Comparative Assessment of the Environmental Performance
of Small Engines
Outdoor Garden Equipment
Prepared for
Department of the Environment and Water Resources
Vehicle Design andand Research P/L
February 2007
Disclaimer The research reported in this document was commissioned by the Environment Standards Branch of the Department of the Environment and Water Resources.
The views and opinions expressed in this publication are those of the authors and do not necessarily reflect those of the Australian Government or the Minister for the Environment and Water Resources.
While reasonable efforts have been made to ensure that the contents of this publication are factually correct, the Commonwealth does not accept responsibility for the accuracy or completeness of the contents, and shall not be liable for any loss or damage that may be occasioned directly or indirectly through the use of, or reliance on, the contents of this publication.
Acknowledgments This report was prepared for the Department of the Environment and Water Resources and the contribution made by Officers of the Department is acknowledged.
The comments on the draft report and other project discussion documents made by members of the Small Engines Expert Panel: Outdoor Equipment were appreciated and considered in finalising this report. The Panel had representation from:
Industry: Allpower Industries Stihl Pty Ltd Briggs & Stratton Honda Australia Motorcycle & Power Equipment Pty Ltd Victa Lawncare Pty Ltd Rover Mowers Limited Roy Gripske & Sons Pty Ltd Parklands Trading Co Pty Ltd Kawasaki Motors
Associations: Outdoor Power Equipment Association
Government: Department of the Environment and Water Resources NSW Department of Environment and Conservation Environment Protection Authority Victoria The Northern Territory Department of Natural Resources, Environment and The Arts.
In addition overseas government and industry colleagues provided useful feedback and information during the project.
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Contents
Disclaimer .................................................................................................................i
Acknowledgments...........................................................................................................i
Abbreviations and Glossary...........................................................................................ii
Executive Summary ..................................................................................................... iii
1. Introduction............................................................................................1
1.1 Emissions from outdoor garden equipment engines..............................1
2. Air Quality and Outdoor Garden Equipment Engines...........................4
2.1 Air Quality Standards ............................................................................6
3. Emission Standards for Small Engines ..................................................8
3.1 Australia.................................................................................................8 3.2 United States ..........................................................................................8 3.3 Canada..................................................................................................12 3.4 Europe ..................................................................................................13 3.5 Summary of Regulations for Non Handheld Equipment.....................15 3.6 Summary of Regulations for Handheld Equipment.............................16
4. Australian Market for Small Engines ..................................................18
4.1 Likely compliance with overseas emissions standards........................18 4.2 Australian Sales of Outdoor Powered Equipment ...............................22
5. Australian Users of Small Engines ......................................................25
5.1 General Public......................................................................................25 5.2 Garden and Ground Maintenance Services..........................................27 5.3 Government Purchasing.......................................................................28
6. Result of Stakeholder Consultation .....................................................30
6.1 Regulations ..........................................................................................30 6.2 Discussion on recommended regulations.............................................31
7. The Way Forward ................................................................................35
7.1 Options to Reduce Emissions from Garden Equipment Engines ........38 7.2 Option 1 – Do Nothing ........................................................................39 7.3 Option 2 – Industry - Government Partnership....................................39 7.4 Option 3 - Quasi Regulation ................................................................39 7.5 Option 4 -Co Regulation......................................................................40 7.6 Option 5 - Regulation...........................................................................40 7.7 Preferred Approach..............................................................................44
References ..............................................................................................................45
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Appendix 1: Detailed Breakdown of Powered Garden Equipment on the Australian Market ..................................................................................................51
Appendix 2: Examples of Current Australian Benchmarking Programs..................55
Appendix 3. Productivity Commission Comments on Labelling and Minimum Performance Standards ........................................................................71
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List of Figures
Figure 1: Example of a Californian Consumer Advisory Hang Tag.........................11
Figure 2: Extract from survey form...........................................................................18
Figure 3: Compliance with overseas standards - all surveyed products....................20
Figure 4: Compliance with overseas standards by equipment type...........................21
Figure 5: Engine type for popular categories ............................................................21
Figure 6: Compliance with overseas standards for popular categories .....................22
Figure 7: OPEA estimates of equipment sales in 2005-06........................................24
List of Tables
Figure 1: Example of a Californian Consumer Advisory Hang Tag.........................11
Figure 2: Extract from survey form...........................................................................18
Figure 3: Compliance with overseas standards - all surveyed products....................20
Figure 4: Compliance with overseas standards by equipment type...........................21
Figure 5: Engine type for popular categories ............................................................21
Figure 6: Compliance with overseas standards for popular categories .....................22
Figure 7: OPEA estimates of equipment sales in 2005-06........................................24
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Abbreviations and Glossary
2c Two stroke with carburettor 2di Two stroke with direct fuel injection 2i Two stroke with pre-chamber fuel injection 4c Four stroke with carburettor 4i Four stroke with fuel injection (includes direct injection) ABS Australian Bureau of Statistics ABT Averaging, Banking and Trading of emissions ADR Australian Design Rule Air NEPM National Environment Protection Measure for ambient air quality BTEX Benzene, toluene, ethylbenzene, xylenes - carcinogenic or mutagenic aromatic
hydrocarbons formed through the combustion process CARB Californian Air Resources Board CBA Cost Benefit Analysis cc Cubic centimetres CO Carbon Monoxide DEC Department of Environment and Conservation di Direct Injection efi Electronic fuel injection EU European Union Euromot The European Association of Internal Combustion Manufacturers g/kW- hr Grams per kilowatt hour HCs Hydrocarbons –most are VOCS and, in relation to small engines, the terms are
often used interchangeably hp Horsepower 1 hp =745.7 watts ISO International Standards Organization kW Kilowatts MEPS Minimum Energy Performance Standards MOU Memorandum of Understanding NATA National Association of Testing Authorities NOx Oxides of Nitrogen NPI National Pollutant Inventory NSW GMR New South Wales Greater Metropolitan Region which includes Sydney, Lower
Hunter and Illawarra regions, encompassing the major metropolitan centres of Sydney, Newcastle and Wollongong. Population approximately 4.7 million.
OPEA Outdoor Power Equipment Association PM10 Particles with an aerodynamic diameter of 2.5 micrometres or less PM2.5 Particles with an aerodynamic diameter of 10 micrometres or less Port Phillip Region in Victoria of 24,000 km2 that includes Greater Melbourne and Greater Region Geelong. It is defined in Victorian environmental policy. Population
approximately 3.4 million (1996) SE Qld South East Queensland - a region that covers the area from the Gold Coast to the
Sunshine Coast and west to Toowoomba. It includes Brisbane & suburbs, population approximately 2.3 million people
USEPA United State of America Environmental Protection Agency VOCs Volatile Organic Compounds WELS Water Appliances: Water Efficiency Labelling and Standards Scheme
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Executive Summary
Background
This report sets out the results of a project to compare and benchmark emissions from small petrol engines (less than 19 kilowatts) that are used to power outdoor garden equipment and were available for sale in Australia during 2006. The equipment powered by these small engines are used in lawnmowers, brushcutters, hedge trimmers and the like.
These engines emit volatile organic compounds (VOCs) and oxides of nitrogen (NOx) which contribute to ozone (photochemical smog) formation in summer. They also emit particles, carbon monoxide (CO) and a range of air toxics such as benzene.
Sydney’s Greater Metropolitan Region (GMR) annually records exceedances of the National Environment Protection (Ambient Air Quality) Measure (Air NEPM) ozone standards. The other jurisdictions meet or are close to meeting the current ozone standards.
The Air NEPM standards are being reviewed and based on current human health evidence the argument appears to be strengthening for tighter ozone standards. Should a stricter standard or an eight-hour standard consistent with international standards/guidelines be adopted, achievability of Air NEPM ozone standards or goals could become an issue for some of the other major urban airsheds.
The United States, California, Canada and Europe regulate emissions from outdoor equipment - the USA has had these in place since 1997. There are no Australian regulations or standards that limit air pollutant emissions from engines used in outdoor garden equipment however as the majority of equipment sold in Australia is imported some do comply with emission standards applicable to the country of origin.
Small engines are not as advanced in environmental terms as motor vehicle engines. As a result even the better-performing small engines emit far greater quantities of pollutants per hour than typical modern car engines. For example the US Environmental Protection Agency (USEPA) 2002 limit for a typical 4 kilowatt (kW) lawnmower motor is about 66 grams (g) of regulated pollutants per hour of operation. A typical 0.8kW brushcutter sold new in 2002 emitted about 160grams of pollutants per hour - reducing to 40grams per hour if bought new in 2006. The equivalent limit for cars under Australian Design Rule 79 is about 16g per hour. In other words, one hour of operation of a brushcutter that meets USEPA 2002 limits produces the same pollution as ten cars, operated over a similar time. These comparisons are subject to differences in test methods but they do provide an indication of the disproportionate amount of pollution emitted by small engines.
Engines that do not comply with current USEPA requirements are likely to emit several times the amount of pollution calculated in the above example. Therefore the worst performing engines are likely to emit more than ten times the emissions of the best performers.
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Based on estimates made using the National Pollutant Inventory database, engines used in lawn mowers contribute approximately 4% on average to VOC emissions from anthropogenic sources in major airsheds in Australia when public open space lawn mowing is included. This is likely to rise to around 11 % in the warmer spring and autumn weekends which is when lawns and other vegetation grows faster and when gardening is more popular. The NPI does not take into account emissions from other types of powered outdoor equipment.
The Australian Market
According to the Outdoor Power Equipment Association (OPEA), approximately 424,000 walk behind lawnmowers and more than 792,000 units of outdoor handheld equipment were sold in Australia in 2005-06. In addition there were sales of about 80,000 replacement engines and 70,000 pumps in 2005-06 most of which were four strokes. The general household consumer represents the major market segment for garden equipment, accounting for up to 90% of product sales with commercial garden services and government purchasing the rest.
Indications are that sales of imported high polluting two stroke engines have increased over the last few years and it appears that the price of some powered garden equipment has dropped to the level where consumers regard them as disposables.
An assessment of outdoor equipment on the Australian market found that the majority of small engines sold in Australia are imported and many come from countries that impose emission limits. The extent of imports into Australia that do not comply with the country of origin standards is not known. However the industry estimate that 40% of garden products are sold through importers who are not linked to manufacturers of US EPA or European certified equipment and the source of some products sold here is difficult to establish. Victa is the only company producing small engines in Australia. Its iconic 2-stroke lawn mower engine currently does not meet overseas emission limits for non-handheld equipment and Victa is undertaking research and development to reduce emissions from its two stroke engine to meet US and European standards.
In spite of several attempts to obtain data on compliance with overseas emission standards from Australian distributors their response was poor. The following figure therefore provides a best estimate of expected compliance of outdoor equipment on the Australian market with European, CARB or USEPA requirements applicable in 2004.
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Figure E1. Compliance with overseas standards for popular categories “Phase 1 equiv” means the engine complies with US EPA phase 1 or 2002.88.EU. “Phase 2 equiv” means the engine complies with US EPA Phase 2, Euro I or Euro 2. “Unknown" means that engine cycle (stroke) was not provided
Measures to Increase Sales of Low Emission Garden Equipment Engines
There is a range of options that could be considered for reducing emissions from engines used in outdoor garden equipment engines in Australia. These include:
1. Maintaining the Status Quo
2. Government – Industry Partnership Program
3. Quasi regulation
4. Co-regulation
5. Regulations based on either a simple benchmark or tiered benchmarks
The Small Engine Expert Panel –Outdoor Equipment has considered in depth the most appropriate approach to take to improve the emissions performance of outdoor garden equipment sold in Australia It recommends the introduction of national regulations to control the emissions from outdoor garden equipment particularly in light of the increase in cheap imports onto the Australian market, which although untested, are considered very likely to have high emission levels. The Expert Panel has developed some broad recommendation on which Australian regulations could be based which takes in consideration the local market and Victa. These are summarised as follows:
1. Mandatory air pollutant emission standards to be introduced in Australia for all outdoor equipment (
The development of any regulation would need to be based on a formal assessment of the costs and benefits of nationally regulating two and four stroke lawn mowers and handheld power equipment, which should commence immediately.
2. Proposed standards to mirror US EPA regulations (compliance with equivalent EU regulations also acceptable).
3. Timing (subject to completion of assessment of costs and benefits):
(a) US EPA Phase 1 – Effective from 2007/2008
(b) US EPA Phase 2 – Fully implemented in 2012 (in step with 2007 USEPA limits) plus a phase-in period and/or provisions for averaging, banking and trading (ABT) of emissions over 2008-2012 to provide for early introduction of cleaner product.
The US EPA Phase 1 and Phase two emissions limits are given in the table below.
4. Walk-behind two stroke mowers to be included in US EPA Category 5 (>50cc) product classifications (to provide Victa time to develop a cleaner engine). Implementation timing is proposed to be the same as Recommendation 3 above.
5. All products also to be certified to relevant EPA product durability categories.
6. Subject to further review, ABT, if included, may be phased out after 2012.
Table E1: Comparison between the USA Phase 1 and Phase 2 standards
Emission Limits G/kW-hr
Phase 1 (1997 –2001) Phase 2 (2007) * HC NOx HC+NOx CO HC+NOx CO
Non-handheld
I-A
Conclusion
From this review it is apparent that it is highly unlikely that the companies in the industry would engage in, or commit to, any voluntary type program. It is therefore clear that the most expedient path to reduce emissions from these small engines is through national regulation. State based regulations could only provide a piecemeal approach that would lead to product dumping in states where there are no regulations and inconsistent regulations that require industry to treat each state market differently. In addition, enforcement of any state based regulations would be a key problem due to existing Commonwealth and State Government mutual recognition legislation.
While any national regulation of emissions from small engines used in garden equipment in Australia are likely to be based on overseas regulations they need to strike a balance between improved environmental outcome, harmonisation with international standards and the characteristics of the local industry. With regulations optimum emissions reduction are potentially achievable by combining minimum emissions standards with tiered product labelling. Whether this approach is justifiable on economic grounds, that is the benefits outweigh the costs, can only be determined through a detailed impact assessment. Based on these findings it is recommended that a formal assessment of the costs and benefits of nationally regulating two and four stroke lawn mowers and handheld power equipment should be commenced.
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1. Introduction
This report sets out the results of a project to compare and benchmark emissions from engines used in outdoor garden equipment that were available for sale in Australia during 2006. Possible outcomes from the project range from consumer guidelines for selecting low emission engines to regulatory controls on emissions. There are currently no state or national regulations that directly control emissions from these engines.
The project was commissioned by the Commonwealth Department of the Environment and Water Resources on behalf of state and territory government departments working on reducing the impacts of small engine emissions. This report was prepared in consultation with an Expert Panel that included representatives from the Outdoor Power Equipment Association (OPEA).
1.1 Emissions from outdoor garden equipment engines
Small engines, particularly conventional two stroke engines used in applications such as outdoor garden equipment are high polluters relative to their engine size and usage1. These small engines emit volatile organic compounds (VOCs) and oxides of nitrogen (NOx) which contribute to ozone (photochemical smog) formation in summer. They also emit particles, carbon monoxide (CO) and a range of air toxics such as benzene. The USA, California, Canada and Europe and regulate emissions of VOCs, NOx, carbon monoxide and particle emissions from outdoor garden equipment.
There are five types of spark-ignition engines that can be used in outdoor garden equipment:
• two stroke with carburettor (2c)
• two stroke with pre-chamber fuel injection (2i)
• two stroke with direct fuel injection (2di)
• four stroke with carburettor (4c)
• four stroke with fuel injection (4i) (includes direct injection)
Carburettor and pre-chamber fuel injection two stroke engines are inherently more polluting than the other three types. This is due to their inability to completely separate the inlet gases from the exhaust gases, resulting in up to 30% of the fuel being left unburnt, and the need to add oil to the fuel to lubricate the engine (four stroke engines have separate reservoirs for fuel and oil). However, twostroke carburettor engines typically weigh less than a four stroke engine of the same power and this tends to make them attractive for handheld equipment. They also tend to have fewer components, are generally cheaper to purchase and are cheaper to maintain than
1 Outdoor equipment covered in this report are engines less than 19kW.
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four stroke motors. Victa Lawncare is currently undertaking research and development to improve the environmental performance of two stroke carburettors and while some emission improvements have been made a two stroke compliant with US or European standards is still considered several years away.
Four stroke carburettor engines are generally quieter, more fuel efficient and are less polluting than conventional two stroke engines.
Direct fuel injection (dfi), either two stroke or four stroke, overcomes the unburnt fuel problem and can meet the stringent regulated exhaust emission limits that apply overseas. However there is not any evidence that dfi engines are being used in outdoor garden equipment available in Australia. It appears that engines used in outdoor garden equipment in Australia are generally restricted to two and four stroke carburettor engines.
Small engines are not as advanced in environmental terms as motor vehicle engines. As a result, even the better-performing small engines emit far greater quantities of pollutants per hour than typical modern car engines. For example the US Environmental Protection Agency (USEPA) 2002 limit for a typical 4 kilowatt (kW) lawnmower motor is about 66 grams (g) of regulated pollutants per hour of operation. A typical 0.8kW brushcutter sold new in 2002 emitted about 160grams of pollutants per hour - reducing to 40grams per hour if bought new in 2006. The equivalent limit for cars under Australian Design Rule 79 is about 16g per hour. In other words, operated over a similar time, one hour of operation of a brushcutter that meets USEPA 2002 limits produces the same pollution as ten cars and a 4kW lawnmower the same pollution as four cars. These comparisons are subject to differences in test methods but they do provide an indication of the disproportionate amount of pollution emitted by small engines.
Engines that do not comply with current USEPA requirements are likely to emit several times the amount of pollution calculated in the above example. Therefore the worst performing engines are likely to emit some ten times the emissions of the best performers.
Because of the combustion of oil these engines also emit high levels of particles. Although small engines only contribute a small amount to total particle emissions, the rate of particle release compared to other engines can be very high. For example lawnmowers can emit over 10 times more particles (in terms of grams per hour) than a petrol motor vehicle (manufactured between 1994 and 2001).
All the above emission comparisons between outdoor garden equipment engines and motor vehicles are subject to differences in test methods but they indicate the disproportionate amount of pollution emitted by small garden equipment engines. It also needs to be recognised that motor vehicles in Australia average more than 15,000 kilometres per year (ABS, 2003) while the annual average use of outdoor garden equipment is around 25 hours for a lawnmower and less for other types of equipment. Commercial operators however are likely to have a much higher usage rates than the general public.
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This paper examines the Australian market for small engines used in lawnmowers and handheld garden equipment, their impact on air quality, relevant overseas regulations and their applicability to Australia and makes recommendations to reduce air quality impacts from these engines.
A wide range of information sources has been referenced for this report including data and information supplied by manufacturers, distributors and dealers in small engines.
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2. Air Quality and Outdoor Garden Equipment Engines
Emission inventories make estimates of emissions of substances from a multitude of sources into airsheds. The National Pollutant Inventory (NPI) which is run cooperatively by the Australian, state and territory governments, contains data on 90 substances that are emitted to the Australian environment. The substances included in the NPI have been identified as important because of their possible health and environmental effects. Industry facilities estimate their own emissions annually and report to states and territories. Non-industry (or diffuse) emissions estimates, which includes emissions from outdoor garden equipment, are made by the states and territories on a periodic basis using information sources such as surveys, databases, and sales figures.
The NPI only reports emissions from domestic lawn mowing and, for a few airsheds, the contribution made by public open space lawn mowing. It does not report on the contribution made by other types of outdoor garden equipment such as brushcutters. National and selected state NPI emissions estimates for the common air pollutants and for Air Toxics NEPM pollutants from domestic lawn mowing are summarised in Table 1. It should be noted that national emissions from lawn mowing are underestimates as the NPI records emissions for major airsheds only, and therefore is not Australia wide, plus the estimates do not include evaporative emissions from fuel tanks and hoses.
This NPI data is indicative only as the accuracy and completeness of the data sets varies across airsheds and is reliant on the estimation techniques used. For example while the population in the NSW is higher than other airsheds its emissions look disproportionally high when compared to the other airsheds. This could be because the estimation technique varies or it is due to some other factor.
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Table 1: National Pollutant Inventory Domestic Lawn Mowing Emission Estimates
Substance Port Phillip
Population 3.4 mill (1996)
SE Qld
Population 2.3 mill
NSW GMR
Population 4.7 mill
Adelaide
Population 1.0 mill
National
Common Air Pollutants (tonnes/year)
Carbon monoxide 12,000 12,000 24,000 6,100 69,000
Total Volatile Organic Compounds 3,600 3,800 7,000 2,000 21,000
Particulate Matter 10.0 um 86 94 170 9 460
Sulphur dioxide 5 5 9 50 81
Oxides of Nitrogen 63 54 120 24 330
Air Toxics (tonnes/year)
Benzene 230 210 390 130 1,200
Formaldehyde 56 38 N/A 31 180
Polycyclic aromatic hydrocarbons 0.7 11 21 0.4 41
Toluene (methylbenzene) 370 360 660 210 2,000
Xylenes (individual or mixed isomers) 270 260 490
150 1,500
Analysis of the NPI database at the national level shows that domestic lawn mowing is the:
- Fourth largest source of benzene, contributing 7% to the total reported airshed load
- Fourth largest source of formaldehyde, contributing 3% to the total reported airshed load
- Fifth largest source of xylene, contributing 6% to the total reported airshed load
- Fifth largest source of toluene, contributing 6% to the total reported airshed load
- Sixth largest source of carbon monoxide, contributing 1.2% to the total reported airshed load
- Ninth largest source of VOCs contributing 3% to the total reported airshed load when biogenics (natural sources such as trees and soil) are excluded
The NSW Department of Environment and Conservation has been upgrading its emissions inventory. Based on 2003 emissions data, non-road anthropogenic sources
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contribute 61.9% of the VOCs to the GMR airshed. Preliminary results2 indicate that VOC emissions from domestic and public open space lawn mowing contributes, on an annual average, 4.1%, of all VOC emissions in the GMR. On a typical weekend during warmer weather this percentage rises to 11%.
Therefore it could be assumed that lawn mowing could contribute approximately 4% on average to VOC emissions from anthropogenic sources in major airsheds in Australia when public open space lawn mowing is included. This percentage is likely to rise significantly in the warmer spring and autumn weekends which is when lawns and other vegetation grow faster and when more people garden.
2.1 Air Quality Standards
In June 1998 the National Environment Protection Measure for Ambient Air (Air NEPM) established national uniform standards for ambient air quality for the six most common air pollutants – carbon monoxide, nitrogen dioxide, photochemical oxidants (measured as ozone), sulfur dioxide, lead and particles less than 10 microns (PM10). The NEPM was varied in 2003 to include PM2.5 advisory reporting standards and in April 2004 a National Environment Protection Measure for Air Toxics was adopted.
Nationally the common pollutants of most concern (particularly in major urban areas) are fine particles and ground level photochemical smog (measured as ozone) which is formed in the warmer months when volatile organic compounds (VOCs) and oxides of nitrogen (NOx) react in the atmosphere under the influence of sunlight in a series of chemical reactions.
Recent health studies (cited in NEPC, 2005) have strengthened the evidence that there are short-term ozone effects on mortality and respiratory disease. The studies also strengthen the view that there does not appear to be a threshold for ozone below which no effects on health are expected to occur. In recent years Australian epidemiological studies have been conducted which confirm the results of overseas studies that there is a relationship between elevated ozone levels and hospitalisations and deaths from certain conditions.
There are two national ozone standards, a one hour standard of 0.10ppm and a four hour standard of 0.08ppm, with a goal that allows for one exceedance per year by 2008. Sydney experiences a number of days each year of ozone levels above these standards. In 2003 Sydney exceeded the one hour standard on 11 days in 2003, 19 days in 2004 and 9 days in 2005. The four hour standard was exceeded on 13 days in 2003, 19 days in 2004 and 13 days in 2005. Further reductions in VOC and NOx emissions are needed to reduce ozone concentrations in Sydney to levels that would comply with the Air NEPM.
The other jurisdictions meet, or are close to meeting the current National Environment Protection (Ambient Air Quality) Measure (Air NEPM) ozone standards (NEPC, 2005). However the ozone standards are being reviewed and based on current human health evidence the argument appears to be strengthening for tighter ozone standards.
2 Presentation to Expert Panel 27 April 2006 by Nick Agipades, Manager Major Air Projects, NSW DEC,
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Should a stricter standard or an eight-hour standard consistent with international standards/guidelines be adopted, achievability of Air NEPM ozone standards or goals could become an issue for some of the other major urban airsheds (NEPC, 2005).
Modeling of ozone for Sydney’s Greater Metropolitan Region (GMR) indicates that the implementation of Euro emission limits for on-road vehicles, and hence the increased presence of these less polluting vehicles in the fleet and retirement of old more polluting vehicles from the fleet, is not sufficient to meet the current NEPM goals. Modeling suggests that very large reductions in precursor emissions would be required to meet the current ozone one hour goal (NEPC, 2005).
Even when the effects of bushfires and when hazard reduction burning are taken into consideration, airsheds such as Launceston, Melbourne and Sydney struggle to meet the national standards for particles (EPA, 2006). However outdoor powered equipment, predominantly from two stroke engines, makes only a minor contribution to ambient fine particle loads.
While carbon monoxide emissions from engines used in outdoor garden equipment are regulated overseas air monitoring in Australia indicates that carbon monoxides levels are well below the national air quality standards and there are no pressing issues requiring CO from outdoor powered equipment to be regulated. In addition data indicates that lowering emissions of VOCs and NOx from small engines reduces CO emissions.
Many of the pollutant sources which contribute to the formation of ozone and to particle levels also contain air toxics such as benzene, toluene, formaldehyde, and xylenes. These air toxics have been shown to be responsible for a range of health problems, including asthma, respiratory illnesses and cancer. The National Environment Protection Measure for Air Toxics requires each jurisdiction to monitor and report annually on five air toxics: benzene, polycyclic aromatic hydrocarbons, formaldehyde, toluene and xylenes. The monitoring data is intended to inform future policy and also the public on ambient levels of these air pollutants. Monitoring of air toxics to date shows that levels are low and below the national monitoring investigation levels (EPA Vic, 2006, DEC, 2006).
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3. Emission Standards for Small Engines
3.1 Australia
At present there are no Australian regulations or standards to limit air pollutant emissions from small (two and four stroke) engines. Australia does benefit to some extent from overseas regulations as many lawnmowers and other gardening equipment sold in Australia have engines manufactured in the United States or Europe, where strict standards apply.
3.2 United States
In the United States emission regulations set by the United States Environmental Protection Agency (USEPA) and the Californian Air Resources Board (CARB) apply to lawn mowers and other powered gardening equipment. Although CARB standards currently tend to be stricter than USEPA standards, by 2006 emissions limits applying under the two standards will be very similar.
United States Environment Protection Agency (US EPA)
In 1995 the USEPA introduced “Phase 1” regulations covering small non-road engines with a power of not more than 19kW (25HP). The regulations applied to equipment manufactured from 1997.
These regulations have seven classes of equipment, based on portability and engine displacement volume (“capacity”). In March 2000 the USEPA published “Phase 2” regulations which are shown in Table 2. These set limits for combined emissions of hydrocarbons (HC) and oxides of nitrogen (NOx), and separate limits for carbon monoxide (CO) emissions and for two stroke engines only, particles.
Table 2: US EPA Phase 2 Small Engine Emissions Standards (HC+NOx in g/kW-hr) (a), (b)
Small Engine Class
Type 2002 2003 2004 2005 2006 2007+
I-A (
When the USEPA introduced “Phase 2” regulations it included averaging, banking and trading provisions (ABT) which were seen “as an important element in making stringent Phase 2 emissions standards achievable with regard to technological feasibility lead time and cost.” (USA 1999). The USEPA also claimed (USA, 2000) that the ABT program secures early emissions benefits through the early introduction of cleaner engines.
ABT provisions which apply to handheld and non handheld engines, are complex but in broad terms averaging means the exchange of emission credits among engine families within a given engine manufacturer’s product line. This allows a manufacturer to produce some engines that exceed the standards and offsetting these exceedances with emissions from engines that are below the standard. Manufacturers are allowed to exchange credits from handheld to non handheld and vice versa. Banking means the retention of emission credits by the engine manufacturer generating the credits for use in a future model year (for averaging or trading). Trading is the exchange of emission credits between engine manufacturers which then can be used for averaging purposes, banked for future use, or traded to another engine manufacturer.
In January 2004 USEPA reported that in 2002 averaging was being used but there was very little use of banking. It determined that the initial ABT programs as too complex and included discount rates on credits. ABT was simplified in 2004 including the elimination of credit discount and multipliers and limits on credit life. To date there has reportedly been limited use of banking however it is anticipated that there will be more widespread use of banking credits if the USEPA proposed Phase 3 comes into effect3 (see below).
Particulate limits (2g/kW-hr) also apply to two stroke engines. Carbon monoxide and durability limits (or useful life) are also prescribed. The durability criteria which were introduced in Phase 2, require that the emission limits must be met through the useful life of the engine. The manufacturer determines useful life of each product using standardised product testing procedures and then, based on the test results, selects the useful life category for each product which can be 125, 250 or 500 hours. These durability criteria acknowledge the large disparity in usage patterns by equipment type and between commercial and residential users. It also takes into account the ability of manufacturers to design and build engines for various design lives and which fit the types of equipment engine is produced for.
The March 2000 USEPA report (USEPA, 2000) estimated that the expected effects of the Phase 2 regulations would be:
• A 70% reduction in HC+NOx, beyond the Phase I standards (which were estimated to have reduced emissions by 32% from the unregulated baseline)
• A 30% reduction in fuel consumption of small handheld equipment • Price increases of between $US23 (Class III) and $US56 (Class V) for
handheld equipment.
3 Dave Gardner, Briggs and Stratton, email 22/5/06
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The US EPA is currently considering ‘Phase 3’ regulations which are catalyst based standards to further reduce exhaust HC and NOx emissions from non handheld engines, reduce evaporative HC and NOx emissions for both handheld and non handheld engines plus include extended durability criteria. These limits are currently at discussion stage only. They align with CARB Tier 3 but a longer lead time is proposed.
Table 3: Proposed Phase 3 Exhaust Emissions
HC+NOx* g/kW-hr
CO g/kW-hr
Year Useful life hrs
Class I 10.0 610 2010 125/250/500
Class II 8.0 610 2011 250/500/1000
Class III-V No changes
HC+NOx std is based on averaging
Californian Air Resources Board (CARB)
Spark ignition engines
CARB regulations first introduced emission limits for small engines manufactured from1995. The more recent schedule of emission limits are shown in Table 4. These limits depend solely on the engine capacity and apply to both handheld and non handheld classes.
Table 4: CARB Emission Limits for Small Engines (HC+NOx in g/kw-hr)
Engine Capacity 2000-2001 2002-2005 2006+
65cc or less 72 72 72
>65cc to 225cc 16.1 16.1 16.1
>225cc 13.4 12.1 12.1
California has particle limits for two strokes, useful life criteria and mandatory engine labeling including a consumer advisory hang tag as shown in Figure 1. The USEPA is also considering introducing an air index label.
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Figure 1: Example of a Californian Consumer Advisory Hang Tag The Californian regulations take into account sales weighted emission performance for families of engines. An engine family is essentially the same engine being used in different equipment items.
In 2003, California adopted a Tier 3 program for exhaust and evaporative emissions and these are based on the use of catalytic convertors. The engine classes better align with US EPA categories however the exhaust standards for Class I and Class II are more stringent than the existing US EPA standards.
Table 5: CARB Tier 3 for Exhaust Emissions
Model Year Displacement Category
Durability Periods (hours)
HC+NOx g/kw-hr
CO g/kw-hr
Particulate g/kw-hr
2005 and subsequent
80 cc - 80 cc - 80 cc - 80 cc - 80 cc -
the averaging, banking, and trading program. Zero-emission small off-road equipment (e.g. push mowers) may certify to the Blue Sky Series emission standards.
In 2005 CARB aligned its test procedures with the USEPA.
Table 6: CARB Blue Sky Provisions
Model Year Displacement Category
HC+NOx g/kw-hr
CO g/kw-hr
Particulate*
2005 and subsequent 80 cc -
Table 7: Canadian Small Spark-Ignition Engine Exhaust Emission Standards
Engine class
Engine Type
Engine Displacement (cm3)
Effective date (model year)
Standard HC+NOx (g/kWhr)
Standard NMHC+NOx (g/kW-hr)
Standard CO (g/kWhr)
I-A Non-handheld
The European Union is currently considering including useful life criteria and averaging and banking provisions plus it is considering introducing a Directive to further reduce emissions from diesel engines. The objective of the proposal is to tighten emissions standards for engines in general non-road applications in light of technological developments and it taking into account the parallel developments for similar legislation in the United States in order to harmonise the environmental standards and to facilitate trade.
Charts comparing the USA, Californian and European Emission Limits are shown below.
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3.5 Summary of Regulations for Non Handheld Equipment
KEY TO CHARTS
USEPA CARB EU
0
10
20
30
40
50
60
70
80
2000
2001
2002
2003
2004
2005
2006
2007
2008
Year Model
HC
+N
Ox g
/kW
-hr
0 to 49cc
0
10
20
30
40
50
60
70
80
2000
2001
2002
2003
2004
2005
2006
2007
2008
Year Model
HC
+N
Ox g
/kW
-hr
50 to 65cc
0
2
4
6
8
10
12
14
16
18
2000
2001
2002
2003
2004
2005
2006
2007
2008
Year Model
HC
+N
Ox g
/kW
-hr
100 to 224cc
0
2
4
6
8
10
12
14
16
18
20
2000
2002
2004
2006
2008
Year Model
HC
+N
Ox g
/kW
-hr
225cc and over (up to 19kW)
15
2000
2001
2002
2003
2004
2005
2006
2007
2008
2000
2001
2002
2003
2004
2005
2006
2007
2008
2000
2001
2002
2003
2004
2005
2006
2007
2008
2000
2001
2002
2003
2004
2005
2006
2007
2008
3.6 Summary of Regulations for Handheld Equipment
KEY TO CHARTS
USEPA CARB EU
20 to 49cc 0 to 19cc
250 250
200
150
HC
+N
Ox g
/kW
-hr
100
200
HC
+N
Ox g
/kW
-hr
150
100
50 50
0 0
Year Model Year Model
50 to 65cc 66 to 80cc
160
160
140
140
120
40 40
20 20
0 0
120
HC
+N
Ox g
/kW
-hr
HC
+N
Ox g
/kW
-hr
100100
8080
60 60
Year Model Year Model
16
Summary of Regulations for Handheld Equipment (continued)
KEY TO CHARTS
USEPA CARB EU
0
20
40
60
80
100
120
140
160
2000
2001
2002
2002
2003
2004
2005
2006
2007
2008
Year Model
HC
+N
Ox g
/kW
-hr
81 to 224cc
0
20
40
60
80
100
120
140
160
2000
2001
2002
2003
2004
2005
2006
2007
2008
Year Model
HC
+N
Ox g
/kW
-hr
225cc and over (up to 19kW)
17
4. Australian Market for Small Engines
4.1 Likely compliance with overseas emissions standards
As part of this assessment an environmental profile of equipment currently on the Australian market has been developed, initially based on information from manufacturers’ brochures and web sites and industry magazines and then confirmed through follow-up with relevant industry contacts.
Each item of equipment has been assessed on its compliance with USEPA, CARB or European regulations. In most cases it was not possible to match models available on the Australian market with CARB lists (CARB publishes exhaust emissions data on all appliances on its web site). This was mainly due to the inconsistency of model designations and uncertainty about “engine families”.
Engine characteristics and retail price were difficult to obtain. Some brochures also made claims of compliance with USEPA, European or CARB requirements. The detailed breakdown of current equipment on the Australian market is given in Appendix 1.
The majority of small engines sold in Australia are imported and many come from countries that impose emission limits. The extent of imports into Australia that do not comply with the country of origin standards is not known. Industry estimates that 40% of garden products are sold through importers who are not linked to manufacturers of US EPA or European certified equipment and the source of some products sold here is difficult to establish. Victa is the only company producing small engines in Australia. Its iconic 2-stroke lawnmower currently cannot meet overseas emission limits.
Outdoor Power Equipment Association (OPEA) assisted in identifying the Australian distributors of most brands of powered garden equipment. In April 2006 a survey form was sent to a total of 43 distributors, representing 97 brands of equipment. The survey form sought information about the engine for all petrol-fuelled garden equipment with a power not more than 19kW.
Figure 2: Extract from survey form
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Initial response to the survey was poor. Despite follow-up action and efforts from the industry association, at the beginning of September 2006 26 distributors had responded to the survey information and only 13 distributors provided all data necessary for benchmarking purposes. This resulted in emission compliance data for about half of the estimated products on the Australian market. Attempts to match Australian models with the database maintained by the Californian Air Resources Board were also of limited success due to inconsistencies in model designations between Australia and the USA and the manner in which model information is coded in the CARB database.
Table 9: Summary of distributor responses
Responses status Not OPEA OPEA ALL*
Number of responses 9 8 (31%) 17 (40%)
Response - all data 4 9 13 (30%)
Response - extra time sought 3 3 (7%)
Response - no petrol products 4 1 5 (12%)
Response - some data 5 5 (12%)
Grand Total 17 26 43 * percentages may not add to 100% due to rounding
Of the 97 brands initially identified:
• 16 brands are apparently no longer sold in Australia.
• No responses were received for 29 brands
• Partial data were received for 12 brands
• All data was available for 30 brands
Table 10: Summary of responses by brand
Count of brands
Analysis status Not OPEA OPEA All
Missing some data 12 12
No data received 9 (27%) 20 (31%) 29 (30%)
No longer sold 13 3 16
Response - no models to list 3 7 10
Response received (electronic form) 5 11 16
Response received (paper form) 3 2 5
Response received (spreadsheet) 9 9
All 33 64 97
A 2004 report for the NSW DEC estimated that there were about 1200 eligible garden
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products in the Australian market. The current project has obtained data for a total of 870 products or 72% of the estimated population. In addition the sampling method is likely to be biased towards products with good environmental performance. In these circumstances the following analysis should be regarded as indicative only.
Survey results
The following tables and figures show expected compliance with European, CARB or USEPA requirements, based on the limited information provided by industry.
Table 11: Engine type and compliance with overseas standards Count of products Engine type
Best STD 2c 4c Unknown All 1997 - US EPA I 53 32 85 (10%) 2002.88.EU 17 17 (2%) 2004 - US EPA II 1 3 4 (
Figure 4: Compliance with overseas standards by equipment type “Phase 1 equiv” means the engine complies with US EPA phase 1 or 2002.88.EU. “Phase 2 equiv” means the engine complies with US EPA Phase 2, Euro I or Euro 2. “Unknown" means that engine cycle (stroke) was not provided
Of the 41 categories of equipment in the survey, 15 had at least 10 current products. Results for these categories are set out below.
Figure 5: Engine type for popular categories
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http:2002.88.EU
Figure 6: Compliance with overseas standards for popular categories “Phase 1 equiv" means the engine complies with US EPA phase 1 or 2002.88.EU "Phase 2 equiv" means the engine complies with US EPA Phase 2, Euro I or Euro 2. “Unknown" means that engine cycle (stroke) was not provided
4.2 Australian Sales of Outdoor Powered Equipment
The Australian Outdoor Power Equipment Association (OPEA), whose membership represents about 80% of the manufacturers/distributors and dealers in the industry, commissions regular independent industry audits of garden equipment sales (OPEA, personal communications). Sales data from OPEA is shown in Table 12.
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http:2002.88.EU
Table 12: Sales of outdoor garden equipment 2002 and 2005-06 2005-06 2 stroke (1,000)
2002 2 stroke (1,000)
2005-06 4 stroke (1,000)
2002 4 stroke (1,000)
2005-06 TOTAL (1,000)
2002 TOTAL (1,000)
Walk behind mowers 72 170 351 76 424 246
Brushcutter/trimmer 321 12 17 180 339 192
Chainsaws 152 0 0 90 152 90
Chipper shredders 0 60 46 0 46 60
Blower/blower vacuums 98 0 11 50 109 50
Ride on mowers 0 25 51 0 51 25
Generators 11 32 96 0 107 32
Hedge trimmers &others 40 192 0 28 40 220
694 491 476 424 1267 915
% for total sales 59.3% 46.3% 40.7% 53.7%
% for mowers 15.2% 28.0% 84.8% 72.0%
According to OPEA approximately 424,000 walk behind lawnmowers and more than 792,000 units of outdoor handheld equipment were sold in Australia in 2005-06. In addition there were sales of about 80,000 replacement engines and 70,000 pumps in 2005-06 most of which were four strokes. These figures show that there has been considerable growth in the sales of most products with the exception of chipper shredders and the category ‘hedge trimmers and others’ whose sales declined in 200506 compared with those in 2002. About 17% of walk behind lawnmowers were two stroke and 83% four stroke which is an improvement in the uptake of cleaner engines when compared to 2002 when about 30% were two stroke. The situation with handheld equipment is reverse with nearly 79% being two strokes compared to 47% in 2002. However, many models of two stroke handheld equipment meet current US emission standards and care should be exercised in using engine type (two stroke or four stroke) as an indicator of emissions performance for this class of equipment.
The OPEA 2005-06 sales estimates are shown in Figure 7. OPEA cautions that there is considerable uncertainty about the estimates for brushcutters and blower/blower vacuums as OPEA’s figures only represent 50% and 60% respectively of sales of these products. No estimates of future sales trends were identified during research for this project.
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Australian sales of 2 and 4 stroke outdoor equipment 2005-6
0 50 100 150 200 250 300 350 400
Walk behind mowers
Brushcutter/trimmer
Chainsaws
Chipper shredders
Blower/blower vacuums
Ride on mowers
Generators
Other
Annual sales (x 1000)
4s 2s
Figure 7: OPEA estimates of equipment sales in 2005-06 Note: "Blower/vac" is an industry term for equipment that combines blowing and vacuuming functions
Briggs and Stratton (Australia) who import engines from the USA, supply the majority of the four stroke engines for handheld equipment sold in Australia and these comply with all the current USA and CARB regulations. Imported handheld garden equipment is shipped fully assembled to a branch or distributor and is then sent to a retailer. The retailer may or may not provide equipment servicing.
OPEA members have expressed concern regarding the increasing sales of imported high polluting two stroke engines that allegedly do not meet any emission standards and come from countries that do not have emission standards. One industry representative reported that some of the imported trimmers were being manufactured in China using outdated designs and tooling from two old bankrupt American companies and these are being sold here at about 30% of the price of traditional brands and very low cost generators from China now account for around 70% of total sales. It is difficult to confirm this trend without undertaking a detailed examination of Australian import data however the significant increase in the sales of two stroke handheld equipment provides some support for this trend.
On the other hand it is claimed by industry that the ride on mower market (predominately with compliant four stroke engines) has been stimulated by the Australian / USA free trade agreement.
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5. Australian Users of Small Engines This section examines the market segments for garden equipment and customer purchasing behaviour.
5.1 General Public
Purchasing behaviour
Research into consumer purchasing behaviour has found that consumers assess a product against a range of attributes for example price, weight, brand reputation, servicing and parts availability, warrantees and guarantees, experience, size, promotions and discounts. Studies have also revealed that up to 82% of Australians had bought products on the basis of social or environmental factors in the previous year (State Chamber of Commerce, 2001). Related to this point, the energy star rating ecolabel on whitegoods was viewed as a credible environmental claims system which is well regarded by the general consumer (Product Category Manager, Mitre 10, personal communications).
As the purchase of small engine garden equipment by the general consumer is an infrequent purchase which carries a certain of amount of risk. With small engines the risk can be functional risk (will not perform as expected), physical risk (for example safe features such automatic cut out on an electric lawn mower), or financial risk especially for the more expensive items. The general consumer is likely to lessen the risk by seeking information and by evaluating the information on the available products over a period of time. The consumer may also lessen the risk by:
• purchasing well known brands;
• buying the brand offering the best warrantees and guarantees;
• buying the most expensive brand, and
• buying a brand they have used before.
Research indicates that the desired attributes of a product may not be well established at the start of a consumer’s search process but will often be refined as the consumer learns more about the product. The consumer will also use a ranking and weighting process based on desired qualities and trade offs may be made.
Reportedly, purchases of engine operated garden equipment are based on price, yard size, fitness for purpose, and other features such as weight and ease of starting (Product Category Manager, Mitre 10, personal communications). Males are the predominant purchasers of garden equipment, however because of changing demographics there has been an increase in the number of women purchasing these products.
Less than 5% of lawnmowers purchased are push or electric mowers (Product Category Manager, Mitre 10 and industry sources, personal communications, 2003).
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Electric mowers are generally perceived as not being as effective as cords have limited range and rechargeable electric mowers require frequent recharging.
There is a recent trend towards ride on mowers (all four strokes) probably because of changing demographics, specifically older age groups moving to more rural environments with larger yards (OPEA, personal communications).
A study (Wilkie, 1994) investigated consumer appliance purchasing behaviour and found that the general consumer consulted a range of information sources before purchasing an appliance. The appliance salesperson was found to be the most important information source for many consumers. Other important information sources include newspaper advertisements, friends and relatives, catalogues, consumer reports and brochures/labels. Since Wilkie’s study the internet will have become increasingly important as a research tool and in some instances as a way to purchase products. As part of this study there is evidence of low priced products being sold into the Australian market via the internet only – a practice that is likely to increase in the future. It was difficult to source any compliance or details on these products.
At the retail chain level, staff product training is generally voluntary, undertaken out of store hours and, as an inducement to attend training sessions, suppliers usually provide incentives for staff. Retail chain purchases are very price driven although some chains are reportedly interested in stocking goods that have credible environmental claims (Mitre 10 and other retail chain sources).
IBIS (2006a) reports that the domestic hardware sector, which is dominated by Danks (Home Timber and Hardware, Thrifty - Link Hardware and Plants Plus Garden Centre) and Bunnings, is classified as a growth market and the sales of lawnmowers and other lawn and garden machinery and equipment represent about 14% of sales revenue.
In summary, it appears that a range of product attributes influences consumer purchases of lawnmowers and outdoor equipment. Currently there is very little information about emissions in any of the information sources a consumer is likely to consult when purchasing these products. Nevertheless, surveys indicate that consumers are concerned about the environment and are open to including environmental considerations into their purchase decision. Educating sales staff about the air emissions from lawnmowers and outdoor equipment together with ecolabels could therefore be important methods for influencing consumers towards the purchase of cleaner products.
Equipment Usage
The USA Outdoor Power Equipment Institute, CARB (cited in USEPA, 1998) and the USEPA (USEPA, 1998) have made estimates of annual usage rates and average life spans of outdoor equipment for the general consumer user and for the commercial user. Table 13 gives USA usage and lifespan range for selected items of powered equipment:
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Table 13: USA Average Usage and Lifespan of Outdoor Garden Equipment For General Consumers and Commercial Users Equipment Annual usage (Hours) Lifespan (years)
General Consumer
Walk- behind mowers 20-25 6 -7
Rear engine ride on mowers 4 6 -7
Chainsaws 7 5-9
Leaf blowers 9-12 5-9
Trimmers 10 5-9
Commercial User
Walk- behind mowers 320 2.7
Rear engine ride on mowers 380 3.8
Chainsaws 405 1-1.3
Leaf blowers 170-293 1.8-2.8
Trimmers 170 - 275 1.5-2.8
Discussions with members of the Australian industry confirm that Australian hours of use are likely to be similar to the American estimates, although this can vary depending on location. For example, in tropical areas lawns are mowed more often because they grow faster in this climate. The American turnover of equipment is however probably higher than here as the Australian consumer tends to keep their equipment longer and so the useful life of a mower is more likely to be, on average, 10 –12 years.
5.2 Garden and Ground Maintenance Services
According to a recent IBIS report (2006b) the revenue for this industry in 2005-06 was $383 million and the industry outlook is ‘bright’ with a predicted annual average 5% growth over the next few years. The Australian customer base for garden maintenance services, including for lawn mowing, is:
Households 55% Business 25% Government 20%
The sector is reportedly a growth industry due to:
• the aging population;
• the increasing numbers of households that are time poor/ income rich; and
• the growing trend for professional landscaping which requires a higher level of garden maintenance.
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The main customer base for these businesses includes middle to upper socioeconomic groups, the aged and people who are physically disabled. Growth is predicted particularly for the franchise industry with demand from the commercial/industrial/government sectors (IBIS, 2003). A 1999 ABS survey reported that nearly one-third of older people purchased at least one domestic service per fortnight with gardening assistance being the most common. This accords with an industry estimate that about 25% of householders pay someone to mow their lawn (Jim Penman, Jim’s Mowing, personal communication). The industry is sensitive to economic conditions and weather, for example the drought has slowed growth over the last few years.
The garden maintenance sector is dominated by small independent operators with two major franchisers: Jim’s Mowing and VIP. VIP nationally has 600 franchises and Jim’s Mowing about 400. Jim’s Mowing reportedly mows about 15,000 lawns and has 5.3% of the market (IBIS 2006b). As franchised lawn mowing services represents about 14% of the lawn mowing services nationally it can be estimated that approximately 280,000 lawns are mowed nationally by commercial operators.
Jim’s Mowing and VIP provide training and advice to new franchisees on equipment, including proper maintenance schedules. Training generally occurs before franchisees purchase their equipment. Most franchisees equipment would consist of two mowers, a brushcutter, an air blower, and possibly a hedge trimmer or chain saw. Operators prefer four stroke mowers and these are used for an average eight hours per week. Brushcutters are generally two strokes as are other motors (IBIS, 2006b and Jim Penman, personal communication).
From the above, it is estimated commercial operators operate mowers for up 3.4 million hours per year (or 8% of the total estimated mowing hours per year) and purchase approximately 6,6000 lawnmowers annually (2.5% of purchases). The sector’s purchases of brushcutters is estimated to be approximately 8,000 units per year, or 3.7% of purchases. Table 13 provides US commercial user’s annual average hours of use and average equipment life spans – it would be anticipated Australian rates would be similar.
The main businesses contracting to provide ground maintenance services to the corporate and government sector (including universities) are Spotless’s Open Space Management, Transfield and Programmed Maintenance Services, all of which are diversified publicly listed companies plus the Danish owned company ISS (previously Tempo Services) (IBIS, 2003 and 2006b and company websites). The type of services they provide means it is likely they would have an array of equipment and a preference for the more powerful ride-on mowers and for Class V handheld equipment.
5.3 Government Purchasing
The way purchasing decisions are made by government or other large organizations is generally very different to the approach taken by the general household consumer.
• many of the purchases are for large quantities of goods;
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• there are well established policies and procedures in place to guide purchasing, with the purchase criteria established early in the buying process; and,
• those making the purchase are likely to be more knowledgeable about the product than the average consumer and they are usually not the eventual user of the goods.
Value for money, fitness for purpose, ability to supply and, over recent years, environmental aspects are likely to be important factors in the purchasing decision for Government.
Local, State and Commonwealth Governments have responsibility for the upkeep of public assets many of which include public open space and other outdoors areas. At the State and Federal level these include schools, universities, sporting facilities, hospitals and defence facilities. These services may be outsourced, individual departments may undertake maintenance and purchase their own equipment or they may purchase equipment through a central purchasing facility. With the central purchasing facility these items are generally purchased under contract. While there is an increase in the inclusion of environmental considerations in the selection criteria for purchasing goods and services especially under contract these considerations mainly relate to waste management and recycling criteria and not air emissions. .
Local councils in some states for example NSW generally take responsibility for ground maintenance within their council areas or for some smaller councils, the service may be contracted to a neighbouring council. In other states such as Victoria there is a trend to outsource ground maintenance contracts to commercial providers.
It is unknown what proportion of total sales that direct Government purchases represent however it likely to represent a relatively small share of several percent of the overall market.
In summary:
• The general household consumer represents the major market segment for garden equipment, accounting for up to 90% of product sales.
• Government is likely to be relatively small direct purchaser of garden equipment.
• Commercial garden services to households purchase approximately 2.5% of lawnmowers per year and 3.7% of brushcutters.
• Large ground maintenance companies are likely to prefer larger and more powerful equipment such as ride-on mowers.
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6. Result of Stakeholder Consultation
6.1 Regulations
The Small Engine Expert Panel – Outdoor Equipment considered in depth an approach to take to improve the emissions performance of outdoor garden equipment sold in Australia. Discussions were particularly focused on the growing influence of cheap, high emissions imported products together with the difficulties that the local manufacturer of lawn mowers is likely to face in complying with the relevant overseas standards. As part of this process the industry representatives on the Panel held additional discussions and they consulted international industry experts at the manufacturing level in Europe, the USA and Japan.
OPEA’s preference is for the adoption of regulations based on the USEPA standards with Phase 1 being adopted possibly from as early as 2007-08. The industry then proposes that Phase 2 be introduced in 2012. Phase 1 USA EPA standards were adopted in the USA in 1995 to be applied to equipment manufactured from 1997 and Phase 2 standards were introduced in 2002 through to 2007 and these included averaging, banking and trading provisions. A comparison between the USA Phase 1 and Phase2 standards is given in Table 14. The USEPA is discussing Phase 3 limits, for the adoption in 2010/2011, which includes tighter exhaust emission limits for non-handheld equipment.
The emissions limit of the two stroke lawn mower manufactured by the sole Australian manufacturer are well above USA Phase 1 limit for non-handheld equipment. One avenue to address this issue, which was supported by the Expert Panel – Outdoor Equipment, would be to place lawn mowers in the US EPA Category 5 (engines >50cc). This would result in emissions for two stroke lawnmowers being limited to 161 g/kW-hour HC + NOx compared to the USA regulated limit of 16.1 g/kW-hour HC + NOx. Doing this would align the ramp-up timetable for mowers with that of other garden products.
Table 14: Comparison between the USA Phase 1 and Phase 2 standards
Emission Limits G/kW-hr
Phase 1 (1997 –2001) Phase 2 (2007) * HC NOx HC+NOx CO HC+NOx CO
Non-handheld I-A
In addition to limiting emissions the Expert Panel support the inclusion of the durability criteria, which apply in the USA under Phase 2 standards, and certification documentation from either the USA or Europe as adequate proof of conformity. Equipment that has not been tested and certified to USA or European standards will be required to have the engines tested in a NATA certified laboratory.
Some in the industry argued that regulations should include provisions for averaging for companies that wish to use it however they felt banking and trading provisions would not be necessary. Industry representatives were not supportive of any Australian consumer labeling requirement, instead OPEA members are willing to supply emissions data for inclusion in a web-based database that would allow purchasers to assess the environmental credentials of different makes and models.
6.2 Discussion on recommended regulations
Timing of introduction
Some industry representatives argue that introduction of Phase 1 standards in 2007-08 will not give the industry an adequate transition period in which to develop competence in emissions certification, establish new procedures and tooling in the dealers workshops, train dealers and technicians on legal requirements, distribute specific tooling and spare parts and reduce stocks of old (non certified) products without incurring an undue financial burden. While others in the industry prefer progressing straight to phase 2 standards.
If the OPEA preference for the adoption of the United States Phase 1 regulations, which operated in the USA between 1995 and 2001, were introduced in Australia in 2007-08 they would be well behind the USA standards and world’s best practice. Furthermore the introduction of the United States Phase 2 - 2007 limits in Australia in 2012 would, if the USEPA introduce Phase 3 in 2010-11, see emission limits for lawnmowers and other non handheld garden equipment in Australia still lagging United States standards and world’s best practice,
To introduce regulations in 2007-08 will require Government firstly to determine the most appropriate mechanism under which to enact the regulations, draft the regulations, prepare the regulatory impact assessment, consult with the broader community and then finalise the regulations. It is likely an Act of Parliament will be required at the Commonwealth level followed by complementary legislation at the State and Territory level. It is possible for this to be achieved in less than a two year timeframe (as was the case for the Water Efficiency Labelling Scheme). However regulations that do not have a level of perceived urgency would take longer. The level of importance and urgency to control emissions from small engines has yet to be debated and determined.
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Modified USEPA limits for lawnmowers
From the 183 lawn mowers identified through the market survey Victa is the main (possibly sole) provider of two stroke mowers with the other lawnmowers having cleaner four stroke engines.
Victa is undertaking work to produce a cleaner product. Victa estimates it would need a number of years to complete development, production tooling and commercialisation of the cleaner engines. In January 2007 it released a new two stroke carburettor lawnmower that has reduced engine emissions by more 30% but the combined HC and NOx emissions are still above USEPA Phase 1 limits. Victa says this new engine is the outcome of four years of collaborative work by Victa and the University of Technology Sydney. Victa is continuing with this research to further reduce emissions.
A clause that allows exemptions to be granted, as occurs in other countries, could be included in the regulations however Victa argues that this would create uncertain trading conditions for the company for a period of time until an exemption were granted.
Placing lawn mowers in the US EPA Category 5 (engines >50cc) has the risk of opening the Australian market to more two stroke lawn mowers, which has the greatest use of any outdoor powered equipment, however it should see the continuance of the sole engine being manufactured in Australia. In 1995 when it was introducing small engine emission limits the USEPA faced a similar issue with two stroke lawn mowers and used a similar approach by allowing two stroke lawn mowers to comply with the handheld standards. It also specified that the number of two stroke lawnmower engines allowed to meet handheld standards would be subject to a declining annual production cap with the allowance provided by the production cap being phased out in 2003. There is also similar precedent for small engine emission limits that depend on engine type - European regulations for marine outboard motors set less stringent requirements for two stroke motors.
Averaging Banking and Trading Provisions
The US EPA did not have averaging, banking and trading provisions in Phase 1 and therefore all small outdoor engines were required to meet the Phase 1 limits. It only introduced ABT provisions in the much more stringent Phase 2 as they would allow the most economic introduction of cleaner engines. The industry claims the systems to use this provision are available and can be implemented in Australia by those who wish to use it at little cost to government.
Industry claim that any supportive economic data related to averaging is sensitive and confidential. It is there difficult, without substantial justification by the industry, to support the provision for averaging in conjunction with Phase 1 particularly given the elapsed time between the introduction of Phase 1 in the USA and their recommended introduction in Australia. If there are some low volume equipment items that still cannot meet the USAEPA Phase 1 standards then these could be subjected to
32
exemptions if adequate justification can be provided (exemptions for small volumes were available under the USEPA regulations).
It was noted that for government to implement regulations a regulatory impact statement is required and this requires an assessment of the costs and benefits of the options considered with clear overall benefits shown for the preferred option. Therefore if the option for manufacturers to use averaging were to be considered more information to support its inclusion would be required.
Other options that could be considered to circumvent the inclusion of averaging include:
i. including clauses that give manufacturers the ability to apply for exemptions from the regulations for classes of equipment that have small sales volumes (these provisions are available in the USA)
ii. limiting the regulation to popular types of equipment
iii. using the end-of-model life provisions that have been used in the Australian Design Rules for cars. In effect the end of model life provisions require new designs to comply from the implementation date but allow older models to remain on sale for a few more years. This is an alternative to ABT because it facilitates earlier introduction of the regulation.
iv. Having a phase in period of say 2 years during which existing models can continue to be sold, but new models coming on to the market must comply with the new standards. At the end of the phase-in period all models must comply with the new standards. This is an approach that is used when Australian Design Rules (ADRs) are introduced for motor vehicles.
Consumer Information
Current Australian directions to reduce the environmental impact of consumer products favor tiered benchmarks using a ‘star’ rating system (see Appendix 3 for examples such as the Mandatory Energy Efficiency Label and the Water Efficiency Labelling Scheme).
As products generally arrive in Australia assembled and packaged industry considers a mandatory requirement to label products with an Australian style star rating would impose a cost on distributors that would drive up the retail price of products. Instead the OPEA members were willing to supply emissions data for inclusion in a web-based database that would allow purchasers to assess the environmental credentials of different makes and models. Given the diverse nature of the industry it is unlikely a database would provide complete coverage of all products on the Australian market but inclusion in the database would indicate that the manufacturer has a commitment to environmental performance. It was acknowledged in discussions that at least some Phase 2 compliant products would become available prior to 2012 and the web-based database would provide one method to promote those cleaner engines.
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In summary the Recommendations of the Expert Panel
1. Mandatory air pollutant emission standards to be introduced in Australia for all outdoor equipment (50cc) product classifications. Implementation timing to be as in Recommendation 3 above.
5. All products also to be certified to relevant EPA durability categories.
6. Subject to further review, ABT (if included) may be phased out after 2012.
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7. The Way Forward
The optimum approach for garden equipment out engine emissions of options needs to be sustainable and cost effective. This will need to be determined through a costs and benefits analysis (CBA). CBA assigns monetary values and typically assesses the impacts on the consumer, on human health, on the environment, on industry and on government. A detailed costs and benefits analysis is beyond the scope of this report, however the following sections draws on available information to provide some indication of the possible costs and benefits that are associated with emissions from garden equipment engines.
Air Quality Benefits
Environment Canada estimated the introduction of the regulations would result in a 44 percent reduction in combined HC+NOx emissions from small engines used in garden equipment and reduction in individual air pollutants over a 25 year period as shown in Table 15: The Canadian estimates incorporate the benefits that would accrue from the MOU signed with the industry in 2000 plus the benefits from the regulations introduced in 2003. In 2000 Canada imported around 1.3 million small spark-ignition engines and machines (i.e. a similar number to Australia) with 80% supplied by the USA.
Table 15: Canadian Small Spark-Ignition Engine Emissions in Year 2025
Substance Base Case Emissions in 2025
Emissions in 2025 with Regulations
Percentage Reduction in 2025 (Regulations vs Base Case)
Criteria Air Contaminants (kilotonnes)
HC 77.2 41.0 46.9%
NOx a 8.4 6.7 20.1%
CO 1,413 1,403 0.7%
Greenhouse Gas (kilotonnes)
CO2 2,903 2,645 8.9% Base case year 2000 (accommodating voluntary agreement) Source: Canada Gazette, Part II, Vol. 137, No. 24, 2003-11-19
Other Environmental Costs and Benefits
In addition to the human health benefits associated with reduced exposure to ozone there is a range of other public benefits including reduced damage to vegetation and therefore higher crop yields, less damage to materials and structures, particularly
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some rubber products, and improved visibility due to a reduction in smog haze. Plus there are benefits associated with lower emissions of other air pollutants.
To date there appears to have been little work undertaken in assigning a monetary value to these benefits as it is considered that they are likely to be small compared to human health impacts
Health Costs and Benefits
The Final Impact Assessment for the Ambient Air Quality National Environment Protection Measure (NEPC 1998) estimated that the health damage costs from exposure to ozone nationally to be in the range of $90 – $270 million (in 1998 dollars). This figure did not include mortality costs because of difficulty in assigning a figure to human life, nor did it include costs associated with minor symptoms such as sore throat, cough, headache, chest discomfort and eye irritation that can result from ozone exposure. On the cost of ozone exposure the Impact Assessment states that ‘the social well-being associated with potentially 6 and 20 million fewer irritating symptoms annually cannot be reliably quantified, but at $1 a symptom, it adds up to an appreciable amount’.
Since the Air NEPM Impact Assessment ozone levels in Australian urban areas have not fallen significantly but the population and medical costs have increased since then. However using the above figures to make a rough estimate the contribution made by engines used in lawnmowers (i.e. not including other garden equipment) to the health damages cost from ozone exposure would be, at a minimum, $3.6 - $10.8 million not including the cost of mortality or minor symptoms. As any action on these engines is likely to only remove high emission engines over a decade or more a CBA would be required to include an assessment of the proportional health benefits that would accrue from only removing the high emitters over time.
Costs and Benefits to the Consumer
In 1995 the USEPA estimated that on average, the cost to the engine manufacturer to install the necessary emission control technology to meet Phase 1 standards (which didn’t have ABT) would be approximately $US2 per engine used in nonhandheld equipment and $US3.50 per engine used in handheld equipment. It also estimated that this would translate to sales-weighted average price increases of about $US7.
The introduction of phase 2 regulations USEPA estimated would result in price increases of between $US20 and $US64 for handheld equipment depending on the equipment class (USEPA, 2000) where handheld engines ranges in price from $60 to $1,000 (USEPA, 1995).
In addition to emission reductions, the implementation of exhaust emission limits has the advantage of reducing fuel consumption and lowering operating costs to the consumer. For example the USEPA estimated that for Phase 1 limits that applied between 1995 and 2001, on an average sales-weighted engine basis, would decrease fuel consumption by 26 percent for non handheld equipment and a 13 percent decrease in fuel consumption for handheld equipment (USEPA, 1995). Phase 2
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(current limits) would result in a further decrease in fuel consumption of approximately 30 percent for handheld engines.
When the USEPA considered the fuel savings offset and the retail price increase it estimated that the average sales-weighted lifetime increase in cost would be about $US6.50 per handheld engine, while nonhandheld engines will realize a lifetime savings of about $US2.50 per engine. This does not include the lifetime savings in maintenance costs, which should further benefit the consumer (USEPA, 1995).
Euromot (The European Association of Internal Combustion Manufacturers) claims that compliance with European minimum performance standards that do not have ABT provisions adds around 30% to the cost of some products that have had to be brought into compliance4 compared to products sold under the ABT system in the US.
Costs and Benefits to Industry and Government
As there is only one local manufacturer among the 43 distributors of powered outdoor garden equipment sold in Australia and all others are importers the main costs to reduce the emissions contribution made by these engines will be associated with program administration and compliance particularly if regulations are introduced.
The Productivity Commission, an independent agency which is the Australian Government’s principal review and advisory body on microeconomic policy and regulation recently examined the cost effectiveness of measures to improve the energy efficiency in household appliances. As part of its review, ‘The Private Cost Effectiveness of Improving Energy Efficiency’, it examined labelling programs (i.e. regulated tiered benchmarks) and minimum mandatory energy efficiency requirements (i.e. a regulated simple benchmark). While the household appliance market is considerably larger than the garden equipment market the Commission’s final report contains some information that is useful for determining the approach that could be used to establish an emissions reduction scheme for garden equipment . A summary of relevant sections of this report is provided in Appendix 3.
The Commission identified both administration and compliance costs associated with labelling programs and minimum mandatory energy efficiency requirements as well the impacts these had on product suppliers.
The Department of the Environment and Water Resources provided details to the Commission on the costs involved in administering both the labelling scheme and the minimum performance standards for energy programs. The information provided showed that:
• the administration costs of the simple benchmark approach were substantially lower (less than one tenth) than for labelling and 84 per cent of administration costs were passed on to appliance purchasers, with the remainder borne by governments;
4 Presentation by Dr Holger Lochmann, Rob Ba
