APPENDIX C SUMMARY OF NSW DEC REVIEWS OF EMISSIONS FROM LAWN & GARDEN EQUIPMENT AND RECREATIONAL MARINE ENGINES

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1 [C1] APPENDIX C SUMMARY OF NSW DEC REVIEWS OF EMISSIONS FROM LAWN & GARDEN EQUIPMENT AND RECREATIONAL MARINE ENGINES

2 [C2] C1 Summary of NSW DEC Review of Emissions from Lawn and Garden Equipment The most recent investigation into the impacts of air emissions from lawn and garden equipment in Australia has been undertaken by the NSW DEC, with the findings of this study reported in Measures to Encourage the Supply and Uptake of Cleaner Lawnmowers and Outdoor Handheld Equipment (NSW DEC, 2005a). Some of the key findings of this study are summarised below. Lawn mowers produce emissions which are a notable source of urban air pollutants. The main sources of the emissions are the exhaust, evaporation from the engine and fuel storage, and emissions from petrol spillage. The potential impact of lawn-mower emissions in an urban environment is often increased because of concentrated use on a few days (e.g. summer weekends). Considering that the average lawn in an Australian city takes between half an hour and an hour to mow each week (DEH 1997a, cited Farrington 1988, Priest 1996), and people tend to take advantage of fine weekends, it is likely that several people in an adjoining area could choose to mow their lawn on the same day. Assuming six people in a block of ten homes decided to mow their lawn during the same period, the emissions would equate to about 240 cars driving around in their yards for almost an hour (DEH 1997a, cited Young 1997). There are a number of factors influencing the amount of pollution a lawn-mower will produce during operation. These include, but are not confined to: engine design, lawn-mower age, techniques of operation, lawn size, maintenance levels and weather conditions. It is also recognised that, while electrically-powered lawn and garden tools produce essentially no pollution from exhaust emissions or from fuel evaporation, even electric equipment is not pollution-free, because the power plants that generate the electricity are emissions sources. The Australian Outdoor Power Equipment Association (OPEA) represents about 80% of the manufacturers, distributors and dealers in the industry (NSW DEC 2005a). 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 (NSW DEC 2005a). Sales estimates sourced from OPEA by the DEC are shown in Figure C.1. OPEA cautions that there is considerable uncertainty about the estimates for brushcutters/ grass trimmers, portable generators and ride-on mowers in particular, as OPEA s figures only represent 50%, 40% and 65% respectively of sales of these products. (Note: "Blower/vac" is an industry term for equipment that combines blowing and vacuuming functions). The DEC also notes that there have been some changes in the industry since these 2002 figures (NSW DEC 2005a). For example, four-stroke blower/vacs are now on the market and are likely to make up a small, but growing, proportion of sales of this product. Similarly, the proportion of four-stroke brushcutters is likely to be increasing. It appears that four-stroke engines are dominating the heavier types of equipment such as ride-onmowers. More recent data provided by OPEA for the 2004 calendar year is summarised in Figure C.2, which shows the increase in sales figures over the past two years.

3 [C3] OPEA data for 2002 Generator Ride-on-mower 2-stroke 4-stroke Blower or Blower/ Vacuum Chipper/shredder Chainsaw Brushcutter/Trimmer Lawnmower Annual sales (x1000) Figure C.1: OPEA Estimates of Equipment Sales in 2002 (Source: NSW DEC 2005a) Figure C.2: OPEA Equipment Sales Data for 2004 (Source: Pers. Comm. Keith Billing, OPEA) Within the industry there is concern regarding the impact on the local market of increasing imports of small engines from Asia which it is believed do not meet any emission standards (NSW DEC 2005a). Import data provided by OPEA indicate that around 571,000 units of outdoor powered

4 [C4] equipment were imported from China in 2004, with OPEA estimating that a further 100,000 units (mainly ride-on mowers, trimmer/brushcutters and pumps) were imported from other countries. OPEA also reports that in previous years, imports from China were extremely small; around 10% of current numbers. A profile of the environmental performance of equipment currently on the Australian market has been developed by DEC, with each item of equipment being assessed on its compliance with USEPA, CARB or European regulations (see Table C.1). Of the products where emissions compliance was specified, it was concluded that at least 55% of new two-stroke carburettor engines across all product types do not meet any emissions standard. All but two specified fourstroke engine products have been shown to comply, or are likely to comply, with at least one emissions limit (either USEPA/ CARB or Europe) and showed greatest compliance to the strictest emission standard (21% of specified four-strokes comply with CARB 2006). Sales estimates for NSW were combined with data about emissions compliance to produce Figure C.3, which should be regarded as indicative only. Information on specified equipment detailed below represents 36% of the total market, i.e. 335,000 sales of 930,000 total sales. This graph shows the distribution of emissions compliance of products by number of products in each emissions category and estimated sales (based on manufacturer's advice about sales quantities for each model). Table C.1: Estimated Emissions Compliance - All Lawn Mowing and Garden Equipment (Source: NSW DEC 2005a) Stroke And Induction a Best Standard Unknown 2c 2i 4c 4i All Unspecified Specified - Does Not Comply Euro Likely USEPA Likely CARB Likely CARB CARB Total specified Total % Comply Or Likely >1% 36% - 54% - 31% a 2c = 2-stroke carburetted; 2i = 2-stroke, fuel injection; 4c = 4-stroke carburetted; 4i = 4-stroke, fuel injection "Unknown" means the type of engine (2c, 2i, 4c or 4i) is unknown (but is most likely to be 2c). Specified means that the status of the products emissions compliance was able to be identified. "Unspecified" means that the status of emissions compliance was unable to be identified. "Does not comply" means the manufacturer/distributor has indicated that the equipment does not comply with any overseas emissions standard. "Likely" means that compliance could not be confirmed but the equipment is likely to comply with exhaust emission limits of the relevant regulations.

5 [C5] % of all sales or models 100% 90% 80% 70% 60% 50% 40% 30% 20% Est.Sales Number of products 10% 0% NONE LIKELY C ARB01 C ARB06 Emissions Standard Figure C.3: Estimated Sales Distribution for all Specified Equipment, by Emissions Compliance (Source: NSW DEC 2005a) Estimated Emission Compliance for Highest Selling Products Table C.2 contains data that is believed to cover all brushcutters currently sold on the Australian market. Brushcutters in the specified category are estimated to comprise 43% of total Australian brushcutters sales, i.e. 43,150 of 100,000 units sold (OPEA 2002 estimates). Sales figures should be regarded as indicative only. Table C.2: Estimated Emissions Compliance Brushcutters (Source: NSW DEC 2005a) Stroke And Induction Best Standard Unknown 2c 2i 4c 4i All Unspecified Specified Does Not Comply 7 7 Euro Likely 0 USEPA Likely 7 7 CARB Likely 9 9 Carb Carb Total specified Total a 2c = 2-stroke carburetted; 2i = s-stroke, fuel injection; 4c = 4-stroke carburetted; 4i = 4-stroke, fuel injection Note each model is placed in one category only.

6 [C6] Table C.3 below is believed to cover all lawnmowers currently sold on the Australian market. Lawnmowers in the specified category are estimated to comprise 65% of total lawnmower sales, i.e. 160,750 units of 246,000 units sold, (OPEA estimates for 2002). Sales figures are based on manufacturers and distributors estimates and should be regarded as indicative only. Table C.3: Estimated Emissions Compliance Lawn Mowers (Source: NSW DEC 2005a) Stroke And Induction Best Standard Unknown 2c 2i 4c 4i All Unspecified Specified Does Not Comply Euro Likely USEPA Likely CARB Likely CARB CARB Total Specified Total a 2c = 2-stroke carburetted; 2i = s-stroke, fuel injection; 4c = 4-stroke carburetted; 4i = 4-stroke, fuel injection Note each model is placed in one category only. C2 Summary of NSW DEC Review of Emissions from Recreational Marine Equipment The most recent investigation into the impacts of air emissions from marine engines in Australia has focussed on outboard motors and personal watercraft. This study was undertaken by the NSW DEC, with the findings reported in Measures to Encourage the Supply and Uptake of Cleaner Marine Outboard Motors and Personal Watercraft (NSW DEC, 2005b). Some key findings of this study are summarised below. In general, marine outboard engines and personal watercraft (which use the same engine technology as outboard motors) are not as advanced in environmental terms as motor vehicle engines. Substantial engine power is required to overcome the high resistance encountered when pushing a small boat at high speed through water. As a result, even the better-performing outboard engines emit significantly higher levels of air pollutants than typical modern car engines, when assessed in hours of operation or kilometres travelled. Carburettor two-stroke engines used in outboard engines and personal watercraft emit proportionally more volatile organic compounds (VOCs) and other air pollutants than the other types of outboard engines sold on the Australian market. Direct fuel injection overcomes the problem of unburnt fuel and there are some fuel injection two-stroke outboard engines available in Australia that meet the stringent exhaust emission limits that apply in the USA. Four-stroke engines, either carburettor or fuel injected, are generally

7 [C7] quieter, more fuel efficient, have separate reservoirs for fuel and oil, are less polluting and have a longer product life compared to conventional two-stroke products. Over 10,000 new outboard engines are sold in NSW each year and this is estimated to represent 27% of sales Australia wide. Up to 80% of sales are to households with the remaining 20% being commercial sales to government departments and rescue organizations. The Outboard Engine Distributors Association estimates that 69% of outboards sold in Australia in 2004 were two stroke carburettor engines. The most frequent use of boats is for fishing, which accounts for an estimated 75 percent of the household use. According to the Australian Bureau of Statistics (ABS) (2003) fishing, either shore- or boat-based, is one of the top ten most popular physical activities for Australians and is most popular with males, especially those over 45. In 2002 the ABS also reported that over a 12 month period 0.9% of Australians aged 18 years and over had been water-skiing or power boating. There are few restrictions on where boats can be used. In comparison, there is a range of regulations that restrict the way personal watercraft are used. For example, personal watercraft are banned from Sydney Harbour and from operating between sunset and sunrise anywhere in NSW. In some areas, personal watercraft are not to be operated in an irregular manner (for example riding in a circle or unnecessarily weaving) within 200 metres from the shore or where a dwelling is located within 200 metres off a riverbank or shore and is visible from the water. In Australia, sales of personal watercraft are only around 2,000 each year. In an analysis of the current Australian market for recreational marine equipment, a total of 331 models of outboard motors and personal watercraft were identified by the NSW DEC, covering eight brands/makes of outboard and four makes of personal watercraft. A breakdown of this data is provided in Table C.4. Table C.4: Current Recreational Marine Equipment on the Australian Market (March 2004) (Source: NSW DEC 2005b) a Type Ranges Stroke a Outboard motors Engine power: 1.5kw to 223kW 2c: 140 (47%) 8 makes, 296 models Annual Aust sales: ~40,000 Personal Watercraft 4 makes, 35 models Annual Aust. sales: ~2000 Engine displacement: ml Price: $799 - $30,000 Engine power: 54kw to 160kW Engine displacement: ml Price: $10,900 -$21,990 2i: 33 (11%) 4c: 111 (38%) 4i: 12 (4%) 2c: 17 (49%) 2i: 5 (14%) 4c: 8 (23%) 4i: 4 (11%) Unspecified: 1 2c = 2-stroke carburetted; 2i = s-stroke, fuel injection; 4c = 4-stroke carburetted; 4i = 4-stroke, fuel injection The general consumer s outboard engine has a lifespan of between 7 to 15 years depending on the level of use and how the engine has been maintained.

8 [C8] Two-stroke engines are often seen as attractive because they are considerably cheaper than four-stroke engines and have greater pull, especially for activities like water-skiing. Figure C.4 shows estimated Australian sales of outboard motors for a range of engine powers, based on advice received by the NSW DEC from manufacturers. It indicates that the highest sales are for engines in the kw range, with the highest number of different engine models available in the kw engine range. Figure C.4: Estimated Outboard Engine Sales Distribution by Engine Power (Source: NSW DEC 2005b) Table C.5, taken from the NSW DEC report, identifies the estimated compliance of outboards available on the Australian market with CARB/USEPA requirements (the USEPA 2006 regulations are treated as equivalent to CARB 1 star requirements). It shows that at least 53% of outboard motors comply with some emission regulation and these are predominantly either fuel-injected two-stroke or four-stroke. Few two-stroke carburettor engines complied with any regulations.

9 [C9] Table C.5: Likely Compliance of Outboard Motors with Emissions Regulations (Source: NSW DEC 2005b) Stroke and Induction Standard 2c 2i 4c 4i All Unspecified Specified None CARB 1S/USEPA CARB 2S CARB 3S Total specified Total % compliance with some standard 6% 88% 96% 100% 53% a % CARB 2S# or better 0% 88% 67% 100% 39% 2c = 2-stroke carburetted; 2i = 2-stroke, fuel injection; 4c = 4-stroke carburetted; 4i = 4-stroke, fuel injection Specified means that the status of the products emissions compliance was able to be identified "Unspecified" means that the status of emissions compliance was unable to be identified CARB 2 is the current Californian standard. 2i includes both direct injection and conventional fuel injection The NSW DEC combines the NSW sales estimates with data about emissions compliance to produce Figure C.5. This graph shows the distribution of emissions compliance of products by number of products in each emissions category and estimated sales (based on manufacturer s advice about sales quantities for each model). "Model count" is the total number of products determined to be in each emissions category. This figure shows that the largest proportion of boat engines bought in Australia, across all engine sizes are in the unspecified category, that is their emissions performance is unknown (1 st column in graph). It is likely that many of these motors would be in the categories None or CARB1 since they are all two-stroke carburettor engines. It is noted by DEC that no sales data were provided for the models that comply with CARB 1 star requirements even though this category had the highest number of different models available on the market.

10 [C10] Figure C.5: Estimated Sales Distribution for Outboard Engines, by Emissions Compliance (Indicative Only), (Source: NSW DEC 2005b) A summary of the NSW DEC analysis of personal watercraft engines compliance with emission standards is provided in Table C.6 and Figure C.6. Figure C.6 suggests that low emissions models of personal watercraft register higher sales than models with high emissions. Table C.6: Likely Compliance of Personal Watercraft with Emissions Regulations (Source: NSW DEC 2005b) Stroke And Induction Standard Unknown 2c 2i 4c 4i All Unspecified 1 1 Specified None CARB 1S CARB 2S CARB 3S 2 2 Total specified Total % compliance with some standard 18% 80% 100% 75% 54% % CARB 2S or better 0% 40% 100% 75% 37% "Unknown" means the type of engine (2c, 2i, 4c or 4i) is not known. Specified means that the status of the products emissions compliance was able to be identified. "Unspecified" means that the status of emissions compliance was unable to be identified. 2i includes both direct injection and conventional fuel injection

11 [C11] Figure C.6: Estimated Sales Distribution for Personal Watercraft, by Emissions Compliance (Indicative Only), (Source: NSW DEC 2005b) The Outboard Engine Distributors Association (OEDA) provided the NSW DEC with Australian sales statistics for different types of outboard motor from 1998 to 2004 (see Table C.7). OEDA represents the companies that sell about 90% of the outboard engines and personal watercraft in Australia. ODEA and the Boating Industry Association of NSW (BIANSW) expect that the proportion of two-stroke carburettor engines will gradually drop from 69% to 46% of all sales between 2004 and This is based on expected withdrawal of two-stroke carburettor models from the market and recent demand for fuelinjected engines. These industry organisations also expect 5% turnover of the outboard motor fleet each year. Table C.7: Trends in Outboard Sales (based on OEDA/BIANSW data) (Source: NSW DEC 2005b) Year 2c 2i 4c/i Total %2i or 4 Australian sales by OEDA members ,186 (84%) 190 (<1%) 6,035 (16%) 38, % ,594 (83%) 432 (1%) 6,708 (16%) 41, % ,984 (80%) 683 (2%) 7,724 (19%) 41, % ,263 (72%) 1,139 (3%) 10,041 (25%) 40, % ,139 (74%) 1,319 (3%) 10,122 (23%) 43, % ,823 (72%) 1,800 (4%) 10,324 (24%) 43, % ,112 (69%) 2,304 (5%) 11,817 (26%) 45, % Note that 2i includes both direct injection and conventional fuel injection

12 [C12] The NSW DEC combined these data with sales forecasts by non-odea brands to prepare Figure C.7. Based on these combined figures, the proportion of two-stroke carburettor engines is expected to decrease from 66% to 43% of all new engine sales between 2004 and Figure C.7: Predicted trends in outboard motor sales in NSW (Source: NSW DEC 2005b) In the DEC report, data provided by Honda Marine on 2002 world sales for outboard motors showed that not as many clean new engines are being sold in Australia as there are in other developed countries: USA 50% four-stroke, expected up to 60% by end of Canada 56% four-stroke Europe 50% four-stroke, expected 60% by end of 2003 Australia 25% four-stroke. Based on the above information, the NSW DEC concluded that: at least 94% of new two-stroke carburettor engines in Australia do not meet any emissions standard; over 96% of four-stroke engine products are likely to comply with at least one exhaust emission limit (either USEPA, CARB or Europe);

13 [C13] four-stroke and fuel-injected two-stroke engines showed greatest compliance to the strictest emission standard; and, it is estimated that about 39% of new outboard motors and 37% of new personal watercraft meet CARB 2 or 3 star requirements.

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