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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