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 petrol vapour recovery during the refuelling of petrol cars at service stations-  Executive Summary - Impact Assessment {COM(2008) 812 final} {SEC(2008) 2937}
Date: 2008-12-04
Institutions: European Commission
Subjects: atmospheric pollutant, diesel fuel, environmental protection, motor fuel, motor vehicle, ozone, petrol, substitute fuel, supply

EN 

EN 

   EN 

 
 
COMMISSION OF THE EUROPEAN 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 petrol vapour recovery during the refuelling of 
petrol cars at service stations  

Executive Summary - Impact Assessment 

{COM(2008) 812 final} 
{SEC(2008) 2937} 

EN 

   EN 

 
 
 
 
 
 
 
EXECUTIVE SUMMARY 

This impact assessment accompanies a legislative proposal aimed at recovering petrol vapour 
which is emitted to the atmosphere during the refuelling of passenger cars at service stations 
(Stage II Petrol Vapour Recovery or PVR). These emissions contribute to local and regional 
air  quality  problems  (benzene  and  ozone)  for  which  there  exist  Community  air  quality 
standards  and  objectives.  Ground  level  ozone  is  a  pollutant  which  crosses  national  borders 
and is also the third most important greenhouse 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 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  despite  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 proposal has been prepared following commitments made by the Commission in: 

–  the Thematic Strategy on Air Pollution1;  

–  the  Commission's  proposal  to  amend  Directive  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  and  its  specifications  apply  uniformly  across  the  EU.  The 
Commission recognised that any relaxation of vapour pressure limits could lead to greater 
emissions of volatile organic compounds from refuelling and evaporative emissions from 
vehicles' fuel  systems  even  in countries where  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 the 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  Community  legislation  on  Stage  I  petrol  vapour 
recovery  (covering  the  storage  and  distribution  of  petrol  from  terminals  to  service  stations) 
and  recognising  the  fact  that  over  half  of  the  Member  States  already  have  national  Stage  II 

1 
2 
3 
4 

Section 4.2.1.2 on page 9 of COM(2005) 446 of 21 September 2005. 
Section 3(4) on pages 7 & 8 of COM(2007) 18 of 31 January 2007. 
Directive 2008/50/EC on ambient air quality and cleaner air for Europe, OJ L152, 11.6.2008, p. 1 – 43. 
http://ec.europa.eu/environment/air/transport/petrol.htm  

EN 

2 

   EN 

 
                                                 
PVR measures in place. Stage II PVR is also a requirement of an international protocol that 
the Community has signed but not ratified. 

Several  options  have  been  considered  including  "conventional"  petrol  vapour  recovery 
systems  which  capture  escaping  petrol  vapour  via  a  vacuum  pump  and  redirect  it  to  the 
underground  storage  tanks  at  service  stations.  This  vapour  is  ultimately  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 underground tanks or pipework and so is less 
disruptive  to  the  service  station  operator  particularly  where  an  unscheduled  retrofit  is 
necessary. 

The costs of installing Stage II have been calculated taking into account, numbers of stations, 
the  size  of  stations,  the  cost  of  Stage  II  equipment  (and  its  installation  cost),  the  economic 
lifetime  of  the  equipment  and  the  economic  value  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 benefits of reduced emissions have been estimated using simple 
damage costs per tonne of petrol vapour emitted 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) 

(b) 

(c) 

(d) 

All new and substantially refurbished service stations with a throughput greater 
than 500 m3 of petrol per annum. 

At  all  new  and  substantially  refurbished  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). 

Option  (b)  together  with  service  stations  situated  in  or  under  residential 
accommodation irrespective of size 

Automatic monitoring of all stage II equipment that would restrict petrol sales 
if the equipment is not functioning correctly (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 the uncertainty over costs and adverse impact on 
cost-effectiveness particularly as other cheaper means may be available to guarantee reliable 
in-service operation of Stage II PVR equipment. 

EN 

3 

   EN 

 
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 
(tonnes) 

Cost effectiveness 
(€/tonne) 

Annualised Costs*  
[& benefits] in 2020 
€m 

3a (At pump) 

179.5 

12 141 

3a (Conventional)  209.5 

12 141 

3b (At pump) 

317.4 

17 769 

3b (conventional) 

389 

17 769 

Excluding 
recovered 
petrol 

Including 
retail value 
of recovered 
petrol 

1540 

1760 

1798 

2160 

915 

1140 

1171 

1533 

3c (At pump) 

not calc. 

not calc. 

 Est. 1500 

Est. 960 

3c (conventional) 

not calc. 

not calc. 

Est. 1890 

Est. 1340 

3d 

Limited information available 

a – Stage II controls at new and substantially 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 residential accommodation irrespective of size/throughput 
d – option (c) plus installation of automatic monitoring equipment 
*-includes economic value of the recovered petrol (retail price) 

11.1 [11.5-34.0] 

13.8[11.5-34.0] 

20.8 [16.9-49.7] 

27.2 [16.9-49.7] 

not calc. 

not calc. 

Limited  information  exists  on  the  numbers  of  service  stations  situated  under  residential 
accommodation  so  it  is  not  possible  to  calculate  the  total  costs  etc.  However,  the  cost 
implications  for  a  small  service  station  with  a  throughput  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 other available measures to reduce emissions of 
volatile organic compounds. 

The  Commission  invited  key  stakeholders  to  respond  directly  to  a  series  of  questions  about 
the possible introduction of Stage II PVR on 28 February. This invitation was also posted to 
the Europa web site so that the general public could also be consulted. The consultation was 
also  publicised  by  "ENDS  Daily"  on  17  March  2008.  Sixteen  responses  were  received 
spanning Member State regions, environmental agencies, NGOs, equipment suppliers, service 
station  operators,  oil  industry  associations  and  vehicle  manufacturers.  A  summary  of  these 
responses  is  available  on  line5.  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 options for installing stage II PVR equipment. These 
responses  have  been  taken  directly  into  account  in  drafting  the  key  elements  of  the 
residential 
accompanying  proposal  notably 

to  service  stations  under 

relation 

in 

5 

http://ec.europa.eu/environment/air/transport/petrol.htm  

EN 

4 

   EN 

 
                                                 
accommodation, the lower cut-off for affected service stations and the automatic monitoring 
of in-service performance of equipment.  

EN 

5 

   EN