Technical Support Report for Regulator Action
Reduced Certification Testing for Motorcycles
May 1975
Notice
Technical support reports for regulatory action do not necessarily
represent the final EPA decision on regulatory issues. They are intended
to present a technical analysis of an issue and conclusions and/or
recommendations resulting from the assumptions and constraints of that
analysis. Agency policy constraints or data received subsequent to
the date of release of this report may alter the conclusions reached.
Readers are cautioned to seek the latest analysis from EPA before
using the information contained herein.
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air and Waste Management
U.S. Environmental Protection Agency
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Reduced Certification Testing:
Small Volume Motorcycle Manufacturers
The following two reports discuss the cost and air quality
impacts of reduced certification testing on small volume motorcycle
manufacturers. Background discussion on light duty vehicle reduced
testing is also presented for perspective.
The discussion of economic impact estimates the costs of cer-
tification for motorcycle manufacturers and compares these costs to
those for automobile manufacturers. Certification costs for small
volume manufacturers are calculated assuming that deterioration
factors are assigned to these manufacturers by EPA and that the
durability distance requirement is waived for these manufacturers.
Based on the significant sales break point at 10,000 units
per manufacturer, it is recommended that the reduced testing break
point for motorcycles be established at 10,000 units per manufacturer.
In addition, it is recommended that the initial reduced testing policy
eliminate the durability requirement for manufacturers with sales of
less than 10,000 units provided the manufacturer accepts deterioration
factors established by EPA; and the number of emission data vehicles
should be reduced where possible for manufacturers with sales of less
than 2000 units. This policy would then be reviewed continually and
modified as necessary.
The air quality impact of reduced testing estimates hydrocarbon
emissions in the LA AQCR for the years 1978 through 1990. Emission
rates are assumed to deteriorate significantly for those manufacturers
who sell less than 10,000 units and qualify for reduced testing.
These rates are then compared to those resulting from requiring full
durability testing by all manufacturers and, thus, little emission
deterioration. The comparison shows minimal air quality impact with
relaxed durability requirements for manufacturers who sell less than
10,000 units.
Prepared by
Division Director f
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UNITED STATES'ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Reduced Testing for Small Volume Motorcycle DATE: March 11, 1975
Manufacturers (85.478-5(e))
FROM: Daniel P. Hardin Jr. /^.^~ia/^-S'/t^4~-J^
Certification & Surveillance Division Stafif
\j
TO: Edmund J. Brune
Director, Certification & Surveillance Division
Background;
1) The original intent of the reduced testing provision for light
duty vehicles (85.075-5(e)) was to reduce the economic impact of
certification testing on small (under 2000 unit sales) vehicle
manufacturers. It was felt that the cost burden of certification
testing could prohibit some manufacturers from gaining certification or
could be passed on as a significant part of the retail price of the
vehicle for small volume manufacturers which would adversely affect their
sales and possibly their existence.
2) The method which CSD chose to reduce testing for LDV was_to relax
the requirements for durability vehicle selection L§5 .074-5 (c}! and for
"A" selection emission data vehicles 185.074-5(b) (2)) The 1974 and
earlier requirements for durability selection were that the manufacturer
run two vehicles to 50,000 miles for each control system. For small
volume manufacturers this requirement was,in some cases, reduced to
one durability vehicle. The requirement for "A" selection emission
data vehicles was a minimum of two vehicles per 85.074-5 (b) (2) .
For small volume manufacturers this was generally reduced to one emission
data vehicle. The impact of this reduced testing effectively cut the
cost of certification by 50 percent. For a small manufacturer with vehicles
of $4500 average retail price, the cost of two durability and two emission
data vehicles represented 3 percent of the retail price or about $142.00 per
car (this assumes the manufacturer built 2,000 vehicles). The reduced
testing made this only 1.5 percent. The average of the small volume-
manufacturers sales is fewer than 500 vehicles per manufacturer, which
raises the cost per vehicle significantly.
3) Two factors have changed since the original inception of the reduced
testing provisions:
a. The test vehicle selection requirements of 85.074-5 have been
relaxed so that two durability and two "A" selection emission
data vehicles are no longer required for 1975 and later model
years (85.075-5). Therefore, there are no areas in which
testing may be significantly reduced for small volume manufacturers.
cPA Form 1320-6 (Rev. 6-72)
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b. The vast majority of small volume manufacturers now build
exclusive personal cars, exotic sports cars or antique replica
• cars. The sales weighted average retail price for all small
volume manufactured vehicles is $13,000. The economic impact
of full certification is now reduced by relaxed regulated
requirements and by the higher retail cost to $71.00 per car
at 2000 unit sales or .5 percent of the retail cost.
4) The ecop.onic impact of certification testing for snail volume
auto manufacturers has been significantly minimized to a point to where the
reduced testing provisions can no longer be effectively exercised.
5) The issue of reduced testing has been raised for motorcycle
certification, with the additional request that the limit be increased
to 10,000 unit sales.
Discussion
1) Small volume motorcycle manufacturers are, by nature, not in a similar
situation to small volume auto manufacturers. They have a product
with significantly lower retail price and a lower profit margin. They
have far less capital and facilities than the small volume auto manufacturer.
For the most part,it may be assumed that the small volume motorcycle
manufacturer is not capable of performing his own durability mileage
accumulation and emission testing, and that it must be contracted for
at increased cost. The support data used in this paper uses figures
established on the basis that the manufacturer would do his own testing
and mileage accumulation as a conservative estimate. About half of the
small volume light duty manufacturers do their own testing and mileage
accumulation and the remainder qualify for durability if not emission data
carryover. Most small motorcycle manufacturers would not qualify for
carryover as they generally use their own engines.
2) Comparing the relative portions of the respective industry made up
by small LDV manufacturers and small motorcycle manufacturers:
LDV
Total industry sales - 10 million
Total small volume manufacturer, sales = 8000 units
.08 percent of market -
Total number of LDV manufacturers =50
Small volume manufacturers 18 = 36 percent of total manufacturers
Motorcycles
Total industry sales ~ 1,080,000
Small volume manufacturer (<2000 units) "=• 3 percent
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Small volume manufacturer (<10,000 units)^ = 5 percent
Total number of manufacturers = 35
Total number of manufacturers < 2000 sales "= 20 (57 percent)
Total number of manufacturers<10,000 sales "= 29 (83 percent)
It is evident that, at least at the outset, a larger portion of
both total manufacturers and industry sales is represented by small
volume motorcycle manufacturers than by small volume LDV manufacturers.
Any regulations impacting that a large portion (3 percent sales, 57 - 83
percent manufacturers) of the motorcycle industry must be considered
carefully for the nature of the impact.
3) The motorcycle regulations have been patterned after the existing
LDV regulations in most areas. The fleet selection requirements have been
only slightly modified and a minimum of one durability motorcycle per
engine-system combination and one emission data motorcycle per displacement
are required.
4) The economic impact of full certification for the large motorcycle
manufacturers is the same as that for large LDV manufacturers. The
average percent of retail price impact on both large LDV manufacturers and
large motorcycle manufacturers is .145 percent. The economic impact of
•full certification on small volume manufacturers is:
<2000 units - 3 to 6 percent of retail price
<10,000 units - about one percent of retail price
This is greater than the impact originally estimated for small volume
LDV manufacturers prior to 1975.
5) The most significant portion of the cost of certification is the
durability mileage accumulation and testing. This is true also for LDV.
a. If the option of reduced testing is exercised to reduce only
emission data vehicle testing, the influence on percent retail
price is less than .5 percent reduction in most cases.
b. If the option of reduced emission testing is exercised to
eliminate durability testing, the influence on percent retail
price is:
<2000 units-cost of 1-2 percent/unit
<10,000 units-cost of .2-.4 percent/unit
1 By examining the 1973 sales data presented in Figure 1, it can be
seen that there is a definite division between the "large volume" motorcycle
manufacturers and the "small volume" motorcycle manufacturers occurring at
about ,10,000 unit sales.
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4.
c. If the option of reduced testing is exercised to eliminate durability
testing below 10,000 unit sales and to reduce emission data testing
below 2,000 unit sales, the impact is:
10,000 units - cost percent of retail - .2 to .4 percent
2,000 units - cost percent of retail - .6 to 1.0 percent
This compares favorably with the cost percent for the large volume
motorcycle manufacturers of .145 percent of retail-price.
6) For the first year or two, the certification group responsible for
motorcycles will still be comming up to speed on motorcycle certification.
While the regulations have been written based on the best available
information, it is conceivable that some revisions to useful life,
maintenance, driving schedule, etc., may be required based on what
occurs during the first year or two of certification. For all manufacturers,
the first year of certification will be the first time any significant
durability mileage is accumulated on motorcycles and some problems will
probably come to light. It is felt that the large volume manufacturers
are better equipped to run durability and to give an accurate analysis :
of the certification process than small volume manufacturers.
Recommendations
1) That 85.478-5(e) be modified to read: "Any manufacturer whose projected
sales of new motorcycles subject to this subpart for the year of production
for which certification is sought is less than 10,000 vehicles may request
a reduction in the number of test vehicles determined in accordance with
the foregoing provisions of this section. The Administrator may agree to
such lesser number as he determines would meet the objectives of this
procedure."
2) That CSD implement a policy for reduced testing under 85.487-5(e)
which would:
a. Eliminate durability testing for those motorcycle manufacturers
with sales of less than 10,000 units provided the manufacturer
accept deterioration factors of:
HC = 1.1236
CO = 1.1403
NOx = 1.0296
(based on average 1974 LDV deterioration factor information)
b. Reduce emission data testing requirements for manufacturers
with sales of less than 2,000 units. Where optional configurations
might be selected under 85.478-5(b)(3) they would be combined
with the (b)(2) displacement selected data vehicles to yield a
"worst case" vehicle for each displacement.
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c. This policy be modified, as required in future years, to meet
the impact, on the industry and on air quality.
1. Revise D.F. assignments based on each year's
durability results from large M/C manufacturers
D..F data.
2. Reassign sales split points, possibly offering no
durability break but emission data breaks to larger
volume manufacturers (4000-10,000 units perhaps)
based on a new impact study.
cc: D. M. Kimball
J. M. Marzen
L. I. Ranka
J. C. Thomson
W. Houtman
•>W. Oliver
R. Jenkins
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APPENDIX
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MOTORCYCLE SALES DATA (1973 Year-To-Date Polk Data)
Honda 464,824
Kawasaki 126,908
Suzuki 137,455
Yamaha • 213,014
Harley Davidson 54,932
BSA-Triumph-Norton 35,859
BMW 6,693
Hodaka 8,606
Bultaco 4,313
Bennelli 900
Ducati 1,000
Husqvarana 3,100
Java 2,300
Moto Guzzi 3,000
Ossa 2,900
+ 20 smaller manufacturers 21,556
(or 1,078 M/C per manufacturer avg.)
Total Sales 1,087,360
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AVERAGE LARGE AUTO MANUFACTURER COST TO CERTIFY
1975 GM - 2,256,000 Sales
About 35 families, Average 4 data cars/family
Total Cost
35 X$125,000 Durability = 4,375,000
140 X $17,000 Data 2,380,000
$6,755,000
Cost/car = $2.99
Avg. Retail $4500
Cost % = .06%
1975 Ford - 1,087,000 Sales
About 35 families, Average 4 data cars/family
Total Cost
35 X$125,000 Durability 4,375,000-
140 X $17,000 Data 2,380,000
$6,755,000
Cost/car = $6.21
Avg. Retail $4500
Cost % = .14%
1975 Chrysler - 611,477 Sales
About 24 families, Average 4 data cars/family
Total Cost
24 X$125,000 Durability 3,000,000
96 X $17,000 Data 1,632,000
$4,632,000
Cost/car = $7.57
Avg. Retail $4500
Cost % = .16%
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AVERAGE LARGE AUTO MANUFACTURER COST TO CERTIFY - continued
1975 AMC - 193,110 Sales
About 10 families, Average 4 data cars/family
Total Cost
10 X$125,000 Durability = 1,250,000
40 X $17,000 Data 680,000
$1,930,000
Cost/car = $9.99
Avg. Retail $4500
Cost % = .22%
BIG FOUR AVERAGE
AVERAGE % COST - .145%
^2000 SALES AVERAGE
AVERAGE % COST - 1.8% (prior to 1974)
12.4 X COST% of BIG FOUR
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SMALL AUTO MANUFACTURER CERTIFICATION COST
I. Durability
A. Prototype Vehicle Cost $25,000
B. Mileage & Maintenance $1.90/mi X 50K 95,000
C. Testing $300/test X 14 Tests 4,200
$124,200
$125,000
II. Emission Data
A. Prototype Vehicle Cost $10,000
B. Mileage & Maintenance $1.60/mi X 4K 6,400
C. Testing $300 X 2 Tests 600
$17,000
Assume 1 engine family, limited product line for manufacturer
of 2000 or less sales.
1 Durability - $125,000
2 Data (1MT, 1AT) 34,000
$159,000
Cost/Car = $80
Avg. Retail 4500 (based on prior to 1974)
Cost/Car = 1.8% of retail price
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MOTORCYCLE MANUFACTURER CERTIFICATION COST
I. Durability >170cc
A. Prototype Vehicle Cost $8,000
B. Mileage & Maintenance $1.90/mi X 19000 36,100
C. Testing $300/test X 15 tests 4,500
$48,600
$50,000
II. Emission Data >170cc
A. Prototype Vehicle Cost $4,000
B. Mileage & Maintenance $1.60/mi X 3000 Mi 4,800
C. Testing $300/Test X Tests 600
$9,400
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MOTORCYCLE MANUFACTURER CERTIFICATION COST
I. Durability < 170cc
A. Prototype Cost $.8,000
B. Mileage & Maintenance $1.80 X 9000 17,000
C. Testing $300/Test X 12 3,600
$28,700
~ $30,000
II. Emission Data < 170cc
A. Prototype Cost $4,000
B. Mileage & Maintenance $1.60 X 2000 3,200
C. Testing $300/Test X 2 600
$7,800
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AVERAGE LARGE MOTORCYCLE MANUFACTURER COST TO CERTIFY
Honda - 464,824 Sales
6 Families 23 Data Bikes
4>170cc Families 14 Data Bikes
2<170cc Families 9 Data Bikes
Total Cost
4 X 50,000>170cc Durability
14 X 9,000> 170cc Data
2 X 30,000<170cc Durability
9 X 7,800<170cc Data
Cost/Bike =
Avg. Retail
Cost %
$200,000
131,600
60,000
70,200
$461,800
$ .99
$1200
.08%
Yamaha - 213,014 Sales
4 Families 11 Data Bikes
3 > 170cc Families 9 Data Bikes
1 < 170cc Family 2 Data Bikes
Total Cost
3 X 50,000 > 170cc Durability
9 X 9,400 > 170cc Data
1 X 30,000 < 170cc Durability
2 X 7,800 < 170cc Data
Cost/Bike = $1.31
Avg. Retail $1200
Cost % .1%
$150,000
84,600
30,000
15,600
$280,200
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.AVERAGE LARGE MOTORCYCLE MANUFACTURER COST TO CERTIFY-continued
Suzuki - 137,455 Sales
6 Families 14 Data Bikes
5 > 170cc Families 10 Data Bikes
1 < 170cc Family 4 Data Bikes
Total Cost
5 X 50,000 > 170cc Durability = $250,000
10 X 9,400 > 170cc Data . = 94,000
1 X 30,000 < 170cc Durability = 30,000
4 X 7,800 < 170cc Data = 31,200
$405,200
Cost/Bike = $2.94
Avg. Retail= $1200
Cost % = .2%
Kawasaki - 126,908 Sales
5 Families 14 Data Bikes
4 > 170cc Families 9 Data Bikes
1 < 170cc Families 5 Data Bikes
Total Cost
4 X 50,000 > 170cc Durability = $200,000
9 X 9,400 > 170cc Data = 84,600
1 X 30,000 < 170cc Durability = 30,000
5 X 7,800 < 170cc Data = 39,000
$353,600
Cost/Bike = $2.78
Avg. Retail = $1200'
Cost % = .2%
AVERAGE COST - BIG 4 MOTORCYCLE MANUFACTURERS
.145% OF RETAIL PRICE
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If Motorcycle allowance is raised to 10,000 unit sales:
Case I; > 170cc
$78/200 r 10,000 sales W/ durability - $28,200
Cost/Bike = $7.82 $2.82
Avg. Retail $1500 $1500
Cost % = .5% .18%
Case II; < 170cc
$53,400 i 10,000 Sales W/0 Durability = $23,400
Cost/Bike = $5.34 $2.34,
Avg. Retail $900 $900
Cost % = .6% .26%
Case III; j~170cc
$131,600 r 10,000 Sales W/0 Durability $51,600
Cost/Bike = $13.16 $5.16
Avg. Retail $1200 $1200
Cost % = $1.09 43%
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Small Volume ( < 2000 unit sales) Manufacturer W/0 Durability
Case I - > 170cc
$28,200 T 2000 units
Cost/Bike = $14.10
Avg. Retail > 170cc - $1500
Cost % = .97%
W/ 2 Data Bikes = .6% (9.40 Cost/Bike)
Case II - < 170cc
23,400 r 2000 units
Cost/Bike = $11.40
Avg. Retail < 170cc = $900
Cost % =1.3%
W/ 2 Data Bikes = .8%(7.80 Cost/Bike)
Case III - $170cc
$51,600 f 2000
Cost/Bike = $25.00
Avg. Retail $1200
Cost % = 2.15%
W/ Reduced Data Bike Testing = 1%
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CASE I. - Small Motorcycle manufacturer < 2000 units
building only > 170cc bikes
with more than 1 "displacement.
1 Family
1 Durability Vehicle $50,000
2 Data Vehicles (Displacement)—___^ 28,200
1 Optional Data
$78,200
Cost/Bike = $40
Avg. Retail > 170cc = $1500
Cost % = 2.7%
W/2 Data 2.3%
W/l Data 2.0%
CASE II - Small Motorcycle manufacturer < 2000 units
building only < 170cc bikes
with more than one displacement.
1 Family
1 Durability Vehicle $30,000
2 Data Vehicles (displacement)^....^ 23,400
1 Optional Data
$53,400
Cost/Bike = $27
Avg. Retail < 170cc = $900
Cost % .3%
W/2 Data = 2.5%
W/l Data = 2.1%
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Case III - Small Motorcycle manufacturer < 2000 units
building both < 170cc & > 170cc
both with more than 1 displacement
2 Families
1 > 170cc $78,200
1 <170cc 53,400
Cost/Bike = $65.00
Avg. Retail $1200
Cost % = 5.4%
W/2 Data/Fam.= 4.8%
W/l Data/Fam.= 4.1%
$131,600
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SOURCES
1) Cost To Certify. General Motors Corp.
Dave Horchler GM V.E.L.
Bob Stempel, Chevrolet Engineering
Prototype Vehicle
Durability - If modification to production car - $ 25,000
Durability - If all new car $100,000 - $500,000
Emission Data- 10,000
50,000 Mile Cost
Durability mileage & maintenance - $1.90/Mi
Durability testing (in house) - $300/Test
Outside testing (est.) $600 +/Test
2) Large Manufacturers Sales - Auto - Automotive News
1974 Total year production
All Manufacturer Sales - Motorcycles - 1973 Polk Data
3) Small Manufacturer Sales - .1974 Part I Application (Auto)
4) Small Manufacturer Retail Price - 1973 - 1974 World Cars Catalogue
5) Auto Average Retail - Estimated on 1975 Prices - $4500
6) Motorcycle Average Retail - Estimated on 1974 Prices
>170cc $1500
<170cc $ 900
7) Motorcycle Prototype Cost - Based on Ratio of Prototype to Retail
of Auto
25000 =5.55
4500
Motorcycle 1500 X 5.55 ~ $8000
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
SUBJECT: Air Quality Impact of Reduced Testing for Small Volume DATE: April 1, 1975
Manufacturers
FROM: William Rogers Oliver, SDSB
TO: The Record
The issue .of reduced testing for small volume motorcycle manu-
facturers has been considered recently in order to reduce the cost
of motorcycle certification. One consideration of reduced certifica-
tion testing has been estimating its impact on air quality0 Since
no data exist to determine the precise air quality impact, a worst
case approach- toward deterioration rates has been used for this report.
Air quality impact has been estimated previously for various
motorcycle hydrocarbon emission standards in the LA AQCR. The base
case used for comparison purposes in this report was the displace-
ment, related. HC standard for the LA AQCR for the 1978 and 1979
years of production and the LDV statutory HC standard for 1980 and
beyond. Various assumptions were necessary for estimating air quality
impact such as population growth rates, annual motorcycle distance
traveled, and emission factor determination. Using these assumptions
and making no allowances for possible reduced testing effects, the
following emission rates resulted.
HC,.Tons/Day
23.36
22.22
18.09
4.235
1.415
Estimating the air quality impact of reduced certification
testing for small volume motorcycle manufacturers can be done by
considering the form of reduced certification. This report will
consider the effect on air quality of removing the durability distance
accumulation requirement for motorcycle manufacturers who sell less
than 10,000 U.S. street legal units. It was assumed that motorcycles
built by these manufacturers met emission standards at the stabilized
emission point and were assigned deterioration factors (D.F.) of 100
for certification purposes. However, when measured in the field, the
motorcycles built by these small volume manufacturers were assumed
to deteriorate significantly more than this. In order to measure
this effect on air quality, an assumption was needed on deterioration
factors for these motorcycles„ By reviewing available LDV data, the
worst case deterioration factor for this case was assumed to be 2.0.
Emission factors for these motorcycles, then, were two times the factors
of the completely controlled motorcycles.
EPA Form 1320-6 (Rev. 6-72)
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Assumptions used for the base case air quality estimates were
used for the estimates of reduced testing impact on air quality.
In addition, the break point for reduced testing was assumed to
be 10,000 units per manufacturer. A 10,000 unit break point means
that the "Big Six" motorcycle manufacturers would not qualify for
reduced testing, but approximately 29 other manufacturers repre-
senting approximately 5% of all U.S. street legal motorcycle sales
would qualify. (The 5% estimate was used in all calculations.)
As an example, in the LA AQCR in 1978, 254,231 motorcycles were
precontrolled (1977 and earlier), 59,676 met the displacement
dependent HC standard, and 3141 motorcycles were produced by manu-
facturers qualifying for reduced testing and had D.F»s of 2.0.
Using these assumptions, the following emission rates resulted
from requiring full certification by the.Big Six manufacturers while
removing the durability requirement for manufacturers who sell less
than 10,000 units in the U.S.
HC, Tons/Day
23.53
22.53
18.38
4.396
1.486
Emission rates were higher for this case than the base case,
as expected. However, significant emission reductions did occur.
To compare the base case and the worst case deterioration factor
computations, the following results represent the percent increase
in emissions over the base case emission reductions resulting from
a two fold increase in emissions from motorcycles built by manu-
facturers selling less than 10,000 U.S. street legal units.
Year Emission Increase over Base Case
1978 0.7%
1979 1.4%
1980 1.6%
1985 3.8%
1990 5.0%
As seen in the table, the increase in emissions over the base
case is very minimal. Thus, a reduced testing program with relaxed
durability requirements for motorcycle manufacturers with U.S. sales
volumes less than 10,000 units will have minimal air quality impact.
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Distribution List
Motorcycle Technical Support Reports for Regulatory Action
Dt Alexander
E. Brune
T. Cackette
J.P. DeKany
C.L. Gray
D. Hardin
K. Hellman
W. Houtman
T. Huls
R. Jenkins
E. Rosenberg
R. Stahman
E.O. Stork
G. Thompson
M. Williams
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