1. Evaporative Emissions from Small Engines Harold Haskew July 2, 2003

2. Ethanol Fuel? The test and certification procedures specify today’s automotive emission test fuel – no ethanol is allowed Is it your intent to update the fuel to an ethanol-containing fuel in the future? From Evaporative Emissions from Off- Road Equipment (June 22, 2001)

3. Permeation Requirements: a Changing Target 2001-02 - Discussions indicating 3.0 g/M2/day (Variable Temp Test 65/105F) 8/22/01 Harold Haskew 8/02 Ron Sahu 10/4/02 Ron Sahu 11-13-02 Workshop - “1.0 g/M2/day for all … Equipment” (Variable Temperature Test 65/105F) 12-18-02 (TP-901) - 40ºC Constant Temp Permeation (Doubles the stringency – but HH Only)

4. Nylon 30 Day minimum Soak @ 72°F 65/105F CARB Diurnal Sulfonation

5. Non Hand-Held Equipment The earlier test procedures required Class 1 WBMs to pass a performance VT-SHED test (1.0 g/day), or a “Design Standard”, and have fuel tank permeation performance limit of 1.0 g/M2/day (65/105F Cycle) The April 03 changes removed: 1) the “Design Standard” option for NHH equipment, and 2) the separate tank permeation requirement. All Class 1 NHH equipment must now meet a 1.0 g/day VT- SHED performance standard.

6. Durability Demonstration (TP-902 4/29/03) 500 hours of direct sunlight exposure on the Cap and Tank 3000 Pressure/vacuum cycles on the Tank (4 to -1 psig) 5000 cycles on the valves, cables, and linkages 1 million “slosh” cycles If canister equipped, the canister must see: –Suitable fuel vapor cycling –100 temperature cycles –10 million vibration cycles at 60 hertz

7. NHH Performance Requirement (TP-902 4/23/03) Perform Durability Demonstration Fill with Fuel and Operate for 5 minutes Soak the tank and components for 140 or more days at 20-40C Drain and fill to 50% with CA Phase 2 Test Fuel Purge Carbon Canister (if so equipped) Operate engine for 15 minutes One hour hot soak Soak at 65F for 2 hours One 65-105-65F Diurnal Cycle in VT-SHED

8. CARB’s Benchmarks (None meet the Current Procedures)  6 Mowers with Phase 4 control systems (Avg = 0.89 g) April 25, 2002 Workshop (WBM-TestResults.xls)  ATL Tests on Mower 03 with Phase 4 controls (1.23 g) (preliminary-data-tables.xls)  WBM with Tank Pressure Relief Valves (1.07g @ 4 psi) (Report dated Sept 17, 2002)  Class 2 Equipment with Carbon Canister (Metal 6 gal Tank) (Report dated March 25, 2003)

9. Summary Evaporative control can be accomplished, given time, talent and resources for development, and a receptive market for the resulting product. We are not aware of any data that exist today demonstrating that Class 1 or 2 equipment can comply with the proposed standards of 1.0 and 2.0 g/day.