THE EPA REGS & YOU
What the EPA’s Control of Emissions from Highway Motorcycles means to you
■ IMAGINE CRUISING DOWN LAZELLE STREET ON YOUR 2010 Road King during the 70th annual Sturgis Rally as the mercury hovers around the 100-degree mark. Your engine temperature climbs above the boiling point of water and your exhaust system glows a dull red. For protection from the extreme heat generated by your bike’s catalytic converter, you’re wearing your aluminized Nomex/Kevlar heat-resistant overalls, the latest (albeit necessary) fashion statement in riding gear.
Does that sound like something out of a science fiction novel? With the enactment of the recent Environmental Protection Agency (EPA) rule, this scenario might not be as far-fetched as it seems. The EPA, on December 23, 2003, passed the Control of Emissions from Highway Motorcycles, significantly tightening emission standards for new motorcycles beginning with the 2006 model year.
A BIT OF HISTORY
In November 2000, the EPA published a regulatory announcement concerning new emission standards for new non-road engines and highway motorcycles. The announcement stated the EPA’s intention to adopt the California Air Resources Board (CARB) motorcycle emission standards — the strictest in the United States — and apply them to all motorcycles nationwide. Why did the EPA propose revisions to the current standards? The Clean Air Act of 1990 dictates that the EPA “consider the need to achieve equivalency of emission reductions between motorcycles and other vehicles to the maximum extent practicable.”
Will 2010 EPA regs have you wearing aluminized Nomex/Kevlar heat resistant overalls to protect you from the heat of your bike’s catalytic converter? Maybe not, as catalytic Converters (cats) are already in use on all Victory motorcycles sold in California. (Photo courtesy of Stanco Manufacturing Inc., Atlanta, Texas)
The EPA statistics show that motorcycles emit up to 21 times more hydrocarbons (HC) per mile than automobiles, and even emit more HC than SUVs. As the EPA explained to AIM , “The emission standards for cars are a fraction of what they are even for the new motorcycle standards. As a result, the cars have to do that much more to control their emissions. Cars are required to have incredibly elaborate emission control systems. If you took a typical car and just put straight pipes on it, the emissions would be similar to a motorcycle. Even though motorcycles’ engines are smaller, and motorcycles are lighter, that doesn’t come into play.”
The EPA statistics also state that highway motorcycles are significant contributors to mobile-source air pollution, currently accounting for 0.6 percent of mobile-source HC emissions, 0.1 percent of mobile-source oxides of nitrogen (NOx) emissions, and less than 0.1 percent of mobile-source particulate matter (PM) emissions. Without further regulations, highway motorcycles would account for 2.2 percent of mobile source HC, 0.3 percent of mobile source NOx, and 0.1 percent of mobile source PM.
What is not as highly publicized is the comparison between motorcycle emissions and all emission sources. Motorcycles currently account for only 0.3 percent of HC emissions from all, not just mobile, sources, with a projected rise to 0.6 percent by 2020. Both NOx and PM motorcycle emissions are currently 0.0 percent of all emission sources, with a 2020 projection of 0.1 percent and 0.0 percent respectively. As Kirk “Hardtail” Willard (photo at right), vice-president of the Motorcycle Riders Foundation (MRF) succinctly states, “We’re not that big a population. We’re about a quarter-inch on a 100-yard football field.”
In early 2001, the MRF released a Riders’ Alert that stated, in part, “The move follows two years of technical talks between the EPA and industry. In those talks, however, the topic never strayed from bikes in the woods to bikes on the highway. According to several industry sources close to the off-road technical talks with the EPA, street bikes were added as a bargaining chip. The Sierra Club had filed suit against the EPA, seeking new restrictions on off-road vehicle emissions sooner rather than later. Having exceeded the deadline for action set in the legal wrangling, the EPA returned to the negotiating table to seek more time to achieve new off-road emission standards.
The Sierra Club acquiesced to the agency’s bid for more time when the hope of tighter controls on highway motorcycles was tossed in to sweeten the deal.”
PUBLIC COMMENTS
Comments were requested by the EPA on the technological feasibility, cost, and appropriateness of implementing more stringent emission standards for highway motorcycles. Objections, questions, and suggestions were received from the motorcycle industry, motorcycle user groups, government agencies, environmental groups, and the public. For instance, Imre Szauter, the American Motorcyclist Association (AMA) Legislative Specialist, stated that the AMA voiced strong concerns regarding safety, cost, performance, consumer modifications, small volume manufacturers, and sub-50cc motorcycles.
During the comment period, Harley-Davidson argued that the EPA should follow California’s lead in regulating engine manufacturers, and that these manufacturers, who build thousands of engines, shouldn’t be exempt simply because they don’t assemble many motorcycles. The EPA responded that it understood Harley-Davidson’s concern, and the issue would be addressed in a 2006 technology review.
Former US Representative James Barcia from Michigan introduced the Motorcycle and Motorcycling Small Business Protection Act into Congress in September 2002. The bill aimed to exclude motorcycles from the emission controls dictated by the Clean Air Act. Although he had the backing of a number of powerful Congressmen, Barcia was not able to get a hearing for the bill, and it was dropped when he didn’t seek reelection the next term. Barcia tells us, “I wanted to indicate to the EPA that Congress has a concern with the direction the EPA was going in, rather than seeing motorcycles as a viable means of transportation. They are not looking at the benefits — motorcycles use less fuel, are more economical, and create less pollution. I don’t understand how they came up with their statistics.”
According to our sources, ABATE of Illinois, in a legislative update distributed to its members in February 2004, revealed that Congressman Barcia admitted that a “member” of Harley-Davidson and AMA had asked him to pull his bill. ABATE of Illinois also stated that the EPA admitted that H-D had come to the agency asking for a new rule to control motorcycle emissions. American Iron Magazine was unable to substantiate these statements in our discussions with the EPA and other sources.
The MRF commissioned economist Garrett A. Vaughn to prepare an economical analysis of the proposed emission standards. The study pointed out that the EPA underestimated implementation costs, ignored the issue of rider safety, ignored the possible impact of the proposed standards on future motorcycle sales, ignored the adverse impact to motorcycle registrations once the CARB standards went into effect, and did not meet its obligations to consider a less stringent alternative to the proposed emission standards.
To the EPA’s credit, it appears that numerous questions, comments, and objections from the motorcycle community were documented and duly responded to, even though a number of manufacturers, independent shops, and motorcyclists’ rights organizations may not have agreed with those responses.