WASHINGTON ? NACS and a host of other industry organizations filed joint comments with the U.S. Environmental Protection Agency (EPA) urging regulations that would promptly and completely remove requirements for Stage II vapor recovery at retail fuel facilities. In July, the agency proposed rules that would allow for elimination of the requirements after June 30, 2013, once on-board vehicle vapor refueling (ORVR) systems are found to be in widespread use in the nation.�
NACS?s comments focused on provisions in the rule that could limit the elimination of Stage II requirements in certain areas and delay their elimination in others.
First, the rule requires states to revise their air quality implementation plans (SIPs) to remove their Stage II requirements once ORVR is in widespread use. The process to revise SIPs is burdensome and costly, especially at a time when states are struggling financially. NACS is concerned that such a process could impede the prompt elimination of Stage II requirements and therefore urged EPA to make removal of Stage II requirements self-enacting upon the ORVR widespread use date of June 30, 2013. Such an action would spare the states the burden of revising their SIPs and provide retailers with immediate resolution of the Stage II requirements.
Second, NACS is concerned that retailers who may seek to construct new sites between now and June 30, 2013, will be required to invest in costly Stage II systems that will be rendered obsolete in less than two years. NACS asked EPA to provide an exemption to new construction facilities to avoid this unnecessary expense.
Finally, NACS expressed concern that EPA regulations affecting the ozone transport region (OTR), which stretches from Virginia to Maine, may result in those states not being able to eliminate Stage II requirements even after ORVR is in widespread use. A prior interpretation by the agency would not allow states to use ORVR as a substitute for Stage II.�NACS urged EPA to reconsider that interpretation and allow these states, which represents a significant percentage of the retail facilities subject to Stage II requirements, to eliminate Stage II provisions. In addition to the costs associated with this requirement, NACS noted that using Stage II systems with vehicles equipped with ORVR may in fact reduce the overall emissions benefits that could be achieved using either system alone.
EPA will review the comments submitted by NACS and all other stakeholders. A final rule is expected later this year or in early 2012.
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