Monitoring and Laboratory Division July 2, 2003 California Air Resources Board Small Off-Road Engine Workshop Evaporative Emission Program

Overview of Presentation Need for Regulation and Regulatory Approach Recap of the November 13, 2002 Proposal Significant Comments Received from EMA and OPEI Significant Changes Made to the November 13, 2002 Proposal Performance-Based Certification Overview Significant Changes Still under Consideration Regulatory Agenda

Need for Regulation Uncontrolled Evaporative Emissions from Non Preempt Equipment tpd 45 tpd 41 tpd

Regulatory Approach Use available technology to reduce emissions Set attainable and cost effective emission standards Enforceable control measure Limit burden on industry by: –Allowing certification of evaporative families –Allowing modifications that don’t affect certification –Allowing a phased-in implementation

Recap of the November 13, 2002 Proposal Allowed performance and design-based certification Contained in-use testing liability Set a 1.0 gram/m 2 /day fuel tank permeation standard applicable to all SORE equipment Set a 1.0 gram/day diurnal evaporative emission standard for equipment > 80 cc to < 225 cc Set a 2.0 gram/day diurnal evaporative emission standard for equipment > 225 cc

Significant Comments Received from EMA and OPEI on the November 13, 2002 Proposal ARB held over 10 meetings with EMA and OPEI since the November 13, 2002 workshop in an attempt to improve the proposal Staff received significant comments from EMA and OPEI to develop an enforceable proposal that limited the burden on industry

Significant Comments (Continued) Proposed design option essentially no different from performance option Liability concern over in-use testing No need for a separate permeation standard for equipment > 80 cc (standard within a standard) Proposed standards too stringent for small displacement engines with large fuel tanks Proposed permeation standard too stringent

Significant Comments (Continued) Not enough lead time to implement permeation standard No material alternative to nylon for handheld equipment using structurally integrated nylon tanks Proposal does not allow for the uncertainty of production variability during implementation Proposal too costly for small volume manufacturers

Significant Changes Made to the November 13, 2002 Proposal Removed design-based certification option (not enforceable) Removed in-use testing liability Added language to allow manufacturers to challenge non-compliance determination through independent testing Removed permeation standard for equipment > 80 cc Added an exemption for structurally integrated nylon tanks on equipment < 80 cc

Performance-Based Certification Overview

Allows engine or equipment manufacturers option to certify Requires testing of worst-case control system for each evaporative family Allows equipment manufacturers to substitute “equivalent” fuel tanks and/or fuel lines without affecting certification

Performance-Based Certification Overview Testing Requirements Performance-based certification requires gravimetric testing of tanks on SORE equipment 80 cc Select a model in the evaporative family that is expected to exhibit worst-case emissions Conduct emission testing per applicable test procedure Results must not exceed applicable standard

Performance-Based Certification Overview Test Procedures TP-901, “Test Procedure for Determining Permeation Emissions from Small Off-Road Engine Equipment Fuel Tanks”: –a gravimetric test procedure TP-902, “Test Procedure for Determining Diurnal Evaporative Emissions from Small Off-Road Engines” –a SHED test procedure

Significant Changes Still Under Consideration Considering raising the permeation standard to 2.0 grams/m 2 /day for equipment < 80 cc Considering extending implementation date of permeation standard for equipment < 80 cc to 2006 Considering diurnal standard with standard based on tank volume (applicable to equipment other than walk- behind mowers) Considering a tiered compliance margin for new equipment compliance testing Considering small volume (< 400 units) design-based standards

Standards Under Consideration

Compliance Margins Under Consideration Tiered compliance margins for new equipment compliance testing to account for production variability

Small Volume Design-Based Standards Under Consideration (Engines Sold Without Tanks) Must use engine certified with “nominal” fuel tank and fuel control system Control equipment must include at a minimum: –an “equivalent” fuel line to control permeation emissions –a vent control system –a sealed tethered fuel cap

Regulatory Agenda Take comments on the current proposal Internal draft complete by July 8, 2003 To OAL (July 29, 2003) Publish staff report and regulatory documents (August 8, 2003) Begin 45 day public comment Present the control measure to the Board for their consideration at September 25-26, 2003 hearing

Contacts and Additional Information