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HH Issues - 1

HH Issues - 1

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HH Issues - 1

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  1. HH Issues - 1 • Proposed permeation standard of 2 g/m2/d at 40C, including durability provisions is more stringent than original proposal: • as discussed earlier, the data support for this is weak • 2 g/m2/d at 40 C is at least two times more stringent as 1 g/m2/d at 65-105 F (original proposal) since the rule of thumb is that a doubling of permeation occurs for roughly every 10C temp rise • test database does not include all durability provisions The Outdoor Power Equipment Institute 341 South Patrick Street • Alexandria, VA 22314 • 703-549-7600 • 703-549-7604 FAX • www.opei.org

  2. HH Issues - 2 • Achieving the proposed permeation standard by 2006 is not feasible as will be discussed in detail subsequently; the OPEI 2007 proposal was based on a tight but realistic set of assumptions • CARB should state explicitly and unequivocally that all compliance provisions are based on CERT fuel only - and not on ethanol-based fuels. The standard will need to be increased to accommodate ethanol fuels. • CARB should consider revising language in Article 8 to deal with product transshipment issues into and out of CA The Outdoor Power Equipment Institute 341 South Patrick Street • Alexandria, VA 22314 • 703-549-7600 • 703-549-7604 FAX • www.opei.org

  3. HH Issues - 3 • Based on earlier discussions, OPEI believes that staff has agreed to the following changes in Article 8 and CP-901: • 2482(i): define HH as engine displacement of less than 80cc • 2482(w): revise the definition of “unibody” tanks per language provided earlier, including DuPont input • 2482(a): change definition of co-ex tanks to have more than just one material (i.e., nylon, EVOH, etc.) • 2489(c)(4)(a): harmonize and simplify labeling language with exhaust regs. The Outdoor Power Equipment Institute 341 South Patrick Street • Alexandria, VA 22314 • 703-549-7600 • 703-549-7604 FAX • www.opei.org

  4. HH Issues - 4 • 2490(d): recognize that the parts list for less than 80cc is tanks only • 2491: have only one warranty statement for exhaust and evap • 2492(a)(7): extend same compliance flexibility proposed provisions for non-HH to HH as well • 2493: expand exemptions to metal and EVOH tanks • CP90, Part I, 1.0: CARB will provide flexibility to “carry-across” test data to other families using similar tanks The Outdoor Power Equipment Institute 341 South Patrick Street • Alexandria, VA 22314 • 703-549-7600 • 703-549-7604 FAX • www.opei.org

  5. HH Issues - 5 • Also, OPEI believes that CARB will consider the following changes to TP-901: • delete references to SHED in favor of vented enclosure • delete requirement on balance accuracy • adjust thermocouple sensitivity to +/- 1F • rethink humidity requirement during testing • delete requirement for full tank during UV testing • delete requirement for 15 hrs/day sunlight for UV testing • remove requirement for full tank during preconditioning soak • delete requirement for 10 days of permeation testing down to 3 days as long as r2 requirement is met The Outdoor Power Equipment Institute 341 South Patrick Street • Alexandria, VA 22314 • 703-549-7600 • 703-549-7604 FAX • www.opei.org