Recently, I was involved in a discussion about AB-1346, a routine decision of the California Legislative Assembly. The bill was passed in October 2021, and requires the California Air Resources Board (CARB) to put in place regulations restricting emissions from new Small Off-Road Engines (SOREs). Not being a Californian - indeed as I am living in the UK and not a USAian at all, this may seem somewhat an odd topic to write about. Nonetheless the bill is generating quite a lot of fuss online and I thought it would be interesting to explore the topic in a little more depth.
While the new law itself is quite light on detail, it links in to an interesting technological transition that’s currently ongoing and rapidly speeding up: the technological obsolescence of small engine-driven machinery, in favour of electrically operated machinery, powered by batteries.
The law has widely been reported as a ban on electrical generators for home use in California, and resultantly the bill has attracted a somewhat disproportionate level of attention from the press and public in this regard. Many people in California and throughout the USA are, or perceive themselves to be, dependent on generators to supply their electricity (at least for some of the time).
While this level of attention would be reasonable if the bill did in fact ban generators; the bill does not, in fact, ban generators. In fact, the other market segments affected will have much more impact on the day-to-day life of Californians.
What the bill does do, is to give legal force to new rules currently being made by CARB. If these rules are adopted as proposed, emissions standards for SOREs will be raised to technically infeasible levels from 2024 onwards, effectively prohibiting production of SOREs for the California market. Generators are included in this, although they will not be completely restricted until 2028. Existing equipment will not be affected by these rules, however - Californians’ generators will not stop suddenly stop working when the clock strikes midnight on the 1st of January 2028, nor will the police go about rounding up outdated generators.
Even in 2028 and afterwards, if somebody wants a new portable generator, they will be able to get one. Both used generators, and new generators bought directly from other states, will still be available; additionally some manufacturers will be able to use accumulated emissions credits to legally sell noncompliant generators.
Why are small engines so good, historically?
Removing SOREs from the market will be a historic and tremendously significant occasion, as they have been a fixture of domestic life for going on 70 years, powering all manner of essential tools: from chainsaws, lawnmowers and leafblowers to pressure washers, arc welders, plate compactors - and indeed, portable generators. All these categories would not exist as they do today without the SORE to give them rotational energy, mechanically converted by their mechanisms into useful work for the home and the job.
Would you bother mowing the lawn once a week if you had to push the mower yourself, instead of riding along in comfort while the SORE does all the work for you? What would you do without a chainsaw as a tree surgeon? Or without an arc welder as you’re building the new oil pipeline that inches its way across the landscape?
SOREs are convenient, portable and powerful. Pour in some fuel, pull the cord and away you go. Maintenance is easy, if you can be bothered, just top off the oil every so often, and switch out the carburator gaskets and spark plug when they wear out. If you can’t be bothered, for not many dollars somebody else will do it for you; if even that’s too complicated for you then you can just throw it away and buy another - small engines are cheap enough that you can afford it.
SOREs are the safe bet. They can operate in harsh conditions without a blink - hot, cold, wet, dry? No bother. What about infrastructure - all you need is a can of fuel, and as an American, you can trust in the supply of petrol for your SORE. The government fights wars for your right to burn oil. No matter who you are or what you do, or where you are in the country; there’s nothing better than a SORE by your side.
Or maybe not, there are downsides too!
When you snap out of your American dream, you realise that your suburban paradise is more like a suburban prison. The car in the garage is not a ticket to freedom, but a shackle to the petrol pump and a life doomed to sit in traffic; the 30-year mortgage not independence but dependence on the market and maintaining your income; and that pristine green lawn is not the status symbol it once was. It must be fertilised, pesticised, mown, leafblown, edged and watered, taking up hours of your time and many of your dollars.
And all that mowing belies one of the problems with the SORE. When every identical house in every identical cul-de-sac with its identical green, manicured lawn has its own mower running for hours a week, that’s a lot of fuel being burned by SOREs in a relatively small area. And that’s not good. The SORE is a noisy, smelly and inconvenient machine. When incessant droning of the neighbours’ leafblowers just won’t shut up when you want to relax, and when the smog hangs in the air like a foul blanket over the city for days on end, you realise that you have a problem. And it’s a big problem too; reading the scientists’ reports about just how many people are dying of this gives you a shock. And then you realise that the carbon dioxide being pumped out of these engines isn’t that benign either.
The truth is that SOREs have a lot of tradeoffs in their design. They may be cheap, lightweight and powerful, but because of this they are designed to be crude and simple machines. There’s no budget (economic, weight, or engineering complexity) for anything more than the bare minimum. They pass out exhaust gases unfiltered, and burn through fuel at an astronomical rate.
In the case of two-stroke engines, even the minimum of pollution control isn’t possible, because of the total-loss lubrication strategy. Engine oil is mixed directly with the fuel and passed through the combustion chamber. The partially burned results are apparent as smoke, full of the worst kinds of pollutants. But when you need an engine small enough to fit in your chainsaw, even the complexity of valves and a sealed crankcase is too much - two stroke it is, consequences be damned.
In the old days, cars and lorries emitted these kinds of pollutants too (and in aggregate, far more than SOREs): unburned hydrocarbons (HC), carbon monoxide (CO) and plain soot; but nowadays the law mandates that this is not the case. Modern cars (as designed) emit almost undetectable quantities of these pollutants, thanks to the catalytic converter, ECU and fuel injection (among countless other technologies). But this is possible because the tradeoffs are different for large and expensive car engines. If adding fuel injection is necessary to pass smog, of course that will get done, but it would probably have happened anyway once consumers realise it is more reliable and leads to lower fuel costs.
It’s only now that cars have got to be so good that SOREs are the next biggest issue to fix.
And it turns out that SOREs are a bit of a pain sometimes too. When the carburator needs to be rebuilt every year (or more often!) because of the new type of petrol with ethanol in it, that gets old fast. And when your nice new car always smells of fumes from the infuriatingly leaky (supposedly anti-leak!) mechanism in the fuel can, you’d really rather not have to carry petrol about quite so often. And when the power goes out and society is falling apart, when are you going to get the petrol for your generator from anyway - it’s not like you can store it for more than a few months without it going off after all. Maybe there really is something better than a SORE?
What are the alternatives to small engines?
Luckily there are now better alternatives to SOREs in many instances. Efficient and powerful permanent magnet AC motors now exist which are far lighter than SOREs, and when combined with Lithium batteries can be just as, if not more, compact and portable. Electric chainsaws are now more popular than engine-driven models for the home market, and many areas mandate the use of electric leafblowers already out of concern for noise pollution. Electric lawnmowers are competitive with petrol-powered ones, and even large lawns are suitable for self-charging robotic mowers, which not only cut out the SORE, but much of the labour too.
Larger and mobile machinery is just as suitable for battery-driven operation, with few exceptions, owing to the breakneck pace of development in the battery and electric car industries.
Even portable generators have been replaced by Lithium power packs for many uses - where only moderate power is needed and recharging facilities are easily to hand hand they are invaluable. And since they have no hazardous fuel nor any exhaust they are safe to use indoors. And for backup power after the Big One, or the next storm, Lithium provides an answer too. Solar panels on the roof and a Powerwall in the garage mean you can be totally self-sufficient, no generator needed.
And more high-tech innovation does look to be on the way: fuel cells powered by methane or hydrogen gas are already available and this segment is currently undergoing a frenzy of investment. Generators and power packs using the technology are sure to come on the market before too long.
All that said, there are still many market segments that are best served by SOREs at the moment, and it certainly is taking a gamble to say everything will be good by 2024-8. The alternatives are typically significantly more expensive than SOREs, and while price-conscious consumers can be served by the pre-2024 used market, prices will no doubt increase for all market participants.
Back to the rules
Looking back to CARB’s proposed rules, we need to read them in more detail to understand the reasoning for the change. Looking at the Initial Statement of Reasons, CARB explains its remit and how current healthy pollution limits are being exceeded in California, and what it plans to do about that:
The California Air Resources Board (CARB or Board) is responsible for protecting the public from the harmful effects of air pollution through the development of programs that reduce the emissions of specific pollutants and their precursors. Several areas within California exceed national ambient air quality standards (NAAQS) set by United States Environmental Protection Agency (U.S. EPA) for both fine particulate matter (PM) with diameter of 2.5 micrometers or smaller (PM2.5) and ozone.
Meeting these public health goals requires phasing out the use of internal combustion engines in both on-road and off-road applications and adopting zero-emission technology.
Governor Newsom’s Executive Order (EO) N-79-20, issued September 23, 2020, (EO N-79-20) orders CARB to develop and propose, “Strategies, in coordination with other State agencies, the U.S. EPA, and local air districts, to achieve 100 percent zero-emission from off-road vehicles and equipment operation in the State by 2035.”
Even so, in California, SORE emit more NOx and ROG [Reactive Organic Gases] than light-duty passenger cars, both in summer and annually. Without additional regulation, SORE will emit 1.8 times the amount of summertime NOx and ROG that California light-duty passenger vehicles emit in 2031 (CARB, 2020 and 2021b).
The pollution figures may seem high, but these are justified by the extremely poor performance of SOREs, high relative usage and extremely good performance of modern cars.
The Proposed Amendments would accelerate the transition to ZEE by setting evaporative and exhaust emission standards to zero for new SORE (engines or equipment produced for sale or lease for use or operation in California), except engines used exclusively in generators, for model year (MY) 2024 and subsequent model years. Implementing emission standards of zero [0.00 grams of hydrocarbons (HC) + NOx per kilowatt-hour, or g·kWh-1, for exhaust emissions and 0.00 grams per test for evaporative emissions] does not necessarily mean that all new sales of small off-road equipment would be ZEE. Banked emission reduction credits could be used to offset emissions from SORE for up to five model years after the credits were generated. Also, engines or equipment emitting below 0.005 g·kWh-1 or g·test-1 could be certified to meet emission standards of zero. However, staff believes that it is unlikely that engines or equipment meeting emission standards of zero will be manufactured. It is more likely that manufacturers will use emission reduction credits in the near-term to offset emissions from SORE while the credits are available.
The way that CARB is going about this is admittedly odd, but also quite appropriate in a way: nobody would have thought that the appropriate level of pollutants would ever be set to zero when pollution first became an issue. But they gave CARB the right to regulate the emissions, and zero is a perfectly appropriate number to regulate it to, given today’s environmental and market conditions.
Have a read of the proposal yourself, the introduction is quite comprehensible and there’s lots of evidence of the real work done by CARB later on. Although at >400 pages you might not want to read the whole thing!
Anyway, to sum up, it’s certainly an interesting time in the small off-road equipment market, and probably a good place for a startup manufacturer of electric equipment, and quite possibly for the consumer as well. As an existing manufacturer of SOREs, maybe not so much. That’s no death sentence though, although there’s no time to spare, the incumbents have strong R&D departments and the state is setting them off in the right direction.
A lot of the lobbying against this change is surely coming from these manufacturers, with the scaremongering media and religious generator users coming along for the ride. But there are legitimate complaints, due to the very short timescale for the phaseout of non-generator SOREs and the increased cost of generator alternatives currently on the market.
It’s clear that this will be good for the health and welfare of Californians, and that existing generator users have nothing to fear from the change, but rather they can expect benefits from the new and innovative products that California will be producing in the near future.
With all this new battery-operated equipment coming on the market soon, there needs to be a big push for a consistent and repairable battery standard. Vendor lockin, battery cost and safety all need to be improved. Existing proprietary batteries - where the options are an overpriced and unrepairable original battery or a dangerous cheap clone are not the solution. A well-designed open standard is needed so that consumers can choose batteries that are compatible between all their equipment and can buy high-quality third party batteries.
This is a ridiculous assessment. California is prone to massive earthquakes and fires. Generators are emergency equipment. You can't rely on lithium batteries and solar to power a refrigerator at anywhere near the price of a generator, which is pretty important if you need to keep your insulin cold for two weeks after an earthquake, or a CPAP, or an oxygen machine. If you need to power a welder so you can facilitate repairs post disaster, the bulk and weight of a solar + lithium setup is prohibitive. Or less a less dramatic example, you need to weld a telephone tower in the mountains and you have to hike in and bring power with you.
No one uses 2stroke engines anymore. They haven't been available since the 90s. People use petrol or diesel for generators in the US.
There is significantly lower hanging fruit compared to small engines when it comes to emissions. Increasing solar incentives where appropriate, continuing the transition to electric vehicles - those are sensible. Small generators are critical emergency equipment. Just look at the super-tsunami that recently hit the Philippines; there are areas that will be without power for months. If we had a major earthquake, yes there would be more resources available in the states, but it's very likely that some areas would be without power for weeks. It's happened before
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