power sources, including initial investment costs, long-term fuel and maintenance costs, performance, runtime, in-use emissions, and lifecycle emissions require careful consideration when considering equipment bans. Historically, legislators and regulators have failed to account for these trade-offs and/or accurately determine the benefits of banning equipment based on a particular fuel source. Finally, the Clean Air Act prohibits states (other than California) and localities from “( adopting or enforcing) any standard or other requirement applicable to the emissions from spark-ignition engines small than 50 horsepower ” 1 . The legislature’s oversight of this code results in Alexandria incorrectly concluding that the municipality adopt or enforce its own rules on small off-road engines or equipment. It cannot. The Clean Air Act, under protection of the Supremacy Clause of the U.S. Constitution, reserve this authority solely for the U.S. Environmental Protection Agency (EPA). No “One-Size-Fits-All” Power-Source Approach There is a wide range of gas- and battery-powered equipment on the market. However, different power sources come with trade-offs. Cost, performance, and runtime differences are the most common concerns for landscape professionals. Following a June 2024 off-road stakeholder workshop, the EPA and Department of Energy published A Market and Technology Assessment for Off-Road Vehicle & Equipment Energy and Emission Innovation report (December 2024). The report highlights the complexity of developing emissions reductions strategies for the off-road the sector, finding “ there is no one solution for substantial emissions reductions (of the off-road sector) ”, and that “ commercial (lawn and garden) equipment (emissions reductions)… may be reliant on (sustainable liquid fuels for future emissions reductions). ” The report highlights barriers to widespread commercial-use electrification, including cost, weight, and the need for long run times between charging, and identifies commercial-use equipment as a “notable exception” from the sectors residential electrification trends. 2 As a result, there is no one-size-fits-all power-source approach when considering the wide range of equipment types, user/use-cases, power-source trade-offs, and benefits. Small Spark-Ignited Engine Emissions Are Federally Regulated – and Insignificant Many believe outdoor power equipment are unregulated, high-emitting sources of exhaust gas emissions. This is not true. The outdoor power equipment industry has a long history of working cooperatively with the U.S. EPA to develop a regulatory framework which has driven low-emissions technology solutions in outdoor power equipment for over three decades. Today, the EPA is on its third phase of pollutant controls for small engine-powered equipment, resulting in up to 90% reductions in exhaust gas and evaporative emissions from previously unregulated machines.
1 40 CFR Part 1074.110(b) 2 United States Environmental Protection Agency & Department of Energy, A Market and Technology Assessment for Off-Road Vehicle & Equipment Energy and Emission Innovation , December 2024
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