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MANAGEMENT OPTIONS FOR

NON-ROAD ENGINE EMISSIONS

IN URBAN AREAS

Department of the Environment and Heritage

Job No 2050 15 November 2005

[i] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Project Title: Management Options for Non-Road Engine Emissions in Urban Areas

Job Number: 2050

Prepared for: Department for the Environment and Heritage

Air Quality Section

Status: Final

Date of release: 15 November 2005

Prepared by: K Lawrence, K Zeise, Dr P Morgan

Approved for release by: K Zeise

REVISIONS

Version Date Description Prepared by Reviewed by

V1 22-Jun-05 Working Draft K Lawrence K Zeise

V2 30-Aug-05 Revised Draft K Lawrence, Dr P Morgan K Zeise

V3 26-Sep-05 Final Draft K Lawrence, Dr P Morgan K Zeise

V4 27-Oct-05 Revised Final Draft K Lawrence, Dr P Morgan K Zeise

V5 15-Nov-05 Final K Lawrence K Zeise

QUALITY CHECKPOINTS

Project Phase Prepared by Approved by

Methodology K Lawrence K Zeise

Assumptions and raw data sources K Lawrence K Bawden

Internal review of manipulated data K Lawrence K Bawden

Report outline K Lawrence K Zeise

ACKNOWLEDGEMENTS

PAE would like to thank Dr Phil Morgan for his assistance in preparing this report and for undertaking the review and analysis of management options for non-road engine emissions in Australia. We would also like to thank the NSW DEC for their assistance in providing data and information on emissions from lawn and garden and recreational water craft.

DISCLAIMER and COPYRIGHT

This report is to be read subject to the report disclaimer and copyright statement located at www.pae.net.au

CITATION: This report should be cited as follows:

Lawrence, K, Zeise, K, & Morgan, P (2005), Management Options for Non-Road Engine Emissions in Urban

Areas, Consultancy report for Department for Environment & Heritage, Canberra. Prepared by Pacific Air & Environment Pty. Ltd.

© Pacific Air & Environment Pty Ltd 2005 ABN 23 887 350 026 www.pae.net.au

Brisbane Sydney Level 1, La Melba 59 Melbourne Street 3 Spring Street South Brisbane Qld 4101 Sydney NSW 2000 PO Box 3306 GPO Box 4216 South Brisbane Qld 4101 Sydney NSW 2001 Ph +61 7 3004 6400 Ph +61 2 8249 4464 Fax +61 7 3844 5858 Fax +61 2 8249 4001

2050 Final Report.doc PAE Job Number 2050

www.pae.net.auwww.pae.net.au

[ii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Table of Contents

EXECUTIVE SUMMARY .....................................................................................................VII

1 INTRODUCTION ......................................................................................................... 1

1.1 STAGE ONE: DESK-TOP EMISSIONS INVENTORY ...................................................................... 1 1.2 STAGE TWO: MARKET STATUS (IMPORT VERSUS DOMESTIC) ........................................................ 2 1.3 STAGE THREE: MANAGEMENT OPTIONS ................................................................................ 2

2 INVENTORY OF EMISSIONS FROM AUSTRALIAN NON-ROAD ENGINES....................... 4

2.1 NON-ROAD ENGINES INCLUDED IN THE INVENTORY................................................................... 4 2.2 POLLUTANTS INCLUDED IN THE INVENTORY............................................................................. 5

2.2.1 Volatile Organic Compounds (VOCs) ...................................................................... 5 2.2.2 Sulphur Oxides (SOX) .......................................................................................... 8 2.2.3 Nitrogen Oxides (NOX)......................................................................................... 8 2.2.4 Carbon Monoxide (CO) ........................................................................................ 8 2.2.5 Particulate Matter (TSP, PM10 and PM2.5)................................................................. 9

2.3 COMPILATION OF THE EMISSIONS INVENTORY.......................................................................... 9 2.3.1 ‘Adjusted’ versus ‘Non-Adjusted’ Emission Factors ..................................................10 2.3.2 Activity Data .....................................................................................................10 2.3.3 Temporal Variations ...........................................................................................10 2.3.4 Speciation of VOC Emission Estimates...................................................................11 2.3.5 Uncertainty in the Estimates................................................................................11

2.4 EMISSIONS INVENTORY..................................................................................................12 2.4.1 National Emissions Summary...............................................................................12 2.4.2 Comparison with NPI Reported Emissions ..............................................................17 2.4.3 Emissions in Urban Environments.........................................................................18

3 PRIORITISATION OF NON-ROAD ENGINE CATEGORIES ........................................... 25

3.1 PRIORITISATION METHODOLOGY .......................................................................................25 3.2 RESULTS OF CATEGORY PRIORITISATION ..............................................................................28

4 OVERVIEW OF NON-ROAD ENGINES USED IN AUSTRALIA ....................................... 30

4.1 IMPACT OF FUEL COMPOSITION ON EMISSIONS .......................................................................30 4.1.1 Fuel Standards ..................................................................................................31 4.1.2 Recycled Used Oil ..............................................................................................31 4.1.3 National Environment Protection (Diesel Vehicle Emissions) Measure .........................32

4.2 NON-ROAD ENGINE MARKETS IN AUSTRALIA .........................................................................32 4.2.1 Lawn & Garden Equipment ..................................................................................33 4.2.2 Airport Service Equipment...................................................................................35 4.2.3 Recreational Equipment ......................................................................................36 4.2.4 Light Commercial, Industrial and Construction Equipment........................................37 4.2.5 Agricultural and Logging Equipment......................................................................39 4.2.6 Recreational Marine Equipment ............................................................................40 4.2.7 Commercial Marine Equipment.............................................................................41 4.2.8 Trains and Locomotives ......................................................................................42


[iii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

5 MANAGEMENT OF NON-ROAD ENGINE EMISSIONS .................................................. 46

5.1 MANAGEMENT STRATEGIES IN PLACE OVERSEAS......................................................................46 5.1.1 US EPA.............................................................................................................46 5.1.2 California Air Resources Board .............................................................................52 5.1.3 Canada ............................................................................................................53 5.1.4 European Union.................................................................................................54

5.2 POTENTIAL EMISSION MANAGEMENT OPTIONS FOR AUSTRALIA .....................................................56 5.2.1 Do Emissions from Non-Road Equipment Need Management?...................................56 5.2.2 Potential Management Options.............................................................................57

5.3 ASSESSING APPROPRIATE EMISSION MANAGEMENT OPTIONS FOR AUSTRALIA.....................................69 5.3.1 Determining a Priority Order for Effectiveness of Management Options ......................69 5.3.2 Assessing the Reductions in Pollutant Emissions .....................................................70 5.3.3 Assessing the Timeline for Reducing Emissions.......................................................71 5.3.4 Assessing Costs and Benefits of Each Option..........................................................73 5.3.5 Determining the Effectiveness of the Management Options ......................................76 5.3.6 Determining the Priorities for Management ............................................................77

5.4 HOW THE MANAGEMENT OPTIONS MIGHT BE APPLIED ...............................................................80 5.4.1 Explicit Government Regulation ...........................................................................80 5.4.2 Co-Regulation ...................................................................................................81 5.4.3 Quasi-Regulation ...............................................................................................82 5.4.4 Alternative Instruments ......................................................................................83 5.4.5 Self-Regulation..................................................................................................84

6 CONCLUSIONS ......................................................................................................... 85

6.1 NON-ROAD ENGINE EMISSIONS INVENTORY FOR AUSTRALIA........................................................85 6.2 JUSTIFICATION FOR MANAGEMENT OF NON-ROAD ENGINE EMISSIONS.............................................86 6.3 RANKING OF EFFECTIVENESS OF MANAGEMENT OPTIONS ............................................................86 6.4 RANKING OF NON-ROAD ENGINE EMISSIONS FOR MANAGEMENT ...................................................86 6.5 RECOMMENDED MANAGEMENT APPROACH .............................................................................87 6.6 PREFERRED MANAGEMENT OPTIONS....................................................................................87

7 REFERENCES ............................................................................................................ 89

APPENDIX A ESTIMATION OF EMISSIONS

APPENDIX B EMISSION FACTORS AND DETAILED RESULTS OF EMISSIONS INVENTORY

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


[iv] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

LIST OF TABLES

Table ES.1: Non-Road Engines Included in this Study ............................................................ viii Table ES.2: Pollutants Covered by Inventory ........................................................................ viii Table ES.3: Current Non-Road Emission Load Estimates for Australia – Criteria Pollutants.............xi Table ES.4: Non-Road Emission Load Estimates for Australia – Speciated VOCs...........................xi Table ES.5: Criteria Pollutant Emission Load Estimates for Urban Areas.................................... xvi Table 2.1: Non-Road Engines Included in this Study................................................................ 4 Table 2.2: Pollutants Covered by Inventory............................................................................ 5 Table 2.3: Current Non-Road Emission Load Estimates for Australia – Criteria Pollutants .............13 Table 2.4: Current Non-Road Emission Load Estimates for Australia – Speciated VOCs ................13 Table 2.5: Comparison of National Emission Load Estimates with NPI 2003/4 Data (kg/yr)...........18 Table 2.6: Criteria Pollutant Emission Load Estimates for Urban Areas.......................................21 Table 3.1: Weighting System for Acute and Chronic Health Effects ...........................................26 Table 3.2: Benchmarks and Weightings with Respect to Human Health Impacts,.........................28 Table 4.1: Off-Road Motorcycles Sales in Australia .................................................................37 Table 4.2: Farming Equipment Sales in Australia....................................................................39 Table 4.3: Comparison of Locomotive Emissions with US Heavy-Duty Vehicle Emission

Standards....................................................................................................................44 Table 5.1: Current US EPA Emission Control Programs for Non-Road Engines.............................46 Table 5.2: Non-Road Emission Estimates Compared with Total National Emissions ......................57 Table 5.3: Key Characteristics of the Six Management Options for Emissions Control ..................58 Table 5.4: Potential Emission Management Options for Lawn and Garden Equipment...................61 Table 5.5: Potential Emission Management Options for Airport Service Equipment ......................62 Table 5.6: Potential Emission Management Options for Recreational Equipment..........................63 Table 5.7: Potential Emission Management Options for Light Commercial Equipment...................64 Table 5.8: Potential Emission Management Options for Industrial Equipment..............................65 Table 5.9: Potential Emission Management Options for Construction Equipment .........................65 Table 5.10: Potential Emission Management Options for Agricultural Equipment .........................66 Table 5.11: Potential Emission Management Options for Logging Equipment ..............................66 Table 5.12: Potential Emission Management Options for Recreational Marine Equipment..............67 Table 5.13: Potential Emission Management Options for Commercial Marine Equipment...............68 Table 5.14: Potential Emission Management Options for Trains and Locomotives ........................69 Table 5.15: Non-Road Engine Emissions compared with National Motor Vehicle Emissions............73 Table 5.16: Matrix for Ranking the Effectiveness of Management Options ..................................77 Table 5.17: Ranking of Source Categories to Determine the Priorities for Management Action.......78 Table A.1: Emission Data for Lawn Mower Engines – Australia and North America........................ 4 Table A.2: Lawnmower Emission Factors Used for NPI Air Emission Trials ................................... 4 Table A.3: Lawnmower Emission Factors Currently Specified in the NPI Handbook ....................... 4 Table A.4: Lawnmower Emission Factors Used in US EPA 1991 Nonroad Emission Inventory.......... 5 Table A.5: Garden Equipment Hours of Operation Used for Emission Calculations ........................ 7 Table A.6: Comparison of Annual Emission Load Estimates for Lawn Mowing Activities ................. 7 Table A.7: NPI Emission Factors for Airport Services Equipment ................................................ 8 Table A.8: Airport Service Equipment Factors Used in US EPA 1991 Emission Inventory................ 9 Table A.9: Airport Equipment Numbers Estimated for the US and Scaled for Australia .................. 9 Table A.10: Comparison of Airport Equipment Emission Loads using NPI & US Factors.................10 Table A.11: NPI Emission Factors for Stationary Petrol and Diesel Engines.................................11 Table A.12: NPI Emission Factors for Miscellaneous LPG Industrial Vehicle Engines .....................12 Table A.13: NPI Emission Factors for Industrial Vehicle Engines – Exhaust.................................14


[v] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Table A.14: NPI Emission Factors for Industrial Vehicle Engines – Evaporative and Crankcase ......14 Table A.15: Equipment Numbers Estimated in the US Inventory and Scaled for Australia .............16 Table A.16: Equipment Numbers Estimated in the US Inventory and Scaled for Australia .............17 Table A.17: Forestry Emission Factors Used in US EPA 1991 Non-Road Emission Inventory ..........18 Table A.18: Equipment Numbers Estimated in the US Inventory and Scaled for Australia .............19 Table A.19: Marine Pleasure Craft Emissions in the Sydney GMR (MAQS, 1992)..........................20 Table A.20: NPI Emission Factors for Recreational Boats .........................................................20 Table A.21: US EPA Inventory Emission Factors for Recreational Boats......................................21 Table A.22: Annual Fuel Use Estimates Used in Emission Calculations for Recreational Boats ........22 Table A.23: Selected Emissions from Commercial Shipping, 1992 (MAQS) .................................23 Table A.24: NPI Emission Factors for Commercial Boats and Ships ...........................................24 Table A.25: Annual Fuel Use Data for Commercial Marine Activities ..........................................24 Table A.26: US EPA Locomotive Emission Factors...................................................................26 Table A.27: NPI Handbook Locomotive Emission Factors .........................................................27 Table A.28: Comparison of Annual Emission Load Estimates for Locomotive Engines ...................28 Table B.1: Annual Emission Load Estimates for Australia (Non-Adjusted Emission Factors)............ 2 Table B.2: Annual Emission Load Estimates for Australia (In-Use Adjusted Emission Factors) ........ 2 Table C.1: Estimated Emissions Compliance - All Lawn Mowing and Garden Equipment ................ 4 Table C.2: Estimated Emissions Compliance – Brushcutters ...................................................... 5 Table C.3: Estimated Emissions Compliance – Lawn Mowers..................................................... 6 Table C.4: Current Recreational Marine Equipment on the Australian Market (March 2004) ........... 7 Table C.5: Likely Compliance of Outboard Motors with Emissions Regulations.............................. 9 Table C.6: Likely Compliance of Personal Watercraft with Emissions Regulations.........................10 Table C.7: Trends in Outboard Sales (based on OEDA/BIANSW data).......................................11


[vi] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

LIST OF FIGURES

Figure ES.1: Sources of Total Non-Road NOX Emissions in Australia .......................................... xii Figure ES.2: Sources of Total Non-Road CO Emissions in Australia ........................................... xii Figure ES.3: Sources of Total Non-Road SO2 Emissions in Australia ......................................... xiii Figure ES.4: Sources of Total Non-Road PM10 Emissions in Australia ........................................ xiv Figure ES.5: Sources of Total Non-Road Total VOC Emissions in Australia................................. xiv Figure ES.6: Estimated National Emissions of Individual VOCs .................................................xv Figure ES.7: Sources of Total Non-Road NOX Emissions in Urban Australia ............................... xvii Figure ES.8: Sources of Total Non-Road CO Emissions in Urban Australia ................................ xvii Figure ES.9: Sources of Total Non-Road SO2 Emissions in Urban Australia ...............................xviii Figure ES.10: Sources of Total Non-Road PM10 Emissions in Urban Australia ............................xviii Figure ES.11: Sources of Total Non-Road Total VOC Emissions in Australia ............................... xix Figure ES.12: Engine Category Contributions for Urban Emissions of Individual VOCs................. xix Figure ES.13: Prioritisation of Engine Categories................................................................... xxi Figure 2.1: Sources of Total Non-Road NOX Emissions in Australia ............................................14 Figure 2.2: Sources of Total Non-Road CO Emissions in Australia .............................................14 Figure 2.3: Sources of Total Non-Road SO2 Emissions in Australia ............................................15 Figure 2.4: Sources of Total Non-Road PM10 Emissions in Australia ...........................................16 Figure 2.5: Sources of Total Non-Road Total VOC Emissions in Australia....................................16 Figure 2.6: Estimated National Emissions of Individual VOCs ...................................................17 Figure 2.7: Distribution of Population Across States and Territories...........................................19 Figure 2.8: Estimated Resident Population of Capital Cities......................................................20 Figure 2.9: Distribution of Population Across Remoteness Areas ...............................................20 Figure 2.10: Division of Non-Road Emission Estimates into Rural and Urban Areas......................21 Figure 2.11: Sources of Total Non-Road NOX Emissions in Urban Australia .................................22 Figure 2.12: Sources of Total Non-Road CO Emissions in Urban Australia ..................................22 Figure 2.13: Sources of Total Non-Road SO2 Emissions in Urban Australia .................................23 Figure 2.14: Sources of Total Non-Road PM10 Emissions in Urban Australia ................................23 Figure 2.15: Sources of Total Non-Road Total VOC Emissions in Urban Australia.........................24 Figure 2.16: Engine Category Contributions for Urban Emissions of Individual VOCs....................24 Figure 3.1: Prioritisation of Engine Categories .......................................................................29 Figure 4.1: Contributions to Total National Pollutant Emissions for Each Fuel Type ......................30 Figure 4.2: Sources of Non-Road Engines Imported into Australia in 2004 .................................34 Figure C.1: OPEA Estimates of Equipment Sales in 2002 .......................................................... 3 Figure C.2: OPEA Equipment Sales Data for 2004 ................................................................... 3 Figure C.3: Estimated Sales Distribution for all Specified Equipment, by Emissions Compliance...... 5 Figure C.4: Estimated Outboard Engine Sales Distribution by Engine Power ................................ 8 Figure C.5: Estimated Sales Distribution for Outboard Engines, by Emissions Compliance ............10 Figure C.6: Estimated Sales Distribution for Personal Watercraft, by Emissions Compliance..........11 Figure C.7: Predicted trends in outboard motor sales in NSW...................................................12


[vii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

EXECUTIVE SUMMARY

ES.1 INTRODUCTION

Pacific Air & Environment (PAE) was commissioned by the Australian Government Department of the Environment and Heritage (DEH) to investigate the current state of non-road engine emissions in Australia and to provide advice on the most appropriate management options for emissions control.

Non-road (or off-road) engines have been defined for the purposes of this study as “internal combustion engines (spark or compression ignition) not primarily used to power goods or passenger vehicles on a roadway, including locomotives in the urban area and water craft”.

At the Commonwealth level, urban air quality in Australia is partly managed through new vehicle emission requirements under the Motor Vehicle Standards Act 1989 in conjunction with the Fuel Quality Standards Act 2000. Governance of industrial sources within regional airsheds is a state government responsibility, while the Commonwealth is responsible for developing and implementing fuel standards and emissions standards for new vehicles.

There are internal combustion engines that are not subject to the Motor Vehicle Standards Act and which therefore are effectively exempt from new engine emission requirements. Recent studies have indicated that emissions from the non-road engine sector may make a significant contribution to urban air pollution and hence may be contributing to upward pressure on environmental and health indicators.

ES.2 INVENTORY OF EMISSIONS FROM AUSTRALIAN NON-ROAD ENGINES

ES2.1 Inventory Methodology

Table ES.1 provides a list of the non-road engines as well as the equipment types included in the study. It is recognised that many of the equipment types, such as chainsaws, generators and forklifts etc, are used in more than one industry or application (e.g., farming, construction, general industry or recreation). Hence, the equipment categories are not mutually exclusive with respect to equipment type.

The pollutants included in this study are listed in Table ES.2. The first four pollutants in this grouping are typically referred to in the international literature as ‘criteria pollutants’. Ozone, another criteria pollutant, is excluded as it is not emitted directly from combustion sources, but forms as a result of secondary reactions of oxides of nitrogen (NOX) and volatile organic compounds (VOCs), which are covered by the inventory. The last five pollutants in the list are referred to as air toxics or hazardous air pollutants (HAPs) and are components of the total VOCs.


[viii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Table ES.1: Non-Road Engines Included in this Study

Category Equipment

Lawn and Garden • Shredders (5HP)

• Fellers/delimbers/ bunchers

• Skidders

Recreational Marine

• Inboard engines • Outboard engines

• Personal water craft (Jet-skis)

• Stern-drive engines

Commercial Marine • International Shipping • Domestic Shipping • Commercial Boats Rail Service Equipment

• Diesel locomotives

Table ES.2: Pollutants Covered by Inventory

Pollutant

Oxides of Nitrogen (NOX) Carbon Monoxide (CO) Sulphur Dioxide (SO2) Particulate Matter (PM) Volatile Organic Compounds (VOCs) Formaldehyde Toluene Xylene Benzene 1,3-Butadiene


[ix] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

The inventory has been compiled using the most appropriate emission estimation technique available for each engine type using international literature and, where possible, data available from Australia. Emissions from the majority of the source types have been estimated using emission estimates presented in overseas studies and scaled using population or other relevant demographic information. The inventory is based on information sourced from the Australian National Pollutant Inventory (NPI), the US Environment Protection Agency (US EPA) for non-road sources in the US and the NSW Department for Environment and Conservation (NSW DEC) for garden and marine equipment in NSW.

For non-road engines in Australia there is limited availability of activity data and other data required for the compilation of a detailed emission inventory, such as numbers of each equipment type, engine sizes, fuel types, fuel consumption rates, hours of operation and geographical distribution. The emission inventory therefore had to rely heavily on the equipment numbers, hours of operation and typical engine sizes compiled for the 1991 US inventory. The types of activity data that were used to compile the inventory included:

Australian and US workforce data for 2004 and 1991 respectively, which was used to scale equipment numbers for the forestry and logging and construction industries;

Equipment population and activity data for lawn and garden equipment, and outboard motors and personal watercraft, compiled by the NSW DEC for NSW;

The numbers of wood splitters used in Australia was scaled from the US equipment numbers based on firewood consumption data for each country for 2001;

Numbers of commercial and industrial engines were estimated based on Australian and US population data for 2003/4 and 1991 respectively;

Data from the Federal Chamber of Automotive Industries was used to estimate numbers of non-road motorbikes, minibikes and farm bikes;

Emissions from airport ground support equipment were estimated based on aircraft movement data for the US and Australia for 1995 and 2001 respectively; and

Marine fuel consumption data for 2003 obtained from the Resources Division of the Australian Department of Industry, Tourism & Resources were used to estimate emissions from commercial boats and ships.

Where available, data from NPI Emission Estimation Manuals and other Australian-based emission inventories was also used in compiling the emission estimates.

The results of the emission estimations are presented in kilograms/year (kg/yr). For many of the engine categories covered by the inventory, emissions will vary seasonally as well as by day of the week. For example, emissions from personal watercraft and domestic lawnmowers will be higher during the summer and on weekends compared to winter months and on weekdays. Other emission sources can be expected to show less significant seasonal variations, such as those associated with commercial or industrial applications, although they may be higher during the working week compared to the weekend.

ES2.2 Limitations of Inventory

The emission inventory has been developed using a ‘top down’ approach as opposed to a detailed ‘bottom up’ source-by-source approach. In addition, for most categories the emissions were quantified using demographic data to scale the equipment populations compiled in the 1991 US inventory. Only limited data are readily available in Australia for the population, use and emissions


[x] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

associated with non-road engines and no consumer or household surveys were undertaken as part of this project.

The reliability of the emission estimates therefore will depend upon a number of factors, including:

The applicability of the 1991 US emission factors and speciation profiles to the Australian non-road engine population;

The appropriateness of the methodologies used to scale the population of each equipment type from the US to Australia (i.e., forestry and logging workforce numbers for logging equipment, population data for commercial equipment);

The accuracy of the demographic data used;

The accuracy of Australian equipment population data sourced from industry groups and the NSW DEC;

The accuracy of assumptions made in splitting the total Australian emission estimates into urban and rural airsheds; and

The accuracy of other assumptions made in developing the inventory, such as the proportion of international marine fuels burnt in or near ports and harbours where the resulting emissions would enter an urban airshed.

As additional data becomes available on non-road engines in Australia, the inventory should be further refined. PAE understands that the DEH intends to update the inventory as soon as information becomes available from the emission inventory currently being compiled by the NSW DEC for the Sydney Greater Metropolitan Area.

ES2.3 Results of Emission Inventory

Total National Emissions

The total annual VOC, CO, NOX, PM10 and SO2 emission loads calculated for Australia are summarised in Table ES.3 and Table ES.4. These emission loads have been calculated using the in-use adjusted emissions factors from the US EPA 1991 inventory, which have been adjusted to account for engine wear, etc. The contributions of each engine category to the total national non-road emissions of these pollutants are presented graphically in Figure ES.1 to Figure ES.6.

The results of the emission load calculations indicate that commercial marine engines are the major contributors to NOX, SO2 and PM10 emissions from non-road engine emissions in Australia, contributing 61%, 96% and 55% of the emissions of these pollutant respectively. Lawn and garden equipment and locomotive engines are the next most significant contributors to national non-road SO2 emissions (Figure ES.3). The lawn and garden equipment category is also the major contributor to national non-road CO (55%) and Total VOC (60%) emissions. Xylene and toluene are the major VOC species emitted, with benzene emissions being the next most significant. Lawn and garden equipment is the major source category for these pollutants.


[xi] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Table ES.3: Current Non-Road Emission Load Estimates for Australia – Criteria Pollutants

CATEGORY VOCs

(kg/annum) CO NOX PM10

(kg/annum) SO2

(kg/annum) (kg/annum) (kg/annum)

Lawn & Garden Equipment

Airport Service Equipment

Recreational Equipment

Light Commercial Equipment

Industrial Equipment

Construction Equipment

Agricultural Equipment

Logging Equipment

Recreational Marine

Commercial Marine

Diesel Locomotives

152,282,000

6,475,000

34,339,000

14,594,000

4,549,000

5,015,000

13,861,000

2,415,000

16,585,000

3,120,000

2,008,000

988,308,000

115,648,000

72,212,000

324,232,000

66,886,000

56,661,000

78,666,000

15,390,000

79,274,000

9,606,000

5,423,000

2,236,000

10,001,000

165,000

2,614,000

2,001,000

6,902,000

2,862,000

86,000

1,722,000

105,931,000

41,076,000

2,072,000

913,000

253,000

394,000

70,000

642,000

519,000

88,000

580,000

8,263,000

982,000

786,000

237,000

50,000

222,000

90,000

135,000

88,000

9,000

184,000

59,783,000

599,000

TOTAL 255,243,000 1,812,306,000 175,597,000 14,775,000 62,182,000

Table ES.4: Non-Road Emission Load Estimates for Australia – Speciated VOCs

CATEGORY Formaldehyde Toluene Xylene Benzene 1,3-Butadiene (kg/annum) (kg/annum) (kg/annum) (kg/annum) (kg/annum)








Logging Equipment

Recreational Marine

Commercial Marine

Diesel Locomotives

1,290,000

94,000

287,000

149,000

14,000

67,000

67,000

6,000

139,000

53,000

183,000

10,243,000

251,000

2,311,000

972,000

170,000

194,000

524,000

91,000

1,116,000

331,000

93,000

14,834,000

275,000

3,349,000

1,383,000

168,000

216,000

653,000

117,000

1,618,000

141,000

11,000

4,568,000

194,000

1,030,000

438,000

136,000

150,000

416,000

72,000

498,000

94,000

60,000

2,436,000

101,000

549,000

233,000

73,000

78,000

221,000

39,000

265,000

48,000

26,000

TOTAL 2,349,000 16,097,000 22,763,000 7,657,000 4,069,000


[xii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.1: Sources of Total Non-Road NOX Emissions in Australia

Figure ES.2: Sources of Total Non-Road CO Emissions in Australia


[xiii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.3: Sources of Total Non-Road SO2 Emissions in Australia


[xiv] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.4: Sources of Total Non-Road PM10 Emissions in Australia

Figure ES.5: Sources of Total Non-Road Total VOC Emissions in Australia


[xv] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.6: Estimated National Emissions of Individual VOCs

Comparison with NPI Reported Emissions

A comparison of the national emission loads estimated in this study against those reported in the 2003/4 NPI database highlighted some of the differences between the data assembled in this study and data in the NPI. For example, there are a number of NPI source categories (water transport, international sea transport and dairy farming) for which no emissions are estimated. It is also noted that emissions from non-road engine sources used at reporting facilities such as mines and industrial sites are reported to the NPI by these facilities together with other emissions for the sites, and are not separated out.

Nonetheless, the comparison showed that in general, the emissions estimated in this study are significantly higher than the emission loads reported in the NPI. In part, this can be expected to be due to a) the two inventories encompassing different categories of engines (e.g. the emissions estimated for lawn and garden equipment in this inventory include a wide range of engines other than lawnmowers) and b) some of the emissions being included in total site emissions for large reporting facilities and thus not being separated out.

Emissions in Urban Environments

In order to provide more detail on which engine categories are key contributors to pollutant loads in urban airsheds compared to those in more rural environments, an estimate has been made of the proportion of the total national emissions emitted within populated urban areas.

This was done using demographic information taken from 2003 census data obtained from the Australian Bureau of Statistics for those engine categories expected to be distributed according to


[xvi] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

population. Other source categories expected to be totally emitted in rural areas (e.g. logging and agricultural) have been excluded from the urban emission estimates. Some categories, such as airport emissions, have been assumed to be solely emitted into urban environments.

Based on the above, the total Australian emissions estimated for urban areas are summarised in Table ES.5, and Figure ES.7 to Figure ES.12.

The results of the emission load calculations indicate that commercial marine engines remain the major contributor to SO2 emissions from non-road engine emissions in urban areas, contributing 72% of the total urban emissions. Lawn and garden equipment is the major contributing category to CO (58%), PM10 (35%) and Total VOC (72%) emissions in urban areas. Airport service equipment and commercial marine activities are the major contributors to NOX emissions.

Table ES.5: Criteria Pollutant Emission Load Estimates for Urban Areas

CATEGORY VOCs CO NOX PM10 SO2

(kg/annum) (kg/annum) (kg/annum) (kg/annum) (kg/annum)








Logging Equipment

Recreational Marine

Commercial Marine

Diesel Locomotives

116,493,000

6,475,000

26,199,000

11,165,000

3,480,000

3,836,000

-

-

12,688,000

202,000

100,000

756,044,000

115,648,000

55,144,000

248,038,000

51,168,000

43,346,000

-

-

60,644,000

622,000

271,000

1,710,000

10,001,000

126,000

2,000,000

1,531,000

5,280,000

-

-

1,317,000

6,716,000

2,054,000

1,585,000

913,000

192,000

301,000

53,000

491,000

-

-

443,000

508,000

49,000

601,000

237,000

38,000

170,000

69,000

103,000

-

-

141,000

3,679,000

30,000

TOTAL 180,638,000 1,330,925,000 30,735,000 4,537,000 5,068,000


[xvii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.7: Sources of Total Non-Road NOX Emissions in Urban Australia

Figure ES.8: Sources of Total Non-Road CO Emissions in Urban Australia


[xviii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.9: Sources of Total Non-Road SO2 Emissions in Urban Australia

Figure ES.10: Sources of Total Non-Road PM10 Emissions in Urban Australia


[xix] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.11: Sources of Total Non-Road Total VOC Emissions in Australia

Figure ES.12: Engine Category Contributions for Urban Emissions of Individual VOCs


[xx] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

ES.3 PRIORITISATION OF NON-ROAD ENGINE CATEGORIES

The engine categories have been prioritised using an air quality index system. The design of the air quality index is intended to provide an overall indication of the ‘pressure’ on air quality, representing a composite of all effects from all emission sources within each category. This approach involved weighting the mass emission rates for each pollutant based on air quality standards, so that the mass emission rates of different pollutants could be added together to give a total indicator of potential effects on air quality. This process necessarily involves the use of a series of simplifying assumptions and estimates, which is a necessary trade-off when aggregating complex data into simple measures for management purposes. The methodology used considered World Health Organisation (WHO), NSW DEC and the Air NEPM guidelines, which are based on health effects.

The results of the analysis are summarised in Figure ES.13. The rankings are shown for both total national emission estimates and urban estimates only, and illustrate the increased importance of lawn and garden, recreational and airport service equipment for urban areas. These are the main source categories, with the highest priority for emissions control, in urban environments. Recreational marine equipment is the next highest ranked category.

ES.4 OVERVIEW OF NON-ROAD ENGINES USED IN AUSTRALIA

ES.4.1 Impact of Fuel Composition on Emissions

The exact composition of exhaust emissions from engines depends on a wide range of factors, including operational parameters (such as speed and motor load), the engine design, the fuel composition and the ambient conditions (e.g. temperature and relative humidity levels). For example, increasing the cetane index (a measure of how readily the fuel auto-ignites) and lowering the aromatic content results in lower emissions of NOX, VOCs, CO, and PM10. Lowering the sulphur content reduces SO2 and particulate sulphur emissions. Therefore, when assessing options for the control and management of emissions from non-road combustion engines, it is important to recognise that the quality of the fuel used in engines is as critical a factor as the design of the engine itself.

ES.4.2 Fuel Standards

New on-road vehicle emission standards harmonising Australian standards with international vehicle emission standards were gazetted in December 1999. These mandatory vehicle emission standards are established as Australian Design Rules (ADRs) under the Motor Vehicle Standards Act 1989. The quality of fuel in Australia, however, was a key constraint to enabling the introduction of new vehicle emission standards. Emerging vehicle engine and emission control technologies, needed to meet the new standards and help achieve reductions in fuel consumption, are affected by the quality of the fuel used. As ADRs are nationally applicable it is also necessary to ensure that fuel of the appropriate quality is available nationally.


[xxi] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Figure ES.13: Prioritisation of Engine Categories


[xxii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

As a complement to emissions standards introduced under ADRs, the Australian Government therefore enacted the Fuel Quality Standards Act 2000, which came into force in 2002 with the commencement of fuel quality standards for petrol and automotive diesel. Fuel quality standards for biodiesel and autogas came into force in 2003. Further fuel quality standards for ethanol and diesohol are under development.

Many of the non-road engines covered by this study, such as lawnmowers, garden equipment, outboard motors and jetskis, will be powered by fuels bought from the major fuel retailers, which will therefore comply with the national fuel standards. It is possible, however, that some non-road engines are operated using fuels that do not meet the standards under the Fuel Quality Standards Act 2000.

ES.4.3 Recycled Used Oil

The Product Stewardship for Oil (PSO) Program was introduced in 2001 by the Australian Government to provide incentives to increase used oil recycling in the Australian community. Through this program, a levy-benefit system has been introduced, where a levy collected on new oil funds benefit payments to used oil recyclers. The volume of oil on which benefits were paid in 2003-04 was 233 million litres, compared to 193.37 million litres in 2002-03 (DEH, 2004). Industry estimates indicated that 150 to 165 million litres of oil were being recycled prior to implementation of the Product Stewardship for Oil Programme (DEH, 2004).

While the majority of recycled oils are used in direct-fired burner equipment such as kilns and power stations, sales of 26 million litres of used oil as diesel fuel were recorded in 2002-03 (AATSE, 2004). Currently, re-refined diesel fuel seems to compete successfully where it can meet the market quality standards. All re-refining processes produce a diesel fraction but only Nationwide in NSW and Environmental Oil in Victoria sell product specifically as diesel fuel for transport and stationary diesel engines. Other producers sell the product as fuel oil for general burning applications, either direct or blended into industrial burning oils (AATSE, 2004).

With the introduction of the Automotive Diesel Determination, the mandatory diesel specification for sulphur was reduced from 5000 ppm to 500 ppm in December 2003 and will reduce further to 50 ppm from 2006. The limit will reduce to 10 ppm in 2008. In comparison, typical sulphur levels in re-refined diesel are 1000 - 9000 ppm. The excise rate for diesel with greater than 50 ppm sulphur also increased on 1 July 2003, as a result of the Diesel Sulphur Excise Differential Program. The lower sulphur specification and the increased excise will have reduced the transport diesel fuel market for used oil-derived material. Applications such as stationary engines, off-road vehicles, earthmoving equipment in remote areas and marine engines are anticipated to offer possibilities to sustain the market for recycled product with sulphur levels greater than 50 ppm (AATSE, 2004).

ES.4.4 Non-Road Engine Markets in Australia

Summaries of the types of non-road engines used in Australia for each engine category covered by the inventory have been compiled. Where information is readily available, an analysis of the Australian market, in terms of factors such as emissions performance, country of manufacture and current sales, is provided. It is noted that this information has been collected through a limited review of publicly available information and discussions with a small number of industry contacts. The sales and import data presented have not been fully verified and the information provided should in no way be viewed as a complete summary of each engine market. More extensive consultation with stakeholders will be required prior to developing any management strategies.


[xxiii] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage


The lawn and garden equipment covered by the non-road engines inventory encompasses a wide range of equipment including lawn mowers, trimmers, edgers and brush cutters, leaf blowers/vacuums, chainsaws, shredders and lawn tractors. Of all these equipment types, the main focus in both Australia and overseas, in terms of emissions from non-road engines, has been on emissions from lawn mowers.

The most recent investigation into the impacts of air emissions from lawn and garden equipment in Australia has been undertaken by the NSW DEC. Figures obtained from industry by the NSW DEC as part of this investigation show Australian sales of lawn mowers and other handheld equipment such as grass trimmers and hedge trimmers to be approximately 900,000 per annum. Of this, lawnmowers make up around 250,000 sales and outdoor handheld equipment 650,000. A profile of the environmental performance of equipment currently on the Australian market was also developed by the DEC, with each item of equipment being assessed on its compliance with US EPA, CARB or European regulations. This work estimated that at least 55% of new two-stroke carburettor engines across all product types do not meet any overseas emissions standard.

Information provided by the NSW DEC shows that the Outdoor Power Equipment Association (OPEA) has expressed concern about the impact on the local market of increasing imports of small engines from Asia that are not believed to meet any emission standards. Information supplied to OPEA indicates that the cost of complying with such regulations would add approximately 50% to the cost of production for each engine. As a result, OPEA has stated that the only way to ensure that products sold on the Australian market are up to the latest technology and emission standards is to bring in regulations across Australia, similar to the European directive or US EPA requirements. If this does not happen, there are significant concerns that Australian will become a dumping ground for poorly performing imports that can’t comply with other countries’ regulations. OPEA also notes that a) lifetime performance requirements need to be incorporated into any regulations, to prevent the sale of equipment that deteriorates rapidly in engine performance and b) realistic penalties and their enforcement should be part of any regulations.


Non-road engines operated at airports include aircraft load lifters, push-back and tow tractors, baggage conveyors and airport service vehicles. This inventory does not include emissions from the aircraft themselves while mobile (taxiing, landing and take-off cycles) or stationary (idling, docked at gate, or during on-wing engine testing).

Emissions from airport support equipment are included in the National Pollutant Inventory as a separate source category. As discussed in Section 2.4.2, however, the NPI emissions loads are considered to be under-reported based on the estimates compiled as part of this study.

Discussions with a contact who manages environmental issues for a major airport in Australia indicated that airport support equipment is normally managed by ground handling agents. There are several ground handling agents operating at each major airport, and each agent has a specific state representative. There is no central database available on the numbers and sources of equipment purchased or operated by agents. Discussions with staff of Patrick Air Services indicates that numbers of equipment items are approximately as follows:

Lifting equipment: 1-2 new imports/year, ~50 in Australia total

Tow tractors: ~250 in Australia, imported through Toyota and Harland


[xxiv] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Import numbers are low, as equipment is rebuilt and engines replaced as equipment ages. It is noted that this information has been obtained from limited research, and in comparison with the data used in the inventory (which was derived from the US figures based on aircraft movements) the numbers appear to be very low. The information therefore needs to be verified and confirmed through a process of formal stakeholder consultation.

According to information from Patrick Air Services, Static Engineering in Adelaide is the only domestic manufacturer of airport service equipment in Australia.


Recreational equipment covered by this inventory includes all terrain vehicles, mini bikes, off-road motorcycles and golf carts. Of these engine types, mini bikes and off-road motorbikes are expected to be the most numerous and to be the greatest contributor to this category of non-road engine emissions.

Road Bikes and Off-Road Bikes form the two major styles of motorcycles with many variations of engine capacity and model categories. There are no motorcycles currently manufactured in Australia. They are imported mainly from Europe, Japan, UK and the USA, although some are now being imported from China and Korea. When seeking an import approval, the importer must indicate whether or not this motorcycle is to be used for “on road” purposes. If so, the vehicle must comply with Australian Design Rules (ADRs) for motorcycles, which relate only to the braking systems and noise levels. However, if the vehicle is to be used for off road purposes, there is no requirement to comply with these ADRs.

Motorcycle sales have been increasing steadily over the past 5 years, with sales for 2004 showing solid growth of 20% over 2003. Total sales for 2004 were 89,000 units - the highest sales in 25 years. The most popular selling models in 2003 and 2004 have been off-road motorcycles, which comprise more than half of the new sales market. Enduro motorcycles are used by the majority of off-road recreational riders and these bikes comply with ADRs and can be fully road registered. Trail bikes also comply with ADRs and are eligible for road registration. They were popular 20 years ago but are now diminishing in popularity. MX are competition bikes used in MX racing and do not comply with ADRs. Two-stroke engines were in the majority of off-road motorcycles 15 years ago, but have now decreased markedly in line with global trends.

The total number of motorcycles on register in Australia is 400,000. However, in line with the popularity of off-road sales, the industry estimates the existence of an additional 350,000 nonregistered motorcycles. In addition to private sales there are significant sales to Government sectors such as Australia Post, Police Forces, Department of Defence, Australian Antarctic Base, Surf Patrols and Rescue Services.

Light Commercial, Industrial and Construction Equipment

Light commercial equipment engines covered by this inventory generally relate to stationary (i.e. non-vehicle) engine types, and include generators, pumps, compressors, welders, and pressure washers. The industrial equipment category includes aerial lifts, forklifts, sweepers/scrubbers and material handling equipment. The construction category includes a wide variety of equipment ranging from paving equipment, to drillers and excavators, to loaders and tractors.

Other industrial equipment such as heavy earth moving and construction equipment, mobile airport equipment, portable well-drilling equipment and generators are accounted for in other engine


[xxv] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

categories as listed in Table 2.1. It is noted in the NPI EET Manual for Combustion Engines (Environment Australia, 2002) that the large shovels used mainly in open-cut mining facilities to load haul trucks are classed as stationary engines as they do not move large distances and the main use of the engine within the shovel is to operate the shovel itself.

The construction category includes a wide variety of equipment ranging from paving equipment, to drillers and excavators, to loaders and tractors.

Discussions with the Australian Industrial Truck Association (AITO) and Forkpro have provided the following information for the forklift industry (including forklifts, straddle carriers, autopickers and hand trolleys):

Approximately 12,000 new engines are imported per year,

Imports of second hand equipment are negligible, and are limited due to the need for safety rating as per Standards Australia requirements;

The majority of the new imports are leased by fleet hire companies, who own them for 4-5 years. During this period the equipment has a higher utilisation rate than that purchased by owner-operators.

There is a thriving second-hand market for this ex-hire equipment which then tends to be operated for a further 10-15 years. This indicates that the current Australian fleet would be around 180,000 vehicles.

In recent years, the new vehicle fleet is split 50:50 between battery-electric and internal combustion engines. Of the internal combustion engines, 10% are diesel, 90% are petrol. Of the petrol engines around 1% are run on petrol while the majority are run on LPG or CNG. The increase in battery-electric powered equipment is partly due to that fact that for warehouse applications, petrol and diesel engines are outlawed for health and safety reasons.

Conversion of petrol engines to run on LPG or CNG can either be performed by the original equipment manufacturer (OEM) or by local fit-out, which results in poorer emissions performance compared to the OEM. There is a significant move towards OEM conversion due to the recognition within the industry of the better emissions performance.

Agricultural and Logging Equipment

The agricultural equipment category includes tractors, combines, sprayers, balers and tillers. Logging equipment covered by this inventory includes chainsaws, shredders, skidders, fellers, bunchers and delimbers.

Discussions with industry contacts indicates that all forestry equipment is imported into Australia as opposed to being manufactured locally, generally from North America, Europe or Japan. The major manufacturers are Komatsu, Caterpillar, Hitachi, Kibalco and Daewoo. Most equipment is imported new, with only a small proportion of second-hand equipment expected. The majority of engines are expected to meet the Tier 2 emission limit requirements set for non-road engines by the California Air Resource Board.


[xxvi] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Recreational Marine Equipment

Recreational marine equipment covered by this inventory includes inboard and outboard motors, personal watercraft (i.e. jet-skis) and stern-drive engines.

The most recent investigation into the impacts of air emissions from marine engines in Australia has focussed on outboard motors and personal watercraft. Figures obtained from industry by the NSW DEC as part of this investigation show that Australian sales of new outboards number around 45,000 per annum. The DEC profile of the environmental performance of equipment currently on the Australian market estimates that around 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.

Commercial Marine Equipment

Commercial ships may emit air pollutants under two major modes of operation: while underway, and at berth (under auxiliary power). Emissions underway come from a ship’s engine exhaust and are influenced by a great variety of factors including engine size, the fuel used (residual oil or diesel oil), operating speed and load. At berth, power must be made available for the ship’s lighting, heating, pumps, refrigeration, ventilation and so on. Ships normally use diesel-powered generators to furnish auxiliary power. Emissions from these generators may also be a source of underway emissions if they are used away from port.

In the early 1990’s, the International Chamber of Shipping reported that worldwide atmospheric pollution from shipping had declined over the previous two decades (ICS, London, 1993). This was stated as having been brought about by improvements in engine efficiency, improved hull and propeller design, and the use of ships with larger cargo-carrying capacity. A presentation on marine fuel from the Hart Refining and Fuel Conference in Brussels in May 2005, however, indicates that SO2 emissions from ships (in the European Union (EU)) are increasing, while land based sources are decreasing. Seagoing ships were identified as the biggest source of SO2 in the EU, while also contributing 20-30% of secondary inorganic particulate matter in most coastal areas.

Trains and Locomotives

Railway locomotives used in Australia are primarily of two types: electric and diesel-electric. Electric locomotives are powered by electricity generated at stationary power plants and emissions are produced only at the electrical generation plant, which is considered a point source and therefore not considered in this inventory. Diesel-electric locomotives, on the other hand, use a diesel engine and an alternator or generator to produce the electricity required to power its traction motors. A third type, the steam locomotive, is used in very localised operations, primarily as tourist attractions.

Locomotive engines have an economic service life of typically 25-30 years due to their low speed and heavy duty construction. It is common practice to perform complete rebuilds of locomotives and their engines during their lifetime to extend the service life as far as possible. Due to their largely modular design, it is possible to incorporate technology upgrades within the engine family at the time of these rebuilds. Older engines can then take advantage of modern specification developments, in certain engine build areas.


[xxvii Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

New technologies are starting to emerge for both retrofit and new diesel locomotive and marine engines that could significantly reduce PM10, VOC, NOX and smoke emissions. Such technologies are reported to be far cheaper than conversion to CNG or LNG fuels, but would still cost substantially more than continued use of existing in-service equipment. Hence, government regulation and tax incentives are considered necessary to accelerate the conversion of old locomotives to newer, clean technology.

ES.5 MANAGEMENT OF NON-ROAD ENGINE EMISSIONS

It should be noted that the following discussion on management options and recommended management strategies has been prepared based on the authors’ professional expertise and experience and represents a preliminary qualitative assessment of the options. It does not in any way represent the opinion of the DEH. Further analysis, investigation and stakeholder consultation would be required prior to the development and implementation of any of the management options discussed below.

ES.5.2 Justification for Management of Non-Road Engine Emissions in Australia

The estimated emissions of the common air pollutants and air toxics from non-road equipment have been shown to be significant contributors to the overall national emissions of these pollutants. In consequence, the introduction of management programs for these emissions would appear to be justified.

When the quantities of non-road emissions were compared with current on-road emissions, they were found to be of similar or greater levels. A recent study by BTRE estimated the health damage costs of on-road emissions for premature mortality associated with these emissions at between $1.1 billion and $2.6 billion, with a central estimate of $1.8 billion, and premature morbidity at between $0.4 billion and $1.2 billion, with a central estimate of $0.8 billion (all estimates in 2005 dollars). That is, the central estimate of health damage costs for on-road emissions is $2.6 billion and, because non-road emissions are of a similar quantity to on-road emissions, a similar figure is likely to apply to the adverse health effects of non-road emissions.

The magnitude of these health damage costs provides additional justification for further investigations into the need to manage non-road equipment emissions.

ES.5.3 Ranking of Effectiveness of Management Options

Six options for management of non-road emissions were proposed. One of these, "No Action", has been shown to be unacceptable, as it would allow adverse health effects already occurring to continue unabated. Thus, five realistic management options have been examined. These were explicit government regulation, co-regulation, quasi-regulation, self-regulation and alternative instruments.

A matrix for judging the effectiveness of these five management options was established. The matrix was based on assessing each option for the quantity of emissions reduced by the option, the timeline for implementing the option and achieving reductions, and the estimated benefits and costs of the option. Each option was analysed to determine how well it met these three criteria.

The order of effectiveness for management options resulting from this analysis was:


[xxviii Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

1. Explicit government regulation

2. Co-regulation

3. Quasi-regulation

4. Alternative instruments

5. Self-regulation

ES.5.4 Ranking of Non-Road Engine Emissions for Management

Priorities for the management emissions from non-road equipment were identified in terms of the combination of the quantity and toxicity of their emissions. A ranking order was established based on their quantities of emissions of the two more harmful pollutants, VOC and PM10.

A combined ranking based on both pollutants established that two non-road emission sources, Industrial and Logging Equipment, were the lowest ranked, and constituted a low priority for management action at present.

Of the remaining nine sources, three - Lawn and Garden, Commercial Marine and Recreational Marine Equipment - constituted a first priority group for management action. A further group of six sources constituted a second priority group. These were Airport Service, Recreational, Agricultural, Light Commercial and Construction Equipment and Diesel Locomotives. Of these, management action has already commenced on Diesel Locomotive emissions through the work program of the Land Transport and Environment Committee (LTEC). Thus there are eight non-road emission sources identified for management action.

ES.5.5 Preferred Management Approach

Given that non-road engines may be manufactured generically, that is, manufactured for use in a range of non-road equipment, not for specific items, then it may be more effective to manage them generically, that is, establish a comprehensive and integrated management program that would target non-road engines as a class. This would represent a more efficient management approach, as emissions reduction becomes a part of the design and manufacturing of all non-road engines, thereby preventing pollution from the engines across the board. This approach is analogous to the way in which Australian Design Rule emission limits apply to all new vehicle engines regardless of the make or model of vehicle/equipment in which they are ultimately intended to be fitted.

ES.5.6 Other Possible Management Options

The analysis of the five realistic management options for effectiveness showed that the Explicit Government Regulation option was more effective than the others in delivering significant emission reductions in a timely and cost-effective manner. Explicit Government Regulation is a well-established management option, based on a highly consultative approach and usually leads to the adoption of best practice emission standards. It provides certainty to all parties and delivers clear health and other benefits. Explicit Government Regulation is also the preferred management option for non-road emissions in countries with which Australia compares itself in the OECD, and in its major trading partners, the United States and Europe.


[xxix] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

Explicit Government Regulation is therefore the recommended management option for emissions from non-road equipment. However, a full quantitative cost-benefit analysis and review would be required to confirm this.

If it is determined that this recommended option cannot or will not be adopted, then Co-regulation was identified as the next preferred option. While it cannot be assured of delivering best practice emission standards, Co-regulation should deliver good practice emission standards, and follows a consultative process. The adopted standards are given statutory force by government and this provides certainty of health and other benefits.

The remaining three options are not recommended, as they rank low in effectiveness.

Quasi-regulation and Self-regulation provide for advisory standards that have no statutory backing and rely on industry to bear the costs of their development and implementation. Government and the community have a vested interest in protection from harmful emissions and it would seem more appropriate to have their involvement in setting emission standards.

The Alternative Instruments option relies essentially on financial instruments and information campaigns to promote equipment complying with agreed emission benchmarks. If non-complying equipment is on sale at lower or similar prices as complying equipment, purchasers may have little incentive to select the complying equipment. With the likelihood of imports of high emitting non-road equipment increasing considerably in coming years, the cost of supporting lower emitting equipment may become prohibitive.

In summary, regulation of non-road emissions is recommended as the most effective management option.


[1] Management Options for Non-Road Engine Emissions in Urban Areas – Draft Department of Environment and Heritage

1 INTRODUCTION

Pacific Air & Environment (PAE) was commissioned by the Australian Government Department of the Environment and Heritage (DEH) to investigate the current state of non-road engine emissions in Australia and to provide advice on the most appropriate management options for emissions control.

Non-road (or off-road) engines have been defined for the purposes of this study as “internal combustion engines (spark or compression ignition) not primarily used to power goods or passenger vehicles on a roadway, including locomotives in the urban area and water craft”.

Internal combustion engines convert the energy stored in fuel to mechanical energy through the oxidation process. Liquid or gaseous fuels, primarily consisting of hydrocarbons, are mixed with air and compressed. The fuel mixture is either ignited (by a sparkplug) or undergoes spontaneous combustion by heat compression (diesel engines). When the fuel ignites, it expands rapidly and releases mechanical and heat energy.

If the combustion reaction were complete, the only by-products would be heat, CO2 and water. No engine, however, provides complete combustion. Emissions such as sulphur oxides (SOX), nitrous oxides (NOX), carbon dioxide (CO2), carbon monoxide (CO) and unburnt volatile organic compounds (VOCs) are produced. As well as the by-products of the combustion process, emissions to air are also caused by evaporation of the fuel itself.

At the Commonwealth level, urban air quality in Australia is partly managed through new vehicle emission requirements under the Motor Vehicle Standards Act 1989 in conjunction with the Fuel Quality Standards Act 2000. There are internal combustion engines that are not subject to the Motor Vehicle Standards Act and which therefore are effectively exempt from new engine emission requirements. Recent studies have indicated that the emissions from the non-road engine sector may form a significant contribution to urban air pollution and hence may be contributing to upward pressure on environmental and health indicators.

Governance of industrial sources within regional airsheds is a state government responsibility, while the Commonwealth is responsible for developing and implementing fuel standards and emissions standards for new vehicles.

This study has been performed in the following three stages:

1.1 Stage One: Desk-Top Emissions Inventory

Compilation of Inventory

PAE has provided a comprehensive desk top inventory of non-road emission sources based on information presented in the literature. DEH has requested that the study focus on the sources located within urban airsheds, but some of the engine types included in the inventory are more likely to operate in more remote areas. PAE believes that there is value in providing as complete a picture as possible of the total Australian emissions from non-road engine categories covered by this study. An estimate of the proportion of the total emissions emitted within urban areas has been presented in this report.



The inventory has been compiled using the most appropriate emission estimation technique (EET) available for each engine type using international literature and, where possible, data available in Australia. Emissions from the majority of the source types have been estimated using emission estimates presented in overseas studies and scaled using population or other relevant demographic information. The inventory is based on information sourced from the Australian National Pollutant Inventory (NPI), the US Environment Protection Agency (US EPA) for non-road sources in the US and the NSW Department of Environment and Conservation (NSW DEC) for garden and marine equipment in NSW.

It is important to note that although there are many differences between Australian and US conditions, most of the work in emission inventory development has been done in the US. It is also worth noting that this emission inventory is compiled from a ‘top down’ approach as opposed to a ‘bottom up’ or detailed element-by-element approach. In general, an emission inventory is generated by multiplying what is referred to as an ‘emission factor’ by ‘activity data’ (i.e., annual throughput of fuel, hours of operation) on a source-by-source basis. For this study, PAE used emission factors from a variety of literature sources, including the US study, NPI estimates and estimates provided by the state agencies for specific projects.

Prioritise Categories in Terms of Impact Per Non-Road Engine Type

The emission data for each engine category has been ranked according to percentage contribution for each pollutant. The ranking of engine types takes into account the relative potential for each pollutant covered by the inventory to give rise to adverse health impacts.

1.2 Stage Two: Market Status (Import versus Domestic)

This section summarises readily available information on the non-road engine market in Australia, where data are available. If known, information on what proportion of the engines is imported or manufactured domestically, the country of origin of imported equipment, and engine specifications is also provided.

1.3 Stage Three: Management Options

Regulatory Approach

In response to the need to examine the possible impacts of emissions for engines that are not covered by the Motor Vehicle Standards Act (MVS) and Australian Design Rules (ADRs), there is a need to develop a strategic approach for the management of non-road engine emissions that is based on factual data, and to determine appropriate management options.

The following options are considered:

i. No action

ii. Self regulation

iii. Quasi-regulation

iv. Co-regulation

v. Explicit government regulation

vi. Alternative instruments



Examples and applicability of programs from other jurisdictions are discussed as part of Stage Three.

Identify Management Options

An assessment needs to made as to whether non-road engine emissions are of a scale that warrants national action. In line with this, the outcome of this study needs to be able to provide information on which engine classes require better management and how urgently the issues need to be addressed. Potential management options have been evaluated in terms of what has been done elsewhere and how practical and economic the options are within the Australian context.



2 INVENTORY OF EMISSIONS FROM AUSTRALIAN NON-ROAD ENGINES

2.1 Non-Road Engines Included in the Inventory

Table 2.1 provides a list of the non-road engines as well as the equipment types included in the study. It is recognised that many of the equipment types, such as chainsaws, generators and forklifts etc, are used in more than one industry or application (e.g., farming, construction, general industry or recreation). Hence the equipment categories are not mutually exclusive with respect to equipment type.

Table 2.1: Non-Road Engines Included in this Study

Category Equipment

Lawn and Garden • Shredders (5HP)

• Fellers/delimbers/ bunchers

• Skidders

Recreational Marine

• Inboard engines • Outboard engines

• Personal water craft (Jet-skis)

• Stern-drive engines

Commercial Marine • International Shipping • Domestic Shipping • Commercial Boats Rail Service Equipment

• Diesel locomotives



2.2 Pollutants Included in the Inventory

The pollutants included in this study are listed in Table 2.2. The first four pollutants in this grouping are typically referred to in the international literature as ‘criteria pollutants’. Ozone, another criteria pollutant, is excluded as it is not emitted directly from combustion sources, but forms as a result of secondary reactions of NOX and VOCs which are covered by the inventory. The last five pollutants in the list are referred to as air toxics or hazardous air pollutants (HAPs) and are components of the total VOCs.

Table 2.2: Pollutants Covered by Inventory

Pollutant

Oxides of Nitrogen (NOX) Carbon Monoxide (CO) Sulphur Dioxide (SO2) Particulate Matter (PM) Volatile Organic Compounds (VOCs) Formaldehyde Toluene Xylene Benzene 1,3-Butadiene

Other pollutants associated with combustion but not included in this study include carbon dioxide (CO2) and heavy metals.

A brief discussion on the air pollutants covered by the inventory and their potential impacts on air quality is provided below.

2.2.1 Volatile Organic Compounds (VOCs)

A wide range of volatile organic compounds (VOCs) is emitted from fuel combustion, storage and handling and the more reactive compounds are of particular interest due to their role in photochemical smog formation. This type of smog is a common air pollution problem in large cities with high motor vehicle usages. Also, as VOC emission rates are critical in controlling hydroxyl radical (OH) concentrations in much of the troposphere, VOC emissions may play a major role in determining the growth rate of global methane and carbon dioxide concentrations, linking VOC emissions to Earth’s climate through the influence upon methane (Guenther et al. 1995). VOCs is a wide grouping that includes many hazardous pollutants, such as benzene.

The term ‘VOC’ has been defined by the US EPA (US EPA, 2004), as ‘any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric chemical reactions’. There are a number of compounds deemed to have ‘negligible photochemical reactivity’ and these are exempt from the definition of VOC. These exempt compounds include methane, ethane, methylene chloride, methyl chloroform, many chlorofluorocarbons, and certain classes of perfluorocarbons.

The NPI definition of VOCs is ‘any chemical compound based on carbon chains or rings (and also containing hydrogen) with a vapour pressure greater than 2 mm of mercury (0.27 kPa) at 25°C,



excluding methane. These compounds may contain oxygen, nitrogen and other elements. Substances that are specifically excluded are: carbon dioxide, carbon monoxide, carbonic acid, carbonate salts, metallic carbides and methane’ (Environment Australia, 2004). This definition is similar to that used by the US EPA, which is appropriate given that the emission factors used for NPI reporting are generally sourced from the US EPA.

A large variety of different VOC species is emitted from a wide range of sources. This includes fugitive and evaporative emissions from petrochemical refining, storage and distribution facilities, solvent production and use, fossil fuel combustion, methane emissions from ruminants, and biogenic sources such as forests.

Additional details on the health and environmental impacts of the individual VOC species covered in the inventory are provided below.

2.2.1.1 Formaldehyde

Formaldehyde may be emitted from manufacturing plants that produce or use formaldehyde or substances that contain formaldehyde. Catalytic cracking, coking operations, and fuel combustion are major sources of formaldehyde from refineries. Stone, clay, and glass production use fuel combustion sources such as boilers, furnaces, and engines in the manufacturing processes which generate formaldehyde. Formaldehyde also occurs in forest fires, animal wastes, microbial products of biological systems, and plant volatiles. It can also be formed in seawater by photochemical processes

In humans, exposure to formaldehyde irritates the eyes, nose, and throat, and can cause skin and lung allergies. Formaldehyde is classified as a 'probable human carcinogen' by Worksafe Australia. It has high chronic toxicity to aquatic life and may cause cancer and other chronic effects in laboratory rodents. Insufficient data are available to evaluate or predict the long-term effects of formaldehyde to plants.

2.2.1.2 Toluene

Consumers are most likely to be exposed to toluene by smoking or using consumer products containing toluene (paints, varnish, nail polish, paint cleaners, stain removers, etc.) especially if there is not good ventilation. Consumers can also be exposed to toluene by exposure to air from production and processing facilities using toluene, and automotive exhaust. Sniffing glue or paint can also lead to high exposures. In the air toluene quickly is reacted into other chemicals, while in the water and soil, bacteria break it down.

Short-term exposure to high levels of toluene results first in light-headedness and euphoria, followed by dizziness, sleepiness, unconsciousness, and in some cases death. When exposure is stopped prior to death the symptoms disappear. Long-term exposures at low levels have caused effects to the kidneys. Long-term exposures to high amounts of toluene by intentional abuse have been linked to permanent brain damage. Also reported are problems with speech, vision, and hearing, loss of muscle control, loss of memory and balance and reduced scores of psychological tests.

Toluene has moderate acute (short-term) toxicity on aquatic life and has caused membrane damage to the leaves in plants. It has moderate chronic (long-term) toxicity to aquatic life. Chronic and acute effects on birds or land animals have not been determined. Toluene is expected to minimally bioaccumulate.



2.2.1.3 Xylene

Xylene is used as a solvent, to manufacture petrol, as a raw material to manufacture chemicals used to make polyester fibre, and to make dyes, paints, lacquers, and insecticides. It is also use

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