Industry is committed to advancing emission reduction technologies. In fact, numerous gas-powered equipment models, including many popular lawnmower and leaf blower options are certified well below federal standards – and well below “fact sheet” or outdated video comparisons. Lawnmowers and many leaf blowers are now powered by efficient four-stroke engines. “Traditional” two-stroke engines have been replaced by more efficient stratified charge technology and/or include catalysts to reduce exhaust gas emissions versus pre-regulated units. As a result, the EPA and DOE estimate the entire lawn and garden sector contribute just 0.4 percent of the nation’s greenhouse gas emissions, despite accounting for an estimated 117 million pieces of equipment. The lawn and garden sectors greenhouse gas emissions are many times less than the “industry”, “electric power”, “agriculture”, “light duty vehicles”, “heavy and medium vehicles”, “rail”, “maritime”, and “aviation” sectors. (And this is likely a significant overestimate because EPA has yet to accurately account for the electrification trends when estimating the sector’s emissions.) Small Spark-Ignited Engine “Facts” and Models do not Accurately Reflect Sector Emissions or Benefits of Banning Small Spark-Ignited Engines Commonly referenced “facts” and government emission models are misleading and significantly overestimate small spark-ignition equipment emissions. Accurate emissions estimates must be determined to support rulemaking benefits. Today, no such accurate estimates exist. In particular; • The California Air Resources Board (CARB) comparison of leaf blowers and mowers to automobiles ignore popular units certified to lower emissions levels, and calculate equipment emissions based on peak horsepower estimates – well above actual in-use averages. As a result, CARB’s broad-brushed comparison overestimates products’ emissions. • EPA’s MOVEs model is outdated for the small engine sector. MOVEs does not recognize recent electrification trends 3 . As a result, EPA overestimates sector emissions across the nation. • CARB SORE 2020 and EPA MOVEs models runtime, age and deterioration rates are overestimated. For example, based on telephone surveys, CARB recently estimated the average homeowner runs a lawn mower for 47 minutes per use. On the other hand, 2001 CARB-collected event logger data estimated 14 minutes of runtime per use. 14 minutes of runtime per use is a much more reasonable estimate considering that California’s average residential property size ranks 49 (of 50) at 0.19 acres – behind only Nevada. As a result, CARB and EPA (which has historically relied in-part on CARB emission factors) models overestimate sector emissions.
3 U.S. Environmental Protection Agency, EPA-420-R-18-010, Nonroad Engine Population Growth Estimates in MOVES2014b , Section 5.2, General Comments from Robert F. Sawyer, pg. 17 (July 2018), “RESPONSE: MOVES does not currently account for the relatively small fraction of nonroad equipment powered by electricity. EPA recognizes that electricity as a fuel for nonroad mobile sources is growing in market share, and that this penetration will need to be addressed in future versions of MOVES.”
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