te stations with a throughput less than 500 
cubic meters per annum so long as there are no adverse health and environmental 
impacts. However, all service stations, rega rdless of throughput, must install Stage I 
PVR equipment if they are located under perm anent living quarters or working areas. 
Any Stage II PVR legislation must be cons istent with the Stage I PVR directive as 
both will apply to the construction and operation of service stations. 
2.3.2.  Refuelling emissions 
The total EU inventory of VOC emissi ons comprises many diverse sources and 
economic sectors unlike that of other pollu tants such as sulphur dioxide which is 
emitted primarily by the power generation sector. As such, a strategy to reduce significantly overall VOC emissions must necessarily tackle many small sources.  
Petrol vapour will occupy the head space in a car's petrol tank so that when the car 
refuels, petrol vapour is di splaced and without any furthe r intervention this vapour is 
vented to the atmosphere. Spillages and drips from the filler nozzle will also evaporate. Overall emissions of VOC associ ated with petrol re fuelling operations can 
be estimated on a country basis and these will depend upon the vapour pressure of 
the fuel, the ambient temperature, the amount  of petrol sold each year and whether 
controls are in operation to limit these emissions. Changes in ambient temperature and vapour pressure can ha ve a significant impact
27. In May 2005, ENTEC estimated 
that emissions for the EU27 plus Croatia in  2010 for vehicle refu elling and spillage 
would be 87.2 ktonnes and 10.4 ktonnes respec tively which represent about 1% of 
total emissions of anthropogenic emissions  in 2005. An increase in the regulated 
vapour pressure from 60 kPa to 70 kPa would increase these emissions to 90.5 and 
10.8 ktonnes respectively. 
2.3.3.  Service stations 
There are some 110,000 service stations in  the EU with a co mbined turnover of 
approximately €250 billion and which employ 440,000 people28. In response to 
competition and static margins the sector continues to restructure towards larger and/or unmanned service stations. For example,  over the last fifteen  years gross retail 
margins on petrol sold in the UK have been in the range € 5.5 – 7 cents per litre and 
the UK has witnessed the closure of about ha lf of the 18,000 stati ons that existed in 
1992
29. Similarly, Denmark has seen a reductio n in the number of smaller stations so 
that in 1990, 22% of all petr ol was sold in stations w ith a petrol throughput of 500m3 
per annum or less whilst in 2003, such stations  accounted for just 8% of petrol sold. 
The number of service stations in each Me mber State is presented in Annex II. 
                                                 
27 See Figure 5.1 of the ENTEC report 
28 European Council for Motor Trades & Repairs. http://www.cecra.eu/e n/about/about.php   
29 Understanding Pump Prices , UK Petroleum Industries Association, June 2007. www.ukpia.com   
 
EN 10   EN Based upon information provided by the Eu ropean oil industry, ENTEC has derived 
a size breakdown of service stations in  the EU (see Annex II). In many Member 
States, over 85-90% of stations have an annual throughput of petrol greater than 
500m3, whilst the average acro ss the EU is about 75%. 
2.3.4.  Types of Stage II PVR Controls employed 
Passive and active technical solutions have  been developed to reduce the emissions 
of petrol vapour during refuelling. Both ex ist on the market today but the passive 
system has vastly inferior vapour recovery  performance and so is not discussed any 
further. There are two active systems: 
(1) A Conventional  system employs a petrol pump filler nozzle consisting of two 
concentric steel tubes, the outer one of which is kept under vacuum using a 
vacuum pump. Displaced vapour is activ ely "sucked" back into the outer 
nozzle and is transferred to the underground storag e tanks of the service 
station. When a service station receives a fresh delivery of petrol, the vapour 
contained and displaced from the sta tion's underground storage tanks is 
captured and stored in the road tanker. It is then returned to the oil refinery or 
terminal where it can be incorporated in to subsequent loads.  The key aspect is 
that petrol vapour that otherwise is di splaced and lost from the vehicle is 
returned "free of charge" to the refinery or terminal where it can be resold. 
However, if the station is not equipped with VOC Stage I c ontrols, the vapour 
displaced from underground storage tanks is  vented to the atmosphere and the 
vapour displaced from the vehicle has no economic value. 
(2) The At Pump  system is different in that the captured vapour displaced from 
the vehicle's tank is collected, cooled a nd condensed into liquid petrol at the 
petrol dispenser. The liquid petrol is th en delivered back to the car's petrol 
tank as part of the ongoing purchase. Th is active system does not require any 
additional underground pipe work at the service station and permits the station operator to resell the petrol va pour otherwise lost to the atmosphere. 
(3) Onboard refuelling vapour recovery  (ORVR) is an emission control system 
that is placed on board a vehicle. Pe trol vapour that is displaced during 
refuelling is directed to wards a large canister c ontaining activated carbon 
where it is absorbed and prevented from  being vented to the atmosphere. The 
absorbed vapour is subsequently fed to the engine and combusted. ORVR 
systems have been mandated in the USA for vehicles manufactured from 
about 1998 onwards. However, in the interim period before all vehicles are fitted with the ORVR equipment, States  will continue to apply Stage II PVR 
controls at service stati ons. This system is not part of the regulatory type 
approval regime for vehicles in the European Union. 
2.3.5.  National Stage II PVR legislation 
Sixteen Member States have already inst alled conventional Stage II controls at 
service stations in various forms (see A nnex I). The Community has signed but not 
 
EN 11   EN ratified the VOC Protocol of the UN ECE Convention on Long Range 
Transboundary Air Pollution (CLRTAP)30. Article 3(b)(ii) of th is Protocol requires 
the parties to implement VOC controls during motor vehicle refuelling. So far, 20 Member States have signed and ratified this  protocol whilst a fu rther 7 have signed 
but not yet ratified. Interes tingly, Spain, Bulgaria, Estoni a and Finland have ratified 
but have not implemented Stage II PVR cont rols nationally. This information is also 
summarised in Annex I. 
2.4. Subsidiarity & proportionality 
Ozone is a transboundary pollutant which together with its precursors can be 
transported over many hundreds of kilometr es in the atmosphere. Air pollution 
problems with such a trans boundary dimension must be ta ckled collectively by the 
Member States together in order for action to be effective. The current air quality objective for ground level ozone in Community law is widely exceeded and such execeedences are very likely to persist de spite the emission reductions of ozone 
precursor gases in the national emissions ceilings directive 2001/81/EC and the aims 
of the Thematic Strategy on Air Pollution. 
The directive governing the minimum quality of petrol and diesel sold in the EU is 
based upon Article 95 of the Treaty an d applies uniformly across the EU. The 
Commission has proposed a relaxation of th e vapour pressure requirements of petrol 
in order to promote a greater use of bioethanol
2. This could however lead to greater 
emissions of volatile organic compounds ev en in those countries  where Stage II PVR 
controls are already implemented. As suc h, Community action is required to address 
this potential increase in VOC emissions  due to its large geographical scope. 
In addition, those manufacturing Stage II equipment and those using it have 
expressed a preference for harmonising te chnical specifications to improve the 
functioning of the internal ma rket in such goods. Action is therefore necessary at the 
Community level. However, only minimu m generic parameters need to be 
established at the Community level so as to overcome the observed obstacles, whilst respecting the varied systems that Member States have already implemented and not 
stifling new innovative technologies. Th e most important parameters are the 
operational efficiency of vapour recove ry and the in-service reliability. 
3. O
BJECTIVES  
3.1. 6th Environmental Action Programme – General Objective 
A general aim of the proposed measures on Stage II PVR are to enable further 
progress to be made towards the attainment of the 6th EAP objectives on air quality 
and air pollution. 
The 6th Environmental Action Programme called for the attainment of air quality 
levels that do not give rise to signifi cant negative impacts on or risks for human 
                                                 
30 Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution concerning the control of 
emissions of volatile organic compounds or their transboundary fluxes which entered into force on 28 
September 2002. 
 
EN 12   EN health and the environment31. It is also called for a thematic strategy on air pollution 
with a view to attaining l ong term objectives of no-exceed ence of critical loads and 
levels for ecosystems and measures to tackle ground level ozone and particulates32. 
Ozone is a priority pollutant that was addressed by the thematic strategy and previously by the national emissions ceilings  directive. The analysis undertaken for 
the strategy concluded that: 
– there are approximately 21,000 cases a nnually of acute mortality and 14,000 
respiratory hospital admissions in the 65+ age group; 
– there are 21 million days where children and almost 9 million days when adults 
use respiratory medication 
– there are 108 million days when children exhibit cough and lower respiratory 
symptoms 
– there are over 50 million days when adults' activity is restricted 
– 827000 km
2 of forest was at risk from damage 
– that damage to commercial crops amount ed to approximately €2.8 billion annually 
in 2000. 
The Thematic Strategy also proposed new ta rgets to improve protection from ozone 
but these fell short of the aspirations of the 6th EAP and the long term objectives of 
the national emissions ceilings directive.  
3.2. Specific objectives of the present proposal 
The proposed Stage II PVR controls also aim: 
– to assist the Member States in their obliga tion to attain air quality limit values for 
benzene as stipulated in Community law 
– to assist Member States in their obligation to attain as  far as possible air quality 
targets for ground level ozone; and 
4. POLICY OPTIONS  
Policy options are: 
(1) Do nothing. 
(2) Install Onboard Refuelling Vapour Rec overy (ORVR) in passenger cars and 
light commercial vehicles. 
(3) Install PVR Stage II equipment at  
                                                 
31 Article 7(1) of Decision N° 1600/2002/EC of the The European Parliament and of the Council laying 
down a the Sixth Community Environmental Action Programme. OJ L 242, 10.9.2002, p. 1. 
32 Article 7(2)(f) of the Sixth Environmental Action Programme. 
 
EN 13   EN (a) All new and substantially refurb ished service stations with a 
throughput greater than 500 m3 of petrol per annum. 
(b) Option (a) and larger existing stations  (i.e. with a throughput in excess 
of 3000 m3 per annum) by end of 2020 
(c) Option (b) and service stations s ituated in or under residential 
accommodation. 
(d) Automatic monitoring of all stage II equipment that would restrict 
petrol sales if the equipment is no t functioning correctly (to be applied 
in conjunction with all above options). 
4.1. Options discarded at an early stage 
4.1.1.  1 – Do Nothing 
Target values and long term objectives for the concentration of ozone in ambient air 
exist in Community legislation but are widely exceeded in the European Union. Ozone is a particularly difficult pollutant  to tackle given that it is formed in situ  in 
the atmosphere and that its precursors and ozone itself are trans ported across national 
borders. The Commission has also recogni sed the potential worsening of ozone 
pollution from increased emissions of VOCs due to an increased  use of biofuels. 
Some of those Member States  with significant ozone problems have yet to introduce 
Stage II whilst others have not implemente d commitments made internationally to do 
so. It is also likely that there will be exceedences of the benzene air quality limit 
value in the vicinity of service stations when the air quality limit value for benzene 
enters into force in 2010 (with possible delay until 2015). Given this, and the fact some equipment suppliers and users have pointed to the expected benefits of 
harmonised minimum technical standards for the functioning of the internal market, 
the "Do Nothing" option is not realistic. 
4.1.2.  Option 2 – ORVR 
There are several key issues associated with On-board Refuelling Vapour Recovery 
that must be assessed when consider ing this as a serious policy option: 
(1) Adaptation of vehicle design. 
Light duty petrol vehicles  manufactured for the European market contain a small  
carbon canister to prevent emissi ons of petrol vapour whilst th e vehicle stands at rest 
(so called "diurnal" emissions). These va pours are absorbed into the canister and 
released to the engine when the vehicle is underway. ORVR systems require a larger  
canister than currently installed in Europ ean cars as well as appropriate piping, 
valves and vapour controls systems. Natu rally, the design of European vehicles 
would have to be adapted if  this option was chosen which would require a change to 
European type-approval legislation. Howe ver, no detailed study has been undertaken 
to assess the technical feasibility and costs of such systems particularly for smaller 
cars where space constraints are important. 
(2) Timescale 
 
EN 14   EN Any introduction of ORVR systems could onl y be applied to new vehicles. It would 
not be possible to retrofit/re-engineer th e vapour systems of existing vehicles. As 
such, the effectiveness of any ORVR syst em would depend upon the rate that new 
ORVR-equipped vehicles entered the fl eet. If one considers that vehicle 
manufacturers require 3 to 5 years lead time to redesign vehicle systems and that the 
a further 15 years is required for vehicle fl eet renewal, then the full benefit of the 
ORVR system can only be delivered some  20 years after any new regulation is 
adopted. 
(3) Costs & performance 
No detailed analysis of ORVR costs has b een undertaken for this impact assessment. 
However, earlier studies such  as that performed by the UK33 showed the cost 
effectiveness of ORVR to be around 35% wo rse than for conventional Stage II petrol 
vapour controls applied to service stations (see below). Costs are associated with the 
design and development of ORVR and the actual costs of the additional equipment that would be fitted to each car. Fuel disp ensers and conventional Stage II equipment 
have the advantage of having been standard ised and can be purchased "off the shelf". 
The UK's RIA indicates that the efficiency of vapour recovery is likely to be greater 
for Stage II PVR than for ORVR
34. 
Both the EU and the USA have regulatory controls on the permitted level of 
hydrocarbon emissions from a motor vehicle at rest. The permitted limits in the USA are much stricter than those in the EU which necessitates the inclusion of a large 
carbon canister in the fuel system to adso rb the hydrocarbons unt il the vehicle is 
driven and the hydrocarbons can be combus ted in the usual manner. The additional 
adaptation of the fuel system required in  the USA to implement ORVR was probably 
less onerous therefore (compared to the cu rrent position in the EU) because of the 
stricter diurnal emissions limits in the US A. This may explain why the US regulators 
have opted for ORVR rather than nati onwide Stage II PVR controls. In addition, 
there have been concerns over the ability of  small gas stations in the USA to deliver 
reliable implementation of Stage II controls. 
For the reasons above, ORVR option has not been taken any further at this stage. 
Nonetheless, diurnal evaporative emissions of  petrol vapour from ve hicles at rest and 
running losses are also significant sources of VOCs. These will not be addressed by Stage II controls at service stations but can  be reduced by an order of magnitude by a 
large carbon canister fitted to the vehicle's fuel system. These benefits alone could 
justify the mandatory installation of large carbon canisters at a later date and the 
Commission is committed to assessing whether the existing type approval test cycle 
for diurnal emissions ought to be harmonise d with those in the US and elsewhere
35. 
If an when such a tightening of the re gulated limits on evaporative emissions is 
considered, the incremental step of pro ceeding to "full" ORVR could also be 
considered as a complement or replacemen t for Stage II PVR controls at service 
                                                 
33 Chem Systems Ltd. "Gasoline Vapour Recovery Costs", Report prepared for the UK Department of the 
Environment, 1994. 
34 Page 7 (" Carbon Cannisters ") of the UK's Regeulatory Imp act Assessment, November 2005. 
35 Communication on the application and future development of Community legislation concerning 
vehicle emissions from light duty vehicles and acces s to repair and maintena nce information (Euro 5 
and 6): 2008/C 182/08: OJ C 182, 19.7.2008, p. 17. 
 
EN 15   EN stations. Naturally any decision would be preceded by an impact assessment that 
would consider the costs and benefits partic ularly those costs/be nefits of Stage II 
controls still to be incurred. 
5. ASSESSMENT OF PVR  STAGE II OPTIONS  
5.1. Assumptions and methodology to esti mate costs for Stage II PVR costs 
The approach taken to assess the cost s for introducing mandatory Stage II PVR 
controls yields the following information: (i) total cost; (ii) annualised costs; (iii) 
amount of petrol vapour abated ; (iv); the economic value of petrol vapour recovered; 
(v) cost effectiveness based on annualised  costs. The methodology is described in 
more detail in the COWI re port prepared from the Commission. It takes information 
about the size and number of petrol servic e stations and determines the magnitude of 
the unabated emissions and the emissions after installing Stage II PVR controls where these have yet to be installed. A spreadsheet model was developed by the 
consultants to make these cal culations. This model also allows a sensitivity analysis 
of the results to certain assumptions to be made. 
The Studies undertaken by ENTEC and COWI clearly show that the key parameters 
influencing the analysis are (i) cost data for Stage II equipment, (ii) lifetimes of 
service station equipment; (iii) the effici ency of Stage II equipment; and (iv) the 
economic value of the recovered petrol pr oduct. These are discussed more fully 
below. In all cases the same assumpti ons were used thr oughout to compare the 
various options. 
5.1.1.  Cost elements for indivi dual service stations 
Relevant cost elements in this analysis are the necessary additional or incremental 
(annualised) costs of introducing PVR St age II controls over and above those 
associated with the new build or refurbishm ent. For example, there will need to be 
new dispensers and associated equipm ent for a new construction or major 
refurbishment regardless of whether PVR Stage II controls are applied. Only the cost differences directly associated with St age II PVR are included in the analysis. 
The key cost elements of  introducing Stage II are: 
– Capital costs for above-ground equipmen t, including appropriately equipped 
dispensers containing vapour return pumps, as well as vapour recovery nozzles, 
coaxial hoses and other equipment; 
– Capital costs for installing the requir ed below-ground pipe work, including a 
vapour return line to th e underground storage tank (only for conventional 
technology); 
– Additional costs of digging up petrol station forecourts at existi ng petrol stations 
where installation is not undertaken as pa rt of a planned kno ck-down and rebuild 
programme (only for co nventional technology); 
– Additional ongoing maintenance and testing costs of PVR Stage II equipment as 
compared to standard equipment. In part icular, the requirement for a regular check 
 
EN 16   EN on the volumetric ratio - with associated adju stments if required - is considered to 
be essential to ensuring th at a reasonable hydrocarbon efficiency is maintained; 
– Costs of powering the additional Stage II equipment; and 
– Savings due to the economic value of fuel recovered. 
This basically leads to the following more or less distinct cases/scenarios for 
calculating the additional or incremental co sts of installing PVR Stage II equipment:  
• Scheduled work at an existing site, where  
– the incremental costs are due to  PVR Stage II equipment only within  new 
dispensers (since work is scheduled, and the costs of new dispensers per se are 
excluded), or where  
– there are incremental costs due to schedul ed installation of underground pipe work 
• Unscheduled work at an existing site, where  
– the incremental costs are due to retrofitting PVR Stage II equipment (to existing 
dispensers) only, or where  
– there are incremental costs due to unsch eduled installation of underground pipe 
work 
• Unscheduled work at an existing site, where  
– the incremental costs are due to new PVR Stage II equipment and new dispensers, 
or where  
– there are incremental costs due to uns cheduled installation of underground 
pipework 
The actual values assumed are that 15 % of service station sites have the necessary 
existing pipe work already installed, and th at 40 % of existing sites would be able to 
retrofit dispensers in the case of unscheduled refurbishments. 
5.1.2.  Actual cost data used 
The cost data presented in this assessm ent is based upon that from the DEFRA 
regulatory impact assessment followi ng an evaluation by the Commission's 
consultant which considered them to be more comprehensive, more recent and more transparent particularly afte r having been subjected to extensive public consultation 
in the UK. DEFRA estimates are, however , based on UK information, which mean 
that these might differ from those in the rest of the EU and those presented by 
ENTEC in its report to the Commission. In particular, the DEFRA regulatory impact 
assessment provided costs data on the "At Pump" system and also assumed that there is a significant fraction of stations where dispensers could not be retrofitted, but would need to be replaced (in the case of  unscheduled refurbishments of existing 
sites), whereas the ENTEC study does not include this assu mption. Retrofitting 
dispensers is significantly cheaper than re placing the dispenser due to non scheduled 
 
EN 17   EN refurbishment and DEFRA estimates are therefore about twice as high as the ENTEC 
estimates. 
The cost assumptions for the Conventional and At Pump Stage II PVR systems used 
in this impact assessment are presented in detail in Annex III. 
5.1.3.  Investment cycles and life times 
According to DEFRA (based on discussions with professional or ganisations) it can 
be assumed that the investment cycle in  the fuel retail sector is 15 years36. At the end 
of the cycle it is usual for a site to undergo necessary refurbishment including any replacement of or changes to dispensers. It is more cost effective for the retailer to 
carry out any additional ne cessary work (such as placement of underground pipe 
work) at the end of the investment cycle. According to ENTEC there will be different 
economic lifetimes for above-ground and below-ground equipment respectively; the 
specific values assumed to be 14 years fo r all below-ground equipment (equalling the 
assumed replacement rate of petrol stations), and 5 years for all above-ground equipment. The regulatory impact assessm ent performed by DEFRA in the UK used 
an economic lifetime of 15 years for above -ground equipment. This is consistent 
with the response of the Petrol Retailers  Association to the Commission's Public 
Consultation which referred to 2
nd hand use of petrol dispensers some 10 to 15 years 
after their first sale. Accordingly, this analysis assumes, 15 years for below-ground 
and above-ground equipment. 
5.1.4.  Abatement efficiency of Stage II equipment 
The cost-effectiveness of Stage II PVR will be  better if more vapour is collected i.e. 
if the system efficiency is greater. However, this has to be balanced against the ability and cost of maintaining a high e fficiency in practical use. Whilst ENTEC 
assumed a recovery efficien cy of 80% for petrol vapour captured, in California 
equipment must perform at 95% or better (similarly for Taiwan, Austria and China) 
whilst the recent legislation in the UK re quires 85% recovery. Other countries have 
mandated efficiencies in the 80 to 90% range . In addition, it has been pointed out in 
the public consultation that th e regulatory efficiency is  linked through to the type-
approval/certification process. So that in Germany, the regul ated efficiency of 80% is 
assessed as an average of two tests where the nozzle is placed correctly in the vehicle's neck filler and one where it is placed at 45 degrees (which reduces the effectiveness). 
This impact assessment has assumed an efficiency of 85%. This reflects the latest 
implementation of Stage II controls but also information from the oil industry
37 
which stated that the latest generation of Stage II equipment is more reliable and better matched to standardised vehicle tank/neck designs thereby overcoming the 
observed poor recovery efficiency of earlier Stage II equipment. 
                                                
 
36 At least for sites with an annual throughput greater than 3000 m3 
37 Response from CONCAWE, the Environmental and Heath & Safety Organisation representing the EU's 
oil industry. 
 
EN 18   EN 5.1.5.  Economic value of recover ed product & taxation 
The vapour which is displaced during refuelli ng resides initially in  the petrol tank of 
the motorist (consumer). So although the cons umer effectively loses some petrol this 
would otherwise be accepted without quest ion by the motorist. The economic value 
arises because the emitted vapour is recovered and recycled. 
When discussing the costs of the two differe nt Stage II systems, the economic value 
of the displaced petrol vapour  must be taken into account. In general terms, the 
economic analysis of various options ta kes the approach of maximising social 
welfare and so the analysis must exclude th e level of any taxes le vied on the petrol. 
The economic value of the recovered product is  simply the retail price exclusive of 
any tax.  
5.1.5.1.  Distributional effects & taxation 
However, there are important distributional effects notably from the perspective of 
the service station operator. The size of thes e effects varies accord ing to the type of 
technology used but it can also vary acco rding to national taxation policies.  
The simplest situation concerns the Conve ntional Stage II PVR system. Here the 
vapour is collected and returned to the oil refinery via the service station's 
underground storage tank. This vapour will ultimately find its way back into the 
petrol distribution system where it will be sold and delivered to a service station operator exclusive of duty and VAT. The ec onomic value of the recovered product is 
simply the retail price of the petrol (e xcluding duty and VAT) and there are no 
notable distributional effects or net impacts on national tax revenues. 
The At Pump system is more complicated. Here the vapour is c ooled, condensed and 
redirected back to the dispenser where it is dispensed. In some Member States, fuel 
duty is levied when petrol is first delivered  to the service station. Hence the vapour 
that is recovered is resold at the us ual forecourt price but no duty and VAT are 
payable by the service station operator. The selling price thus represents the economic value of the recovered petrol vapour to the operator in this  scenario. This is 
the position in the UK who included this be nefit as part of the regulatory impact 
assessment accompanying the introduction of na tional Stage II legislation. Some may 
argue that the Government is deprived of tax revenue from the sale of the recovered 
petrol and that this represents an equal a nd opposite cost to society. However, this is 
unclear given that national authorities ha ve previously alrea dy taxed the petrol 
delivered to the service station and so ther e is no net impact on national tax revenues. 
In other countries, fuel duty may be levied at  the point of sale i.e.  at the dispenser. As 
such the recovered vapour will effectively be taxed twice and the economic value of the recovered product will agai n be the retail pr ice. Here national tax revenues may 
be increased because of At Pump Stage II PVR equipment. 
In the analyses presented here, costs are pr esented with and without the retail value 
of the recovered product. Tax is excluded though as described above, this may be an important consideration for service stati on operators given that tax forms well over 
50% of the forecourt price of petrol. 
 
EN 19   EN 5.2. Benefits 
A simplified approach to the calculation of benefits has been ta ken. This necessarily 
ignores the important benefits for (1) hum an health associated with exposure to 
benzene; and (2) the impacts on forests and the natural environment from exposure to 
ground level ozone. Only the impacts on health and agricultural crops from ozone have been estimated in monetary terms. 
The approach taken builds upon the work on costs and benefits completed in the 
context of the Clean Ai r For Europe Programme
38. Simplified damage cost functions 
were developed expressed as a monetary figure per tonne of pollutant emitted. Mortality and morbidity have been treated fo r health. The range of  unit values arises 
because of the different approaches to m onetise premature mortality (i.e. using the 
mean value in a VOLY approach (value of  life years) or the mean VSL approach 
(value of statistical life). For simplicity  reasons, a single EU-wide average value has 
been chosen for the damage cost func tion for 1 tonne of VOC emitted which is 
equivalent to € 950 – 2800 per tonne of VOC emitted. 
5.3. Option 3(a) – Stage II PVR at new & substantially refurbished stations 
This option would apply Stage II PVR controls at new serv ice stations and at existing 
stations with a throughput of petrol greater than 500 m
3 per annum as part of a 
planned refurbishment. 
Obviously there is little benefit environm entally in installing Conventional Stage II 
vapour recovery at a servic e station that is not equipped with Stage I PVR as 
ultimately any captured vapour will end up being vented to the atmosphere. The VOC Stage I directive 94/63/EC does not a pply to stations with an annual throughput 
of less than 100 m
3. It also allows Member States to derogate stations with a 
throughput of less than 500m3 per annum if there are no health or environmental 
impacts. As such, the Conventional Stage II system can generally only be applied to 
stations with a throughput of petrol of greater than 500 m3 per annum. 
A summary of the costs, cost effectiveness and monetised benefits for this option are 
given below for the At Pump PVR system . 
Petrol vapour abated in 2020 (tonnes) 12 141 
Total cost € 179.5 m 
Annualised cost (2020) € 18.7 m 
Cost-effectiveness excluding value of recovered petrol € 1540/tonne 
Value of recovered petrol (retail value excluding tax in 2020) € 7.6 m 
Nett annualised cost including retail valu e of recovered petrol (2020) € 11.1 m 
                                                 
38 "Damages per tonne emission of PM 2.5, NH 3, SO 2, NOx and VOCs from each EU25 Member State and 
surrounding areas" AEA Technology March 2005. (as pa rt of the service contr act for carrying out cost-
benefit analysis of air quality related issues in particular in the Clean Air for Europe Programme. 
 
EN 20   EN Cost effectiveness including retail val ue of recovered petrol € 915/tonne 
Monetised benefits (2020)* € 11.5 to 34 m 
* This includes only those impacts on human health and agricultural crops from  exposure to ground level 
ozone. It excludes im pacts of benzene on human health and the im pacts of ozone on forests and the natural 
environment.  
A summary of the costs, cost effectiveness and monetised benefits for this option are 
given below for the Conventional Stage II PVR system . 
Petrol vapour abated in 2020 (tonnes) 12 141 
Total cost € 209.5 m 
Annualised cost (2020) € 21.4 m 
Cost-effectiveness excluding value of recovered petrol € 1760/tonne 
Value of recovered petrol (retail value excluding tax in 2020) € 7.6 m 
Nett annualised cost including retail valu e of recovered petrol (2020) € 13.8 m 
Cost effectiveness including retail val ue of recovered petrol €1140/tonne 
Monetised benefits (2020)* € 11.5 to 34 m 
* This includes only those impacts on human health and agricultural crops from  exposure to ground level 
ozone. It excludes im pacts of benzene on human health and the im pacts of ozone on forests and the natural 
environment. NB the value of petrol recovered inclusive of tax is not re levant for the Conventional PVR system 
as the vapour is returned to the oil refinery term inal and not recycled to the petrol dispenser. 
5.4. Option 3(b) – Stage II PVR at new & substantially refurbished stations and 
larger existing stations with a throughput greater than 3000m3 
If new Stage II controls are applied to new and substantially refurbished stations then 
all existing stations will eventually be f itted with such equipment as each undergoes 
renewal. This renewal process could be  speeded up and may make sense for the 
largest existing stations which make a propo rtionately greater co ntribution to overall 
emissions. The largest size category of serv ice station considered by the ENTEC and 
COWI reports covers those stations with  a petrol throughput  greater than 3000 m3 
per annum based upon available statistics. 
An economic lifetime of 15 years implies that  one fifteenth (6.7%) of existing sites 
will undergo scheduled refurbishment in a ny given year. Assuming legislation would 
enter into force in 2013, it co uld be expected that 47% of  existing sites could install 
PVR Stage II controls by 2020 as a scheduled part of their investment cycle whilst 
the remainder would require unscheduled refurbishment with proportionately higher 
costs. 
A summary of the costs, cost effectiveness and monetised benefits for this option are 
given below for the At Pump PVR system . 
 
EN 21   EN Petrol vapour abated in 2020 (tonnes) 17 769 
Total cost € 317.4 m 
Annualised cost (2020) € 31.95 m 
Cost-effectiveness excluding value of recovered petrol € 1798/tonne 
Value of recovered petrol (retail va lue excluding tax in 2020) € 11.1 m 
Nett annualised cost including retail valu e of recovered petrol (2020) € 20.8 m 
Cost effectiveness including retail val ue of recovered petrol € 1171/tonne 
Monetised benefits (2020)* €16.9 to 49.7m 
* This includes only those impacts on human health and agricultural crops from  exposure to ground level 
ozone. It excludes im pacts of benzene on human health and the im pacts of ozone on forests and the natural 
environment.  
A summary of the costs, cost effectiveness and monetised benefits for this option are 
given below for the Conventional Stage II PVR system . 
Petrol vapour abated in 2020 (tonnes) 17 769 
Total cost € 389 m 
Annualised cost (2020) € 38.4 m 
Cost-effectiveness excluding value of recovered petrol € 2160 /tonne 
Value of recovered petrol (retail va lue excluding tax in 2020) € 11.1m 
Nett annualised cost including retail valu e of recovered petrol (2020) € 27.2 m 
Cost effectiveness including retail val ue of recovered petrol € 1533/tonne 
Monetised benefits (2020)* €16.9 to 49.7m 
* This includes only those impacts on human health and agricultural crops from  exposure to ground level 
ozone. It excludes im pacts of benzene on human health and the im pacts of ozone on forests and the natural 
environment. NB the value of petrol recovered inclusive of tax is not re levant for the Conventional PVR system 
as the vapour is returned to the oil refinery term inal and not recycled to the petrol dispenser. 
5.5. Option 3(c) – Stage II PVR at all statio ns located in residential accommodation 
(scheduled versus unscheduled installations) 
In some Member States it is common to find relatively small service stations 
integrated into residential buildings. This was recognised in the VOC Stage I 
directive which required PVR controls during  petrol deliveries at  all such stations 
irrespective of size. The bene fit of these Stage I contro ls would be maximised if 
Stage II PVR controls are also instal led at the same service stations.  
Unfortunately, there are no statistics on the num ber of service stations integrated into 
residential accommodation and so it is di fficult to quantify total costs for requiring 
 
EN 22   EN Stage II controls to be fitted. However, from the COWI study it is possible to derive 
an approximate estimate of the costs of fitti ng Stage II controls to a station with one 
fuel dispenser (4 nozzles ) with a thr oughput of 500 m3 or less which ought to be a 
useful surrogate for the cost of installi ng Stage II PVR at a small service station 
within residential accommodation. 
Illustrative costs associated with a scheduled  and unscheduled installation of Stage II 
PVR are given in the table below. 
Conventional At Pump Cost-effectiveness (€/tonne) 
Scheduled Unscheduled Scheduled Unscheduled 
Without retail value of recovered 
petrol of €0.4 per litre 1890 5452 1500 3370 
Including retail value of recovered 
petrol of €0.4 per litre 1340 4910 960 2820 
(1) Assumes 15 year economic lifetime; (2) Assumes price excluding tax of €0.40 
In its response to the Commission's pub lic consultation, CONC AWE stated that it 
was about to publish a repo rt concerning worker e xposure to benzene in the 
downstream oil industry. This report concludes " that in certain circumstances the 
contribution of uncontrolled re fuelling emissions to ambien t benzene concentrations 
can be significant in terms of the air quality limit value for benzene " and that 
"refuelling emissions can result in genera l population exposures, at least during 
certain peak periods, abo ve the air quality limit value . The case of service stations 
below residential buildings is one of the circumstances in which this situation can 
occur. The report recommends that service stations in such locations should be 
assessed for the advisability of introducing Stage II controls. "  
It is clear that the costs for such small sta tions differ appreciably if the installation of 
Stage II PVR controls is made as part of the natural economic  cycle i.e. as a 
scheduled refurbishment rather than an uns cheduled retrofit. As such, the preferred 
option would be to insist on installing Stag e II PVR when a station is constructed as 
new or when an existing station undergoes a major refurbishment. In any event, if a 
new regulation entered into force in 2013, approximately 50% of existing service 
stations would undergo refurbishment as  part of the natural cycle by 2020.  
5.6. Option 3(d) – automatic monitoring 
The overall cost-effectiveness of Stage II PVR equipment would be maximised if the 
equipment actually functions correctly once in stalled. However, in its response to the 
public consultation, the Umweltbundesamt stat ed that in the late 1990s up 50% of 
systems tested in Germany were non-comp liant. The ENTEC report also noted that 
in Denmark 25% of systems and in the Rotterdam area of the Netherlands close to 20% of operators did not undertake the ne cessary inspections to ensure correct 
functioning
39. 
                                                 
39 ENTEC Report pages 22 – 25. 
 
EN 23   EN Checking of the performance on installed e quipment can be carried  out periodically 
and a period of every one to  two years seems to be comm on. Alternatively, automatic 
"real-time" monitoring can be required whic h has the advantages of permitting self-
calibration/fine tuning of the equipment wh ilst in operation and also lengthening the 
period between inspections and thereby reducing inspection & maintenance costs for 
the station operator (c.f. an inspectio n cost of c.a. €200-250 per dispenser). 
Since 2003, Germany has mandated automatic  monitoring and doubled the period 
between inspections of Stage II equippe d dispensers to two years. German 
Authorities estimated that the cost to retr ofit each dispenser is of the order of €2000. 
New equipment is likely to be less than th is although no firm estimates are available. 
The European Oil industry points to the f act that the newer generation of Stage II 
equipment is more reliable and that simple r fault detection proce dures are possible at 
one tenth the cost of "trad itional" automatic monitoring. 
The justification for automatic monitoring is  not clear-cut and such monitoring is not 
required in many of those Member States wh ere Stage II PVR controls are already in 
place. What is clear is that those operator s who have installed automatic monitoring 
usually benefit from a longer period between mandatory insp ections as part of their 
operating permit or licence. 
5.7. Sensitivity of cost estimates 
The COWI study looked at the impacts of ch anges in assumptions on the calculation 
of costs. The following table gives a cl ear indication as to  the direction and 
magnitude of changes in key assumptions for the Option 2(a) (new and substantially refurbished stations): 
Cost effectiveness in 2020 (€/tonne) Conventional At Pump 
15 year lifetime for above ground equipment*  1140 915 
10 year lifetime for above ground equipment* 1546 1326 
5 year lifetime for above ground equipment* 2787 2574 
Collection efficiency of 80%** 1681 1448 
Collection efficiency of 90%** 1425 1217 
All high cost assumptions 2282 1974 
All low cost assumptions 809 677 
* Assuming a collection effi ciency of 85%; ** using an  economic lifetime of 10 
years for above ground equipment 
5.8. Comparison with cost-effectiveness of other measures 
The table below presents the marginal costs of abatement for selected measures to 
abate VOC emissions from stationary sour ces. This information is taken from the 
GAINS integrated assessment model deve loped by the Interna tional Institute of 
Applied Systems Analysis which contai ns comprehensive information on air 
 
EN 24   EN pollution abatement measures and their costs40. The cost curve contains many more 
measures than presented here but shows that Stage II costs fall into the low to mid part of the cost curve. 
. . 
Technical measure Abatement cost 
in €/tonne of 
VOC 
Water based inks in the Packaging Industry 80 
Incineration of VOCs in coil coating 220 
Hydrocarbon machine in textile dry cleaning 340 
Activated carbon absorption in Indu strial adhesives application 420 
Improved application gunwash in vehicle refinishing 550 
Water based inks in screen printing 660 
Water based adhesives 695 
Inks used in Packaging – enclosure and activated carbo n absorption 1000 
Stripping and vent gas treatment in PVC manufacture 1150 
Wood treatment – activated carbon absorption 1340 
Water based inks and enclosure and carbon absorption 1600 
Water based inks and enclosure and incineration 1850 
Substitution of products in rubber synthesis 2300 
Substitution in vehicle refinishing sector 3400 
Wood treatment vacuum impregnation & incineration 4000 
Substitution of vehicle refinishing paints & incineration 6000 
Domestic solvents reformulation 12000 
Textile dry cleaning activated carbon absorption 20000 
Closed solvent degreasing with HF an d activated charcoal absorption 62000 
5.9. Administrative costs 
Due to the hazardous nature of petrol and petrol dispensing f acilities and the legal 
requirement to apply the Petrol Stage I PV R directive 94/63/EC, the Member States 
                                                 
40 http://www.iiasa.ac.at/rains /gains-online.html?sb=9   
 
EN 25   EN are all likely to have in place a system of  permitting which authorises the operation 
of service station activities. As suc h, the single most important additional 
administrative activity for the Member States  will be the modification and re-issue of 
all necessary permits and verification of compliance with relevant permit conditions. 
There will also be savings due to the reduced need to demonstrate conformity with varied national requirements  as minimum harmonised spec ifications should lead to 
mutual recognition of national standards. 
The total one-off costs for permits is the product of the number of  service stations 
affected by the new regulations and the cost for processing and issuing a new permit. A typical charge levied for the modification and re-issue of a permit is of the order of 
€120 and this is a cost that is recoverabl e by the permit issuing authority. The reports 
from ENTEC and COWI identified approxi mately 17,700 additional service stations 
that would be affected by any new legisl ation. The total administrative cost is 
estimated therefore at €2.1 million.  
Compliance certification would also entail additional administrative costs for service 
station operators. Information from the UK's RIA suggests that these requirements 
would present an annual cost per station of €150. For, 17,700 stations the total annual 
cost would be €2.65 million per annum. 
5.10. Social & employment aspects 
5.10.1.  Employment 
The impacts of new Stage II controls must be seen against those changes which are 
already happening in the sector. As noted earlier, there is already a shift towards 
larger stations with shops and towards unm anned service stations. For the smallest 
service stations with a throughput of 500 m
3 per annum, the necessary investment 
costs for a worst case unscheduled installation of Stage II equipment are 
approximately €16-28,000. This is equivalent  to approximately € 0.2-0.5 cents per 
litre of petrol. Sinc e January 2007, the real cost of  petrol has risen by over 60% 
representing approximately €cents 30 per litre. Operators have been able to pass 
these costs on to consumers without any no ticeable impact on demand for petrol. In 
general, no significant impact is expected on net income levels of service station 
operators as costs are likely to  be passed onto to consumers. 
The current proposal is likely  to lead to an increased demand for Stage II equipment 
and for its inspection and maintenan ce. The minimum harmonised technical 
standards should also make it easier for or iginal equipment manu facturers to supply 
into other Member States from those in which they are established. The impacts of 
these positive benefits have not been quan tified but are likely to safeguard or to 
augment current employment levels in this manufacturing sector. 
5.10.2.  Social inclusion, cohesion and environmental equity 
Environmental equity promotes the equita ble distribution of societal burdens and 
benefits with specific emphasis on e xposure to environmental toxicants41. This is 
                                                 
41 Air Quality Guidelines – Global Update 2005 . World Health Organisation Europe 2006, p. 136. 
 
EN 26   EN consistent with the core principles of social equity and cohesion of the EU's 
sustainable development strategy42. Emerging information suggests that because of 
the influence of loca l sources, urban sub-popu lations exist that have consistently 
higher exposure to ambient pollution and that these areas of high exposure often 
coincide with lower socioeconomic position. Moreover, groups of lower socioeconomic position may also be more re sponsive to air pollution and have lower 
baseline health status
41. 
In relation to industrial emissions to air and water in the UK, Friends of the Earth 
determined that 82% of carcinogenic emi ssions are in the 20% most deprived 
localities43. An analysis of the London Conges tion charge also identified the 
asymmetric impacts of air pollution in deprived areas but that in this case the benefit of the congestion charging scheme brought pr oportionately greater benefits in these 
deprived areas
44. 
Service stations are more likely to be dist ributed in urban areas and at the side of 
major roads. As such there is scope for disproportionate impacts particularly in relation to those petrol service stations situated in or close to residential accommodation where the cost of such accommod ation is likely to be less costly and 
attract the more economically disadvantage d. This was recognised in the VOC Stage 
I directive where petrol vapour from road tanker deliveries has to be recovered at 
service stations located in residential accommodation irre spective of how large these 
stations are. Conversely, Stag e II PVR controls at servic e stations close to or under 
residential accommodation are likely to deliver greater benefits to those in lower socioeconomic groups which is entirely  consistent with the principle of 
environmental equity.  
5.11. Workers' health & safety 
Those working at or close to service stati ons constitute a group likely to experience a 
greater accumulated exposure to benzene th an the general public . Such workers will 
be in a similar position to those who re side in accommodation built above or very 
close to service stations and who will benefit from the application of Stage II PVR controls at se rvice stations. 
6. C
OMPARISON OF OPTIONS  
The table below presents a summary of the costs and cost-effectiveness of the 
various options where this is possible. 
Option Total cost 
€m Emissions 
abated Cost effectiveness 
(€/tonne) Annualised Costs* 
[& benefits ] in 
                                                 
42 Communication from the Commission to the Council and the European Parliament of 25 May 2005 on 
a draft declaration on guiding principles for Sustainable Development; COM(2005) 218 final. 
43 Pollution and Poverty – Breaking the link ; Friends of the Earth Policy and Research Unit 2005. 
www.foe.co.uk/resource/reports/pollution_poverty_report.pdf 
44 Congestion Charge has modest impact on the life expectancy of Londoners ; London School of Hygiene 
& Tropical Medicine, University of London, February 2008. 
www.lshtm.ac.uk/news/2008/congestioncharge.html .  
 
EN 27   EN (tonnes) Excluding 
recovered 
petrol Including 
retail value 
of recovered 
petrol 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) 
The preferred option is Option 3(c) which would (i) apply to new and refurbished 
stations above 500m3 throughput; (ii) require retrofitti ng of existing stations above a 
throughput of 3000 m3 by 2020; and (iii) require all ne w or substantially refurbished 
stations situated under residential accomm odation to equip with Stage II controls 
irrespective of size.  
It is clear that obliging the larger existing st ations to install Stage II controls before 
2020 imposes additional costs but also delivers substantially greater emissions reductions albeit with a slightly worse cost-effectiveness. However, the costs are relatively modest for both options. Opti on 3(b) has annualised costs in 2020 of 32 
and 38 million euros in 2020 for the "at pump" and "conventional" systems respectively before taking into account the value of recovered petrol (€21 to 27 
million when the value of recovered petrol is included).  
Whilst it is not possible to calculate direc tly the costs associated with Option 3(c), 
where all stations in residential acco mmodation would fit Stage II controls, the 
illustrative calculation shows that the costs of a scheduled retrofit of a small service station would be similar to the average for all service stations in Options 3(a) and 
3(b). The costs of an unsche duled retrofit are substantially higher and do not justify 
the imposition of a time limit. However, in the 10 years following adoption of any new Directive on Stage II PVR, over two thir ds of such stations would have been 
expected to have undergone a scheduled refurbishment.  
Whilst automatic monitoring would certainly guarantee the delivery of the intended 
benefits in practice, there is uncertainty over the costs of such systems and whether 
there are not simpler and cheaper systems th at can deliver as well. This conclusion 
was supported by the findings of ENTEC re port which determined a 50% worsening 
 
EN 28   EN in cost-effectiveness for the mandatory inclusion of automatic monitoring45. 
However, given the increased probability of reliable in-servi ce performance there 
will undoubtedly be less need for periodic  inspection of the Stage II equipment 
which would represent a cost saving. 
7. MONITORING AND IMPLEMENTATION  
Extensive reporting mechanisms are already in place to monitor ambient air quality 
and Member States' adherence to Commun ity air quality objectives. Non-compliance 
with legal air quality requirements is enfo rced pursuant to exis ting Treaty provisions. 
Member States will need to transpose th e Stage II directive's provisions once adopted 
and to bring about their practical implementation and the Commission will need to assess the conformity of those transposi ng measures. Monitoring of Member States' 
progress can be gauged from the emission inve ntory reports that they are obliged to 
compile and submit to the Commission (and the Convention on Transboundary Air Pollution) pursuant to the national emissi ons ceilings directive. There are also 
statistics compiled by national and European oil industry associations which can also 
assist in evaluating progress. It is thought that the imposition of an additional specific 
reporting burden may be disproportionate as  this would require the compilation of 
additional statistical information at the national level. In any event, the Commission has the prerogative to ask at any moment how the Member States have implemented 
Community law. 
                                                
 
45 Table 6.24, p. 55 of the ENTEC report prepared for the Commission (May 2005). 
 
EN 29   EN Annex I  
Status of Stage II PVR Implemen tation in the Member States  
Country Details of Stage II  PVR controls Expected 
compliance with 
NECD ceiling for 
VOCs in 201046 Status w.r.t. UNECE 
VOC protocol 
(compliance in respect 
of Stage II) 
Austria Controls apply to all service stations by 1998 at the latest yes Ratified (yes) 
Belgium Brussels Region : Controls apply to all service stations by 2 007 except if throughput of petrol is less 
than 500m3 per annum and not situated under dwellings; 
Flanders : Controls apply to all service stations greater than 100m3 petrol throughput per annum. 
Wallonia : Controls apply to all new and existing stations by 2010. yes Ratified (yes) 
Cyprus No legislation but stations generally fit appropriate underground pipe work yes Non-signatory 
Czech 
Republic Controls apply to all stations by 2004 yes Ratified (yes) 
Denmark Controls apply to all stations with petrol throughput greater than 500m3 by 2000 No Ratified (yes) 
Estonia No legislation yes Ratified (no) 
Finland No legislation yes Ratified (no) 
France Controls apply to all new stations greater than 500m3 petrol throughput by 2001 and existing stations 
with throughput greater than 3000m3 by 2002 No Ratified (yes) 
Germany Controls apply for all new and existing stations great er than 1000m3 petrol throughput by 1997 yes Ratified (yes) 
Greece No legislation yes Signatory only 
                                                 
46 http://www.eea.europa.eu/highlights/more-eu-me mber-states-to-miss-2010-air-pollutant-limits   
 
EN 30   EN Country Details of Stage II  PVR controls Expected 
compliance with 
NECD ceiling for 
VOCs in 201046 Status w.r.t. UNECE 
VOC protocol 
(compliance in respect 
of Stage II) 
Hungary Controls apply to all statio ns with throughput greater than 100m3 by 2003 yes  Ratified (yes) 
Ireland No legislation yes Non-signatory 
Italy Controls apply to all petrol stations by 2000 yes  Ratified (yes) 
Latvia Controls apply to all new stations from 2000 yes  Non-signatory 
Lithuania Controls apply to all new stations with a throughput greater than 100m3 (500m3 in rural areas) and all 
stations by 2007. yes Ratified (yes) 
Luxembourg Controls apply to all petrol station by January 2005 yes  Ratified (yes) 
Malta No legislation yes Non-signatory 
Netherlands Controls apply to all stations with throughput greater than 500m3 by 1999 yes  Ratified (yes) 
Poland Controls apply to all service stations with throughput greater than 100m3 by 2005 no Non-signatory 
Portugal No legislation no Signatory only 
Slovakia Controls apply to all stations with a throughput greater than 1000m3 from January 2005. Stations with a 
throughput greater than 100m3 but less than 1000m3 and located under permanent dwellings or 
industrial premises must comply by 1 January 2008. yes Ratified (yes) 
Slovenia Legislation applies to all new and refurbished stations yes Non-signatory 
Spain No legislation no Ratified (no) 
Sweden Controls apply to all stati ons with throughput greater than 100m3 by 1995 though exemptions can be 
granted for rural stations with a throughput less than 300m3. yes Ratified (yes) 
 
EN 31   EN Country Details of Stage II  PVR controls Expected 
compliance with 
NECD ceiling for 
VOCs in 201046 Status w.r.t. UNECE 
VOC protocol 
(compliance in respect 
of Stage II) 
UK Controls will be applied to all new stations and ex isting stations with a throughput greater than 3500m3 
from January 2010. New stations with throughputs less than 500m3 are exempt. yes Ratified (yes) 
Bulgaria No legislation but most st ations have controls in place yes  Ratified (no) 
Romania No legislation yes Non-signatory 
Croatia No legislation n/a Non-signatory 
European 
Community n/a yes Signatory only 
.
 
EN 32   EN Annex II  
Numbers of petrol stations by Member State & size  
Country N° of 
stations % of stations 
> 500m3 p.a. Country N° of stations % of stations 
> 500m3 p.a. 
Austria 2900 - Latvia* 590 53% 
Belgium 3400 - Lithuania* 625 - 
Cyprus* 250 84% Luxembourg 280 - 
Czech Republic 2150 91% Malta* 80 - 
Denmark 2100 91% Netherlands 3700 - 
Estonia* 500 - Poland 6700 - 
Finland 2050 80% Portugal 2350 - 
France 13600 - Slovakia* 780 94% 
Germany 15250 84% Slovenia* 420 90% 
Greece 8200 - Spain 8700 - 
Hungary 1600 - Sweden 4000 - 
Ireland 1850 - UK 9800 90% 
Italy 22500 - Croatia* 600  
Information taken from Statistics published by The European Petroleum Industries Association unless otherwise 
stated. *signifies information taken from Annex A of the ENTEC Report. 
Service station throughput (m3/yr) % of total volume of petrol supplied % of service stations 
< 500 10.7% 26.9% 
< 1000 21.5% 41.2% 
< 1500 32.2% 55.5% 
< 2000 41.4% 64.3% 
< 2500 50.5% 73.1% 
< 3000 59.6% 82.0% 
< 4000 71.7% 88.5% 
< 5000 83.6% 95.0% 
> 5000 16.4% 5.0% 
 
EN 33   EN Annex III  
Costs of Stage II Petrol Vapour Recovery  
Conventional System 
Annual throughput (m3) 0 - 500 500 - 1000 1000 - 2000 2000-3000 3000+ 
Assumed number of dispensers  1 2 3 4 6 
Number of nozzles per dispenser  4 4 4 4 4 
Supplementary materials and labour  
Unscheduled installation of underground pipe work    
Underground pipework 4,860.00 5,265.00 6,075.00 7,290.00 8,910.00
Surround to pipework 405.00 810.00 1,215.00 1,620.00 2,430.00
Tank connections and valves  494.10 988.20 1,490.40 1,992.60 2,972.70
Trench excavation for vapour 
recovery pipework 5,670.00 6,075.00 6,885.00 8,100.00 12,150.00
Remove pumps and replace  405.00 81 0.00 1,215.00 1, 620.00 2,430.00
Installation of vapour recovery 
equipment  486.00 972.00 1,458.00 1,944.00 2,916.00
Unscheduled total  12,320.10  14,920.20  18,338.40  22,566.60  31,808.70
Scheduled installation of underground pipe work    
Underground pipework 1,344.60 1,393.20 1,458.00 1,558.44 1,934.28
Surround to pipework 324.00 567.00 810.00 1,296.00 1,944.00
Tank connections and valves  494.10 988.20 1,490.40 1,992.60 2,972.70
Trench excavation for vapour 
recovery pipework 0.00 0.00 0.00 0.00 0.00
Remove pumps and replace  405.00 81 0.00 1,215.00 1, 620.00 2,430.00
Installation of vapour recovery 
equipment  486.00 972.00 1,458.00 1,944.00 2,916.00
Scheduled total,  2,608.20  3,839.40  5,094.90  6,629.04  9,523.98
Existing pipework at hand      
Underground pipework 0.00 0.00 0.00 0.00 0.00
Surround to pipework 0.00 0.00 0.00 0.00 0.00
Tank connections and valves  494.10 988.20 1,490.40 1,992.60 2,972.70
Trench excavation for vapour 
recovery pipework 0.00 0.00 0.00 0.00 0.00
Remove pumps and replace  405.00 81 0.00 1,215.00 1, 620.00 2,430.00
Installation of vapour recovery 
equipment  486.00 972.00 1,458.00 1,944.00 2,916.00
Existing pipework total  939.60  1,879.20  2,826.90  3,774.60  5,645.70
Costs of PVR Stage 2 equipment  
New dispenser (unscheduled)     
Dispenser  10,484.32 20,968.64 31,452.96 41,937.28 62,905.92
Vapour recovery equipment  2,930.40 5,860.80 8,791.20 11,721.60 17,582.40
Nozzle  2,326.56 4,653.12 6,979.68 9,306.24 13,959.36
New dispenser - total  15,741.28  31,482.56  47,223.84  62,965.12  94,447.68
New dispenser (scheduled)     
Dispenser  0.00 0.00 0.00 0.00 0.00
Vapour recovery equipment  2,930.40 5,860.80 8,791.20 11,721.60 17,582.40
Nozzle  2,326.56 4,653.12 6,979.68 9,306.24 13,959.36
New dispenser - total  5,256.96  10,513.92  15,770.88  21,027.84  31,541.76
Retrofit to existing dispenser     
Dispenser  0.00 0.00 0.00 0.00 0.00
Vapour recovery equipment  3,984.16 7,968.32 11,952.48 15,936.64 23,904.96
Nozzle  2,344.32 4,688.64 7,032.96 9,377.28 14,065.92
 
EN 34   EN Retrofit to existing dispenser, total  6,328.48  12,656.96  18,985.44  25,313.92  37,970.88
Recurring costs (per year - dependent on number of dispensers) 
Maintenance and power costs     
Incremental maintenance and tests  249.13 337.93 426.73 515.53 693.13
Incremental power 7.40 14.80 22.20 29.60 44.40
Total "m&p" costs  256.53  352.73  448.93  545.13  737.53
 
"At pump" System 
Annual throughput (m3) 0 - 500 500 - 1000 1000 - 2000 2000-3000 3000+ 
Assumed number of dispensers  1 2 3 4 6
Number of nozzles per dispenser  4 4 4 4 4
Supplementary materials and labour  
System using new technology (Regardless of new, scheduled or unscheduled)  
Installation of vapour recovery 
equipment  486.00 972.00 1,458.00 1,944.00 2,916.00
New technology total  486.00  972.00  1,458.00  1,944.00  2,916.00
Costs of PVR Stage 2 equipment  
New dispenser (unscheduled)    
Dispenser  10,484.32 20,968.64 31,452.96 41,937.28 62,905.92
Vapour recovery equipment  2,960.00 5,920.00 8,880.00 11,840.00 17,760.00
Nozzle  2,326.56 4,653.12 6,979.68 9,306.24 13,959.36
New dispenser (unscheduled), total  15,770.88  31,541.76  47,312.64  63,083.52  94,625.28
     
New dispenser (scheduled)     
Dispenser  0.00 0.00 0.00 0.00 0.00
Vapour recovery equipment  2,960.00 5,920.00 8,880.00 11,840.00 17,760.00
Nozzle  2,326.56 4,653.12 6,979.68 9,306.24 13,959.36
New dispenser (scheduled), total  5,286.56  10,573.12  15,859.68  21,146.24  31,719.36
     
Retrofit to existing dispenser     
Dispenser  0.00 0.00 0.00 0.00 0.00
Vapour recovery equipment  4,440.00 8,880.00 13,320.00 17,760.00 26,640.00
Nozzle  2,344.32 4,688.64 7,032.96 9,377.28 14,065.92
Retrofit to existing dispenser, total  6,784.32  13,568.64  20,352.96  27,137.28  40,705.92
Recurring costs (per year - dependent on number of dispensers)  
Maintenance and power costs    
Incremental maintenance and tests  249.13 337.93 426.73 515.53 693.13
Incremental power  7.40 14.80 22.20 29.60 44.40
Total "m&p" costs  256.53  352.73  448.93  545.13  737.53