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 - Impact Assessment {COM(2008) 812 final} {SEC(2008) 2938}
Date: 2008-12-04
Institutions: European Commission
Subjects: atmospheric pollutant, diesel fuel, environmental protection, motor fuel, motor vehicle, ozone, petrol, substitute fuel, supply

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

Impact Assessment 

{COM(2008) 812 final} 
{SEC(2008) 2938} 

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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,  bring  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  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 
Commission  recognised  that  this  could  lead  to  greater  emissions  of  volatile 
organic  compounds  and  indicated  that  recovery  of  petrol  vapour  during  the 
refuelling of cars would be proposed in order 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  measures  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 the 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  direct  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  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 

1 
2 
3 

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. 

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industry associations and vehicle manufacturers. A summary of these responses is 
available on line4. 

–  Those  involved  in  the  manufacture  and  supply  of  Stage  II  equipment  supported 
the  introduction  of  harmonised  specifications  as  did  environmental  agencies  and 
NGOs. Independent petrol retailers expressed the view that Member States should 
be allowed to decide for themselves whether to proceed with Stage II PVR. Those 
who supported Stage II PVR preferred an approach that tackled 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  adverse  health  impacts  (leukaemia),  the 
mainstream  European  downstream  oil  industry  supported  the  view  that  service 
stations  built  under  residential  accommodation  presented  the  greatest  potential 
risk and that these stations should be assessed for their suitability to install Stage 
II controls irrespective 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/regulatory  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 aspects including a treatment of taxation, 

assumptions used; 

–  Clarification  of  the  combinations  of  options  particularly  in  relation  to  automatic 
monitoring  of  petrol  vapour  recovery  equipment  and  in-service  compliance  and 
also further explain comparisons to vehicular measures in the USA. 

4 
5 

6 

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8 

http://ec.europa.eu/environment/air/transport/petrol.htm  
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  
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/pdf/cowi_report_stage2_feb08.pdf  
Final  Regulatory  Impact  Assessment  on  Petrol  Vapour  Recovery  stage  II  controls  (PVR  II),  Air  and 
Environment Quality Division, Department for Environment, 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  
Discussion Paper: Action for Air – Improving air quality through vapour recovery at service stations, 
2007. 
Climate 
& 
Department 
http://circa.europa.eu/Members/irc/env/stage2/library?l=/background_documents/aus-
nsw_vapourrecovery/_EN_1.0_&a=d  

Environment 

Change 

August 

NSW, 

of 

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The  draft  text  has  been  amended  in  several  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  into  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 
ceilings9. 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  long  term  objectives  for  health  and  the 
environment,  as  established  in  the  6th  Environmental  Action  Programme  and  the 
national emissions ceilings directive 2001/81/EC, will not be attained on the basis of 
current  policies  even  by  2020.  The  Strategy  proposed  several  measures  to  help 
deliver  further  progress  towards  the  long  term  objectives  including  additional 
controls on the refuelling of petrol 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  regulations  vary  in  scope  particularly  in 
terms of the minimum size of petrol station captured, the required vapour collection 
efficiency and the post-installation compliance regime. 

9 

10 

11 

12 
13 

Directive  2001/81/EC  on  national  emission  ceilings  for  certain  atmospheric  pollutants:  OJ  L  309, 
27.11.2001, p.22. 
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. 
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. 
Directive 98/70/EC relating to the quality of petrol and diesel fuels: OJ L 350, 28.12.1998, p. 58. 
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. 

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Since the Thematic Strategy was adopted, the College has also decided to facilitate a 
greater  take-up  of  biofuels  such  as  bioethanol  in  the  road  transport  sector.  The 
Commission acknowledged, however, 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 "Stage 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 petrol. It is also a known human genotoxic 
carcinogen and is associated with a heightened risk of illnesses such as leukaemia. A 
Community air quality standard exists for the protection of public health15 but there 
is  no  known  safe  level  of  exposure.  Human  exposure  comes  mainly  from  tobacco 
smoke, petrol vapour and from vehicle exhaust emissions. The air quality limit value 
for benzene is expressed as an annual average concentration 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 will comply with the air quality limit value by 
2010.  However,  there  may  remain  problems  at  heavily  trafficked  locations  and 
residential areas in the immediate vicinity 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-industrial exposure to benzene in non-smokers. 
Vehicle  refuelling  comprised  between  75-85%  of  total  exposure  in  the  winter  and 
summer  respectively16  even  though  the  benzene  content  of  petrol  is  only  1%  by 
volume  (as  in  the  EU)  and  individuals  were  assumed  only  to  spend  a  few  minutes 
refuelling their vehicles. Similar conclusions have been reached in European studies 
where  individuals  had  similar  time/activity  diaries  and  where  individuals  spent 
approximately 60% of their time indoors at home17.  

The  French  petroleum  industries  association  reported  in  2006  on  a  wide-ranging 
measurement campaign of benzene concentrations at and around 43 service stations 
in  France18.  For  those  service  stations  constructed  under  apartment  buildings,  the 

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18 

Directive  94/63/EC  on  the  control  of  volatile  organic  compound  (VOC)  emissions  resulting  from  the 
storage of petrol and its distribution from terminals to service stations: OJ L365, 31.12.1994, p. 24. 
Directive 2000/69/EC relating  to  limit  values  for  benzene  and  carbon  monoxide  in  ambient  air: OJ  L 
313, 13.12.2000, p. 12. 
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. 
R.  Edwards,  M.  Jantunen,  Benzene  exposure  in  Helsinki,  Finland.  Atmospheric  Environment  35(8) 
2001 p. 1411-1420 (part of the EXPOLIS project). 
L'Union Française des Industries Pétrolières publie une étude relative au bezène 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  

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observed  concentrations  at  the  petrol  dispenser  were  in  the  range  10  –  85.7  µg/m 3 
(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 quality limit at most places, there are likely 
to  be  elevated  concentrations  in  the  immediate  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 processes to form ground level ozone and 
other components of photochemical smog. Ozone is a transboundary pollutant so that 
precursors  emitted  in  one  country  are  dispersed  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  targets22  to  protect  against  exposure  to 
ozone.  

The  World  Health  Organisation  recommends  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  effect  on  mortality.  The  ozone  directive 
established a target value 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 
EEA23. Although reductions in emissions of ozone precursors appear to have led to 
lower  peak  concentrations  of  ozone  in  the  troposphere,  the  current  target  level  is 
frequently exceeded for a substantial part of the urban population of the EEA-32. In 

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20 

21 

22 
23 

M. Zamitt and A.J. Vella; Influence of service stations on air quality; Xjenza 2003, vol. 8, p. 3. 
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. 
Air  Quality  and  Land  Use  Handbook:  A  community  health  perspective;  California  Environmental 
Protection 
30. 
Air 
(http://www.arb.ca.gov/ch/landuse.htm)  
Directive 2002/3/EC relating to ozone in ambient air: OJ L 67, 9.3.2002, p. 14. 
Air Pollution in Europe 1990-2004, Steinar Larssen et al, European Environment Agency, Copenhagen 
2007. 

Resources 

California 

Agency 

Board, 

2005, 

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p. 

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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 exceeded over a wide area and by a large margin. 

Several  studies  have  shown  that  ozone  peak  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  directive,  concentrations  are  averaged  over  3 
years it is clear that the target value was not met in large parts of continental Europe 
(see Fig 1).  

ozone
exceedance days (>120 µg/m3)
2002-2004
all stations, data coverage > 75%

0 days

0- 25 days

25- 50 days

> 50 days

source: ETC/ACC-AIRBASE                                                                                              June -2006

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  areas  24%,  traffic  sites  18%, 
9%,  industrial,  and  5%  not  properly  classified.  [Reproduced  by  permission  of  the  European 
Environment Agency] 

The reductions in ozone precursor emissions that should result 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  forcing  of  ground  level  ozone  since  1750  is 
+0.35  Wm-2  and  ozone  is  the  third  most  important  greenhouse  gas  after  carbon 

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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 emissions of VOCs, NOx and carbon monoxide. 

2.2.  Mixtures of ethanol and petrol 

The vapour pressure of a particular liquid VOC is a measure 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  called  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 kPa for ethanol contents in petrol 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 emissions of hydrocarbons 
during refuelling but it will also increase the 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  mixture  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 head space above the liquid. 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  tanker,  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 where it can be re-incorporated into the petrol 
pool  and  re-supplied  to  service  station  operators.  Stage  I  PVR  requires  certain 

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26 

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. 
Basic Physical Chemistry, Walter J. Moore, Prentice Hall International, London 1983, pp 213 
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). 

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underground pipe work to be installed in order that vapour can be returned safely to 
the tanker.  

The  smallest  petrol  service  stations  with  a  volumetric  throughput  of  petrol  of  less 
than  100  cubic  metres  (m3)  per  annum  are  exempt  from  the  directive's  provisions. 
Moreover, Member States may also derogate 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, regardless of throughput, must install Stage I 
PVR equipment if they are located under permanent living quarters or working areas. 
Any Stage II PVR legislation must be consistent 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  emissions  comprises  many  diverse  sources  and 
economic  sectors  unlike  that  of  other  pollutants  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 displaced and without any further intervention this vapour is 
vented  to  the  atmosphere.  Spillages  and  drips  from  the  filler  nozzle  will  also 
evaporate. Overall emissions of VOC associated with petrol refuelling 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 have a significant impact27. In May 2005, ENTEC estimated 
that emissions for the EU27 plus Croatia in 2010 for vehicle refuelling and spillage 
would  be  87.2  ktonnes  and  10.4  ktonnes  respectively  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  combined  turnover  of 
approximately  €250  billion  and  which  employ  440,000  people 28.  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 half of the 18,000 stations that existed in 
199229. Similarly, Denmark has seen a reduction in the number of smaller stations so 
that in 1990, 22% of all petrol was sold in stations with 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 Member State is presented in Annex II. 

27 
28 
29 

See Figure 5.1 of the ENTEC report 
European Council for Motor Trades & Repairs. http://www.cecra.eu/en/about/about.php  
Understanding Pump Prices, UK Petroleum Industries Association, June 2007. www.ukpia.com  

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Based upon information provided by the European 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 across 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  exist  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  actively  "sucked"  back  into  the  outer 
nozzle  and  is  transferred  to  the  underground  storage  tanks  of  the  service 
station. When a service station receives a fresh delivery of petrol, the vapour 
contained  and  displaced  from  the  station'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 into subsequent loads. The key aspect is 
that  petrol  vapour  that  otherwise  is  displaced  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 controls, 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 and condensed into liquid petrol at the 
petrol  dispenser.  The  liquid  petrol  is  then  delivered  back  to  the  car's  petrol 
tank as part of the ongoing purchase. This active system does not require any 
additional  underground  pipe  work  at  the  service  station  and  permits  the 
station operator to resell the petrol vapour otherwise lost to the atmosphere. 

(3)  Onboard refuelling vapour recovery (ORVR) is an emission control system 
that  is  placed  on  board  a  vehicle.  Petrol  vapour  that  is  displaced  during 
refuelling  is  directed  towards  a  large  canister  containing  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  stations.  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  installed  conventional  Stage  II  controls  at 
service stations in various forms (see Annex I). The Community has signed but not 

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the  VOC  Protocol  of 

ratified 
the  UN  ECE  Convention  on  Long  Range 
Transboundary  Air  Pollution  (CLRTAP)30.  Article  3(b)(ii)  of  this  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 further 7 have signed 
but not yet ratified. Interestingly, Spain, Bulgaria, Estonia and Finland have ratified 
but have not implemented Stage II PVR controls 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  kilometres  in  the  atmosphere.  Air  pollution 
problems  with  such  a  transboundary  dimension  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 directive governing the minimum quality of petrol and diesel sold in the EU is 
based  upon  Article  95  of  the  Treaty  and  applies  uniformly  across  the  EU.  The 
Commission has proposed a relaxation of the vapour pressure requirements of petrol 
in order to promote a greater use of bioethanol2. This could however lead to greater 
emissions of volatile organic compounds even in those countries where Stage II PVR 
controls are already implemented. As such, 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  technical  specifications  to  improve  the 
functioning of the internal market in such goods. Action is therefore necessary at the 
Community  level.  However,  only  minimum  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.  The  most  important  parameters  are  the 
operational efficiency of vapour recovery and the in-service reliability. 

3. 

OBJECTIVES 

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  significant  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. 

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health and the environment31. It is also called for a thematic strategy on air pollution 
with a view to attaining long term objectives of no-exceedence 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  annually  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 km2 of forest was at risk from damage 

–  that damage to commercial crops amounted to approximately €2.8 billion annually 

in 2000. 

The Thematic Strategy also proposed new targets 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 obligation 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 Recovery (ORVR) in passenger cars and 
light commercial vehicles. 

(3) 

Install PVR Stage II equipment at  

31 

32 

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. 
Article 7(2)(f) of the Sixth Environmental Action Programme. 

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(a) 

(b) 

(c) 

(d) 

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

Option (a) and larger existing stations (i.e. with a throughput in excess 
of 3000 m3 per annum) by end of 2020 

Option  (b)  and  service  stations  situated  in  or  under  residential 
accommodation. 

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). 

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 transported across national 
borders.  The  Commission  has  also  recognised  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 implemented 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 considering 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 emissions of petrol vapour whilst the vehicle stands at rest 
(so  called  "diurnal"  emissions).  These  vapours  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  European  cars  as  well  as  appropriate  piping, 
valves  and  vapour  controls  systems.  Naturally,  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. However, 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 

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Any introduction of ORVR systems could only be applied to new vehicles. It would 
not  be  possible  to  retrofit/re-engineer  the  vapour  systems  of  existing  vehicles.  As 
such,  the  effectiveness  of  any  ORVR  system  would  depend  upon  the  rate  that  new 
ORVR-equipped  vehicles  entered 
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  fleet  renewal,  then  the  full  benefit  of  the 
ORVR  system  can  only  be  delivered  some  20  years  after  any  new  regulation  is 
adopted. 

the  fleet.  If  one  considers 

(3) 

Costs & performance 

No detailed analysis of ORVR costs has been 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% worse 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 dispensers and conventional Stage II equipment 
have the advantage of having been standardised 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 ORVR34. 

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  adsorb  the  hydrocarbons  until  the  vehicle  is 
driven and the hydrocarbons can be combusted 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  current  position  in  the  EU)  because  of  the 
stricter diurnal emissions limits in the USA. This may explain why the US regulators 
have  opted  for  ORVR  rather  than  nationwide  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 vehicles 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 harmonised with those in the US and elsewhere35. 
If  an  when  such  a  tightening  of  the  regulated  limits  on  evaporative  emissions  is 
considered,  the  incremental  step  of  proceeding  to  "full"  ORVR  could  also  be 
considered  as  a  complement  or  replacement  for  Stage  II  PVR  controls  at  service 

33 

34 
35 

Chem Systems Ltd. "Gasoline Vapour Recovery Costs", Report prepared for the UK Department of the 
Environment, 1994. 
Page 7 ("Carbon Cannisters") of the UK's Regeulatory Impact Assessment, November 2005. 
Communication  on  the  application  and  future  development  of  Community  legislation  concerning 
vehicle  emissions  from  light  duty  vehicles  and  access  to  repair  and  maintenance  information  (Euro  5 
and 6): 2008/C 182/08: OJ C 182, 19.7.2008, p. 17. 

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stations.  Naturally  any  decision  would  be  preceded  by  an  impact  assessment  that 
would  consider  the  costs  and  benefits  particularly  those  costs/benefits  of  Stage  II 
controls still to be incurred. 

5. 

ASSESSMENT OF PVR STAGE II OPTIONS 

5.1. 

Assumptions and methodology to estimate costs for Stage II PVR costs 

The  approach  taken  to  assess  the  costs  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 report prepared from the Commission. It takes information 
about the size and number of petrol service 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 calculations. 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  efficiency  of  Stage  II  equipment;  and  (iv)  the 
economic  value  of  the  recovered  petrol  product.  These  are  discussed  more  fully 
below.  In  all  cases  the  same  assumptions  were  used  throughout  to  compare  the 
various options. 

5.1.1.  Cost elements for individual service stations 

Relevant  cost  elements  in  this  analysis  are  the  necessary  additional  or  incremental 
(annualised)  costs  of  introducing  PVR  Stage  II  controls  over  and  above  those 
associated with the new build or refurbishment. For  example, there  will need to be 
new  dispensers  and  associated  equipment  for  a  new  construction  or  major 
refurbishment regardless of whether PVR Stage II controls are applied. Only the cost 
differences directly associated with Stage II PVR are included in the analysis. 

The key cost elements of introducing Stage II are: 

–  Capital  costs  for  above-ground  equipment,  including  appropriately  equipped 
dispensers  containing  vapour  return  pumps,  as  well  as  vapour  recovery  nozzles, 
coaxial hoses and other equipment; 

–  Capital  costs  for  installing  the  required  below-ground  pipe  work,  including  a 
vapour  return  line  to  the  underground  storage  tank  (only  for  conventional 
technology); 

–  Additional costs of digging up petrol station forecourts at existing petrol stations 
where installation is not undertaken as part of a planned knock-down and rebuild 
programme (only for conventional technology); 

–  Additional ongoing maintenance and testing costs of PVR Stage II equipment as 
compared to standard equipment. In particular, the requirement for a regular check 

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on the volumetric ratio - with associated adjustments if required - is considered to 
be essential to ensuring that 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 costs 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 scheduled 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  unscheduled  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  unscheduled  installation  of  underground 

pipework 

The actual values assumed are that 15 % of service station sites have the necessary 
existing pipe work already installed, and that 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  assessment  is  based  upon  that  from  the  DEFRA 
regulatory  impact  assessment  following  an  evaluation  by  the  Commission's 
consultant which considered them to be more comprehensive, more recent and more 
transparent particularly after 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  assumption.  Retrofitting 
dispensers is significantly cheaper than replacing the dispenser due to non scheduled 

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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  organisations)  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  necessary  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 for all below-ground equipment (equalling the 
assumed  replacement  rate  of  petrol  stations),  and  5  years  for  all  above-ground 
equipment. The regulatory impact assessment 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 2nd 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  efficiency  in  practical  use.  Whilst  ENTEC 
assumed  a  recovery  efficiency  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 requires 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  the  regulatory  efficiency  is  linked  through  to  the  type-
approval/certification process. So that in Germany, the regulated 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  industry37 
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 
37 

At least for sites with an annual throughput greater than 3000 m3 
Response from CONCAWE, the Environmental and Heath & Safety Organisation representing the EU's 
oil industry. 

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5.1.5.  Economic value of recovered product & taxation 

The vapour which is displaced during refuelling resides initially in the petrol tank of 
the motorist (consumer). So although the consumer effectively loses some petrol this 
would otherwise be accepted without question by the motorist. The economic value 
arises because the emitted vapour is recovered and recycled. 

When discussing the costs of the two different 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  takes  the  approach  of  maximising  social 
welfare and so the analysis must exclude the level of any taxes levied 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 these effects varies according to the type of 
technology used but it can also vary according to national taxation policies.  

The  simplest  situation  concerns  the  Conventional  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 economic value of the recovered product is 
simply  the  retail  price  of  the  petrol  (excluding  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 cooled, 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  usual  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  benefit  as  part  of  the  regulatory  impact 
assessment accompanying the introduction of national 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 and opposite cost to society. However, this is 
unclear  given  that  national  authorities  have  previously  already  taxed  the  petrol 
delivered to the service station and so there 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 again be the retail price. Here national tax revenues may 
be increased because of At Pump Stage II PVR equipment. 

In the analyses presented here, costs are presented 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 station operators given that tax forms well over 
50% of the forecourt price of petrol. 

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5.2. 

Benefits 

A simplified approach to the calculation of benefits has been taken. This necessarily 
ignores  the  important  benefits  for  (1)  human  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 Air For Europe Programme38. Simplified damage cost functions 
were  developed  expressed  as  a  monetary  figure  per  tonne  of  pollutant  emitted. 
Mortality and morbidity have been treated for health. The range of unit values arises 
because  of  the  different  approaches  to  monetise  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  function  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 service stations and at existing 
stations  with  a  throughput  of  petrol  greater  than  500  m3  per  annum  as  part  of  a 
planned refurbishment. 

Obviously  there  is  little  benefit  environmentally in installing Conventional Stage II 
vapour  recovery  at  a  service  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 apply to stations with an annual throughput 
of  less  than  100  m3.  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) 

Total cost 

Annualised cost (2020) 

12 141 

€ 179.5 m 

€ 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 value of recovered petrol (2020) 

€ 11.1 m 

38 

"Damages per tonne emission of PM2.5, NH3, SO2, NOx and VOCs from each EU25 Member State and 
surrounding areas" AEA Technology March 2005. (as part of the service contract for carrying out cost-
benefit analysis of air quality related issues in particular in the Clean Air for Europe Programme. 

EN 

19 

   EN 

 
                                                 
Cost effectiveness including retail value 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  impacts  of  benzene  on  human  health  and  the  impacts  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) 

Total cost 

Annualised cost (2020) 

12 141 

€ 209.5 m 

€ 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 value of recovered petrol (2020) 

€ 13.8 m 

Cost effectiveness including retail value 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  impacts  of  benzene  on  human  health  and  the  impacts  of  ozone  on  forests  and  the  natural 
environment. NB the value of petrol recovered inclusive of tax is not relevant for the Conventional PVR system 
as the vapour is returned to the oil refinery terminal 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 fitted 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 proportionately greater contribution to overall 
emissions. The largest size category of service 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 any given year. Assuming legislation would 
enter into force in 2013, it could 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 

20 

   EN 

 
Petrol vapour abated in 2020 (tonnes) 

Total cost 

Annualised cost (2020) 

17 769 

€ 317.4 m 

€ 31.95 m 

Cost-effectiveness excluding value of recovered petrol 

€ 1798/tonne 

Value of recovered petrol (retail value excluding tax in 2020) 

€ 11.1 m 

Nett annualised cost including retail value of recovered petrol (2020) 

€ 20.8 m 

Cost effectiveness including retail value 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  impacts  of  benzene  on  human  health  and  the  impacts  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) 

Total cost 

Annualised cost (2020) 

17 769 

€ 389 m 

€ 38.4 m 

Cost-effectiveness excluding value of recovered petrol 

€ 2160 /tonne 

Value of recovered petrol (retail value excluding tax in 2020) 

€ 11.1m 

Nett annualised cost including retail value of recovered petrol (2020) 

€ 27.2 m 

Cost effectiveness including retail value 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  impacts  of  benzene  on  human  health  and  the  impacts  of  ozone  on  forests  and  the  natural 
environment. NB the value of petrol recovered inclusive of tax is not relevant for the Conventional PVR system 
as the vapour is returned to the oil refinery terminal and not recycled to the petrol dispenser. 

5.5. 

Option 3(c) – Stage II PVR at all stations 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  benefit  of  these  Stage  I  controls  would  be  maximised  if 
Stage II PVR controls are also installed at the same service stations.  

Unfortunately, there are no statistics on the number of service stations integrated into 
residential accommodation and so  it is difficult to quantify total costs for requiring 

EN 

21 

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Stage II controls to be fitted. However, from the COWI study it is possible to derive 
an approximate estimate of the costs of fitting Stage II controls to a station with one 
fuel dispenser (4 nozzles) with a throughput of 500 m3 or less which ought to be a 
useful  surrogate  for  the  cost  of  installing  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. 

Cost-effectiveness (€/tonne) 

Conventional 

At Pump 

Without  retail  value  of  recovered 
petrol of €0.4 per litre 

Including  retail  value  of  recovered 
petrol of €0.4 per litre 

Scheduled  Unscheduled  Scheduled 

Unscheduled 

1890 

5452 

1500 

3370 

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  public  consultation,  CONCAWE  stated  that  it 
was  about  to  publish  a  report  concerning  worker  exposure  to  benzene  in  the 
downstream  oil  industry.  This  report  concludes  "that  in  certain  circumstances  the 
contribution of uncontrolled refuelling emissions to ambient benzene concentrations 
can  be  significant  in  terms  of  the  air  quality  limit  value  for  benzene"  and  that 
"refuelling  emissions  can  result  in  general  population  exposures,  at  least  during 
certain peak periods, above 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 stations 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  unscheduled  retrofit.  As  such,  the  preferred 
option would be to insist on installing Stage 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 installed. However, in its response to the 
public  consultation,  the  Umweltbundesamt  stated  that  in  the  late  1990s  up  50%  of 
systems tested in Germany were non-compliant. 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  necessary  inspections  to  ensure  correct 
functioning39. 

39 

ENTEC Report pages 22 – 25. 

EN 

22 

   EN 

 
                                                 
Checking of the performance on installed equipment can be carried out periodically 
and a period of every one to two years seems to be common. Alternatively, automatic 
"real-time" monitoring can be required which has the advantages of permitting self-
calibration/fine tuning of the equipment whilst in operation and also lengthening the 
period between inspections and thereby reducing inspection & maintenance costs for 
the station operator (c.f. an inspection cost of c.a. €200-250 per dispenser). 

Since  2003,  Germany  has  mandated  automatic  monitoring  and  doubled  the  period 
between  inspections  of  Stage  II  equipped  dispensers  to  two  years.  German 
Authorities estimated that the cost to retrofit each dispenser is of the order of €2000. 
New equipment is likely to be less than this although no firm estimates are available. 
The  European  Oil  industry  points  to  the  fact  that  the  newer  generation  of  Stage  II 
equipment is more reliable and that simpler fault detection procedures are possible at 
one tenth the cost of "traditional" automatic monitoring. 

The justification for automatic monitoring is not clear-cut and such monitoring is not 
required in many of those Member States where Stage II PVR controls are already in 
place. What is clear is that those operators who have installed automatic monitoring 
usually benefit from a longer period between mandatory inspections as part of their 
operating permit or licence. 

5.7. 

Sensitivity of cost estimates 

The COWI study looked at the impacts of changes in assumptions on the calculation 
of  costs.  The  following  table  gives  a  clear  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*  

10 year lifetime for above ground equipment* 

5 year lifetime for above ground equipment* 

Collection efficiency of 80%** 

Collection efficiency of 90%** 

All high cost assumptions 

All low cost assumptions 

1140 

1546 

2787 

1681 

1425 

2282 

809 

915 

1326 

2574 

1448 

1217 

1974 

677 

*  Assuming  a  collection  efficiency  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  sources.  This  information  is  taken  from  the 
GAINS  integrated  assessment  model  developed  by  the  International  Institute  of 
Applied  Systems  Analysis  which  contains  comprehensive  information  on  air 

EN 

23 

   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 

Incineration of VOCs in coil coating 

Hydrocarbon machine in textile dry cleaning 

Activated carbon absorption in Industrial adhesives application 

Improved application gunwash in vehicle refinishing 

Water based inks in screen printing 

Water based adhesives 

Inks used in Packaging – enclosure and activated carbon absorption 

Stripping and vent gas treatment in PVC manufacture 

Wood treatment – activated carbon absorption 

Water based inks and enclosure and carbon absorption 

Water based inks and enclosure and incineration 

Substitution of products in rubber synthesis 

Substitution in vehicle refinishing sector 

Wood treatment vacuum impregnation & incineration 

Substitution of vehicle refinishing paints & incineration 

Domestic solvents reformulation 

Textile dry cleaning activated carbon absorption 

Closed solvent degreasing with HF and activated charcoal absorption 

5.9. 

Administrative costs 

80 

220 

340 

420 

550 

660 

695 

1000 

1150 

1340 

1600 

1850 

2300 

3400 

4000 

6000 

12000 

20000 

62000 

Due  to  the  hazardous  nature  of  petrol  and  petrol  dispensing  facilities  and  the  legal 
requirement to apply the Petrol Stage I PVR directive 94/63/EC, the Member States 

40 

http://www.iiasa.ac.at/rains/gains-online.html?sb=9  

EN 

24 

   EN 

 
                                                 
are all likely to have in place a system of permitting which authorises the operation 
of  service  station  activities.  As  such,  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  specifications  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 approximately 17,700 additional service stations 
that  would  be  affected  by  any  new  legislation.  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  unmanned  service  stations.  For  the  smallest 
service  stations  with  a  throughput  of  500  m3  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.  Since  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 noticeable 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  maintenance.  The  minimum  harmonised  technical 
standards should also make it easier for original equipment manufacturers to supply 
into other Member States from those in which they are established. The impacts of 
these  positive  benefits  have  not  been  quantified  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  equitable  distribution  of  societal  burdens  and 
benefits  with  specific  emphasis  on  exposure  to  environmental  toxicants41.  This  is 

41 

Air Quality Guidelines – Global Update 2005. World Health Organisation Europe 2006, p. 136. 

EN 

25 

   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  local  sources,  urban  sub-populations  exist  that  have  consistently 
higher  exposure  to  ambient  pollution  and  that  these  areas  of  high  exposure  often 
lower 
coincide  with 
socioeconomic position may also be more responsive to air pollution and have lower 
baseline health status41. 

lower  socioeconomic  position.  Moreover,  groups  of 

In  relation  to  industrial  emissions  to  air  and  water  in  the  UK,  Friends  of  the  Earth 
determined  that  82%  of  carcinogenic  emissions  are  in  the  20%  most  deprived 
localities43.  An  analysis  of  the  London  Congestion  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 proportionately greater benefits in these 
deprived areas44. 

Service  stations  are  more  likely  to  be  distributed  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 accommodation is likely to be less costly and 
attract the more economically disadvantaged. 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 irrespective of how large these 
stations are. Conversely, Stage II PVR controls at service stations close to or under 
residential  accommodation  are  likely  to  deliver  greater  benefits  to  those  in  lower 
socioeconomic  groups  which 
the  principle  of 
environmental equity.  

is  entirely  consistent  with 

5.11.  Workers' health & safety 

Those working at or close to service stations constitute a group likely to experience a 
greater accumulated exposure to benzene than the general public. Such workers will 
be  in  a  similar  position  to  those  who  reside  in  accommodation  built  above  or  very 
close to service stations and who will benefit from the application of Stage II PVR 
controls at service stations. 

6. 

COMPARISON 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 

43 

44 

EN 

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. 
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 
Congestion Charge has modest impact on the life expectancy of Londoners; London School of Hygiene 
& 
2008. 
www.lshtm.ac.uk/news/2008/congestioncharge.html.  

University 

Medicine, 

February 

Tropical 

London, 

of 

26 

   EN 

 
                                                 
(tonnes) 

Excluding 
recovered 
petrol 

Including 
retail value 
of recovered 
petrol 

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 

1540 

1760 

1798 

2160 

915 

11.1 [11.5-34.0] 

1140 

13.8[11.5-34.0] 

1171 

20.8 [16.9-49.7] 

1533 

27.2 [16.9-49.7] 

3c (At pump) 

not calc. 

not calc. 

 Est. 1500 

Est. 960 

3c (conventional) 

not calc. 

not calc. 

Est. 1890 

Est. 1340 

not calc. 

not calc. 

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) 

The  preferred  option  is  Option  3(c)  which  would  (i)  apply  to  new  and  refurbished 
stations above 500m3 throughput; (ii) require retrofitting of existing stations above a 
throughput of 3000 m3 by 2020; and (iii) require all new or substantially refurbished 
stations  situated  under  residential  accommodation  to  equip  with  Stage  II  controls 
irrespective of size.  

It is clear that obliging the larger existing stations 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.  Option  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  directly  the  costs  associated  with  Option  3(c), 
where  all  stations  in  residential  accommodation  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 unscheduled 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  thirds  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 that can deliver as well. This conclusion 
was supported by the findings of ENTEC report which determined a 50% worsening 

EN 

27 

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in  cost-effectiveness  for  the  mandatory  inclusion  of  automatic  monitoring45. 
However,  given  the  increased  probability  of  reliable  in-service  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 Community air quality objectives. Non-compliance 
with legal air quality requirements is enforced pursuant to existing Treaty provisions. 
Member States will need to transpose the 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 transposing measures. Monitoring of Member States' 
progress can be gauged from the emission inventory reports that they are obliged to 
compile and submit to the Commission (and the Convention on Transboundary Air 
Pollution)  pursuant  to  the  national  emissions  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 

28 

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Annex I  
Status of Stage II PVR Implementation 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 

Belgium 

Brussels  Region:  Controls  apply  to  all  service  stations  by  2007  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. 

Cyprus 

No legislation but stations generally fit appropriate underground pipe work 

Czech 
Republic 

Controls apply to all stations by 2004 

Denmark 

Controls apply to all stations with petrol throughput greater than 500m3 by 2000 

Estonia 

No legislation 

Finland 

No legislation 

France 

Controls apply to all new stations greater than 500m3 petrol throughput by 2001 and existing stations 
with throughput greater than 3000m3 by 2002 

Germany 

Controls apply for all new and existing stations greater than 1000m3 petrol throughput by 1997 

Greece 

No legislation 

46 

http://www.eea.europa.eu/highlights/more-eu-member-states-to-miss-2010-air-pollutant-limits  

yes 

yes 

yes 

yes 

No 

yes 

yes 

No 

yes 

yes 

Ratified (yes) 

Ratified (yes) 

Non-signatory 

Ratified (yes) 

Ratified (yes) 

Ratified (no) 

Ratified (no) 

Ratified (yes) 

Ratified (yes) 

Signatory only 

EN 

29 

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 stations with throughput greater than 100m3 by 2003 

Ireland 

No legislation 

Italy 

Controls apply to all petrol stations by 2000 

Latvia 

Controls apply to all new stations from 2000 

Lithuania 

Controls apply to all new stations with a throughput greater than 100m3 (500m3 in rural areas) and all 
stations by 2007. 

Luxembourg  Controls apply to all petrol station by January 2005 

Malta 

No legislation 

Netherlands 

Controls apply to all stations with throughput greater than 500m3 by 1999 

Poland 

Controls apply to all service stations with throughput greater than 100m3 by 2005 

Portugal 

No legislation 

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. 

Slovenia 

Legislation applies to all new and refurbished stations 

Spain 

No legislation 

Sweden 

Controls apply to all stations with throughput greater than 100m3 by 1995 though exemptions can be 
granted for rural stations with a throughput less than 300m3. 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

yes 

no 

no 

yes 

yes 

no 

yes 

Ratified (yes) 

Non-signatory 

Ratified (yes) 

Non-signatory 

Ratified (yes) 

Ratified (yes) 

Non-signatory 

Ratified (yes) 

Non-signatory 

Signatory only 

Ratified (yes) 

Non-signatory 

Ratified (no) 

Ratified (yes) 

EN 

30 

EN 

 
  
Country 

Details of Stage II PVR controls 

UK 

Controls will be applied to all new stations and existing stations with a throughput greater than 3500m3 
from January 2010. New stations with throughputs less than 500m3 are exempt. 

Bulgaria 

No legislation but most stations have controls in place 

Romania 

No legislation 

Croatia 

No legislation 

European 
Community 

n/a 

.

Expected 
compliance with 
NECD ceiling for 
VOCs in 201046 

Status w.r.t. UNECE 
VOC protocol 
(compliance in respect 
of Stage II) 

yes 

yes 

yes 

n/a 

yes 

Ratified (yes) 

Ratified (no) 

Non-signatory 

Non-signatory 

Signatory only 

EN 

31 

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 

Belgium 

Cyprus* 

2900 

3400 

250 

Czech Republic 

2150 

Denmark 

Estonia* 

Finland 

France 

Germany 

Greece 

Hungary 

Ireland 

Italy 

2100 

500 

2050 

13600 

15250 

8200 

1600 

1850 

22500 

- 

- 

84% 

91% 

91% 

Latvia* 

Lithuania* 

590 

625 

Luxembourg 

280 

Malta* 

80 

Netherlands 

3700 

- 

Poland 

80% 

Portugal 

- 

Slovakia* 

84% 

Slovenia* 

Spain 

Sweden 

UK 

- 

- 

- 

- 

6700 

2350 

780 

420 

8700 

4000 

9800 

Croatia* 

600 

53% 

- 

- 

- 

- 

- 

- 

94% 

90% 

- 

- 

90% 

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 

< 1000 

< 1500 

< 2000 

< 2500 

< 3000 

< 4000 

< 5000 

> 5000 

10.7% 

21.5% 

32.2% 

41.4% 

50.5% 

59.6% 

71.7% 

83.6% 

16.4% 

26.9% 

41.2% 

55.5% 

64.3% 

73.1% 

82.0% 

88.5% 

95.0% 

5.0% 

EN 

32 

   EN 

 
 
Annex III 
Costs of Stage II Petrol Vapour Recovery 

Conventional System 

Annual throughput (m3) 

Assumed number of dispensers  
Number of nozzles per dispenser  

0 - 500 
1 
4 

500 - 1000 
2 
4 

1000 - 2000 
3 
4 

2000-3000 
4 
4 

3000+ 
6 
4 

Supplementary materials and labour 

Unscheduled installation of underground pipe work 
Underground pipework 
Surround to pipework 
Tank connections and valves  
Trench excavation for vapour 
recovery pipework 
Remove pumps and replace  
Installation of vapour recovery 
equipment  
Unscheduled total 

4,860.00 
405.00 
494.10 
5,670.00 

405.00 
486.00 

12,320.10 

5,265.00 
810.00 
988.20 
6,075.00 

810.00 
972.00 

6,075.00 
1,215.00 
1,490.40 
6,885.00 

1,215.00 
1,458.00 

7,290.00 
1,620.00 
1,992.60 
8,100.00 

1,620.00 
1,944.00 

8,910.00
2,430.00
2,972.70
12,150.00

2,430.00
2,916.00

14,920.20 

18,338.40 

22,566.60 

31,808.70

Scheduled installation of underground pipe work 
Underground pipework 
Surround to pipework 
Tank connections and valves  
Trench excavation for vapour 
recovery pipework 
Remove pumps and replace  
Installation of vapour recovery 
equipment  
Scheduled total,  

1,344.60 
324.00 
494.10 
0.00 

405.00 
486.00 

2,608.20 

1,393.20 
567.00 
988.20 
0.00 

810.00 
972.00 

1,458.00 
810.00 
1,490.40 
0.00 

1,215.00 
1,458.00 

1,558.44 
1,296.00 
1,992.60 
0.00 

1,620.00 
1,944.00 

1,934.28
1,944.00
2,972.70
0.00

2,430.00
2,916.00

3,839.40 

5,094.90 

6,629.04 

9,523.98

Existing pipework at hand  
Underground pipework 
Surround to pipework 
Tank connections and valves  
Trench excavation for vapour 
recovery pipework 
Remove pumps and replace  
Installation of vapour recovery 
equipment  
Existing pipework total  

New dispenser (unscheduled) 
Dispenser  
Vapour recovery equipment  
Nozzle  
New dispenser - total  

New dispenser (scheduled) 
Dispenser  
Vapour recovery equipment  
Nozzle  
New dispenser - total  

Retrofit to existing dispenser  
Dispenser  
Vapour recovery equipment  
Nozzle  

0.00 
0.00 
494.10 
0.00 

405.00 
486.00 

0.00 
0.00 
988.20 
0.00 

810.00 
972.00 

0.00 
0.00 
1,490.40 
0.00 

0.00 
0.00 
1,992.60 
0.00 

1,215.00 
1,458.00 

1,620.00 
1,944.00 

0.00
0.00
2,972.70
0.00

2,430.00
2,916.00

939.60 

1,879.20 

2,826.90 

3,774.60 

5,645.70

Costs of PVR Stage 2 equipment 

10,484.32 
2,930.40 
2,326.56 
15,741.28 

20,968.64 
5,860.80 
4,653.12 
31,482.56 

31,452.96 
8,791.20 
6,979.68 
47,223.84 

41,937.28 
11,721.60 
9,306.24 
62,965.12 

0.00 
2,930.40 
2,326.56 
5,256.96 

0.00 
3,984.16 
2,344.32 

0.00 
5,860.80 
4,653.12 
10,513.92 

0.00 
8,791.20 
6,979.68 
15,770.88 

0.00 
11,721.60 
9,306.24 
21,027.84 

0.00 
7,968.32 
4,688.64 

0.00 
11,952.48 
7,032.96 

0.00 
15,936.64 
9,377.28 

0.00
23,904.96
14,065.92

62,905.92
17,582.40
13,959.36
94,447.68

0.00
17,582.40
13,959.36
31,541.76

EN 

33 

   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  
Incremental power 
Total "m&p" costs  

249.13 
7.40 
256.53 

337.93 
14.80 
352.73 

426.73 
22.20 
448.93 

515.53 
29.60 
545.13 

693.13
44.40
737.53

"At pump" System 

Annual throughput (m3) 
Assumed number of dispensers  
Number of nozzles per dispenser  

0 - 500 

500 - 1000 
2 
4 

1 
4 

1000 - 2000 

2000-3000 

3000+ 

3 
4 

4 
4 

6
4

Supplementary materials and labour 

System using new technology (Regardless of new, scheduled or unscheduled)  
1,458.00 
Installation of vapour recovery 
equipment  
New technology total  

1,458.00 

972.00 

486.00 

972.00 

486.00 

1,944.00 

2,916.00

1,944.00 

2,916.00

New dispenser (unscheduled) 
Dispenser  
Vapour recovery equipment  
Nozzle  
New dispenser (unscheduled), total  

New dispenser (scheduled) 
Dispenser  
Vapour recovery equipment  
Nozzle  
New dispenser (scheduled), total  

Retrofit to existing dispenser  
Dispenser  
Vapour recovery equipment  
Nozzle  
Retrofit to existing dispenser, total  

Costs of PVR Stage 2 equipment 

10,484.32 
2,960.00 
2,326.56 
15,770.88 

20,968.64 
5,920.00 
4,653.12 
31,541.76 

31,452.96 
8,880.00 
6,979.68 
47,312.64 

41,937.28 
11,840.00 
9,306.24 
63,083.52 

62,905.92
17,760.00
13,959.36
94,625.28

0.00 
2,960.00 
2,326.56 
5,286.56 

0.00 
5,920.00 
4,653.12 
10,573.12 

0.00 
8,880.00 
6,979.68 
15,859.68 

0.00 
11,840.00 
9,306.24 
21,146.24 

0.00
17,760.00
13,959.36
31,719.36

0.00 
4,440.00 
2,344.32 
6,784.32 

0.00 
8,880.00 
4,688.64 
13,568.64 

0.00 
13,320.00 
7,032.96 
20,352.96 

0.00 
17,760.00 
9,377.28 
27,137.28 

0.00
26,640.00
14,065.92
40,705.92

Recurring costs (per year - dependent on number of dispensers) 

Maintenance and power costs 
Incremental maintenance and tests  
Incremental power  
Total "m&p" costs 

249.13 
7.40 
256.53 

337.93 
14.80 
352.73 

426.73 
22.20 
448.93 

515.53 
29.60 
545.13 

693.13
44.40
737.53

EN 

34 

   EN