IN THE MATTER OF:
PETITION OF FORD
MOTOR COMPANY FOR
ADJUSTED STANDARD FROM
35
Ill.Adm.Code
§
2 18.586
To:
William Ingersoll
Acting General Counsel
Division of Legal Counsel
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield, IL 62794-9276
william.ingersoll~epa.state.il.us
RECEIVED
CLERK S OFFICE
FEB 25
2005
STATE OF ILLINOIS
Pollution Control Board
Charles Matoesian
Assistant
Counsel
Division ofLegal Counsel
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield,
IL 62794-9276
Charles.Matoesian@epa.state.il.us
PLEASE TAKE NOTICE
that on this day, the 25th day ofFebruary, 2005, I caused to
be
filed with the Clerk of the Illinois Pollution Control Board the
PETITION OF FORD
MOTOR COMPANY FOR ADJUSTED STANDARD FROM 35 I1I.Adm.Code
§
218.586
and the
APPEARANCES OF KATHLEEN
C. BASSI, JANE E. MONTGOMERY,
and
KAVITA M. PATEL,
copies ofwhich are herewith served upon you.
Is!
7atIl(een
C.
(Bassi
Jane E. Montgomery
Kathleen
C. Bassi
Kavita M. Pate!
Schiff Hardin LLP, Attorneys
for Petitioners
6600 Sears Tower, 233
South Wacker Drive
Chicago, Illinois
60606
312-258-5500 (telephone)
312-258-5600 (facsimile)
kbassi@schiffhardin.com
kpatel@schiffhardin.com
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
)
)
ASO5-O
)
(Adjusted Standard
—
Air)
)
)
NOTICE OF FILING
CH2\ 1207030.1
1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: )
) AS 05-_____
PETITION OF FORD MOTOR COMPANY FOR
ADJUSTED STANDARD FROM
35 Ill.Adm.Code § 218.586
)
)
)
(Adjusted Standard – Air)
PETITON FOR ADJUSTED STANDARD
NOW COMES Ford Motor Company (“Ford”) by and through its attorneys, Schiff
Hardin LLP, pursuant to Section 28.1 of the Environmental Protection Act (“Act”) (415 ILCS
5/28.1) and 35 Ill.Adm.Code Part 104, Subpart D, and petitions the Board to grant it an adjusted
standard from the provisions for Stage II vapor recovery (“Stage II”), codified at 35
Ill.Adm.Code § 218.586, and to require, in place of Stage II vapor recovery, that Ford comply
with the standards of the federal onboard refueling vapor recovery regulations (“ORVR”). In
support of its petition, Ford states as follows:
A. Description of Standard from Which Relief Is Sought (§ 104.406(a))
Ford seeks an adjusted standard from the provisions of Section 218.586 of the Board’s
air pollution control regulations. Section 218.586 provides for Stage II vapor control of gasoline
fueling operations. The regulations require that affected dispensers of gasoline install, use, and
maintain a vapor collection and control system certified by the California Air Resources Board
(“CARB”) for the fueling of motor vehicles. Section 218.586(a)(2) defines
Certified
and
establishes the minimum capture and control efficiency for motor vehicle fueling operations:
Certified means any vapor collection and control system which has
been tested and approved by CARB as having a vapor recovery
and removal efficiency of at least 95% (by weight) shall constitute
a certified vapor collection and control system. CARB testing and
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
2
approval is [SIC] pursuant to the CARB manual, incorporated by
reference at 218.112 of this Part.
35 Ill.Adm.Code § 218.586(a)(2). The Board adopted Stage II vapor recovery at R91-30, 16
Ill.Reg. 13864, effective August 24, 1992.
1
The U.S. Environmental Protection Agency
(“USEPA”) approved Illinois’ Stage II vapor recovery rules as part of the state implementation
plan (“SIP”) at 58 Fed. Reg. 3841 (January 12, 1993). Exhibit 1.
Section 202(a)(6) of the Clean Air Act (Exhibit 2), however, requires that automobile
manufacturers such as Ford incorporate ORVR systems in new passenger vehicles (“cars”). As
designed and consistent with Section 202(a)(6), Ford’s ORVR systems recover at least 95% of
the gasoline vapors displaced during the refueling of vehicles. 59 Fed. Reg. 16262, 16279-80
(April 6, 1994) (final rule anticipates 95-98% reduction in vehicles’ refueling emissions),
Exhibit 3. Congress anticipated that as new cars equipped with ORVR replaced older vehicles,
Stage II vapor recovery would no longer be needed. The Clean Air Act provides that Stage II
would not apply in moderate nonattainment areas once USEPA had adopted ORVR regulations
and that the Administrator could waive Stage II requirements in serious, severe, and extreme
nonattainment areas as appropriate. 42 U.S.C. § 7521(a)(6).
B. Regulation of General Applicability to Implement the Clean Air Act (§ 104.406(b))
The Board promulgated Section 218.586 to implement the Stage II requirements of
Section 182(b)(3)(A) of the Clean Air Act (42 U.S.C. § 7511a(b)(3)(A)). Exhibit 2a.
C. Level of Justification Necessary for Adjusted Standard (§ 104.406(c))
No level of justification or other requirements for adjusted standards are specified in
Section 218.586.
1
The Board also adopted clean-up amendments to the regulation at R93-9, 17 Ill.Reg. 16636, effective
September 27, 1993.
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
3
D. Nature of, Location of, and Area Affected by Petitioner’s Activity That Is the
Subject of This Petition (§ 104.406(d))
Ford owns a motor vehicle assembly plant, the Chicago Assembly Plant (“the Plant”),
located at 12600 South Torrence Avenue, Chicago, Cook County, Illinois. The Plant is located
in the Chicago ozone nonattainment area. The vicinity is an industrial area, although a
residential area is also nearby.
Ford assembles Ford Montego, Ford Five Hundred, and Ford Freestyle vehicles at the 2.7
million-square-foot Plant constructed in 1924. Ford currently employs approximately 2,700
persons at the Plant. The Agency issued Ford a Title V permit for the Plant pursuant to the
Clean Air Act Permit Program at Section 39.5 of the Act (415 ILCS 5/39.5), and this permit
continues in effect for the Plant.
The cars produced at the Plant are assembled from parts manufactured at other locations.
A final assembly activity includes providing the vehicle with sufficient fuel to be moved from
the assembly area to a holding area prior to transport to the customer. Ford’s permit allows it to
dispense up to 3.93 million gallons of gasoline at the Plant per year. Uncontrolled emissions
from the initial fueling would be approximately 22 tons of volatile organic material (“VOM”)
per year. Ford applies Stage II vapor control measures to capture emissions from this initial
fueling of the new motor vehicles, removing approximately 21 tons per year.
Generally see
Exhibit 4.
Recently, Ford began producing cars equipped with ORVR systems. The federal
standard for ORVR efficiency is 95% removal of refueling vapors. 42 U.S.C. § 7521(a)(6),
Exhibit 2. Each ORVR system for Ford’s vehicles, however, is designed and certified to meet a
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
4
98% capture and control efficiency. Exhibit 4. All of the vehicles manufactured at the Plant are
equipped with ORVR systems, consistent with federal law. Exhibit 4.
E. Efforts Necessary for Ford to Comply with Section 218.586 (§ 104.406(e))
The Stage II vapor recovery system at the Plant is nearing the end of its life. Ford had
installed a Stage II vapor recovery system before the adoption of Section 218.586. This system
was upgraded and certified to meet CARB standards in 1994, subsequent to the applicability of
Section 218.586 to the Plant, and complies with the regulations for Stage II. In order for it to
continue to comply with the requirements of Section 218.586, Ford would have to replace the
system.
The existing system utilizes a specialized gasoline-dispensing nozzle that is designed to
capture any displaced gasoline vapor from the motor vehicle fuel tank during the initial filling
operation and to route the captured vapors through a pipeline to an afterburner (flare) located on
the roof of the Plant. The afterburner ignites and combusts the vapors, using natural gas as a
supplemental fuel as necessary. The afterburner is equipped with a continuous natural gas-fired
pilot so that it is ready to combust gasoline vapors captured in the system when they reach the
lower explosive level in the afterburner.
Generally see
Exhibit 5.
When vehicles equipped with ORVR are fueled by nozzles equipped with Stage II vapor
recovery, the systems compete. ORVR is designed to draw or retain displaced gasoline vapors
in the car’s carbon canister. Likewise, Stage II vapor recovery draws the displaced vapors
through a vacuum into its own exhaust system for destruction by the flare. While Ford does not
believe the use of the competing systems is dangerous or harmful to the environment (there will
be increasingly more competing systems in nonattainment areas as more and more of the
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
5
national fleet is equipped with ORVR until Stage II is no longer required), to require Stage II
where only ORVR-equipped vehicles are fueled defeats the purpose of both systems and is
contrary to the intent of Section 202(a)(6) of the Clean Air Act. The only reasonable alternative,
then, is to allow Ford to discontinue the use of the Stage II system and to rely on the ORVR
systems, because Ford has reached the point at the Plant that was anticipated by the Clean Air
Act,
i.e.
, that ORVR would replace Stage II.
Costs are discussed in Section F, following.
F. Proposed Adjusted Standard, Level of Effort Required, Costs (§ 104.406(f))
Ford proposes that the Board grant an adjusted standard that waives the requirements of
Section 218.586 and requires that Ford fuel only ORVR-equipped vehicles at the Plant.
Specifically, the adjusted standard would state as follows:
The Ford Motor Company Chicago Assembly Plant is not subject
to the requirements of Section 218.586, effective immediately, so
long as the vehicles fueled at the Chicago Assembly Plant are
equipped with onboard vapor recovery systems certified by the
U.S. Environmental Protection Agency to capture a minimum of
95% of the gasoline vapor displaced during fueling.
Ford already fuels only vehicles equipped with ORVR systems at the Plant. Therefore,
the level of effort for Ford to comply with the adjusted standard is minimal, merely to continue
fueling only ORVR-equipped vehicles and to discontinue use of the existing Stage II system.
Ford estimates that the cost of removal by Stage II of gasoline vapors not captured by the
ORVR systems in the cars being fueled, should the Board deny this Petition, is approximately
$200,000 per ton. The ORVR systems remove approximately 21.19 tons per year of VOM,
nominally equivalent to the amount removed by the Stage II system prior to the commencement
of fueling ORVR-equipped vehicles. The ORVR systems allow up to 0.43 tons per year of
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
6
VOM to be emitted to the atmosphere. It is debatable whether the Stage II system can even
capture this small amount of vapors, as this is the amount that would typically be emitted to the
atmosphere by operation of the Stage II system. However, assuming that it can capture the
requisite portion of these emissions, it would capture and destroy 95% of the amount not
captured by the ORVR systems, or 0.408 tons per year, leaving 0.022 tons per year emitted to
the atmosphere.
Generally see
Exhibit 4.
Ford evaluated the costs of installing and operating a new Stage II system. Using a
conservative approach to calculate the cost of installing a new system, Ford estimates the total
annual cost to be $81,538 but that the cost per ton of VOM removed would be $200,000.
See
Exhibit 3. This cost per ton is clearly extraordinary and far beyond what the Board has already
concluded is a reasonable cost for installation of Stage II vapor recovery. In its opinion
addressing repeal of Stage II in Metro-East, the Board included the Agency’s estimates of
approximately $40,000 for installation of a Stage II system at a typical gasoline station, a one-
time expense, plus approximately $7,000 per year to operate it.
See
Exhibit 6 at p. 4. Ford’s
costs are nearly double that amount on an annual basis. Further, it is reasonable to assume that
busy gasoline stations remove far more gasoline vapors per year than Ford because of the sheer
volume dispensed, thus making their cost per ton of VOM removed exponentially lower. The
cost-per-ton of VOM removed if Ford must continue to use Stage II is far beyond that
considered acceptable for reasonably available control technology (“RACT”).
2
2
Ford is not suggesting that Stage II is RACT, as it is a particular control measure required by the Clean
Air Act, or expressing an opinion as to whether Stage II should constitute RACT. However, costs considered
acceptable under RACT can serve to provide perspective here.
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
7
The costs of adding the ORVR systems to the vehicles assembled at the Plant are
irrelevant, as Ford is required by the Clean Air Act to install them regardless of the Board’s
decision with respect to this Petition. The question is whether Ford should have to bear the
additional cost of replacing its Stage II system when Stage II has been made obsolete at the Plant
by ORVR.
G. Quantitative and Qualitative Impact of Petitioner’s Activity on the Environment
Under Conditions of Compliance with Section 218.586 v. Adjusted Standard (§
104.406(g))
Since the original installation of the Stage II system, the Plant began producing ORVR-
equipped vehicles to meet the federal ORVR standards. The ORVR systems capture at least
95% of the evaporative emissions that otherwise could be lost during refueling. These new
ORVR systems capture displaced gasoline vapor and absorb it in the vehicle’s onboard carbon
canister. Over time, as the engine runs, the vapors are desorbed by engine heat and used as fuel
for the engine.
See
Exhibit 7.
As discussed above, these two, distinct vapor recovery systems compete to capture any
displaced gasoline vapor during the fueling process, essentially rendering each less effective
from a technical and practical engineering perspective. The Stage II system can reduce the
actual efficiency of the ORVR-equipped vehicles from their potential 95-98% reduction levels.
Further, operating both systems simultaneously results in starving the Stage II system, as the
ORVR system is capturing emissions previously captured by the Stage II system. The Stage II
system was designed to have at least a 95% capture efficiency. As a result of fueling ORVR-
equipped vehicles, the Stage II system is capturing only approximately 95% of the vapors left
after 95% are captured by the ORVR system. Therefore, in order for the flare to operate
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
8
properly, it is burning mostly natural gas, the percentage of gasoline vapors being extremely
small.
New federal mobile emissions models, MOBILE6 and 6.2, apply a 95% reduction credit
in refueling emissions from uncontrolled levels for ORVR-equipped vehicles.
See
Exhibit 8.
Likewise, MOBILE5 assumed a 95% reduction for operation of Stage II and for ORVR,
recognizing that “where Stage II is in place and on-board-equipped vehicles begin to enter the
fleet, the control is dominated by onboard, which is generally more effective than Stage II.”
User’s Guide to MOBILE5
, Section 2.2.7, “Refueling Emissions” <epa.gov/otaq/m5.htm> (May
1994), Exhibit 9. USEPA has observed that “ORVR fully displaces the need for Stage II vapor
recovery.” 67 Fed. Reg. 45909 (July 11, 2002), Exhibit 10. Therefore, the control achieved by
the ORVR-equipped vehicles assembled at the Plant is at worst equivalent to and at best better
than the existing Stage II system used to satisfy the requirements of Section 218.586.
The overall amount of VOM emitted to the atmosphere will not change as a result of
implementation of the proposed adjusted standard. Therefore, there will be no qualitative
change to the environment in the vicinity of the Plant as a result. Inherently, the environment is
improved by the dissemination of ORVR-equipped vehicles in the national fleet, as ORVR
systems remove gasoline vapors regardless of where the vehicle is fueled, including in areas not
currently required to implement Stage II. Granting the adjusted standard would allow Ford to
discontinue use of a flare, thus reducing the emissions associated with such operation, largely
additional emissions of nitrogen oxides and carbon monoxide. In that sense, there is an
improvement to the environment if the Board were to grant the Petition.
There are no cross-media impacts resulting from granting or not granting the Petition.
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
9
H. Justification of the Proposed Adjusted Standard (§ 104.406(h))
Section 218.586 does not include a level of justification for adjusted standards.
Therefore, this provision is not applicable to this Petition.
I. Consistency with Federal Law (§ 104.406(i))
The granting of this Petition will be consistent with federal law. As discussed above, the
Clean Air Act requires that vehicle manufacturers equip new vehicles with ORVR systems.
See
Exhibits 2 and 3. Moreover, as provided in Section 202(a)(6) of the Clean Air Act, the
Administrator may waive the Stage II requirement in serious, severe, and extreme nonattainment
areas as appropriate.
USEPA has previously approved suspension of Stage II requirements for rental car
facilities where the fueling is limited to ORVR-equipped vehicles.
See
Exhibits 10 (USEPA
approved removal of Stage II requirements for those who dispense to vehicles equipped with
ORVR in Georgia) and 11 (USEPA approved removal of Stage II control equipment from a
rental car facility in Florida because all of the vehicles refueled there would be equipped with
ORVR systems).
3
USEPA approved as part of the Florida SIP the suspension of Stage II
requirements for a rental car facility because it was estimated that there would be “100% use of
the onboard refueling vapor recovery technologies for all vehicles and [there would be a] high
cost of complying with [installing a new Stage II system].” Exhibit 11. This situation is exactly
the situation that Ford is facing right now. The only vehicles fueled at the Plant are new
3
Atlanta is classified as a serious nonattainment area and so is required to have Stage II. USEPA approved
a SIP for the Atlanta area that waives the requirements of Stage II where a facility fuels ORVR-equipped vehicles
exclusively, exactly the situation that is occurring at the Ford Chicago Assembly Plant. Florida retained Stage II as
part of its attainment SIP for a moderate nonattainment area, which is the subject of the USEPA action. USEPA is
granting relief consistent with the waiver provisions of Section 202(a)(6) of the Clean Air Act because Florida
relied on Stage II for its attainment demonstration. Included with Exhibit 11 are copies of the two federal guidance
documents that served as the basis for USEPA’s approval. We understand that USEPA is creating additional
guidance but has, nevertheless, proceeded with the approvals for Georgia and Florida.
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
10
vehicles equipped with ORVR systems. Granting this Petition for Adjusted Standard to Ford
would not affect Stage II requirements elsewhere in the Chicago nonattainment area but would
be consistent not only with the Clean Air Act but also with actions that USEPA has taken in
other “captive” fueling situations. The Board may grant the Petition for Adjusted Standard
consistent with federal law.
If the Board grants the Petition, the Agency must submit the adjusted standard to USEPA
for inclusion in the SIP. To satisfy the SIP public participation requirements in the Clean Air
Act, there must be a public hearing on this matter.
J. Request for Hearing (§ 104.406(j))
To satisfy SIP public participation requirements, Ford requests that the Board hold a
hearing on this Petition for Adjusted Standard.
K. Citations to Supporting Documents and Authorities (§ 104.406(k))
Ford has cited to various documents and authorities in support of this Petition. Such
citations are embedded in the Petition, and copies have been included among the Exhibits hereto.
L. Additional Information Required in the Regulation of General Applicability (§
104.406(l)
No additional requirements are included in Section 218.586.
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
11
WHEREFORE, for the reasons set forth above, Ford Motor Company respectfully
requests that the Board grant its Petition for Adjusted Standard from the requirements of 35
Ill.Adm.Code § 218.586, Stage II vapor recovery, applicable to the Chicago Assembly Plant.
Respectfully submitted,
Ford Motor Company, Petitioner
by
/s/
Kathleen C. Bassi
Kathleen C. Bassi
Dated: February 25, 2005
Jane E. Montgomery
Kathleen C. Bassi
Kavita M. Patel
Schiff Hardin LLP, Attorneys for Petitioner
6600 Sears Tower, 233 South Wacker Drive
Chicago, Illinois 60606
312-258-5500 (telephone)
312-258-5600 (facsimile)
kbassi@schiffhardin.com
kpatel@schiffhardin.com
CH2\ 1157506.9
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: )
) AS 05-_____
PETITION OF FORD MOTOR COMPANY FOR
ADJUSTED STANDARD FROM
35 Ill.Adm.Code § 218.586
)
)
)
(Adjusted Standard – Air)
CERTIFICATE OF SERVICE
I, Kathleen C. Bassi, an attorney, hereby certify that on February 25, 2005, I
served a true and accurate copy of
PETITION OF FORD MOTOR COMPANY FOR
ADJUSTED STANDARD FROM 35 Ill.Adm.Code § 218.586
and the
APPEARANCES OF
KATHLEEN C. BASSI, JANE E. MONTGOMERY,
and
KAVITA M. PATEL
via
electronic transmission to the following individuals:
William Ingersoll
Acting General Counsel
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
william.ingersoll@epa.state.il.us
Charles Matoesian
Assistant Counsel
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Charles.Matoesian@epa.state.il.us
/s/
Kathleen C. Bassi_
___________
Kathleen C. Bassi
CH2\ 1152292.1
ELECTRONIC FILING, AS 2005-005, RECEIVED, CLERK'S OFFICE, FEBRUARY 25, 2005
RECEIVED
CLERKS OFFICE
FEB 252005
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
Pollution Control Board
IN THE
MATTER OF:
)
)
ASO5-O
PETITION OF
FORD MOTOR COMPANY FOR
)
(Adjusted Standard
-
Air)
ADJUSTED STANDARD FROM
)
35 Ill.Adm.Code
§
218.586
)
APPEARANCE
Now comes Kavita M. Patel of the law firm of Schiff Hardin LLP and hereby enters her
appearance on behalf ofPetitioner, Ford Motor Company, in this proceeding.
Respectfully submitted,
Kavita M. Patel
Attorney for Ford Motor Company
Dated:
December
,
2004
Kavita M. Patel
SchiffHardin LLP
6600
Sears Tower
Chicago, Illinois 60606
312-258-5500
CH2\ 1172320.1
RECEIVED
CLERK’5 OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
FEB
252005
STATE OF ILLINOIS
Pollution Control Board
IN
THE MATTER OF:
)
)
ASO5-____
PETITION OF FORD MOTOR COMPANY FOR
)
(Adjusted Standard
-
Air)
ADJUSTED STANDARD FROM
)
35 I11.Adm.Code
§
218.586
)
APPEARANCE
Now comes Kathleen C.
Bassi ofthe law firm of SchiffHardin LLP and hereby enters
her appearance on behalfofPetitioner, Ford Motor Company, in this proceeding.
Respectfully
submitted,
Is! 7iatIi1~en
C. (BassL
Kathleen C. Bassi
Attorney for Ford Motor Company
Dated:
February
25,
2005
Kathleen
C. Bassi
SchiffHardin LLP
6600
Sears Tower
Chicago, Illinois 60606
312-258-5500 (telephone)
312-258-5600 (facsimile)
kbassi@schiffhardin.com
CH2\ 1172323.1
FEB 25
2005
BEFORE
THE ILLINOIS POLLUTION CONTROL BOAR~TATE
OF ILLINOIS
POll~ti~~
Control Board
IN THE MATTER OF:
)
)
ASO5-O
PETITION OF FORD MOTOR COMPANY FOR
)
(Adjusted Standard
-
Air)
ADJUSTED STANDARD FROM
)
35 Il1.Adm.Code
§
218.586
)
APPEARANCE
Now comes Jane E. Montgomery ofthe
law firm ofSchiffHardin LLP and hereby enters
her appearance on behalfofPetitioner, Ford Motor Company, in this proceeding.
Respectfully submitted,
Is! Jane E.
Montgomery
Jane E. Montgomery
Attorney for Ford Motor Company
Dated:
February
25,
2005
Jane E. Montgomery
SchiffHardin LLP
6600
Sears Tower
Chicago, Illinois 60606
312-258-5500 (telephone)
312-258-5600 (facsimile)
CH2\
1172321.1
RECEIVED
CLERK’S OFFICE
FEB 252005
BEFORE THE ILLINOIS POLLUTION CONTROL BOA~IWEOF ILLINOIS
rotiution Control Board
INTHE MATTER OF:
)
)
ASO5-O
PETITION OF FORD MOTOR COMPANY FOR
)
(Adjusted Standard
-
Air)
ADJUSTED STANDARD FROM
)
35 Ill.Adm.Code
§
218.586
)
EXHIBITS
1.
Exhibit
1
Approval
and Promulgation of Implementation Plans; Illinois,
United States Environmental Protection Agency, 58 Fed. Reg.
3841
(January 12,
1993)
2.
Exhibit 2
42 U.S.C.A.
§
752 1(a)(6)
3.
Exhibit 2a
42 U.S.C.A.
§
751 la(b)(3)(A)
4.
Exhibit 3
Control ofAir Pollution From New Motor Vehicles and New
Motor Vehicle Engines; Refueling
Emission Regulations for
Light-Duty Vehicles and
Light-Duty Trucks,
59
Fed. Reg.
16262 (April 6,
1994)
5.
Exhibit 4
Affidavit ofJohn C. Baguzis
6.
Exhibit
5
Diagram ofControlled
Stage II Process Operation with vapor
recovery system, P/V valve, and add-on control device
(processor)
7.
Exhibit 6
In the Matter ofStage II Vapor Recovery in the Metro-East
Area: Repeal ofIll. Adm.
219.586, R93-28 (February 17,
1994)
8.
Exhibit 7
ORVR System Description
9.
Exhibit 8
User’s Guide to MOBILE6. 1 and 6.2,
August 2003, Section
2.8.9.2, “Effects of Stage II on Refueling Emissions” at
www.epa.
gov/otag!m6 .htm
10.
Exhibit 9
User’s Guide to MOBJLE5, May 1994,
Section 2.2.7
“Refueling Emissions” at www.epa.govlotag/m5.htm
11.
Exhibit 10
Approval and Promulgation ofImplementation Plans; Georgia:
Approval ofRevisions to State Implementation Plan, 67 Fed.
Reg. 45909 (July
11, 2002)
12.
Exhibit
lOa
Portions ofGeorgia Rules for Air Quality
Control
13.
Exhibit
11
Approval
and Promulgation of Implementation Plans: Florida
Broward County Aviation Department Variance, 69 Fed. Reg.
17929 (April 6, 2004)
14.
Exhibit lla
Impact ofRecent Onboard Decision on Stage II Requirements
in Moderate Nonattainment Areas, United States
Environmental Protection Agency (March 9,
1993)
15.
Exhibit
11 b
Impact ofRecent Onboard Decision on Stage II Requirements
in Moderate Nonattainment Areas, United States
Environmental Protection Agency (June 23,
1993)
CH2\
1190062.1
