United States
Environmental Protection
Agency
Otfice ot Air ana' Radiation
(ANR-443)
Washinaton. DC 20460
May 1995
Air
EPA Regulatory Impact Analysis
and Regulatory Support
Document
Control of Air Pollution; Emission
Standards for New Nonroad Spark-
Ignition Engines At or Below 19
Kilowatts
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REGULATORY IMPACT ANALYSIS
AND
REGULATORY SUPPORT DOCUMENT
Control of Air Pollution;
Emission Standards for
New Nonroad Spark-Ignition Engines At or Below 19 Kilowatts
May 1995
U.S. Environmental Protection Agency
Office of Mobile Sources
Certification Division
2565 Plymouth Road
Ann Arbor, MI 48105
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ACKNOWLEDGEMENTS
Members of the Engine Manufacturers Association (EMA), the Outdoor Power
Equipment Institute (OPEI), the Portable Power Equipment Manufacturers Association
(PPEMA), and many individual manufacturers have provided EPA with input on the
technical aspects of the engines and equipment potentially impacted by the proposed
emission standards. A number of manufacturers provided essential test data,
production engines for testing, or prototype engines for testing. These manufacturers
include Briggs & Stratton Corporation, Tecumseh Products Company, McCulloch
Corporation, Homelite Corporation, and Poulan/WeedEater. EPA sincerely
appreciates the cooperation of industry in EPA's technical evaluation of these engines
and equipment.
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TABLE OF CONTEN
Chapter 1: Technology Assessment
1.1. Adequacy of Proposed Test Procedures 1-2
1.1.1. Emission Test Procedures 1-2
1.1.2. Durability Test Procedures 1-3
1.1.2.1. General Emission Control System Durability ... 1-3
1.1.2.2.1. Certification of Catalysts by Thermal
Aging 1-5
1.1.2.2. Representation of Available Fuel 1-9
1.1.2.3. Differential Impacts on Emissions of Various
Blends 1-9
1.2. Achievability of Emission Standards 1-9
1.2.1 Engine Class Determinations 1-9
1.2.2. Class I and II (non-handheld) Engine Concepts Proven
with Prototype Engines 1-11
1.2.3. Class III-V (handheld) Engine Concepts Proven with
Prototype Engines 1-12
1.2.4. Lowest Feasible Emission Standards 1-13
1.3 Impacts on Performance 1-15
1.3.1 Fuel Consumption 1-16
1.3.2. Power 1-18
1.3.3. Noise 1-20
1.3.4. Safety 1-20
1.3.5. Maintenance 1-21
1.4. Impacts on Equipment 1-21
Chapter 1: References 1-53
Chapter 2: Technology Market Mix and Cost Estimates for Small SI Engines
and Related Equipment 2-1
2.1 Market Mix and Emission Reduction Technology Estimates 2-3
2.2 Variable Hardware and Production Cost Estimates per Engine
Class 2-4
2.2.1 Class I 2-6
•
ii
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Ill
2.2.2. Class II ........................................... 2-12
2.2.3. Handheld Equipment Engines (Classes III, IV and V) .....,...,, 2-15
2.2.3.1. Class III ,....,..,„,...,„.,....,.,......,.,,, 2-16
2.2.3.2. Class IV'......,..,............. .............. 2-19
2.2.3.3. Class V .................................... 2-21
2.3 Research and Development Cost Estimates per Class ....,.,...,...,. 2-23
2.4. Equipment Variable Hardware and Production Cost Estimates .......... 2-25
2.5 Total Costs for Implementing Emission Control Technology ,...., 2-28
Chapter 2 References 2-39
Chapter 3: Analysis of Aggregate Costs and Economic Impacts ................... 3-1
3.1. Aggregate Cost Analysis ..... 3-11
3.1.1. Profitability on Increased Costs 3-11
3.1.2. Variable Hardware Costs 3-14
3.1.2.1. Per-Engine Variable Hardware Costs For Each
Emission Standard Category-- 3-14
3.1.2.2. Aggregate Annual Variable Hardware Cost ...... 3-16
3.1.3. Production Costs . ..... 3-17
3.1.3.1. Per-Engine Production Costs For Each Emission
Standard Category- 3-17
3.1.3.2. Aggregate Annual Production Cost Increase 3-19
3.1.4. Increase in Capital Costs .............................. 3-20
3.1.5. Program Administration Costs .......................... 3-21
3.1.6. Fuel Savings ............ 3-22
3.1.7. Consumer Cost 3-23
3.1.8. Cost Summary .................... 3-25
3.1.8.2. Accounting for Costs as They are Recovered ........ 3-26
3.6.3. Evaluation of the Stream of Costs 3-26
3.2. Incremental Economic Impacts 3-27
3.2.1. Capital 3-27
3.2.2. Employment ................... 3-27
3.3. Energy 3-29
Chapter 3: References 3-40
Chapter 4: Environmental Benefit 4-1
4.1. Estimated Emissions Reductions 4-2
4.1.1. Aggregate HC and CO Reductions and NOx Increment 4-3
4.1.1.1. Sales 4-3
4.1.1.2. Survival Probabilities 4-3
4.1.1.3. In-Service Population 4-4
4.1.1.4. Aggregate Source Emissions Inventory 4-4
4.2 Air Quality Benefits ............. ....................... 4-5
4.2.1. VOC.............. 4-5
4.2.1.1. Health and Welfare Effects of VOC Emissions 4-5
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IV
4.2.2. Benzene , . 4-6
4.2.2.1. Projected Benzene Emission Reductions 4-7
4.2.2.2. Health Effects of Benzene Emissions ........ 4-7
4.2.2.3. Carcinogenicity of Benzene and Unit Risk
Estimates 4-8
4.2.3. 1,3- Butadiene , 4-9
4.2.3.1. Projected 1,3-Butadiene Emission Reductions .. 4-10
4.2.3.2. Health Effects of 1,3 - Butadiene Exposure 4-10
4.2.3.3. Carcinogenicity of 1,3-Butadiene 4-10
4.2.4. CO 4-11
4.2.4.1. Health and Welfare Effects of CO 4-11
4.2.4.2. Developmental Toxicity and other systemic
Effects of Carbon monoxide 4-14
Chapter 4: References 4-17
Chapter 5: Cost-Effectiveness Analysis 5-1
5.1. Cost-Effectiveness Methodology 5-1
5.2. Annualized Costs and Annualized Pollutant Reductions 5-2
5.3. Cost-Effectiveness 5-2
5.3.1. Hydrocarbon (HC) Cost-Effectiveness 5-2
5.3.2. Carbon Monoxide (CO) Cost-Effectiveness 5-5
Chapter 5: References 5-9
Appendix A: Small Engine Testing Facility, University of Michigan Walter E. Lay
Automotive Laboratory A-1
A.1. Goals A-1
A.2. Objectives A-2
A.3. Description of Facility — A-2
Appendix B: Manufacturer and Product Summary B-1
B.1. Introduction B-1
B.2. Engine Manufacturer Summary — ... B-1
B.2.1. Listing of Known Engine Manufacturers B-3
B.2.2. Listing of Known Engine Models per Manufacturer B-3
B.2.2.1. Number of Engine Models B-3
B.2.2.2. Engine Model Codes B-4
B.2.2.3. Number of Engine Models in Each Standard
Category Per Manufacturer B-4
B.3. Estimate of Historical and Future Equipment Consumption
(Sales) B-11
B.4. Analysis of Fuel Consumption and Power Changes B-44
B.5. Technology Cost Estimation B-50
Appendix B References B-67
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Appendix C: Baseline Emissions, In-Use Deterioration, and Development of In-Use Emission
Function .......,....,...,„....„..,....,,,,,,.......,...,... C-1
C.1. Baseline and In-Use Emissions Estimates for Pre and Post Control Engines C-2
C.1.1. Determination of Baseline Emissions and In-Use Deterioration Estimates
for Pre-Control Engines ,......,...,...., C-3
C.1.2. Determination of Baseline and In-Use Deterioration for Post-Control
Engines C-5
C.2. EPA Development of Emissions Deterioration Equation for Environmental Benefit
Analysis C-7
C.3 In-Use Pre-Control and Post Control Engine Testing C-9
C.3.1 Estimated Emission Deterioration per Technology for Classes I and IC-10
C.3.1.1. Enleanment with Major redesigns to carburetor and fuel
distribution system and Enleanment with Minor redesigns to
carburetors C-10
C.3.1.2. Changes in ignition timing, valve timing C-11
C.3.1.3. Combustion Chamber Redesign C-11
C.3.1.4. Valve System Improvements including Valve Timing.. C-11
C.3.1.5. OHV with minor mods to carburetor C-11
C.3.1.6. Improved Cooling C-11
C.3.1.7. Conversion of 2 Stroke to 4 Stroke Engine Design . C-12
C.3.1.8. OPTION: Catalyst C-12
C.3.2. Estimated Emission Deterioration per Technology for Class III-V
Engines C-13
C.3.2.1. Major and Minor Carburetor Modifications C-13
C.3.2.2. Carburetor Limiter Adjustment Caps C-14
C.3.2.3. Combustion Chamber /Scavenging/Port Timing
Modifications C-14
C.3.2.4. Cooling Improvements C-14
C.3.2.5. 4 Stroke C-14
C.3.2.6. OPTION: Catalyst C-14
Appendix C: References C-35
Appendix D: Summary of Burden Imposed by the Information Collection Requirements — D-1
Appendix E: Hourly Test Length Estimate E-1
Appendix F: Supplementary Tables for Chapter 4 F-1
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VI
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Introduction
This document presents the Regulatory Impact Analysis (RIA) for
the Final Rulemaking (FRM) for the establishment of Emission
Standards for New Nonroad Spark-ignition Engines At and Below 19
Kilowatts, herein after referred to as the Smallgas FRM.
This RIA is organized into chapters and appendices. Chapter 1
presents the engineering evaluation EPA has undertaken to determine
the possible technical solutions for emission reductions from these
engines. In Chapter 2, the specific technology and the related cost of
such solutions are discussed. Chapter 3 considers the aggregate costs of
the Proposal and analyzes economic impacts. Chapter 4 quantifies the
emission reduction benefits of the Proposal and assesses impacts on
environmental and health effects of these emissions. Chapter 5 presents
the schedule of emission reductions and costs of the Proposal and
relates them to one another in terms of cost-effectiveness. Several
appendices are provided which contain analyses and data upon which
data in the chapters are based.
Vll
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vm
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Chapter 1: Technology Assessment
The Clean Air Act Amendments of 1990 Section 213(a)(3) present
statutory criteria that EPA must evaluate in determining standards
which achieve the greatest degree of emission reduction. These criteria
include technical feasibility, cost, time line constraints, safety, noise and
energy. This chapter presents the technical analyses and information
that form the basis of EPA's determination that the proposed emission
standards are technically achievable accounting for all the above
constraints except cost.. Specific areas of discussion are: adequacy of the
test procedures; emission control technologies; achievable emission
reduction; impacts on performance (i.e., energy, noise and safety); and
impacts on equipment. Cost information is presented in Chapter 2.
1.1. Adequacy of Proposed Test Procedures
1.1.1. Emission Test Procedures
In order for EPA to successfully regulate tailpipe emissions, the
Agency strives to establish test procedures that ensure use of
technologies that not only meet the emission standards when tested over
the required test procedures, but also result in a predictable emission
reduction in actual use. In the nonroad environment, one engine model
is likely to be used in a large number of equipment applications. It will
1-1
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1-2
take a substantial amount of EPA time to develop test procedures that
give the best approximation of average use of a nonroad engine in
actual use. EPA and industry are currently studying test procedure
options with a goal to choose emission test procedures that ensure
emission reductions from engines that use future technologies capable of
meeting the second phase emission standards. However, considering
the first phase emission standards levels and the tight time constraints
proposed in this Smallgas FRM, EPA has decided that a meaningful first
step in HC, CO, and NOX emission reduction can be realized in the near
future from small SI engines using available test procedures. The test
procedures available at this time are the SAE J1088 engine test
procedures for nonroad engines developed by the Society of Automotive
Engineers (SAE) and currently being coordinated with the ISO 8178 test
procedures developed by the International Standards Organisation
(ISO).
The SAE procedures were first published in 1974 with a push to
finalize the test procedures coming as a result of the regulatory actions
of the California Air Resources Board (CARB) in 1990. The 1974 SAE
procedures were the result of work from the SAE Small Engine
Emissions Subcommittee which submitted a proposal for spark ignited
engines. The Small Engine Emissions Subcommittee was formed which
consisted of individuals from industry, the academic community, and
the federal government. The J1088 test procedures document that
resulted from this group's work is a draft recommended practice. As
such it allows as much flexibility as possible in the physical construction
of the experimental apparatus. As a result of the flexibilities afforded
by the recommended practice, there is currently much variation in test
equipment in the laboratories of small engine manufacturers.
The finalized version of the J1088 recommended practice accounts
for the evaluation of gaseous exhaust emissions from small utility
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engines typically less than 20 kW. The SAE procedures include a steady
state test cycle comprised of a specified number of different load and
speed conditions called "modes". Emission measurements are taken
three times per mode only after the engine reaches equilibrium
temperatures in that mode. Three different cycles (sets of modes) are
available for the range of small engines: (1) those used in non-handheld
intermediate speed applications; (2) those in non-handheld rated speed
applications; and, (3) those used in handheld rated speed applications.
The cycle for non-handheld intermediate speed applications consists of
six different speed/load modes, five load conditions that span the load
range of the engine at intermediate speed and one no load condition at
idle speed. The cycle for non-handheld rated speed applications also
consists of six different modes, five load conditions at rated speed and
one no load condition at idle speed. The modes are then weighted to
estimate the relative percentage of time a non-handheld engine spends
in each mode of operation in actual use. The cycle for handheld
applications consist of 2 modes, one full load condition at rated speed
and one no load condition at idle speed. For handheld applications,
weightings of the two modes are based on the relative percentage of
operation time in each mode expected in actual use. The weightings
utilized by CARB(l) are also used in this rulemaking.
Test procedures for this rule are detailed in Subpart E, Sections
90.401- 90.426. The procedures are compatible with J1088, however a
number of specific modifications have been made to limit the flexibilities
of the recommended practice. This allows the certification test
procedures to be more repeatable between laboratories performing the
testing. This is important to ensure that in-use testing can be compared
to the emission standards without realizing a wide tolerance band to
accommodate technical differences in how the test procedures are
performed at different laboratories.
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1-4
1.1.2. Durability Test Procedures
1.1.2.1. General Emission Control System Durablllty-EPA
expects the emission control technologies used to meet the exhaust
emission standards specified in this rulemaking will be sufficiently
durable that post control emission performance deterioration rates will
not increase over pre-control deterioration rates. In Chapter 5, EPA
provides its rationale behind this expectation.
Although EPA is not adopting full emission control system
durability demonstration requirements in this notice, manufactures are
fully expected to design such systems to be effective under normal in-
use operating conditions over time. Full emission control system
durability demonstration requirements are expected to be included in
the second phase regulations for small engines.
1.1.2.2. Catalytic Converter System Durablllty-EPA is adopting
durability demonstration requirements for catalysts in this notice.
Relative to all other types of emission-related engine components,
catalysts are unique in the following respects.
• A catalytic converter represents an emission control system that
can realize substantial emission control deterioration without
causing an engine performance change detectable by the
equipment operator.
• Since it is the last component in the emission control system, a
catalyst can compensate for sub-standard performances by other
emission control components, but it is not itself supported by any
other back-up component that would be able to compensate for a
reduction in catalyst performance capability.
• The addition of a catalyst can allow compliance with the
emission standards without any improvements in the
performance of other emission-related engine components and
without any reduction in engine-out emissions.
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• Substantial reductions in conversion efficiency can result from
abrasion or fracturing as a result of relative motion between the
catalyst and its protective outer metal jacket, poisoning as a result
of fuel contaminants (e.g., lead), glazing as a result of excessive
quantities of lubricating oil in the exhaust, and/or thermal
degradation as a result of exposure to excessively high
temperatures for prolonged periods.
EPA is concerned that these unique conditions that are inherent
in catalyst usage warrant the need for some means for validating the
adequacy of catalysts that are added to engines to provide compliance
with the emission standards during in-use operation. Various
approaches can be used for ensuring that the "long term" conversion
capabilities of catalyst will be adequate. For example, certification
engines can be tested with catalysts which have been subjected to some
type of "aging" process which substantiates that the catalysts are
adequately designed and fabricated. Alternatively, certification engines
can be tested with new catalysts that have been proven to be
satisfactory by meeting the requirements of a catalyst certification
procedure that is separate from the engine emission certification test.
These two alternatives are discussed in more detail below.
The main advantage of a validation approach that would involve
the use of "aged" catalysts on certification engines would be its
simplicity. The aging process could be carried out by either the engine
manufacturers or the catalyst vendors. In either case, there would be no
requirement for special catalyst performance testing, and hence, no need
for the establishment of performance standards that would be needed
for evaluating the test results.
The main disadvantage of this approach is the possible negative
impact on catalyst usage that might result from a Phase I certification
process which imposes durability testing requirements on catalysts but
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not on certification engines or any other engine components involved in
their construction. The dependence of successful certification of engine
families on the performance capabilities of aged catalysts might result in
engine manufacturers being reluctant to use catalysts to meet the
applicable emission standards. Also, given that there are no field data
on small engine catalysts, it would be extremely difficult to design a fair
aging procedure that could be evaluated by the certification engine test
and accompanying emission standards.
The adverse results of using an aged catalyst on a certification
engine would be avoided by the engine manufacturer's use of a new
catalyst that is "certified" by the supplier or the engine manufacturer as
having design and fabrications details that result in specific long term
conversion performance capabilities. The main advantage of this
approach is that it addresses the reluctance of engine manufacturers to
use catalyst technology because it makes the demonstration process
transparent to the engine manufacturer. The catalyst manufacturer may
provide a statement of compliance to the engine manufacturer to be
submitted as part of the certification application. This approach has the
disadvantage of being more complicated in that it would additionally
involve the establishment of limits on the amount of efficiency loss that
is acceptable and a test procedure for determining compliance with such
limits.
As a consequence of concerns regarding possible negative impacts
on catalyst development for small engines that might result from a
provision requiring the certification of engines with aged catalysts, EPA
is not adopting such a requirement in this Small Gas FRM. Instead,
EPA is requiring that for systems utilizing catalysts, certification engines
must be equipped with a new "certified" catalyst during emission
certification testing. A "certified" catalyst is one which has been
demonstrated to be capable of successfully meeting the requirements of
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a separate catalyst durability demonstration procedure which is
described in more detail in the following text section. This approach
will ensure that durable catalysts are used on small engines while
avoiding excessive requirements that could discourage the development
of very promising catalyst technology.
1.1.2.2.1. Certification of Catalysts by Thermal Aging-
Exhaust emission control systems which utilize catalytic converters have
been used extensively in on-highway applications for a number of years.
Such usage has resulted in improvements that greatly mi; mize the
likelihood of the previously discussed degradations in cr.;.Jyst
conversion efficiency. For example, abrasion and fracturing has been
essentially eliminated by the use of intumescent protective wrapping
which permanently expand when initially heated and, as a result, hold
the catalysts securely in position with very little possibility of
destructive contact with the outer metal jackets. Poisoning by lead in
the fuel has been eliminated by the use of "lead-free" fuel. Oil glazing
has been minimized by improvements in engine design and build
practices which reduce the various adverse effects of engine wear, such
as excessive oil consumption. Thermal degradation effects have been
reduced by: (a) improvements in engine design and manufacture which
reduce the possibility of operation that can result in excessive catalyst
temperatures, such as ignition misfire; and (b) improvements in catalyst
design and fabrication which raise thermal thresholds so that brief
exposure times to temperatures well in excess of normal operating
temperatures can be tolerated without significant loss of conversion
efficiency. Exposure to temperatures as high as lOOOoC for several
hours without an excessive loss of conversion capability is possible
when a catalyst is designed and fabricated in accordance with currently
used good engineering practice.
EPA anticipates that the use of catalysts for nonroad applications
n
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will be based on on-highway experience concerning means for
minimizing catalyst performance degradation. However, the design and
operating conditions of small engines may be even more conducive to
high catalyst temperatures than on-highway applications. Catalysts
used for small engines will be located very near the exhaust port. Also,
the exhaust of small engines is likely to contain a higher fraction of
unburned fuel, which in the presence of oxygen, can provide a greater
potential for excess catalyst temperatures from exothermic oxidation
reactions. For these reasons, EPA is focusing on resistance to thermal
stress for evaluation in the catalyst certification procedure. The purpose
of the certification procedure is to ensure that the catalysts are designed
and fabricated in accordance with principles that have been proven to
provide adequate resistance to thermal degradation.
1.1.2.2.2. Generation of Elevated Catalyst Temperatures-
With respect to evaluating a catalyst's resistance to thermal
degradation, two basically different approaches can be used for
generating the desired elevated exposure temperatures. In one
approach, the catalyst is heated as a consequence of being exposed to a
high temperature environment. In the other approach, the catalyst is
heated as a result of two effects, the temperature of a hot gas mixture
that enters the catalyst and the exothermic conversion reactions that
occur as the mixture flows through the catalyst. These are described in
more detail later.
1.1.2.2.3. Exposure to Hot Air in an Oven--A test catalyst
can be exposed to a high temperature environment by placing it in an
oven that is at the desired air temperature and maintaining the oven at
that temperature for a specific time interval. This is one of the simplest
methods for thermally stressing the catalyst since a relatively few
number of test parameters are involved. Also, this technique has been
used for many years in catalyst design development work. The two
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essential parameters are the oven temperature and the duration of the
exposure. Other possible variables of importance include the chemical
composition and volumetric flow rate of a gas or gaseous mixture that
flows through the internal passages in the catalyst during oven
exposure.
1.1.2.2.4. Exposure to Synthetic Exhaust Gas Mixtures-
The heating of a catalyst as a consequence of exposure to a hot gas
mixture which undergoes catalytic reaction can be accomplished by
means of a heated synthetic exhaust gas mixture. This approach to
catalyst thermal stressing is more representative of in-use conditions
than oven exposure but it involves considerably more test variables.
These variables include the means that is used to generate the gas
mixture, the composition and temperature of the mixture, and time that
it flows through the test catalyst. All of these variables, with the
exception of the duration of the exposure, can be based on the
conditions that will exist when the in-use engine for which the catalyst
is intended is in normal operation. Exposure duration involves one
additional parameter, the anticipated life of the engine. The degree to
which the exposure testing represents the conditions that the catalyst
will experience in the field will be directly related to how closely the
duration of the exposure correlates with the anticipated engine life.
With respect to such correlation, variations in the exposure procedure
are possible. Regardless of the duration of the correlated exposure time,
variations in the exposure testing procedure are possible. For example,
the duration of the exposure test may be set equal to the correlated
exposure time. On the other hand, the duration of the test may be
shortened, with some technique, such as linear regression, being used to
extrapolate test results to the full correlated exposure time.
1.1.2.2.5. Exposure to Actual Exhaust Gas Mixture-As is
the case with exposure to synthetic exhaust gas mixtures, exposure to
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real exhaust gas mixtures is more representative of in-use conditions
than oven exposure but it involves even more test variables than is the
case with exposure to synthetic exhaust gas mixtures. The variables that
are involved in addition to temperature and time include engine type,
engine operating conditions, the duration of each different type of
engine operation and the chemical composition and volumetric flow rate
of the exhaust gas mixture during each type of engine operation. As is
the case with exposure to synthetic exhaust gas mixtures, other variables
must be considered, such as the representivity of the duration of the
exposure and the use of an abbreviated exposure period with some
means for extrapolating the test results.
1.1.2.2.6. Adopted Methodology-The use of an oven
exposure procedure for the evaluating catalyst resistance to thermal
degradation is adopted in this Small Gas FRM. This procedure involves
the heating of the test catalyst in air to an initial temperature 500°C for 2
hours, and a final temperature 1000°C for six hours. This procedure is
adopted in lieu of procedures which involve exposure to synthetic or
actual exhaust gas mixtures for a number of reasons. One of the main
reasons is that EPA believes that the oven aging procedure aggressively
and directly stresses the catalyst and is the best method for assessing the
most major catalyst durability concern: thermal stability. Also this
method is much less complex than the other exposure procedures.
Another reason is the present lack of the information that is
essential for the effective implementation of the other two alternative
procedures. For example, in the case of the procedure which involves
exposure to synthetic exhaust gas mixtures, information is lacking
regarding the most appropriate test parameters, such as the
temperature of the mixtures and the duration of the exposure.
Similarly, with respect to the procedure which involves exposure to
actual exhaust gas mixtures, information is needed regarding a number
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of test variables that are related to the engine that is used to generate
the exhaust gas mixture, such as its combustion cycle and power output,
the manner in which it is operated and the operating times that are
involved in each phase of the operating cycle.
1.1.2.3. Evaluation of Aging Effects-
1.1.2.3.1. Basic Evaluation Approach-Catalytic
converter evaluation would involve the determination of the extent to
which the performance characteristics of the test catalyst had been
adversely affected. Of particular significance ~vould be the adverse
effects on the catalysts conversion capabilities vvith respect to the
oxidation of hydrocarbons and/or carbon monoxide and/or the
reduction of oxides of nitrogen.
1.1.2.3.2. Conversion of Synthetic Exhaust Gas Mixture-
The effect of the aging process on catalyst conversion effectiveness could
be determined by flowing a synthetic exhaust mixture through the
catalyst under representative conditions and determining the reduction
in efficiency that occurs. One advantages of such an approach is its
simplicity. Engine operation is not involved, also there are relatively
few variables, such as the composition, temperature, and flow rate of
the gas mixture. One of the disadvantages is the requirement for some
means for generating the mixture.
1.1.2.3.3. Conversion of Actual Exhaust Gas
Mixture~In lieu of a synthetic exhaust gas mixture, an exhaust gas
mixture could be used that is obtained by the operation of an engine
that is representative of the in-use engines that will be equipped with
the production catalysts. However, a number of variables that are
related to the engine, such as the components involved in its
construction, its age and condition, and its horsepower rating, and a
number of variables that are involved in its operation, such as speed
and load complicate this procedure.
o?'
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1.1.2.3.4. Adopted Methodology-The use of a
procedure which uses a synthetic exhaust gas mixture for evaluating the
effects of thermal stressing is adopted for several reasons. One of the
main reasons is the relative simplicity of such a procedure. For
example, it does not involve the questions regarding the in-use
representivity of test parameters, such as the temperature of the mixture
and the duration of the test, that arise when a synthetic exhaust gas
mixture is used for actually thermal stressing a catalyst. For evaluation
purposes, any fixed temperature which allows the conversion reactions
of interest to occur can be specified. The specification of a particular
exposure time is not required since the conversion efficiency existing as
a result of the previous thermally stressing is involved rather than a
time-related change in efficiency. Furthermore, a procedure which uses
synthetic exhaust gas is simpler than a procedure that uses actual
exhaust gas in that it does not involve detailed information that is not
readily available at this time regarding the operating conditions of the
various types of engines that are utilized in the various applications
covered by this Small Gas FRM. Another reason supporting use of
synthetic exhaust gas mixture is the standardization that would result;
all catalysts would be aged under the specific conditions that are
specified in Subpart E of this Part.
1.1.2.4. Allowable Degradation Limits-Durability testing of on-
highway engines results in emission control system deterioration that is
typically in the range of 10 to 20%. As a consequence of the
improvements that have been made in engine design and fabrication,
most of this deterioration is the result of reductions in the performance
of catalysts which have an initial conversion efficiency on the order of
90%. On-highway experience suggests that a limit of 15% on the
deterioration of catalysts that are used on the engines that are covered
by this notice might be appropriate.
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The limited information that has been obtained by EPA
regarding small engine catalysts suggests the possible use of very wide
variations in initial conversion efficiency, with values as low as 30% in
some applications. Such a development might make the use of several
different deterioration limits that are proportional to ranges of initial
conversion efficiencies appropriate. EPA thereby establishes a fixed
deterioration limit of 20% on the basis of on-highway experience and
the absence of information at this time regarding the conversion
efficiencies that will be used with small engines.
In addition, the Agency does not hold catalyst manufacturers
accountable for pollutants which they were not designed to reduce (i.e.,
NOX) or oxidize (i.e., HC or CO). Therefore, the engine manufacturer
must specify the pollutants that the catalyst will be converting and
submit data on only that pollutant. For catalysts that convert CO on an
already low CO emitting engine (i.e., CO levels are below the standards
enough such that if the catalyst is removed or deteriorates to 0%
efficiency on conversion of CO, then the engine will still emit CO
emissions below the CO standards), the catalyst manufacturer of the
two-way catalyst will r c have to meet the CO conversion deterioration
limit.
1.1.3 Certification Fuels
1.1.3.1. Representation of Available Fuel-Manufacturers will
have two options for certification fuel used for gasoline fueled engines
for this rule. The first option is an industry average fuel which has the
composition of a typical summertime fuel sold in 1990. The second
option is to use a certification grade fuel commonly known as Indolene.
The specifications for each fuel are detailed in Section 90.308 and Table
3 in Appendix A to Subpart D of the regulation language. Table 1-07
shows how the specifications of Clean Air Act Baseline (CAAB) relates
-------
1-14
to certification fuels including Indolene, California certification Phase I
fuel and European test fuels(2)(3)(4)(5)(6).
1.1.3.2. Differential Impacts on Emissions of Various Blends--
Preliminary testing has been performed with shows the emission results
of regulated and unregulated emissions on several fuels. The testing
was performed on a 4-stroke OHV 2.6kW Tecumseh engine which can
be considered an advanced engine for it was OHV and contained pump
lubrication, electronic ignition and aluminum, cylinder with iron sleeve
which is not presently representative of the majority of lawn mower
engines in the field.- Table 1-08 presents information on changes in
emissions results due to different test fuels(7). Slight variations between
emission test results are observed. A maximum difference of 20% is
seen in the results on Reformulated fuel with Ethanol compared to the
industry average.
1.2. Achievabilitv of Emission Standards
The following emission information on available technologies and
data on prototypes using the technologies were collected from industry,
SAE papers and EPA analysis of information on technologies. EPA has
determined that, to set equitable standards for the vast range of engines
covered by this proposal, it is necessary to set up five engine classes
that are capable of achieving different standards. The need for these
classes is discussed in the section 1.2.1, and the classes will be integral
to each discussion of achievability.
1.2.1. Engine Class Determinations
EPA is proposing, based on input from industry and the
California Air Resources Board, to group engines in five classes each
assigned a unique set of emission standards based on technical
feasibility. The first two classes are for non-handheld equipment
engines. The remaining three classes are for handheld equipment
-------
1-15
engines. All classes are distinguished by engine displacement with
Class I consisting of engines less than 225 cubic centimeters(cc) and
Class II includes engines greater than 225cc. Handheld classes consist of
Class III including engines less than 20cc, Class IV including engines
20cc-50cc and Class V consisting of engines greater than 50cc.
EPA has decided to divide the regulated engines into five classes
because there are unique constraints that make five sets of proposed
emission standards necessary in the first phase of regulation. First, it is
necessary to adopt different emission standards for the classes of
engines used in handheld equipment than for classes of engines used in
non-handheld equipment. Second, within the combustion process type,
there is still a need to adopt different levels of emission standards based
on engine displacement size. California is also regulating these engines
within the same five classes for much the same reasons as EPA. This
will ensure harmonization between the Federal and California programs.
Current 2-stroke engines cannot be modified in the short timeline
of this rule (within a reasonable cost) to achieve the low level of HC and
CO emission achievable by modifying current 4-stroke engines.
Handheld equipment engines have unique performance needs, such as
high power to weight ratio, high speed, and multi-position use, that are
currently most often achieved through the use of 2-stroke engine
technology. Non-handheld equipment are generally not as constrained
and can use either 2- or 4-stroke engines. Furthermore, by the
implementation date in this phase 1 rule, there are inadequate
technological substitutes to replace all 2-stroke engines and still meet the
unique needs of handheld applications. Therefore, the emission
standards achievable for Classes III-V on the phase 1 timeline must be
the levels achievable through modification of current 2-stroke handheld
engines. Since 4-stroke engines are generally available fo use in non-
handheld equipment, the emission standards for the Classes of non-
-------
1-16
handheld engines will be based on modification of 4-stroke engines.
EPA will further divide engine classes on the basis of engine
displacement. Divisions are adopted because there are two distinct
technical hurdles faced by engines with smaller displacement. Smaller
displacement engines experience: (1) Higher level of flame quenching in
the combustion chamber; and, (2) Lower average horsepower output
than larger displacement engines.
First, smaller engines produce higher levels of HC emissions due
to wall induced flame quenching. As combustion chamber displacement
decreases the resulting surface to volume ratio becomes greater. The
fuel ignites at the same rate as a larger engine, but the fuel/air mixture
propagates to the cylinder wall more quickly, resulting in a higher
percentage of fuel remaining unburnt in the quench area and being
expelled from the cylinder in the unburnt state.
Flame quenching can occur at any time during operation. When
an engine is first started, flame quenching occurs when the Jtuel
condenses or deposits on the surfaces of the combustion chamber and is
not ignited during flame propagation. This often results in higher HC
and CO emissions during cold start up. After the engine is up to
operating temperature, the likelihood of such condensation or deposition
is reduced, however flame quenching continues. As the spark initiated
flame expands within the air/fuel mixture, it is extinguished or
"quenched" when it contacts the relatively cooler surfaces within the
chamber or small crevices into which the flame does not propagate.
Smaller cylinder diameter engines have less time for the flame to
expand within the charge before it contacts the combustion chamber
surfaces and is quenched or extinguished. The rapidity with which the
flame expands is such that changes in the time available as a result of
small changes in cylinder design are not usually significant.
Larger displacements engines inherently experience less emissions
-------
1-17
from flame quenching. The portion of the total HC emissions that result
from flame quenching changes whenever the surface to volume ratio of
the combustion chamber changes. When the volume of a combustion
chamber is fixed, only relatively small changes can be made to the
surface to volume ratio by modifying the relative dimension of the
combustion chamber, or the shape of the cavities within it. When the
volume of a combustion chamber increases as a result of proportional'
increases in its dimensions (i.e., the manufacturer increases engine
displacement), the surface to volume ratio decreases because the surface
area increases as the square of the diameter, whereas the volume
increases as the cube of the diameter.
Second, as the displacement decreases, emissions generated per
unit of work accomplished increases because the power output
decreases more rapidly than the HC emissions. Due to this technical
reality, using the same standard for all engines, regardless of
displacement, may be inequitable and unfair to the smallest
displacement engines.
Smaller displacement engines have been showi. to produce higher
mass emission levels for tru same work output than a larger
displacement engine. This s due to the fact that reducing displacement
has less of an impact on mass emissions (g/hr) than it has on loss in
work output (kW-hr). Therefore, the emission produced relative to the
amount of work done (g/kW-hr) by a smaller engine is greater than the
emission produced by a larger engine doing the same amount of work.
Again, given the same range of feasible technologies, the smaller
displacement engine will be unable to achieve as low an emission
standard as a larger displacement engine.
Finally, dividing engine classes on the basis of engine
displacement within either the non-handheld or handheld engine
categories allows some differentiation of standards for consumer and
-------
1-18
commercial engines. For example, in the handheld engine categories,
engines under 20cc are low cost consumer market focused, 20-50cc
engines are a mixture of both low cost consumer and commercial
markets, and greater than 50cc engines are more expensive commercial
market focused. Technology solutions available to lower cost consumer
engines are more constrained by cost than solutions for larger
commercial engines, since the consumer user market is very sensitive to
price increase. At the same time, larger commercial engines will be
capable of meeting lower emission standards because these engines are
on average higher horsepower and are built with a longer expected
useful life, and therefore are built to a higher precision. These features
will generally result in lower baseline emissions and thus require less
modification to comply with the emission standards than comparable
consumer quality engines.
1.2.2. Class I and II (non-handheld) Engine Concepts Proven with
Prototype Engines
The majority of engines in Class I are produced for the low cost
consumer market and are of 4-stroke side valve design. In the past, cost
has been the major design consideration for these engines, with some
attention to maintaining adequate performance and durability. As a
result, many internal engine modifications that have already been
applied to higher cost commercial engines, to optimize durability and
performance, have not yet been applied to these low cost consumer
engines. Therefore, a range of internal engine modifications will have to
be made to these engines to help them comply with proposed Phase 1
emission standards. This will require substantial attention to fuel
system modifications and changes to the design of existing engine
components. Achievable technologies for this rulemaking include
enleanment of the operating air to fuel ratio with major and minor
-------
1-19
modifications to the carburetor and fuel distribution system, changes in
ignition timing, combustion chamber redesign, valve system and
improvements including valve timing, improved cooling, conversion
from side valve to overhead valve engine design, and conversion from
2-stroke to 4-stroke engine designs.
A portion of the engines in Class II will also realize design
changes to existing components. Because Class II engines are generally
higher power and of higher quality than Class I engines, their baseline
emissions are lower on average and less modifications are required to
bring Class II engines into compliance. Achievable technologies for this
rulemaking include enleanment with minor carburetor modifications,
combustion chamber redesign, improved cooling, changes in ignition
timing, and conversion of 2-stroke to 4-stroke engine designs.
The use of catalytic converters, exhaust gas recirculation, and air
injection technology may occur on a limited basis or not at all in the
1997 model year. While EPA recognizes that these technologies have
the potential to provide substantial emission reductions in the future,
the safety and durability concerns with these technologies may not be
fully resolved by the 1997 model year. Limited catalyst system designs
have been developed that generate low conversion efficiencies. These
catalyst designs present a reduced safety concern because they do not
generate the high exotherms that can translate into excessive exhaust
system temperatures. These low efficiency catalysts can only bring
engines into compliance that has been modified sufficiently to generate
emissions close to the standards without a catalyst. Therefore,
durability is less of a concern, since failure of the catalyst will not cause
a gross increase in emissions. Currently EPA has not seen an adequate
EGR design or stand alone air injection system that woula be available
by the 1997 model year that addresses durability concerns.
Table 1-09 shows the available data on non-handheia prototype
-------
1-20
engines in this category(8)(9) with pre-control numbers presented in
Table 1-15. All of the prototype engines meet their respective emission
standards. For Class I engines, the actual percentage reductions in
emissions range from 51% to 98% for HC and 43% to 89% for CO. As
expected in the prototypes available, NOX emission increased in some
cases from 71% to 281%. For Class II engines, EPA had results from
only one engine with shop air delivered to the muffler, thereby acting as
a thermal reactor. Results showed percentage reductions of 33% for HC
and 13% for CO. For this engine, NOX emissions were also reduced by
.39%. Class I and II prototype engines show the composite HC +NOX
and CO emission levels below the standard. These prototypes represent
the greatest degree of emission control technology achievable given the
aggressive timeline for earliest possible introduction of these engines
into commence at reasonable cost, one of the parameters for
achievability listed in CAA section 213(a)(3).
1.2.3. Class III-V (handheld) Engine Concepts Proven with Prototype
Engines
A large portio.n of engines in Classes III-V are produced for the
low cost consumer market. In the past, cost has been the major design
consideration for these engines, with some attention to maintaining
adequate performance and durability. As with the low-cost non-
handheld engines, many internal engine modifications that have already
been applied to higher cost commercial engines, to optimize durability
and performance, have not yet been applied to these low cost handheld
engines. Therefore, a range of internal engine modifications will have to
be made to these engines to help them comply with emission standards.
This will require substantial attention to changes in the fuel system
modifications and design of existing engine components. Achievable
technologies for this rulemaking include enleanment with minor and
-------
1-21
major changes to the carburetor, carburetor limiter caps, combustion
chamber/scavenging/port timing modifications, cooling improvements
and conversion of a limited number of engine designs to 4-stroke engine
design.
The use of catalytic converters, exhaust gas recirculation, fuel
injection, and air injection technology may occur on a limited basis or
not at all on handheld engines in the 1997 model year. While EPA
recognizes that these technologies have the potential to provide
substantial emission reductions in the future, the safety a?: a durability
concerns with these technologies may not be fully resolveJ. by the 1997
model year. Limited catalyst system designs have been developed that
generate low conversion efficiencies. For the same reasons discussed in
the previous section, these low efficiency catalyst designs provide a
reduced safety and durability concern. Currently EPA has not seen an
adequate EGR design or stand alone air injection system that would be
available by the 1997 model year that addresses durability concerns.
Industry and research labs have collected emission data on a
number of engines used in the three handheld equipment classes (Tables
1-16 to 1-20). Table 1-10 lists the emission results of three prototype
engine designs compared with a number of current 2-stroke engines and
2-stroke engines enleaned to 6% CO(10)(11)(12)(13)(14)(15). One engine
is a 4-stroke handheld engine which can be used in a limited number of
handheld applications(16).
All of the prototype engines meet their respective standards. The
actual percentage reductions in emissions ranged from 1 to 94 % for
HC and 10 to 82 % for CO. The typically low NOX emission generated
by these engines increased from 15 to 325 %. In one case CO increased
by 38 % and in the same case NOX decreased by 21 %.
In the case of Class in and Class IV engines, it is dear that the
HC standard is the one that is driving the technology for the CO and
31
-------
1-22
NOX levels are as much as two to three times lower than the standard
and do not appear to be driving the design process. For Class V, CO
and HC are the driving standards. The NOX levels on one engine are
seen to be four times lower than the standard.
1.2.4. Lowest Feasible Emission Standards
EPA has determined that there are some new technologies being
developed that are capable of meeting lower standards than adopted in
this FRM, but cannot be developed within the timeline of this rule, nor
at reasonable cost.
Technologies such as high efficiency catalytic converters, low cost
fuel injection systems, 4-stroke engine designs in place of 2-stroke
engine designs, and overhead valve in place of side valve, are currently
available on a limited basis to be used on engines covered by this FRM.
These technologies have the potential to develop much greater emission
reductions than those technologies determined to be feasible for this
rule. However, there are a number of technical barriers and safety
issues that must still be overcome before standards can be set that
would reflect general or blanket use of these technologies. EPA has
determined that extensive use of these three technologies will not be
feasible within the time allocated to complete this Smallgas FRM.
EPA expects no use of low efficiency catalytic converter
technology as a result of the adopted standards. However, the option
does exist that some engine manufacturers may choose to utilize the
technology in a limited number of cases as explained in Chapter 2, and
there is a less likelihood that catalytic converters designed with high
efficiencies will be utilized on small SI engines. High efficiency catalysts
generate a large exotherm which can increase exhaust temperatures and
can ignite unburnt fuel in the exhaust. This presents safety concerns for
handheld equipment where the engine is in close proximity to the
-------
1-23
operator or may be used around flammable objects. For other engines
there is a lesser proximity concern, yet there is a need to accommodate
the existence of higher temperatures around the fuel system presenting
both safety concerns and vapor lock concerns, as well as safety concerns
when the equipment operates around yard waste.
As has been the case for other mobile sources that currently
utilize aftertreatment technologies, EPA believes that, given sufficient
development time, creative solutions will be developed to overcome
these concerns. However, the Agency has determined that there is
insufficient time available to address these safety concerns adequately to
propose tighter standards that might require high efficiency catalytic
converters within the court-mandated timeline.
Fuel injection systems that inject fuel directly into the combustion
chamber of an engine have the potential to greatly reduce HC emissions
over the current production 2-stroke engine, and the potential to reduce
emissions to a lesser extent on 4-stroke engines. To ensure that all
exhaust gases have been purged from the cylinder and that a new
air/fuel charge has been introduced for the next power stroke, current
2-stroke engines are designed to expel some of the uncombusted
air/fuel mixture into the exhaust before the exhaust valve closes and the
power stroke takes place. Introducing this raw fuel directly into the
exhaust stream results in very high HC emission from these engines.
With direct cylinder fuel injection systems, fuel is not introduced until
after the cylinder has been purged and the exhaust valve has closed. As
a result, no raw fuel escapes into the exhaust and the resulting HC
emission is reduced substantially.
High pressure, direct cylinder fuel injection systems have been
successfully developed for 2-stroke applications for the automotive
industry and will be introduced in the future in passenger cars in
Europe and possibly the U.S. EPA is aware of fuel injection system
-------
1-24
designs that are currently being explored for both nonroad small spark-
ignited engine applications as well as for outboard marine applications
(that also use 2-stroke engines). These designs are well behind the
development curve of automotive engine systems and face unique
hurdles with respect to size, simplicity, and cost. EPA is not currently
aware of any fuel injection system that has been developed to the point
that it would be available within the timeline constraints of this rule.
Fuel injection systems have less benefit for 4-stroke engines.
There are lower cost options to keep raw fuel from entering the exhaust,
thus there is less justification for manufacturers to assume the cost of
such systems for the minimal emission benefit.
Using 4-stroke engines in current 2-stroke applications can
substantially reduce the HC emission over current 2-stroke engine
designs. However, 2-strokes currently enjoy a number of performance
advantages over typical 4-strokes. The 2-strokes typically operate at
higher speeds, have a higher power to weight ratio (especially important
in handheld applications), and can operate in any position. While
development is underway to design small 4-strokes with acceptable
performance features, to date, only one manufacturer is planning to
produce a 4-stroke engine whether this rule is promulgated or not. That
engine currently has limited application within the handheld category
and currently is more expensive than comparable 2-stroke engines in its
class. While EPA believes this technology has great promise for the
future to reduce emissions further than the levels adopted in this rule,
the Agency has determined that this technology will not be available
within the time constraints of this rule.
Using overhead valve engines in place of side valve engines
would require a major retooling of the engine manufacturing industry.
While this might occur over time, a sudden changeover within the
timeline constraints of this rule would be extremely costly and might
-------
1-25
not be physically possible. The side valve engine makes up the majority
of the low cost consumer market. This represents tens of millions of
engines sold per year. Not only would the industry be required to
divest facilities and tooling geared toward such enormous production
volumes, but at the same time, it would have to invest in redesigning
OHV engine lines that were designed to be flexible and lower volume.
Current manufacturing facilities are at different stages in their life cycle.
As Phase 1 emission standards take effect, and as EPA works toward
\e Phase 2 requirements for these engines, the industry may evolve
toward overhead valve designs in a more orderly fashion. Adopting
standards today that would require overhead valve technology would
result in an extremely costly rule.
1.3. Impacts on Performance
Section 213 (a)(3) of the Clean Air Act Amendment requires that
EPA give appropriate consideration to factors including energy, noise
and safety associated with the application of technologies. EPA has
chosen the THC, NOX and CO standards such that the effects on
performance will be minimal. This section discusses EPA's assessment
of the effects of this Small Gas FRM on energy (i.e., fuel economy),
power, noise, safety, and maintenance. The analysis is based on
information presented in Table 1-11(17)(18)(19)(20)(21)(22)(23). Detailed
calculations are included in Appendix B.
1.3.1. Fuel Consumption
Data showing the impact of the application of engine technologies
on fuel consumption by nonoptimized prototype engines are listed in
Table 1-11. Fuel consumption will decrease slightly based on the
application of technologies of enleanment, increased combustion
efficiency, and reduction of scavenging losses.
-------
1-26
The early nonoptimized 4-stroke side valve and handheld 2-
stroke prototype engines using enleanment demonstrated a brake
specific fuel consumption reduction of between 6% to 22% (see Table 1-
11). However, this reduction is expected to decrease slightly as these
engines are optimized to achieve best performance within the proposed
requirements. This occurs as the level of enleanment on many of these
engines is customized across the engine performance band and the
average enleanment during all operation is reduced. Table 1-11 also
shows data on one overhead valve engine (OHV) and one 2-stroke
handheld engine which suggests that some engines will experience no
fuel consumption reduction or a small fuel consumption increase. The
Class II OHV engine prototype and Class IV 2-stroke prototype showed
fuel consumption increases of between 1% and 3%, respectively.
EPA has analyzed the likely average fuel consumption change
considering all factors that would impact the final figure in actual use.
EPA estimates that the actual fuel consumption will be an average of
25% reduction in nonhandheld engines, i.e., Class I and II engines, and
13% reduction in handheld engines, Classes EH-V, per engine basis sales
weighted. Since this is a desirable impact, little additional design effort
will be expended to optimize fuel consumption effects. The main
influence on the decrease in fuel consumption for nonhandheld engines
is the conversion of 2-stroke Class I engines to 4-stroke Class I engine
designs. The reduction for handheld engines is influenced by the use of
enleanment and the reduction of scavenging losses. The following
explains the methodology utilized to calculate fuel consumption
changes. Details can be found in Appendix B.
Fuel consumption changes are expressed in percentage reduction
with respect to nonhandheld (Classes I and II) and handheld (Classes
III-V). Each fuel consumption change is calculated by first estimating
fuel consumption for each engine design in each class for pre-control
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1-27
and post-control engines (summarized in Tables 1-01 and 1-02 from
Table 1-11). These estimates are then sales weighted by multiplying the
fuel consumption by the resultant of the division of the 19961 total sales
in each engine design and class by the 1996 total sales in the appropriate
handheld or nonhandheld group as defined previously.
TABLE 1-01
Pre-Control Fuel Consumption Estimates Per Engine Per Class (g/kW-hr)
CLASS
I
II
III
IV
V
sv
830
570
--
~
~
OH:
60"
510
—
—
--
OTHER
603
510
--
~
--
2-STROKE
854
570
830
830
560
Table 1-02
Post-Control Fuel Consumption Estimates Per Engine per Class(g/kW-hr)
CLASS
I
II
III
IV
V
sv
600
520
--
--
--
OHV
430
520
—
253
--
OTHER
430
520
720
720
529
2 STROKE
0
0
437.76
321.632
EPA's 1996 sales estimates were utilized to sales weight power
estimates for pre-control and post-control engines. Pre-control sales
estimates were taken directly from 1996 sales estimates. Detailed
1 Sales estimates for 1996 are used as the basis for calculations in this
RIA/RSD. The year 1996 is included in the definition of the 1997 model
year. See the Final Rulemaking for a complete explanation.
-------
1-28
discussion on the determination of 1996 sales estimates per class and
engine design is discussed in Chapter 3 with detailed calculations
shown in Appendix B. Post-control sales estimates were calculated by
applying technology change estimates that would affect sales in each
class and technology to the base 1996 sales estimates. The technology
changes that were applied to the pre-control sales estimate were: (1)
apply 2-stroke engine sales Class I to a 50/50 split between side valve
and overhead valve engine designs, (2) apply 2-stroke engine sales in
Class II to 100% side valve engines, (3) 1% of side valve engines in Class
I are sold as overhead valve designs in Class I, and, (4) 1% of Class IV
handheld engines convert to a new Class IV 4-stroke engine design (a
new design by an engine manufacturer).
Table 1-12 shows the fuel consumption numbers for pre-control,
post-control and calculated percent fuel consumption change per engine
design per class and summarized in nonhandheld and handheld
designations. Additional calculations for number of barrels reduced and
resultant cost savings is presented in Chapter 3 on Aggregate Costs. For
that analysis, EPA calculated sales weighted averages for the handheld
and nonhandheld variables of kilowatt rating, usage and load factor,
fuel consumption rates and useful life. The equipment categories were
differentiated by residential and professional usages. Fuel consumption
changes over time was not accounted for in the fuel consumption
estimates.
1.3.2. Power
The test results of seven non-optimized prototype engines
demonstrate a maximum rated power loss of between 0% to 13% (see
Table 1-11). In one case, the prototypes experienced a power gain of
14%. The power gain was associated with the use of enleanment and a
catalyst. Manufacturers will optimize final designs such that the
expected power loss on resulting production engines will be minimized.
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1-29
EPA estimates that the resulting average power change in actual use
will be a gain of approximately 5% for non-handheld engines and a
reduction of 3% for handheld engines (Table 1-13). The major
contributor to the gain for non-handheld engines is enleanment and
combustion chamber redesign for more efficient combustion for Class I
side valve engines which make up a large majority of engines in this
rulemaking. For handheld engines, a majority of the engines are
estimated to utilize enleanment technology which is estimated to result
in an increase or decrease in power, depending . n each -r gine design.
Power changes are expressed in percental.- reduciicn by class.
The power change is calculated by first estimating the power for each
engine design in each class for pre-control and post-control engines
(summarized in Tables 1-03 and 1-04 from Table 1-11). These estimates
are then sales weighted by multiplying the power by the resultant of the
division of the 1996 total sales in each engine design and class by the
1996 total sales in the appropriate handheld or nonhandheld group as
defined previously. Discussion of the calculation of 1996 sales is found
in the previous section 1.3.1 Fuel Consumption.
Table 1-03
Pre-Control Power Estimates Per Engine Per Class in kW
CLASS
I
II
III
IV
V
sv
0.9
3.25
--
•
--
OHV
0.9
3.06
--
--
--
OTHER
0.9
3.06
--
--
--
2-STROKE
1
3.25
0.86
0.86
2.28
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1-30
Table 1-04
Post Control Power Estimates Per Engine per Class in kW
CLASS
I
II
III
IV
V
sv
1.08
3.06
--
--
• .
OHV
0.87
3.01
--
1
--
OTHER
0.87
3.01
--
--
--
2-STROKE
1
3.25
0.83
0.83
2.27
Table 1-13 shows the results from pre-control, post-control, and
calculated percentage power change per engine design per engine class
and summarized in non-handheld and handheld designations.
Although overall power may increase, some engines may experience a
decrease in power availability. However, real time data collected on
equipment in actual use (26) demonstrate that many engines require
only a portion of their maximum rated horsepower (sometimes as little
as 30%), to operate most applications. The remaining power available
prevents engine stalling when extreme torque fluctuations are
experienced. This is especially true in the case of nonhandheld engines.
The operators of these engines will likely experience no performance
impact as a result of this rule. Even in those cases where the power loss
does carry through to actual use, the small performance loss projected
will not substantially compromise the ability of an engine to perform its
work adequately.
1.3.3. Noise
Regulations exist in Europe on the noise level acceptable from
lawnmowers. Additional voluntary standards exist in the United States
through the American National Standard Institute (ANSI). The noise
standards for the EEC regulation for lawnmowers is presented in Table
t/0
-------
1-31
1-05(24). A more general list of regulations and voluntary standards is
listed in Table 1-14.
The objective of the European regulation is to ensure protection
against nuisances due to noise by reducing the inconvenience caused by
the noise emitted by lawnmowers. Small engine manufacturers export
product from the United States to the countries in which this law is in
effect. As a result, EPA does consider the influence of emission
reduction technologies on the noise.
Although n ise data on engines with emission reduction
technologies has not been collected, it is the Agency's technical
judgment, based on years of emission control system experience with
on-highway vehicles and engines, that there will be no negative impact
on noise due to the emission control technologies being considered for
this Phase 1 rule.
Table 1-05
Cutting Width of Lawnmower (L)
L<50cm
50cm120cm
Permissible sound power levei
dB(A)/l pW
96
100
105
1.3.4. Safety
Many safety regulations and recommendations have been
established for small engines and their related use in equipment. These
regulations will affect the feasibility of using some technologies on
handheld engines. One example is regulations requiring spark arresters
on equipment used on certain federal lands. The regulation results in a
temperature limit on exhaust and exhaust surfaces which, to date, has
resulted in a limitation on the feasibility of the use of catalysts for
-------
1-32
handheld engines due to the high heat levels emitted during conversion
of pollutants as seen when applied to these engines.
Safety recommendations and regulations also have an impact on
the end use of the engines. Some small SI equipment have operating
restrictions of certain speeds and loads. One example is ANSI standard
B71.1 which contains information for measuring mower blade tip speed
and a description of the use of safety brake systems. A summary of
such regulations and recommendations is presented in Table 1-14.
EPA estimates that the impact of engine changes to be made by
engine manufacturers will not affect these safety recommendations and
regulations. EPA projects very little change to exhaust system surface
and gas temperatures due to this rule. Thus, there will be no impact on
manufacturers' ability to comply with exhaust temperature safety limits.
Even if catalysts are used on a small percentage of non-handheld
engines, the low conversion efficiencies generated will generate easily
manageable levels of additional exhaust system heat
1.3.5. Maintenance
Small SI engines are used in equipment from handheld trimmers
to industrial generator sets and by a wide variety of users including
consumers and professionals. EPA has received a number of survey
results from industry, cooperative agreements and contract work. EPA
has received a study from OPEI which surveyed a number of
lawnmower and lawn/garden tractor owners to investigate maintenance
habits. A survey of over 1000 lawnmower users was also conducted
through a Cooperative Research and Development Agreement with
Electric Powers Systems Research which included a number of electric
utilities around the United States of America. EPA also received survey
data from 20 to 30 handheld equipment owners in the San Antonio,
Texas area as part of a contracted work assignment. Results from the
-------
1-33
surveys ranged from no maintenance over the owners experience with
the equipment to regular maintenance practices. As a result, there were
no maintenance patterns in relation to small SI engines. Therefore, EPA
cannot conclude what the impacts of maintenance will be based on
applying emission reduction technologies to these engines.
1.4. Impacts on Equipment
EPA estimates that the HC, NOX, and CO emission standards can
be met within the adopted timeline with a range of engine emission
control technologies that will have minimal impact on engine and
equipment design. However, EPA has also estimated that to adopt
more stringent HC, NOX, and CO standards than those finalized in
today's rule, would necessitate equipment redesign to accommodate
more sophisticated technologies, such as high efficienv-y catalysts.
Generally, additional attention to engine design to minimize
impact on equipment will be the most efficient approach. The market
for equipment used in nonhandheld applications is governed by
horizontally integrated engine manufacturers (i.e., engine manufacturers
do not make the equipment). As a result, equipment manufacturers will
consider minimal equipment impacts as one of their purchasing criteria.
In this highly competitive market, engine manufacturers have strong
incentive to build complying engines that will not impact equipment
design. By contrast, the market for handheld engine applications
consists of a majority of vertically integrated companies (i.e., the engine
and equipment are built by the same manufacturer). These
manufacturers have more latitude to effectively plan changes to
equipment and/or engines to minimize costs. Given that latitude, EPA's
past experience strongly suggests that most changes will be applied to
the engines of handheld equipment as well.
EPA estimates that most engine models will require only internal
-------
1-34
modifications (such as tighter tolerances, and fuel mixture enleanment
strategies) to meet the emission standards. These modifications will
have little, if any, effect on equipment design. This is based on the
assumption that a majority of equipment designs are more sensitive to
changes on external dimensions of an engine rather than any slight
change in power that may occur due to change in combustion efficiency.
Such equipment includes generator sets and chainsaws which have
equipment panels and other components designed tightly around the
external dimensions of the engine.
EPA expects that some engine models will require external engine
changes occurring as a result of improved engine cooling and carburetor
limiter caps to meet the emission standards. These modifications will
affect the design of equipment panels and components. The largest
impact of this change on a manufacturer is in designing the equipment
component dies. However, since equipment component dies wear out
and are repaired or replaced several times a year, the major cost to
change the die will be inherent to doing business, and only a marginal
cost will be due to the die modifications caused by this rule. As
discussed in detail in this RSD, handheld engines have unique technical
constraints that require higher standards than all other engines covered
by this FRM. For engines that qualify as handheld, EPA set standards
based on a separate feasibility determination. Since the emission
standards for handheld engines are less stringent, EPA will not preclude
handheld engines from certifying to the tighter standards adopted for
non-handheld engines.
EPA estimates that few engine models will be discontinued as a
result of this FRM. Models that may be discontinued represent older
engine designs and low volume sales. Since this market generally has a
large number of engine models, substitutions should be readily available
for these few incidences of model discontinuation.
-------
1-35
Catalytic converter use is not predicted for the Phase 1 rule.
However, as a back-up, catalytic converters may be used on a limited
number of engine families that cannot be made to comply by the 1997
model year. Should catalyst use occur, a small percentage of equipment
using engines equipped with catalysts may require additional shielding
as a result of higher exhaust skin temperatures.
Table 1-06 summarizes EPA's estimates of equipment impacts as
a result of this rulemaking. Percentages for the table were calculated
from equipment estimates as utilized for first year of implementation.
Table 1-06
Equipment Design Change Estimates
EQUIPMENT CATEGORY
Equipment with Class I Engines
Equipment with Class II Engines
Handheld Equipment Engines
EQUIPMENT DESIGN CHANGES
NONE
OPTION:
3% Alterations for Catalyst use
NONE
40% Alterations for Additional Cooling
OPTION:
.05% Alterations for Catalyst Use
fj-
-------
1-36
Table 1-07
Certification Fuel (CAAB) and Other Test Fuels
Property
Sulfur, ppm, max.
Sulfur, wt. pet., max. (ASTM
D1266.D2622, D2785)
Phosphorus, g./liter, max.
(ASTM D 3231)
Manganese, g/liter, max
Benzene, %
(ASTM D3606)
Lead (organic) gr/liter, max.
(ASTM D3237)
RVP, psi
Sensitivity, minimum
(ASTM D 2699/2700)
Octane, Research, minimum
(ASTM D2699)
Motor Octane Number
(ASTM D2700)
Octane, R+M/2
(ASTM D 2700)
Distillation (ASTM D 85)
IBP.C
1 0% point, C
50% point, C
90% point, C
End Point, C, max
Aromatics, %
(ASTM D2267/D1319)
Aromatics, max. %
Olefins, %
(ASTM D1319)
Olefins, max. %
CAAB
339+/- 94
0.02
0.004
1.5
0.02
8.7 +7-0.2%
ASTM D5191
87.3 +/- 0.5%
32.8+7-11
53.3 +7- 5.5
103.3 +7- 5.5
165.6+7-5.5
212.8
32 +7- 4.0
9.2 +/- 4.0
40CFR
86.113-90(8)
0.10
0.00132
0.0132
8.7-9.2
7.5
93
24-36
49-57
93-110
149-163
212.8
35
10
California
Phase 1
0.03
0.00132
0.0132
7.5-8.0
7.5
93
24-38
49-60
93-110
149-163
212.8
35
10
CEC Legislative
Fuel
RF-05-A-85
.04
0.0013
5% vol max
(oxygenates
prohibited)
0.005
.S6-.64 bar
(8.1-9.3 psi)
95.0 min
85.0 min
(137.5min-calc)
24-40
42-58
90-110
155-180
190-215
45vol.
20vol.
CEC Legislative
Fuel
RF-05-A-83
(' need specs •
* from 1 bottle)
36 mg/kg
<0.1 mg/l
<0.0025 g/1
.61 bar
(8.85 psi)
7.5
91.9
84.4
34
54
100
161
206
21.6%v/v
9.0 %v/v
-------
1-37
Saturates. %
(ASTM 01 31 9)
Saturates, max. %
Oxidation stability induction
period
(ASTM D525)
Carbon/hydrogen ratio
(Ultimate analysis)
Residue
(ASTM 086)
Existent oum
(ASTM 03? '•
Copper'' -nt50C
(ASTMC:
Density at iSv
(DIN 51 757-D)
remainder
remainder
remainder
remainder
480 min
2% max
4mg/100ml max
1 max
59.5 %v/v
>1000min
6.41:1
0.7257 kg/;
-------
1-38
Table 1-08
Average (3 tests) 1-Bag J1088 6-Mode Test Results by Fuel
Tecumseh 4-Stroke 2.6kw WBM Engine
Fuel Type
Industry
Average
Reformulated
with MTBE
Reformulated
with Ethanol
Alihatic
Regulated Emissions (note: THC = Methane + NMHC, Partculates not regulated)
Methane
NMHC
CO
NOx
Paniculate
g/kw-hr
2.68
21.5
480
1.73
0.76
g/kw-hr
3.27
18.8
447
1.61
0.43
Individual Toxic Species and Oxygenates
1 ,3-Butadiene
Ethanol
MTBE
Benzene
Formaldehyde*
Acetaldehyde*
mg/kw-h
209
--
--
925
145
25
mg/kw-h
178
--
508
713
139
27
g/kw-hr
3.15
17.2
433
1.7
0.48
mg/kw-h
164
719
--
801
142
78
g/kw-hr
4.73
20.3
464
1.6
0.28
mg/kw-h
178
--
--
217
157
34
Distribution of Nonmethane Exhaust Organics using Speciation Procedures
Other
Saturates
Olefins
Aromatics
Oxygenates
Carbonyls
Unidentified
TOTAL
(NMOG)
g/kw-hr
5.86
7.25
5.7
--
0.21
2.92
21.9
g/kw-hr
5.48
8.48
3.77
0.51
0.23
1.57
20
Ozone Formation Potential of Exhaust Organics
g/kw-hr
6.38
7.4
3.27
0.72
0.27
1.15
19.2
g/kw-hr
9.2
11
0.43
-
0.24
1.23
22.1
-------
1-39
Methane
Other saturates
Olefins
Aromatics
Oxygenates
Carbonyls*
Unidenwa
TOTAL
g/kw-hr
0.031
4.24
28.7
19.6
--
1.11
7.86
61.5
g/kw-hr
0.035
3.9
32.1
11.1
0.24
1.09
4.24
52.7
g/kw-hr
0.032
4.39
29.1
9.51
1.62
1.29
3.1
49
* Each value represents a single determination
Ref:SAE#911222
g/kw-hr
0.055
6.05
42.4
1.17
«
1.22
3.34
54.2
-------
1-40
Table 1-09
Technologies to Reduce Emissions from Current Production Small
Nonroad SI Engines in Classes I and II
ENGINE DESCRIPTION
CURRENT EMISSIONS
(g/kW-hr)
HC
NO,
CO
AFTER STANDARD (g/kW-hr)
HC
NO,
CO
% Change From Present
HC
NO,
CO
Technology
Class I (<225cc)
4-Stroke, SV 2.98KW
(190cc)
4-Stroke, SV
3.73kW(190cc)
4-Stroke, OHV
2.98kW (148cc)
2-stroke 3.73kW(145cc)
66
24.5
13.4
13.4
255
1.55
1.61
3.3
3.3
0.416
638
680
499
499
595
5.76
11.9
5.76
2.83
5.76
5.91
2.75
5.91
8
5.91
75
385
75
54
75
-91
-51
-57
-79
-98
+281
+71
+79
+142
+132
-88
-43
-85
-89
-87
4-stroke OHV
Lean & EGR
Lean & Catalyst
Lean & EGR
Lean & Catalyst
4-stroke OHV Lean &
EGR
Class II (>225cc)
4-Stroke, SV
8.95kW (465cc)
4-stroke OHV
8.21kW(338cc)
8.7
10.9
6.72
2.57
367
340
7.4
7.25
6.0
2.56
469
295
--
-33
-
-0.39
-
-13
Class II Standards
Air Injected Into Muffler
Additional Current Emission Level data are presented in Table 1-15.
-------
1-41
Table MO
Technologies to Reduce Emissions from Current Production Small
Nonroad SI Engines in Classes III, IV and V
1
tlMQiNE
DESCRIPTION
CURRENT EMISSIONS
(g/kw-hr)
HC
NO,
CO
AFTER STANDARD (g/kw-hr)
HC
NO,
CO
% CHANGE FROM PRESENT
HC
NO,
CO
TECHNOLOGY
Class III (<20cc)
16.3cc Trimmer
384
0.5
499
295
0.9
499
•
--
-
HC - Standard, Est for
NOx & CO
Class IV (20-SOcc)
25cc Trimmer
30.1 cc Chainsaw
Average of 27
2-Stroke Engines
Average of 27 2-Stroke
Engines
197
178
350
350
1.0
0.4
N/A
N/A
449
384
964
964
176
179
228
20
1.0
0.5
N/A
5.4
404.5
333
596
170
-10
-1
-35
-94
-2.3
21
N/A
+325
-10
-13
38
-82
Enleanment (4.5%)
Enleanment?
Avg of 27
2-Stroke Engines with 6%
CO Enleanment
4-stroke
Class V (>50cc)
53cc
Chainsaw
Average of Eighteen
2-Stroke Engines
120
214
0.7
N/A
427
696
110
108
0.8
N/A
357
368
-8
-50
15
N/A
-16
-47
Enleanment (6%)
Avg of four
2-Stroke Engines with 6%
CO Enleanment
Indicated Average numbers were taken from data presented in Tables 1-16 through 1-20.
-------
1-42
Table 1-11
Fuel Consumption and Power on Prototype Engines
ENGINE DESCRIPTION
CURRENT BSFC
(kg/kw-hr)
AFTER
STANDARD
(kg/kw-hr)
% CHANGE IN
BSFC
CURRENT POWER
(Kw)
AFTER
STANDARD (kw)
% CHANGE IN
POWER
TECHNOLOGY
Class I (<225cc)
4-Stroke, SV
2.98kW(190cc)
4-Stroke, SV
373kW(190cc)
4-Stroke OHV
2.98kw(148cc)
2-Stroke
3,73kW(145cc)
0.83
0.75
0.603
0.603
0.854
0.43
0.60
0.43
0.47
0.43
-48
-20
-29
-22
-50
0.9
1.0
0.9
0.9
1.0
0.87
1.08
0.87
0.82
0.87
-3
+14
-3
-9
-13
4 Stroke OHV Lean & EGR
Lean & Catalyst
Lean & EGR
Lean & Cat
4 Stroke OHV Lean & EGR
Class II (>225cc)
4-Slroke, SV
8.95KW (465cc)
4-Stroke OHV 8.21 kw(338cc)
0.57
0.51
0.52
0.52
-9
+1
3.25
3.06
3.06
3.01
-6
-2
4-Stroke OHV Air Injected
Air Injected
(Muffler)
Class III (<20cc)
N/A
Class IV (20-SOcc)
25cc Trimmer
30.1ccChainsaw
4-Stroke
1.04
0.62
0
0.8
0.64
0.25
-22
+3
-
0.56
1.15
0
0.55
1.11
.746
-2
-4
~
Enleanment
Enleanment?
New Technology
Class V (>50cc)
53cc Chainsaw
0.56
0.53
-6
2.28
2.27
-0.5
Enleanment (6%)
-------
1-43
Table 1-12
Estimated Change of Fuel Consumption Per Class and Tecnnology
Based on 1996 Sales Weighting
CLASS
PRE-
CONTROL
(g/kW-hr)
POST-
CONTROL
(g/kW-hr)
% CHANGE
FROM PRE-
CONTROL
CLASS I
SV
OHV
Other
2-Stroke
528
32
0
69
402
43
0
0
-24
+35
-29
•100
CLASS II
SV
OHV
Other
2-Stroke
TOTAL NHH
106
21
1
0
758
97
21
1
0
565
9
+2
+2
-100
•26
CLASS III
2-Stroke
60
52
-13
CLASS IV
2-Stroke
4-Stroke
725
0
623
2
-14
CLASS V
2-Stroke
TOTAL HH
30
815
29
706
-6
-13
Note: See Appendix B for calculation details.
-------
1-44
Table 1-13
Estimated Change of Power Per Class and Technology
Based on 1996 Sales Weighting
CLASS
PRE-
CONTROL
(kW)
POST-
CONTROL
(kW)
% CHANGE
FROM PRE-
CONTROL
CLASS I
SV
OHV
Other
2-Stroke
0.57
0.047
0
0.081
0.72
0.09
0
0
26
83
-3
-100
CLASS II
SV
OHV
Other
2-Stroke
TOTAL NHH
0.60
0.12
0.01
0
1.44
0.57
0.12
0
0
1.51
-6
-2
-2
-100
+5
CLASS III
2-Stroke
0.062
0.06
-3
CLASS IV
2-Stroke
4-Stroke
0.75
0
0.72
0.01
-4
--
CLASS V
2-Stroke
TOTAL HH
0.12
0.94
0.12
0.91
0
-3
Note: See Appendix B for calculation details.
-------
1-45
Table 1-14
Sample of Noise and Safety Regulations and Voluntary Standards for Small Engines
CLASSES
OF ENGINES
SAFETY REGULATION OR
RECOMMENDATION
DESCRIPTION
REGULATIONS
All Classes
All Classes
Class i and II
Class I
As Applicable
As Applicable
As Applicable
As Applicable
Title 36 CFR Part 261.1
Title 43 CFR 420.1 1
EEC Council Directive of 19 Dec 1978
EEC Council Directive 84/538/EEC
1 7 Sept 1 984 & 7 April 1987
EEC Council Directive 84/533/EEC
EEC Council Directive 84/536/EEC
EEC Commission Directive of 7 April
1987 for Heat Protection (USO 5395:
1990(E))
ISO 11 094
(International Standard specific to
mowing equipment)
Spark arresting device on equipment in lands overseen
by the US Forest Service
Spark arresting device on equipment on Reclamation
Lands
Noise emission of construction plant and equipment
Council Di rective of the approximation of the laws of the
Member States relating to the permissible sound power
levels of lawnmowers
Compressors
Power Generators
Temperature for surfaces and protection from exposure
to exhaust components > 10cm3
Acoustics - test code for the measurement of airborne
noise emitted by power lawnmowers, lawn tractors, lawn
and garden tractors, professional mowers and lawn and
garden tractors with mowing attachments.
VOLUNTARY STANDARDStfEST PROCEDURES
As Applicable
'Classes III-V
Classes III-V
Classes I and II
As Applicable
As Applicable
As Applicable
As Applicable
As Applicable
NIOSH Lifting Limits for Individuals
ANSI B175.1 - Gasoline Powered Chain
Saws - Safety Requirements
ANSI 81 75.2 Handheld and Backpack,
Gasoline Engine Powered Blowers
ANSI 671.1(1990)
ANSI 871. 3 (1984)
ANSI 871.4(1 990)
ANSIB71.5
ANSI B71. 6 (1990)
ANSI 871. 8 (1986)
Guidelines for allowable weight of equipment based on
ergonomics of the human body.
Includes safety requirements for topics including throttle
eoriral linkage, spark arresting mufflers, chain guards,
r1''
Soufia-lavel Labeling Requirements and Test
Procedures
Blade tip speed for WBM and Riding Mowers, Safety
Brake
Snowthrowers
Commercial Turf Equipment
American National Standard for Powered Lawn, Garden
and Snow Removal Equipment - Operator-Ear Sound
Pressure Level - measurement and Rating Procedure
Shredders and Grinders
Tillers
-------
1-46
Table 1-15
Individual Tests of Current Production Small Engines Used In
Class I and Class II Small SI Engines, Weighted J1088, g/kW-hr
ENGINE
HC
g/kw-hr
NOx
g/kw-hr
CO
g/kw-hr
Wtd
A/F
Wtd. Power
kW
BSFC
kg/kw-hr
Meet
Standard
4-Stroke <225ec
135cc, 4.5hp
OHV
140cc,4.5hp
OHV
148cc, 4hp
SV
148cc,4hp
OHV
148cc, 3.5hp
(WMB) with
Liner
190cc, 5hp
SV (WBM)
14.2
12.6
14.2
12.6
66.0
65.4
24.5
25.1
22.5
21.4
27.5
25.2
23.9
3.04
3.55
3.12
3.67
1.55
1.55
2.57
2.76
2.14
2.01
1.58
1.77
1.45
512
511
512
484
649
630
485
480
529
516
540
666
692
11.4
11.5
11.4
11.5
11.6
11.6
11.7
11.8
N/A
N/A
N/A
10.5
10.9
0.895
0.903
0.895
0.903
0.88
0.91
1.07
1.02
N/A
N/A
N/A
0.955
0.985
0.608
0.598
0.608
0.596
0.839
0.821
0.614
0.62
N/A
N/A
N/A
0.874
0.838
N
N
N
N
N
N
N
N
N
N
N
N
N
2-Stroke <225cc
145cc, 5hp
267
243
0.42
0.40
599
591
10.5
10.9
0.955
0.985
0.869
0.839
N
N
4-slroke >255cc
338cc, 1 1 hp
OHV
338cc, 1 1 hp
OHV
400cc, 12hp
SV
400cc, OHV
782cc, 18hp
SV
5.88 kw/7.88
hpOHV
7.33
8.70
10.88
9.64
7.86
9.26
9.28
8.58
6.97
7.1
2.80
2.99
2.57
7.24
6.19
1.78
3.59
3.90
5:42
5.03
342
340
340
347
387
408
484
479
260
260
11.9
12
11.3
12.7
12.5
0.955
0.985
3.06
3.245
3.253
0.492
0.492
0.512
0.565
0.578
difficult to decipher
12
12
12.7
12.9
5.33
5.237
2.19(2.93)
2.10(2.82)
0.632
0.644
0.442
(0.727)
0.449
(0.738)
Y
Y
N
N
N
Y
N
N
Y
Y
(References: SAE#910560, SAE#911807,SAE#911805.SAE#911222)
-------
1-47
Table 1-16
Individual Emissions of Current Production Handheld Equipment Engines
20cc-50cc, WOT Mode J1088, kg/kw-hr
ENGINE
CC
21
24
24
24
24
25
26
26
28
30
30
32
32
32
32
32
34
34.41
35
35.2
38
38
38
40
40
40
HC
g/kw-hr
434.32
229.22
219.84
217.16
241.29
281.50
360.59
360.59
268.10
281.50
294.91
402.14
563.00
268.10
670.24
569.71
268.10
264.08
435.66
268.10
201.07
268.10
308.31
294.91
167.56
268.10 .
NOX
g/kw-hr
1.50
1.29
1.06
1.21
<.27
-.27
CO
g/kw-hr
1202.4
328.42
395.44
378.02
418.23
804.29
1139.41
1142.09
938.34
804.29
804.29
938.34
1313.67
1005.36
1340.^8
1313.67
804.29
694.37
871.31
737.27
871.31
804.29
831.10
890.08
670.24
804.29
Wtd
A/F
N/A
12.3
11.9
11.1
11.4
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Wtd
Power
KW
N/A
0.54
0.54
0.53
0.51
N/A
0.41
N/A
N/A
N/A
N/A
N/A
0.41
N/A
N/A
N/A
1.12
1.19
N/A
1.08
N/A
N/A
N/A
N/A
1.64
N/A
BSFC
kg/kw-hr
N/A
0.75
0.75
0.72
0.81
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Meet
Emission
Sid?*
N
Y
Y
Y
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
Y
N
-------
1-48
42
42
44
45
160.86
113.94
115.28
294.91
-21
-.27
670.24
589.81
671.58
871.31
N/A
N/A
N/A
N/A
1.87
2.16
N/A
N/A
N/A
N/A
N/A
N/A
Y
Y
Y
N
'Note that these emission numbers are from the WOT mode of J1088 which is weighted 90% of
the J1088 two mode test, except the four test results of the 24cc engine which is from
SAE#910560 (Sources: Heiden Report, McCullough Corporation,SAE#910560)
-------
1-49
Table 1-1?
Emissions of Current Production Handheld Equipment Engines >50cc
WOT Mode J1088, g/kW-hr
ENGINE CC
50
51
51
51
51
54
54
54
54
54.1
55
57
57
60
61
61
61
61
•67
67
67
67
70
70.46
81
83
87
87
92
HC
(g/kW-hr)
308.31
335.12
160.86
160.86
127.35
191.69
202.28
195.71
127.35
123.32
227.88
502.68
481.23
335.12
214.48
214.48
160.86
160.86
154.16
116.62
120.64
120.64
428.95
201.07
127.35
164.88
127.35
107.24
308.3'
Nox
(g/kW-hr)
0.20
-.27
0.16
-.27
-.27
-.27
-.27
-.27
-.27
-.27
CO
(g/kW-hr)
871
804
684
684
590
696
• 696
697
590
603
804
603
1005
804
804
737
65:
657
643
590
576
576
871
745
576.
718
576
575
737
'Note that these emission numbers are from the WOT mode ci '038 which is weighted 90% of the J1088 two mode test
(Sources: Heiden Report. McCullough Corporation)
-------
1-50
Table 1-18
Small SI Engines 20-50CC With Emission Reduction Technology
Handheld ApplicationsTable, WOT Mode of J1088
ENGINE CC
28-30?
21
21
25
25
26
28
30
30
31
32
32
32
32
35
35
38
38
38
40
40
44
45
21
21
24
24
25
25
30.1
Technology
4 Stroke
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
?
?
?
?
?
?
?
HC
g/kw-hr
20
291
670
416
147
189
181
201
201
201
147
107
322
268
302
235
161
134
174
201
184
101
194
206
201
443
345
168
168
176
NO,
g/kw-hr
5
0.64
0.58
0.17
0.64
1.15
0.88
0.56
CO
g/kw-hr
170
643
1206
938
536
592
536
536
550
603
503
469
670
737
570
737
469
469
496
469
453
393
536
299
328
927
332
441
353
294
Met Emission
Standard?'
Y
Y
N
N
Y
Y
Y
Y
Y
Y
Y
Y
N
N
N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
Y
Y
Y
0
-------
1-51
30.1
38
33
?
?
?
182
211
213
0.50
0.86
0.67
371
531
467
Y
Y
Y
'Note that these emission numbers are from the WOT mode of J 1088 which is weighted
30% of the J1088 two mode test (Sources: Heiden Report, McCullough Corporation).
-------
1-52
Table 1-19
Small SI Engines >50CC With Emission Reduction Technologies
Handheld Applications, WOT Mode of J1088
ENGINE
CC
50
51
51
51
54
54.1
55
57
57
60
61
61
67
70
83
87
92
Technology
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO
6% CO '
6% CO
6% CO
6% CO
6% CO
HC
g/kw-hr
208
201
122
174
157
107
194
174
235
268
147
161
91
322
129
97
214
NO,
g/kw-hr
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
CO
g/kw-hr
469
469
402
496
406
369
469
429
536
536
489
456
362
536
405
374
469
The follow ng are repeat tests of the same engine design • four
different engines.
53
53
53
53
9
9
9
9
105
115
114
114
0.74
0.84
0.80
0.78
357
356
358
363
'Note that these emission numbers are from the WOT mode of
J1088 which is weighted 90% of the J1088 two mode test
(Sources: Heiden Report, McCullough Corporation).
-------
Chapter 1 References
i.
State of California Air Resources Board California Exhaust Emission
Standards and Test Procedures for 1994 and Later Utility and Lawn and
Garden Equipment Engines, Attachment B, Mail Out #92-06, January
30, 1992, page 40.
2.
Section 211(k)(10)(B)(i) of the CAA
3.
CFR, Title 40, Part 86, Section 113-90(a)
4.
California Phase I Gasoline, Section 9(a)(l)(i) of tne California Exhaust
Emission Standards and Test Procedures for 1988 and Subsequent Model
Passenger Cars, Light-Duty Trucks and Medium-Duty Vehicles, as
amended July 12, 1991.
5.
CEC Legislative Fuel, RF-05-A-85
6.
Husqvarna AB, Letter to Cheryl Caffrey, EPA from Dan Ericsson,
Specification of Certification Fuels (Analysis Certificate No 23586 for
CEC Legislative Fuel RF-05-A-83) (EPA requests information on the
general specifications)
7.
Hare, Charles T, et al, Toward the Environmentally-Friendly Small
Engine: Fuel, Lubricant, and Emission Measurement Issues, SAE
#911222, 1991.
1-53
-------
1-54
8.
White, Jeff, et al, Emission Control Strategies for Small Utility Engines,
9. SAE #911807, 1991.
White, Jeff Emission Factors for Small Utility Engines, SAE #910560,
1991
10.
Swanson, Mark and Dow, Paul Homelite Corporation Exhaust Emission
Test Results, November 22, 1991.
11.
PPEMA/AQC, In-Use Emissions Test Report (25cc String Trimmer),
February 5, 1993
12.
PPEMA/AQC, EPA/PPEMA In-Use Emissions Test Report (30.1cc
Chainsaw), February 8, 1993
13.
Heiden Associates Report, A 1989 California Baseline Emissions
Inventory for Total Hydrocarbon and Carbon Monoxide Emissions from
Portable Two-Stroke Power Equipment, 24 July 1990.
14.
McCulloch Corporation, Small Engine Test Data to Cheryl Caffrey,
EPA from Rod Harms, May 11, 1993 & May 13, 1993.
15.
PPEMA/AQC In-Use Emissions Test Report (for 53cc Chain Saw),
March 12, 1993
16.
Popular Science, New Environmental Technology Developed for Portable
Lawn and Garden Engines by Ryobi America Corporation, March,
1993, pp 90-96.
17.
White, supra note 8
18.
White, supra note 8
19.
PPEMA/AQC, supra note 11
-------
1-55
20.
21. PPEMA/AQC, supra note 12
Phone Conversation with Dee North of EPA and Bela Csonka of
Ryobi on November 15, 1993.
22.
Ryobi, supra note 16
23.
PPEMA/AQC, supra note 15
24.
Official Journal of the European Communities, Coun-:;l Directive of
17 September 1984 on the approximation of the laws of the iember States
relating to the permissible -sound power level of lawnmowers
(84/538/EEC), 19.11.84.
-------
1-56
It I*
-------
Chapter 2: Technology Market Mix and Cost Estimates
for Small SI Engines and Related Equipment
The Clean Air Act Amendments of 1990 section 213(a)(3) present
statutory criteria that EPA must consider cost in determining whether
proposed standards achieve the greatest degree of emission reduction.
This chapter presents the Agency's estimation of costs for expected
technologies including associated variable hardware, production,
research and development and related equipment costs.
To calculate estimated costs incurred by engine manufacturers,
market mix percentage estimates for pre and post control engines must
first be assessed. This is done by determining the pre-control engine
market percentage makeup from available sales data. Then estimates on
the amount of use of emission reduction technologies are made and
applied to the pre-control sales mix in order to estimate post-control
market mix percentages. Resources and description of the
methodologies for these estimates are described in 2.1 Technology
Market Mix Estimates.
Variable hardware and production costs are determined by
estimating variable hardware and production costs for each emission
reduction technology to a calculated post-control technology sales mix
estimate. The methodology for estimating emission reduction
2-1
-------
2-2
technology costs, post-control technology sales mix, and variable
hardware and production costs are presented in 2.2 Variable Hardware
and Production Cost Estimates per Engine Class.
Research and development costs are determined by estimating costs
to research and development activities required of each emission
reduction technology. These costs are amortized and therefore do not
apply on a per engine basis as do variable hardware and production
cost estimates. Discussion of the methodology utilized to estimate
research and development costs are presented in 2.3. Research and
Development Cost Estimates per Engine Class. Detailed discussion on
amortized research and development costs is presented in Chapter 3.
Engines are utilized in equipment which may require alterations due
to changes in the reduced emission engines. One example is the
requirement of carburetor limiter caps on engines which contain an
adjustable carburetor. Handheld equipment has a shroud around the
engine. The shroud near the adjustable jet must be widened to allow
for the carburetor limiter cap. A discussion of equipment impacts is
presented in 2.4 Equipment Variable Hardware and Production Cost
Estimates. A summary of all resultant cost estimates are listed in Table
2-01.
Table 2-01
Estimated Costs Per Engine Per Class and Equipment
for Small SI Engines
ENGINE
CLASS
I
II
III
IV
V
Variable
Hardware
(Engine)
$1.89
$0.65
$1.69
$1.92
$2.37
Production
(Engine)
$0.74
$0.31
$0.49
$0.34
$0.48
Research and
Development
(Total per
Engine Class)
$10,803,000
$10,000,000
$72,500
$2,115,000
$2,812,500
Equip-
ment
Impacts
$0.10
$1.00
$1.24
$1.24
$1.24
Additional
Catalyst
Variable
Hardware
$1.32
NA
$0.03
$0.03
$0.03
Additional
Catalyst
Research &
Development
$100,483
NA
$20,000
$20,000
$20,000
Additional
Equipment
Impacts
due to
Catalyst
$0.06
NA
$0.20
$0.20
$0.20
-------
2-3
2.1 Market Mix and Emission Reduction Technology Estimates
Market mix estimates are calculated percentage sales estimates of
engine designs (ie: side valve, overhead valve, 2-stroke, etc.) per class
(i.e., Classes I-V) of the year prior to and the first year of emissions
regulation. Additional changes for the later 2-stroke phase-in are also
included. Emission reduction technology estimates are percentage
estimates of individual emission reduction technologies that will be
applied to engine designs as a result of emission regulation. The
following describes the methodology us<; to calculate market mix
estimates and emission reduction technc ^y estimates for small SI
engines. A summary of results are in Tuples 2-05 and 2-06 with detailed
calculations in Appendix B Manufacturer and Product Summary.
The pre-control small SI engine market mix estimate is based on the
Power System's Research (PSR) "Engindata" database. The database
contains information such as engine models, engine manufacturers, bore
and stroke measurements, valve orientations, equipment usages and
sales data. The engines and corresponding engine sales are separated
into engine displacement classes (i.e., Class I (<225cc), Class II (>225cc),
and handheld engine classes (Class III (<20cc), Class IV (20-50cc), and
Class V (>50cc))), 4-stroke side valve, overhead valve, 2-stroke engine
designs, and an "other" category of alternative fuel, fuel injected, and
water-cooled engines (see Appendix B). PSR sales numbers for 1992 are
utilized for estimating pre-control market mix. Although this should be
based on sales estimates for the year prior to engine regulation, i.e.,
1995, EPA has determined that the technology mix will not change
significantly between 1992 and 1995 sales years.
EPA has estimated percentage usages of emission reduction
technologies for engine designs in Classes I-V and calculated resulting
post-control percentage engine design sales mix for the first full year of
regulation implementation. Emission reduction technology estimates are
-------
2-4
based on emission data provided in SAE technical papers(l)(2)(3)(4)(5)
(6), confidential discussions with manufacturers and internal analyses.
2.2 Variable Hardware and Production Cost Estimates per Engine
Class
Many of the emission reduction technologies assumed feasible for
this rule consist of engine design changes with a minor number of
technologies requiring the addition of extra hardware, such as catalysts.
As a result, many technologies require changes in manufacturer
production including tooling and die design. The following definitions
were utilized to separate costs for emission reduction technologies into
variable hardware, production, research and development costs.
Variable hardware costs are those costs which are associated with pieces
of hardware added to an engine. Examples include carburetor limiter
caps, additional metal to the engine block, and valve guides.
Production costs are those costs which relate to inputs in production.
These costs consist of additional production tasks related to the addition
of carburetor limiter caps and increased maintenance on tooling due to
tighter component tolerances. Research and development costs are
those costs associated with development of engine and engine
component designs. Changes to production such as tooling and die
design changes are included in research and development costs due to
their one-time effect on the production process. Examples include
engine block die design and retooling for tighter production tolerances.
EPA developed cost estimates for variable hardware and production
costs for post-control engine sales, in the following manner (detailed
calculations are in Appendix B). First, engine sales numbers for the first
year of implementation were taken from EPA's estimated sales of small
SI engine equipment for the first year of implementation as presented in
Chapter 4 of this document. Second, the equipment sales estimates
-------
2-5
were separated into engine classes and engine designs based on the PSR
"Engindata" database equipment/engine design splits for the 1992 sales
year. Third, the number of engines in each class and engine design
were adjusted by applying the percentage use estimates for each
emission reduction technology which were determined in 2.1 Market
Mix and Emission Reduction Technology Estimates. Fourth, estimates
were made for the variable hardware cost and production cost for each
emission reduction technology. Fifth, cost estimates for each emission
reduction technology were multiplied by the corresponding number of
engines within each class. Lastly, all costs associated for each emission
reduction technology within each class were summed and divided by
the number of engines in the class, thereby yielding a sales weighted
cost per engine in the class. Tables 2-07 to 2-11 show the cost estimates
for each emission reduction technology per class and engine design.
Tables 2-07 and 2-08 show that costs are estimated to be slightly
higher for Class I engines than Class II engines. This result is due to the
number and extent of emission reduction technologies required per
engine to meet the respective emission standards in each class. Many of
the Class II engines have the advantage of lower surface to volume
ratios and higher power than Class I engines which allows them to have
lower brake specific emissions. In addition, Class II engines are
comprised of a larger number of higher quality engines in relation to
Class I which require less alterations to meet emission standards. EPA
estimates that many of the internal engine modifications that will be
made to low cost engines to help them comply with the adopted
standards have already been applied to commercial engines to optimize
durability and performance.
For Classes III-V, shown in Tables 2-09 to 2-11, EPA estimates that
the technology costs will be evenly spread due to the similar levels of
modification required in engines throughout these classes with some
11
-------
2-6
differences in Class IV where there is a mixture of professional and
residential designed engines.
2.2.1 Class I
The majority of engines in Class I are made for the low cost
consumer market and are of 4-stroke side valve design. Cost is the
major design consideration for these engines, with some attention to
maintenance of adequate performance and durability. As a result, major
changes are required on a large portion of these engines in order to
meet emission regulations. The major feasibility barriers for these
engines include exhaust valve seat temperature and high surface to
volume ratio as described in Section 1.2. Table 2-07 summarizes the
technologies EPA is estimating will be available to meet emission
standards for Class I engines on the implementation time line specified
in this rule. In summary, EPA estimates that increased variable
hardware and production costs for Class I engines will be $1.82 and
$0.50 per engine respectively. These estimates apply to the sales and
annual consumption of Class I small engines in the United States. The
percentages apply to the change in annual sales as a result of first full
year of regulation implementation. Cost estimates are based on
confidential conversations with manufacturers of engines and engine
components.
EPA estimates that 78% of the present 4-stroke side valve engines
will utilize enleanment with major redesigns occurring to the carburetor
and fuel distribution systems. A large majority of current engines have
very simplistic carburetor systems which run very rich in order to
provide stable operation under a variety of speed, load and altitude
conditions. Carburetors will be required to provide more precise fuel
distribution to the engine as the engines are enleaned. Major redesigns
consist of replacing the fuel system and carburetor with new designs
-------
2-7
which includes changes from adjustable to fixed jet and changing the jet
size to enlean the air/fuel mixture entering the engine. EPA estimates
that no engines will utilize adjustable carburetors thereby virtually
eliminating the need for limiter caps and refined adjustment and idle
needles.
EPA estimates that 80% of the carburetors presently used in Class I
are manufactured by the engine manufacturer while 20% are purchased
from an outside source. The variable hardware and production costs
will vary for this Small Gas FRM based on who bears the additional cost
of redesigning the carburetor. EPA requests further information on the
in-house and outside sourced carburetors. The variable hardware cost
for purchased carburetors is estimated at $1.50 per engine. EPA
estimates that the variable hardware costs of manufactured carburetors
is $0.00 per engine. In making this determination, EPA assumed that
there will be no increase in parts or materials for the newly designed
carburetors. Production costs estimates are also contingent on whether
the engine manufacturer produces its own carburetors or purchases
them from an outside source. For an engine manufacturer producing its
own carburetor, two things will increase, (1) the frequency of
production machine maintenance frequency of production machinery
due to tighter production tolerances on carburetor components, and (2)
the number of carburetor pieces not meeting production specifications.
Production costs also include the costs of increasing production of a
higher quality but smaller volume carburetor and fuel system or
providing alterations to a production system in order to account for
carburetor and fuel system changes. EPA estimates production costs at
$0.20 per engine.
EPA estimates that 21% of the 4-stroke side valve engines will utilize
enleanment with minor adjustments to the existing carburetors. It is
estimated that a large number of these engines will be horizontal shaft
-------
2-8
orientated engines. This estimate is based on discussions with engine
manufacturers who have indicated that the emissions from horizontally
crankshaft orientated engines have been found to be less than those
from comparable vertically crankshaft orientated engines. Minor
carburetor changes include conversion from adjustable to fixed jet and
jet size changes to enlean the air/fuel mixture entering the engine. EPA
assumes that 80% of carburetors in this category are made by engine
manufacturers and that 20% of carburetors are purchased from an
outside source. The cost for outside purchased carburetors is estimated
to increase the cost of each engine by $0.50 with no cost increase for the
in-house manufactured carburetors. Production cost increases for in-
house manufactured carburetors are estimated to be $0.20 per engine
based on the same items for major carburetor and fuel system changes
which include increase in production machinery maintenance and
increased components not meeting production specifications.
EPA estimates that improved ignition systems, such as solid state
ignition systems, are already used on all small engines for improved
reliability and spark control and therefore will not be a technology
change. However, EPA does estimate that 50% of the side valve engines
will utilize changes in ignition timing. Since spark timing has been
optimized for power rather than fuel economy or emissions, it is likely
that changes in ignition timing will be utilized. Changes in base
ignition timing may affect power and, therefore, further compensations
will have to be made in order to improve engine power. Base ignition
timing changes require modification to change the relative position
between the two halves of the magnetic pick-up. For example, on most
engines, the ignition breaker is part of the engine flywheel. For these
systems a modified flywheel key would be used to index the flywheel
the desired number of degrees relative to the engine crankshaft. This
modification will require research and development time to determine
-------
2-9
the level of timing modification required. EPA estimates the necessary
changes are limited to either one machining operation to index the
crankshaft keyway, or a redesigned key. This results in a small
adjustment to the mill cutting key or a one-time die change for the
offset key.
EPA estimates that 95% of 4-stroke side valve engines will utilize
combustion chamber redesigns. Combustion chamber redesigns include
maximization of the surface to volume ratio and stiffening of the engine
block. As described in Chapter 1, side valve 4-stroke small engines
have large surface to volume ratios, in relation to overhead valve
engines, and crevices to which the flame front does not reach.
Decreasing the surface to volume ratio will improve combustion
efficiency as the time to flame quenching is lengthened and less of the
fuel is left unburned. Stiffening of the engine block will allow for more
even heat distribution which will result in less affects of warping of the
cylinder on the piston and valve openings, resulting in improved
combustion efficiency. Combustion chamber redesign is estimated to
require $0.10 in additional variable hardware costs based on the
increased amount of material used in the die. Production costs are
estimated to increase $0.20 based on increased maintenance and die
replacement due to tighter tolerances and increased number of rejects.
EPA estimates that 80% of 4-stroke side valve engines will utilize
valve system improvements including valve timing. In a large number
of side valve engines, valve seating and timing characteristics have not
been optimized. As a result, scavenging can occur as the air/fuel
mixture enters the combustion chamber and leaves (before it is ignited)
through an exhaust valve that is either not seating properly or has not
yet closed. Combustion may even occur with the valves still partially
open for the same reason stated above, thereby leading to low
compression and raw exhaust escaping through the exhaust port. Valve
-------
2-10
timing changes will not be substantial and represent minimal cost.
However, valve guides will be added to the valve system to improve
durability into the valve/mating surface fit regardless of engine block
warpage and thereby reduce the oil and/or exhaust gases that may
escape. The variable hardware cost estimate for valve system
improvements is $0.40 per engine. Production costs include the
additional step of inserting the valve guides in each engine. Production
costs are estimated at $0.20 per engine.
EPA estimates that 1% of 4-stroke side valve design engines, i.e.,
larger low production engines, will be exchanged for 4-stroke overhead
valve (OHV) designs. OHV engines are readily available in similar side
valve horsepower size and there will likely be excess capacity available
in OHV engine production facilities to accommodate the small increase
in production necessary to replace these low volume side valve models.
Therefore, to obviate the need to perform any development work on the
low production side valve engine, the manufacturers will find it more
cost effective to replace them with OHV engine designs. There will be
no increase in variable hardware cost estimates per engine or increase in
production costs for engine manufacturers already making both engine
designs and therefore capable of covering this increased demand with
existing production facilities.
EPA estimates that 50% of the 4-stroke side valve, overhead valve
and other engines will require improved cooling in addition to changes
made by carburetor enleanment and combustion chamber redesigns.
Improved cooling changes are required to prevent premature wear of
the valves, valve seats and piston rings. Improved cooling changes can
consist of additional surface area, on the cylinder head and engine
block, and increased fan area. Improved oil splash and oil circulation
systems as well as improved materials for the valve train and piston
components will help to remove heat from the valve train and piston
-------
2-11
areas. Variable hardware costs consist of increased material for
components such as cylinder head, engine block and fan moldings.
Variable hardware costs are estimated at $0.10 per engine. EPA
estimates that no new production-related costs will be incurred. One
time die design changes are expected to occur simultaneously with
combustion chamber redesign costs and are included in research and
development costs.
EPA estimates that 100% of the 4-stroke OHV engines will utilize
enleanment through minor r difications to the carburetor. This
estimate is based on confides .al information from engine manufacturers
and emission data published in SAE papers as listed in Appendix B.
Most of the OHV design engines are newer engine designs and are used
in more expensive and durable equipment. Therefore, these engines
tend to be of higher quality in terms of machining tolerance and
durability. Such features allow these engines to produce lower baseline
emissions, thus requiring less modification to meet the adopted
standards. Modifications include fuel metering needle resensitizing and
conversion to fixed jet systems. EPA estimates that engine
manufacturers produce 80% of the c buretors for these engines while
purchasing 20% from outside sources. As a result, the variable
hardware cost is estimated to apply only to the outside sourced
carburetors for an additional $0.50 per engine. Variable hardware costs
for in-house manufactured engines are estimated at no cost to the
engine manufacturer based on the same reasons discussed earlier for
side valve engines. Production costs for in-house manufactured
carburetors are estimated to increase $0.20, again for the same reasons
stated for side valve engines including more precise production
tolerances.
Special sales cap provisions are included in this regulation for Class I
2-stroke engines. In the initial implementation year, the sales cap will
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2-12
be the number of 2-stroke engines in lawnmowers and snowblowers
sold in 1994 and must meet the handheld Class V emission 'evels. The
technologies to meet this level include enleanment with major
carburetor and fuel districution changes (estimated $0.20 production cost
per engine), carburetor limiter caps ($1.00 HVC and $0.20 production
costs per engine), combustion chamber redesigns ($0.10 HVC and $0.20
production costs per engine) and improved cooling ($0.10 HVC per
engine). In the year 2003, the 2-stroke engines must meet the same non-
handheld Class I emission levels. At this time, EPA expects that either
technologies, such as fuel injection and catalysts, will be available and
applicable for 2-stroke Class I engines. Costs are estimated at $20.00
Hardware Variable Cost and $1.00 Production Cost per engine to meet
Class I emission levels with a 2-stroke engine.
EPA also estimates that technology changes will be necessary for
50% of "other" Class I engines. For example, fuel injected engine
designs, 50% will require enleanment with fuel injector optimization.
This estimation is based on the assumption that these engines are of
high quality and thus will need less technology changes to meet the
emission standards. These engines are a very small percentage of the
market. They are too expensive to be considered direct substitutes, but
meet high durability needs of a very small segment of the market (i.e.,
less than .01%). These engines are not driving the feasibility
determination of this rule. EPA estimates that there is a $0.20 increase
in variable hardware costs for these engines based on the more complex
fuel injector components. To simplify the cost estimate, EPA assumed
that all fuel injector components are outside sourced.2 Therefore, EPA
2 This is not a totally valid assumption. However, the population of these engines is so small that
a more rigorous analysis would not impact cost ofthe rule. PSR database showed B&S as
manufacturer of FI engine. B&S was contacted and they said they did not produce an FI engine,
however, Kohler dews produce an FI engine in Class n.
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2-13
estimates no change in production costs.
EPA estimates that there will be no use of catalysts to meet the
requirements of this regulation. This is based on confidential
discussions with manufacturers and consideration of lead time available
until implementation of the regulation. However, the use of catalysts is
an option to engine manufacturers and if used, EPA estimates that 33%
of 4-stroke side valve engines could utilize minimally loaded catalysts,
mainly to reduce emission variances due to production variability. The
variable hardware cost estimate for minimally loaded catalysts is $1.32
pe: Class I engine in addition to the per Class I engine variable
hardware estimate previously discussed. The cost estimate is based on
a catalyst cost of $4.00. EPA estimates no production costs since the
catalyst is purchased from an outside source.
Each engine will require a label which indicates engine certification.
The estimated hardware variable cost of the label per engine is $0.04.
The production/administration cost to apply the label is estimated at
$500 per engine family. This cost is included under administrative
costs.
2.2.2. Class II
The majority of Class n engines are of 4-stroke overhead valve and
side valve designs. This class, according to PSR data, contains only one-
half of 1% 2-stroke engines. The engines are of higher horsepower and
are also larger displacement than Class I engines. As a result, the
effects of flame quenching are less and therefore the emissions are lower
on a brake specific basis. EPA estimates that a majority of the side
valve engines will require minor improvements, such as carburetor
adjustments and combustion chamber redesign, while the overhead
valve engines will need little to no improvements. These estimates are
based on examination of emission data. EPA also estimates that the 2-
stroke engines will convert to 4-stroke, engine design.
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2-14
Table 2-08 summarizes the technologies EPA is estimating will be
available to meet the emission standards for Class II engines. In
summary, EPA estimates that the sales-weighted average increase in
variable hardware and production costs for Class II engines will be
$0.65 and $0.16 per engine, respectively. The estimates apply to the
sales and annual consumption of Class II small engines in the United
States. The percentages apply to the change in annual sales as a result
of first full year of regulation implementation. Cost estimates are based
on confidential conversations with manufacturers of engines and engine
components.
EPA estimates that 100% of the 4-stroke side valve engines in Class
II will utilize enleanment with minor redesigns to the existing
carburetors. Minor carburetor changes consist of jet size changes to
account for enleanment and/or steps to change from adjustable jet
carburetors to fixed jet carburetors. EPA estimates that no engine
manufacturer will utilize adjustable carburetors due to the added cost of
certification in the full range of all adjustable parameters. EPA also
estimates that nearly 100% of the carburetors used in this class are
purchased from an outside source. As a result, the variable hardware
cost estimate for tliis change is $0.50 per engine based on carburetor
manufacturer's increased costs to produce carburetors with tighter
tolerances and an allocation of a portion of the tooling changes in
production runs. EPA estimates the production costs to the engine
manufacturer for this change to be $0.00 per engine.
EPA estimates that 100% of the 4-stroke side valve engines will
utilize combustion chamber redesign for the reasons listed ir- Class I
which include decreasing surface to volume effects and providing for
more efficient combustion. Combustion chamber redesign is estimated
to cost an additional $0.10 in variable hardware costs based on
additional material to stiffen the cylinder. Production costs are
fo
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2-15
estimated at $0.20 per engine to account for increased maintenance and
increased frequency of replacement of dies due to tighter tolerances.
EPA estimates that 25% of 4-stroke side valve, overhead valve, and
other engines will require improved cooling. Improved cooling changes
can consist of additional surface area, on the cylinder head and engine
block, and increased fan area. EPA estimates a $0.10 increase in
variable hardware cost per engine for additional material for this
increased surface area. EPA estimates no increase in production costs
for the same reasons as listed in Class I analyses.
EPA estimates that 1% of the 4-stroke OHV engines will utilize
enleanment with minor modifications to the carburetor. This estimate is
based on emission data which shows that a majority of these engines
can already meet emission standards. Engines close to the 225cc cutoff
may require some adjustment of the carburetor. The variable hardware
cost estimate per engine is $0.50 for the same reasons cited for Class II
side valve engines.
EPA estimates that all of the current 2-stroke engines in this class
will be discontinued and the consumer will choose either 4-stroke side
valve or overhead valve engines. " \ere is no variable hardware cost for
this change. Production costs are also nonexistent based on the estimate
that 4-stroke production lines can fulfill the limited 2-stroke market in
this class.
EPA estimates that for the "other" category of engines, which
includes water cooled and alternative fueled engine designs, 1% will
require enleanment with minor carburetor modifications. This
estimation is based on the assumption that these engines are of high
quality and thus will need less technology changes to meet the
standards. These engines are a very small percentage of the market.
They are too expensive to be considered direct substitutes, but meet
high durability needs of a very small segment of the market (i.e., less
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2-16
than one-tenth of 1%). The variable hardware cost estimate per engine
is $0.50 based on previous statements for other engines in this Class.
Previous statements also give reasons for EPA's estimate of $0.00
increase in production costs.
Each engine will require a label which indicates engine certification.
The estimated hardware variable cost of the label per engine is $0.04.
The production/administration cost to apply the label is estimated at
$500 per engine family. This cost is included under administrative
costs.
2.2.3. Handheld Equipment Engines (Classes III, IV and V)
To comply with the emission standards, manufacturers will have to
enlean practically every engine. Manufacturers have said that the main
constraints encountered with enleanment are engine temperature and
performance loss. While specific modifications were compiled through
confidential discussions with manufacturers and will be summarized
below, the main areas of modification involve either strategies that
offset engine temperature increases from enleanment through cooling
system design, or modifications that minimize the amount of
enleanment required through carburetor and combustion chamber
modifications and aftertreatment options. Classes III, IV, and V are
discussed separately because although these engines will utilize the
same technologies, the percentage of engines that will do so will be
different. This is based on estimates that engines in the higher
displacement categories are less influenced by the surface to volume
ratio on quenching and are of higher quality, thereby require less
n
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2-17
improvements to meet the emission standards. The HC emission
standards are proportionally decreased for each class with the CO
standard for Class V being cut from 804 to 603 g/kW-hr. Technology
information with respect to specific emission benefits are included in
Chapter 1.
2.2.3.1. Class Ill-This class is for engines less than 20cc.
Engines in Class III have been seen not to extend much lower 16cc and
have low sales based on the limited number of models in relation to
Classes IV and V. Table 2-09 summarizes the : Sinologies EPA is
estimating will be available to meet the emissiOi standards for Class HI
engines. In summary, EPA estimates that increased variable hardware
and production costs for Class III engines will be $1.69 and $0.40 per
engine respectively. The estimates apply to the sales and annual
consumption of Class III small engines in the United States. The
percentages apply to the change in annual sales as a result of the first
full year of regulation implementation. Cost estimates are based on
confidential conversations with manufacturers of engines and engine
components.
EPA estimates that 100% of Class in engines will require minor
carburetor modifications consisting of a resensitizing of the carburetor
adjustment and idle needles, limiter caps for adjustable carburetors and
carburetor jet size changes for fixed jet carburetors. Although there are
some fixed jet engines in the higher sizes, EPA estimates that these
engines will remain with adjustable jets due to their sensitivity to
operating conditions, including temperature, humidity, and altitude
which affect the air to fuel, ratio. The estimated variable hardware costs
per engine is $0.50. EPA estimates that Class III engine manufacturers
do not make their own carburetors and therefore will not experience
any carburetor production costs.
EPA estimates that 100% of engines in this class will utilize
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2-18
carburetor limiter caps. Limiter caps will be required on up to three
adjustment needles (idle, low speed and high speed mixtures) on the
carburetors. The use of limiter caps allows for some limited engine
adjustment to maintain smooth operation when engines in actual use are
exposed to temperature, humidity and altitude changes. The variable
hardware cost estimate is $1.00 per engine. Production costs are
estimated at $0.20 per engine based on the requirement of adding test
stations and workers to test emissions throughout the limiter caps
ranges as required by this regulation.
EPA estimates that 100% of Class IE engines will incorporate
combustion chamber, scavenging, and port timing modifications.
Manufacturers will redesign the piston, combustion chamber and
cylinder by tightening tolerances, increasing component stiffness to
reduce distortion, optimizing port shapes and timing, and reducing
dead space in the combustion chamber. Such design improvements will
reduce emissions by reducing scavenging losses of raw fuel (i.e., HC
emission) and ensuring more complete combustion (i.e., HC and CO
emission). EPA estimates the variable hardware cost to be $0.10 per
engine based on the additional material required to each engine.
Production costs are estimated at $0.20 based on increased maintenance
and frequency of replacement due to tighter tolerances. The number of
unacceptable parts may also increase, thereby increasing the cost of
production.
EPA estimates that 50% of the engines will require cooling changes.
Emission data has shown that a portion of the engines already meet or
are close to the emission standards while others will require extensive
emission reduction. EPA assumes that engines requiring extensive
emission reduction will utilize cooling changes. This is based on
considerations that as engines are enleaned there is less fuel available to
cool the engine and therefore additional cooling must be found in order
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2-19
to assure correct engine operation. Most engines currently operate
around 175 to 230°C combustion chamber temperature. One
manufacturer provided data showing that engines can live at
temperatures up to 290°C, at which point severe engine failure may
occur. The data also indicated that the increases in combustion chamber
temperature from enleaning an engine by 3% to 4%, approximately what
is required to meet the emission standards, could be accommodated
without causing engine damage. EPA estimates this is applicable to
most engines. EPA estimates variable hardware cost to be $0.10 per
engine. This is based on the estimate that cooling changes will require
additional material to provide increased surface area in engine head and
block and engine fan. EPA estimates there will be no production costs
for this technology change.
EPA estimates that no engine will utilize catalysts. However, the
option does exist and if utilized, EPA estimates that l%of Class III
engines could utilize low efficiency catalytic converters in order to
account for increased variability in emission characteristics when the
prototype emission reduction engine is put into production. The
variable hardware cost estimate is $3.00 per catalyst or $.03 per Class III
engine. The cost is based on confidential meetings with engine and
catalyst manufactures. This estimated use of a low efficiency catalyst is
based on the consideration that low efficiency converters (i.e., less than
30% HC conversion efficiency) would generate a small exotherm in the
muffler but would not substantially increase the muffler skin
temperature over that experienced by non-catalyzed systems. -EPA
assumes there will be no increase in production costs given EPA's
understanding that catalysts will be incorporated in the engine muffler.
EPA estimates that a portion of engine models will be discontinued,
however, the demand will be fulfilled by other available engine models.
This is based on cost estimates that the decision by a manufacturer to
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2-20
discontinue an engine model is usually made on the basis of cost and
life cycle. A mature engine that is near the end of its production cycle
will not likely be modified, but will be discontinued or replaced with a
newer model. Furthermore, some engine models may require such
extensive modification to comply with the emission standards that it
makes more sense to discontinue the model rather than modify it. In
either case, manufacturers have not indicated to EPA that they intend to
give up any substantial amount of market share as a result of this FRM.
Manufacturers may be able to convince customers to switch over to
similar engines within its product line. Therefore, EPA is assuming that
the discontinued models will either be in markets for which the
manufacturer has a replacement model, or in markets which the
manufacturer has few sales.
Each engine will require a label which indicates engine certification.
The estimated hardware varaible cost of the label per engine is $0.04.
The production/administration cost to apply the label is estimated at
$500 per engine family. This cost is included under administrative
costs.
2.2.3.2. Class IV-Class IV engines (20cc-50cc) are similar to
Class III engines (<20cc) in that they are presently all 2-stroke. As a
result, many of the descriptions for the use of engine technologies
discussed in the Class III section 2.2.3.1. apply to this class cf engines
and are referred to where appropriate. The percentages of use for each
technology are different from those in Class HI due to the fact that there
are more commercially orientated.engines of higher quality in this
category. As a result, EPA estimates Class IV engines will need less
changes to meet emission standards. Table 2-10 summarizes the
technologies EPA is estimating will be available to meet the emission
standards for Class IV engines. In summary, EPA estimates that
increased variable hardware and production costs for Class IV engines
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2-21
will be $1.9.2 and $0.25 per engine, respectively. The estimates apply to
the sales and annual consumption of Class IV small engines in the
United States. The percentages apply to the change in annual sales as a
result of first full year of regulation implementation. All cost estimates
are based on confidential conversations with manufacturers of engines
and engine components.
EPA estimates that 75% of Class IV engines will require major
carburetor modifications. Major carburetor modifications include an in
depth redesign of the carburetor in order to deliver more precise fuel
distribution to the engine as required by an enleaned engine. Major
modifications consist of replacing the fuel system and carburetor with
new designs. The estimated variable hardware cost per engine is $1.50
and production costs are estimated at $0.00.
EPA estimates that 25% of Class IV engines will require major
carburetor modifications as described in Class III. The estimated
variable haidware cost per engine is $0.50 and no production costs.
EPA estimates that 50% of Class IV engines will utilize engine limiter
caps as discussed in Class III. Some Class IV engines are already using
fixed jet carburetors and therefore the estimated percentage post-control
use is less than that in Class III. The estimated variable hardware cost
is $1.00 per engine and production cost estimate is $0.20 per engine.
EPA estimates that 75% of engines requiring major carburetor
changes will also incorporate combustion chamber, scavenging, and port
timing modifications for reasons specified in Chapter 1. The variable
hardware cost per engine is estimated at $0.10 for additional material
required for new engine designs. Production costs are estimated at
$0.20 for reasons stated in Class HI.
As discussed for Class in engines, EPA estimates that 50% of Class
IV engines will require cooling changes. EPA estimates the variable
hardware cost and production costs at $0.10 and $0.00 per engine
11
-------
2-22
respectively for reasons described in Class HI.
EPA estimates that 1% of the market will convert to a 4-Łtroke
engine design. This is based on discussions with one engine
manufacturer who stated that 4-stroke engines will be available in
January of 1994 for use in trimmers and other medium speed handheld
equipment. The cost differential between a 4-stroke engine and current
2-stroke engines, at least in the short term, will be greater than the
expected cost of modifications that would be required by current 2-
stroke engines to comply with the emission standards. Nevertheless,
any manufacturer choosing to use 4-stroke technology for market-based
reasons will have no problem complying with the standards.
As for Class III engines, EPA has determined that no catalytic
converters will be utilized on Class IV engines. However, the possibility
does exist that manufacturers may utilize low efficiency catalysts. If this
option is chosen, EPA estimates that 1% of Class IV engines could
utilize low efficiency catalytic converters in order to account for
increased variability in emission characteristics when the engine is put
into production. The cost estimate is $3.00 per catalyst or $0.03 per
Class IV engine. EPA estimates that a small portion of Class IV engines
will be discontinued and other available models will be substituted.
This is based on discussions found under this topic in Class III section
2.2.3.1.
Each engine will require a label which indicates engine certification.
The estimated hardware varaible cost of the label per engine is $0.04.
The production/administration cost to apply the label is estimated at
$500 per engine family. This cost is included under administrative
costs.
2.2.3.3. Class V-This class is for handheld engines greater than
50cc. Class V engines are similar to Class III engines (<20cc) and Class
IV engines (20-50cc) in that they are presently all 2-stroke. As a result,
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2-23
many of the descriptions for the use of engine technologies given in
Class III apply to this class of engines and are referred to where
appropriate. The post control use percentages for each technology are
different from those in Class III and IV due to the dominance of higher
quality commercially orientated engines in this class. Table 2-11
summarizes the technologies EPA is estimating will be available to meet
the emission standards for Class V engines. In summary, EPA estimates
that increased variable hardware and production costs for Class V
engines will be $2.37 and $0.39 per engine, respectively. The estimates
apply to sales and annual consumption of Class V small engines in the
United States. The percentages apply to the change in annual sales as a
result of first year of regulation implementation. All cost estimates are
based on confidential conversations with manufacturers of engines and
engine components.
EPA estimates that 75% of Class V engines will require major
carburetor modifications as described for Class IV engines. Variable
hardware and production costs are estimated at $1.50 and $0.00 per
engine respectively.
EPA estimates that 25% of Class V engines will require minor
carburetor modifications as described for Class III engines. Variable
hardware and production costs are estimated at $0.50 and $0.00 per
engine respectively.
EPA estimates that 92.5% of Class V engines will utilize limiter caps.
Limiter caps will be used on this class of largely fixed main jet engines
in order to provide flexibility of adjustment with the enleaned engines.
Limiter caps will be required for the same reasons stated for Class III
engines. EPA estimates the variable hardware and production costs to
be $1.00 and $0.20 per engine respectively.
EPA estimates that 100% of Class V engines will require combustion
chamber redesign to reduce scavenging losses and improve combustion
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2-24
efficiency. Combustion chamber redesign and related costs -,vdll consist
of the same as discussed in Class III. The estimate variable hardware
and production costs are at $0.10 and $0.20 per engine respectively.
EPA estimates that 50% of the Class V engines will require cooling
changes for the same reasons discussed in Class III. The estimated
variable hardware and production costs are at $0.10 and $0.20 per
engine respectively.
EPA has determined that no catalytic converters will be utilized on
Class V engines. However, the option does exist that manufacturers
may utilize low efficiency catalysts. If this option is chosen, EPA
estimates that 1% of the small engines could utilize low efficiency
catalytic converters in order to account for increased variability in
emission characteristics when the engine is put into production. The
cost estimate per catalyst is $3.00 and increased variable hardware cost
is $0.03 per Class V engine. This is based on reasons presented in Class
III.
EPA estimates that a small portion of Class V engine models will be
discontinued and substituted as discussed in the section on Class III
engines.
Each engine will require a label which indicates engine certification.
The estimated hardware varaible cost of the label per engine is $0.04.
The production/administration cost to apply the label is estimated at
$500 per engine family. This cost is included under administrative
costs.
2.3 Research and Development Cost Estimates per Class
Research and development costs are considerable for small SI
engines based on the fact that this is the first time engine manufacturers
are being required to address the issue of HC, CO, and NOX emission
reductions for all of their engine product lines. Research and
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2-25
development costs include time and resources spent to investigate
emissions on current engines, investigation, design and application of
engine design changes and/or emission reduction technology, and one
time tooling and die design changes for the production line. Since
many small engine manufacturers have begun research and
development activities to address emission reductions on a portion of
their production, as a result of 1991 requirements by the California Air
Resources Board (CARB), only a portion of the total research and
development cost is accounted for by this ruienaaking. One exception is
Class V engines in which all of the research and development cost
estimate is applied to the federal rule, because the class contains a
majority of engines utilized in farm and construction applications which
are preempted from CARB rulemakings.
Information for research and development cost estimates were taken
from confidential discussions with engine and component manufacturers
and internal analysis. EPA has based its analysis on the assumption
that research and development activities will be required on each
individual engine model due to the extent of changes in engine designs.
The PSR Engindata database contains information on engine
manufacturers and engine models, however, PSR requested that this
information remain confidential. As a result, only the number of
models in each class and technology group is described in Table 2-12
and detailed worksheets in Appendix B. Confidentiality is also kept by
generalizing the application of various technologies to a specified
number of engine models rather than a specified number of engines.
Class I engines are specifically sensitive to this due to the fact that there
are only two major engine manufacturers in this class and that some
engine models sell millions of engines while other engine models sell-
very few in comparison. As a result, research and development costs
are estimated by applying the percentage of technology usage (e.g., 78%
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2-26
of side valve engines are estimated to require major carburetor changes),
to the number of engine models (e.g., 78% of the engine models are
estimated to require major carburetor changes). No consideration was
made for overlapping use of parts in several models, such as engine
blocks, since this detailed information was not available. This may
result in a slight overestimation of costs, however this may also account
for costs not considered in this analysis.
Table 2-12 shows EPA's cost estimates for research and development
activities for EPA Phase I rulemaking are $10,000,000 for Class I,
$10,000,000 for Class II, $72,500 for Class III, $2,115,000 for Class IV, and
$2,812,500 for Class V. Research and development costs for catalyst
development were estimated separately at $100,483 for Class I, $0.00 for
Class II (no catalyst use assumed), and $20,000 for each class in Class
III-V. These costs are considered capital costs and therefore are
amortized over time, see Chapter 3 for details.
Research and development costs appear to be the same for Classes I
and II, however the numbers are the same for different reasons. Class I
engine models are fairly low in number, however estimates indicate
they will require a great deal of work to meet standards due to such
factors as the disadvantage of high surface to volume ratios. Class n
engine models are estimated to require less development for meeting
emission standards, however, Class II contains a large number of engine
models which must be reviewed and changed to meet emission
standards. The lower research and development estimate costs for Class
III-V engines indicate the less number of pieces in the current 2-stroke
design in comparison to 4-stroke engine designs which are a majority in
Classes I and II. Comparing estimated costs for Classes III-V show that
Class III is very low. This is based on the observation that Class in has
very few models in relation to the other two classes. Class IV and V
have similar cost estimates even though Class V contains the entire
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2-27
research and development costs, Class IV contains more engine models.
All Catalyst research and development activities are assumed to be
the same for all Classes. The activities consist of the engine
manufacturer working with the catalyst manufacturer to develop
catalyst designs and the engine manufacturer testing the engines in the
laboratory of the respective company. The only changes between each
class is the percentage of models on which the catalysts may be utilized.
EPA's estimated research and development costs for catalyst
development are summarized in Table 2-02.
Table 2-02
Estimated Research and Development Costs for the Catalyst Option
CLASS
CLASS 1 (33%)
CLASS' II (0%)
CLASS III (1%)
CLASSIV(1%)
CLASS V(1%)
# OF MODELS
BASED ON ENGINE
SALES
16
0
1
1
1
ESTIMATED COST
FOR R&D PER
MODEL
$20,000
$20,000
$20,000
$20,000
TOTAL ESTIMATED
COST PER CLASS
$320,000
$0.0
$20,000
$20,000
$20,000
2.4. Equipment Variable Hardware and Production Cost Estimates
Small engines are utilized on a wide variety of equipment from
handheld trimmers and chain saws to garden tractors and generator
sets. The wide variety of equipment designs and ease of designing
equipment which use small SI engines presents a challenge when
estimating costs for these classes of engines. As a result, the following
analysis is based on the major equipment type for each engine class.
Based on PSR Engindata, the majority of Class I engines are utilized in
lawnmowers, the majority of Class II engines are utilized in lawn
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2-28
tractor, garden tractor engines, and generator sets, Class III engines are
utilized in trimmers, Class IV engines are utilized in trimmers,
blowers/vacs and chain saws, the majority of Class V engines are
utilized in chain saws.
The majority of lawnmowers utilizing Class I engines consist of a
revealed engine bolted to a metal or plastic deck which houses the grass
cutting blade and is moved over the grass on four wheels. EPA
estimates that any change in shape of the engine will not require any
equipment redesign. As a result, EPA estimates that increased variable
hardware and production cost changes for this equipment is $0.00.
However, if the option of catalysts is utilized on these engines, then the
engine and deck will require shrouding which will protect the user from
the hot surfaces as well as assure that no dry grass is collected near the
exhaust port which may ignite due to the hot escaping gases. EPA
estimates that of the 33% of engines that may utilize catalysts, a total of
3% will require shrouding due to the hazardous exotherms developed
by some catalysts. Variable hardware cost changes are estimated at
$0.03 and production changes are estimated at $0.03 per Class I engine.
Lastly, a label must be visible to the user as required by this regulation.
It is likely that the majority of Class I engines will be uncovered,
thereby it is estimated that only 10% will require labels. EPA estimates
the label cost will be $1.00 per label and thereby $0.10 per engine (10%
of $1.00). These estimates are based on confidential discussions with
engine and equipment manufacturers.
Garden tractors general design incorporates an engine in a plastic
housing either on the front or back of the rider. The engine is
surrounded by a shrouding, in most cases, under which the fuel is also
stored. Based on the technologies expected for this rule, EPA estimates
that there will be no changes to the equipment and therefore no
increased variable hardware and production costs. EPA estimates that
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2-29
catalysts will not be used on any of the engines for these equipment
types. Lastly, costs for an additional label will be incurred by the
equipment manufacturer if the engine label is covered by the equipment
housing. It is likely that the majority of Class II engines will be covered,
thereby it is estimated that 100% will require labels. EPA estimates the
label cost will be $1.00 per label. All cost estimates are based on
confidential discussions with engine and equipment manufacturers.
Equipment impacts for the handheld engine classes include changes
in shrouding designs due to the application of carburetor limiter caps.
Presently, the shrouding surrounds the engine very closely and does not
provide room for placement of the limiter cap on the engine. Costs
include changes in plastic shrouding dies to accommodate this change.
Although limiter caps were estimated to be utilized on 100% of Class III,
50% of Class IV and 50% of Class V engines, EPA estimates that
changes will be required on 40% of the equipment in these categories.
This is based on the assumption that not all of the equipment that will
utilize engines with limiter caps will require design changes. As a
result, EPA estimates that increased variable hardware and production
costs will be $0.20 and $0.04 per handhe equipment.
If engine manufacturers choose the option of utilizing catalysts, then
EPA estimates there will be an impact on equipment in order that it
provide adequate shielding for user safety and adequate cooling such
that equipment panels do not melt. An example is chain saws in which
the housing is made from plastic and surrounds the equipment. Any
increased temperature due to the use of a catalyst will require
additional shielding or increased cooling panel designs in order to keep
temperatures to a minimum and within already established surface and
exhaust temperature limits. Although EPA estimated that 1% of the
engines may utilize catalysts, EPA estimates that this change will affect
only one half of 1% of equipment in Classes III-V. This difference is
-------
2-30
due to the expected range in catalyst loadings that will be utilized on
these engines and the resultant variation in heat exotherms that will be
generated. Variable hardware and production costs are estimated at
$0.10 and $0.10 for Class III-V engines respectively.
Lastly, costs for equipment manufacturers include the addition of a
label if the engine label is covered by the equipment housing. It is
likely that the majority of Class HI, IV, and V engines will be covered,
thereby it is estimated that 100% will require labels. EPA estimates the
label cost will be $1.00 per label. These estimates are based on
confidential discussions with engine and equipment manufacturers.
Table 2-03
Equipment Design Changes
EQUIPMENT
CATEGORY
Equipment with
Class 1 Engines
EQUIPMENT DESIGN
CHANGES
10% Additional Label
OPTION:
3% Alterations for
Catalyst use:
VARIABLE
HARDWARE
COST
ESTIMATE
$0.10
$0.25
PRODUCTION
COST ESTIMATE
$0.00
$0.25
Total Sales-Weighed Cost Estimate Per Equipment with CLASS 1 Engines = $ 0.10
Option: $0.10 + $0.03 VHC + $0.03 PC = $0.16
Equipment with
Class II Engines
100% Additional Label
$1.00
$0.00
Total Sales-Weighed Cost Estimate Per Equipment with CLASS II Engines = $ 1 .00
Equipment with
Class III-V Engines
(Handheld
Equipment Engines)
100% Additional Label
40% Panel Alterations
for Cooling and Limiter
Cap Placement:
OPTION:
.05% Alterations for
Catalyst Use:
$1.00
$0.50
$0.25
$0.00
$0.10
$0.25
Total Sales-Weighted Cost Estimate Per Equipment with CLASS III-V Engines = $1.20 VHC
+0.04 PC= $1.24 Option: $1.20 + $0.10 VHC + $0.14 PC = $1.44
-------
2-31
2.5 Total Costs for implementing Emission Control Technology
Table 2-04 summarizes the estimated costs per engine per class as
documented in this chapter. The retail cost of equipment in which all
engines in Class I and II, ranges from $90 to $9,000. On average, the
cost to install the necessary emission control technology on these
engines will be approximately $2.32 per engine for Class I and $0.81 for
Class II. Equipment costs to utilize post control engines is estimated at
$0.10 for Class I engines and $1.00 for Class II engines. Po5: Class I
engines, this correlates to a total equipment and engine in ase of $2.42
per engine/equipment. For Class II engines, this correlates o a total
increase of $1.81 per engine/equipment. If the option of catalysts is
utilized then the engine costs are increased by $1.32 and the equipment
impact is increased by $0.06 for a total of $3.80 per Class I engine. EPA
estimates that no catalysts will be used on Class n engines, therefore,
there is no additional cost for this option.
The equipment in which Class III-V engines are installed range from
$60 to $1,000. On average, the cost to install the necessary control
technology on Class III engines will be approximately $2.09 per engine,
Class IV engines will be approximately $2.17 per engine and Class V
will be approximately $2.76 per engine. For Class III-V engines,
equipment costs are estimated at $1.24 per engine for a total equipment
and engine impact of $3.33 for Class III engines, $3.41 for Class IV
engines, and $4.00 for Class V engines. If the catalyst option is chosen
by an estimated 1% of the engines then the costs for all Class III-V
engines are raised $0.03 and equipment $0.20 resulting in estimated
increases of $3.56 for Class III engines, $3.64 for Class IV engines and
$4.23 for Class V engines.
-------
2-32
Table 2-04
Summary of Engine/Equipment Estimated Costs
CLASS
Class 1
Class II
Class III
Class IV
Class V
PER ENGINE COST ESTIMATED)
Engine
(HVC & PC)
2.32
0.81
2.09
2.17
2.76
Equipment
0.10
1.00
1.24
1.24
1.24
Total
$2.42
$1.81
$3.33
$3.41
$4.00
WITH CATALYST OPTION ($)
Engine
3.64
NA
2.12
2.20
2.79
Equipment
0.16
NA
1.44
1.44
1.44
Total
$3.80
NA
$3.56
$3.64
$4.23
-------
2-33
Table 2-05
Change in Technology Mix
Class I and Class II Engines
Present Engine
Design
Present
Market %
in Class
Assumed Market
%: Full
implementation
Technology
Class 1 Engines (<225cc)
Side Valve,
Carbureted
Overhead Valve,
Carbureted
2-Stroke,
Carbureted
Other (Fuel
Injected)
83
6.3
10.4
.06
84
10
5.8
,06
• 78% Enleanment with major redesigns to
carburetor and fuel distribution
o 21% Enleanment with minor redesigns to
carburetor
» 50% Change? in ignition timinr.
• 35% Combustion chamber rec'- i
• 80% Valve System, Improvem*-
including Valve Timing
• 1% OHV with minor mods to carburetor
» 50% Improved Cooling
• 100% Enleanment with minor modifications
to carburetor
• 50% Improved Cooling
in 1996
• 45% converted to 4 Stroke (50/50 sv and
OHV)
« 55% Enleaned with Major redesigns to
carburetor and fuel distribution
• 55%Carburetor Limiter Cap
» 55% Combustion chamber Redesign
• 55% Improved Cooing in 2003
• 100% 2 Stroke (Fuel Injection/Catalys/Other)
• 50% Fuel carburetion optimization
• 50% Improved Cooling
Class II Engines (>225cc)
Side Valve,
Carbureted
Overhead Valve,
Carbureted
2-Stroke,
Carbureted
Other
(Water-Cooled,
Altern. Fuels)
78.1
20.40
.50
.95
78.4
20.66
0.0
.95
• 100% Enleanment with minor carburetor
modifications
• 100% Combustion Chamber Redesign
• 25% Improved Cooling
* 10% Change in ignition timing
• 1% Enleanment with minor carburetor
modifications
• 25% Improved Cooling
• 1 00% 4 Stroke, sv
° 1% Enleanment with minor carburetor
modifications
• 25% Improved Cooling
-------
2-34
Table 2-06
Change in Technology Mix
Classes III, IV, and V
Present
Engine
Design
Present
Market %
in Class
Assumed
Market %:
Full
Implementation
Technology
Class III (<20cc)
2-Stroke,
Carbureted
100
100
« 100% Minor carburetor mods
« 100% Carburetor Limiter Caps
» 100% Combustion Chamber/
Scavenging/ Port Timing Modifications
• 50% Cooling Improvements
Class IV (20-50cc)
2-Stroke,
Carbureted
4-Stroke,
Carbureted
100
0
99
1
• 75% Major carburetor redesign
• 25% Minor carburetor mods
« 50% Carburetor Limiter Caps
« 75% Combustion Chamber/
Scavenging/ Port Timing Modifications
« 50% Improved Cooling
' 1% 4 Stroke Engine Design
Class V (>50cc)
2-Stroke,
Carbureted
100
100
• 75% Major carburetor redesign
• 25% Minor carburetor mods
° 92.5% Carburetor Limiter Caps
• 100% Combustion Chamber/
Scavenging/Port Timing Modifications
• 50% Improved Cooling
100
-------
2-35
Table 2-07
CLASS I ENGINES
Change in Variable Hardware Cost and Production Cost Estimates
Present
Engine
Design
Side Valve,
Carbureted
Overhead
Valve,
Carbureted
2-Stroke,
Carbureted
Other (Fuel
injection)
Labels
Present
Market
%ln
Class
83
6.3
10.4
.06
Assumed %
Market:
Full
Implementation
84
10
5.8
.06
Technology
« 78% Enleanment with major redesigns
to carburetor and fuel distribution system
80% manufactured in-house:
20% outsourced:
« 21% Enleanment with minor redesigns
to carburetor
80% manufactured in-house:
20% outsourced:
° 50% Changes in ignition timing:
• 95% Combustion Chamber redesign:
» 80% Valve System Improvements
Valve Timing:
• 1% OHV with minor mods to
carburetor:
• 50% Improved Cooling:
° 100% Enleanment with minor
modifications to carburetor
80% manufactured in-house:
20%outsoun:: 1
• 50%
Improved Cooling
In 1997 model year
• 45% 4 Stroke (50% sv, 50% phv)
• 55% Enleanment with major
modifications to carburetor
• 55% Carburetor Limiter Caps
• 55% Combustion chamber Redesign
• 55% Improved Cooing In 2003
• 100% 2 Stroke (Fl, Catalyst, Other)
• 50% Fuel carburetion optimization:
• 50% Improved Cooling:
All Engines
TOTAL COST ESTIMATE PER CLASS 1 ENGINE = $2.32
Variable
Hardware
Cost: Per
Engine
No Cost
$1.50
No Cost
$0.50
No Cost
$0.10
$0.40
$0.50
$0.10
No Cost
$0.10
No Cost
$0.50
$0.10
No Cost
No Cost
$1.00
$0.10
$0.10
$20.00
No Cost
$0.10
$0.04
$1.82
Production
Cost:
Per Engine
$.20
No Cost
$.20
No Cost
No Cost
$0.20
$0.20
No Cost
No Cost
No Cost
No Cost
$0.20
No Cost
No Cost
No Cost
$0.20
$0.20
$0.20
No Cost
$1.00
$0.20
No Cost
$0.50
lot
-------
2-36
Table 2-08
. CLASS II ENGINES
Change in Variable Hardware Cost and Production Cost Estimates
Present
Engine
Design
side valve,
carbureted
overhead
valve,
carbureted
2-stroke
Other (Water-
Cooled and
Altem. Fuel)
Labels
Present
Market
%in
Class
78.1
20.4
.50
.95
Assumed
%: Full
Impleme
notation
78.4
20.7
0.0
.95
Technology
» 100%Enleanmentwith
minor carburetor
modifications:
• 50% Combustion .
Chamber Redesign:
» 25% Improved Cooling:
• 10% Changes in Ignition
Timing:
« 1% Enleanment with
minor carburetor
modifications
« 25% Improved Cooling
100% 4-Stroke, SV
« 1% Enleanment with
minor carburetor
modifications
« 25% Improved Cooling
All Engines
TOTAL COST ESTIMATE PER CLASS II ENGINE = $0.81
Variable Hardware
Cost Estimate per
Technology
$0.50
$0.10
$0.10
No Cost
$0.50
$0.10
No Cost
$0.50
50.10
$0.04
$0.65
Production Cost
Estimate Per
Technology
No Cost
$0.20
No Cost
No Cost
No Cost
No Cost
No Cost
No Cost
No Cost
$0.16
/OJ-
-------
2-37
Table 2-09
Change in Technology Mix for Class III Engines,
Variable Hardware Cost and Production. Cost Estimates
Present
Engine
Design
2-stroke
engine,
carbureted
Labels
Present
Market %
100%
Assumed %
Market on Date
of Full
Implementation
100%
Technology
• 100% Minor
carburetor mods:
• 100% Carburetor
Limiter Caps:
° 100% Combustion
Chamber/Scavenging/
Port Timing
Modifications:
« 50% Cooling
Improvements:
All Engines
TOTAL COST ESTIMATE PER CLASS IV ENGINE = $2.09
Variable
Hardware Cost
Estimate per
Technology
$0.50
$1.00
$0.10
$0.10
$0.04
$1.69
Production
Cost Estimate
per
Technology
No Cost
$0.20
$0.20
No Cost
$0.09
$0.40
-------
2-38
Table 2=10
Change in Technology Mix for Class IV Engines,
Variaole Hardware Cost and Production Cost Estimates
Present
Engine
Design
2-stroke
engine,
carbureted
4-stroke
engine,
carbureted
Labels
Present
Market %
99%
1%
Assumed %
Market on Date
of Full
Implementation
99%
1%
Technology
° 75% Major carburetor redesign:
« 25% Minor carburetor mods:
' 50% Carburetor Limiter Caps:
0 75% Combustion
Chamber/Scavenging/ Port Timing
Modifications:
• 50% Improved Cooling:
• 1% 4 Stroke Engine Design:
All Engines
TOTAL COST ESTIMATE PER CLASS IV ENGINE = $2.17
Cost
Estimate for
Each Engine
Technology
$1.50
$0.50
$1.00
$0.10
$0.10
No Cost
$0.04
$1.92
Production
Costs Estimate
per
Technology
No Cost
No Cost
$0.20
$0.20
No Cost
No Cost
9
$0.25
-------
2-39
Table 2-11
Change in Technology Mix for Class V Engines,
Variable Hardware Cost and Production Cost Estimates
Present
Engine
Design
2 stroke
engine,
carbureted,
air cooled
Labels
Present
Market
%
100%
Assumed %
Market on
Date of Full
Implementation
100%
Technology
» 75% Major carburetor redesign:
° 25% Minor carburetor mods:
• 92.5% Carburetor Limiter Caps:
• 100% Combustion
Chamber/Scavenging/Port Timing
Modifications:
» 50% Improved Cooling:
All Engines
TOTAL COST ESTIMATE PER CLASS V ENGINE = $2.76
Cost
Estimate for
Each Engine
Technology
$1.50
$0.50
$1.00
$0.10
$0.10
$0.04
$2.37
Estimated
Production
Costs per
Technology
No Cost
No Cost
$0.20
$0.20
No Cost
$0.39
-------
2-40
Table 2-12
RESEARCH AND DEVELOPMENT COST ESTIMATES
Class &
Engine
Design
% Number of Models per Technology (same as
estimated % engines per technology)
Number
of
Models
Estimated
Cost per
Model
Total Cost
CLASS I - 51 models
Side Valve
(36 models)
Overhead
Valve
(10 models)
2-Strokes
(4 models)
Other
(1 model)
78% Major Carburetor Redesign of which:
- 80% models made in-house
- 20% models outsourced
21% Minor Carburetor Adjustments of which:
- 80% models made in-house
- 20% models outsourced
50% Ignition Timing
95% Combustion Chamber Redesign
80% Valve System Changes
1%OHV
50% Improved Cooling
100% Minor Carburetor Improvements of which:
-80% models made in-house
-20% models outsourced
50% Improved Cooling
1996
55% Major Carburetor. Improvements
55% Combustion Chamber Redesign
55% Improved Cooling
50% Minor Carburetor Improvements
50% Improved Cooling
226
6
2
18
34
29
0
18
8
2
5
2.2
.5
.5
$30,000
$20,000
$30,000
$20,000
$40,000
$325,000
$70,000
0
$20,000
$30,000
$20,000
$30,000
$20,000
$325,000
$20,000
$20,000
$30,000
$673,920
$112,320
$181,440
$30,240
$720,000
$1,111,500
$2,016,000
0
$360,000
$240,000
$40,000
$150,000
$44,000
$715,000
$44,000
$10,000
$15,000
CLASS I TOTALS: $16,466,920
FEDERAL RULEMAKING: $10.803.000
lot,
-------
2-41
CLASS II -144 Models
Side Valve
(93 models)
Overhead
Valve
(42 models)
Other
(9 models)
100% Minor Carburetor Improvements
100% Combustion Chamber Redesign
25% Improved Cooling
10% Ignition Timing
100% Minor Carburetor Modifications
50% Improved Cooling
50% Minor Carburetor Modifications
50% Improved Cooing
93
93
23
9
42
21
4.5
4.5
$30,000
$325,000
$20,000
$40,000
$30,000
$30,000
$20,000
$30,000
$2,790,000
$3,022,500
$465,000
$372,000
$1,260,000
$630,000
$90,000
$135,000
CLASS II TOTALS: $35,967,000
FEDERAL RULEMAKING: $10,000,000
CLASS III - 1 model
100% Minor Carburetor Adjustments
100% Limiter Adjustment Caps
100% Combustion Chamber Modifications
50% Improved Cooling
1
1
1
.5
$40,000
$5,000
$80,000
$40,000
$40,000
$5,000
$80,000
$20,000
CLASS III TOTALS: $145,000
FEDERAL RULEMAKING: $ 72,500
CLASS IV - 27 models
75% Major Carburetor Redesign
25% Minor Carburetor Adjustments
50% Limiter Adjustment Caps
75% Combustion Chamber Modifications
50% Improved Cooling
1% 4 Stroke Design
20 '. 300
7 ; -.;.ooo
14 ! S5.GOO
20
14
NA
$80,000
$40,000
NA
$2,025,000
$270,000
$67,500
$1,620,000
$540,000
NA
CLASS IV TOTALS: $4,522,500
FEDERAL RULEMAKING: $2,115,000
-------
2-42
CLASS V - 15 models
75% Major Carburetor Redesign
75% Minor Carburetor Adjustments
Limiter Adjustment Caps
Combustion Chamber Modifications
Improved Cooling
11
4
8
15
8
$100,000
$40,000
$5,000
$80,000
$40,000
$1,125,000
$1,500.000
$37,500
$1.200,000
$300,000
CLASS V TOTALS: $2,812,500
FEDERAL RULEMAKING: $2,812,500
I of
-------
Chapter 2: References
i.
White, Jeff, et al, "Emission Factors for Small Utility Engines", SAE
#910560, 1991
2.
Burrahm, Robert, et al, "Small Utility Engine Emissions Reduction
Using Automotive Technology", SAE #911805,1991
3.
Swanson, Mark, "An Emission Comparison Between a Carburetor and
an Electronic Fuel Injection System for Utility Engines", SAE #911806,
1991.
4.
White, Jeff, et al, "Emission Control Strategies for Small Utility Engines",
SAE #911807, 1991.
5.
Hare, Charles, et al, "Toward the Environmentally-Friendly Small
Engine Fuel, Lubricant, and Emission Measurement Issues", SAE
#911222, 1991.
6.
Cotton, Kenneth J, "A Study of the Potential of Propane Fuel to Reduce
Utility Engine Exhaust Emissions", SAE #921696,1992.
2-43
-------
2-44
-------
Chapter 3: Analysis of Aggregate Costs
and Economic Impacts
This chapter discusses the structure of industries producing
engines and equipment affected by this F?.Ai, aggregates the technology
related pollution control costs presented in Chapter 2, and discusses
possible economic effects of the regulation.
The aggregate costs are calculated from the estimated costs per
engine discussed in Chapter 2. Both the estimated per-engine costs
presented in Chapter 2 and the aggregate costs presented in this chapter
are derived from estimates of annual consumption of these engines in
the United States.3 Manufacturers' aggregate costs for variable hardware
cost increases, production cost increases, development cost \nd
administrative costs are capitalized where appropriate and. aruuialized
over a 30 year time horizon. Further, price increases beyond
manufacturers' cost increases are estimated, as well as savings in fuel
costs. Total costs to society are presented as the aggregate costs to
consumers.
Possible economic effects are discussed. EPA considered how to
3 Consumption is defined as U.S. production - exports + imports + (previous year's year-
end inventory - current year's year-end inventory). Appendix B presents EPA analysis of
consumption of these engines as well as projections of future consumption of these engines.
Consumption of engines is frequently referred to as sales in this chapter.
3-1
-------
3-2
deal with the issue of how this regulation might impact the productive
use of capital in the U.S., employment, and energy. On the whole, any
incremental economic effects on this sector are likely to be small
compared to the economy as a whole. Economic impacts on individual
manufacturers, including differential effects according to plant size (e.g.,
large, medium, or small sized), were not specifically addressed. An
analysis of the competitive structure of the industry suggested that full
cost pass through of pollution control costs could be expected. These
industries are characterized by monopolistic competition with high
degrees of product differentiation, strong buyer power from the
equipment manufacturers and mass merchandisers, tight marginal cost
structures, and (in a few sectors) good potentials for substitution from
other, more "environmentally friendly" power sources.
3.1. Industry Description
The industry description presented here is taken from a report
prepared under a contract work assignment for EPA by Jack Faucett
Associates.(l) The purpose of the work assignment was to prepare a
report describing and analyzing the market structure, conduct, and
performance of the small nonroad engine and equipment industry and
to assess the technologies represented by the most common engines and
equipment. The following descriptions are excerpted from that report.
Some sections which are excerpted are specific to the Lawn and Garden
Equipment Standard Industrial Code (SIC) 3524, although 11 SIC code
categories were analyzed in the report. The reason this section is
focusing on the lawn and garden equipment category is that most of the
engines and equipment covered by this regulation are in that category.
Ill
-------
3-3
[TJhe small nonroad engine market is best described as a chain of
industries that: convert raw materials into components, engines, and
equipment; distribute the final product to end users; and, provide service and
parts as required. The establishment of regulation or alternative market based
regulatory approaches will impact this chain of industries in a variety of ways.
The structure of this chain, and the characteristics of the industries that
comprise it, will influence how successful alternative control strategies will be
in practice.
Figure 3-01 provides a schematic of the relationships and flow of
goods for engine manufacturers. To begin the process, raw materials and
components are purchased from suppliers. Necessary raw materials include
the steel and aluminum required to manufacture engine parts. The amounts
and types of purchased components will vary from one manufacturer to
another. Some engine manufacturers make their own parts, others purchase
components. Die-cast molds are used to forge parts. The finished parts and
components are assembled into engines on an assembly line.
Complete engines are sent to one of three places: equipment
manufacturers, distributors, or export markets. A great deal of engines are
sold directly to equipment manufacturers. In cases where engine
manufacturers are vertically integrated, these sales would be recorded as intra-
company transfers. Direct sales to equipment manufacturers is particularly
common for high volume consumer equipment and for technically demanding
equipment for the commercial market. The large volume engine
manufacturers such as Briggs & Stratton and Tecumseh sell directly to mass
merchandiser equipment manufacturers such as Murray Ohio Manufacturing
and Arvcdcan Yard Products. Price and economies of scale4 are the primary
factors rompetition for engine sales to mass merchandisers. For direct sales
to equ:. «nt manufacturers producing mid-range and premium priced
equipment, engineering and design cooperation is essential. In these cases, the
engine manufacturers also work closely with the equipment manufacturers to
develop superior products.
For smaller equipment manufacturers, or for some of the cases where
there is no need for technical cooperation, it is usually not cost-effective for the
engine manufacturer to sell engines directly to the equipment manufacturer.
In these cases, engine manufacturers often ship engines to independent
wholesale distributors. As independent businesses, these distributors carry
engines from multiple manufacturers. The distributors then sell the engines to
original equipment manufacturers (OEM's) to be installed as product
components. Distributors also sell 'loose" engines as replacement parts.
Large-scale end-users and dealers/retailers who provide service on used
equipment are the most frequent purchasers of replacement engines. Engines
not sold to equipment manufacturers or domestic distributors are shipped as
exports.
An economy of scale is said to exist when larger output is associated with lower average cost.
//J
-------
Figure 3-01: Engine Manufacturer—Product Distribution Network
Raw Material
Suppliers
-Steel
-Aluminum
-Other
Component
Suppliers
-Spark Plugs
-Carburetors
-Mufflers
-Filters
-Other
Engine
Manufacturers
Equipment
Manufacturers
Distributors
Exports
Large-Scale
End Users
(replacement engines)
Dealer/Retailer
Service Outlets
(replacement engines)
3-4
-------
3-5
In every segment of the utility industry, equipment manufacturers
must decide whether to use "two-tiered" distribution channels or to interface
directly with their dealer network. In a two-tiered distribution system, an
independent wholesale distributor acts as an interface between the equipment
manufacturers and the dealer network. Distributors add value by providing
service to both the equipment manufacturers and the dealer network.
Distributors remove a great deal of the inventory burden from dealers.
Because dealers generally do not have the facilities or financial strength to
maintain large inventories, they must frequently order parts for repair.
Successful distributors can usually provide parts within 24 hours. In the
absence of a distributor, parts must be shipped from the equipment
manufacturers by package delivery services (such as UPS). This can take
several days or more, depending on manufacturer location and the availability
of the part Furthermore, because many dealerships are small businesses, they
often rely on their distributors for bookkeeping and general business support.
Enhanced service provided by the distributors improves the reputation of the
equipment manufacturers. Also, distributors provide market information to
manufacturers because they are closer to the consumers and are often able to
identify emerging trends faster than the manufacturers themselves.
Despite the added value that distributors provide for both dealers and
manufacturers, they are declining in numbers and importance. This shift is
generally attributed to the ever increasing price competition in the consumer
marketplace. The value added by distributors must be offset by the profit
margin required by the additional tier in the distribution chain. Although
distributors will remain important, particularly for premium line equipment,
their impact on the market is projected to decline.
The distribution system for lawn and garden equipment manufacturers
is probably the most diverse and complex in die utility market. This is
primarily due to the different needs of the commercial and consumer markets.
The bulk of all lawn and garden unit sales go to consumer end-users.5
However, commercial customers represent too large a market to ignore, and
some equipment manufacturers and members of the distribution chain focus
strictly on the commercial business. Balancing the commercial customers need
for performance and service with the consumer customers need for a low price
is the challenge facing manufacturers and the distribution channels they have
developed.
Figure 3-02 provides a schematic of the relationship? and flow of
goods from the viewpoint of the lawn and garden equipment manufacturers.
These manufacturers design and manufacture their own parts and/or purchase
components. The finished parts and components are assembled into end-user
equipment. Finished goods are sent to one of three places: wholesale
distributors, dealers or other retail establishments, or shipped for export.
For example, OPEI estimates that 90% of walk behind lawnmower sales go to the residential
market.
-------
Figure 3-02: Lawn and Garden Manufacturer—Product Distribution Network
Raw Materials
Supplier
•Steel
•Plastics
•Canons
-Ptinl
-Aluminum
•Magnesium
•Olher
Equipment
Manufacturer
Component
Manufacturer
•Engines
•Transmission
•Wheels
-Attachments
•Tires
-Etc.
Wholesaler/
Distributor
Export
(a) Primarily commercial and mid-range/high-end consumer equipment
(b) Primarily tales by large manufacturers to large Dealer/Retail outlet*
(c) Primarily lower end consumer equipment
Dealer/Retailer:
-Hardware Store
-Lawn sad Garden Cent
-Farm Supply
-Home Center
-Other
National
Merchandiser
-Montgomery Wards
•Scars
Discounter
•KMan
•Walman
3-6
-------
3-7
Some manufacturers use a direct (i.e., one-tier rather than two-tier)
distribution system, dealing directly with dealers or other retail establishments.
The larger the manufacturers and the larger the retail unit, the more likely that
this link will be direct. Mass merchandiser manufacturers deal directly with
mass merchant and discount retial outlets. Some manufacturers deal directly
with all types of retail outlets. The trend towards direct distribution is
expected to continue, as is the trend towards the mass merchandisers. These
trends serve to keep prices low, foster price based competition, and put a
squeeze on distributors and local dealers. The average service dealer makes
$100,000 to $250,000 in sales per year. There are 300 dealers that bring in over
$1,000,000 in revenues annually. There are also a great many dealers that have
less than $100,000 annual revenues. Dealers are extremely dependent on
service revenue to stay in business. Approximately 50 percent of the average
dealers revenues are realized through parts and repair work.6
As emission requirements force small nonroad engines to be more
complex, more will be expected of small engine technicians. The situation is
similar to automobile dealers who must perform vehicle emission compliance
work. Jeff Voelz, Marketing Director at Onan Corporation, noted that,
"dealers will have to get savvy and understand that this is their future."7 As in
the automotive industry, emission control advances are likely to reduce the
user's maintenance abilities and require an increase in small engine technician
skills.
Although two-tier distribution is declining, it is still an important
feature of the distribution network. According to a survey of its members,
OPEI found that 41.4 percent of shipments were distributed through wholesale
distributors in 1988. Many manufacturers use two-tier distribution for
virtually every type of retail establishment, although distributors are generally
bypassed when shipments go to mass merchandisers and discounters. Because
of fierce price based competition, the pressure is on distributors to prove their
ability to add value in order to maintain their volumes of business in the
future.
Most manufacturers choose to focus on either the consumer or
commercial market. These factors, in turn, influence their choice of
distribution channels. Manufacturers that focus strictly on the consumer
market, especially at lower end prices, generally retail exclusively through
mass merchandisers. Manufacturers that focus strictly on the commercial
market, generally rely exclusively on dealers. Mid-range manufacturers and
other manufacturers that wish to compete at the commercial or top-end
consumer market and the low-end consumer market face a difficult choice. It
is tempting to use both mass merchandisers (for sales volume) and dealers (for
value added service). However, this creates tremendous conflict within the
channels, particularly for the dealers. The dealers cannot match mass
merchandisers on price, and frequently end up as repair shops, merely
North American Equipment Dealers Association.
Phone conversation on June 8, 1992.
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3-8
servicing the equipment that they can no longer sell. The solution to this
situation that has been most successful is to sell separate lines of products,
restricting the mass merchandisers from selling the higher quality product
lines. McCullough has been able to do this successfully. Toro tried to do this,
but eventually withdrew from mass merchandiser outlets. Toro is now trying
the mass merchandisers again with its Lawnboy subsidiary.
This discussion of lawn and garden manufacturer distribution channels
primarily addresses nonhandheld equipment manufacturers, although, in
general, it applies to handheld equipment manufacturers as well. There are,
however, some unique facets of the handheld manufacturers distribution
networks that have not been previously addressed. The major difference is
that the handheld manufacturers all make their own engines. This changes the
mixture of raw materials and components they purchase as well as their
manufacturing and design processes. A separate engine market would not
suffice for handheld manufacturers because of the size, performance, and
design restrictions places on their products by the unique end-user
requirements for handheld equipment.
There are only a handful of nonhandheld equipment manufacturers
that are vertically integrated. Honda is the most important of these, producing
a broad line of premium engines and products from its North Carolina plant.
Kubota is also another example of a major manufacturer of both engines and
equipment.(2)
The Lawn and Garden Equipment Industry (SIC 3524) accounted for
0.11 percent of GDP in 1990. ... Constant dollar shipments have increased
sharply, with a 33.1 percent increase from 1984 to 1990. ... [RJoughly the
same number of companies were responsible for the increased output,
indicating that new firms entering the industry may not have been responsible
for higher output. Value added as a percent of output for the industry in 1990
was 40.9 percent, roughly the same as the internal combustion engine industry.
This industry does not seem to be capital intensive, as assets were only
18.8 percent of output in 1990, less than the corresponding percentage for All
Manufacturing Industries... In addition, capital turnover rates are 15.6 years,
slightly above the average for All Manufacturing Industries. As a result,
should regulation result in new purchases of capital, the industry may not
have as much difficulty as other industries in adapting to regulatory actions.
Concentration in this industry is high, as the 8 largest companies
control 71 percent of the market. These companies may have the ability to
influence the price of their products. Yet the industry does not seem to have
excess capacity, with a capacity utilization rate of 73 percent. This figure is
slightly less than the 76 percent rate for All Manufacturing Industries...
Because the Statistics of Income Classification code relevant to the
Farm Machinery and Equipment industry includes both 4-digit SIC codes 3523
Iff
-------
3-9
and 3524, the profitability analysis for the Farm Machinery and Equipment
industry also applies to the Lawn and Garden Equipment industry. For 1988,
profitability for this industry seemed quite good, with the average return on
equity up to 17.9 percent, a 14.1 percent increase from 1990. The average debt
to asset ratio, however, is among the higher of the seven minor industries
considered ... at 42 percent.
Constant dollar shipments are expected to grow at an annual rate of 2
percent over the next 5 years for the Lawn and Garden Equipment Industry.
The U.S. Industrial Outlook attributes this increase to several factors, first
among them are demographic changes in the LJ.S. population. In particular,
the fastest growing age group, 44-54, .vill be near their maximum earning
potential, which should result in larger expenditures on lawn and garden
equipment. The report also notes thai: many of these consumers will be more
inclined to upgrade their current properties, which may entail landscaping.
The removal of trade barriers in Mexico and Canada as a result of the North
American Free Trade Agreement (NAFTA) should give companies in the three
North American countries the opportunity to expand their exports. In
addition, the report mentions that possible environmental standards may have
an impact on sales, but the report does not give a clear indication of whether
or not these regulations will cause sales to increase or decrease.(3)
[Mjany of the eleven 4-digit SIC industries encompassing the small
nonroad engine and equipment industry are characterized by significant value
added, fairly high concentration, growth in the value of shipments, capital
intense production processes, high capital turnover, and relatively efficient
capacity utilization. These basic industry trends determine the competitive
nature of the industry and condition the interactions of the firms that form
these industries with suppliers, consumers and each other.(4)
[T|he competitive features of the small nonroad engine and equipment
industry have been reviewed. These features include: channels of product
distribution, the levels of vertical and horizontal integration across engine and
equipment manufacturers supplying the nonroad engine and equipment
industry, the types and extent of barriers to entry that may exist in this
industry, the degree of market power inherent in the nonroad engine and
equipment industry at various levels of producer interactions, the availability
and importance of substitute power sources for internal combustion engines,
the global competitive position of U.S. firms in this industry, and
characteristics of end-users which drive the demand for the various products
that are sold in the small nonroad equipment industry. Such a comprehensive
description of this industry's competitive features has revealed various
interesting results which should be summarized.
First, the level of vertical integration in the small nonroad engine and
equipment industry appears to be rather small. Where present, vertical
integration is concentrated in three areas of the industry: foreign lawn and
garden engine and equipment manufacturers, foreign recreational engine and
-------
3-10
equipment manufacturers, and handheld lawn and garden engine and
equipment manufacturers. For example, Honda produces both the engine and
equipment components of their lawn and garden products... In fact, most of
the vertically integrated companies are foreign companies.
Horizontal integration, on the other hand, is common among engine
manufacturers in the small nonroad engine and equipment industry. This
follows directly from the fact that a single engine design is often used in many
small nonroad equipment applications. ...[Tjecumseh and Briggs & Stratton
engines, for example, are employed by various types of equipment including
lawn and garden equipment, light commercial and industrial equipment, light
agricultural equipment, and others.
Second, advertising and product differentiation, economies of scale,
and large capital requirements appear to be the only forms of barriers to entry
that may characterize the small nonroad engine and equipment industry.
However, the effectiveness of these phenomena is difficult to assess.
Nevertheless, advertising plays an important role in the lawn and garden
equipment industry, as shown by its relatively high advertising intensity ratio.
Similarly, product differentiation is important in this market as evidenced by
the large number of brands and product models that are offered for different
equipment types, such as lawnmowers or chainsaws...
Economies of scale and large capital requirements, on the other hand,
are likely to be more important at the engine manufacturing level of the
industry, since this level is capital intensive and characterized by few
dominant sellers. It should also be noted that patents may play an important
role in deterring new entry as a result of Section 308 of the Clean Air Act.
Ryobi, for example, may clearly have a competitive advantage if its new 4-
stroke CleanAir Engine is protected through patent.
...[O]ne general characteristic of the industries that comprise the small
nonroad engine and equipment industry is high levels of seller concentration.
Empirically, high seller concentration has been shown to perpetuate product
pricing that is above the marginal cost of the products production.(S)
...[Rlesults that are characterized by this pricing outcome are economically
inefficient, and display the market power, of at least the market leaders, in the
industry. However, although the small nonroad engine and equipment
industry is generally characterized by seller concentration, ... the various
relationships between the economic agents operating in this industry are not
characterized by significant levels of market power. Much of the reasoning
behind this conclusion centers on the concept of contestable markets... The
fact that the small nonroad engine and equipment industry is not characterized
by market power implies that if regulatory actions increase the production
costs of the firms producing in this industry, then these incremental costs will
likely be passed on to consumers, or end-users, in the form of higher prices.
Moreover, the likelihood that market power is not prevalent in the small
nonroad engine and equipment industry implies that economic profits are not
being accrued in the long run. This in turn suggests that entry into the market
-------
3-11
is relatively free. Although some aspects of barriers to entry may exist (such
as product differentiation, advertising, and economies of scale), their
effectiveness at deterring entry is not necessarily evident.
Fourth, the prevalence of substitute power sources and equipment that
displace equipment powered by internal combustion engines is most evident
in the lawn and garden equipment market where electrically powered
machines have been common for many years. However, the sale of electrified
lawn and garden equipment is hampered by various factors. For example, the
long extension cords necessary for the operation of electrified equipment are
cumbersome, while electrified lawn and garden equipment are generally not a
viable option for commercial users. However, use of battery packs could
potentially resolve some of the detrimental user oriented extemalitites
associated with electrically powered lawn and garden equipment.(6)
3.1. Aggregate Cost Analysis
This section presents the methodology used to estimate and the
numerical estimates of the aggregate costs due to this regulation.
Variable hardware costs, marginal production costs, development costs,
and administrative costs of compliance are presented in this section.
This section also presents the costs to the consumer, including estimates
of the increased profits to economic entities in the various levels of
industry, including the engine manufacturer, equipment manufacturer,
and mass merchandiser. Cost savings due to reduced fuel consumption
are also addressed, including the valuation of the reduced fuel
consumption to the consumer.
3.1.1. Profitability on Increased Costs
The aggregate cost estimates presented in this chapter take into
account the potential for price increases beyond a cost increase, in other
words, profit on increased costs is accounted for. As costs increase,
manufacturers and retailers must pass along cost increases and markups
over cost in order to maintain current percentage levels of profitability
that are seen in the market. Manufacturers have indicated differing
points of view on whether the total cost increases, including margins for
profitability, due to pollution control regulation will be passed on to
13(1
-------
3-12
other manufacturers, merchandisers, and consumers.
One point of view is that all costs will be successfully passed
through to consumers with a margin for profitability for each type of
cost. It has been argued that profitability margins are already very low
implying that no further reduction in profitability margin could be
tolerated without severe economic impacts. Further, manufacturers who
support this view indicate that the market is so competitive that all
manufacturers will seek the low cost solution to compliance, that this
solution will be the same for all manufacturers of similar engines and
equipment in particular market niches, and that all manufacturers will
pass through cost increases that do not differ significantly among
manufacturers.
EPA decided the market structure merited analyzing costs according
to the following: evidence suggests that all pollution control costs can
be passed through each level of the industry (e.g., engine manufacturer,
equipment manufacturer, and mass merchandiser). These costs are to
be imposed on consumer goods, i.e., small nonroad engines, and thus
primarily displace future personal consumption expenditures. When
regulatory costs displace a stream of consumption expenditures, the
Kolb-Scheraga two-stage discounting procedure is appropriate to utilize
to value the stream of benefits and costs to society over time. The Kolb-
Scheraga two-stage discounting procedure and its appropriateness in
this scenario is explained in more detail later in this chapter.
Profitability estimates are difficult to determine. Due to time
constraints which limited further data collection efforts, EPA assumed
that profitability estimates would be approximately equal to the return
on sales for each level of the industry. Additionally, EPA had readily
available annual reports for Briggs & Stratton Corporation and for Toro
Company and used these to derive estimates for return on sales in the
industry. For this analysis, EPA is assuming the average return on sales
-------
3-13
for Briggs & Stratton Corporation for the years 1991, 1992, and 1993 as
the average profitability of producing engines for engine manufacturers.
Therefore, the profitability on engine manufacturer cost increases is
assumed to be 16%. For equipment manufacturers, EPA did not have
annual reports, except for Toro. Because Toro markets mainly to the
mid-range to premium segments of the market, EPA didn't use Toro's
gross profit percentage as Toro must recover a high percentage over cost
of goods sold in order to cover high selling, general, and administrative
expenses. Operating profit for Toro might be closer to the profit levels
achieved by the high volume low-end equipment manufacturers because
these high volume manufacturers should have low selling, general, and
administrative expenses. Operating profit for Toro Company ranged
from approximately 4-7% for 1989-1991. Therefore, for the majority of
the market that represents the low end equipment, EPA assumed a 5%
return on sales. EPA did not have income statements for mass
merchandisers or dealers of equipment at the time this analysis was
prepared: the dealer return on sales was assumed to be 5%. In
cumulative terms, this amounts to an increase in price of approximately
26% from the engine manufacturer to the consumer. This markup is
approximately equal to the markup (usually called a "retail price
equivalent" (RPE) markup) EPA typically uses in regulatory analyses of
on-highway emission standards. Jack Faucettt Associates has published
a report(7) under contract to EPA which lists 26% as the estimated RPE
for on-highway cars and light-duty trucks, 27% for on-highway heavy-
duty gasoline engines, and 36% for on-highway heavy-duty diesel
engines.
A second point of view is that only the variable hardware costs will
be passed through to the consumer. Some manufacturers have
indicated to EPA that buyer power of the mass merchandisers is so
great for the majority of these engines and equipment that they will
-------
3-14
have difficulty raising prices at all. Proponents of this point of view
argue that perhaps variable hardware cost will be passed through with
a profit margin, but that other costs would not be passed through. This
argument does not seem very supportable because potential increases
are small in absolute terms and it is in the interest of merchandisers/
dealers to ensure a continuous high degree of competition in the market,
particularly at the opening price point. If all manufacturers' costs
increase by approximately the same amount due to the increase in
marginal cost, each manufacturer can proceed to charge a price that
fully recovers costs plus markup under the (reasonable) assumption that
other manufacturers are doing the same thing.8 Therefore, EPA did not
estimate costs assuming that only a portion of the costs would be
passed through.
The remainder of this chapter presents costs which include the
markup on manufacturers' and retailers' costs to the consumer.
3.1.2. Variable Hardware Costs
Variable hardware costs are the costs for hardware changes made to
engines and equipment in order to comply with new emission
standards. Hardware costs are variable because they depend on
production volumes.
3.1.2.1. Per-Engine Variable Hardware Costs For Each Emission
Standard Category--EPA has developed a weighted average variable
hardware cost estimate for each standard category. These estimates are
8 The model of perfect competition shows that manufacturers in a perfectly competitive
environment experience zero economic profits in the long term. Models of monopolistic
competition, which is the market structure for these engines and equipment, also show that in the
long term, zero economic profits exist. Therefore, attempts by manufacturers to capture market
share by shaving profit margins will likely lead to negative economic profits in the long term.
Negative economic profits generally are not sustainable for a company. .
I Cr- I
-------
3-15
presented in Chapter 2 with the methodology used to derive the
estimates. It should be emphasized that these estimates are
representative of the relative variable hardware cost increase for the
market as a whole. They do not represent the potential increase in
variable hardware cost for specific engine or equipment models.
Neither are they intended to imply that all engines and equipment in a
particular emission standard category will increase in price by the stated
amount, no less and no more. The price of specific engines and
equipment is set by the market, and is reflective of the competitive
structure of the market. Production volume per manufacturer, in
particular, will play an essential role in what the increase in market
price will be. However, production volume will have a larger cost
minimization effect for marginal production costs than for variable
hardware costs.
Table 3-01 presents a summary of the increased variable hardware
cost estimates for both engine and equipment manufacturers.
Table 3-01
Best Estimate Technology
Per-Engine and Per-Equipment
Sales-Weighted Average Variable Hardware Cost
Per Emission Standard Category
Engine
Equipment
Total
Customer
Price
Emission Standard Categories
I
$1.82
$0.10
$1.92
$2.40
II
$0.65
$1.00
$1.65
$1.92
III
$1.69
$1.20
$2.89
$3.45
IV
$1.92
$1.20
$3.12
$3.74
V
$2.37
$1.20
$3.57
$4.31
Note: Class I has a delayed implementation for 2-strokes to meet the nhh standard.
The cost from model year 1997 to 2002 is $0.73. The $1.82 per engine is the cost in
2003.
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3-16
Under the catalyst option, the sales-weighted average variable
hardware costs would be greater, as presented in Table 3-02
Table 3-02
Catalyst Option
Per-Engine and Per-Equipment
Sales-Weighted Average Variable Hardware Cost
Per Emission Standard Category
Engine
Equipment
Total
Customer Price
Emission Standard Categories
1
$3.14
$0.13
$3.27
$4.10
II
$0.65
$1.00
$1.65
$1.92
III
$1.72
$1.30
$3.02
$3.60
IV
$1.95
$1.30
$3.25
$3.89
V
$2.40
$1.30
$3.70
$4.45
Table 3-03 presents the estimates of the non-handheld and handheld
sales-weighted av€'rage variable hardware cost. These estimates are
reflective of the relative variable hardware cost increase to all handheld
equipment and non-handheld equipment. Therefore, the following
estimates characterize the cost increases to each type of equipment in
relation to the emission standard category with the highest volume
sales.
Table 3-03
Sales-Weighted Average Variable Hardware Cost
for Nonhandheld and Handheld Equipment
Best Estimate
Technology
Catalyst Option
Nonhandheld
$2.29
$3.60
Handheld
$3.75
$3.90
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3-17
3.1.2.2. Aggregate Annual Variable Hardware Cost--The annual
variable hardware cost is calculated according to the following formula.
v SALES
Ł(
77 TOTALSALES
where
i emission standard category, (i.e.: I, n, III, IV, or
V)
SALESj annual sales in the emission standard category
TOTALSALES total annual sales
VHCj variable hardware cost estimate to the consumer
in the emission standard category.
In the first year of implementation of this regulation, 1996, the total
variable hardware cost increase, including the manufacturers' and
retailer's markup is presented in the Table 3-04. The table presents two
separate results: the catalyst option estimates are not additive to the
best estimate technology cost estimate.
Itf
-------
3-18
Table 3-04
2003 Total Annual
Variable Hardware Cost Increase
to the Consumer
Emission
Standard
Category
1
II
III
IV .
V
TOTAL
Smillions
(1993$)
Best
Estimate
Technology
7.7
4.4
1.7
22.5
1.6
49.6
Catalyst
Option
32.2
4.4
1.8
23.8
1.7
64.0
3.1.3. Production Costs
Production costs are the costs for changes made to production line
equipment in order to produce engines which comply with new
emission standards. Examples of production costs are costs for changes
in dies 'or tooling. Refer to section 2.2 for a detailed discussion of the
underlying changes to production line equipment and methodology
used to arrive at the following production cost estimates for the
emission standard categories.
3.1.3.1. Per-Englne Production Costs For Each Emission Standard
Category-EPA has developed a sales-weighted average production cost
increase estimate for each emission standard category. These estimates
are presented in Chapter 2 with the methodology used to derive the
estimates. Production cost increase estimates are based on a set of
assumptions, as outlined in Chapter 2, relating to optimum production
volume output on a production line. Manufacturers who do operate
their production lines at optimum output may not be able to achieve the
-------
3-19
economies of scale that other manufacturers can achieve. These possible
effects were not analyzed. Therefore, the following per-engine
production cost estimates assume optimum capacity utilization in the
industry.
Table 3-05 presents a summary of the increased production cost
estimates for both engine and equipment manufacturers.
Table 3-05
Best Estimate Technology
Per-Engine and Per-Equipment
Sales-Weighted Average Production Cost
Per Emission Standard Category
Engine
Equipment
Total
Customer Price
Emission Standard Categories
1
$0.50
$0.00
$0.50
$0.63
II
$0.16
$0.00
$0.16
$0.20
III
$0.40
$0.04
$0.44
$0.55
IV
$0.25
$0.04
$0.29
$0.36
V
$0.39
$0.04
$0.43
$0.54
Under the catalyst option, the sales-weighted average production
cost increase would be greater, as presented in Table 3-06.
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3-20
Table 3-06
Catalyst Option
Per-Engine and Per-Equipment
Sales-Weighted Average Production Cost
Per Emission Standard Category
Engine
Equipment
Total
Customer Price
Emission Standard Categories
1
$0.50
$0.03
$0.53
$0.66
II
$0.16
$0.00
$0.16
$0.20
III
$0.40
$0.14
$0.54
$0.66
IV
$0.25
$0.14
$0.39
$0.47
V
$0.39
$0.14
$0.53
$0.65
Table 3-07 presents the estimates of the non-handheld and handheld
sales-weighted average production cost increase. These estimates are
reflective of the relative cost increase to all handheld equipment and
non-handheld equipment. Therefore, the following estimates
characterize the cost increases to each type of equipment in relation to
the emission standard category with the highest volume sales.
Table 3-07
Sales-Weighted Average Production Cost
for Nonhandheld and Handheld Equipment
Best Estimate
Technology
Catalyst Option
Nonhandheld
$0.53
$0.56
Handheld
$0.38
$0.49
3.1.3.2. Aggregate Annual Production Cost lncrease~The annual
production cost increase is calculated according to the following
formula.
I36
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3-21
where
SALES,
TOTALSALES
PC,
r SALESt
77 TOTALSALES '
emission standard category, (i.e.: I, II, III, IV, or
V)
annual sales in the emission standard category
total annual sales
production cost increase estimate to the
consumer in the emission standard category
In the first year of implementation of this regulation, 1996, the total
production cost increase, including the manufacturers' and retailer's
markup is presented in the Table 3-08. The table presents two separate
results: the catalyst option estimates are not additive to the best
estimate technology estimate.
Table 3-08
2003 Total Annual Production
Cost Increase to the Consumer
Emission
Standard
Category
1
II
III
IV
V
TOTAL
(millions
(1993$)
Best
Estimate
Technology
4.9
0.5
0.3
2.2
0.2
8.1
Catalyst
Option
5.2
0.5
0.3
2.9
0.2
9.2
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3-22
3.1.4. Increase in Capital Costs
Potential capital cost increases include costs for development and
application of engine designs with reduced emissions and costs for test
facilities.
EPA has not accounted for any costs due to construction of test
facilities because the California emission regulation applicable to these
engines will in effect require the manufacturers to have more testing
capability than will be necessary for California alone. The excess test
capability will suffice for testing applicable to the Federal requirements.
EPA has included an estimate of increased costs for development
and application of engine designs with reduced emissions. Chapter 2
explains the rationale behind the development cost estimate and the
methodology used to estimate those costs. EPA has estimated the total
development costs to be approximately $10 million for Class I, $10
million for Class II, and $5 million for Classes III, IV, and V. These
costs were amortized and discounted over 5 years at a discount rate of
0.07. Then the annualized costs were discounted at a rate of 0.03 (the
consumption rate of interest) to their future value in the year of
recovery, 1996 through the year 2000. These discount rates vvere
applied according to the Kolb-Scheraga two-stage discounting
procedure. This procedure is further explained in the cost summary
section later in this chapter.
Table 3-09 presents the estimate of the amortized and discounted
capital costs for development and application of emission reduction
technology in the year 1996. There are no additional development costs
for the catalyst option.
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3-23
Table 3-09
Amortized and Discounted Development Cost
in 1996
Emission Standard
Class
I
II
III, IV, & V
TOTAL
Smillions
(1996$)
2.6
2.6
1.3
6.5
3.1.5. Program Administration Costs
The program administration costs presented here are the costs
industry is estimated to incur due to the enforcement programs:
certification, selective enforcement auditing, importation of
nonconforming engines, precertification and testing exemption, engine
exclusion determination, and emission defect reporting.
Appendix D contains the supporting statements for the Information
Collection Requests submitted to OMB. These supporting statements
contain estimates of the testing, recordkeeping, and reporting burden on
industry due to the final regulations! In total, EPA estimates the
regulations will cause a burden of $22 million for the initial year of
regulation, with a large portion of this cost due to set up of the
certification recordkeeping systems for manufacturers. EPA estimates
the annual cost to be $10 million for the years following the initial year
of implementation. Please refer to the supporting statements in
Appendix D for additional information specific to each enforcement
program.
3.1.6. Fuel Savings
As explained in Chapter 2, the technological changes necessary to
bring these engines into compliance with the emission standards will
-------
3-24
cause a decrease in fuel consumption of approximately 26% for a non-
handheld engine and 13% for a handheld engine. Over the lifetime of
these equipment, this amounts to a sales-weighted discounted lifetime
fuel savings of $1.75 for non-handheld equipment and $0.13 for
handheld equipment using a discount rate of 0.03. Table 3-10 presents
the aggregate fuel consumption estimates for the 30 year time horizon of
this analysis. EPA assumed that there are 42 gallons of gasoline per
barrel of oil. The value of gasoline is assumed to be $ 1.25 per gallon in
1993 dollars.
-------
3-25
Table 3-10
Aggregate Fuel Consumption Reduction Estimates
YEAR
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
BASELINE
TONS
6805133
6958270
7100274
7237739
7374688
7508215
7638768
7767294
7894824
8022001
8147267
8270911
8393422
8515276
8636877
8752849
8863775
8971064
9076218
9180279
9283735
9386836
9489767
9592546
9695280
9777433
9840976
9890929
9932905
9970735
10006270
CONTROLLE
D
TONS
6534027
6442717
6400425
6416960
6475446
6552609
6639113
6731905
6829702
6931590
7035079
7139626
7245039
7351304
7458404
7561225
7660094
7756119
7850512
7944111
8037295
8130265
8223135
8315939
8408705
8482989
8540558
8.585868
8623954
8658197
8690339
REDUCTION
TONS
(271,106)
(515,553)
(699,849)
(820,779)
(899,242)
• (955,606)
(999,655)
(1,035,389)
(1,065,122)
(1,090,411)
(1,112,188)
(1,131,285)
(1,148,383)
(1,163,972)
(1,178,473)
(1,191,624)
(1,203,681)
(1,214,945)
(1,225,706)
(1,236,168)
(1,246,440)
(1,256,571)
(1,266,632)
(1,276,607)
(1,286,575)
(1,294,444)
(1,300,418)
(1,305,061)
(1,308,951)
(1,312,538)
(1,315,931)
REDUCTION
GALLONS
(1,725,680)
(3,281,666;
(4,454,771)
(5,224,531)
(5,723,974)
(6,082,749)
(6,363,136)
(6,590,595)
(6,779,855)
(6,940,828)
(7,079,446)
(7,201,004)
(7,309,839)
(7,409,068)
(7,501,372)
(7,585,082)
(7,661,829)
(7,733,528)
(7,802,025)
(7,868,620)
(7,934,004)
(7,998,491)
(8,062,533)
(8,126,027)
(8,189,477)
(8,239,566)
(8,277,592)
(8,307,146)
(8,331,907)
(8,354,740)
(8,376,338)
REDUCTION
BARRELS
(41,088)
(78,135)
(106,066)
(124,394)
(136,285)
(144,827)
(151,503)
(156,919)
(161,425)
(165,258)
(168,558)
(171,452)
(174,044)
(176,406)
(178,604)
(180,597)
(182,425)
(184,132)
(185,763)
(187,348)
(188,905)
(190,440)
(191,965)
(193,477)
(194,988)
(196,180)
(197,086)
(197,789)
(198,379)
(198,922)
(199,437)
-------
3-26
3.1.7. Consumer Cost
As explained in the beginning of this chapter, full cost pass through
and profitability on increased costs are assumed. Table 3-11
summarizes the assumed profitability factors, sometimes referred to as
retail price equivalent factors, which were used in this analysis to
estimate the price increase to the consumer.
Table 3-11
Profitability Factors
(Retail Price Equivalent Factors)
Level
Engine Manufacturer
Equipment Manufacturer
Mass Merchandiser
Approximate Total Percent Increase
Factor
0.16
0.05
0.05
0.26
These factors were applied to the specific engine and equipment
manufacturer costs identified in Chapter 2. For example, EPA has
estimated some variable hardware costs and production costs specific to
engines and specific to equipment. For equipment specific costs, EPA
marked up the cost 10%. The cost of the engines to the equipment
manufacturer was assumed to include a 16% markup on the engine
manufacturer's costs. However, equipment manufacturer costs were not
marked up 16% for equipment design changes which the equipment
manufacturer incurs due to changes in the engine design.
Table 3-12 presents the increased per-unit costs of equipment with
profitability factors applied. The estimates for variable hardware costs
and production costs include costs to the engine and the equipment
manufacturer. The capital cost and program administration costs are
costs the engine manufacturer incurs and passes through the production
chain.
-------
3-27
Table 3-12
Specific Per-Unit Equipment Costs
With Profitability Markup
Per-Unit
Cost Categories
Variable Hardware Cost
Production Cost
Capital Cost
Administration Cost
TOTAL
Equipment
Non-Handheld
$2.29
0.53
0.59
1.80
$5.22
Handheld
$3.75
0.38
0.72
1.80
$6.66
Fuel cost savings to the consumer over the lifetime of these
equipment will substantially offset the increased price of nonhandheld
equipment but will only slightly offset the price of handheld equipment.
The lifetime consumer cost increase, including the discounted fuel
savings, for nonhandheld equipment is $2.43 and for handheld
equipment is $6.44. These fuel savings, even in the case of nonhandheld
equipment, will probably not affect consumer purchase decisions
because of their small magnitude. However, the smali magnitude of the
price increase, excluding the fuel savings, should not lead to any
significant decreases in consumption (sales) of these engines in the U.S.
The above prices increases are most applicable to the lowest priced
equipment, which is the high sales volume equipment. For non-
handheld equipment, the percent increase would be $5.22/$100=0.05
and for handheld equipment $6.66/$69=0.10. Such small price increases
should not alter consumer purchase decisions. Particularly for
lawnmowers, people use the equipment until it does not start, then they
simply replace it with new equipment. Few people tune up or rebuild
their engines, except in the higher priced lawnmower and garden tractor
equipment. For these higher priced equipment, the price increase due
131
-------
3-28
to regulation will be less than that indicated here because the
technological changes necessary to comply with the emission standards
will only require calibration changes, which may not affect the price of
such equipment. For the low priced equipment, the price increases
noted here are less than the typical cost of a tune-up or a rebuild on
these engines. Tune-ups cost about $20, while engine rebuilds cost
about $40. These alternatives to buying a new engine are rather
expensive compared to the cost of new equipment and are time
consuming. As the price of new equipment, including the price increase
due to regulation, is only two to three times as much as the
maintenance alternatives, it is unlikely that consumers will change their
buying patterns. However, if in the long run engines are more durable
due to regulation and require less maintenance, there may be an effect
on sales. EPA is not able to verify or refute whether engines will be
more durable or require less maintenance at this time. Therefore, no
decrease in sales due to regulation has been assumed.
3.1.8. Cost Summary
This section summarizes the total industry increase in cost, total
retail price increase in cost, and the fuel savings accounted for over the
30 year time horizon of this analysis. EPA has analyzed the costs in the
years in which they occur and the costs in the years in which they are
recovered by retail price increases. Further, EPA has evaluated the
stream of costs over time. Tables 3-13 through 3-17 are located at the
end of this chapter.
3.1.8.1. Accounting for Costs as They are Incurred-Manufacturers
incur some costs years ahead of when the costs are recovered by sales.
Manufacturers must allow time to design, test, evaluate, certify, and
produce the engine before sale. Typically, design work occurs in the
-------
3-29
year before recalibration work. The following year certification is
undertaken. Production begins the year after certification.
Table 3-13 shows these costs as they were accounted for in EPA's
best estimate technology cost analysis and Table 3-14 presents these
costs for the catalyst option.
3.1.8.2. Accounting for Costs as They are Recovered-EPA assumes
that costs which occur in years preceding production are recovered over
sales throughout the production cycle. For instance, EPA assumes the
annualized design cost for 1993 is recovered on the 1996 sales.
Similarly, annualized design costs occurring in 1994 are recovered on
the 1997 sales. Therefore, the methodology attributes the first year of
amortized costs to the first year of sales, the second year of amortized
costs to the second year of sales, et cetera. These costs are shown in the
year of recovery in future value9.
Table 3-15 and 3-16 shows the total costs which are recovered in
each sales year through 2026 for the best estimate technology analysis
and the catalyst option analysis, respectively.
3.1.8.3. Evaluation of the Stream of Costs-In accounting for the "time
value" of money, the stream of costs estimated to be recovered in
future sales must be converted to the present value10 of the yearly costs.
The present value of the costs as recovered is stated in Table 3-17 in
1993 dollars. The methodology used to determine the present value is
calculated according to recent Agency guidance (i.e., the Kolb-Scheraga
Q
Future value means the value at a future date of money that has been paid or received in prior
periods.
10
received in future periods.
Present value means the value of money today of a stream of amounts expected to be paid or
Itf
-------
3-30
two-stage procedure).(8) Kolb-Scheraga point out that the economics
literature has established the social rate of time preference as the
appropriate rate for discounting the benefits and costs of public projects,
once they are expressed in terms of consumption gained and foregone,
and provide a procedure for doing this. According to this methodology,
capital costs are amortized at a rate reflecting the marginal rate of return
on private investment (7 percent). Annualized capital costs are then
added to operating costs (e.g., variable hardware costs, administrative
costs) to yield the stream of additional revenues that must be collected
through price increases to pay for all costs imposed by a regulation.
The total cost stream is then discounted to present value at 3 percent, an
estimate of the consumption rate of interest (a proxy for the social rate
of time preference). This methodology is appropriate in this case
because capital costs imposed by this Small Gas FRM are likely to be
passed directly through to consumers in the form of higher prices and
thus reduce the consumption of goods and services. This methodology
is more appropriate in this instance than simply discounting all costs at
7 percent because the capital stock is not permanently lowered. Thus,
the two-stage procedure accounts for both displaced private investment
(in the annualization process) and foregone consumption (by
discounting both costs and benefits by the social rate of time
preference).
Table 3-17 presents the total annualized stream of costs and the
present value stream of the total annualized costs. The net present
value of the stream of increased costs over the 30 year time horizon of
this analysis is $1,093 million for the best estimate technology analysis
and $1,445 million for the catalyst option analysis. The total national
average annual cost of this rule is estimated to be $55 million. Under
the catalyst option, the total national average annual cost estimate
becomes $73 million.
-------
3-31
3.2. Incremental Economic impacts
3.2.1. Capital
Impacts on capital as a result of this rule are the result of increased
investment by manufacturers in order to make their engines comply.
These costs become part of the cost of manufacturing nonroad engines/
equipment and are recaptured in price increases. As a result, private
capital investment is unlikely to be displaced. All expenditures related
to this rule can be expected to be borne from consumer savings or
consumer credit markets, not from private capital markets. EPA
estimates the net present value of capital costs to be approximately $27
million over the 30 year time horizon of this analysis or approximately
an average annual cost of $6.5 million for the years 1996 through 2000.
3.2.2. Employment
EPA estimates that there will be no negative impacts on employment
as a result of this rule. It is possible that in time jobs will be created by
the need to hire engineers, technicians, and machinists to develop and
implement technological solutions for reducing emissions from these
engines. The engineering staffs the manufacturers currently employ are
relatively small. However, manufacturers have indicated to EPA that
they do not currently plan on hiring new engineers, technicians, and
machinists to fill high wage, technical jobs in order to meet production
demands.
EPA examined the possibility that employment may be decreased by
manufacturers' abandoning product lines for which emissions are too
costly to reduce. The low absolute levels of costs added to nonroad
engines/equipment due to this regulation's effect on the production line
changes are too marginal to lead to the obsolescence of a product line.
Furthermore, manufacturers have indicated to EPA that obsolescence of
low volume engine models does not necessarily decrease employment
-------
3-32
because low volume engine models are produced on the same
production lines as other higher volume engine models. After a
regulation is implemented, shifts in the market between engine models
may occur, but unless total units sold decrease due to a price effect,
employment should not be affected by changes in availability of engine
models.
EPA explored the effect of this regulation on total industry demand
and concluded that demand is unlikely to be affected. First, as already
mentioned, EPA estimates that the emission standards will increase the
price of the engines to the consumer by only a few dollars. Industry
sales volume should be unaffected by such a small price increase.
Second, even if the relative price increases between manufacturers due
to this regulation are different (e.g., $1.00 versus $4.00), a manufacturer
with only a slightly higher price will be unlikely to face dramatic
decreases in market share because of the product differentiation
characteristic of monopolistic competition. While the market is
competitive at all levels and is the most competitive at the opening price
point for these engines and the equipment which utilizes them, product
differentiation provides a range within which prices can move without
appreciably affecting demand for the product. However, for nonroad
engines/equipment affected by this rule, prices for like products are
expected to increase by the same amount. Thus, significant decreases in
sales are not projected.
3.3 Energy
Reduced energy consumption will be the result of the FRM.
Resultant increases in fuel economy of these engines mean demand for
energy will decrease marginally in the U.S. EPA estimates this decrease
to be approximately 0.2 million barrels of oil per year. The resultant
impact on the U.S. balance of trade is approximately $9 million.
-------
3-33
Table 3-13
Best Estimate Technology Costs as Incurred
(1993$)
Year
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
Variable
Hardware
Cost
25000000
25000000
26000000
26000000
26000000
27000000
27000000
28000000
28000000
28000000
29000000
29000000
30000000
30000000
30000000
31000000
31000000
31000000
32000000
32000000
32000000
32000000
33000000
33000000
33000000
Production
Cost
10000000
10000000
11000000
11000000
11000000
11000000
11000000
12000000
12000000
12000000
12000000
12000000
12000000
12000000
13000000
13000000
13000000
13000000
13000000
13000000
13000000
14000000
14000000
14000000
14000000
Capital
Cost
1000000
6000000
6000000
6000000
6000000
5000000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Program
Admin.
Cost
22000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
Gasoline
Savings
-2000000
-4000000
-6000000
-7000000
-7000000
-8000000
-8000000
-8000000
-8000000
-9000000
-9000000
-9000000
-9000000
-9000000
-9000000
-9000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
Total
0
1000000
6000000
28000000
49000000
47000000
46000000
40000000
40000000
40000000
40000000
42000000
42000000
41000000
42000000
42000000
43000000
43000000
44000000
45000000
44000000
44000000
45000000
45000000
45000000
46000000
47000000
47000000
47000000
-------
3-34
Table 3-13
Best Estimate Technology Costs as Incurred
(1993$)
Year
2021
2022
2023
2024
2025
2026
Variable
Hardware
Cost
34000000
34000000
34000000
34000000
34000000
34000000
Production
Cost
14000000
14000000
14000000
14000000
14000000
14000000
Capital
Cost
0
0
0
0
0
0
Program
Admin.
Cost
10000000
10000000
10000000
10000000
10000000
10000000
Gasoline
Savings
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
Total
43COOOOO
48000000
48000000
48000000
48000000
48000000
-------
3-35
Table 3-14
Catalyst Option Costs as Incurred
(1993$)
Year
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Variable
Hardware
Cost
39000000
39000000
40000000
41000000
41000000
42000000
42000000
43000000
44000000
44000000
45000000
45000000
46000000
47000000
47000000
48000000
48000000
49000000
49000000
50000000
50000000
51000000
51000000
52000000
52000000
52000000
Production
Cost
10000000
10000000
11000000
11000000
11000000
11000000
11000000
12000000
12000000
12000000
12000000
12000000
12000000
12000000
13000000
13000000
13000000
13000000
13000000
13000000
13000000
14000000
14000000
14000000
14000000
14000000
Capital
Cost
1000000
6000000
6000000
6000000
6000000
5000000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Program
Admin.
Cost
22000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
10000000
Gasoline
Savings
-2000000
-4000000
-6000000
-7000000
-7000000
-8000000
-8000000
-8000000
-8000000
-9000000
-9000000
-9000000
-9000000
-9000000
-9000000
-9000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
-10000000
Total
1000000
6000000
28000000
63000000
61000000
60000000
55000000
55000000
55000000
55000000
57000000
58000000
57000000
58000000
58000000
59000000
60000000
61000000
62000000
61000000
62000000
62000000
63000000
63000000
65000000
65000000
66000000
66000000
66000000
-------
3-36
Table 3-14
Catalyst Option Costs as Incurred
(1993$)
Year
2022
2023
2024
2025
2026
Variable
Hardware
Cost
52000000
53000000
53000000
53000000
53000000
Production
Cost
14000000
14000000
14000000
14000000
14000000
Capital
Cost
0
0
0
0
0
Program
Admin.
Cost
10000000
10000000
10000000
10000000
10000000
Gasoline
Savings
-10000000
-10000000
-10000000
-10000000
-10000000
Total
66000000
67000000
67000000
67000000
67000000
-------
3-37
Table 3-15
Best Estimate Technology Costs as Recovered
(1993$)
Year
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Variable
Hardware
Cost
$25,000,000
$25,000,000
$26,000,000
$26,000,000
$26,000,000
$27,000,000
$27,000,000
$28,000,000
$28,000,000
$28,000,000
$29,000,000
$29,000,000
$30,000,000
$30,000,000
$30,000,000
$31,000,000
$31,000,000
$31,000,000
$32,000,000
$32,000,000
$32,000,000
$32,000,000
$33,000,000
$33,000,000
$33,000,000
$34,000,000
$34,000,000
$34,000,000
$34,000,000
$34,000,000
$34,000,000
Production
Cost
$8,000,000
$8,000,000
$8,000,000
$8,000,000
$9,000,000
$9,000,000
$9,000,000
$9,000,000
$9,000,000
$9,000,000
$9,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
Capital
Cost
$1,000,000
$8,000,000
$8,000,000
$8,000,000
$8,000,000
$7,000,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
.$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
• $0
$0
$0
$0
Program
Admin.
Cost
$29,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
Gasoline
Savings
($2,000,000)
($4,000,000)
($6,000,000)
($7,000,000)
($7,000,000)
($8,000,000)
($8,000,000)
($8,000,000)
($8,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
Total
$63,000,000
$54,000,000
$55,000,000
$55,000,000
$56,000,000
$56,000,000
$49,000,000
$50,000,000
$50,000,000
$50,000,000
$51 ,000,000
$52,000,000
$53,000,000
$53,000,000
$53,000,000
$54,000,000
$54,000,000
$54,000,000
$55,000,000
$55,000,000
$55,000,000
$56,000,000
$57,000,000
$57,000,000
$57,000,000
$58,000,000
$58,000,000
$58,000,000
$58,000,000
$58,000,000
$58,000,000
-------
3-38
Table 3-16
Catalyst Option Costs as Recovered
(1993$)
Year
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Variable
Hardware
Cost
$39,000,000
$39,000,000
$40,000,000
$41,000,000
$41,000,000
$42,000,000
$42,000,000
$43,000,000
$44,000,000
$44,000,000
$45,000,000
$45,000,000
$46,000,000
$47,000,000
$47,000,000
$48,000,000
$48,000,000
$49,000,000
$49,000,000
$50,000,000
$50,000,000
$51,000,000
$51,000,000
$52,000,000
$52,000,000
$52,000,000
$52,000,000
$53,000,000
$53,000,000
$53,000,000
$53,000,000
Production
Cost
$9,000,000
$9,000,000
$9,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$10,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$11,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
$12,000,000
Capital
Cost
$1,000,000
$8,000,000
$8,000,000
$8,000,000
$8,000,000
$7,000,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
Program
Admin.
Cost
$29,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
$13,000,000
Gasoline
Savings
($2,000,000)
($4,000,000)
($6,000,000)
($7,000,000)
($7,000,000)
($8,000,000)
($8,000,000)
($8,000,000)
($8,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($9,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
($10,000,000)
Total
$78,000,000
$69,000,000
$70,000,000
$72,000,000
$72,000,000
$72,000,000
$65,000,000
$66,000,000
$67,000,000
$67,000,000
$69,000,000
$69,000,000
$70,000,000
$71,000,000
$71,000,000
$72,000,000
$72,000,000
$73,000,000
$74,000,000
$75,000,000
$75,000,000
$76,000,000
$76,000,000
$77,000,000
$77,000,000
$77,000,000
$77,000,000
$78,000,000
$78,000,000
$78,000,000
$78,000,000
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3-39
Table 3-17
Annualized Costs and Corresponding Present Value
Year
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
Best Estimate Technology
Annualized
$64,000,000
$57,000,000
$58,000,000
$58,000,000
$59,000,000
$58,000,000
$52,000,000
$52,000,000
$53,000,000
$53,000,000
$54,000,000
$54,000,000
$55,000,000
$55,000,000
$56,000,000
$56,000,000
$57,000,000
$57,000,000
$57,000,000
$58,000,000
$58,000,000
$59,000,000
$59,000,000
$59,000,000
$60,000,000
$60,000,000
$60,000,000
$60,000,000
$60,000,000
$61,000,000
$61,000,000
Discounted
$58,000,000
$50,000,000
$49,000,000
$48,000,000
$47,000,000
$45,000,000
$39,000,000
$38,000,000
$38,000,000
$37,000,000
$36,000,000
$35,000,000
$35,000,000
$34,000,000
$33,000,000
$32,000,000
$32,000,000
$31,000,000
$30,000,000
$30,000,000
$29,000,000
$29,000,000
$28,000,000
$27,000,000
$27,000,000
$26,000,000
$25,000,000
$24,000,000
$24,000,000
$23,000,000
$23,000,000
Catalyst oOoption
Annualized
$76,000,000
$70,000,000
$70,000,000
$71,000,000
$72,000,000
$71,000,000
$65,000,000
$66,000,000
$66,000,000
$67,000,000
$68,000,000
$69,000,000
$69,000,000
$70,000,000
$71,000,000
$71,000,000
$72,000,000
$72,000,000
$73,000,000
$73,000,000
$74,000,000
$75,000,000
$75,000,000
$76,000,000
$76,000,000
$77,000,000
$77,000,000
$77,000,000
$77,000,000
$77,000,000
$77,000,000
Discounted
$69,000,000
$61,000,000
$59,000,000
$59,000,000
$58,000,000
$55,000,000
$49,000,000 '
$48,000,000
$47,000,000
$46,000,000
$46,000,000
$45,000,000
$44,000,000
$43,000,000
$42,000,000
$41,000,000
$40,000,000
$39,000,000
$39,000,000
$38,000,000
$37,000,000
$36,000,000
$35,000,000
$35,000,000
$34,000,000
$33,000,000
$32,000,000
$31,000,000
$30,000,000
$29,000,000
$29,000,000
-------
3-40
-------
Chapter3: References
i.
5.
6.
Jack Faucett Associates, Small Nonroad Engine and Equipment Industry
Study, JACKFAU-92-413-14, December 1992
2.
ibid, pages 68-76.
3.
ibid., page 57-58.
4.
ibid., p. 67.
Curry, B., George, K.D., Industrial Concentration: A Survey, The
Journal of Industrial Economics, March 1983.
Jack Faucett Associates, Small Nonroad Engine and Equipment Study,
JACKFAU-92-413-14, p. 123-126.
7.
Jack Faucett Associates, Update of EPA's Motor Vehicle Emission Control
Equipment Retail Price Equivalent (RPE) Calculation Formula (JACKFAU-
85-322-3J, September 1985.
8.
U.S. Environmental Protection Agency, Office of Policy, Planning, and
Evaluation, Guidelines for Performing Regulatory Impact Analyses, Appendix
C, EPA-230-01-84-003, March 1991, Washington, DC.
3-41
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3-42
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Chapter 4: Environmental Benefit
This chapter presents the methodology used by EPA to quantify the
emission reduction benefits that will be realized through the adopted
HC, CO, and NOX emission standards for small SI engines. Benefits, in
terms of HC and CO emission reductions and NOX increments , are
presented in two forms: per-engine benefits and aggregate source
benefits. "Per-engine" benefits are the emission reductions expected to
occur during the life of an engine whose emissions are controlled in
response to the adopted standard. "Aggregate source" benefits are the
estimated, future nationwide emission reductions from affected engines,
for a given source i.e. equipment type. Estimated "aggregate source"
benefits illustrate the potential future effect of the standard on the
emission inventory of the source. Air quality benefits are discussed
qualitatively for all three pollutant standards.
Many of the detailed results discussed below are presented in
separate tables included in Appendix F - Supplementary Tables and
Appendix C (in-use emission factors).
4.1. Estimated Emissions Reductions
To estimate the average annual emissions per current nonroad small
SI engine, EPA used results from the Nonroad Engine and Vehicle
4-1
-------
4-2
Emission Study(l) (i.e., the nonroad study) to represent the baseline
emissions (i.e., emissions without controls). As in the study, total
emissions are calculated for each type of equipment using
In this equation,
NJ j - nationwide population of ith equipment type using
engine j
HP; j - average rated horsepower of engine j used in
equipment type i
LOAD; - ratio (%) between average operational power output
and rated power for the ith equipment type
HOURSj - average annual hours of usage for the ith equipment
type
EFj j - brake specific emission rate (kilowatts/hr) for engine
typej
MASS;,,- - annual nationwide emissions (grams) for the ith
equipment type using engine j
For the benefits analysis described here, EPA performed separate
calculations for each of 12 major equipment categories (as listed in
Appendix C, Table C-01), each one of which could be equipped with
one or more of 14 different engine types with average power ratings
displayed in Table F-01. The 'All Other Equipment Category' is a major
catch-all category which includes Shredders, Pressure Washers, etc. and
Loose Distributed Engines. Population and activity information used to
construct the Inventories relied predominately on data available in a
commercially available marketing research data base that includes most
types of nonroad equipment (2).
-------
4-3
4.1.1. Aggregate HC and CO Reductions and NOX Increment
The calculation of aggregate HC and CO reductions and NOX
increment is described in this section. The calculation takes into account
U.S consumption of these equipment types, usage , and related survival
rates as described below. Together with estimates of new and in-use
emissions from the engines that are used in the various equipment
types, EPA has derived projected nationwide annual emissions through
2020.
4.1.1.1. Sales—To estimate future emission levels, some
projection of the future population of uncontrolled and controlled
engines is needed. Because engines are introduced into the field
through sales, estimates are needed not only of sales prior to the
standard, but also of sales after the standard goes into effect. For years
between 1973 and 1992, consumption of major categories of nonroad
equipment were reported by leading industry sources. The
methodology used for sales projections made for years 1993 to 2026 is
described in Appendix B. These sales have been adjusted to exclude
those engines that are covered by California's lawn, garden, and utility
engine rule.
The results of this analysis are summarized in Table F-02 in
Appendix F, which presents figures reported by PSR and projected
estimates by type of use i.e., Residential and Commercial. However, it
should be recognized that, while national growth is measured at the
level of the economy as a whole, growth in specific areas of the country
is likely to vary from area to area in response to the specific
demographic and commercial trends in those areas. These effects
should be taken into account in estimating growth at the local level.
The rule allows for flexibility in the start date, with engines meeting
the standards phasing in during calendar years 1996 and 1997. In
/JO'
-------
4-4
calculating total emissions, therefore, 50% of the sales in 1996 were
assumed to comply with the standards. This was accounted for in 1996
sales fractions.
In addition, the rule allows 2-stroke lawnmower engines to meet
handheld rather than non-handheld standards through 2002, with the
restriction that the sales of 2-stroke lawnmower engines will be limited
in 1998 to 75% of baseline and in 1999-2002 to 50% of baseline levels.
Starting in 2003, all 2-stroke lawnmower engines will comply with non-
handheld standards. The baseline levels for each manufacturer of 2-
stroke lawnmower engines are the highest sales from either 1992, 1993,
or 1994. In the model, this was approximated by using 1994 sales across
the board.
These restrictions have been accounted for in the sales fractions of
the affected years. Tables F-03 and F-04 present sales fractions used to
determine sales before 1996 and after full implementation of the
standards starting in 2003.
4.1.1.2. Survival Probabllltles-In calculating the emission
reductions that are expected to occur during the life of an equipment,
the emissions of whose engine are controlled in response to the adopted
standard, EPA relied on the estimates of survival rates presented by
EEA to ARE (3). Table F-05 presents the parameter values theta and b of
the Weibull Cumulative distribution that was determined based on data
given in Table 3-3 of the Jack Faucett Report submitted to the EPA.
4.1.1.3. In-Servlce Population—By coupling the sales estimates
and projections given in Table F-02 with the engine survival rate
function described in F-05 and the pre- and post-control sales fractions
in Tables F-03 and F-04, EPA calculated the estimated populations from
1973 to 2026 for all equipment types as well as engine types with which
/Cfl
-------
4-5
they are equipped. In doing so, EPA distinguished between controlled
and uncontrolled engines, so that the effect of the standards could be
ascertained.
4.1.1.4. Aggregate Source Emissions Inventory-EPA projected
future annual nationwide emissions from engines addressed in this
Small Gas FRM under the baseline (no controls applied) and controlled
scenarios. This was accomplished using
MASSy. 2J (SALESj*
* >•/•"
In this equation,
y - inventory year
;' - year of sale
SALESj - engine sales in year j
Sy.j - fraction of engines sold in year;' that
survive in year y
AUrel y.j - relative annual usage in year y of engine
sold in year ;', as percent of average
annual usage over engine life
MASSav&j - average annual per-engine emissions of
engines sold in year;
EPA calculated baseline .per-equipment emissions using pre-
control/baseline emission factors from the Nonroad Study. The in-use
population estimates were generated by taking into account the pre-
control sales mix (Table F-03) and a survival function defined by
constants as displayed in Table F-06. To obtain average annual per-
equipment emissions for engines controlled to the levels required to
-------
4-6
comply with EPA's emission standards, emissions were recalculated
using post-control sales mix (Table F-04) and in-use emission factors
(Refer to Appendix C).
Table F-08 presents total annual nationwide emissions from engines
addressed in this Small Gas FRM under the baseline scenario, and Table
F-09 presents results for the controlled scenario. These are shown
graphically in Figures 4-01 to 4-03.
In Figures 4-01 to 4-03, the annual benefit of the regulation is
indicated by the difference between the upper and lower curves. The
area between the curves represents the net benefit of the regulation
during the time period 1996 to 2020. The averaged results indicate that
the adopted standard represents on average a 32%/7% reduction in
annual HC/CO emissions from engines to which the standards apply.
Figure 4-01
Projected Nationwide Annual HC Emissions -1996-2020
Nonroad SI Engines Below 19kW
WD
I
3000 2DM 2BV 3D12 SOW
-------
4-7
Figure 4-02
Projected Nationwide Annual CO Emissions - 1996-2020
Nonroad SI Engines Below 19kW
8
j "
S
1998
2DCO
ZD4
Q
2DOB
Yea-
«- VUtiQrtd
2DQ
2016
ZBD
-------
4-8
Figure 4-03
Projected Nationwide Annual NOX Emissions -1996-2020
Nonroad SI Engines Below 19kW
4.2 Air Quality Benefits
Air quality benefits associated with reduction in VOC and CO
emissions are discussed in this section. Health and welfare effects of the
pollutants as they impact on ozone formation are described. Further,
the role of CO in ambient air quality problems are discussed.
4.2.1. VOC
EPA expects that reducing VOC and CO emissions from small
nonroad spark ignition engines will help to mitigate the health and
welfare impacts of ambient HC and CO as well as urban and regional
tropospheric ozone formation and transport.
4.2.1.1. Health and Welfare Effects of VOC Emissions-VOC is the
general term used to denote volatile organic compounds, a broad class
of pollutants encompassing hundreds of specific toxic compounds,
-------
4-9
primarily Benzene and 1,3 Butadiene as well as aldehydes and gasoline
vapors. As stated previously, VOC is a criteria pollutant for which the
EPA has established a NAAQS. Measures to control VOC emissions
should reduce emissions of air toxics. However, the magnitude of
reduction will depend on whether the control technology reduces the
individual toxics in the same proportion that total VOCs are reduced.
Since nonroad engines have significant VOC impacts , thay are expected
to have significant toxics impacts as well.
At elevated concentrations, VOC, a precursor to ozone, can adversely
affect human health, agricultural production and environmental welfare.
EPA is examining new directions and long-term efforts toward VOC
reductions as well as approaches that are largely untried.
Nonroad sources contribute substantially to summertime VOC and
NOX emissions and winter CO emissions. The median contribution of
total nonroad emissions to VOC and NOX inventories in summer, and
CO inventories in winter, ranges from 7.4-12.6% VOC, 14.5-17.3% NOX/
and 5.2-9.4% winter CO, depending on the area (1). The lawn and
garden equipment category is a major contributor to summertime VOC
emissions, accounting for a median ranging from 2.4% to 4.7% of the
total VOC inventory in tons per summer day, depending on the area.
4.2.2. Benzene
Benzene is a dear, colorless, aromatic hydrocarbon which has a
characteristic odor. It is both volatile and flammable. Benzene contains
92.3% carbon and 7.7% hydrogen with the resulting chemical formula
C6H6. Benzene is present in both exhaust and evaporative emissions.
Data show the benzene level of gasoline to be about 1.5%. Some
exhaust benzene is unburned fuel benzene. Some benzene also forms
from engine combustion of non-aromatic fuel hydrocarbons. The
fraction of benzene in the exhaust varies depending on control
-------
4-10
technology and fuel composition and is generally about 3 to 5%. The
fraction of benzene in evaporative emissions also depends on control
technology and fuel composition and is generally about 1%.
Mobile sources account for approximately 85% of total benzene
emissions, of which 30% can be attributed to nonroad mobile sources.
These estimates were obtained from EPA's Nonroad Engine and Vehicle
Emissions Study (NEVES EPA, 1991b). For nonroad engines, benzene
was estimated to be about 3.0% of VOC emissions and 1.7% of
evaporative VOC emissions. The split between exhaust and evaporative
benzene emissions was assumed to be 80% exhaust to 20% evaporative.
Thus, the overall benzene fraction of nonroad VOC emissions was
estimated to be 2.74%.
4.2.2.1 Projected Benzene Emission Reductions—Nonroad engines
account for approximately 25% of the total benzene emissions with 60%
attributed to highway motor vehicles and 15% to stationary sources.
Many of the stationary sources attributed with benzene emissions are
industries producing benzene as a by-product or use benzene to
produce other chemicals.
Since benzene levels generally decrease proportionally to overall
emissions, once emission control technology is applied, the amount of
benzene produced by new small SI engines should reduce after the rule
becomes effective.
4.2.2.2 Health Effects of Benzene Emissions-Health effects caused
by benzene emission differ based on concentration and duration of
exposure. EPA's Total Exposure Assessment Methodology (TEAM)
Study identified the major sources of exposure to benzene for much of
the U.S. population. These sources turn out to be quite different from
what had previously been considered as important sources. The study
-------
4-11
results indicate that the main sources of human exposure are associated
with personal activities, not with the so-called "major point sources".
The results imply that personal activities or sources in the home far
outweigh the contribution of outdoor air to human exposure to benzene.
Since most of the traditional sources exert their effect through outdoor
air, some of the nonroad small SI engine sources could explain the
increased personal exposures observed. The TEAM Study is described
in detail in a four-volume EPA publication^) and in several journal
articles.
The average ambient level of benzene ranges from 4.13 to 7.18
u g/m3, based on urban air monitoring data. A crude estimate of
ambient benzene contributed by <19 kW SI engine sources can be
calculated by multiplying the total ambient concentration by the
percentage of nonroad engine-produced benzene. This figure must be
adjusted then to reflect time spent indoors and in other
microenvironments by using the factor developed in the Motor-Vehicle-
Related Air Toxics Study. Applying the nonroad adjustment factor of
.25 and integrated adjustment factor of .622 to reflect only nonroad
exposure to benzene, the range becomes .642 to 1.12 ug/m3.
Based on data from EPA's NEVES, the exhaust and crankcase
emissions from a 2.9 kW (3.9 hp) lawnmower with a 4-stroke engine
contain 3.5 grams of benzene. A 2.9 kW (3.9 hp), 2-stroke lawnmower
exhaust has 17 grams of benzene. A small, 2.2 kW (3 hp) chainsaw
emits 28.2 grams of benzene per hour, compared to a large, 4.5 kW (6
hp) chainsaw that emits 40.8 grams per hour. No study as yet has been
conducted on the health effects of benzene emissions specifically from
small SI engines.
A separate study conducted at Southwest Research Institute (SWRI)
reported a 2-stroke, 4.5 kW(6hp) moped engine fueled with industry
average unleaded gasoline emitted 2,260 mg/hph of benzene. A
-------
4-12
4-stroke walk-behind mower .powered by an overhead valve, 2.6 kW (3.5
hp) engine emitted 690 mg/hph of benzene when fueled with average
unleaded gasoline.
Concentration and duration of exposure to benzene are especially
important to consider in the case of small SI engine applications, since
the operator is typically in the direct path of the exhaust given out by
the engine. Rate of dilution of the exhaust by the air surrounding the
engine depends on local weather conditions.
4.2.2.3 Carclnogenlclty of Benzene and Unit Risk Estimates—The
International Agency for Research on Cancer (IARC), classified benzene
as a Group I carcinogen. A Group I carcinogen is defined as an agent
that is carcinogenic to humans. IARC (1987) based this conclusion on
the fact that numerous case reports and follow-up studies have
suggested a relationship between exposure to benzene and the
occurrence of various types of leukemia. The leukemogenic 'i.e., the
ability to induce leukemia) effects of benzene exposure were studied in
748 white males employed from 1940-1949 in the manufacturing of
rubber products in a retrospective cohort mortality study (Infante, et al.
1977 a,b). Statistics were obtained through 1975. A statistically
significant increase in the incidence of leukemia was found by
comparison to the general U.S. population. The worker exposures to
benzene were between 100 ppm and 10 ppm during the years 1941-1945.
There was no evidence of solvent exposure other than benzene. In
addition, numerous investigators have found significant increases in
chromosomal aberrations of bone marrow cells and peripheral
lymphocytes from workers with exposure to benzene (IARC 1982).
Exposure to benzene has also been linked with genetic changes in
humans and animals. EPA has concluded that benzene is a Group A,
known human carcinogen based on sufficient human epidemiologic
-------
4-13
evidence (Rinsky, et al. 1981; Ott, et al. 1978; Wong, et al. 1983)
demonstrating an increased incidence of nonlymphocytic leukemia from
occupational inhalation exposure. The supporting animal evidence
(Goldstein, 1980; NTP, 1986; Maltoni, et al., 1983) showed an increased
incidence of neoplasia in rats and mice exposed by inhalation and
gavage. EPA calculated a cancer unit risk factor for benzene of
S.SxCug/m)"1 based on the results of the above human epidemiological
studies in benzene-exposed workers in which an increase of death due
to nonlymphocytic leukemia was observed. EPA's office of Research
and Development (ORD) has recently started to review the process and
update benzene risk assessment.
The California Department of Health Services (DHS, 1984), which
provides technical support to CARB, has also determined that there is
sufficient evidence to consider benzene a human carcinogen. CARB
performed a risk assessment of benzene that was very similar to EPA's
risk assessment. The CARB risk estimate is actually a range, with the
number calculated by EPA serving as the lower bound of cancer risk
and a more conservative (ie., higher) number, based on animal data ,
serving as the upper bound of cancer risk. The CARB potency estimate
for benzene ranges from 8.3xlO~6 to 5.2xlO"s ug/m3.
A number of adverse noncancer health effects have also been
associated with exposure to benzene. People with long-term exposure
to benzene at levels that generally exceed 50 ppm (162,500 ug/m3) may
experience harmful effects on the blood-forming tissues, especially the
bone marrow. These effects can disrupt normal blood production and
cause a decrease in important blood components, such as red blood cells
and blood platelets, leading to anemia and a reduced ability to clot.
Exposure to benzene at comparable or even lower levels can be harmful
to the immune system, increasing the chance for infection and perhaps
lowering the body's defense against tumors by altering the number and
-------
4-14
function of the body's white blood cells. In studies using pregnant
animals, inhalation exposure to benzene in the range of 10-300 ppm
(32,500-975,000 ug/m3) indicates adverse effects on the developing fetus,
including low birth weight, delayed bone formation, and bone marrow
damage.
4.2.3. 1,3- Butadiene
1,3-Butadiene is a colorless, flammable gas at room temperature with
a pungent, aromatic odor, and a chemical formula C4H3. 1,3-Butadiene
is insoluble in water and because of its reactivity, is estimated to have a
short atmospheric lifetime. The actual lifetime depends upon the
conditions at the time of release, such as the time of day, intensity of
sunlight, temperature etc. 1,3 Butadiene is formed in vehicle exhaust by
the incomplete combustion of the fuel and is assumed not to be present
in vehicle evaporative and refueling emissions.
1,3- Butadiene emissions appears to increase roughly in proportion to
exhaust hydrocarbon emissions. Since hydrocarbons are decreased by
the use of a catalyst on a motor vehicle, 1,3-butadiene emissions are
expected to decrease proportionally with the use of any emission control
technology that decreases total hydrocarbon emission. The percentage
of 1,3-butadiene in unregulated small SI engines is estimated to be
approximately 1.3 percent.
4.2.3.1 Projected 1,3-Butadiene Emission Reductions-Current EPA
estimates indicate that mobile sources account for approximately 94% of
the total 1,3-butadiene emissions, out of which 41% can be attributed to
nonroad mobile sources. The remaining 1,3-butadiene emissions come
from stationary sources mainly related to industries producing 1,3-
butadiene and those industries that use 1,3-butadiene to produce other
compounds.
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4-15
4.2.3.2 Health Effects of 1,3 - Butadiene Exposure-The annual
average ambient level of 1,3-butadiene ranges from 0.12 to 0.56 jig/m3.
According to data from EPA's NEVES, 1,3-Butadiene content in exhaust
and crankcase from a 2.9 kW (3.9 hp), 4-stroke lawnmower is
approximately 1.5 gms/hr of usage. For a 2.9 kW (3.9 hp), 2-stroke
lawnmower, 1,3-butadiene content in exhaust is 7.0 grams per hour.
Butadiene emitted from small, 2.2 kW (3hp) chainsaw is approximately
12.2 grams per hour from a large 4.5 kW (6 hp) chainsaw.
A separate study conducted at SwRI revealed a 2-stroke, 4.5 kW (6
hp) moped engine emitted 207 mg/kW-hr (154 mg/hp-hr) when fueled
with industry average unleaded gasoline. A .26 kW (3.5 hp) overhead
valve, walk-behind mower emitted 209 mg/kW-hr (156 mg/hp-hr) of
1,3-butadiene when fueled with industry average unleaded gasoline.
Since 1,3-butadiene levels normally decrease proportional to overall
hydrocarbons once emission control technology is applied, 1,3-butadiene
levels are expected to be less from new small SI engines after this rule
becomes effective. This, in turn, will reduce risk of exposure to 1,3-
butadiene produced by these sources.
Since the operator of a small SI engine- equipped application is
typically near the equipment while it is in use, the concentration of
toxic pollutants in the exhaust and their health effects need to be
investigated. Although the air around the engine quick;ly dilutes the
exhaust, the rate of dilution depends on the weather conditions.
4.2.3.3 Carcinogenictty of 1,3-Butadlene-Long-term inhalation
exposure to 1,3-butadiene has been shown to cause tumors in several
organs in experimental animals. Epidemiolpgic studies of
occupationally exposed workers were inconclusive with respect to the
carcinogenicity of 1,3-butadiene in humans. Based on inadequate
human evidence but sufficient animal evidence, EPA has concluded that
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4-16
1,3-butadiene is a Group B2, probable human carcinogen. IARC has
classified 1,3-butadiene as a Group 2A, probable human carcinogen.
EPA calculated a cancer unit risk factor of Z.SxlO"4 (ug/m3)'1 for 1,3-
butadiene based on the results of a study in mice in which an increase
in the incidence of tumors in the lung and blood vessels of the heart, as
well as lymphomas were observed. EPA's Office of Research and
Development has just recently started the process of updating 1,3-
butadiene risk assessment.
Exposure to 1,3-butadiene is also associated with adverse noncancer
health effects. Exposure to high levels (on the order of hundreds of
thousands ppm) of this chemical for short periods of time can cause
irritation of the eyes, nose, and throat, and exposure to very high levels
can cause effects on the brain leading to respiratory paralysis and death
Studies of rubber industry workers who are chronically exposed to 1,3-
butadiene suggest other possible harmful effects including heart disease,
blood disease, and lung disease. Studies in animals indicate that 1,3-
butadiene at exposure levels of greater than 1,000 ppm (2.2x106 ug/m3)
may adversely affect the blood-forming organs. Reproductive and
developmental toxicity has also been demonstrated in experimental
animals exposed to 1,3-butadiene at levels greater than 1,000 ppm.
4.2.4. CO
The Clean Air Act directs the Administrator of the EPA to establish
National Ambient Air Quality Standards (NAAQS) for several
widespread air pollutants, based on scientific criteria and allowing for
an adequate margin of safety to protect public health. The current
primary and secondary NAAQS for CO are 9ppm for a one hour
average and 35 ppm for an eight hour average.
4.2.4.1. Health and Welfare Effects of CO-Carbon monoxide is a
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4-17
colorless, odorless, tasteless and nonirritating gas and gives no signs of
its presence. It is readily absorbed from the lungs into the bloodstream,
there forming a slowly reversible complex with hemoglobin (Hb) known
as carboxyhemoglobin (COHb).
Blood COHb levels do not often exceed 0.5 to 0.7% in normal
individuals unless exogenous CO is breathed. Some individuals with
high endogenous CO production can have COHb levels of 1.0 to 1.5%
(e.g. anemics). The presence of COHb in the blood reduces the amount
of oxygen available to vital tissues, affecting primarily the
cardiovascular and nervous systems. Although the formation of COHb
is reversible, the elimination half-time is quite long because of the right
binding between CO and Hb. This can lead to accumulation of COHb,
and extended exposures to even relatively low concentrations of CO
may produce substantially increased blood levels of COHb.
Health effects associated with exposure to CO include cardiovascular
system, central nervous system (CNS), and developmental toxicity
effects, as well as effects of combined exposure to CO and other
pollutants, drugs, and environmental factors. Concerns about the
potential health effects of exposure to CO have been addressed in
extensive studies with various animal species as subjects. Under varied
experimental protocols, considerable information has been obtained on
the toxicity of CO, its direct effects on the blood and other tissues, and
the manifestations of these effects in the form of changes in organ
function. Many of these studies, however have been conducted at
extremely high levels of CO (i.e., levels not found in ambient air).
Although severe effects from exposure to these high levels of CO are
not directly germane to the problems from exposure to current ambient
levels of CO, they can provide valuable information about potential
effects of accidental exposure to CO, particularly those exposures
occurring indoors.
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All gasoline-powerd engines produce carbon monoxide. According
to the National Institute for Occupational Safety and Health 'NIOSH),
Americans who use gasoline-powered pressure washer indoors are
risking their lives. This gas can rapidly build up in any indoor area,
and individuals can be overcome without even realizing that they are
being exposed. Confusion, headache, dizziness, fatigue, and weakness
may set in too quickly for victims to save themselves. According to
NIOSH director, Dr. J. Donald Millar, "Carbon monoxide strikes quickly,
and it strikes without warning. Workers must be aware of the hazard
and prevent exposure to this potentially fatal gas." Each of the victims
interviewed by NIOSH expressed shock at how quickly they were
overcome. Carbon monoxide poisoning can cause permanent brain
damage , including changes in personality and memory. Once inhaled,
carbon monoxide decreases the ability of the blood to carry oxygen to
the brain and other vital organs. Even low levels of carbon monoxide
can set off chest pains and heart attacks in people with coronary artery
disease.
Although no studies measuring the human health effects of CO
emanating from small SI engine exhaust have been conducted, ample
research results are available concerning general health effects of
exposure to CO . The effects of exposure to low concentrations - such
as the levels found in ambient air - are far more subtle and considerably
less threatening than those occurring in direct poisoning from high CO
levels. Maximal exercise performance in healthy individuals has been
shown to be affected at COHb levels of 2.3% and greater. Central
nervous sytem effects, observed at peak CO Hb levels of 5% and
greater, include reduction in visual perception, manual dexterity,
learning, driving performance, and attention level. Of most concern,
however, are adverse effects observed in individuals with chronic heart
disease at COHb levels of 3 to 6%. At these levels, such individuals are
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4-19
likely to have reduced capacity for physical activity because they
experience chest pain (angina) sooner. Exercise-related cardiac
arrhythmias have also been observed in some people with chronic heart
disease at COHb levels of 6% or higher and may result in an increased
risk of sudden death from a heart attack.
The NAAQS set by EPA are intended to keep COHb levels below
2.1% in order to protect the most sensitive members of the general
population (i.e., individuals with chronic heart disease). However,
elderly people, pregnant women (due to possible fetal effects), small
children, and people with anemia or with diagnosed or undiagnosed
pulmonary or cardiovascular disease are also likely to be at increased
risk for CO effects.
According to the Nonroad Study/a 4-stroke, 2.9 kW (3.9 hp)
lawnmower engine emits 1051.1 g/hr CO while a 2-stroke, 2.9 kW (3.9
hp) engine meets 1188.4 g/hr CO. A separate study conducted at SwRI
revealed that a 2-stroke moped engine fueled with typical unleaded
gasoline emits 184 g/Kw-hr (137 g/hp-hr) of CO. A 4-stroke, 2.6 kW
overhead valve, walk-behind mower fueled with typical unleaded
gasoline emits 480 g/kW hr (358 g/hp-hr) of CO.
Since small SI engines are typically used in applications that require
the operator to be near, and perhaps in the direct path of the exhaust,
the above numbers provide some basis for determining the effects of
exhaust CO on the operator of the engine. Laboratory animal studies
reveal that CO can adversely affect the cardiovascular system,
depending on the exposure conditions utilized in these studies.
4.2.4.2. Developmental Toxlclty and Other Systemic Effects of Carbon
Monoxide—Studies in laboratory animals of several species provide strong
evidence that maternal CO exposures of 150 to 220 ppm, leading to
approximately 15 to 25% COHb, produce reductions in birth weight,
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4-20
cardiomegaly, delays in behavioral development, and disruption in
cognitive function (Singh, 1986). The current data (Hoppenbrouwers, et
al., 1981) from human children suggesting a link between environmental
CO exposures and sudden infant death syndrome are weak. Human
data from cases of accidental high CO exposures (Klees, et al, 1985;
Crocker, et al, 1985) are difficult to use in identifying a low observed-
effect level for CO because of the small numbers of cases reviewed and
problems in documenting levels of exposure.
Behaviors that require sustained attention or sustained performance
are most sensitive to disruption by COHb. The group of human studies
(Benignus, et al, 1987,1990) on hand-eye coordination (compensatory
tracking), detection of infrequent events (vigilance), and continuous
performance offer the most consistent and defensible evidence of COHb
effects on behavior at levels as low as 5%. These effects at low CO-
exposure concentrations, however, have been very small and somewhat
controversial. Nevertheless, the potential consequences of a lapse of
coordination, vigilance, and the continuous performance of critical tasks
by operators of machinery such as public transportation vehicles could
be serious.
At higher levels of exposure, where COHb concentrations exceed 15
to 20%, there may be direct inhibitory effects of CO resulting in
decreases in renobiotic metabolism, which might be important to
individuals receiving treatment with drugs. Inhalation of high levels of
CO, leading to COHb concentrations greater than 10 to 15%, have been
reported to cause a number of other systemic effects in laboratory
animals as well as humans suffering from acute CO poisoning. There
are reports in the literature of effects on liver, kidney, bone, and
immune capacity in the lung and spleen (Zebro, et al, 1983). It
generally is agreed that these effects are caused by severe tissue damage
occurring during acute CO poisoning.
IV-
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4-21
Chapter 4: References
1. EPA, Nonroad Engine and Vehicle Emission Study, EPA Report
Number 21A-2001, Washington, DC, November, 1991.
2. Power Systems Research, Engine Data and Parts Link Data bases,
St. Paul, Minnesota 55121.
3. Energy and Enviornmental Analysis, Emissions Inventory on
Non-Farm (MS-1), Farm(MS-2), and Lawn and Garden
(Utility)(MS-3) Equipment - Status Report, Arlington, VA,
December 1983.
4. Jack Faucett Associates, Nonroad Mobile Source Sales and Attrition
Study : Identification and Evaluation of Available Data Sources -
Final Report, Bethesda, Maryland, February 1993, p.3-11
5. National Research Council, Rethinking the Ozone Problem in
Urban and Regional Air Pollution, National Academy Press,
Washington, DC, 1991.
6. Fisher, D. and Oppenheimer, M., Atmospheric Deposition and the
Chesapeake Bay Estuary, Journal Ambio, Volume 20, pp. 102-108
(1991).
7. U.S. Environmental Protection Agency, Review of the National
Ambient Air Quality Standards for Ozone - Assessment of
Scientific and Technical Information: OAQPS Staff Paper, EPA-
450/2-92-001, June 1989.
8. U.S. Environmental Protection Agency, Review of the National
Ambient Air Quality Standards for Ozone - Assessment of
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4-22
Scientific and Technical Information: OAQPS Staff Paper, EPA-
450/2-92-001, June 1989.
9. U.S. Environmental Protection Agency, Review of the National
Ambient Air Quality Standards for Ozone - Assessment of
Scientific and Technical Information: OAQPS Staff Paper, EPA-
450/2-92-001, June 1989.
10. U.S. Environmental Protection Agency, Review of the National
Ambient Air Quality Standards for Ozone - Assessment of
Scientific and Technical Information: OAQPS Staff Paper, EPA-
450/2-92-001, June 1989.
11. U.S. Environmental Protection Agency, Review of the National
Ambient Air Quality Standards for Ozone - Assessment of
Scientific and Technical Information: OAQPS Staff Paper, EPA-
450/2-92-001, June 1989.
12. U.S. Environmental Protection Agency, Review of the National
Ambient Air Quality Standards for Ozone - Assessment of
Scientific and Technical Information: OAQPS Staff Paper, EPA-
450/2-92-001, June 1989.
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Chapter 5: Cost-Effectiveness Analysis
Based upon the costs and pollutant reductions described in the
preceding chapters, EPA has prepared a cost-effectiveness analysis for
this Small Gas FRM. Because the benefits to society of this Small Gas
FRM are not easily monetized, a cost-effectiveness analysis has been
prepared.
If all program costs are allocated to hydrocarbon (HC) reductions,
today's Small Gas FRM has a .cost-effectiveness of $280 per ton of HC
reduced. Alternatively, if all program costs are allocated to carbon
monoxide (CO) reductions, the cost-effectiveness would be $113 per ton.
If the costs of the program were equally split between HC and CO,
the cost-effectiveness of HC reduction would be $140 per ton and the
cost-effectiveness of CO would be $57 per ton. Since the primary
purpose of this rule is to control HC emissions, the most appropriate of
the above ratios is the first one (i.e., $280 per ton HC abated), however,
this does not include consideration of the fact that there is a value of
also achieving the CO reduction.
Thus, it is important to note that the cost of technology which only
acts to reduce one pollutant should only be attributable to the reduction
of that pollutant. For instance, if a technology only acted to reduce CO,
5-1
/7J'
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5-2
the cost of that technology would not be used to calculate the cost-
effectiveness of reducing HC. EPA could not identify any technologies
which manufacturers would use to only reduce one pollutant.
These cost-effectiveness numbers are favorable relative to the cost-
effectiveness of other control measures required under the Clean Air
Act. To the extent that cost-effective nationwide controls are applied to
small SI engines, the need to apply more expensive additional controls
to mobile and stationary sources in the future may be reduced.
This chapter describes how the cost-effectiveness numbers presented
above were calculated. Further, this chapter presents some alternative
viewpoints on methodologies to calculate cost-effectiveness numbers.
5.1. Cost-Effectiveness Methodology
For both HC emissions and CO emissions, program cost-effectiveness
is presented for this rule as the ratio of the net present valur of the
stream of costs to society divided by the net present value of the stream
of emission reductions on an inventory basis. Because of the inherent
pollution formation characteristics of the combustion process and the
technology required by this Small Gas FRM, the associated cost of
producing engines which comply with the adopted standards cannot be
attributable to individual pollutants. Therefore, the per-pollutant cost-
effectiveness is calculated using the same cost estimate in the numerator
for each ratio, while utilizing individual pollutant impacts in the
denominator. This produces the most conservative cost-effectiveness
number for each pollutant. In other words, the per-pollutant cost-
effectiveness number reflects the total cost incurred to achieve the
needed emission reduction for that pollutant.
The per-pollutant cost-effectiveness estimates are easiest to interpret
under this methodology when viewed in isolation. From this
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5-3
perspective, society is concerned with the reduction of one particular
pollutant. Comparing cross-pollutant cost-effectiveness estimates under
this methodology can be clarified as follows. From the perspective of.
reducing HC emissions, the adopted FRM program would generate
windfalls (i.e., unexpected gains) of CO reductions because standards
are set such that the HC reducing set of technology also produces CO
reductions. Two important points are 1) that the adopted level of HC
reduction is not gained unless the total costs are incurred and 2) that no
additional costs are incurred to achieve the CO reduction. If the rule
were viewed as placing the priority on reducing CO, interpreting the
cost-effectivness estimates from the perspective of reducing CO would
be similar.
5.2. Annualized Costs and Annualized Pollutant Reductions
The annualized costs of the Small Gas FRM and the annualized
effectiveness of the Small Gas FRM in terms of the tons of pollutants
(HC, CO, and NOX) reduced are shown in Figures 5-01 and 5-02. Figure
5-01 shows the costs annualized at 7 percent, then discounted to present
value at 3 percent.
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5-4
Figure 5-03
PRGRAM COSTS OVER TIME
1993 dollars
•••*-.„
....... anniulized ooitf
2Mt Ull 10U un
....... pnwatvthu ofuuuulixodoodi
111
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5-5
Figure 5-04
PROGRAM EFFECTIVENESS OVER TIME
reduction in pollutants (tons)
..»—•—•—•-
HC
jou
YEAR
CO _
NOs
5.3.
Cost-Effectiveness
This section presents the cost-effectiveness of the FRM program
based on the net present value of the costs divided by the net present
value of the HC and CO pollutant benefits.
5.3.1. Hydrocarbon (HC) Cost-Effectiveness
HCs are the primary target pollutant for this regulatory effort. EPA
believes that the "best estimate technology" method of determining cost-
effectiveness follows the Kolb-Scheraga approach. (2) After
annualization at 7%, the costs (and emission reductions) are discounted
at 3%. Therefore, the corresponding HC cost-effectiveness is $280 per
ton applying all program costs to HC.
Table 5-01 presents the HC cost-effectiveness numbers for the Phase
1 program. These ratios take into account the total program costs
m
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5-6
incurred in order to achieve the proposed magnitude of HC reductions.
Because these ratios are based on total program costs, reductions in CO
emissions are considered to be windfalls.
Table 5-01
HC Cost-Effectiveness
Using Total Program Costs
Discount
Rate
0.00
0.03
0.07
Technology Assumptions
Best Estimate
Technology
232
280
289
Catalyst
Option
292
325
353
Table 5-02 presents the alternative HC cost-effectiveness numbers for
the Phase 1 program. These ratios assign half the total program costs
incurred to the magnitude of HC reductions.
Table 5-02
HC Cost-Effectiveness
Using Half the Total Program Costs ($/Ton)
Discount
Rate
0.00
0.03
0.07
Technology Assumptions
Best Estimate
Technology
116
140
145
Catalyst
Option
146
163
177
The HC cost-effectiveness of this rule using total program costs is
nearly comparable to the HC cost-effectiveness of two other CAA
mandated requirements which achieve only VOC benefits. The CAA
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5-7
has mandated reductions in reid vapor pressure of motor vehicle
gasoline. EPA has estimated the cost-effectiveness of these HC
reductions at $140 per ton. The CAA has also mandated reductions in
evaporative VOC emissions from motor vehicles. The cost-effectiveness
of these HC reductions have been placed at $170 per ton.
Two other CAA mandated programs which achieve only VOC
benefits are considerably less cost-effective than this Phase 1 Smallgas
FRM. For example, the cost-effectiveness of "Stage II" vapor recovery
systems for control of vehicle refueling HC emissions at gas dispensing
facilities is estimated to be $1,020 per ton. Another CAA mandate
which is even less cost-effective regards reduction of VOC emissions
from consumer and commercial solvents. EPA estimates the cost-
effectiveness of reducing VOCs from solvents at $2,000 per ton. Also,
the CAA mandate for "Tier I" on-highway motor vehicle emission
standards reduced both VOCs and NOX, with a VOC cost-effectiveness
estimate of $3700 per ton. Further, the CAA mandate for on-board
diagnostic equipment for on-highway motor vehicles reduces HC, CO,
and NOX, with an estimated cost-effectiveness for HC of $1974 dollars
per ton.
Clearly, the HC cost-effectiveness using total program costs
presented above for today's Phase 1 Small Gas FRM is very cost-
effective in relative terms.
5.3.2. Carbon Monoxide (CO) Cost-Effectiveness
CO is the secondary target pollutant for this regulatory effort. The
"best estimate technology" method of determining CO cost-effectiveness
used the same approach as with HC. The corresponding CO cost-
effectiveness is $113 per ton applying all program costs to CO.
The Phase 1 program adopted today produces the program cost-
effectiveness numbers shown in Table 5-03. These ratios take into
191
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5-8
account the total program costs incurred in order to achieve the
magnitude of CO reductions. Because these ratios are based on total
program costs, reductions in HC emissions are considered to be
windfalls.
Table 5-03
CO Cost-Effectiveness
Using Total Program Costs
Discount
Rate
0.00
0.03
0.07
Technology Assumptions
Best Estimate
Technology
93
113
117
Catalyst
Option
117
131
143
Assigning half of the total program costs to CO produces the
program cost-effectiveness numbers shown in Table 5-04.
Table 5-04
CO Cost-Effectiveness
Using Half the Total Program Costs
Discount
Rate
0.00
0.03
0.07
Technology Assumptions
Best Estimate
Technology
47
57
59
Catalyst
Option
59
66
72
The CO cost-effectiveness of this rule is between the cost-
effectiveness estimates of three CAA mandated CO reductions for
mobile sources. One mandate was to reduce the CO emissions from
motor vehicles operating at cold temperatures. EPA estimated the CO
131-
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5-9
cost-effectiveness at -$84 to -$8 per ton. Another CAA mandate for on-
board diagnostic equipment for on-highway motor vehicles reduces HC,
CO, and NOX, with an estimated cost-effectiveness for CO of $124
dollars per ton. A third mandate affecting CO required the use of
oxygenated fuels in CO nonattainment areas during the wintertime.
The CO cost-effectiveness was estimated to range from -$247 per ton to
$695 per ton. Achieving CO reductions from nonroad smallgas engines
by today's Small Gas FRM is not as cost-effective as the CO reductions
already achieved from technological changes to mo' •• vehicles, but is
more cost-effective than the use of oxygenated fuels j/i some
nonattainment areas and more cost-effective than the CO reductions
achievable through the use of on-board diagnostic equipment for on-
highway motor vehicles.
In summary, the cost-effectiveness of the HC and CO standards
included in the current Small Gas FRM is favorable relative to the cost-
effectiveness of other VOC and CO control measures required under the
Clean Air Act. To the extent that cost-effective nationwide controls are
applied to small SI engines, the need may be reduced to apply in the
future more expensive additional controls to mobile and stationary
sources that also contribute to ozone nonattainment and visibility.
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5-10
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5-11
Chapters: References
i.
EPA, Nonroad Engine and Vehicle Emission Study, EPA Report Number
21A-2001, Washington DC, november, 1991.
2.
U.S. Environmental Protection Agency, Office of Policy, Planning, and
Evaluation, Guidelines for Performing Regulatory Impact Analyses, Appendix C,
EPA-230-01-84-003, March 1991, Washington, DC.
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5-12
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Appendix A: Small Engine Testing Facility,
University of Michigan Walter E. Lay Automotive
Laboratory
In the fall of 1992, the EPA's Certification Division entered into a
Cooperative Agreement with the University of Michigan's Walter E. Lay
Automotive Laboratory (the "Auto Lab"). The goals and objectives of
the Agreement are outlined below.
A.1. Goals
• Provide the University of Michigan with the opportunity to develop
a world-class small engine and marine outboard engine research
facility.
• Provide interaction between university personnel and staff from an
internationally recognized government laboratory acclaimed for its
expertise and resources in the engine emission control area.
• Provide EPA access to the expertise and resources needed to
investigate emissions from nonroad engine sources through
cooperation with researchers and students from the College of
A-l
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A-2
Engineering at the university.
A.2. Objectives
• Assemble and validate a fully operational emission test stand capable
of testing small spark-ignited engine emissions.
• Measure exhaust emissions (e.g., hydrocarbons^ oxides of nitrogen,
and carbon monoxide) from small utility engines using SAE
recommended practice J1088.
• Develop constant volume sampling (CVS) dilution exhaust
measuring techniques for non-road small engines.
A.3. Description of Facility
The testing facility at the University of Michigan Walter E. Lay
Automotive Laboratory is based in the following pieces of equipment.
• Beckman analyzer bench with
• NDIR carbon monoxide and carbon dioxide measurement
• Flame lonization Detector for the measurement of total
hydrocarbons
• a chemiluminescent detector for the measurement of oxides of
nitrogen
• Micro-Dyne 15 horsepower vertical/horizontal hydraulic motoring
dynamometer
• Computer based dynamometer control system and total data
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A-3
acquisition, including various voltage, temperature, and pressure
measurements
• A critical flow venturi constant volume sampling system for the
continuous measurement of total dilute exhaust volume flow
• A mass fuel flow measuring system using an external fuel supply
tank mounted on a load cell whose voltage output was read by the
control system
The Auto Lab has been utilizing the six mode non-handheld engine
test cycle and the two mode handheld engine test cycle described in the
February, 1993 version of the Society of Automotive Engineers (SAE)
recommended test procedure J1088. The Auto Lab has reported all
weighted emission results using the small engine weighting factors
established by the California Air Resource Board's 1995 utility engine
regulation.
The Auto Lab has been using the recommended test procedures and
emission calculations established by the SAE J1088 procedure, with the
exception of measuring emissions using the Constant Volume Sampling
method, not the Raw Gas Method described in the J1088 procedure.
The facility has tested two correlation engines which have been run
at industry emissions laboratory and has proven they are collecting
valid emission data.
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A-4
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Appendix B: Manufacturer and Product Summary
B.1. Introduction
This appendix summarizes information on the equipment related to
the category of engines regulated, nonroad 0-19 kilowatt spark-ignited
engines. This appendix summarizes the engine manufacturers and their
products, the technology used on these engines, and estimates the
amount of these engines consumed in the United States.
B.2. Engine Manufacturer Summary
There are a wide variety of engine manufacturers producing engine
products which will be regulated. Mostly, engine manufacturers
produce either 2-stroke engines or 4-stroke engines, although the major
manufacturers produce some of each. Data on the manufacturers and
their products is limited. EPA has purchased databases from Power
Systems Research called EnginData and PartsLink which summarize
data on manufacturers and their products for the engines to be
regulated as well as all other types of engines consumed in North
America(l). EPA used this database as a basis of information because it
contains the most extensive amount of publicly available information
B-l
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B-2
regarding the products of concern to this regulation. However, there
are some significant problems with the information contained in the
database as well as the extent of information contained in the database.
EnginData gathers information by surveying equipment
manufacturers regarding purchases of engines per year, contacting
private trade organizations, and contacting government agencies. As
PSR itself notes, "(a)lthough Power Systems Research has gone to
considerable lengths to make this information as accurate as possible,
errors and omissions inveitably occur. The data is continually reviewed
and updated, including both historical corrections and revised
forecasting. Subscribers to the complete database receive quarterly
revisions and clients requesting extracts will receive the most current
data available."11 Please refer to the EnginData Rreference Guide which
is in the docket for a further discussion of the information contained in
the EnginData databse.
EPA has made efforts to compare the information generated from
EnginData to other sources. When the information from other sources
was sufficient or better, EPA has adopted the other source information.
This appendix outlines the alternative sources of information and
describes the rationale for choosing data other than PSR data for
purposes of analysis of technology, costs, and benefits.
B.2.1. Listing of Known Engine Manufacturers
EPA has generated a listing of engine manufacturers from the PSR
Engindata database. It appears that there are approximately 28 engine
manufacturers selling gasoline engines under 25 horsepower. Of these,
20 manufacturers produce 2-stroke engines and 14 manufacturers
produce 4-stroke engines. There are 5 manufacturers who produce both
11 Power Systems Research, "EnginData North America Reference Guide, Edition 13.2," page 1.
-------
B-3
2-stroke and 4-stroke engines. Please refer to Table B-01, which
summarizes the manufacturers who produce 2- and 4-stroke engines.
B.2.2. Listing of Known Engine Models per Manufacturer
PSR's EnginData database contains the most extensive listing of
information at the engine model level. The data in this section is
excerpted from this database. Presented in the section are the number
of engine models per manufacturer, the engine model codes, and the
estimated number of engine models in each standard category. The
estimated number of engine models in each standard category is based
on an analysis of the equipment which each engine model is used in.
This equipment information is contained in the PSR EnginData database,
although the specific engine model and equipment type combinations
are not summarized here.
B.2.2.1. Number of Engine Models—Some statistics on the 2-stroke
and 4-stroke products differ substantially. There are over three times as
many 4-stroke engine models as there are 2-stroke engine models. The
most diverse 4-stroke manufacturer produces nearly five times as many
engine models as the most diverse 2-stroke engine manufacturer. There
are thirteen 2-stroke engine manufacturers who produce less than three
engine models, while approximately half that number of manufacturers
produce less than three 4-stroke engine models. There seems to be a
much larger number of 4-stroke engine manufacturers producing
diverse product lines. There are five 4-stroke engine manufacturers of
moderate diversity producing between 17 and 20 engine models, or
approximately 9 % of the number of 4-stroke engine models each.
There are just three 2-stroke engine manufacturers in a similar situation.
Other statistics on the 2- and 4-stroke products are similar. For 2-
stroke engines, the two most diverse engine manufacturers produce 40%
-------
B-4
of the engine models, while the most diverse engine manufacturer
produces 20% of the product models. For 4-stroke engines, the two
largest manufacturers produce 43% of the engine models, while the
most diverse engine manufacturer produces 27% of the product models.
The data these conclusions are based on are summarized in Table
B-02.
B.2.2.2. Engine Model Codes—EPA identified each manufacturer's
specific engine model codes as listed in the PSR EnginData database. It
is unclear whether each engine model corresponds to an "engine family"
as defined in the regulations.12 In order to estimate the admininstrative
costs of the proposed regulatory programs, EPA used the number of
engine models as an approximation of the number of engine families.
B.2.2.3. Number of Engine Models In Each Standard Category Per
Manufacturer~EPA estimated the number of each manufacturers engine
models which would be likely to be in a particular standard category.
This estimation was based on the definition of handheld engines. EPA
considered the engine size and the specific type of equipment which the
engine is used in when considering which standard category to assign a
specific engine to. Some engines appeared to be used in either a
handheld or nonhandheld application. For those engines, EPA assigned
them to the standard category for which the engine had the highest
sales volume.
12 See proposed regulation Subpart B.
-------
B-5
Table B-01
Engine Manufacturers
Manufacturer
Acme
Briggs & Stratton
Columbia
Cushman
Daihatsu Motors
Homelite
Honda
Inertia Dynamic
Kawasaki
Kioritz
Kohler
Komatsu-Zenoah
Kubota
Lawn-boy
McCulloch
Mitsubishi Heavy Industries
Newton Engines
Onan
Poulan
Power Bee
Stihl
Suzuki
Tecumseh
Teledyn-Wisconsin
U.S. Engines
Wacker
Yamaha
Yanmar
0-25 hp
2-Stroke
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
0-25 hp
4-Stroke
•
•
•
•
•
•
•
•
•
•
•
•
•
•
-------
B-6
Table B-02
Number of Engine Models Per Manufacturer
nndnuTaciurer
Acme
Bombadier-Rotax
Briggs & Stratton
Columbia
Cushman
Daihatsu Motors
Homeiite
Honda
Inertia Dynamic
Kawasaki
Kioritz
Kohler
Komatsu-Zenoah
Kubota
Lawn-boy
McCulloch
Mitsubishi Heavy Industries
Newton Engines
Onan
Poulan
Power Bee
Stihl
Suzuki
Tecumseh
Teledyn-Wisconsin
U.S. Engines
Wacker
Yamaha
Yanmar
TOTALS
Number of Engine Models for Each Engine Type
2-Stroke
1
1
1
13
2
2
3
2
7
1
12
3
6
1
5
1.
2
1
64
4-Stroke
4
56
1
2
17
20
20
3
2
4
18
. 3
34
28
1
1
214
Total Number of
Engine Models
4
1
57
1
1
2
13
17
2
20
2
20
3
3
2
7
3
• 4
18
12
3
6
4
39
28
1
2
2
1
278
-------
B-7
Table B-03
4-Stroke Engine Models
ACME
BRIGGS&STRATTON
CUSHMAN
DAIHATSU MTR
HONDA
KAWASAKI
KOHLER
KUBOTA
MHI
NEWTON ENG
ONAN
SUZUKI
A220
100700
112200
122700
130900
161400
190400
193700
252400
260700
294400
326400
402700
80200
92500
AL550W
104700
114700
124700
131700
170400
190700
195400
252700
261700
294700
350400
422400
80300
92900/94900
ALN290W
110700/111700
114900
125700
132200
170700
191700
221400
254400
281700
303400
400700
422700
82200
93900
ALN330W
110900 '
121700
130200
132400
171400
192700
233400
256700
290400
303700
402400
60100
90700/91700
99700
C-222
AB
G100
GX140
GX360
GXV120(US)
GXV340
FA130D
FB460V(US)
FC540V
FE170D
FG200D
CH18
CV12.5
CV22
M10
M18
MV-18
GH280
G510
400/401
CCK
ELITE 140
MCCK
P218
P224
S150
EB
G100K1
GX240
GX390
GXV140(US)
FA210D
FCISOV(US)
FD590V
FE250D
FG300D
CH20
CV14
K582
M12
M20
GS230
G910
404/407
CCKA
ELITE 75
NHC
P218V
T260
S80Y
GX110
GX270
GXV110
GXV160
FA210V
FC290V
FD620
FE290D
KF150
CH22
CV1S
K91(MX)
M14
M8
WG600-B
410/419
CCKB
ELITE 95
P216
P220
V140X
GX120
GX340
GXV120
GXV270
FA76D
FC420V(US)
FE120
•FE350
CHS
CV20
L654
M16
MV-16
418
ELITE 125
JB
. P216V
P220V
-------
B-8
TECUMSEH
TELEDYN-WISC
YANMAR
YAMAHA
H30
H70
HM70
HMXL70
OH120
OVRM40
TVM170
TVS120
VH70
ACN
EY-18-3W
EY-44W
TJD
WI-145
WI-280
W01-115
H3S
HH100
HM80
( HS40
OH140
OVRM50
TVM195
TVS75
AENL
EY-21W
S-12D
TRA-12D
WI-145V
WI-340
W01-150
H50
HH60
HMSK100
HS50
OH160
OVXL120
TVM220
TVS90
AGND
EY-25W
S-14D
W2-1230
WI-185
WI-390
W01-210
H60
HM100
HMSK80
LAV50
OH180
TVM140
TVS105
TVXL105
BKN
EY-27W
S-8D
W2-880
WI-185V
WI-450V
W01-340
3TG66E
J38
-------
B-9
Table B-04
2-Stroke Engine Models
BOMBRDIER-ROTAX
BRIGGS&STRAN
COLUMBIA
HOMELITE
INERTIA DYNAMIC
KIORITZ
KOMATSU-ZENOAH
LAWN-BOY
MCCULLOCH
MHI
POULAN
POWER BEE
STIHL
SUZUKI
TECUMSEH
US ENGINES
WACKER
YAMAHA
250
96700
DX
HM25
HM31
HM88
HM38
IDC-285
SRM-311D
G2A
MODEL M
MC21
MC51
HM57
HM39
HM54
IDC-310
SRM-4600
G4C
MODEL F
MC32
MC70
HM67
HM47
HM100
G4K
MC35
MC82
HM77
HM26
HM102
MC38
T130
XR20
1800
2000
58021
210
500
XR50
2300
4900
70019
262
800
XR80
3400
3700
82027
400
PR0200
657
5400
700
401
TC200
TVS840
AH520
AV520
AH600
354
WM80
WM100
S215
-------
B-10
Table B-05
Manufacturer
Acme
Bombadier-Rotax
Briggs & Stratton
Columbia
Cushman
Daihatsu Motors
HomelHe
Honda
Inertia Dynamic
Kawasaki
Kioritz
Kohler
Komatsu-Zenoah
Kubota
Lawn-boy
McCulbch
Mitsubishi Heavy Industries
Newton Engines
Onan
Poulan
Power Bee
Stihl
Suzuki
Tecumseh
Teledyn-Wisconsin
U.S. Engines
Wacker
Yamaha
Yanmar
TOTALS
Number of Engine Models
for Each Standard Category
1
22
5
5
1
1
1
2
4
1
3
3
3
4
3
12
7
1
2
1
80
II
3
1
33
1
1
2
7
12
19
3
1
1
19
20
20
1
1
144
III
1
1
IV
9
2
2
3
1
1
6
2
1
27
V
6
2
5
2
15
-------
B-ll
B.3. Estimate of Historical and Future Equipment Consumption
(Sales)
EPA analyzed the information from the PSR database as well as
information from Outdoor Power Equipment Institute (OPEI), the
Portable Power Equipment Manufacturers Association (PPEMA), and a
study done for the California Air Resources Board by Booz, Allen,
Hamiliton (BAH).
Data presented in this section shows the estimates of historical
consumption from these sources. Data from two regression analyes is
also presented. EPA did a regression of historical sales using ordinary
least squares methodology. EPA considered using the regression
equation produced from this historical sales regression to predict future
sales. However, EPA decided to use the regression results from a
second regression analysis in which the best estimate historical sales
were regressed with estimates of historical and projected population
estimates from the Bureau of Economic Analysis.(Z) Some regression
results predicted negative sales for a few equipment types. In those
instances, EPA assumed no change in future sales levels from the last
year for which historical sales were estimated. EPA's actual "best
estimates" of consumption are presented in Appendix F, Table F-02.
-------
10
8 -
6 -
CO
4 -
2 -
historical lawnmower sales
1973 1975 1977 1979 1981 1983 1985 1987 1989 1991
1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 After 19
EnginData +• OPEI
-------
Edgers/Trimmers
3 -
M
I 2
1 -
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData
BAH
A OPEI & PPEMA
B-13
-------
Chainsaws
(I)
I 2
I I I I I I I _l 1 L
J I L
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData ^ BAH A PPEMA |
^^4
-------
rear engine riders
500
400
300
o
200
100
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData * OPEI
*
B-15
-------
100
80
60
40
20
shredders/grinders/chippers |
o
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData » BAH I
-------
blowers/vaccuums
1500
1000
o
500
197319741975197619771978197919801981 1982198319841985198619871988198919901991 1992
EnginData ^ BAH
PPEMA
B-17
-------
i
I
1200
1000 -
800 -
600 -
400
200 -
lawn and garden tractors
(OPEI: riding garden tractors)
i i i i i i
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData » OPEI |
-------
snowblowers
1500
1000
tn
T>
500
_L
J_
J_
_L
_L
J_
J_
_L
_L
_L
_L
_L
_L
_L
J_
_L
J L
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData • OPEI
B-19
-------
w
TJ
O
1400
1200
1000 -
800
600
400
200
1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992
EnginData » OPEI. |
^K
-------
B-21
LAWNMOWER CONSUMPTION ESTIMATION
6500
6000
5500
5000
4500
4000
Q
Q
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
population regression
historical consumption regression
10
trenchers
Q I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression
-------
trimmers/edgers/cutters consumption estimate
B-22
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
population regression » historical consumption regression |
dumpers/tenders)
3500
3000
2500
2000
1500
1000
500
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
-------
B-23
chainsaw consumption estimation
c
o
3 -
2 -
1 -
-1
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression « historical consumption regression
en
T3
•c
railway maintenance equipment]
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression * historical consumption regression
-------
leafblower consumption estimation
B-24
0 "—C
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 '2028 2033 2038
US human population regression « historical consumption regression
skid steer loaders
-5 -
_10 i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
311
-------
B-25
generator set consumption estimation
1000
800
600
400
200
Q \ II I Ill 1 I I I I -I I I I I I I I I I I I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population regression « historical consumption regression
in
•a
c
aerial lifts
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression j
-------
800
600 -
400 -
200 -
tillers consumption estimation
B-26
-200
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population estimation * historical consumption estimation I
agricultural mowers
2500
2000
1500
1000
500
Q I I I I I I I I I I I I I I I I I I I I I I I M I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I' I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
-------
B-27
snowblower consumption estimation
1500
1000
o
500 -
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population regression » historical consumption regression
§
o
refrigeration/ac equipment
-2
I I I -I I II I I I I I Ill
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
-------
commercial turf
consumption estimation
B-28
800
600 -
1 400 -
200 -
1 I I I I I I I I I I I I I I 1 I I I I I I I I I I I I I I 1 I I I I I I I I I I I I I I I I t I I I I I I I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population
o historical consumption regression
aircraft support equipment
2000
1500
1000
500
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
-------
B-29
400
300
200
100
rear engine riders
consumption estimates
D
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population
historical consumption regression
2000
1500 -
1000 -
500 -
bore/drill rigs
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
-------
1800
1600
1400
1200
1000 -
800 -
600 -
lawn & garden tractors
consumption estimation
B-30
jnn I I I I I I I I I I I I I .I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population
historical consumption estimation
pavers
1500
1000
500
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression j
-------
B-31
400
300
I 200
100
pumps
consumption estimation
B a
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population
« historical consumption estimation
light plants/signal boards
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression * historical consumption regression
-------
shredders
consumption estimation
400
B-32
I I I I t I I I I I I III I I I I I I t I I I I I I ( I I I I I I I I I I I I 1 I I I I I I I I I I I I I I I I I I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population
historical consumption estimation
1200
1000
800
600
400
200
other agricultural equipment
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
-------
B-33
400
300 -
o
pressure washers
consumption estimation
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population regression » historical consumption regression
1200
1000
800
600
400
200
crushing/processing equipment
I I I I I I t I I I I I I I t ) i M I 1 I t I I I I I I I I I I I I I I I I I I I I I I I II I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression [
-------
O
120
100
80
60 -
40 -
20
carts
coin cion estimation
B
B-34
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population regression « historical consumption estimation
300
200 -
100 -
-100 -
-200
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
-------
B-35
120
100
80
60
40 -
20
air compressors
consumption estimation
U)
1
o
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
US human population regression * historical consumption regression
200
100
-100
-200
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression [
-------
80
60
3j 40
20
welders
consumption estimate
B-36
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
oil field equipment
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
-------
B-37
other lawn and garden equipment
consumption estimation
50
40
30
20
10
I 1 .!_ .1 .1 I I I I 1 1 1 I I I I I I I I I I I I I I _1_ i I I i I L. I_1_.1._L I t I I I I I 1 I I I I I I I I I I 1 1 I I I I
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression «• historical consumption regression
paving equipment
consumption estimation
so
40
30
20
10
o
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression j
-------
concrete/industrial saws
consumption estimation
B-38
50
40
30
20 -
10 -
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression •» historical consumption regression
50
40
30
sprayers
consumption estimation
o
K
20
10
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression *• historical consumption regression
-------
B-39
30
surfacing equipment
consumption estimation
20
o
10 -
U.S. human population regression * historical consumption regression
200
i
in
-100 -
-200 -
-300
woodsplitters
consumption estimation
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
-------
cement mixers
consumption estimation
B-40
50
40
30
1
20
10
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
specialty vehicles and carts
consumption estimation
40
30
20
10
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression j
-------
B-41
plate compactors
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression
10
tampers/rammers
tn
c
o
a
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression * historical consumption regression
-------
other general industrial
B-42
15
10
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression |
2 wheel tractors
I
D
O
j' a
a •
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression * historical consumption regression
-------
B-43
25
20
15
hydrolic power units
o
10
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression
scrubbers/sweepers |
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression j
-------
3
O
2 -
0 I—i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i i .iiii i
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression • historical consumption regression I
B-44
10
irrigation sets
I
o
6 -
4 -
O
•
1973 1978 1983 1988 1993 1998 2003 2008 2013 2018 2023 2028 2033 2038
U.S. human population regression » historical consumption regression
-------
B-45
B.4. Analysis of Fuel Consumption and Power Changes
The following tables present the spreadsheet analysis of the
estimation of changes in fuel consumption and power which may result
from this regulation. The methodology used was to derive a sales-
weighted estimate of any such changes.
-------
CALCULATION OF SALES WEIGHTED FUEL CONSUMPTION CHANGE
RESULTS:
Fuel Consumption Change
NHH
HH
-25%
-13%
PRE-CONTROL
1. CALCULATION OF % POPULATION FOR NHH & HH ENGINES
(Ref: PSR Engindata Database)
Class 1:
Class II:
Class III:
Class IV:
Class V:
6.234,570 515,849
1,821,659 394.804
SV OHV OTHER 2 STROKE
4.745 794.029
24,025 5.347
NHH:
484,290
5,879.834
365,989
HH:
9795026
6730113
SV OHV OTHER 2 STROKE
CLASS! 0.64 0.05 0.00 0.08
CLASS II 0.19 0.04 O.OQ 0.00
CLASS III - - - 0.07
CLASS IV - 0.87
CLASS V - 0.05
NOTE: Class I and II percentages are calculated with total nhh population
Class III-V percentages are calculated with total hh population
POST CONTROL
1. CALCULATION OF % POPULATION FOR NHH & HH ENGINES
(Ref: EPA estimated 1996 sales)
SV OHV OTHER 2 STROKE
6.569.239 975,209 4,745
1,827.005 394.804 24.025
NHH: 9795026
484,290
58,798 - 5,821,035
365,989 .
HH: 6730113
SV OHV OTHER 2 STROKE
0.67 0.10 0.00
0.19 0.04 0.00
0.07
0.01 - 0.86
0.05
NOTE: Class I and II percentages are calculated with total nhh populatior
Class III-V percentages are calculated with total hh population
Assumptions to engine design changes from Pre-Control Population Numbers are:
1. Class 12-stroke engines will not meet the NHH standard and therefore were split
50/50 between Class I SV and Class I OHV engines
2. Class II 2-stroke engines will not meet the NHH standared and are all placed
in with Class II SV engines
3. 1% of SV engines in Class I are sold as OHV
4. 1% of Class IV handheld engines convert to the new 4-stroke technology
G:\SMALLGAS\RSD\COST\COSTEST.WK3
B-46
-------
?. FUEL CONSUMPTION (g/kW-hr)
(see references for Table 1-11 in Chapter 1)
SY OHV OTHER 2 STROKE
Class 1: 830 603 603 854
Class II: 570 510 510 570
Class III: - - - 830
Class IV: - -- ~ 830
Class V: - -- - 560
NOTES: 1. Class III fuel consumptin is copied from Class IV fuel consumption
2. "Other" fuel consumption numbers are copied from "OHV"
3. FUEL CONSUMPTION x SALES WEIGHTING
SV OHV OTHER 2 STROKE
Class): 528.3 31.8 0.3 69.2
Class II: 106.0 20.6 1.3 0.3
NHH: 757.70
Class III: -- - -- 59.7
Class IV: -- - -- 725.1
Class V: - - -- 30.5
HH: 815.32
SV
600
520
0
0
0
OHV
430
520
0
253
0
2. FUEL CONSUMPTION (g/kW-hr)
(see references for Table 1-11 in Chapter 1)
OTHER 2 STROKE
430 0
520 0
0 720
0 720
0 529
NOTES: 1 . Class III fuel consumptin is copied from Class IV fuel cons
2. "Other" fuel consumption numbers are copied from "OHV"
3. FUEL CONSUMPTION x SALES WEIGHTING
SV QHV OTHER 2 STROKE
402.4 42.8 0.2 0.0
97.0 21.0 1.3 0.0
NHH: 564.65
51.8
2.2 -- 622.7
28.8
HH: 705.53
4. % CHANGE FROM PRE-CONTROL
SV OHV OTHER 2 STROKE
Class I: -24% 35% -29% -100%
Class II: -9% 2% 2% -100%
NHH: -25%
Class III: -13%
Class IV: -14%
Class V: -6%
HH: -13%
B-47
-------
CALCULATION OF SALES WEIGHTED FUEL CONSUMPTION CHANGE
RESULTS:
NHH
HH
Fuel Consumption Change
-25%
-13%
PRE-CONTROL
1. CALCULATION OF % POPULATION FOR NHH & HH ENGINES
(Ref: PSR Engindata Database)
SV OHV OTHER 2 STROKE
Class 1: 6,234,570 515,849 4,745 794,029
Class II: 1,821,659 394,804 24,025 5,347
NHH: 9795026
Class III: -- - -- 484,290
Class IV: - -- -- 5,879,834
Class V: - - - 365,989
HH: 6730113
SV OHV OTHER 2 STROKE
CLASS! 0.64 0.05 0.00 0.08
CLASS II 0.19 0.04 0.00 0.00
CLASS III '- -- -- 0.07
CLASS IV -- - - 0.87
CLASS V « - - 0.05
NOTE: Class I and II percentages are calculated with total nhh population
Class III-V percentages are calculated with total hh population
POST CONTROL
1. CALCULATION OF % POPULATION FOR NHH & HH ENGINES
(Ref: EPA estimated 1996 sales)
SV
OHV
OTHER 2 STROKE
6,569,239 975,209
1,827,005 394,804
58,798
4,745
24,025
NHH:
484,290
5,821,035
365,989
HH:
9795026
6730113
SV OHV OTHER 2 STROKE
0.67 0.10 0.00
0.19 0.04 0.00
0.07
0.01 - 0.86
0.05
NOTE: Class I and II percentages are calculated with total nhh population
Class III-V percentages are calculated with total hh population
Assumptions to engine design changes from Pre-Control Population Numbers are:
1. Class 12-stroke engines will not meet the NHH standard and therefore were split
50/50 between Class I SV and Class I OHV engines
2. Class II 2-stroke engines will not meet the NHH standared and are all placed
in with Class II SV engines
3. 1% of SV engines in Class I are sold as OHV
4. 1% of Class IV handheld engines convert to the new 4-stroke technology
B-48
-------
CALCULATION OF SALES WEIGHTED POWER CHANGE
RESULTS
NHH
HH
Power Change
5%
-3%
PRE-CONTROL
1. CALCULATION OF % POPULATION FOR NHH & HH ENGINES
(Ref: PSR Engindata Database)
Class 1:
Class II:
Class III:
Class IV:
Class V:
CLASS!
CLASS II
CLASS III
CLASS IV
CLASS V
sv
6,234,570
1,821,659
OHV
515,849
394,804
OTHER
4.745
24,025
2 STROKE
794.029
5,347
NHH:
484,290
5,879,834
365,989
HH:
9795026
6730113
SV QHV OTHER 2 STROKE
0.64 0.05 0.00 0.08
0.19 0.04 0.00 0.00
0.07
0.87
0.05
NOTE: Class I and II percentages are calculated with total nhh population
Class III-V percentages are calculated with total hh population
POST-CONTROL
1. CALCULATION OF % POPULATION FOR NHH & HH ENGINES
(Ref: EPA estimated 1996 sales)
SV OHV OTHER 2 STROKE
6,569,239 975,209 4,745
1,827,005 394,804 24,025
NHH 9795026
484.290
58,798 -- 5,821,035
365,989
HH 6730113
SV OHV OTHER 2 STROKE
0.67 0.10 0.00
0.19 0.04 0.00
0.07
0.01 -- 0.86
0.05
NOTE: Class I and II percentages are calculated with total nhh population
Class III-V percentages are calculated with total hh population
Assumptions to engine design changes from Pre-Control Population Numbers are:
1. Class 12-stroke engines will not meet the NHH standard and therefore were split
50/50 between Class I SV and Class I OHV engines
2. Class II 2-stroke engines will not meet the NHH standared and are all placed
in with Class H SV engines
3. 1% of SV engines in Class I are sold as OHV
4. 1 % of Class IV handheld engines convert to the new 4-stroke technology
(XJ
B-49
-------
2. POWER
(see references for Table 1 -11 in Chapter 1)
SV OHV OTHER 2 STROKE
Class 1: 0.9 0.9 0.9 1
Class II: 3.25 3.06 3.06 3.25
Class III: - - - 0.86
Class IV: - - -- 0.86
Class V: - -- - 2.28
NOTES: 1. Class III power is copied from Class IV power
2. "Other* power numbers are copied from "OHV
2. POWER
(see references for Table 1 -11 in Chapter 1)
SV OHV OTHER 2 STROKE
Class 1: 1.08 0.87 0.87
Class II: 3.06 3.01 3.01
Class III: - - -- 0.83
Class IV: - 1 -- 0.83
Class V: - - - 2.27
NOTES: 1. Class III power is copied from Class IV power
2. "Other" power numbers are copied from "OHV
3. POWER x SALES WEIGHTING
SV OHV OTHER
2 STROKE
0.57
0.60
0.05
0.12
Class 1:
Class II:
Class III:
Class IV:
Class V:
4. % CHANGE FROM PRE-CONTROL
SV
0.00 0.08
0.01 0.00
NHH:
0.06
0.75
0.12
HH:
Class 1:
Class II:
Class III:
Class IV:
Class V:
QHV OTHER 2 STROKE
26% 83% ^3% -100%
-6% -2% -2% -100%
NA
NHH:
HH:
-3%
-4%
-0%
1.44
0.94
5%
-3%
3. POWER x SALES WEIGHTING
SV OHV OTHER
2 STROKE
Class 1:
Class II:
Class III:
Class IV:
Class V:
0.72
0.57
0.09
0.12
0.01
0.00
0.01
NHH:
0.06
0.72
0.12
HH:
1.51
0.91
-------
B-51
B.5. Techoloav Cost Estimation
The following tables present the spreadsheet analysis of the
estimation of technology related costs due to the final regulation. These
costs include variable hardware costs, production costs and research and
development costs.
-------
B-52
The following tables present the spreadsheet analysis of the estimation of technolog
related costs due to the proposed regulation. These costs include variable hardware
costs, production costs and research and development costs.
I. DEVELOPMENT OF TECHNOLOGY MIX ESTIMATE TABLES
A. PRESENT MARKET % ESTIMATE FOR EACH CLASS
1. PSR "Engindata" Database. 1992 Sales
Class Side Valve OHV 2 Stroke Other TOTALS
I 8,052,156 613,380 1,039,798 12,608 9717942
II 2,183,681 570,401 13,847 26,526 2794455
III --- -- 340,596 -- 340596
IV --- — 3,598,296 --- 3598296
V — --- 337,565 11 337576
2. Calculated Percent in Each Class and Technology
IV
V
-Side Valve OHV
2 Stroke Other
83%
78%
—
___
—
6%
20%
—
_..
—
11%
0%
100%
100%
100%
0%
1%
—
0.00%
Note: Contents for "Other" Category
Class I
Class II
Class III
Class IV
Class V
Fuel Inj Water. SV Water. OH Alt Fuel
12,608
18,551 7,824 151
11
-------
B-53
B. ASSUMED MARKET % ON DATE OF FULL IMPLEMENTATION
1. Technology Mix Change Estimates Affecting Present Market %
Class I
sv -1% To Overhead Valve Engine Design
0.33 From 2 Stroke Design Engines
ohv 1% From Side Valve
0.67 From 2 Stroke Design Engines
2 stroke -x Prior to 2003. lawnmower and snowthrower
engines can meet hh stds for 1997 model year
(sales are limited to 1994 sales) and the upper limit
decreases 25% of 1994 sales each year and holds at 50%
In 2003, all 2 strokes must meet the nhh engine std
other No Change
Class II
sv 100% From 2 Stroke Design Engines
2 stroke -100%ToSV
other No Change
Class III No Change
Class IV 1 % To 4 Stroke OHV
Class V No Change
References:
1. Emission Test Data
SAE Papers: 910560,911222,911805,911806.911807,921696
1993 In-Use Test Program by Portable Power Equipment
Manufacturer's Association
2. Confidential discussions with engine manufacturers in 1993
-------
CALCULATION OF ENGINE/EQUIPMENT/TECHNOLOGY COMBINATIONS FOR IMPLEMENTATION YEAR (ASSUMED 1996)
NOTES:
1. ENGINE/EQUIPMENT/TECHNOLOGY 1992 sales combinations are available from PSR
2. Costs for ENGINE technologies apply to implementation year sales (implementation year assumed 1996)
3. EPA consumption estimates for 1996 EQUIPMENT sales were made for the implementation year in EPA's small engine nonroad model calculations
These pages present calculations to determine equipment sales percentages and corresponding engine technologies
1. Table of PSR data on equipment with corresponding 1992 sales of engines in each class and technology
2. Tabulation of percentage of engines in each class and technology
3. Application of percentages to 1996 equipment consumption estimates
A. PSR "Engindata" Database.1992
LAWNMOWERS
TRIM/EDGE/CUTTER
LEAF BLOW/VACS
CHAINSAW
GENTR SETS
TILLERS
SNOWBLOWER
COMM TURF
REAR ENG RIDER
LN/GDN TRACTORS
PUMPS
ALL OTHER EQUIP
TOTAL ENGINES:
(per Class and Tech)
Class I
sv
4274556
79804
35966
—
167347
261864
255957
22826
22140
8219
68957
2854520
8052156
B. Calculated %'s in Each Class and
LAWNMOWERS
TRIM/EDGE/CUTTER
LEAF BLOW/VACS
CHAINSAW
GENTR SETS
TILLERS
SNOWBLOWER
COMM TURF
REAR ENG RIDER
LN/GDN TRACTORS
PUMPS
ALL OTHER EQUIP
Class I
sv
81.95%
2.63%
13.84%
0.00%
37.94%
76.61%
44.47%
10.14%
5.90%
0.81%
45.77%
70.59%
Sales
OHV
412392
332
4974
—
4872
—
—
9182
—
—
3912
168243
603907
Technology
OHV
7.91%
0.01%
1.91%
0.00%
1.10%
0.00%
0.00%
4.08%
0.00%
0.00%
2.60%
4.16%
2-Stroke Other
529110
— —
—
—
—
13383
164426
2331
— —
— .
32574
297974 12608
1039798 12608
(Based on A.)
2-Stroke Other
10.14%
0.00%
0.00% —
0.00%
0.00%
3.92%
28.56%
1.04%
0.00%
0.00%
21.62%
7.37% 0.31%
Class II
SY.
—
551
16899
—
226567
66497
155253
142717
293060
805991
43152
451545
2202232
Class II
sv
0.00%
0.02%
6.50%
• 0.00%
51.37%
19.45%
26.97%
63.37%
78.04%
78.98%
28.64%
11.17%
OHV
—
—
161
—
39304
74
—
41771
60325
193106
1873
241611
578225
OHV
000%
0.00%
0.06%
0.00%
8.91%
0.02%
0.00%
18.55%
16.06%
18.92%
1.24%
5.97%
2-Stroke
—
—
—
—
—
—
—
—
—
—
182
13665
13847
2-Stroke
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.12%
0.34%
Other
—
—
—
—
2985
—
—
6369
—
13247
11
3763
26375
Other
0.00%
0.00%
0.00%
0.00%
0.68%
0.00%
0.00%
2.83%
0.00%
1.30%
0.01%
0.09%
Class III
2-Stroke
—
340596
—
—
—
—
—
—
—
—
—
—
340596
Class III
2-Stroke
0.00%
11.22%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Class IV
2-Stroke
—
2582511
201848
813937
—
...
—
—
—
—
—
—
3598296
Class IV
2-Stroke
0.00%
85.09%
77.68%
72.65%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Class V
2-Stroke
—
31220
—
306345
—
—
—
—
—
—
—
—
337565
Class V
2-Stroke
0.00%
1.03%
0.00%
27.35%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Total Per
Equipment
5216053
3035014
259848
1120282
441075
341818
575636
225196
375525
1020563
150661
4043929
16805605
-------
G, ERA 1996
LAWNMOWERS res
LAWNMOWERS prof
TRIM/EDGE/CUTTER res
TRIM/EDGE/CUTTER prof
LEAF BLOW/VACS res
LEAF BLOW/VACS prof
CHAINSAWS res
CHAINSAWS prof
GENTR SETS res
GENTR SETS prof
TILLERS res
TILLERS prof
SNOWBLOWER res
SNOWBLOWER prof
COMM TURF res
COMM TURF prof
REAR ENG RIDER res
REAR ENG RIDER prof
LN/GDN TRACTORS res
LN/GDN TRACTORS prof
PUMPS res
PUMPS prof
ALL OTHER EQUIP res
ALL OTHER EQUIP prof
sandResylti
m§!§ Tables.l
ng Classifies
B)
ition of Enain
esinQ|as§e
&and.Iechtil^^GrouDjs from Application Of Technology Percentages Calculated in
Class 1 Class II
J99g Total §y OHV 2-Slrote Other SY OHV 2-St
4537087
504121
3532130
783325
1513460
228737
882045
294015
109026
327079
204133
44810
382556
42506
0
259802
259707
13669
871431
45865
42307
126920
380102
1140306
5041208
4315455
1742197
1176060
436105
248943
425062
259802
273376
917296
169227
1520408
TOTAL ENGINES:
4194927
113472
241140
0
165461
193881
189004
27208
16118
7387
89346
1109778
6347723
530784
472
33349
0
4817
6579
0
12408
0
0
29091
138729
756229
315497
0
0
0
0
0
121416
0
0
0
0
0
436913
0
0
0
0
0
0
0
0
0
0
0
4740
4740
0
783
113302
0
224014
48429
114642
164648
213343
724436
48470
169769
1821837
0
0
1079
0
38861
54
0
48190
43916
173566
2104
90839
398609
\
-3L
Class III Class IV Class V r-y-
EKfi Other 2-Stroke 2-Stroke 2-Stroke Vo
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2951
0
0
7348
0
11907
12
1415
23633
0
484290
0
0
0
0
0
0
0
0
0
0
484290
0
3672046
1353326
854462
0
0
0
0
0
0
0
0
5879834
0
44391
.
0
321598
0
0
0
0
0
0
0
0
365989
-------
B-5b
III HARDWARE VARIABLE COST ESTIMATES
Hardware Variable Costs are costs for additional pans, materials or increasas in purchase prices of existing components added to engine
as a result of application of a technology
Costs are based on a limited amount of confidential information.
Summary of Cost Estimate oar Class par Engine
Class i SO 73 onor to 2003
Class I S1.82 after 2003
Class II $0 65
Class III S1.69
Class IV $1 92
Class V S2.37
Additional Cost for the
Catalyst Potion
Class I $132
Class II $0.00
Class ill $0.03
Class IV $0.03
Class V $0.03
A 1996 ENGINE CONSUMPTION ESTIMATES (from II.C1
Claw I Clan II ON* III dm IV CtneV
SY OHV ?-Slroka Qthaf SY OHV &Łlmka. Other 2-Stroke 2^SlmKB 2dSlmK»
6347723 756229 436913 4740 1827179 398609 0 23633 464290 5879834 365989
B APPLICATION OF TECHNOLOGY MIX ESTIMATES AND COST CALCULATIONS
Claw)
The Phase I njlemaking states that snowbtower engines may meet handheld standards.
The Phase I rulemaking states that all 2-stroke engines under a weight cap can also be considered handheld.
In 2003. 2 stroke engines must meet nonhandhetd standards. All of the other 2-stroke engine applications in Ctassee I and II
are assumed to be transferred to 4-stroke engine design. Therefore, the number of 2-stroke engines will be less than that estimated in 1996.
Number of Engines Estimated
SIDE VALVE das* I Sales (Post-Control) •
78% Enieanment with Maior Carb Adjustments
21 % Enieanment with Minor Can) Adjustments
50% Changes in Ignition Timing
95% Combustion Chamber Redesign
80% Valve System Improvements '
1% OHV w/minor carb
50% Improved Cooling
Qtiy. Class I Sales (1996) -
100% Enieanment with Minor Carb Adj
50% Improved Cooling
OTHER Class I Sales (1996) -
50% Fuel Carburetion Optimization
50% improved Cooling
6347723
with Taehnoloov
4951224
1333022
3173662
6030337
5078178
63477.23
3173862
756229
4740
756229
378115
2370
2370
ififfi.
$1.50
$0.50
No Cost
$0.10
$0.40
$0.50
$0.10
$0.50
$0.10
NO Cost
$0.10
8Q&
0
0
Cost for Engines
20% with Tachnoloov
$1,486,367.18
$133.302.18
$8.347.72
$75.622.90
2-STROKES Class I Sales (1996) - 436913
(2-strokes consist of lawnmower engines capped sales in 1994 * snowbtower sales»tillers. the rest are split in 4-strokes))
100% Enieanment with Major Carburetor Adjustments 436913 $0.00
100% Carburetor Limiter Cap 436913 $1.00
100% Combustion Chamber Redesign 436913 $0.10
100% improved Cooling 436913 $0.10
Class I Sales (2003) • 436913
100% Technology to reach nhh Phase I Class I emission standards 436913 $20.00
In 1996 and 1997. all 2 stroke lawnmowers (the amt sold in 1994) and snowbtowers and other nh categorized equip
are allowed to meet the hh standard (to: 2 wheeled titan). In 2003.2-stroke lawnmowwi must me* tt» nhh std.
This estimate assumes the 2-strokea win have • solution costing $20.00/engme in 2003. If no solution
is found by that time then it is assumed that 4-strokes win be used.
LABELS
All Engines
Engine Labeling
7545609
7545605 $0.04
TOTAL COST:
TOTAL! CLASS I ENGINES:
CLASS I COST/ENGINE:
$1.465.367.18
$133.302.18
$0.00
$603.033.69
$2.031.271.36
$6.347.72
$317.386.15
$75.622.90
$37.811.45
$0.00
$237.00
$0.00
$436.913.00
$43.691.30
$43,691.30
M73B260.00
$301.824.20
up to 2003 3003 and on
$5.516.499.43 '$13.730.463.83
7545605 7545605
0.73 1.82
-------
B-57
Class II
SIDE VALVE Class II Sales (1996) =
100% Enleanment with Minor Cart) Adjustments
100% Combustion Chamber Redesign
25% Improved Cooling
10% Changes in Ignition Timing
Class II Sales (1996)
100% Enleanment with Minor Carb Adj
50% Improved Cooling
OTHER
Class II Sales (1996) =
50% Fuel Carburetion Optimization
50% Improved Cooling
All Engines
Engine Labeling
Class III
2 Stroke Class III Sales (Post-Control)
100% Enleanment with Minor Carb Adjustments
100% Carburetor LJmiter Cap
100% Combustion Chamber Redesign
50% Improved Cooling
LABELS All Engines
Engine Labeling
ass IV
2 Stroke Class IV Sales (Post-Control)
.75% Enleanment with Major Carb Adjustments
25% Enleanment with Minor Carb Adjustments
50% Carburetor LJmiter Cap
75% Combustion Chamber Redesign
50% Improved Cooling
1% 4 Stroke Engine Design
LABELS All Engines
Engine Labeling
Class V
2 Stroke Class V Sales (Post-Control)
75% Enleanment with Major Carb Adjustments
25% Enleanment with Minor Carb Adjustments
93% Carburetor LJmiter Cap
100% Combustion Chamber Redesign
50% Improved Cooling
LABELS All Engines
Engine Labeling
Number of Engines Estimated
with Technology HVC
1827179
1827179 $0.50
1827179 $0.10
456795 $0.10
182717.9 . No Cost
398609
398609 $0.50
199305 $0.10
23633
11817 No Cost
11817 $0.10
2249421
2249421 $0.04
TOTAL COST:
TOTAL * CLASS II ENGINES:
CLASS II COST/ENGINE:
Number of Engines Estimated
484290 with Technology HVC
484290 $0.50
484290 $1.00
484290 $0.10
242145 $0.10
484290
484290 $0.04
TOTAL COST:
TOTAL * CLASS III ENGINES:
CLASS III COST/ENGINE:
Number of Engines Estimated
with Technology HVC
5879834
4409875 $1.50
1469958 $0.50
2939917 $1.00
4409875 $0.10
2939917 $0.10
56798
5879834
5879834 $0.04
TOTAL COST:
TOTAL « CLASS IV ENGINES:
CLASS IV COST/ENGINE:
Number of Engines Estimated
with Technology HVC
365989
274492 $1.50
91497 $0.50
338540 $1.00
365989 $0.10
182995 $0.10
365989
365989 $0.04
TOTAL COST:
TOTAL # CLASS V ENGINES:
CLASS V COST/ENGINE:
Cost for Engine
with Technolog
$913,589.50
$182,717.90
$45,679.48
SO.OO
$199,304.50
$19,930.45
$0.00
$1,181.65
$89.976.84
$1,452,380.32
2249421
$0.65
Cost for Engine
with Technolog
$242,144.96
$484,289.93
$48,428.99
$24,214.50
$19.371.60
$818,449.98
484290
$1.69
Cost for Engine
with Technolog
$6,614,812.90
$734,979.21
$2,939,916.85
$440,987.53
$293,991.68
$0.00
$235.193.35
$11,259,881.52
5879834
$1.92
Cost for Engine
with Technolog
$411.737.72
$45,748.64
-$338,539.90
$36,598.91
$18,299.45
$14.639.56
$865,564.18
365989
$2.37
ALYST OPTION
Class I
Class II
Class III
Class IV
Class V
# Engines HVC Cost Add'l Cost per Class
33% 2490050 $4.00 $9,960.198.60 1.32
0% 0
1% 4843
1% 58798
1% 3660
$3.00 $14,528.70
$3.00 $176,395.01
$3.00 $10,979.67
0.03
0.03
0.03
-------
B-58
IV.
PRODUCTION COST ESTIMATES
Production Costs are any additions or charges to production lines, tooling, etc. that is more than a one time cost (ie: not a one time die change).
This can include additional stations for new parts being added to an engine or increased maintenance and frequency of die replacement.
Costs are based on a limited amount of confidential information.
Summary of Cost Patimatag per Class per Engine
Class! $0.48 prior to 2003
Class I $0.50 after 2003
Class II $0.16
Class III $0.40
Class IV $0.25
Class V $0.39
Catalyst Option
Class I $0.00
Class II $0.00
Class III $0.00
Class IV $0.00
Class V $0.00
A. 1996 ENGINE CONSUMPTION ESTIMATES POST CONTROL
Claw I
SV
6347723
2-Stroka
756229 436913
Class II
Other SY. QHV
4740 1827179 398609
2-Stroka Other
0 23633
Class III Class IV Class V
2-Stroke 2-Stroke 2-Stroke
484290 5879834 365989
B APPLICATION QP TECHNOLOGY MIX ESTIMATES AND COST CALCULATIONS
For engine carburetkxi changes: estimated
80% mfr-d in-house, 20% outsourced
Class I
SIDE VALVE Class I Sales (Post Control) =
78% Enleanment with Major Garb Adjustments
21% Enleanment with Minor Carb Adjustments
50% Changes in Ignition Timing
95% Combustion Chamber Redesign
80% Valve System Improvements
1% OHVw/ minor carb
50% Improved Cooling
6347723
Number of Engines
with Technology
4951224
1333022
3173862
6030337
5078178
63477
3173862
Estimated
EC
80%.
Cost for Engines
20% with Technology
Class I Sales (Post-Control) =
100% Enleanment with Minor Cart Adj
50% Improved Cooling
2-STROKES
100% Enleanment with Major Carburetor Adjustments
Carburetor Limiter Cap
Combustion Chamber Redesign
Improved Cooling
756229
436913
100%
100%
100%
(2003)
100%
Estimated production cost with technology
756229
378115
436913
436913
436913
436913
436913
$0.20 792195.8
$0.20 213283.5
No Cost
$0.20
$0.20
No Cost
No Cost
$0.20 120996.6
No Cost
$0.20 69906.08
$0.20
$0.20
No Cost
$1.00 436913
$792.195.83
$213.283.49
$0.00
$1,206.067.37
$1,015.635.68
$0.00
SJLQfl
$120.
$69.906.08
$87.382.60
$87,382.60
$0.00
$436.913.00
OTHER Class I Sates (Post-Control) = 4740
50% Fuel Carouretton Optimization 2370
50% Improved Cooling 2370
LABELS All Engines 7545605
Engine Labeling 7545605
$0.20 474 $474.00
No Cost $0.00
$0.09 Inc in Admin Cos
prior to 2003 after 2003
$3,593,324.29 $3,785.566.01
7545605 7545605
$0.48 $0.50
TOTAL COST:
TOTAL * CLASS I ENGINES:
TOTAL COST/CLASS I:
-------
B-59
Number of Engines
with Technology
1827179
1827179
456795
634772
Class II
SIDE VALVE Class II Sales (Post-Control) = 1827179
100% Enleanment with Minor Carb Adjustments
100% Combustion Chamber Redesign
25% Improved Cooling
10% Changes in Ignition Timing
Qhy Class II Sales (Post-Control) = 398609
100% Enleanment with Minor Carb Adj 398609
50% Improved Cooling 199305
OTHER Class II Sales (Post-Control) = 23633
50% Fuel Carburetion Optimization 11817
50% Improved Cooling 11817
LABELS All Engines 2249421
Engine Labeling 2249421
Class III
2zSJaika Class III Sales (Post-Control) = 484290
100% Enleanment with Minor Carb Adjustments
100% Carburetor Limiter Cap
100% Combustion Chamber Redesign
50% Improved Cooling
LABELS All Engines 484289.9
Engine Labeling 484290
Class IV
Class IV Sales (Post-Control)
75% Enleanment with Major Carb Adjustments
25% Enleanment with Minor Carb Adjustments
50% Carburetor Limiter Cap
75% Combustion Chamber Redesign
50% Improved Cooling
1 % 4 Stroke Engine Design
LABELS All Engines
Engine Labeling
Class V
2-Stroke Class V Sales (Post-Control)
75% Enleanment with Major Carb Adjustments
25% Enleanment with Minor Carb Adjustments
93% Carburetor Limiter Cap
100% Combustion Chamber Redesign
50% Improved Cooling
LABELS All Engines
Engine Labeling
5879834
5879834
Number of Engines
with Technology
4409875
1469958
2939917
4409875
2939917
58798
5879834
365989
365989.1
Number of Engines
with Technology
274492
91497
338540
365989
182995
365989
Estimated
ŁC_
No Cost
$0.20
No Cost
No Cost
No Cost
No Cost
No Cost
No Cost
$0.09
TOTAL COST:
TOTAL * CLASS II ENGINES:
TOTAL COST/CLASS II:
Number of Engines
with Technology
484290
484290
484290
242145
Estimated
.EC.
No Cost
$0.20
$0.20
No Cost
$0.09
TOTAL COST:
TOTAL * CLASS III ENGINES:
TOTAL COST/CLASS III:
Estimated
.EC.
No Cost
No Cost
$0.20
$0.20
No Cost
No Cost
$0.09
TOTAL COST:
TOTAL # CLASS III ENGINES:
TOTAL COST/CLASS III:
Estimated
.EC.
No Cost
No Cost
$0.20
$0.20
No Cost
$0.09
TOTAL COST:
TOTAL * CLASS III ENGINES:
TOTAL COST/CLASS III:
Cost for Engines
with Technology
$0.00
$365,435.80
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
Inc In Admin Cos
$365.435.80
2249421
$0.16
Cost for Engines
with Technology
$0.00
$96,857.99
$96,857.99
$0.00
Inc in Admin Cos
$193,715.97
484290
S0.40
Cost for Engines
with Tachnologv
$0.00
$0.00
$587.983.37
$881,975.05
$0.00
$0.00
Inc In Admin Cos
$1,469,958.42
5879834
$0.25
Cost for Engines
with Technology
$0.00
$0.00
$67,707.98
$73,197.82
$0.00
Inc In Admin Cos
$140,905.80
365989
$0.39
CATALYST OPTION
Class I
Class II
Class III
Class IV
Class V
0 Engines PVC
33%
0%
1%
1%
1%
0
0
4843
58798
3660
$0.00
$0.00
$0.00
$0.00
$0.00
Catalysts will be produced by an outside source
-------
B-60
V. RESEARCH AND DEVELOPMENT COST ESTIMATES
Research and Development Costs are all research and development of technologies and application
to engine and associated costs with application (ie: prototype, testing, etc.). One time costs associated with
changes in tooling and dies is also included.
Costs are based on a limited amount of confidential information.
Summary of Cost Estimates per Engine per Tachnoloov Catalyst Option
Class I $10,803.000.00 Class! $320,000.00
Class II $10,000,000.00 Class II $0.00
Class III $72,500.00 Class III $20,000.00
Class IV $2.115,000.00 Class IV $20,000.00
Class V $2.812,500.00 Class V .$20.000.00
Notes:
Analysis of costs vary depending on the number of models in each technology per class and the sales of each model.
The following analysis uses the the number of models as a basis in order to maintain manufacturer confidentiality.
The variable nature of the small engine manufacturing processes for the wide range of engines allows itself to flexibility in this analysis.
Costs associated with work for previous engine regulations, ie: CARB, are estimated and subtracted from the total estimated cost.
The estimates may be overestimates due to application of changes to more than one model.
A. NUMBER OF MODELS IN EACH CLASS (Ret PSR "Enqindata" Database!
1992 PSR Engindata Database 1996 Estimate
CLASS I CLASS I
Side Valve 36 Side Valve 36
OHV 10 OHV 10
2-stroke 33 2-stroke 4
Other 1 Other 1
CLASS II CLASS II
Side Valve 93 Side Valve 93
OHV 42 OHV 42
2-Stroke 2 • 2-Stroke
Other 9 Other 9
CLASS III CLASS III
2-Stroke 1 2-Stroke 1
CLASS IV CLASS IV
2-Stroke 27 2-Stroke 27
CLASS V CLASS V
2-Stroke 15 2-Stroke 15
Notes:
Two stroke Class I and Class II engines are dropped based on the assumption that the models will not meet the applicable standards.
No additional models in any classes are added, for it is assumed that current production will pick up the removed sales volume.
Class II Other - 3 ohv water cooled, 6 side valve water cooled
-------
B-61
B. APPLICATION OF TECHNOLOGY MIX ESTIMATF!} AND COSTS CAICIILATIONS
Notes:
The analysis Is skewed based on several points: 1. The percentage of engine sates does not correspond directly to the number of models
2. Some of the models also use the same components, so not al models wH have to be worked on.
EPA requests actual cost data and comments on this methodology.
Clan I
SIDE VALVE OOF MODELS- 36
(Note: Assumed 80% of carburetors manufactured In-house by Class I engine manufacturers)
1.
OHV
1.
OTHER
1.
2-STRQKES
1.
78% Enteanment with Major Carb Adjustments
80% Manufacturer of Carburetors
Design carburetors
make prototypes and test engines
One time changes to existing tooling and dies
20% Non manufacture carburetors
work with carburetor manuf
One time changes to existing tooling and dies
21% EnteanmentwKh Minor Carb Adjustments
80% Manufacturer of Carburetors
Design carburetors
make prototypes and test engines
One time changes to existing toolng and dies
20% Non manufacture carburetors
work with carburetor manuf
One time changes to existing toolng and dies
50% Changes In Ignition Timing
Design Ignition Timing Changes, cams, etc.
Make prototypes, test engines, etc.
One time changes to existing toolng and dies
95% Combustion Chamber Redesign
Design new engine blocks and heads, pistons, etc
Make prototypes and test engines
One time changes to existing toolng and dies
80% Varve System Improvements
Design new cam, research new materials
BuU prototypes, test engkws and repeat
One time changes to existing toolng and dies
1% OHV w/minor cart
No cost - Just Increase In OHV production
50% Improved Cooing
Design cooing systems
BuU prototypes, test engines and repeat
One time changes to existing toolng and dies
* OF MODELS- 10
100% Enteanment with Minor Carb Adjustments
80% Manufacturer of Carburetors
Design carburetors
make prototypes and test engines
One time changes to existing tooling and dies
20% Non manufacture carburetors
Work wtti carburetor manufacturer
One time changes to existing toolng and dies
50% Improved Cooing
Design cooing systems
BuU prototypes, test engines and repeat
One time changes to existing toolng and dies
SOF MODELS- 1
50% FuelCarbureaonOpflrntzstton
Research and develop new program for fuel Injector chip
Develop prototypes and test engines, repeat
50% Improved Coofcig
Design cooing systems
BuU prototypes, test engines and repeat
One dme changes to existing toolng and dies
»OF MODELS- . 4
55% Major Carburetor Improvements
work wKh carburetor manuf
One Oma changes to existing toolng and dies
55% Combustion Chamber Redesign
Design new engine blocks and heads, pistons, etc
Make prototypes and test engines
One urne changes to existing toolng and dies
55% Improved Cooing
Design cooing systems
BuU prototypes, test engines and repeat
One time changes to existing toolng and dies
S/Model
$10,000.00
$10.000.00
'$10,000.00
$10,000.00
$10,000.00
$10,000.00
$10.000.00
$10,000.00
$10,000.00
$10,000.00
$10,000.00
$10.000.00
$20.000.00
$25,000.00
$25,000.00
$275.000.00
$10.000.00
$10.000.00
$50,000.00
$10,000.00
$10.000.00
Inc In Comb Cmbr
$10.000.00
$10,000.00
$10,000.00
$10.000.00
$10.000.00
$10.000.00
$10,000.00
$10,000.00
$10,000.00
$10.000.00
$10.000.00
$10.000.00
$10.000.00
$10.000.00
$10.000.00
$25,000.00
$29,000.00
$275,000.00
$10.000.00
$10,000.00
Inc In Comb Cmbr
TOTAL COST:
CARB COST:
PtaMlCaat
n of Mod Cost/Tech
22
2
18
34
29
0
18
2
5
0.50
0.50
2.2
22
22
$224.640.00
$224.640.00
$224,640.00
$56.160.00
$56.160.00
$60.480.00
$60.480.00
$60.480.00
$15.120.00
$15,120.00
$180.000.00
$180.000.00
$360.000.00
$855,000.00
$855.000.00
$9,405,000.00
$288,000.00
$288.000.00
$1,440,000.00
$180,000.00
$180,000.00
$80.000.00
$80,000.00
$80.000.00
$20,000.00
$20.000.00
$50.000.00
$50.000.00
$50.000.00
$5.000.00
$5.000.00
$5.000.00
$5.000.00
$5.000.00
$15,663.920.00
$22.000.00
$22.000.00
$55,000.00
$55,000.00
$605,000.00
$22.000.00
$22.000.00
$803.000.00
$16.466.920.00
$5,663.920.00
$10,803.000.00
-------
B-62
Claw II Note: assumed no angina manuf made cart's
SIDE VALVE * OF MODELS • 93
1 100% Enleanment with Minor Cart) Adjustments
Manufacturer of Carburetors
Design carburetors $10.000.00
maka prototypes and test engines $10.000.00
One time changes to existing tooling and dies • $10.000.00
2. 100% Combustion Chamber Redesign
Design new engine blocks and heads, pistons, etc $25.000.00
Make prototypes and test engines $25.000.00
One time changes to existing tooling and dies $275.000.00
3. 25% Improved Cooling
Design cooling systems $10.000.00
Build prototypes, test engines and repeat $10.000.00-
One time changes to existing tooling and dies (may be incorporate (COMB CHBR)
4. 10% Changes in Ignition Timing
Design Ignition Timing Changes, cams, etc. $10.000.00
Maka prototypes, test engine*, etc. $10,000.00
One time changes to existing tooling and die* $20.000.00
93
93
23
$930.000.00
$930.000.00
$930.000.00
$2.325.00000
$2.325.000.00
$25.575.000.00
$232.500.00
$232.500.00
$0.00
$93.00000
$93.000.00
$186.000.00
QHY «OF MODELS - 42
1. 100% Enleanment with Minor Carb Ad) 42
Manufacturer of Carburetors
Design carburetors $10,000.00 $420.000.00
make prototype* and test engine* $10.000.00 $420.000 00
One time change* to existing tooling and dies $10,000.00 $420.000.00
2. 50% Improved Cooling . 21
Design cooling systems $10.000.00 $210.000.00
Build prototypes, test engines and repeat $10,000.00 $210.000.00
One time change* to existing tooling and dies $10.000.00 $210,000.00
OTHER
1,
0 OF MODELS • 9
50% Fuel Carburetion Optimization
Research and develop new program for fuel injector chip
Develop prototype* and test engines, repeat
$10.000.00
$10.00000
50% Improved Cooling
Design cooling system* $10,000.00
Build prototype*, test engine* and repeat $10.000.00
One time change* to existing tooling and dies (may be incorporate $10.000.00
TOTAL COST:
GARB COST:
PhaMlCoat
Claw III
1.
2.
3.
* OF MODELS • 1
100% Enleanment with Minor Carb Adjustment*
Conduct research with carburetor manufacturer
Develop prototypes and test carburetors on bench an
100% Carburetor Limiter Cap
Develop finely adjustable needles (up to 3)
Purchase plastic cap for adjustment (RAD COST7?)
100% Combustion Chamber Redesign
Design new block
Make prototypes, test anginas and repeat
One time cost of changing die design and tooling change*
50% Improved Cooling
Design cooling system (additional fins, fans, etc.)
Build prototype* and tact
Claw IV
1.
2.
3.
4.
5.
6.
$30.000.00
$10.000.00
$5,000.00
$0.00
$30.000.00
$30.000.00
$20.000.00
$20.000.00
$20,000.00
TOTAL COST:
CARB COST:
PhMVlCMt
* OF MODELS- 27
75% Enleenment with Major Carb Adjustments
Conduct research with carburetor manufacturer $50.000.00
Develop prototype* and test carburetors on bench an $50.000.00
25% Enleanment with Minor Cvb Adjustments
Conduct research with carburetor manufacturer $30.000.00
Develop prototypes and test carburetors on bench an $10,000.00
50% Carburetor Limiter Cap
Develop finely adjustable needles (up to 3) $9.000.00
Purchase plastic cap for adjustment (R4D COST??) $0.00
75% Combustion Chamber Redesign
Design new block $30,000.00
Make prototypes, test engines and repeat $30,000.00
One time cost of changing die design and tooling changes . $20.000.00
50% Improved Cooling
Design cooling system (additional fins. fans, etc.) $20.000.00
Build prototypes and test $20,000.00
1% 4 Stroke Engine Design
Research, design, develop, build prototypes, teat engine*
(not a required technology, more like a company choice)
TOTAL COST:
CARB COST:
PhaMlCoat
45
4.5
0.5
20
14
20
14
$45.000.00
$45.000.00
$45.000.00
$45.000.00
$45.000.00
$35.967.000.00
$25.967.000.00
$10.000.000.00
$30.00000
$10.000.00
$5.000.00
$0.00
$30.000.00
$30,000.00
$20.000.00
$10.000.00
$10,000.00
$145.000.00
$72.500.00
$72,500.00
$1,012.500.00
$1.012.500.00
$202.500.00
. $67,500.00
$67.500.00
$607.500.00
$607.500.00
$405.000.00
$270.000.00
$270.000.00
$4.522.500.00
$2.407.500.00
$2.116,000.00
-------
B-63
Class V » MODELS* 15
1. 75% EnteanmefltwW) Major Cart) Adjustments n .25
Conduct research with carburetor manufacturer $50.000.00 $562.500.00
Develop prototypes and test carburetors on bench and engl $50,000.00 $562.50000
2. 25% Enteanmentwtth Minor Carb Adjustments . 3.75
Conduct research with carburetor manufacturer $30.000.00 $112.500.00
Develop prototypes and test carburetors on bench and engl $10.000.00 $37.500.00
3. 93% Carburetor Limner Cap • 13.875
Develop finely adjustable needles (up to 3) $5.000.00 $69.375.00
Purchase plastic cap for adjustment (RAD COST??) $0.00 . $0.00
4. 100% Combustion Chamber Redesign 15
Design new block $30.000.00 $450.000.00
Make prototypes, test engines and repeat $30.000.00 $450.000.00
One time cost of changing die design and tooling changes $20,000.00 $300.000.00
5. 50% Improved Cooling • 7.5
Design cooling system (additional fkis, fans, etc.) $20.000.00 $150.000.00
BuUd prototypes and test $20.000.00 $150.000.00
Toolrig costs Incoporated In comb cmbr redesign
TOTAL COST: $2.844.375.00
CARBCOST: SO 00
Phase I Cost $2.812.500.00
C. CATALYST OPTION
For al Classes, research and development wN be performed In conjunction win catalyst manufacturers
EstUseof *ofW
Catalysts PerC
Class) 33%
Class II 0%
Class III 1%
Class IV 1%
Class V 1%
todeto %x Total # of Models Est Cost Total Cost Per
lajj &pf Models Used for C Per Model Class
47
144
1
27
15
15.51
0
0.01
027
0.15
18
0
1
1
1
$20.000.00 $320,000.00
$20.000.00 $0.00
$20.000.00 $20.000.00
$20.000.00 $20.000.00
$20,000.00 $20.000.00
-------
Appendix B: References
1.
Power Systems Research, Engindata and PartsLink Databases, St. Paul
Minnesota, 1992
2.
U.S. Department of Commerce, Bureau of Economic Analysis, BEA Regional
Projections to 2040, Volume 3: BEA Economic Areas, Washington, DC, 1992.
R-64
-------
Appendix C: Baseline Emissions, In-Use Deterioration,
and Development of In-Use Emission Function
Information on in-use emissions from small SI engines is utilized in
EPA's efforts to quantify the emission benefits that would be realized,
through the adopted HC, CO, and NOX emission standards for new
small nonroad SI engines, as presented in Chapter 4 Environmental
Benefits. This chapter presents supporting information to the
assumptions on in-use deterioration estimates for each class and small SI
engine design as well as background to the development of the in-use
emission equation estimate for pre-control engines and post-control
engines used to calculate engine emissions at each year along an
engine's useful life.
EPA also considered setting in-use emission standards as part of this
rule. While the data available are adequate to adjust the inventory for
the various in-use effects, sufficient data are not available to set in-use -
emission standards at this time.
C-l
-------
C-2
C.1. Baseline and In-Use Emissions Estimates for Pre- and Post
Control Engines
The category of small SI engines consists of a wide variety of engines
utilized in a wide range of equipment which are used by people, in both
residential and professional settings, with unique usage and
maintenance habits. In-use emissions deterioration of small SI engines
is influenced by several variables including engine design, engine
quality, the manner in which and where the equipment is used as well
as how well the engine and equipment is maintained and stored.
Some of the variables, such as engine design and engine quality, are
directly influenced by the regulation, however factors such as user
maintenance and use habits are not directly affected.
EPA estimates that the rule will result in many of the designs and
features of higher cost engines being incorporated in lower cost engines
in order to meet the emission standards. The features that result in
reduced emissions such as more rigid cylinders and closer tolerances are
the same features currently used to increase performance and durability
on higher quality engines. These changes are estimated to reduce in-use
emission deterioration. On the other hand, in-use emissions of a
regulated engine may be a greater percentage of a new engines total
lifetime emissions due to the lower new engine emissions.
Unique user habits, including the manner in which and where the
equipment is used as well as how well the engine and equipment is
maintained and stored, effects engine in-use emissions deterioration.
For example, a user that routinely keeps the fins on the engine block
free from debris will allow the engine to maximize the use of one of its
cooling mechanisms, thereby allowing the heat to transfer away from
the engine block and keep component tolerances in an acceptable range.
This contributes to a more efficiently running engine by reducing the
-------
C-3
change for engine damage, such as burnt piston rings. Ho.wever, user
habits vary widely and thus adds an unpredictable variable in the task
of estimating small engine in-use emissions deterioration.
All of these factors affect the ability to predict in-use emission
deterioration for the engines covered by this rule. The following
discussion presents EPA's methodology to estimate baseline and in-use
deterioration estimates for pre and post control engines while keeping in
mind all factors just mentioned.
C.1.1. Determination of Baseline Emissions and In-Use Deterioration
Estimates for Pre-Control Engines
The baseline and in-use emissions estimates for pre-control engines
in this analysis were based on information presented in the EPA's 1991
Nonroad Vehicle and Emission Study Report and Appendices(l) and the
California Air Resources Board Technical Support Document for their
Lawn and Garden Regulation(2). Information from SAE technical
papers(3), and industry submitted engine emission data(4)(5)(6)(7)(8)(9)
was utilized to fill in holes and support or suggest changes to the
existing information from the 1991 Nonroad Study and CARB technical
support document
The 1991 Nonroad Study presents baseline and in-use emission
numbers per small SI equipment type. Table C-01 presents the baseline
emissions, in-use emissions and resulting factors from the nonroad
study for equipment utilizing 2- and 4-stroke engines. The choice of
equipment categories represents the most popular usages of small SI
engines with the category of All Other Equipment containing
miscellaneous applications.
Baseline emissions for engine Classes I-V and engine design
characteristics (i.e., side valve, overhead valve and 2-stroke) within those
classes cannot be obtained directly from information from the 1991
-------
C-4
Nonroad study emissions per equipment types. The equipment types
contain engines with a number of different engine designs, which result
in different emission characteristics, and can be spread over several
engine Classes. Baseline emissions for Class I and II engines were taken
from CARB's technical support document(lO) which were also utilized
in EPA's 1991 Nonroad Study. The CARB technical support document
and its sources did not provide emissions break out for engines in
Classes III-V. Classes IV and V were based on industry data utilized in
the Heiden report(ll). Class III engines were assumed to have similar
emission characteristics to Class IV engines and therefore estimates for
Class IV were utilized for Class III. Table C-02 contains the summary of
baseline emissions assigned to each class and technology within each
class.
In-use emissions were calculated by applying deterioration factors to
baseline emissions. Deterioration factors per equipment were
determined from those numbers utilized in EPA's 1991 Nonroad Study
and those calculated from information collected by industry and EPA
after publication of the Study. Industry information provided further
validation for the choice of some of the in-use deterioration estimates
utilized in the Study as well as provide a basis for changing a few of
the deterioration estimates. Hydrocarbon deterioration factors for 2-
stroke handheld engines, presented in Table C-01, were adjusted from
2.1 to 1.2 based on industry submitted data and EPA analysis. Industry
data, presented in C.3 In-Use Pre-Control and Post-Control Engine
Testing and Table C-12, indicate that 2-stroke emissions deteriorated less
than 2.1 percent times that of new engine emission numbers as indicated
by the study. Industry data was collected by an accelerated
accumulation of in-use operation time on engines with emission taken
at interval points. EPA estimated that the numbers may represent
professional use of the engines and related equipment due to the fast
-------
C-5
accumulation of operation hours. However, this simulation of in-use
operation may result in low estimates for consumer usage patterns
which would include effects of maintenance and time effects, such as
usage of old fuel or malmaintenance. The second change made to the
study numbers was the change of HC and NOX deterioration estimates
of 2-stroke engines used in pumps from 2.1 to 1.2 for HC and .4 to 1.0
for NOX. This was done to keep consistency with other like engines.
The deterioration factors were then determined for each Class of
engines broken out by OHV, SV and 2-stroke, 4-stroke. Deterioration
factors presented in Table C-01 for 4-stroke and 2-stroke engine
equipment were applied to the corresponding engine Classes and engine
designs. For example, 4-stroke equipment deterioration factors were
applied to Class I 4-stroke OHV engines and 2-stroke equipment
deterioration factors were applied to Class III 2-stroke engines. The
deterioration factors for each Class and engine design are shown in
Table C-03. Distinction in relative in-use emissions for various engine
designs, i.e., side valve, ohv, 2-stroke, is found when the deterioration
estimates are multiplied by the new engine emission numbers, i.e.,
baseline, which are different for each engine design. The resultant pre-
control engine Baseline and Minimum In-Use Exhaust Estimate utilized
in EPA's analysis is summarized in Table C-04.
C.1.2. Determination of Baseline and In-Use Deterioration for Post-Control
Engines
Baseline emissions and in-use deterioration factor estimates for post
control engines were based on adopted emission standards and a •
calculation of deterioration from pre-control engines. The expected mix
of emission reduction technologies are presented in technology market
mix Tables 2-02 and 2-03 in Chapter 2-Technology Market Mix and Cost
Estimates for Small SI Engines and Related Equipment. The following
-------
C-6
summarizes expected changes in in-use emission deterioration for small
SI engines.
The Agency assumed that all engine designs within each class would
start with the same new engine emission number, i.e., the respective
emission standards, in each class. Table C-05 lists baseline numbers to
the corresponding engine classes and engine designs. Two- stroke
engines in Classes I and II were assumed to transfer to 4-stroke side
valve and overhead valve designs. The explanation for other classes
and technologies are as follows.
Class 1 side valve engines are expected to utilize enleanment to
reduce emissions. Emission data on Class I OHV engines show a 50/50
split in HC and NOX (Table 2-05 in Chapter 2). EPA expects that the
same result applies to enleaned side valves. As a result, the 16 g/kw-hr
standard is split with 8g/kw-hr for HC and 8 g/kw-hr for NOX. The
CO standard is set as the exhaust limit for these engines based on data
which shows the CO limits of pre-control engines are higher than the
standard. It is expected that enleanment will cause CO to be reduced.
Class II OHV engines already meet the standards and as a result, it
is expected that their emission values will not change. For side valve
engines, it is expected that enleanment and other minor engine changes
will occur that will result in a 70% of the standard being HC and 30% of
the standard for NOX.
Classes III-V post-control engine baseline numbers are based on the
emission standards. Class IV 4-stroke handheld engine emission
numbers were provided by one engine manufacturer.
The post control technologies were then analyzed to determine if in-
use deterioration would increase or decrease based on EPA's knowledge
of the technologies. Refer to C.3 In-Use Pre-Control and Post-Control
Engine Testing for an in-depth discussion.
Expected emission reduction technologies consist of engine structure
-------
C-7
(e.g., more rigid cylinder walls, tighter tolerances, etc.) and production
changes that will tend to improve engine performance quality, and
emission reduction strategies such as enleanment, valve and ignition
timing and possible use of catalysts. As a result, EPA estimates that
improvements in engine structure and production practices tend to
increase component life and thus in-use deterioration to post control
engines would be the same or less than occurs to pre-control engines.
At the same time, emission control strategies such as enleanment or
limited use of catalytic converters could marginally increase the rate of
deterioration of post-control engines if not optimized. Based on the
limited amount of available data of in-use emissions on post control
engines (Tables C-ll and C-12) and EPA's technical assessment of
directional change in deterioration, EPA decided it reasonable at this
time to estimate the same deterioration amount as was seen in pre-
control engines.
EPA assumed that the deterioration of pre-control engines is additive
to post-control engines baseline emissions and the amount of
deterioration will not change based on the technologies that will be
utilized for meeting emission standards. Therefore, Minimum In-Use
Exhaust Estimates for post-control engines are calculated by taking the
difference of the in-use and new engine emission levels from pre-control
and adding that number to the post control baseline numbers.
C.2. EPA Development of Emissions Deterioration Equation for
Environmental Benefit Analysis
EPA's analysis for Chapter 4 on Environmental Benefit considers
emissions deterioration over a period of time. As a result, a function is
constructed to provide emission numbers for each year over the
specified number of years for pre- and post-control engines.
Information from the emission factors presented in sections C.I.I, and
-------
C-8
C.I. 2. and EPA and industry in-use emission collection test data were
utilized to determine the emission equation.
EPA's 1991 Nonroad Study calculations of in-use emission
deterioration utilized a straight line deterioration from new engine
emission levels to end of useful life emission levels with the average
deterioration representing the emission factors presented in Table C-01.
For example, small 4-stroke engines, such as lawnmowers, were
portrayed to emit an average of 2.1% times increase for HC, a 1.9%
times increase for CO and a decrease of 60% for NOX over its new
engine emission levels for its entire useful life.
Additional in-use emission data collected by EPA and industry since
the study, Tables C-8, C-9, C-ll and C-12, indicates that the in-use
emissions deterioration was very random, however showed a general
trend to increase more rapidly at the beginning of an engines useful life
and then stabilizes to the end of its useful life (Figures C1-C4). Thereby
data would correlate better to an exponential curve rather than a linear
line as utilized in the 1991 Nonroad Study. As a result, an exponential
function was developed to represent emission deterioration and was
formulated as follows (hydrocarbons (HC) is used as an example)
HC=HCin.use+ (HCin.use - HC new)(l-e-ase/(B50'3>)
where:
- Hydrocarbon Emission numbers for new engines
(pre-Table 4, post-Table 5)
HCin.use - Hydrocarbon Minimum In-use Estimates (pre-
Table 4, post-Table 5)
age - Number of Years After New
B50 - Implied 650 from Attrition Constants (Weibull
Function) (see Chapter 4 Environmental Benefits)
Concerns for differences in use by consumer and professional users
-------
C-9
are considered in Chapter 4 Environmental Benefits through use of
usage rates of hours/yr and estimated useful lives. The quality of the
engine is distinguished in estimates for HCnew and
C.3 In-Use Pre-Control and Post Control Engine Testing
Since 1991, EPA and industry have been involved in individual
testing programs to collect emission data on in-use small SI engines.
EPA conducted an in-use emissions program at Southwest Research
Institute on four walk-behind mower engines and a string trimmer
engine in 1991 which was utilized for EPA's 1991 Nonroad Study (Table
C-08 and C-09). In 1993, two small engine test cells were established
and operated to perform emission tests including testing of in-use
engines. The labs were at EPA's National Vehicle Fuel Emissions
Laboratory (NVFEL) and at the University of Michigan's Walter E. Lay
Automotive Laboratory through a Cooperative Research Agreement
with EPA (Appendix A). Emissions testing of pre and post-control in
Classes I and II was performed through an industry program and
shared with EPA (Table C-ll). Emissions testing of pre and post-control
engines in Classes III-V was performed through an industry program
and shared with EPA, as stated previously in C.I.I, and presented in
Table C-12. Initial analysis of the test data has shown that in-use
emissions from small SI engines is variable. Many factors influence the
result including the variety of engine quality currently being
manufactured, varieties in engine carburetors (adjustable and fixed jet),
engine quality control during manufacture, user engine maintenance
and amount of equipment use.
Many holes exist for in-use data on post control engines, as a result,
engineering judgment is used as a tool to estimate in-use emission
deterioration changes based on technologies. Section C.3.1. presents
assumptions made for estimating engine deterioration for HC, CO and
-------
C-10
NOX pollutants in various engine designs for Classes I and II. C.3.2.
presents assumptions made for same in Classes in-V. Expected engine
changes are presented in technology market mix tables in Chapter 2
Technology Market Mix and Cost Estimates for Small SI Engines and
Related Equipment. Combinations of several of the technologies will
most likely be used on the majority of engine models with smaller
displacement engines requiring more than one emission reduction
technology more often than larger displacement engines. The trade-offs
in in-use emission deterioration are assumed to be of no significance. In
summary, EPA estimates that the in-use deterioration for post control
engines will1 be less variable than pre-control engines due to factors
including improvements in quality control during engine and carburetor
manufacture and more uniform use of combustion efficient engine
designs amongst engine manufacturers.
-------
C-ll
C.3.1 Estimated Emission Deterioration per Technology for Classes I and II
Due to the limited number of available test results of in-use
emissions from post-control engines, engineering judgement is used to
provide a best guess on the effect of each emission reduction technology
on in-use emissions deterioration. The following is a description of such
for each technology.
C.3.1.1. Enleanment with Major redesigns to carburetor and fuel
distribution system and Enleanment with Minor redesigns to carburetor-
Enleanment requires the addition of other emission reduction
technologies in order to reduce the effects of engine wear. Addition
technologies such as improved cooling and optimization of materials
can be used to enhance heat transfer from the engine combustion
chamber and related components. Deterioration can occur from the
expansion of engine component materials beyond acceptable tolerance
ranges for proper engine operation and improper valve seating due to
warped engine block mating surfaces. Enleanment may result in
slightly harder starting and higher temperatures, however, it is expected
that the affect will be minimized due to redesign of the carburetor to
inject additional fuel when required.
OHV engines are estimated to require less degree of enleanment to
meet emission standards. In addition, the portion of overhead valve
engines which utilize enleanment with minor modifications to
carburetor are expected to experience little to no change in engine wear
due to less fuel cooling available to the engine. This will not result in
increased valve/seat sealing for the combustion cylinder is not directly
linked to the valve seat area.
Alternative fueled engines and fuel injected engines are estimated to
utilize fuel carburetion optimization. This may also result in an
enleaned engine for which the manufacturer will have to make
-------
C-12
compensation for harder starting and higher combustion temperatures.
However, the changes may be so slight as to not affect the engine
deteriorating negatively.
C.3.1.2. Changes In Ignition timing, valve timing-Changing the
ignition timing before top dead center will result in more efficient
burning of the fuel. Thereby emission deterioration is expected to be no
greater than current engines.
C.3.1.3. Combustion Chamber Redeslgn-Combustion chamber
redesign is estimated to include tighter tolerances and restructuring of
the engine block for stiffer cylinders and better heat transfer for less
valve seat warping. Deterioration is expected to remain constant or
decrease due to tighter tolerances of piston within the cylinder wall.
C.3.1.4. Valve System Improvements Including Valve Timing-Valve
system improvements are estimated to include of the addition of valve
guides where none exist, tighter tolerances between valve guides and
valve stems, improvements in valve cam design, better quality materials
for valves and optimization of valve timing. In-use emission
deterioration is expected to remain unchanged from current engines.
C.3.1,5. OHV with minor mods to carburetor-This technology
change is estimated to be for Class I side valve engines only. Therefore,
in-use emission deterioration would be the same as this technology for
overhead valve engines with minor modifications to the carburetor as
presented in C.3.1.1.
C.3.1.6. Improved Coollng-This technology is estimated to be
utilized on a portion of each engine Class to reduce engine deterioration
-------
C-13
from the use of enleanment. Improved cooling is expected to include
increased fin area on the engine block and redesign of air from fan for
maximum cooling. Neither of these changes affect combustion
processes of the engine however do influence, indirectly, the amount of
temperature seen in the combustion chamber. No deterioration of these
parts are expected. However, user use of the engine and equipment
may result in some blocking or covering of fin surface area, thereby
reducing the available space for cooling.
C.3.1.7. Conversion of 2 Stroke to 4 Stroke Engine Design—Four-
stroke technologies exist for the applications in which 2-stroke engines
are utilized. As a result, EPA estimates that 2-stroke engine designs will
convert to 4-stroke engine designs due to the difficulty of the 2-stroke
meeting Class I and Class II emission standards. EPA estimates that
this will result in changes of emission deterioration from 2-stroke
characteristics to 4-stroke characteristics. Two-strokes have fewer
moving parts than the 4-stroke counterparts which have valve systems.
Two-stroke engines are also run extremely rich and as a result may or
may not result in the observation of emission deterioration except due
to decreased power which may result from inefficient combustion. This
results in a higher g/kw-hr number.
C.3.1.8. OPTION: Catalyst-Based on discussion with catalyst
manufacturers and information provided at the SAE Fuels and
Lubricants Conference in 1993, EPA expects that catalysts used on small
engines will deteriorate in-use. EPA has incorporated a durability
demonstration requirement in this rulemaking, see Chapter 1, for all
catalysts utilized on small SI engines. EPA feels the durability
demonstration requirement will ensure that catalyst deterioration is
reasonable.
-------
C-14
The catalyst may deteriorate quickly if oil is emptied into the catalyst
by tilting the engine such that oil drips into the catalyst. Oil may also
enter the catalyst each time the engine is used and shut off for fuel and
oil do enter and exit the engine as the engine is winding down. Four-
stroke engines generally use ash oils which poison the catalyst. These
factors influence the emission deterioration by providing an emission
reduction technology which may have a limited useful life of its own.
This thereby sways the in-use estimate for side valve engines close to
the present engine level for deterioration. EPA estimates that engines
utilizing catalysts will also require a majority of the previous
technologies applied to the engine design in order to reduce the
required amount of conversion for minimum heat exotherms. As a
result, the same deterioration for engines without catalyst is used for
engines with catalyst.
C.3.2. Estimated Emission Deterioration per Technology for Class III-V
Engines
Two-stroke handheld engines have very few moving parts, however,
they have been shown to encounter exhaust port dogging due to excess
fuel exiting the combustion chamber unburned. The quality of the
engine has indicated how long the engine will last with power loss
being one of the main contributors to increases in emissions on pre-
control engine designs. Chapter 2 shows that similar technologies are
utilized on all three engine classes. As a result, each technology is
described with some general references to each class where appropriate.
C.3.2.1. Major and Minor Carburetor Modifications-Handheld 2-
stroke engines operation can be sensitive to carburetor settings when
utilized in under a wide variety of conditions such as temperature,
humidity and altitude. Many engine designs will convert to fixed jet
-------
C-15
carburetors to reduce the production costs of adding a limiter
adjustment cap. In-use emission deterioration will be limited due to the
shortened or nonexistent ability of the user to adjust the carburetor to
leaner or richer mixtures. This is estimated to decrease emission
deterioration for the user will submit the engine to increased
maintenance in order to obtain acceptable operation when plugging
occurs in the engine carburetor or air filter. Enleanment also reduces
exhaust port plugging which results in reduced emission deterioration.
C.3.2.2. Carburetor Limiter Adjustment Caps-Adjustment limiter
caps are utilized to restrict the range of carburetor adjustment that the
user may access in order to keep the engine in compliance with
emission regulations. This adjustment will only occur at time of
maintenance. EPA estimates there will be no deterioration of the
limiting cap or mechanisms that are used to perform this function.
C.3.2.3. Combustion Chamber /Scavenging/Port Timing Modifications-
Better fuel transfer or the addition of third ports in the combustion
cylinders are possible technologies for this heading. Chamber designs
to reduce scavenging may result in smaller exhaust ports to increase
backpressure in the chamber thereby forcing less raw fuel through the
engine. Smaller exhaust ports may result in more frequent exhaust port
plugging which will require the user to clean it out more frequently or
take it in for service to be cleaned. This may well be offset by reduced
port plugging due to the enleaned fuel mixture. Port timing
modifications will reduce fuel/oil scavenging as the timing of the
opening of inlet and exhaust ports with the position of piston during
power strokes is optimized. EPA estimates that this will not contribute
to increased in-use engine emissions.
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C-16
C.3.2.4. Cooling Improvements-Cooling improvements are
expected to consist of those mentioned for Class I and II engines which
include the reduction in wear of other components. No deterioration of
cooling components is expected.
C.3.2.5. 4-Stroke~This is a new engine technology expected on
the market in 1994. EPA has no test data on in-use deterioration
characteristics of this engine, however, it is estimated that the engines
that utilize this technology will have similar emission in-use
deterioration to other 4 stroke engines.
C.3.2.6. OPTION: Catalyst-Only a small portion of engines may
choose to use catalyst as an option. In-use emission deterioration
Engines with catalyst are expected to be similar to those for Class I and
II engines. EPA has estimated that engines utilizing catalyst will have
made all of the prior technology changes before utilizing catalysts and
as a result, the same deterioration for engines without catalyst is used
for engines with catalyst.
Based on discussion with catalyst manufacturers, EPA expects that
catalysts used on small engines will deteriorate in-use. EPA has
submitted a durability demonstration requirement in this rulemaking,
see Chapter 1, for all catalysts utilized on small SI engines. EPA feels
the durability demonstration requirement will ensure that catalyst
deterioration is reasonable.
The following is a summary for each regulated pollutant:
• HC: For many engine designs, the carburetors will be fixed jet
which thereby results in much less variability in emissions from use
in the real world. Tolerances will be improved thereby increasing
-------
C-17
the efficiency of burn and reducing scavenging in both 2- and 4-
stroke side valve engine designs. The use of better materials and
quality control is expected to yield less HC deterioration. The
optional catalyst use will result in in-use emission characteristics of
engines with other changes and therefore will not go to present pre-
control emission levels if the catalyst should fail.
CO Deterioration of CO is estimated to be limited due to the use
of fixed carburetor jets and limiter caps on adjustable carburetors.
Small engine equipment owners will increase frequency of
maintenance due to the inability enrich or enlean the engine. NOx:
As seen for pre-control engines, NOx is estimated to decrease as the
engine ages, thereby resulting in favorable emission deterioration for
NOX.
0
-------
Table C-01
Baseline and In-Use Emission Numbers from EPA's 1991 Nonroad Study(12)
EQUIPMENT CATEGORY
BASELINE
(g/kW-hr)
HC
CO
NO,
IN-USE
(g/KW-hr)
HC
CO
NO.
4-STROKE ENGINES
Lawnmowers
Trimmers/Edgers/Brush Cuners
Chainsaws
Leaf Blowers/Vacuums
Generator Sets
Tillers
S no wb lowers
Commercial Turt
Rear Engine Riders
Lawn and Garden Tractors
Pumps
All Other Equipment
2-STROKE ENGINES
Lawnmowers
Trimmers/Edgers/Brush Cutters
Chainsaws
50.5
32.41
NA
26.01
12.73
50.54
50.54
12.6
12.47
12.6
12.47
576.4
527.27
NA
509.79
473.19
576.41
576.41
474.53
473.19
474.53
473.19
2.71
2.71
NA
2.72
2.72
2.71
2.71
2.83
2.72
2.83
2.72
106.13
68.07
NA
54.61
26.74
106.13
106.13
26.46
26.18
26.46
26.18
1095.17
1001.81
NA
968.59
899.06
1095.17
1095.17
901.61
899.06
901.61
899.06
1.09
1.09
NA
1.09
1.09
1.09
1.09
1.13
1.09
1.13
1.09
278.82
301.01
399.46
486
728.22
699
.39
1.22
1.29
585.52
632.14
842.9
1237.8
1854.72
1780.29
.39
1.22
1.29
IN-USE FACTOR
HC
2.1
2.1
CO
1.9
1.9
NO,
0.4
1.0
ADJUSTED IN-USE FACTORS
HC
2.1
1.2
CO
19
1.9
NO,
0.4
1.0
C-18
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C-19
EQUIPMENT CATEGORY
Leaf Blowers/Vacuums
Generator Sets
Tillers
Snowblowers
Commercial Turf '
Rear Engine Riders
Lawn and Garden Tractors
Pumps
All Other Equipment
BASELINE
(9*W-hr)
HC
288.59
278.82
278.82
278.82
278.82
NA
NA
5.74
CO
716.81
486
486
486
486
NA
NA
113
NO,
1.29
.39
.39
.39
.39
NA
NA
9.44
IN-USE
(g/kW-hr)
HC
606.05
585.52
585.52
585.52
585.52
NA
NA
12.05
CO
1825.66
1237.8
1237.8
1237.8
1237.8
NA
NA
287.8
NO,
129
.39
.39
.39
.39
NA
NA
3.78
IN-USE FACTOR
HC
2.1
CO
1.9
NO,
.4
ADJUSTED IN-USE FACTORS
HC
1.2
CO
1.9
NO,
1.0
NA = Not Applicable
Note: All Other Equipment include the following: Distributed Loose Engines, Commercial Turf Equipment, Other Lawn and Garden, Wood Splitters, Pressure Washers, Front Mowers, Welders, Specialty Vehicles
and Carts, Shredders, Cement/Mtr Mixers, Golf Carts, Paving Equipment, Air Compressors, and Sprayers.
-------
Table C-02
Pre-Control Engines
New Engine Baseline Numbers
CLASS
Class 1
Class II
Class III
Class IV
Class V
Engine Design
Side Valve
Overhead Valve
2-Stroke
Side Valve
Overhead Valve
2-Stroke
2-stroke
air-cooled
2-stroke
air- cooled
2-stroke
air-cooled
HC
g/kW-hr
52.3
18.0
279
12.9
6.97
(279)
(350)
350
214
CO
g/kW-hr
578
548
651
463
681
(651)
(964)
964
696
NO,
g/kW-hr
2.68
2.4
.389
2.75
4.69
(.389)
(1.26)
1.26
(1.26)
Reference
CARB
CARS
SAE 910560
CARB
CARB
(Class I -
2- Stroke)
(Class IV -
2-Stroke)
Industry Data
Industry Data
(NO,:Class IV
- 2-Stroke)
Key:
(xxx) means the no data was available, therefore numbers were implied from other classes and categories
CARB = (13)
SAE = (14)
Industry = Number is an average of a number of engines from Industry Data presented in Table 17 in
Chapter 1
C-20
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C-21
Table C-03
Adjustment Factors As Applied to Engine Classes and Technologies
Class
Class !
Class II
Class III
Class IV
Class V
Engine Design
4-Stroke - OHV
4-Stroke - SV
2-Stroke
4-Stroke - OHV
4-Stroke-SV
2-Stroke
2-Stroke
2-Stroke
2-Stroke
HC
2
2
1
2
2
1
1
1
1
CO
2
2
2
2
2
2
2
2
2
NO,
0
0
1
0
0
1
1
1
1
Table C-04
EPA Analysis Baseline and Minimum In-Use Estimates Pre-Control
Class
Class 1
Class II
Class III
Class IV
Class V
Engine Design
4-Stroke - OHV
4-Stroke - SV
2-Stroke
4-Stroke - OHV
4-Stroke-SV
2-Stroke
2-Stroke
2-Stroke
2-Stroke
NEW ENGINE
EXHAUST (g/kW-hr)
HC
18
52.3
279
7
13
279
350
350
214
CO
548
578
651
681
463
651
964
964
696
NO,
2.4
2.7
.4
4.7
2.8
.4
1.3
1.3
1.3
MINIMUM IN-USE
EXHAUST ESTIMATE
HC
37.7
109.8
334.8
14.6
27.2
224.8
420
420
256.8
CO
1042
1098
835.2
1294
879
78.1.2
1156.8
1156.8
835.2
NO,
.4
1.9
1.3
1.9
1.1
0.4
1.3
1.3
1.3
-------
C-22
Table C-05
Post-Control
In-Use Adjustment Factors for Small SI In-Use Deterioration
CLASS AND
TECHNOLOGY
BASELINE POST
CONTROL ENGINE
EMISSIONS
(g/kW-hr)
(Class Standards)
HC
CO
NO,
EMISSIONS
DIFFERENCE
(Pre-Control
Engines; In-Use -
Baseline Estimate)
HC
CO
NO,
MINIMUM IN-USE
EXHAUST
ESTIMATE
HC
CO
NO,
CLASS 1
4-Stroke-OHV
4-Stroka - SV
OPTIONAL:
4-Slroke - SV
w/Calalyst
2-Stroke
8.0
8.0
8.0
0.0
402
402
402
0.0
8.0
8.0
8.0
0.0
19.7
57.5
494
520
-2
-.8
27.8
65.5
65.5
-
895
922
922
-
6.6
6.4
6.4
-
CLASS II
4-S(roke - OHV
4-Stroke-SV
2-Slroke
7.0
9.4
0.0
402
402
.0.0
4.7
4.0
0.0
. 7.6
14.2
613
416
-2.8
-1.7
14.6
23.6
-
1015
818
-
1.9
2.4
-
CLASS III
2-Stroke
OPTIONAL: 2-
Stroke w/ Catalyst
295
295
805
805
5.4
5.4
70
192.8
0
365
365
997.8
997.8
5.4
5.4
CLASS IV
2-Stroke
4-Stroke
OPTIONAL: 2-
Stroke w/Calalyst
241
20
241
805
170
805
5.4
5.4
5.4
70
192.8
0
365
42
365
997.8
323
997.8
5.4
2.1
5.4
CLASS V
2-Stroke
OPTIONAL: 2-
Stroka w/Calalyst
161
161
402
402
5.4
5.4
42.8
139.2
0
203.8
203.8
541.2
541.2
5.4
5.4
-------
C-23
Table C-06
Post-Control
In-Use Adjustment Factors for Small SI In-Use Deterioration
Class
Class 1
Class II
Class III
Class IV
Class V
Engine Design
4-Stroke - OHV
4-Stroke - SV
4-Stroke - SV
w/ Catalyst
2-Stroke
4-Stroke - OHV
4-Stroke-SV
2-Stroke
2-Stroke
2 Stroke
w/ Catalyst
2-Stroke
4-Stroke
2-Stroke
w/Catalyst
2-Stroke
2-Stroke
w/Catalyst
HC
3.43
8.10
8.10
-
3.09
5.06
--
2.31
2.31
2.60
2.13
2.60
2.46
2.46
CO
2.23
2.29
2.29
.-
4.22
3.19
-
2.08
2.08
2.08
2.10
2.08
2.56
2.56
NOx
0.815
0.790
0.790
-- •
1.40
1.16
-
1.00
1.00
1.00
0.40
1.00
1.00
1.00
-------
C-24
Table C-07
Pre-Control In-Use Exhaust Emissions
Class I and Class ll(15)(16)
Class
Class I
Class II
Engine
Design
Side Valve
Overhead
Valve
2-Stroke
Side Valve
Overhead
Valve
2-Stroke
Engine Specifics
*2yr, Tecumseh
(1st test)
*2yr Tecumseh
(2nd & 3rd test)
*4yr, Tecumseh
*8yr, B&S
NA
*11yr, 126cc,
Lawn-Boy
7-1 Oyr, Lawn-Boy
7-1 Oyr, Lawn-Boy
NA
NA
NA
HC
(g/kw-
hr)
91
363
132
102
244
802
1246
CO
(g/kw-
hr)
871
1795
1314
1115
559
1737
1621
NOx
(g/kw-
hr)
1.26
4.76
0.56
1.09
0.68
1.53
0.92
wtd
A/F
10.4
0.67
10.1
10.1
13.2
-
-
Wtd
Power
(kW)
0.67
0.39
0.63
0.65
0.86
0.41
0.53
BSFC
(kg/k
w-h)
1.33
1.95
1.27
1.08
0.88
2.38
2.54
Key:
NA= not available
* = used in EPA 1991 Nonroad Study
(Note: EPA recognizes the submittal of a June 1990 report entitled Toro Small Air-Cooled Engine Exhaust
Emissions Baseline" by Toro which performed testing on a number of small SI engines. Data in this report
is worthwhile to note, however cannot be compared to the data above for emissions were not collected on all
modes of the test cycle used above.)
-------
C-25
Table C-08
Pre-Control In-Use Exhaust Emissions
Classes III, IV and V(17)(18)
Class
Class III
Class IV
Class V
Engine
Design
2-stroke
3yr, 17.5cc
Trimmer
2-stroke
3 yr, 22cc
Blower
2-stroke
30.5cc
Trimmer
Commercial
Use
2-stroke
*4yr, 31cc
Trimmer
2-stroke
6 yr, 29.5cc
Chainsaw
2-stroke
65cc
Chainsaw
Commer-
cial Use
Engine
Condition
As-ls
Lt Maint.
Heavy
Maint
As-ls
As-ls
Lt Maint.
As-ls
As-ls
Lt Maint.
Heavy
Maint
As-ls
Lt Maint.
HC
(g/kw-hr)
435
221
185
200
143
273
1725
339
413
424
199
259
CO
(g/kw-hr)
974
235
255
310
375
168
2802
221
435
801
195
558
NOx
(g/kw-hr)
0.41
1.21
1.07
0.36
1.37
1.89
0.98
6.0
3.6
0.92
3.24
0.72
Wtd
A/F
-
--
..
„
„.
-
9.4
-
—
-
..
_
Wtd
Power
(kW)
0.38
0.45
0.50
0.63
0.82
0.80
0.16
0.62
0.52
0.63
2.72
2.52
Wtd BSFC
(kg/kW-h)
1.34
0.864
0.71
0.60
1.52
0.75
3.90
0.94
1.20
1.19
0.89
1.53
•utilized in EPA 199T Nonroad Study
-------
C-26
Table C-09
In-Use Deterioration Estimates:
Examples for Comparison of Pre-Control Baseline Factors and In-Use Engine Emission Results
Class I: 4-Stroke Side Valve Engines
Pollutant
HC
CO
NO,
New Engine
(Class!
Side Valve)
(g/kW-hr)
52.3
578
2.7
Used Engine
#1
(8 year -I48cc)
(g/kW-hr)
102
436
1.1
Factor
(In-Use/New)
1.95
0.75
0.41
Used Engine
#2
(4 year -164cc)
(g/kW-hr)
132
1276
0.57
Factor
(In-Use/New)
2.5
2.2
0.21
Factors Utilized
In EPA Analysis
for 4-Stroke
Engines
2.1
1.9
0.4
Engine from Table C-02
Used Engine numbers are from Table C-07
Class I: 2-Stroke Engines
Pollutant
HC
CO
NO,
New Engine
(Class!
2-Stroke)
(g/kW-hr)
279
651
0.4
Used Engine
#1
(11 yr I26cc)
(g/kW-hr)
244
559
0.68
Factor
(In-Use/New)
0.87
0.86
1.71
Used Engine
12
(7-10 yr)
(g/kW-hr)
802
1737
1.53
Factor
(In-Use/New)
2.9
2.7
3.8
Factors Utilized In
EPA Analysis for
2- Stroke Engines
1.2
1.9
1.0
New Engine fromTable C-02
Used Engine numbers are from Table C-07
-------
C-27
Table C-11
Classes I and II
Industry In-Use Emission Test Program
Pre and Post Control Engines(19)
Engine Design and
Specifics
Pre- or
Post-
Control
Design
Hours
Number
of
Engines
Reported
Before or
After
Maintenance
HC+NO,
(% from
baseline)
CO
(% from
baseline)
Class I (<225cc)
Composite of Engine
Designs
Pre-Control
('Best")
Post-Control
(Worst")
50
100
150
50
100
150
11
11
9
7
7
5
Before
After
Before
After
Before
After
-
-
--
147.2
144.6
199.2
181.6
203.1
192.7
173.3
197.3
201.4
98.3
93.3
106.8
101.6
103.9
100.6
121.0
107.6
114.2
Class II (>225cc)
Composite of Engine
Designs
Work in progress, Information not available to date-
The testing was performed by small engine manufcturers during 1992 and 1993 and was limited to
lawn mowing equipment both walk behind and ride on
"Future" technology means fuel system calibrations and other engine modifications that are
implemented to bring the engines into compliance with CARB's Tier 1 rule.
The maintenance performed on the "best" maintenance engines was that recommended by the
manufacturer of .the enigne. "Worst" maintenance allows only repairs - no routine maintenance was
performed on worst maintenance engines.
All of the data (above) is from 4-stroke engines
The numbers (above) are the percentag eof the respective emissiosn relative to those measured on a
new engine (new engine = 100%)
-------
C-28
TableC-12
Classes III-V
Industry In-Use Emission Test Program
Pre and Post Control Engines (20)(21)(22)(23)(24)
ENGINE
Pre- or Post-
Control Design
(How Aged)
Hours
HC
(g/kW-hr)
CO
(g/kW-hr)
NOx
(g/kW-hr)
CLASS III
NA
CLASS IV
30. Ice Chain Saw
25cc Trimmer
Pre (dyno)
Post (dyno)
Post (field)
Pre (dyno)
'unclog exhaust
port
Post (dyno)
0
12.5
25
37.5
50
0
12.5
25
37.5
50
0
12.5
25
37.5
50
2.5
15
25
39
39'
50
2.5
3.5?.
15
25
177.87
203.16
175.09
216.37
190.38
176.14
188.66
157.31
156.09
173.82
181.91
161.68
167.33
159.38
1.43
186.18
188.51
161.55
229.1
190.89
186.65
167.56
148.94
212.4
172.09
347.92
383.64
227.81
276.36
287.03
293.87 .
338.37
299.37
206.58
315.95
370.88
124.84
107.31
119.77
282.21
465.38
469.17
409.02
548.38
551.46
551.46
440.95
251.34
613.6
398.52
0.49
.43
0.72
0.69
0.74
0.57
0.48
0.56
0.91
0.81
0.47
1.40
1.14
2.24 '
0.58 '
.74
0.63
1.07
0.61
0.64
0.68
1.15
1.02
0.57
1.13
-------
C-29
24cc Blower
38cc chainsaw
Post (field)
Pre (dyno)
Post (dyno)
adj for Stds
Post (field)
Pre (dyno)
Post (dyno)
37.5
50'
51.3
2.5
3.5?
12.5
25
37.5
50*
0.75
3
15
30
42.5
55.5
0.25
3
15
29.5
42.5
55
3
15
30.5
43
54
Break-in
12.5
25
37.5
50
break-in
after mod
12.5
200.01
189.04
190.89
167.56
167.56
198.43
172.09
161.55
229.53
531.57
507.76
319.65 .
345.17
322.93
273.80
443.10
409.02
336.61
354.48
345.10
365.84
345.17
317.97
408.68
388.74
360.44
239.71
263.10
294.66
274.26
384.81
234.95
211.18
217.93
585.13
223.41
602.37
352.76
524.46
596.16
326.06
237.16
528.85
1280.39
1356.73
632.43
603.22
688.52
604.64
927.17
556.82
691.09
759.61
630.31
818.25
331.77
445.79
971.03
891.42
411.08
543.29
503.33
672.05
637.17
694.04
525.88
530.95
467.61
0.80
1.07
0.59
0.88
0.75
0.71
1.13
1.29
0.73
0.17
0.13
0.35
0.34
0.23
0.19
0.18
0.24
0.23
0.15
0.31
0.31
0.64
0.62
0.16
0.64
1.56
0.80
0.95
0.94
0.99
0.98
0.66
0.85
0.92
-------
C-30
21 cc Trimmer
Post (field)
Pre (dyno)
Post (dyno)
Post (field)
25
37.5
50
break-in
after mod
12.5
25
37.5
50
break-in
12.5
25
37.5
50
break-in
after mod
12.5
25
37.5
50
break-in
after mod
12.5
25
37.5 before
maint
37.5 after
maint
50
214.48
244.83
255.74
220.74
213.48
199.49
199.17
223.54
247.14
256.93
223.47
246.65
236.36
241.48
244.58
205.86
164.06
168.85
180.17
164.44
393.01
201.07
190.72
184.32
150.80
158.80
133.79
533.26
629.59
649.25
505.60
466.69
443.56
401.38
475.19
565.81
323.95
398.40
501.24
429.15
431.27
378.63
299.21
276.10
317.16
340.23
265.71
475.26
327.94
403.87
305.35
299.64
333.06
145.50
0.93
0.73
0.98
0.50
0.67
0.76
0.73
0.50
0.57
0.78
0.65
0.56
0.62 .
0.64
0.49
0.65
0.60
0.70
0.56
0.79
0.52
0.57
0.71
0.85
0.72
0.70
1.20
CLASS V
53cc Chain Saw
Pre-(dyno)
(Engine #1)
3
75
150
225
119.50
119.72
109.75
111.80
426.84
462.86
408.53
470.99
0.69
0.50
0.57
0.49
-------
C-31
No
Pre (dyno)
(Engine #2)
Post (dyno)
(Engine #1}
Post (dyno)
(Engine #2)
Post (field)
(Engine #1)
Post (field)
(Engine #2)
300
3
75
150
225
300
3
75
150
225
300
3
75
150
225
300
3
75
150-300
3
75
150
225
300
134.99
114.45
101.39
149.37
117.61
127.23
104.69
92.21
93.29
105.34
126.23
115.41
112.81
102.04
108.60
105.57
113.60
116.84
505.62
378.10
308.35
337.78
357.58
431.03
357.05
288.01
305.92
348.81
466.66
355.50
332.51
288.33
292.74
309.69
358.32
372.57
0.57
0.80
0.87
0.78
0.73
0.73
0.73
0.93
0.93
0.77
0.57
0.85
0.77
0.86
0.87
0.80
0.80
0.76
not yet finished
113.72
113.86
118.83
112.10
363.03
387.29
413.39
340.39
0.78
0.69
0.74
0.83
not yet finished
te: All data is based on the WOT mode ot the two mode J1088 test
031
-------
C-l
IN-USE EMISSIONS DATA - CO
< 225 cc, 4 Stroke, Future Technology
% of 0 Hour GO Emissions
160
126
100
NOTE: Numbers shown above
bars indicate the .number
of engines reported.
•H Before Maintenance
—— Average Before/After
GDQO After Maintenance*
0 Hours 60 Hours 10O Hours 16O Hours
In-Use Hours From Start of Test
BFB/12-1/-93 ^Maintenance performed per manufacturers recommendations
C-27
-------
figure C-2
250
226
200
*Qf 0 Hour HC+NQx Emissions:
EMISSIONS DATA - HONOx
cc, 4 Stroke. Future Technology
11
11
126 h-
100
76
8
NOTE: Numbers shown above
bars Indicate the number
of engines reported.
Before Maintenance
Average Be fore/After
After Maintenance*-
—— MMOUHa 1
0 Hours 60 Hours 100 Hour* 160 Hours
In-Use Hours From Start of Test
BFB/12-17-03 -Maintenance performed per manufacturers recommendations
C-28
-------
C-3
IN-USE EMISSIONS DATA - CO
< 225 cc, 4 Stroke, Future Technology
150
126
100
76
60
26
of 0 Hour CO Emissions
NOTE: Numbers shown above the line Indicate
the number of engines reported.
No maintenance was performed on these engines.
Repairs were allowed.
0 Hours 60 Hours 10O Hours 160 Hours
In-Use Hours From Start of Test
BFB/12-17-03
C-29
-------
Fieffe C-
IN-USE EMISSIONS DATA - HC+NOx
< 225 cc, 4 Stroke, Future Technology
250
226
200
176
160
126
100
76
60
26
% of 0 Hour CO Emissions
NOTE: Numbers shown above the line indicate
the number of engines reported.
No maintenance was performed on tneee engines.
Repairs were allowed. •
0 Hours 6O Hours 10O Hours 160 Hours
In-Use Hours From Start of Test
BFB/12-17-93
C-30
-------
APPENDIX C REFERENCES
1. United Environmental Protection Agency, National Vehicle and Fuel
Emissions Laboratory, Nonroad Engine and Vehicle Emission Study
Report and Appendicies, EPA 21A-2001, November 1991
2. State of California Air Resources Board, Technical Support
Document for California Exhaust Emission Standards and Test
Procedures for 1994 and Subsequent Model Year utility and Lawn
and Garden Equipment Engines, Mail Out #92-06, January 30,1992.
3. White, Jeff, et al, Emission Factors for Small Utility Engines, SAE
#910560, 1991
4. OPEI In-Use Emissions Testing, facsimile to Cheryl Caffrey, EPA
from Brad Bohlman, December 17, 1993
5. PPEMA/AQC, In-Use Emissions Test Report (25cc String Trimmer),
February 5, 1993
6. PPEMA/AQC, EPA/PPEMA In-Use Emissions Test Report (30.1cc
Chainsaw), Februarys, 1993
7. PPEMA/AQC, PPEMA/AQC Test Report (for 24cc Blower), March
15, 1993
8. PPEMA/AQC In-Use Emission Testing 38cc Chain Saw, March 1993
9. PPEMA/AQC In-Use Emissions Test Report (53cc Chain Saw),
March 12, 1993
10. State of California Air Resources Board, supra note 2, pages 28 &
30
C-32
-------
C-33
11. Heiden Associates Report, -4 1989 California Baseline Emissions
Inventory for Total Hydrocarbon and Carbon Monoxide Emissions
12. from Portable Two-Stroke Power Equipment, July 1990.
US EPA, supra note 1, pages 29,31,33,35
13.
State of California Air Resources Board, supra note 2
14.
White, supra note 3
15.
SwRI, Emission Tests ofln-Use Small Utility Engines, September 1991
16.
University of Michigan Small Engine Test Facility, 1993 Cooperative
Agreement with the U.S. Environmental Protection Agency
17.
SwRI, Emission Testing of In-Use Handheld Engines, March 1994
18.
Ibid.
19.
OPEI, supra note 4
20.
PPEMA/AQC, supra note 5
21.
PPEMA/AQC, supra note 6
22.
PPEMA/AQC, supra note 7
23.
PPEMA/AQC, supra note 8
24.
PPEMA/AQC, supra note 9
-------
C-34
#11
-------
Appendix D: Summary of Burden Imposed by the
Information Collection Requirements
The information collection requirements of the rule have been
submitted for approval to the Office of Management and Budget (OMB)
under the Paperwork Reduction Act, 44 U.S.C. 3501 et seq. EPA has
prepared six Information Collection Request (ICR) documents for this
Smallgas FRM. The supporting statements in each of the ICRs reflects
the Agency's estimates, in hours and dollars, of burden imposed by
specific sections of the regulations on certain nonroad engines—
specifically spark-ignition engines at or below 19 kilowatts, excluding
marine and nonroad recreational vehicles, such as snowmobiles, all
terrain vehicles (ATVs), offroad motorcycles.
The regulation associated with these ICRs fulfills, in part, the
Agency's obligations found in §213 of the Clean Air Act, as amended.
EPA has regulated similar on-highway engines for many years and
these nonroad regulations are patterned after that program and will
impose very similar information collection and reporting requirements.
A summary of the estimated total annual burden imposed by the Small
D-l
-------
D-2
Gas FRM is presented in Table D-l13, below. Copies of the complete
ICR documents may be obtained from Sandy Farmer, U.S. EPA,
Information Policy Branch, Mail Code 2136, 401 M St., S.W.,
Washington, DC 20460 or by calling (202) 260-2740.
13 Table D-l presents estimates of burden for years after the first effective year of the
regulation. It is assumed for this previously unregulated industry, that the first year resource
requirements will be higher than in subsequent years, because manufacturers will have to
establish physical and procedural systems to comply with the information collection and reporting
requirements. The estimated first year costs of compliance are broken down and presented in the
ICRs.
#13
-------
D-3
Table D-1
Summary of Estimated Total Annual Burden Impos'ed by the
Information Collection and Reporting Requirements
EPA ICR
Number
N/A
282
N/A
N/A
12
95.03
N/A
Type of Information
Emission Certification
Emission Defect Information
Importation of Nonconforming Engines
Selective Enforcement Auditing
Engine Exclusion Determination
Pre-certjfication and Testing Exemption
In-use Testing (Proposed -Not Finalized)
OMB
Control
Number
N/A
2060-0048
N/A
N/A
2060-0124
2060-0007
N/A
Annual Totals
Note: The
highly depe
changes, e
Time
(Hours)
144,245
262
7,329
15,647
90
346
0
167,919
Cost
(Dollars)
7,933,475
12,838
354,447
1,604,958
3,420
13,167
0
9,922,305
hours spent by a given manufacturer on information collection activities in any given year is
ndent upon manufacturer specific variables such as numbers of engine families, running
mission defects, etc.
-------
D-4
-------
Appendix E: Hourly Test Length Estimate
The test procedure for this rulemaking is based on the SAE J1088 6-
mode and 2-mode procedures. The procedure has been modified by
EPA in many ways. These modifications to SAE J1088 include
tightening of testing and measuring equipment specifications and
calibration requirements, specification of acceptable certification fuel and
the acceptable option of constant volume (dilute) sampling. The
modifications to SAE J1088 are intended to ensure greater uniformity in
practices and results among manufacturers for gaseous emission
measurement. This is an explanation of the time estimate derived for
the modified test procedure.
There are two test time estimate categories. One is the "set up" time
and the other is the "test" run time.
The set up time will depend on whether the test has previously been
run on a particular engine block. If the test has been run on the
particular engine block, then less time will be required to set up the test
than if no test had been run.
If the test has been run before on the engine block in question, then
the following 3 steps must be done:
1. make engine adapters for the dynamometer,
2. make flywheel adapters for the dynamometer,
3. make exhaust system hook ups to the measurement system.
(This involves setting the measurement system up with the
correct back pressure.)
E-l
-------
E-2
These are time consuming tasks. This estimate represents the
minimum time required. It is assumed that these three steps are
performed once per engine family. However, it is likely to be several
times per engine family because the boring holes for screws may be
different for each flywheel. There may be other changes between
models in the same engine family as well. Ignoring these differences,
the "first time set up" estimate is two 8-hour days (i.e., 16 hours).
If an emission test has been run on the engine block in question,
then the first time set up work is complete. The necessary equipment
can be retrieved and re-assembled for another test. The set up in this
case is termed the "yearly set up" because it would be the set up done
to perform a certification test after the first model year in which an
engine family is certified. The yearly set up includes connecting the
throttle linkage,
wiring,
pressure transducers, and
fuel line hookup;
initial service accumulation on new engine.
EPA estimates 10 hours to do the yearly set up. In addition, a selective
enforcement audit test would require this yearly set up.
Therefore, the estimated total set up time required for the first time
the test is performed is 16 hours plus 10 hours (i.e., 26 hours). Each
yearly test would only require 10 hours for set up.
"Running the test" and gathering emissions involves the following
five steps.
1. Setting the exhaust restrictions. Minimal time is required for
this.
2. Testing performed to stabilize the test conditions. Full
emissions are not taken. This takes about .5 hours.
3. Testing done with full emissions measurement. For the 6-
mode test, EPA estimates 2 hours, for the 2- mode test EPA
estimates 1 hour. (The average of 1.5 hours is used for
calculation below.)
-------
E-3
4. Documentation of the test. This takes about 2 hours.
5. Taking the engine out of the test cell. This takes about 1
hours.
Therefore, it is estimated that approximately 5 hours are required to run
the test.
The Table E-01 summarizes the hourly test estimates. EPA requests
comments on all time estimates.
Table E-01
Hourly Test Estimates
Category
First Time Set Up
Yearly Set Up
Running the Test
TOTAL
First Test
Performed
26
10
5
41
Yearly Tests
or SEA Tests
0
10
5
15
-------
E-4
-------
Appendix F: Supplementary Tables
for
Chapter 4
F-1
3 oo
-------
F-2
Table F-01 -Average Power Ratings
Equipment Type
IN MOWERS
LN MOWERS
TRIM/EDGECUTTEH
TRIM/EDGE/CUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTRSETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMMTURF
COMMTURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
G2H1
0.0
0.0
0.7
0.7
0.6
0.6
0.7
0.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
G2H1C
0.0
0.0
0.7
0.7
0.6
0.6
0.7
0.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
G2H2
0.0
0.0
0.9
0.9
1.2
1.2
1.0
1.0
0.0
0.0
1.2
1.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
1.0
G2H2C
0.0
0.0
0.9
0.9
1.2
1.2
1.0
1.0
0.0
0.0
1.2
1.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
1.0
G4H2
0.0
0.0
0.9
0.9 .
1.2
1.2
1.0
1.0
0.0
0.0
1.2
1.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.0
1.0
G2H3
0.0
0.0
2.3
2.3
2.2
2.2
2.5
2.5
0.0
0.0
0.0
0.0
2.4
2.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.0
3.0
G2H3C
0.0
0.0
2.3
2.3
2.2
2.2
2.5
2.5
0.0
0.0
0.0
0.0
2.4
2.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.0
3.0
G2N1
3.0
3.0
0.0
0.0
0.0
0.0
0.0
0.0
0.6
0.6
0.0
0.0
0.0
0.0
3.0
3.0
0.0
0.0
0.0
0.0
1.2
1.2
2.2
2.2
G2N2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
9.0
9.0
5.4
5.4
G4N10
3.0
3.0
2.6
2.6
0.0
0.0
3.6
3.6
3.5
3.5
0.0
0.0
0.0
0.0
3.8
3.8
0.0
0.0
0.0
0.0
3.4
3.4
3.3
3.3
G4N1S
2.8
2.8
2.0
2.0
0.0.
0.0
3.3
3.3
3.3
3.3
3.1
3.1
3.3
3.3
3.6
3.6
3.7
3.7
3.7
3.7
3.0
3.0
3.0
3.0
G4N1SC
2.8
2.8
2.0
2.0
0.0
0.0
3.3
3.3
3.3
3.3
3.1
3.1
3.3
3.3
3.6
3.6
3.7
3.7
3.7
3.7
3.0
3.0
3.0
3.0
G4N20
0.0
0.0
0.0
0.0
0.0
0.0
6.9
6.9
8.4
8.4
8.2
8.2
0.0
0.0
11.2
11.2
7.2
7.2
10.5
10.5
8.1
8.1
9,7
9.7
G4N2S
6.0
6.0
6.0
6.0
0.0
0.0
6.1
6.1
9.9
9.9
5.2
5.2
6.4
6.4
10.6
10.6
7.4
7.4
9.5
9.5
7.8
7.8
8.5
8.5
-------
F-3
Table F-02
Historical and Projected Consumption
Equipment Type
LN MOWERS
LN MOWERS
TRIM/EDGE/CUTTER
TRIM/EDGE/CUTTEH
CHAINSAWS
CHAINSAWS
LEAF BLOWAfACS
LEAF BLOW/VACS
GENTR SETS
GENTRSETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMMTURF
COMMTURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
1973
5,186,765
576,307
0
0
1,258,573
419,524
0
0
' 40,636
121,909
306,416
67,262
223,398
24,822
0
0
323,473
17,025
672,262
35,382
12,474
37,422
97,637
292,911
1974
4,862,592
540,288
0
0
1,389,490
463,163
0
0
47,867
143,602
321,421
70,556
169,226
18,803
0
0
358,633
18,875
784,058
41,266
14,745
44,234
117,595
352,786
1975
3,809,030
423,226
0
0
1,565,374
521,791
0
0.
55,483
166,448
347,383
76,255
116,763
12,974
0
281
. 225,025
11,843
513,073
27,004
14,502
43,507
122,897
368,692
1976
3,971,117
441,235
0
0
1,693,455
564,485
0
0
69,089
207,266
362,191
79,505
123,192
13,688
0
308
242,605
12,769
522,414
27,495
16,259
48,778
145,662
436,985
1977
4,052,160
450,240
0
0
1,829,150
609,717
0
0
64,813
194,438
449,239
98,613
199,532
22,170
0
331
242,605
12,769
526,463
27,709
15,773
47,320
158,254
474.761
1978
4,376,333
486,259
0
0
2,043,852
681,284
0
0
81,588
244,764
444,809
97,641
309,779
34,420
0
43,538
248,711
13,090
593,580
31,241
23,648
70,943
200,759
602,277
1979
4,781,549
531,283
0
0
2,074,905
691,635
10,231
1,546
81,478
244,435
445,043
97,692
309,779
34,420
0
77,526
312,598
16,453
655,080
34,478
28,915
86,746
215,996
647,988
1980
4,619,462
513,274
678,776
150,533
1,867,767
622,589
74,136
11,205
71,900
215,700
519,593
114,057
309,779
34,420
0
87,635
286,168
15,061
609,225
32,064
23,465
70,395
228,774
686,321
1981
3,727,987
414,221
1,011,050
224,222
1 ,284,465
428,155
238,957
36,115
69,241
207,724
390,279
85,671
256,684
28,520
0
78,381
227,841
11,992
445,147
23,429
18,804
56,412
233,515
700,545
1982
3,727,987
414,221
921,817
204,433
988,050
329,350
433,540
65,523
53,766
161,297
387,163
84,987
70,743
7,860
0
81,302
237,866
12,519
461,170
24,272
14,062
42,185
207,720
623,160
-------
Table F-02 (contd.)
Historical and Projected Consumption
Equipment Type
LN MOWERS
LN MOWERS
TRIM/EDGE/CUTTER
TRIM/EDGE/CUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTR SETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMM TURF
COMM TURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
1983
3,565,901
396,211
1,219,749
270,505
1,077,680
359,227
540,271
81,654
54,505
163,514
317,832
69,768
196,590
21,843
0
84,686
251,536
13,239
466,603
24,558
14,147
42,440
210,633
631.900
1984
4,011,638
445,738
1,353,228
300,107
1,188,483
396,161
626,891
94,745
58,015
174,044
310,821
68,229
259,142
28,794
0
94,196
322,623
16.980
561,148
29,534
24,817
74,452
241,136
• 723,409
1985
4,208,573
467,619
1,415,912
314,008
1,077,680
359,227
914,166
138,163
60,199
180,596
281,998
61,902
313,502
34,834
0
102,491
323,534
17,028
597,242
31,434
27,232
81,695
259,011
777,033
1986
4,376,333
486,259
1,762,515
390,875
952,763
317,588
777,307
117,479
64,931
194,792
242,269
53,181
358,926
39,881
0
116,773
293,459
15,445
664,311
34,964
29,550
88,650
262,007
786,022
1987
4,781,549
531,283
2,026,524.
449,424
952,763
317,588
810,497
122,495
75,836
227,507
211,888
46,512
391,691
43,521
0
131,628
341,761
17,987
819,581
43,136
31,634
94,902
268,766
806,298
1988
4,538,419
504,269
2,229,176
494,367
971,818
323,939
1,138,770
172,108
88,297
264,891
222,015
48,735
396,159
44,018
0
163,110
341,761
17,987
846,247
44,539
34,770
104,311
283,215
849,644
1989
4,295,290
477,254
2,379,027
527,599
990,873
330,291
1,169,779
176,795
109,013
327,039
237,595
52,155
404,350
44,928
0
178,810
236,955
12,471
804,566
42,346
35,427
106,280
297,154
891,463
1990
4,619,462
513,274
2,402,809
532,874
972,524
324,175
1,200,787
181,481
105,407
316,221
233,700
51,300
264,354
29,373
0
194,763
225,107
11,848
898,615
47,296
35,782
107,345
293,709
881,127
1991
4,335,811
481,757
2,382,714
528,417
813,730
271,243
1,231,795
186,168
102,189
306,567
230,584
50,616
212,228
23,581
0
184,656
190,475
10,025
836,675
44,036
33,913
101,740
300,008
900,023
1992
4,173,725
463,747
2,428,775
538,632
830,004
276,668
1,262,803
190,854
103,280
309,839
267,197
58,653
212,228
23,581
0
196,944
186,830
9,833
685,803
36,095
- 35,531
106,592
283,521
850,564
1993
4,494,621
499,402
2,640,476
585,581
830,004
276,668
1,293,811
195,541
102,542
307.625
279,587
61,373
264,882
29,431
0
206,495
152,637
8,034
980,776
51,620
36,692
110,075
309,249
927,748
-------
F-5
Table F-02 (contd.)
Historical and Projected Consumption
Equipment Type
LN MOWERS
LN MOWERS
TRIM/EDGE/CUTTER
TRIM/EDGE/CUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTR SETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMM TURF
COMM TURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prot.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
1994
4,586,246
509,583
2,852,176
632,530
830,004
276,668
1,324,820
200,227
101,804
305,411
299,896
65,831
317,537
35,282
0
216,046
135,747
7,145
1,014,812
'53,411
37,852
113,557
334,990
1,004,970
1995
4,258,667
473,185
3,063,877
679,480
830,004
276,668
1,355,828
204,913
101,065
303,196
201,439
44,218
370,191
41,132
0
225,596
257,878
13,573
815,330
42,912
39,013
117,040
360,475
1,081,425
1996
2,127,894
236,433
1,591,225
352,888
415,002
138,334
704,516
106,477
51,406
154,218
96,963
21,285
188,409
20,934
0
116,911
128,425
6,759
412,623
21,717
19,956
59,868
184,920
554,759
1997
4,252,908
472,545
3,301,021
732,071
830,004
276,668
1,462,236
220,995
104,558
313,674
186,414
40,920
383,445
42,605
0
242,047
255,822
13,464
835,161
43,956
40,811
122,433
379,203
1,137,610
1998
4,250,028
472,225
3,419,594
758,367
830,004
276,668
1,515,439
229,036
106,304
318,913
178,901
39,271
390,072
43,341
0
250,272
254,795
13,410
845,077
44,478
41,710
125,130
388,567
1,165,702
1999
4,247,149
471,905
3,538,166
784,663
830,004
276,668
1,568,643
237,077
108,051
324,152
171,389
37,622
396,698
44,078
0
258,498
253,767
13,356
854,993
45,000
42,609
127,826
397,931
1,193,794
2000
4,244,269
471,585
3,656,738
810,959
830,004
276,668
1,621,847
245,118
109,797
329,391
163,876
35,973
403,325
44,814
0
266,723
252,739
13,302
864,909
45,522
43,508
130,523
407,296
1,221,887
2001
4,241,670
471,297
3,763,786
834,699
830,004
276,668
1,669,880
252,378
111,374
334,121
157,094
34.484
409,308
45,479
0
274,149
251,812
13,253
873,861
45,993
44,319
132,958
415,749
1 ,247,248
2002
4,239,070
471,008
3,870,834
858,439
830,004
276,668
1,717,912
259,637
112,950
338,850
150,311
32,995
415,291
46,143
0
281,575
250,884
13,204
882,813
46,464
45,131
135,392
424,203
1,272,610
2003
4,236,470
470,719
3,977,881
882,179
830,004
276,668
1,765,945
266,897
114,527
343,580
143,529
31,506
421,273
46,808
0
289,001
249,956
13,156
891,765
46,935
45,942
137,827
432,657
1,297,972
2004
4,233,871
470,430
4,084,929
905,919
830,004
276,668
1,813,978
274,156
116,103
348,310
136,746
30,017
427,256
47,473
0
296,427
249,028
13,107
900,717
47,406
46,754
140,261
441,111
1,323,334
F-03- Pre-Control Sales Mix
-------
F-6
Equipment Type
LN MOWERS
IN MOWERS
TRIM/EDGE/CUTTER
.TRIM/EDGE/CUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTR SETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMM TURF
COMMTURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prof.
Res,
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
G2H1
0.000000
0.000000
0.050130
. 0.050130
0.003480
0.003480
0.052795
0.052795
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H1C
0.000000
.0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H2
0.000000
0.000000
0.917271
0.917271
0.642622
0.642622
0.629887
0.629887
0.000000
0.000000
0.010133
0.010133
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H2C
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G4H2
0.000000
0.000000
0.000000
0.000000.
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H3
0.000000
0.000000
0.007745
0.007745
0.353898
0.353898
0.208551
0.208551
0.000000
0.000000
0.000000
0.000000
0.320526
0.320526
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H3C
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2N1
0.050000
0.150000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.001713
0.001713
0.000000
0.000000
0.000000
0.000000
0.009866
0.009866
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.097388
0.097388
G2N2
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.002384
0.002384
G4N10
0.070000
0.060000
0.001564
0.001564
0.000000
0.000000
0.000694
0.000694
0.005727
0.005727
0.000000
0.000000
0.000000
0.000000
0.040016
0.040016
0.000000
0.000000
0.022245
0.022245
.0.000000
0.000000
0.037479
0.037479
G4N1S
0.880000
0.790000
0.023077
0.023077
0.000000
0.000000
0.072079
0.072079
0.285285
0.285285
0.793762
0.793762
0.373202
0.373202
0.064715
0.064715
0.049877
0.049877
0.803968
0.803968
0.004857
0.004857
0.406449
0.406449
G4N1SC
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G4N20
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000086
0.000086
0.055057
0.055057
0.000088
0.000088
0.000000
0.000000
0.365753
0.365753
0.156253
0.156253
0.001254
0.001254
0.142077
0.142077
0.008111
0.008111
G4N2S
0.000000
0.000000
0.000213
0.000213
0.000000
0.000000
0.035908
0.035908
0.652218
0.652218
0.196018
0.196018
0.306272
0.306272
0.519650
0.519650
0.793870
0.793870
0.172533
0.172533
0.853066
0.853066
0.448188
0.448188
Table F-04- Post-Control Sales Mix
-------
F-7
Equipment Type
LN MOWERS
LN MOWERS
TRIM/EDGE/CUTTER
TRIM/EDGBCUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTR SETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMM TURF
COMM TURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
G2H1
0.000000
0.000000
0.048626
0.048626
0.003376
0.003376
0.051211
0.051211
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
. 0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H1C
0.000000
0.000000
0.001504
0.001504
0.000104
0.000104
0.001584
0.001584
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H2
0.000000
0.000000
0.900000
0.900000
0.640000
0.640000
0.630000
0.630000
0.000000
0.000000
0.009829
0.009829
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H2C
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G4H2
0.000000
0.000000
0.018345
0.018345
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H3
0.000000
0.000000
0.007513
0.007513
0.350000
0.350000
0.210000
0.210000
0.000000
0.000000
0.000000
0.000000
0.320000
0.320000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2H3C
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2N1
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G2N2
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G4N10
0.125000
0.125000
0.001564
0.001564
0.000000
0.000000
0.000694
0.000694
0.005761
0.005761
0.000000
0.000000
0.000000
0.000000
0.045000
0.045000
0.000000
0.000000
0.022245
0.022245
0.000000
0.000000
0.090000
0.090000
G4N1S
0.875000
0.875000
0.020000
0.020000
0.000000
0.000000
0.070000
0.070000
0.290000
0.290000
0.800000
0.800000
0.370000
0.370000
0.065000
0.065000
0.050000
0.050000
0.800000
0.800000
0.000971
0.000971
0.460000
0.460000
G4N1SC
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
G4N20
0.000000
0.000000
0.000000
0.000000
0.000000
0.000000
0.000086
0.000086
0.055057
0.055057
0.000088
0.000088
0.000000
0.000000
0.365753
0.365753
0.156253
0.156253
0.001254
0.001254
0.142077
0.142077
0.008154
0.008154
G4N2S
0.000000
0.000000
0.000213
0.000213
0.000000
0.000000
0.035908
0.035908
0.652218
0.652218
0.196018
0.196018
0.306272
0.306272
0.519650
0.519650
0.793870
0.793870
0.172533
0.172533
0.853066
0.853066
0.450530
0.450530
-------
F-8
Table F-05
Weibull Constants
Equipment Type
LN MOWERS
LN MOWERS
TRIM/EDGE/CUTTER
TRIM/EDGE/CUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTR SETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMM TURF
COMM TURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GDN TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Res
Prof
Theta
7.3
2.5
5.1
2.7
5.1
1.0
5.1
2.7
7.3
2.7
7.3
5.4
5.4
5.4
3.7
7.3
3.7
7.3
3.7
7.3
2.7
7.3
2.7
b
1.6
1.6
2.1
2.5
2.1
3.0
2.1
2.5
1.6
2.5
1.6
1.7
1.7
1.7
1.6
1.6
1.6
1.6
1.6
1.6
2.5
1.6
2.5
Implied BSD
5.8
2.0
4.3
2.3
4.3
0.9
4.3
2.3
5.8
2.3
5.8
4.4
4.4
4.4
2.9
5.8
2.9
5.8
2.9
5.8
2.3
5.8
2.3
-------
F-9
Table F-07
Average Annual Use, Load Factor
Equipment Type
LN MOWERS
LN MOWERS
TRIM/EDGE/CUTTER
TRIM/EDGE/CUTTER
CHAINSAWS
CHAINSAWS
LEAF BLOW/VACS
LEAF BLOW/VACS
GENTR SETS
GENTR SETS
TILLERS
TILLERS
SNOWBLOWER
SNOWBLOWER
COMM TURF
COMM TURF
REAR ENG RIDER
REAR ENG RIDER
LN/GDN TRACTORS
LN/GON TRACTORS
PUMPS
PUMPS
ALL OTHER EQUIP.
ALL OTHER EQUIP.
Use
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Res.
Prof.
Hr/Yr
25
406
9
137
13
303
10
282
9
143
17
472
8
136
682
36
569
45
721
14
217
15
234
Avg. Load
Factor (%)
33
33
50
50
50
50
50
50
68
68
40
40
35
35
50
50
38
38
44
44
69
69
50
50
Hrs/Yr Load
Factor
8
134
5
69
6
151
5
141
6
97
7
189
3
47
0
341
14
216
20
317
9
149
7
117
Jo?
-------
F-10
Table F-08
Projected Annual Nationwide Nonroad SI Engine Emissions in
Tons/Year
1996-2020, Baseline Scenario
Year
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
. 2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
Baseline HC
767,794.09
782,746.42
796,289.25
809,319.86
822,374.09
835,156.41
847,690.91
860,070.75
872,352.57
884,673.93
896,699.69
908,725.46
920,751.22
932,605.62
944,460.03
955,564.80
966,669.58
976,953.04
987,236.50
997,519.96
1,007,603.00
1,017,686.05
1,027,769.09
1,037,810.61
1,047.852.13
Baseline CO
(exhaust)
8,892,921.81
9,115,293.81
9,320,055.38
9,516,966.64
9,712,174.88
9,902,869.27
10,088,881.21
10,271,413.42
10,452,066.32
10,631,865.23
10,806,945.20
10,982,025.17
11,157,105.14
11,328,766.23
11,500,427.32
11,661,582.98
11,822,738.63
11,971,891.37
12,121,044.11
12,270,196.85
12,415,530.81
12,560,864.78
12,706,198.74
12,850,875.77
12.995.552.79
Baseline No,
(exhaust)
15,877.35
16,274.24
16,654.29
17,023.24
17,399.83
17,749.50
18,097.07
18,443.42
18,772.76
19,144.85
19,461.75
19,778.65
20,095.55
20,418.07
20,740.59
21,032.57
21,324.55
21,600.51
21,876.46
22,152.42
22,426.47
22,700.52
22,974.57
23,239.63
23,504.69
-------
F-11
Table F-09
Projected Annual Nationwide Nonroad SI Engine Emissions in
Tons/Year
1996-2020, Controlled Scenario
Year
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
HC
767,809.20
679,966.77
640,627.27 .
615,552.65
600,789.08
597,108.96
597,628.98
597,358.68
599,198.51
603,491.02
609,696.89
615,902.77
622,108.64
629,541.67
636,974.70
644,388.77
651,802.84
658,926.56
666,050.28
673,173.99
680,304.00
687,434.01
694,564.03
701,717.06
708.870.10
CO
(exhaust)
8,892,925.08
8,870,690.48
8,945,831.89
9,046,691.48
9,173,426.42
9,314,827.02
9,463,911.39
9,620,007.27
9,777,341.34
9,945,515.28
10,103,826.70
10,262,138.11
10,420,449.53
10,579,342.37
10,738,235.21
10,887,941.98
11,037,648.74
11,176,492.58
11,315,336.42
11,454,180.26
11,589,647.32
11,725,114.38
11,860,581.44
11,995,479.16
12,130.376.89
NO,
(exhaust)
15,876.15
27,259.79
33,786.07
38,344.24
41,344.41
43,388.18
44,971.64
46,232.00
47,406.34
48,506.23
49,403.81
50,301.39
51,198.97
52,037.23
52,875.50
53,629.73
54,383.96
55,073.03
55,762.10
56,451.17
57,122.42
57,793.67
58,464.92
59,130.36
59.795.79
------- |