Comparative Assessment of the Environmental Performance of Small Engines Outdoor Garden Equipment Prepared for Department of the Environment and ...
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Comparative Assessment of the Environmental Performance
of Small Engines
Outdoor Garden Equipment
Prepared for
Department of the Environment and Water Resources
Vehicle Design and
and Research P/L
February 2007Disclaimer
The research reported in this document was commissioned by the Environment
Standards Branch of the Department of the Environment and Water Resources.
The views and opinions expressed in this publication are those of the authors and do
not necessarily reflect those of the Australian Government or the Minister for the
Environment and Water Resources.
While reasonable efforts have been made to ensure that the contents of this
publication are factually correct, the Commonwealth does not accept responsibility
for the accuracy or completeness of the contents, and shall not be liable for any loss or
damage that may be occasioned directly or indirectly through the use of, or reliance
on, the contents of this publication.
Acknowledgments
This report was prepared for the Department of the Environment and Water Resources
and the contribution made by Officers of the Department is acknowledged.
The comments on the draft report and other project discussion documents made by
members of the Small Engines Expert Panel: Outdoor Equipment were appreciated
and considered in finalising this report. The Panel had representation from:
Industry: Allpower Industries
Stihl Pty Ltd
Briggs & Stratton
Honda Australia Motorcycle & Power Equipment Pty Ltd
Victa Lawncare Pty Ltd
Rover Mowers Limited
Roy Gripske & Sons Pty Ltd
Parklands Trading Co Pty Ltd
Kawasaki Motors
Associations: Outdoor Power Equipment Association
Government: Department of the Environment and Water Resources
NSW Department of Environment and Conservation
Environment Protection Authority Victoria
The Northern Territory Department of Natural Resources,
Environment and The Arts.
In addition overseas government and industry colleagues provided useful feedback
and information during the project.
iContents
Disclaimer .................................................................................................................i
Acknowledgments...........................................................................................................i
Abbreviations and Glossary...........................................................................................ii
Executive Summary ..................................................................................................... iii
1. Introduction............................................................................................1
1.1 Emissions from outdoor garden equipment engines..............................1
2. Air Quality and Outdoor Garden Equipment Engines...........................4
2.1 Air Quality Standards ............................................................................6
3. Emission Standards for Small Engines ..................................................8
3.1 Australia.................................................................................................8
3.2 United States ..........................................................................................8
3.3 Canada..................................................................................................12
3.4 Europe ..................................................................................................13
3.5 Summary of Regulations for Non Handheld Equipment.....................15
3.6 Summary of Regulations for Handheld Equipment.............................16
4. Australian Market for Small Engines ..................................................18
4.1 Likely compliance with overseas emissions standards........................18
4.2 Australian Sales of Outdoor Powered Equipment ...............................22
5. Australian Users of Small Engines ......................................................25
5.1 General Public......................................................................................25
5.2 Garden and Ground Maintenance Services..........................................27
5.3 Government Purchasing.......................................................................28
6. Result of Stakeholder Consultation .....................................................30
6.1 Regulations ..........................................................................................30
6.2 Discussion on recommended regulations.............................................31
7. The Way Forward ................................................................................35
7.1 Options to Reduce Emissions from Garden Equipment Engines ........38
7.2 Option 1 – Do Nothing ........................................................................39
7.3 Option 2 – Industry - Government Partnership....................................39
7.4 Option 3 - Quasi Regulation ................................................................39
7.5 Option 4 -Co Regulation......................................................................40
7.6 Option 5 - Regulation...........................................................................40
7.7 Preferred Approach..............................................................................44
References ..............................................................................................................45
iiAppendix 1: Detailed Breakdown of Powered Garden Equipment on the Australian
Market ..................................................................................................51
Appendix 2: Examples of Current Australian Benchmarking Programs..................55
Appendix 3. Productivity Commission Comments on Labelling and Minimum
Performance Standards ........................................................................71
iiiList of Figures
Figure 1: Example of a Californian Consumer Advisory Hang Tag.........................11
Figure 2: Extract from survey form...........................................................................18
Figure 3: Compliance with overseas standards - all surveyed products....................20
Figure 4: Compliance with overseas standards by equipment type...........................21
Figure 5: Engine type for popular categories ............................................................21
Figure 6: Compliance with overseas standards for popular categories .....................22
Figure 7: OPEA estimates of equipment sales in 2005-06........................................24
List of Tables
Figure 1: Example of a Californian Consumer Advisory Hang Tag.........................11
Figure 2: Extract from survey form...........................................................................18
Figure 3: Compliance with overseas standards - all surveyed products....................20
Figure 4: Compliance with overseas standards by equipment type...........................21
Figure 5: Engine type for popular categories ............................................................21
Figure 6: Compliance with overseas standards for popular categories .....................22
Figure 7: OPEA estimates of equipment sales in 2005-06........................................24
iAbbreviations and Glossary
2c Two stroke with carburettor
2di Two stroke with direct fuel injection
2i Two stroke with pre-chamber fuel injection
4c Four stroke with carburettor
4i Four stroke with fuel injection (includes direct injection)
ABS Australian Bureau of Statistics
ABT Averaging, Banking and Trading of emissions
ADR Australian Design Rule
Air NEPM National Environment Protection Measure for ambient air quality
BTEX Benzene, toluene, ethylbenzene, xylenes - carcinogenic or mutagenic aromatic
hydrocarbons formed through the combustion process
CARB Californian Air Resources Board
CBA Cost Benefit Analysis
cc Cubic centimetres
CO Carbon Monoxide
DEC Department of Environment and Conservation
di Direct Injection
efi Electronic fuel injection
EU European Union
Euromot The European Association of Internal Combustion Manufacturers
g/kW- hr Grams per kilowatt hour
HCs Hydrocarbons –most are VOCS and, in relation to small engines, the terms are
often used interchangeably
hp Horsepower 1 hp =745.7 watts
ISO International Standards Organization
kW Kilowatts
MEPS Minimum Energy Performance Standards
MOU Memorandum of Understanding
NATA National Association of Testing Authorities
NOx Oxides of Nitrogen
NPI National Pollutant Inventory
NSW GMR New South Wales Greater Metropolitan Region which includes Sydney, Lower
Hunter and Illawarra regions, encompassing the major metropolitan centres of
Sydney, Newcastle and Wollongong. Population approximately 4.7 million.
OPEA Outdoor Power Equipment Association
PM10 Particles with an aerodynamic diameter of 2.5 micrometres or less
PM2.5 Particles with an aerodynamic diameter of 10 micrometres or less
Port Phillip Region in Victoria of 24,000 km2 that includes Greater Melbourne and Greater
Region Geelong. It is defined in Victorian environmental policy. Population
approximately 3.4 million (1996)
SE Qld South East Queensland - a region that covers the area from the Gold Coast to the
Sunshine Coast and west to Toowoomba. It includes Brisbane & suburbs,
population approximately 2.3 million people
USEPA United State of America Environmental Protection Agency
VOCs Volatile Organic Compounds
WELS Water Appliances: Water Efficiency Labelling and Standards Scheme
iiExecutive Summary
Background
This report sets out the results of a project to compare and benchmark emissions from
small petrol engines (less than 19 kilowatts) that are used to power outdoor garden
equipment and were available for sale in Australia during 2006. The equipment
powered by these small engines are used in lawnmowers, brushcutters, hedge
trimmers and the like.
These engines emit volatile organic compounds (VOCs) and oxides of nitrogen (NOx)
which contribute to ozone (photochemical smog) formation in summer. They also
emit particles, carbon monoxide (CO) and a range of air toxics such as benzene.
Sydney’s Greater Metropolitan Region (GMR) annually records exceedances of the
National Environment Protection (Ambient Air Quality) Measure (Air NEPM) ozone
standards. The other jurisdictions meet or are close to meeting the current ozone
standards.
The Air NEPM standards are being reviewed and based on current human health
evidence the argument appears to be strengthening for tighter ozone standards. Should
a stricter standard or an eight-hour standard consistent with international
standards/guidelines be adopted, achievability of Air NEPM ozone standards or goals
could become an issue for some of the other major urban airsheds.
The United States, California, Canada and Europe regulate emissions from outdoor
equipment - the USA has had these in place since 1997. There are no Australian
regulations or standards that limit air pollutant emissions from engines used in
outdoor garden equipment however as the majority of equipment sold in Australia is
imported some do comply with emission standards applicable to the country of origin.
Small engines are not as advanced in environmental terms as motor vehicle engines.
As a result even the better-performing small engines emit far greater quantities of
pollutants per hour than typical modern car engines. For example the US
Environmental Protection Agency (USEPA) 2002 limit for a typical 4 kilowatt (kW)
lawnmower motor is about 66 grams (g) of regulated pollutants per hour of operation.
A typical 0.8kW brushcutter sold new in 2002 emitted about 160grams of pollutants
per hour - reducing to 40grams per hour if bought new in 2006. The equivalent limit
for cars under Australian Design Rule 79 is about 16g per hour. In other words, one
hour of operation of a brushcutter that meets USEPA 2002 limits produces the same
pollution as ten cars, operated over a similar time. These comparisons are subject to
differences in test methods but they do provide an indication of the disproportionate
amount of pollution emitted by small engines.
Engines that do not comply with current USEPA requirements are likely to emit
several times the amount of pollution calculated in the above example. Therefore the
worst performing engines are likely to emit more than ten times the emissions of the
best performers.
iiiBased on estimates made using the National Pollutant Inventory database, engines
used in lawn mowers contribute approximately 4% on average to VOC emissions
from anthropogenic sources in major airsheds in Australia when public open space
lawn mowing is included. This is likely to rise to around 11 % in the warmer spring
and autumn weekends which is when lawns and other vegetation grows faster and
when gardening is more popular. The NPI does not take into account emissions from
other types of powered outdoor equipment.
The Australian Market
According to the Outdoor Power Equipment Association (OPEA), approximately
424,000 walk behind lawnmowers and more than 792,000 units of outdoor handheld
equipment were sold in Australia in 2005-06. In addition there were sales of about
80,000 replacement engines and 70,000 pumps in 2005-06 most of which were four
strokes. The general household consumer represents the major market segment for
garden equipment, accounting for up to 90% of product sales with commercial garden
services and government purchasing the rest.
Indications are that sales of imported high polluting two stroke engines have increased
over the last few years and it appears that the price of some powered garden
equipment has dropped to the level where consumers regard them as disposables.
An assessment of outdoor equipment on the Australian market found that the majority
of small engines sold in Australia are imported and many come from countries that
impose emission limits. The extent of imports into Australia that do not comply with
the country of origin standards is not known. However the industry estimate that 40%
of garden products are sold through importers who are not linked to manufacturers of
US EPA or European certified equipment and the source of some products sold here is
difficult to establish. Victa is the only company producing small engines in Australia.
Its iconic 2-stroke lawn mower engine currently does not meet overseas emission
limits for non-handheld equipment and Victa is undertaking research and
development to reduce emissions from its two stroke engine to meet US and European
standards.
In spite of several attempts to obtain data on compliance with overseas emission
standards from Australian distributors their response was poor. The following figure
therefore provides a best estimate of expected compliance of outdoor equipment on
the Australian market with European, CARB or USEPA requirements applicable in
2004.
ivFigure E1. Compliance with overseas standards for popular categories
“Phase 1 equiv” means the engine complies with US EPA phase 1 or 2002.88.EU.
“Phase 2 equiv” means the engine complies with US EPA Phase 2, Euro I or Euro 2.
“Unknown" means that engine cycle (stroke) was not provided
Measures to Increase Sales of Low Emission Garden Equipment
Engines
There is a range of options that could be considered for reducing emissions from
engines used in outdoor garden equipment engines in Australia. These include:
1. Maintaining the Status Quo
2. Government – Industry Partnership Program
3. Quasi regulation
4. Co-regulation
5. Regulations based on either a simple benchmark or tiered benchmarks
The Small Engine Expert Panel –Outdoor Equipment has considered in depth the
most appropriate approach to take to improve the emissions performance of outdoor
garden equipment sold in Australia It recommends the introduction of national
regulations to control the emissions from outdoor garden equipment particularly in
light of the increase in cheap imports onto the Australian market, which although
untested, are considered very likely to have high emission levels. The Expert Panel
has developed some broad recommendation on which Australian regulations could be
based which takes in consideration the local market and Victa. These are summarised
as follows:
1. Mandatory air pollutant emission standards to be introduced in Australia
for all outdoor equipment (The development of any regulation would need to be based on a formal
assessment of the costs and benefits of nationally regulating two and four
stroke lawn mowers and handheld power equipment, which should
commence immediately.
2. Proposed standards to mirror US EPA regulations (compliance with
equivalent EU regulations also acceptable).
3. Timing (subject to completion of assessment of costs and benefits):
(a) US EPA Phase 1 – Effective from 2007/2008
(b) US EPA Phase 2 – Fully implemented in 2012 (in step with 2007
USEPA limits) plus a phase-in period and/or provisions for
averaging, banking and trading (ABT) of emissions over 2008-2012
to provide for early introduction of cleaner product.
The US EPA Phase 1 and Phase two emissions limits are given in the table
below.
4. Walk-behind two stroke mowers to be included in US EPA Category 5
(>50cc) product classifications (to provide Victa time to develop a cleaner
engine). Implementation timing is proposed to be the same as
Recommendation 3 above.
5. All products also to be certified to relevant EPA product durability
categories.
6. Subject to further review, ABT, if included, may be phased out after 2012.
Table E1: Comparison between the USA Phase 1 and Phase 2 standards
Emission Limits Phase 1 (1997 –2001) Phase 2 (2007) *
G/kW-hr HC NOx HC+NOx CO HC+NOx CO
Non-handheld
I-AConclusion
From this review it is apparent that it is highly unlikely that the companies in the
industry would engage in, or commit to, any voluntary type program. It is therefore
clear that the most expedient path to reduce emissions from these small engines is
through national regulation. State based regulations could only provide a piecemeal
approach that would lead to product dumping in states where there are no regulations
and inconsistent regulations that require industry to treat each state market differently.
In addition, enforcement of any state based regulations would be a key problem due to
existing Commonwealth and State Government mutual recognition legislation.
While any national regulation of emissions from small engines used in garden
equipment in Australia are likely to be based on overseas regulations they need to
strike a balance between improved environmental outcome, harmonisation with
international standards and the characteristics of the local industry. With regulations
optimum emissions reduction are potentially achievable by combining minimum
emissions standards with tiered product labelling. Whether this approach is justifiable
on economic grounds, that is the benefits outweigh the costs, can only be determined
through a detailed impact assessment. Based on these findings it is recommended that
a formal assessment of the costs and benefits of nationally regulating two and four
stroke lawn mowers and handheld power equipment should be commenced.
vii1. Introduction
This report sets out the results of a project to compare and benchmark emissions from
engines used in outdoor garden equipment that were available for sale in Australia
during 2006. Possible outcomes from the project range from consumer guidelines for
selecting low emission engines to regulatory controls on emissions. There are
currently no state or national regulations that directly control emissions from these
engines.
The project was commissioned by the Commonwealth Department of the
Environment and Water Resources on behalf of state and territory government
departments working on reducing the impacts of small engine emissions. This report
was prepared in consultation with an Expert Panel that included representatives from
the Outdoor Power Equipment Association (OPEA).
1.1 Emissions from outdoor garden equipment engines
Small engines, particularly conventional two stroke engines used in applications such
as outdoor garden equipment are high polluters relative to their engine size and
usage1. These small engines emit volatile organic compounds (VOCs) and oxides of
nitrogen (NOx) which contribute to ozone (photochemical smog) formation in
summer. They also emit particles, carbon monoxide (CO) and a range of air toxics
such as benzene. The USA, California, Canada and Europe and regulate emissions of
VOCs, NOx, carbon monoxide and particle emissions from outdoor garden
equipment.
There are five types of spark-ignition engines that can be used in outdoor garden
equipment:
• two stroke with carburettor (2c)
• two stroke with pre-chamber fuel injection (2i)
• two stroke with direct fuel injection (2di)
• four stroke with carburettor (4c)
• four stroke with fuel injection (4i) (includes direct injection)
Carburettor and pre-chamber fuel injection two stroke engines are inherently more
polluting than the other three types. This is due to their inability to completely
separate the inlet gases from the exhaust gases, resulting in up to 30% of the fuel
being left unburnt, and the need to add oil to the fuel to lubricate the engine (four
stroke engines have separate reservoirs for fuel and oil). However, twostroke
carburettor engines typically weigh less than a four stroke engine of the same power
and this tends to make them attractive for handheld equipment. They also tend to have
fewer components, are generally cheaper to purchase and are cheaper to maintain than
1
Outdoor equipment covered in this report are engines less than 19kW.
1four stroke motors. Victa Lawncare is currently undertaking research and
development to improve the environmental performance of two stroke carburettors
and while some emission improvements have been made a two stroke compliant with
US or European standards is still considered several years away.
Four stroke carburettor engines are generally quieter, more fuel efficient and are less
polluting than conventional two stroke engines.
Direct fuel injection (dfi), either two stroke or four stroke, overcomes the unburnt fuel
problem and can meet the stringent regulated exhaust emission limits that apply
overseas. However there is not any evidence that dfi engines are being used in outdoor
garden equipment available in Australia. It appears that engines used in outdoor
garden equipment in Australia are generally restricted to two and four stroke
carburettor engines.
Small engines are not as advanced in environmental terms as motor vehicle engines.
As a result, even the better-performing small engines emit far greater quantities of
pollutants per hour than typical modern car engines. For example the US
Environmental Protection Agency (USEPA) 2002 limit for a typical 4 kilowatt (kW)
lawnmower motor is about 66 grams (g) of regulated pollutants per hour of operation.
A typical 0.8kW brushcutter sold new in 2002 emitted about 160grams of pollutants
per hour - reducing to 40grams per hour if bought new in 2006. The equivalent limit
for cars under Australian Design Rule 79 is about 16g per hour. In other words,
operated over a similar time, one hour of operation of a brushcutter that meets USEPA
2002 limits produces the same pollution as ten cars and a 4kW lawnmower the same
pollution as four cars. These comparisons are subject to differences in test methods
but they do provide an indication of the disproportionate amount of pollution emitted
by small engines.
Engines that do not comply with current USEPA requirements are likely to emit
several times the amount of pollution calculated in the above example. Therefore the
worst performing engines are likely to emit some ten times the emissions of the best
performers.
Because of the combustion of oil these engines also emit high levels of particles.
Although small engines only contribute a small amount to total particle emissions, the
rate of particle release compared to other engines can be very high. For example
lawnmowers can emit over 10 times more particles (in terms of grams per hour) than a
petrol motor vehicle (manufactured between 1994 and 2001).
All the above emission comparisons between outdoor garden equipment engines and
motor vehicles are subject to differences in test methods but they indicate the
disproportionate amount of pollution emitted by small garden equipment engines. It
also needs to be recognised that motor vehicles in Australia average more than 15,000
kilometres per year (ABS, 2003) while the annual average use of outdoor garden
equipment is around 25 hours for a lawnmower and less for other types of equipment.
Commercial operators however are likely to have a much higher usage rates than the
general public.
2This paper examines the Australian market for small engines used in lawnmowers and
handheld garden equipment, their impact on air quality, relevant overseas regulations
and their applicability to Australia and makes recommendations to reduce air quality
impacts from these engines.
A wide range of information sources has been referenced for this report including data
and information supplied by manufacturers, distributors and dealers in small engines.
32. Air Quality and Outdoor Garden Equipment
Engines
Emission inventories make estimates of emissions of substances from a multitude of
sources into airsheds. The National Pollutant Inventory (NPI) which is run
cooperatively by the Australian, state and territory governments, contains data on 90
substances that are emitted to the Australian environment. The substances included in
the NPI have been identified as important because of their possible health and
environmental effects. Industry facilities estimate their own emissions annually and
report to states and territories. Non-industry (or diffuse) emissions estimates, which
includes emissions from outdoor garden equipment, are made by the states and
territories on a periodic basis using information sources such as surveys, databases,
and sales figures.
The NPI only reports emissions from domestic lawn mowing and, for a few airsheds,
the contribution made by public open space lawn mowing. It does not report on the
contribution made by other types of outdoor garden equipment such as brushcutters.
National and selected state NPI emissions estimates for the common air pollutants and
for Air Toxics NEPM pollutants from domestic lawn mowing are summarised in
Table 1. It should be noted that national emissions from lawn mowing are
underestimates as the NPI records emissions for major airsheds only, and therefore is
not Australia wide, plus the estimates do not include evaporative emissions from fuel
tanks and hoses.
This NPI data is indicative only as the accuracy and completeness of the data sets
varies across airsheds and is reliant on the estimation techniques used. For example
while the population in the NSW is higher than other airsheds its emissions look
disproportionally high when compared to the other airsheds. This could be because
the estimation technique varies or it is due to some other factor.
4Table 1: National Pollutant Inventory Domestic Lawn Mowing Emission
Estimates
Substance Port SE Qld NSW GMR Adelaide National
Phillip
Population Population Population
Population 2.3 mill 4.7 mill 1.0 mill
3.4 mill
(1996)
Common Air Pollutants (tonnes/year)
Carbon monoxide 12,000 12,000 24,000 6,100 69,000
Total Volatile Organic
3,600 3,800 7,000 2,000 21,000
Compounds
Particulate Matter 10.0 um 86 94 170 9 460
Sulphur dioxide 5 5 9 50 81
Oxides of Nitrogen 63 54 120 24 330
Air Toxics (tonnes/year)
Benzene 230 210 390 130 1,200
Formaldehyde 56 38 N/A 31 180
Polycyclic aromatic
0.7 11 21 0.4 41
hydrocarbons
Toluene (methylbenzene) 370 360 660 210 2,000
Xylenes (individual or mixed 150
270 260 490 1,500
isomers)
Analysis of the NPI database at the national level shows that domestic lawn mowing
is the:
- Fourth largest source of benzene, contributing 7% to the total reported airshed
load
- Fourth largest source of formaldehyde, contributing 3% to the total reported
airshed load
- Fifth largest source of xylene, contributing 6% to the total reported airshed load
- Fifth largest source of toluene, contributing 6% to the total reported airshed load
- Sixth largest source of carbon monoxide, contributing 1.2% to the total reported
airshed load
- Ninth largest source of VOCs contributing 3% to the total reported airshed load
when biogenics (natural sources such as trees and soil) are excluded
The NSW Department of Environment and Conservation has been upgrading its
emissions inventory. Based on 2003 emissions data, non-road anthropogenic sources
5contribute 61.9% of the VOCs to the GMR airshed. Preliminary results2 indicate that
VOC emissions from domestic and public open space lawn mowing contributes, on an
annual average, 4.1%, of all VOC emissions in the GMR. On a typical weekend
during warmer weather this percentage rises to 11%.
Therefore it could be assumed that lawn mowing could contribute approximately 4%
on average to VOC emissions from anthropogenic sources in major airsheds in
Australia when public open space lawn mowing is included. This percentage is likely
to rise significantly in the warmer spring and autumn weekends which is when lawns
and other vegetation grow faster and when more people garden.
2.1 Air Quality Standards
In June 1998 the National Environment Protection Measure for Ambient Air (Air
NEPM) established national uniform standards for ambient air quality for the six most
common air pollutants – carbon monoxide, nitrogen dioxide, photochemical oxidants
(measured as ozone), sulfur dioxide, lead and particles less than 10 microns (PM10).
The NEPM was varied in 2003 to include PM2.5 advisory reporting standards and in
April 2004 a National Environment Protection Measure for Air Toxics was adopted.
Nationally the common pollutants of most concern (particularly in major urban areas)
are fine particles and ground level photochemical smog (measured as ozone) which is
formed in the warmer months when volatile organic compounds (VOCs) and oxides
of nitrogen (NOx) react in the atmosphere under the influence of sunlight in a series
of chemical reactions.
Recent health studies (cited in NEPC, 2005) have strengthened the evidence that there
are short-term ozone effects on mortality and respiratory disease. The studies also
strengthen the view that there does not appear to be a threshold for ozone below
which no effects on health are expected to occur. In recent years Australian
epidemiological studies have been conducted which confirm the results of overseas
studies that there is a relationship between elevated ozone levels and hospitalisations
and deaths from certain conditions.
There are two national ozone standards, a one hour standard of 0.10ppm and a four
hour standard of 0.08ppm, with a goal that allows for one exceedance per year by
2008. Sydney experiences a number of days each year of ozone levels above these
standards. In 2003 Sydney exceeded the one hour standard on 11 days in 2003, 19
days in 2004 and 9 days in 2005. The four hour standard was exceeded on 13 days in
2003, 19 days in 2004 and 13 days in 2005. Further reductions in VOC and NOx
emissions are needed to reduce ozone concentrations in Sydney to levels that would
comply with the Air NEPM.
The other jurisdictions meet, or are close to meeting the current National Environment
Protection (Ambient Air Quality) Measure (Air NEPM) ozone standards (NEPC,
2005). However the ozone standards are being reviewed and based on current human
health evidence the argument appears to be strengthening for tighter ozone standards.
2
Presentation to Expert Panel 27 April 2006 by Nick Agipades, Manager Major Air Projects, NSW DEC,
6Should a stricter standard or an eight-hour standard consistent with international
standards/guidelines be adopted, achievability of Air NEPM ozone standards or goals
could become an issue for some of the other major urban airsheds (NEPC, 2005).
Modeling of ozone for Sydney’s Greater Metropolitan Region (GMR) indicates that
the implementation of Euro emission limits for on-road vehicles, and hence the
increased presence of these less polluting vehicles in the fleet and retirement of old
more polluting vehicles from the fleet, is not sufficient to meet the current NEPM
goals. Modeling suggests that very large reductions in precursor emissions would be
required to meet the current ozone one hour goal (NEPC, 2005).
Even when the effects of bushfires and when hazard reduction burning are taken into
consideration, airsheds such as Launceston, Melbourne and Sydney struggle to meet
the national standards for particles (EPA, 2006). However outdoor powered
equipment, predominantly from two stroke engines, makes only a minor contribution
to ambient fine particle loads.
While carbon monoxide emissions from engines used in outdoor garden equipment
are regulated overseas air monitoring in Australia indicates that carbon monoxides
levels are well below the national air quality standards and there are no pressing
issues requiring CO from outdoor powered equipment to be regulated. In addition data
indicates that lowering emissions of VOCs and NOx from small engines reduces CO
emissions.
Many of the pollutant sources which contribute to the formation of ozone and to
particle levels also contain air toxics such as benzene, toluene, formaldehyde, and
xylenes. These air toxics have been shown to be responsible for a range of health
problems, including asthma, respiratory illnesses and cancer. The National
Environment Protection Measure for Air Toxics requires each jurisdiction to monitor
and report annually on five air toxics: benzene, polycyclic aromatic hydrocarbons,
formaldehyde, toluene and xylenes. The monitoring data is intended to inform future
policy and also the public on ambient levels of these air pollutants. Monitoring of air
toxics to date shows that levels are low and below the national monitoring
investigation levels (EPA Vic, 2006, DEC, 2006).
73. Emission Standards for Small Engines
3.1 Australia
At present there are no Australian regulations or standards to limit air pollutant
emissions from small (two and four stroke) engines. Australia does benefit to some
extent from overseas regulations as many lawnmowers and other gardening
equipment sold in Australia have engines manufactured in the United States or
Europe, where strict standards apply.
3.2 United States
In the United States emission regulations set by the United States Environmental
Protection Agency (USEPA) and the Californian Air Resources Board (CARB) apply
to lawn mowers and other powered gardening equipment. Although CARB standards
currently tend to be stricter than USEPA standards, by 2006 emissions limits applying
under the two standards will be very similar.
United States Environment Protection Agency (US EPA)
In 1995 the USEPA introduced “Phase 1” regulations covering small non-road
engines with a power of not more than 19kW (25HP). The regulations applied to
equipment manufactured from 1997.
These regulations have seven classes of equipment, based on portability and engine
displacement volume (“capacity”). In March 2000 the USEPA published “Phase 2”
regulations which are shown in Table 2. These set limits for combined emissions of
hydrocarbons (HC) and oxides of nitrogen (NOx), and separate limits for carbon
monoxide (CO) emissions and for two stroke engines only, particles.
Table 2: US EPA Phase 2 Small Engine Emissions Standards
(HC+NOx in g/kW-hr) (a), (b)
Small Engine Type 2002 2003 2004 2005 2006 2007+
Class
I-A (When the USEPA introduced “Phase 2” regulations it included averaging, banking
and trading provisions (ABT) which were seen “as an important element in making
stringent Phase 2 emissions standards achievable with regard to technological
feasibility lead time and cost.” (USA 1999). The USEPA also claimed (USA, 2000)
that the ABT program secures early emissions benefits through the early introduction
of cleaner engines.
ABT provisions which apply to handheld and non handheld engines, are complex but
in broad terms averaging means the exchange of emission credits among engine
families within a given engine manufacturer’s product line. This allows a
manufacturer to produce some engines that exceed the standards and offsetting these
exceedances with emissions from engines that are below the standard. Manufacturers
are allowed to exchange credits from handheld to non handheld and vice versa.
Banking means the retention of emission credits by the engine manufacturer
generating the credits for use in a future model year (for averaging or trading).
Trading is the exchange of emission credits between engine manufacturers which then
can be used for averaging purposes, banked for future use, or traded to another engine
manufacturer.
In January 2004 USEPA reported that in 2002 averaging was being used but there was
very little use of banking. It determined that the initial ABT programs as too complex
and included discount rates on credits. ABT was simplified in 2004 including the
elimination of credit discount and multipliers and limits on credit life. To date there
has reportedly been limited use of banking however it is anticipated that there will be
more widespread use of banking credits if the USEPA proposed Phase 3 comes into
effect3 (see below).
Particulate limits (2g/kW-hr) also apply to two stroke engines. Carbon monoxide and
durability limits (or useful life) are also prescribed. The durability criteria which were
introduced in Phase 2, require that the emission limits must be met through the useful
life of the engine. The manufacturer determines useful life of each product using
standardised product testing procedures and then, based on the test results, selects the
useful life category for each product which can be 125, 250 or 500 hours. These
durability criteria acknowledge the large disparity in usage patterns by equipment type
and between commercial and residential users. It also takes into account the ability of
manufacturers to design and build engines for various design lives and which fit the
types of equipment engine is produced for.
The March 2000 USEPA report (USEPA, 2000) estimated that the expected effects of
the Phase 2 regulations would be:
• A 70% reduction in HC+NOx, beyond the Phase I standards (which were
estimated to have reduced emissions by 32% from the unregulated baseline)
• A 30% reduction in fuel consumption of small handheld equipment
• Price increases of between $US23 (Class III) and $US56 (Class V) for
handheld equipment.
3
Dave Gardner, Briggs and Stratton, email 22/5/06
9The US EPA is currently considering ‘Phase 3’ regulations which are catalyst based
standards to further reduce exhaust HC and NOx emissions from non handheld
engines, reduce evaporative HC and NOx emissions for both handheld and non
handheld engines plus include extended durability criteria. These limits are currently
at discussion stage only. They align with CARB Tier 3 but a longer lead time is
proposed.
Table 3: Proposed Phase 3 Exhaust Emissions
HC+NOx* CO Year Useful life
g/kW-hr g/kW-hr hrs
Class I 10.0 610 2010 125/250/500
Class II 8.0 610 2011 250/500/1000
Class III-V No changes
HC+NOx std is based on averaging
Californian Air Resources Board (CARB)
Spark ignition engines
CARB regulations first introduced emission limits for small engines manufactured
from1995. The more recent schedule of emission limits are shown in Table 4. These
limits depend solely on the engine capacity and apply to both handheld and non
handheld classes.
Table 4: CARB Emission Limits for Small Engines (HC+NOx in g/kw-hr)
Engine Capacity 2000-2001 2002-2005 2006+
65cc or less 72 72 72
>65cc to 225cc 16.1 16.1 16.1
>225cc 13.4 12.1 12.1
California has particle limits for two strokes, useful life criteria and mandatory engine
labeling including a consumer advisory hang tag as shown in Figure 1. The USEPA is
also considering introducing an air index label.
10Figure 1: Example of a Californian Consumer Advisory Hang Tag
The Californian regulations take into account sales weighted emission performance
for families of engines. An engine family is essentially the same engine being used in
different equipment items.
In 2003, California adopted a Tier 3 program for exhaust and evaporative emissions
and these are based on the use of catalytic convertors. The engine classes better align
with US EPA categories however the exhaust standards for Class I and Class II are
more stringent than the existing US EPA standards.
Table 5: CARB Tier 3 for Exhaust Emissions
Model Year Displacement Durability HC+NOx CO Particulate
Category Periods (hours) g/kw-hr g/kw-hr g/kw-hr
2005 and 80 cc - 80 cc - 80 cc - 80 cc - 80 cc -the averaging, banking, and trading program. Zero-emission small off-road equipment
(e.g. push mowers) may certify to the Blue Sky Series emission standards.
In 2005 CARB aligned its test procedures with the USEPA.
Table 6: CARB Blue Sky Provisions
Model Year Displacement HC+NOx CO Particulate*
Category g/kw-hr g/kw-hr
2005 and subsequent 80 cc -Table 7: Canadian Small Spark-Ignition Engine Exhaust Emission
Standards
Engine Engine Engine Effective Standard Standard Standard
class Type Displacement date (model HC+NOx NMHC+NOx CO
(cm3) year) (g/kW (g/kW-hr) (g/kW
hr) hr)
Non- 2005 and
I-AThe European Union is currently considering including useful life criteria and
averaging and banking provisions plus it is considering introducing a Directive to
further reduce emissions from diesel engines. The objective of the proposal is to
tighten emissions standards for engines in general non-road applications in light of
technological developments and it taking into account the parallel developments for
similar legislation in the United States in order to harmonise the environmental
standards and to facilitate trade.
Charts comparing the USA, Californian and European Emission Limits are shown
below.
143.5 Summary of Regulations for Non Handheld Equipment
KEY TO CHARTS
USEPA CARB EU
0 to 49cc 50 to 65cc
80 80
70 70
HC+NOx g/kW-hr
60
HC+NOx g/kW-hr
60
50 50
40 40
30 30
20 20
10 10
0 0
2000
2001
2002
2003
2004
2005
2006
2007
2008
08
00
01
02
03
04
05
06
07
20
20
20
20
20
20
20
20
20
Year Model
Year Model
100 to 224cc
225cc and over (up to 19kW)
18 20
16 18
14 16
HC+NOx g/kW-hr
HC+NOx g/kW-hr
12
14
12
10
10
8
8
6 6
4 4
2 2
0
0
2000
2001
2002
2003
2004
2005
2006
2007
2008
00
02
04
06
08
20
20
20
20
20
Year Model Year Model
153.6 Summary of Regulations for Handheld Equipment
KEY TO CHARTS
USEPA CARB EU
20 to 49cc
0 to 19cc
250
250
200
200
HC+NOx g/kW-hr
HC+NOx g/kW-hr
150 150
100 100
50 50
0
0
00
01
02
03
04
05
06
07
08
00
01
02
03
04
05
06
07
08
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Year Model Year Model
50 to 65cc
66 to 80cc
160
160
140
140
120
120
HC+NOx g/kW-hr
HC+NOx g/kW-hr
100
100
80
80
60 60
40 40
20 20
0 0
0
1
2
3
4
5
6
7
8
00
01
02
03
04
05
06
07
08
0
0
0
0
0
0
0
0
0
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Year Model Year Model
16Summary of Regulations for Handheld Equipment (continued)
KEY TO CHARTS
USEPA CARB EU
81 to 224cc 225cc and over (up to 19kW)
160 160
140 140
120 120
HC+NOx g/kW-hr
HC+NOx g/kW-hr
100 100
80 80
60 60
40 40
20 20
0 0
00
01
02
03
04
05
06
07
08
00
01
02
02
03
04
05
06
07
08
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
Year Model Year Model
174. Australian Market for Small Engines
4.1 Likely compliance with overseas emissions standards
As part of this assessment an environmental profile of equipment currently on the
Australian market has been developed, initially based on information from
manufacturers’ brochures and web sites and industry magazines and then confirmed
through follow-up with relevant industry contacts.
Each item of equipment has been assessed on its compliance with USEPA, CARB or
European regulations. In most cases it was not possible to match models available on
the Australian market with CARB lists (CARB publishes exhaust emissions data on
all appliances on its web site). This was mainly due to the inconsistency of model
designations and uncertainty about “engine families”.
Engine characteristics and retail price were difficult to obtain. Some brochures also
made claims of compliance with USEPA, European or CARB requirements. The
detailed breakdown of current equipment on the Australian market is given in
Appendix 1.
The majority of small engines sold in Australia are imported and many come from
countries that impose emission limits. The extent of imports into Australia that do not
comply with the country of origin standards is not known. Industry estimates that 40%
of garden products are sold through importers who are not linked to manufacturers of
US EPA or European certified equipment and the source of some products sold here is
difficult to establish. Victa is the only company producing small engines in Australia.
Its iconic 2-stroke lawnmower currently cannot meet overseas emission limits.
Outdoor Power Equipment Association (OPEA) assisted in identifying the Australian
distributors of most brands of powered garden equipment. In April 2006 a survey
form was sent to a total of 43 distributors, representing 97 brands of equipment. The
survey form sought information about the engine for all petrol-fuelled garden
equipment with a power not more than 19kW.
Figure 2: Extract from survey form
18Initial response to the survey was poor. Despite follow-up action and efforts from the
industry association, at the beginning of September 2006 26 distributors had
responded to the survey information and only 13 distributors provided all data
necessary for benchmarking purposes. This resulted in emission compliance data for
about half of the estimated products on the Australian market. Attempts to match
Australian models with the database maintained by the Californian Air Resources
Board were also of limited success due to inconsistencies in model designations
between Australia and the USA and the manner in which model information is coded
in the CARB database.
Table 9: Summary of distributor responses
Responses status Not OPEA OPEA ALL*
Number of responses 9 8 (31%) 17 (40%)
Response - all data 4 9 13 (30%)
Response - extra time sought 3 3 (7%)
Response - no petrol products 4 1 5 (12%)
Response - some data 5 5 (12%)
Grand Total 17 26 43
* percentages may not add to 100% due to rounding
Of the 97 brands initially identified:
• 16 brands are apparently no longer sold in Australia.
• No responses were received for 29 brands
• Partial data were received for 12 brands
• All data was available for 30 brands
Table 10: Summary of responses by brand
Count of brands
Analysis status Not OPEA OPEA All
Missing some data 12 12
No data received 9 (27%) 20 (31%) 29 (30%)
No longer sold 13 3 16
Response - no models to list 3 7 10
Response received (electronic form) 5 11 16
Response received (paper form) 3 2 5
Response received (spreadsheet) 9 9
All 33 64 97
A 2004 report for the NSW DEC estimated that there were about 1200 eligible garden
19products in the Australian market. The current project has obtained data for a total of
870 products or 72% of the estimated population. In addition the sampling method is
likely to be biased towards products with good environmental performance. In these
circumstances the following analysis should be regarded as indicative only.
Survey results
The following tables and figures show expected compliance with European, CARB or
USEPA requirements, based on the limited information provided by industry.
Table 11: Engine type and compliance with overseas standards
Count of products Engine type
Best STD 2c 4c Unknown All
1997 - US EPA I 53 32 85 (10%)
2002.88.EU 17 17 (2%)
2004 - US EPA II 1 3 4 (Figure 4: Compliance with overseas standards by equipment type
“Phase 1 equiv” means the engine complies with US EPA phase 1 or 2002.88.EU.
“Phase 2 equiv” means the engine complies with US EPA Phase 2, Euro I or Euro 2.
“Unknown" means that engine cycle (stroke) was not provided
Of the 41 categories of equipment in the survey, 15 had at least 10 current products.
Results for these categories are set out below.
Figure 5: Engine type for popular categories
21Figure 6: Compliance with overseas standards for popular categories
“Phase 1 equiv" means the engine complies with US EPA phase 1 or 2002.88.EU
"Phase 2 equiv" means the engine complies with US EPA Phase 2, Euro I or Euro 2.
“Unknown" means that engine cycle (stroke) was not provided
4.2 Australian Sales of Outdoor Powered Equipment
The Australian Outdoor Power Equipment Association (OPEA), whose membership
represents about 80% of the manufacturers/distributors and dealers in the industry,
commissions regular independent industry audits of garden equipment sales (OPEA,
personal communications). Sales data from OPEA is shown in Table 12.
22Table 12: Sales of outdoor garden equipment 2002 and 2005-06
2005-06 2002 2005-06 2002 2005-06 2002
2 stroke 2 stroke 4 stroke 4 stroke TOTAL TOTAL
(1,000) (1,000) (1,000) (1,000) (1,000) (1,000)
Walk behind mowers 72 170 351 76 424 246
Brushcutter/trimmer 321 12 17 180 339 192
Chainsaws 152 0 0 90 152 90
Chipper shredders 0 60 46 0 46 60
Blower/blower vacuums 98 0 11 50 109 50
Ride on mowers 0 25 51 0 51 25
Generators 11 32 96 0 107 32
Hedge trimmers &others 40 192 0 28 40 220
694 491 476 424 1267 915
% for total sales 59.3% 46.3% 40.7% 53.7%
% for mowers 15.2% 28.0% 84.8% 72.0%
According to OPEA approximately 424,000 walk behind lawnmowers and more than
792,000 units of outdoor handheld equipment were sold in Australia in 2005-06. In
addition there were sales of about 80,000 replacement engines and 70,000 pumps in
2005-06 most of which were four strokes. These figures show that there has been
considerable growth in the sales of most products with the exception of chipper
shredders and the category ‘hedge trimmers and others’ whose sales declined in 2005
06 compared with those in 2002. About 17% of walk behind lawnmowers were two
stroke and 83% four stroke which is an improvement in the uptake of cleaner engines
when compared to 2002 when about 30% were two stroke. The situation with
handheld equipment is reverse with nearly 79% being two strokes compared to 47%
in 2002. However, many models of two stroke handheld equipment meet current US
emission standards and care should be exercised in using engine type (two stroke or
four stroke) as an indicator of emissions performance for this class of equipment.
The OPEA 2005-06 sales estimates are shown in Figure 7. OPEA cautions that there
is considerable uncertainty about the estimates for brushcutters and blower/blower
vacuums as OPEA’s figures only represent 50% and 60% respectively of sales of
these products. No estimates of future sales trends were identified during research for
this project.
23Australian sales of 2 and 4 stroke outdoor equipment 2005-6
Other
Generators
Ride on mowers
Blower/blower vacuums
4s
2s
Chipper shredders
Chainsaws
Brushcutter/trimmer
Walk behind mowers
0 50 100 150 200 250 300 350 400
Annual sales (x 1000)
Figure 7: OPEA estimates of equipment sales in 2005-06
Note: "Blower/vac" is an industry term for equipment that combines blowing and vacuuming functions
Briggs and Stratton (Australia) who import engines from the USA, supply the
majority of the four stroke engines for handheld equipment sold in Australia and these
comply with all the current USA and CARB regulations. Imported handheld garden
equipment is shipped fully assembled to a branch or distributor and is then sent to a
retailer. The retailer may or may not provide equipment servicing.
OPEA members have expressed concern regarding the increasing sales of imported
high polluting two stroke engines that allegedly do not meet any emission standards
and come from countries that do not have emission standards. One industry
representative reported that some of the imported trimmers were being manufactured
in China using outdated designs and tooling from two old bankrupt American
companies and these are being sold here at about 30% of the price of traditional
brands and very low cost generators from China now account for around 70% of total
sales. It is difficult to confirm this trend without undertaking a detailed examination of
Australian import data however the significant increase in the sales of two stroke
handheld equipment provides some support for this trend.
On the other hand it is claimed by industry that the ride on mower market (predominately
with compliant four stroke engines) has been stimulated by the Australian / USA free trade
agreement.
245. Australian Users of Small Engines
This section examines the market segments for garden equipment and customer
purchasing behaviour.
5.1 General Public
Purchasing behaviour
Research into consumer purchasing behaviour has found that consumers assess a
product against a range of attributes for example price, weight, brand reputation,
servicing and parts availability, warrantees and guarantees, experience, size,
promotions and discounts. Studies have also revealed that up to 82% of Australians
had bought products on the basis of social or environmental factors in the previous
year (State Chamber of Commerce, 2001). Related to this point, the energy star rating
ecolabel on whitegoods was viewed as a credible environmental claims system which
is well regarded by the general consumer (Product Category Manager, Mitre 10,
personal communications).
As the purchase of small engine garden equipment by the general consumer is an
infrequent purchase which carries a certain of amount of risk. With small engines the
risk can be functional risk (will not perform as expected), physical risk (for example
safe features such automatic cut out on an electric lawn mower), or financial risk
especially for the more expensive items. The general consumer is likely to lessen the
risk by seeking information and by evaluating the information on the available
products over a period of time. The consumer may also lessen the risk by:
• purchasing well known brands;
• buying the brand offering the best warrantees and guarantees;
• buying the most expensive brand, and
• buying a brand they have used before.
Research indicates that the desired attributes of a product may not be well established
at the start of a consumer’s search process but will often be refined as the consumer
learns more about the product. The consumer will also use a ranking and weighting
process based on desired qualities and trade offs may be made.
Reportedly, purchases of engine operated garden equipment are based on price, yard
size, fitness for purpose, and other features such as weight and ease of starting
(Product Category Manager, Mitre 10, personal communications). Males are the
predominant purchasers of garden equipment, however because of changing
demographics there has been an increase in the number of women purchasing these
products.
Less than 5% of lawnmowers purchased are push or electric mowers (Product
Category Manager, Mitre 10 and industry sources, personal communications, 2003).
25Electric mowers are generally perceived as not being as effective as cords have
limited range and rechargeable electric mowers require frequent recharging.
There is a recent trend towards ride on mowers (all four strokes) probably because of
changing demographics, specifically older age groups moving to more rural
environments with larger yards (OPEA, personal communications).
A study (Wilkie, 1994) investigated consumer appliance purchasing behaviour and
found that the general consumer consulted a range of information sources before
purchasing an appliance. The appliance salesperson was found to be the most
important information source for many consumers. Other important information
sources include newspaper advertisements, friends and relatives, catalogues,
consumer reports and brochures/labels. Since Wilkie’s study the internet will have
become increasingly important as a research tool and in some instances as a way to
purchase products. As part of this study there is evidence of low priced products being
sold into the Australian market via the internet only – a practice that is likely to
increase in the future. It was difficult to source any compliance or details on these
products.
At the retail chain level, staff product training is generally voluntary, undertaken out
of store hours and, as an inducement to attend training sessions, suppliers usually
provide incentives for staff. Retail chain purchases are very price driven although
some chains are reportedly interested in stocking goods that have credible
environmental claims (Mitre 10 and other retail chain sources).
IBIS (2006a) reports that the domestic hardware sector, which is dominated by Danks
(Home Timber and Hardware, Thrifty - Link Hardware and Plants Plus Garden
Centre) and Bunnings, is classified as a growth market and the sales of lawnmowers
and other lawn and garden machinery and equipment represent about 14% of sales
revenue.
In summary, it appears that a range of product attributes influences consumer
purchases of lawnmowers and outdoor equipment. Currently there is very little
information about emissions in any of the information sources a consumer is likely to
consult when purchasing these products. Nevertheless, surveys indicate that
consumers are concerned about the environment and are open to including
environmental considerations into their purchase decision. Educating sales staff about
the air emissions from lawnmowers and outdoor equipment together with ecolabels
could therefore be important methods for influencing consumers towards the purchase
of cleaner products.
Equipment Usage
The USA Outdoor Power Equipment Institute, CARB (cited in USEPA, 1998) and the
USEPA (USEPA, 1998) have made estimates of annual usage rates and average life
spans of outdoor equipment for the general consumer user and for the commercial
user. Table 13 gives USA usage and lifespan range for selected items of powered
equipment:
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