The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Outdoor Power Equipment Institute

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX OPEI represents a wide range of companies in the lawn and garden equipment industry -- Integrated handheld product manufacturers. Integrated and Non-integrated wheeled product engine manufacturers. Integrated and Non-integrated wheeled product OEMs. –Wheeled product OEMs typically purchase Class II engines without either fuel tanks or exhaust systems, which must be custom-designed to fit the unique geometry of equipment with very tight space constraints. Component vendors (fuel tanks, carburetors, mufflers, etc.). Today, you will hear presentations from various OPEI members that represent each of these different categories.

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX OPEI Membership Overview Significant small business constituency. –Smaller operating budgets. –Very limited human resources. –Less sophisticated testing abilities. –Lack exhaust and evaporative emission and heat testing capabilities. –Not in a position to perform emission certification responsibilities. –Mostly based in the Eastern U.S. and thus cannot attend meetings in California on short notice.

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX OPEI Membership Overview Appreciate CARB’s willingness to hold public workshops. Accommodations needed to enable small businesses and international members to participate: –One month advanced notice generally required for workshops. –Appreciate allowing video tape of workshop for small U.S. and foreign members that cannot afford to travel to California.

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Industry Commitments Product Safety –Member companies spend millions of dollars annually to participate in research, testing and industry meetings to support industry’s commitment to producing safe products.

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Industry Commitments Environmental Protection –Long term success working with EPA and CARB through proactive cooperation. –Dramatic drop in small gasoline engine emissions over last 10 years -- Phase 2 engines, on average, are between 75% and 90% cleaner than engines from mid-1990s. –These levels are the result of OPEI members investing tens of millions of dollars in emission reduction technologies.

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Moving Forward By carefully considering the unique non-integrated market and application constraints of the lawn and garden industry, we can achieve our mutual air quality and safety goals

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Challenges Peculiar to the Power Equipment Industry Member companies collectively offer a multitude of different products requiring unique exhaust and fuel tank systems. –One size does not “fit all.” –Customization is the rule. –Over 2,000 different equipment models (with over 200 different unique exhaust and a multitude of fuel systems) sold in California by hundreds of different OEMs (most of whom are very small companies). Products are designed and installed by multiple entities who must respond to competing emissions and safety requirements. –Significantly more lead time required than by a more integrated industry. –Unilateral emission or heat design strategies are unworkable and must be coordinated among multiple companies.

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Challenges Peculiar to the Power Equipment Industry Equipment and engines have tight space, weight and geometry constraints and function in severe operating conditions: –Noise –Debris-rich environment –Vibration Equipment is operated by consumers in residential settings making product safety of paramount importance (OPEI’s September 10 and April 4 comments): –Heat generated by equipment operation and catalyst effect. –Surface temperature restrictions (melting plastics and operator burns). –Refueling and storage safety considerations. Captured grass clippings Muffler reignition

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Remaining Challenges Exhaust and evaporative controls/regulations must respond to safety/application challenges and non-integrated production process Huge challenge of designing, testing, and integrating a myriad of different new regulated components made by different vendors/suppliers through iterative process Addressing safety concerns with high-efficiency, large catalysts Addressing safety concerns with pressurizing fuel tank system in terms of tank cracking, fuel leaks, and spewing of gas when consumer opens pressurized tank

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX Industry Commitments Product Safety –OPEI wants to partner with CARB (and other knowledgeable safety experts) to address all the safety aspects of the upcoming exhaust and evaporative emission regulations. –Standing commitment from OPEI to CARB to conduct or substantially contribute to a joint field study (including the provision of sample power equipment).

The Outdoor Power Equipment Institute 341 South Patrick Street Alexandria, VA FAX CARB and OPEI -- A Continued Dialog to Create Effective, Safe and Achievable Regulations Continued dialog is necessary on the following critical issues: –Evaluation of CARB’s and OPEI’s underlying database. –What physically would be required to install safely and effectively the proposed technologies on actual power equipment? –The proposed implementation timeline for designing, engineering, testing, and certifying emission-compliant and safe products. –CARB’s inventory estimate and inventory projections for equipment –The emissions reduction projections from this regulation. –The cost-effectiveness assumptions for this regulation and their impact on California businesses.