1. Stage II Vapor Recovery Update SIP Steering Committee Meeting April 13, 2011

2. On-Board Vapor Recovery Clean Air Act (CAA) requires newer cars have an on-board vapor recovery system (ORVR); phased in for 1998 and newer vehicles CAA says EPA may eliminate requirement for states to maintain Stage II when EPA determines that ORVR is in “widespread use” EPA has not determined w hat level of ORVR fleet penetration constitutes “widespread use” 2

3. Widespread Use (WSU) Guidance WSU guidance has been discussed for years; EPA is expected to issue a proposed rule by mid-2011 Each state makes its own decision if and when to eliminate its Stage II program based on: – EPA’s WSU parameters – State’s vehicle fleet characteristics – Benefits/costs of keeping Stage II to capture vapors from older vehicles that do not have ORVR – Dis-benefit of “incompatible” Stage II systems 3

4. “Incompatible” Stage II Systems 2 types of Stage II systems: vapor balance and vacuum assist – Use of vacuum assist systems with ORVR- equipped cars creates excess emissions ; more vapors are released than if there was just ORVR – Results in an earlier “crossover year” - the year when Stage II is no longer getting air quality benefits – MA has a substantial number of vacuum assist systems 4

5. State Analysis MassDEP beginning analysis of Stage II for MA fleet in anticipation of EPA WSU proposal Requires analysis of: fleet characteristics; fleet turnover; % vacuum assist systems; use of an incompatibility “excess emission factor” Looking at potential for Stage I enhancements ( also part of OTC control measures review ) Evaluating Stage II decommissioning requirements 5

6. EPA’s Partial Widespread Use Guidance 2006 - EPA issued WSU guidance for rental car facilities If rental facility certifies to the state that 95% of the vehicles refueling at its facility have ORVR, then WSU use is met States are free to amend their Stage II regulations and SIPs to incorporate an exemption for rental car facilities 2007 guidance – EPA extended policy to apply to other corporate/commercial fleets 6

7. MassDEP Proposed Revisions to Stage II Massport requesting an exemption from Stage II for new Logan Airport rental car facility Consistent with EPA’s limited WSU guidance for fleets that can certify 95% of vehicles have ORVR MassDEP expects to propose regulation to exempt rental car, corporate/commercial fleets covered by EPA’s WSU guidance from Stage II Reviewing potential for Stage I enhancements as a condition of exemption Looking at decommissioning requirements for existing facilities 7