Removal of Stage II Gasoline Vapor Recovery Program Requirements
2024-02-09 2024-02-09
EPA-R03-OAR-2022-0790-0009 EPA-R03-OAR-2022-0790-0010
05:00:00 05:00:00
https://api.regulations.gov/v4/comments/EPA-R03-OAR-2022-0790-0009 https://api.regulations.gov/v4/comments/EPA-R03-OAR-2022-0790-0010
Anonymous Anonymous
Anonymous Anonymous
I do not agree with the proposal to remove requirements for VRS in DC. Washington DC is a city, and cities have already been proven to cause increased exposure to pollutants. Relaxing the restrictions on air quality cannot possibly be in the best interest of public health, and this proposal leads me to believe that economic and technological factors were considered as well. Even if it truly has been proven not to affect attainment, this proposal will definitely negatively affect the air quality in D.C.According to A Method for Determining In-Use Efficiency of Stage II Vapor Recovery Systems, the research found that the estimated efficiency of these systems was between 81% and 93%, when compared to other conventional methods. With efficiency this high, it seems that this is not a factor driving their removal.   In the Final Rule Determining Widespread Use of Onboard Refueling Vapor Recovery and Waiver of Stage II Requirements, the EPA states that Removing Stage II control equipment will also eliminate expenses associated with operating Stage II systems. This makes it clear that they are not prioritizing public health and welfare when considering the proposal. Washington D.C. is currently in nonattainment for 8-hour Ozone. It reached nonattainment in 2018, and has been in it since. With the removal of Stage II Vapor Recovery Systems, the air quality can only continue to get worse. The proposal states that this removal of requirements is necessary due to conflicts with other systems, but did not explicitly explain how these other systems will be regulated to make up for it. Sources:Environmental Protection Agency. (2015). Final Rule Determining Widespread Use of Onboard Refueling Vapor Recovery and Waiver of Stage II Requirements [Fact Sheet]. https://www.epa.gov/sites/default/files/2015-09/documents/stage_2_vapor_factsheet.pdfMacIntosh, D. L., Hull, D. A., Brightman, H. S., Yanagisawa, Y.,  Ryan, P. B. (2003, July 1). A method for determining in-use efficiency of Stage II Vapor Recovery Systems. Environment International, 20 (2), 201-207.  https://www.sciencedirect.com/science/article/pii/0160412094901376#:~:text=The%20estimated%20efficiency%20per%20refueling,between%2081%25%20and%2093%25 I do not agree with the Environmental Protection Agencys (EPA) plan to remove the requirement of Stage II Vapor Recovery System (VCR) in cars of the District of Columbia (DC). Stage II Vapor recovery systems were required in DC since 1993 because the city was labeled as, Serious nonattainment for the 1-hour 1979 ozone NAAQS in the Federal Register at 56 FR 56694 (November 6, 1991).I think continuing the mandate of Onboard Refueling Vapor Recovery (ORVR) is not enough to ensure better air quality for the residents of DC and anyone affected by the citys air pollution. The EPA states, Given the widespread use of ORVR, Stage II control systems now provide increasingly less air pollution reduction beyond what is provided by ORVR and therefore are increasing less cost-effective (EPA). Although it may be more cost effective to remove the mandate of Stage II VCR, it is not worth or comparable to the health of the people affected by this. I dont believe this mandate should be lifted, because I think the continued use of Stage II VCRs can only help to improve DCs air quality. If we remove this mandate we are setting up the city to be classified as a serious nonattainment for the 1 hour ozone NAAQs.CitationsFact Sheet. FACT SHEET FINAL RULE DETERMINING WIDESPREAD USE OF ONBOARD REFUELING VAPOR RECOVERY AND WAIVER OF STAGE II REQUIREMENTS, Environmental Protection Agency, www.epa.gov/sites/default/files/2015-09/documents/stage_2_vapor_factsheet.pdf. Accessed 8 Feb. 2024. The Federal Register. Federal Register :: Request Access, 16 May 2012, www.federalregister.gov/documents/2012/05/16/2012-11846/air-quality-widespread-use-for-onboard-refueling-vapor-recovery-and-stage-ii-waiver. 