Monitoring and Laboratory Division July 2, 2003

1. Small Off-Road Engine WorkshopEvaporative Emission Program Monitoring and Laboratory Division July 2, 2003 California Air Resources Board

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

3. Need for Regulation Uncontrolled Evaporative Emissions from Non Preempt Equipment 2020 51 tpd 2010 45 tpd 2000 41 tpd

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

5. Recap of the November 13, 2002 Proposal • Allowed performance and design-based certification • Contained in-use testing liability • Set a 1.0 gram/m2/day fuel tank permeation standard applicable to all SORE equipment • Set a 1.0 gram/day diurnal evaporative emission standard for equipment > 80 cc to < 225 cc • Set a 2.0 gram/day diurnal evaporative emission standard for equipment > 225 cc

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

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

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

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

10. Performance-Based Certification Overview

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

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

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

14. Significant Changes Still Under Consideration • Considering raising the permeation standard to 2.0 grams/m2/day for equipment < 80 cc • Considering extending implementation date of permeation standard for equipment < 80 cc to 2006 • Considering diurnal standard with standard based on tank volume (applicable to equipment other than walk-behind mowers) • Considering a tiered compliance margin for new equipment compliance testing • Considering small volume (< 400 units) design-based standards

15. Standards Under Consideration

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

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

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

19. Contacts and Additional Information