NAFA Supports Proposed Ruling Regarding Onboard Refueling Vapor Recovery
NAFA plays an active role in presenting the collective voice of the fleet manager. On August 23, Phil Russo, CAE, NAFA’s Executive Director, sent a letter to the Environmental Protection Agency to express the Association’s support for the proposed rule outlining criteria for determining whether on-board refueling vapor recovery ("ORVR") is in widespread use for purposes of controlling motor vehicle refueling emissions throughout the motor vehicle fleet.
Automakers were required to install ORVR on one hundred percent of new passenger cars beginning in 2000; and to install ORVR on one hundred percent of new light-duty trucks and vans (less than 6000 lbs gross vehicle weight rating or GVWR) beginning in 2003. Based on a recent survey of more than two hundred NAFA Members, the overwhelming number of corporate and public fleet vehicles have been put into service since the point in time when one hundred percent of vehicles were to be equipped with ORVR. According to survey results, eighty-nine percent of corporate fleets and fifty percent of public fleet vehicles were less than six years old. This reflects that most fleets adhere to a strict replacement policy that, by this point in time, has taken the older vehicles not equipped with ORVR out of service.
The high percentage of fleet vehicles equipped with ORVR supports EPA’s determination of ORVR widespread use and a general waiver of the Stage II requirement effective nationwide on June 30, 2013.
In a letter sent to Lisa P. Jackson, EPA Administrator, Russo wrote, "Many NAFA Members maintain central fueling facilities to dispense gasoline for vehicles required to be equipped with ORVR, including passenger cars, light trucks and complete heavy-duty gasoline-powered vehicles under 10,000 lbs GVWR. As such, these facilities are currently required to use Stage II vapor recovery systems.
"We agree with EPA’s assessment that the use of ORVR is significant in the national motor vehicle fleet and that ORVR widespread use will occur by the mid-point in the 2013 calendar year. Because corporate and public fleet vehicles are typically newer, the use of ORVR is even greater in centrally-fueled fleets. Fleet penetration of ORVR exceeds EPA’s estimate that that ORVR-equipped vehicles comprise approximately sixty-four percent of the in-service vehicle fleet nationwide and account for around seventy-four percent of the vehicle miles traveled in the nationwide fleet."
NAFA, however, is concerned regarding the effect of the proposed regulation on refueling facilities in the ozone transport region (OTR). States in the OTR are subject to a separate Stage II-related requirement. Under CAA section 184(b)(2); all areas in the OTR must implement either Stage II or measures that achieve "comparable" emissions reductions. This independent requirement is not affected by any widespread use determination or waiver of the Stage II requirement. Thus, unless areas in the OTR implement measures that achieve "comparable" emission reductions, they appear to still remain obligated to require Stage II vapor recovery controls.
"We are concerned that under the Agency’s current interpretation of Section 184(b)(2) of the Clean Air Act (’CAA’), refueling stations in the OTR may be unable to avail themselves of the Proposal’s benefits. Accordingly, we urge the EPA to (a) revise its interpretation of Section 184(b)(2) to permit ORVR to be recognized as an emission reduction measure considered ’comparable’ to Stage II, and (b) delay the deadline for comments on the Proposal to at least one month after the Agency revises its interpretation," continued Russo.
This letter is another example of how NAFA’s legislative team in Washington, D.C. and Ottawa strengthen the voice of the fleet management industry, playing an active role in helping shape pending legislation and keeping the Association’s membership up-to-date on pertinent rules and regulatory changes.
To view the letter that was sent to the EPA, visit this location at NAFA.org.