In November 2000, the Environmental Protection Agency signaled its intention to adopt California's emissions standards -- the strictest in the country -- and apply them nationwide to all motorcycles -- street and off-road. Among the new controls on the drawing board: ways to stop motorcyclists from customizing the look, sound and performance of their machines.
Combating new, questionable emission controls on street bikes may emerge as the leading federal issue to be tackled in Washington by the Motorcycle Riders Foundation and its co-partners, State Motorcyclists' Rights Organizations (SMROs) nationwide.
"Given that California has recently put in place technologically challenging standards for [large displacement street] motorcycles in a time frame that we would likely consider for a possible federal program, we are likely to look very closely at the pros and cons of harmonizing the federal program and whether the California standards are appropriate for a nationwide federal program," the agency wrote in its November Advance Notice of Proposed Rulemaking (ANPR) which appeared again in the Federal Register December 7th.
The move follows two years of technical talks between 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 EPA, street bikes were added as a bargaining chip. The Sierra Club had filed suit against EPA, seeking new restrictions on off-road vehicle emissions sooner rather than later. Having exceeded the deadline for action set in the legal wrangling, EPA returned to the negotiating table to seek more time to achieve new off-road emission standards. Sierra Club acquiesced to the agency's bid for more time when the hope of tighter controls on highway motorcycles were tossed in to sweeten the deal.
The first step to new, tougher emission standards, EPA's ANPR reads like a regulator's wish list: catalytic converters, new controls on the smallest of motorcycle makers and ways to prevent or prohibit motorcyclists from customizing their rides.
Wary of motorcyclists' desire to improve the look, sound and performance of our bikes through improvements to exhaust and other systems -- a practice it terms "tampering" -- EPA is researching strategies to "mitigate this problem." EPA is concerned that "standards which result in the widespread use of catalytic converters will achieve less benefits than projected due to consumer tampering with the exhaust systems. The agency will solicit comment on "the magnitude of these consumer practices" and ways to stop it -- either by device, prohibitions or both.
EPA also seeks to control the smallest of motorcycle makers. With small-volume American motorcycle manufacturers spreading, to our delight, like micro-breweries, EPA questions the appropriateness of the current federal definition of small business as applied to small-volume bike makers. The agency's interest here is hardly academic: it wishes to impose the same, California-style controls on all motorcycles, period, regardless of the small number of bikes produced.
Meanwhile, the European Union has pressed for a two-tier reduction in motorcycle emissions in 2002 and 2006. Citing new developments in injection technology, MRF's European ally, the Federation of European Motorcycle Associations (FEMA), reports that many of the motorcycles sold in Europe may meet the new requirements without a closed-loop catalytic converter (or "cat").
In this country, however, with its advance notice littered with mentions of the device, it's clear that EPA is a cat lover.
MRF and FEMA share profound concerns about cats on motorcycles, among them:
In Europe, the average journey length for an automobile is 20 kilometers. At that point, a cat is up to operating temperature (a nominal 800 degrees Fahrenheit). The average journey length for a bike in Europe is far less. With a cat operating at colder temperatures, the result is more harmful emissions, not less.
MRF advances motorcycling as a safe, sound and exhilarating transportation alternative to cars, and Americans are responding by buying and using motorcycles like never before. Nevertheless, our bikes cover a tiny fraction of the miles racked up by passenger cars, making the contribution to pollution by highway motorcycles a tiny fraction of a percent.
In 1997, cars, light trucks and SUVs accumulated 2.4 trillion vehicle miles traveled. Of the 5.1 million highway motorcycles operating in 1998, the Motorcycle Industry Council estimates, the average bike clocked just 2,613 miles that year. In short, we rode just .55% of the miles driven by cars, light trucks and SUVs.
During the regulatory proceedings that led to California's stricter emission standards, the California Air Resources Board estimated that the average emission level generated by in-use highway motorcycles was .96 grams of hydrocarbons per mile. Expressed as a function of the number of motorcycles registered at the time of that debate, street bikes emitted six one-thousandths of one percent of the emissions generated by all on-road motor vehicles -- hardly justification for costly devices that strangle American motorcycles, hike prices for consumers, threaten small business, chill the burgeoning motorcycle after-market and limit if not eliminate riders' freedom to customize our rides.
Public comments must be received by EPA not later than February 5, 2001. If you, as an individual and as an SMRO, submit your comments, you will be part of the debate that will stretch through the Summer of 2001.
Public comments should contain sound technical arguments. Rhetoric and name-calling will not move the debate in the direction you want it to go.
According to the court decree, the EPA Administrator must sign the new standards not later than September 14, 2001.
Keep in mind that the court decree requires new standards on off-road vehicles only. Technical talks between EPA and makers have focused solely on off-road vehicles for two years. Street riders have not been given that period of time for involvement, much less study and consultation. Federal highway motorcycle emissions haven't changed in 23 years, but if it's time to consider a change, it's time to give our community the time to study it.
Study the advanced notice. You can obtain HTML or PDF versions at the Federal Register on-line by pointing your browser to the following site, http://www.access.gpo.gov/su_docs/aces/aces140.html and then, using the search function there, find the December 7, 2000, document titled "Control of Emissions From Non-road Large Spark Ignition Engines, Recreational Engines (Marine and Land-Based), and Highway Motorcycles."
Know the other chess player: EPA's mandate is not to obtain a new standard that many might agree is "reasonable." EPA's mandate is to obtain the maximum gain possible considering technology and cost.
1. FIRST, ASK CONGRESS FOR HELP. Write a letter to your Congressman and two U.S. Senators immediately to inform them of this situation and to ask for their help. Let them know you are concerned that a choke-hold on highway motorcycles is being rushed into place, and you need their support to help break the choke-hold. Use your own words or borrow as much as you'd like from this alert, but send the letters now.
2. SECOND, SEND YOUR PUBLIC COMMENTS TO EPA. In all correspondence, refer to Docket A-2000-01, the "Control of Emissions From Non-road Large Spark Ignition Engines, Recreational Engines (Marine and Land-Based), and Highway Motorcycles."
a. BY MAIL. Send paper copies of written comments (in duplicate if possible) to:
National Vehicle and Fuels Emission Laboratory
2000 Traverwood, Ann Arbor, MI 48105
b. VIA E-MAIL. E-mail comments to:
3. THIRD, TRIPLE YOUR VOICE. Send this alert to 3 other riders you know. Urge them to send their comments AND join MRF by calling 202-546-0983. We will need all the help we can get to break the choke-hold.
- MRF: My Ride is Freedom -
For further information contact Tom Wyld at 202-546-0983 or by e-mail at firstname.lastname@example.org
The first motorcyclists' rights organization to establish a full-time legislative advocacy presence in Washington, the Motorcycle Riders Foundation is the only Washington voice devoted exclusively to the street rider. MRF established MRFPAC in the early 1990s to advocate the election of candidates who would champion the cause of rider safety and rider freedom. MRF proudly claims state motorcyclists' rights organizations and the very founders of the American rider rights movement among its leading members. Motorcyclists worldwide can thumb-start their search for rider rights and safety on the web at www.mrf.org.
© All information contained in this release is copyrighted. Reproduction permitted with attribution. The Motorcycle Riders Foundation, incorporated in 1987, is an independent, membership-based national motorcyclists' rights organization head quartered in Washington D.C. which operates in co-partnership with State Motorcyclists' Rights Organizations nationwide. The MRF is involved in federal and state legislation and regulations, motorcycling safety education, training, licensing and public awareness. The MRF provides individual and SMRO member-volunteers with guidance, support and information to protect motorcyclists' rights and advance motorcycling and its associated lifestyle. The MRF sponsors annual regional and national educational seminars for motorcyclists' rights activists and publishes a bi-monthly newsletter, THE MRF REPORTS. Voice: 202-546-0983, Fax: 202-546-0986, E-Mail: email@example.com, website: http://www.mrf.org
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