United States Air and Radiation EPA420-F-03-045
Environmental Protection December 2003
Agency
Office of Transportation and Air Quality
&EPA Frequently Asked
Questions
In-Depth Information for Motorcycle
Owners on EPA's New Emission
Standards for Highway Motorcycles
In December 2003, the U. S. Environmental Protection Agency (EPA)
published a Final Rulemaking (FRM) establishing more stringent
emission standards for highway motorcycles. This information sheet
addresses questions raised by concerned motorcycle owners.
Why is EPA adopting new emission standards for
highway motorcycles?
Motorcycles are regulated under section 202 of the Clean Air Act which
calls for EPA to consider the need to achieve equivalent emission reduc-
tions from both motorcycles and other vehicles as much as possible. The
Clean Air Act also requires EPA to set new standards for off-road motor-
cycles, which we did in 2002. EPA has not revised the on-road motor-
cycle emission standards for over 20 years. While there have been many
vehicle emission control technology advances over the past two decades,
today's motorcycles produce more harmful emissions per mile than
driving a car or even a large sport utility vehicle (SUV). The current
federal motorcycle emission standard for hydrocarbon emissions is about
90 times the hydrocarbon standard for today's passenger cars. And,
although many of today's motorcycles actually meet the current Califor-
nia emission standards, the current California hydrocarbon standard is
still about 20 times the current federal passenger car limits. The new
standards will also reduce motorcycle riders' exposure to air toxics and
particulate matter. Some states have also said that new motorcycle
standards will help them achieve their air quality goals.
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What kind of emission controls may be used by
manufacturers?
We are adopting standards that manufacturers can meet on an average
basis, which may encourage manufacturers to use a broader array of
technologies across their product line. The standards will generally be
effective in two "tiers," a Tier 1 that will take effect in the 2006 model
year and a Tier 2 that will take effect in the 2010 model year. We don't
specify what emission controls manufacturers must use to comply with
the regulations, but we anticipate many manufacturers will choose to
meet them by increasing their use of secondary air injection, electronic
fuel injection, and catalytic converters. These technologies are used to
varying degrees on current highway motorcycles. An averaging standard
allows manufacturers some flexibility to choose how and on which
motorcycles to use certain technologies by balancing more-polluting
models with less-polluting models.
Will catalytic converters be required on all highway
motorcycles?
Motorcycles are unique vehicles, and the application of some passenger
car technologies will raise unique issues when applied to motorcycles.
These issues may be more critical with some makes, models, or styles
than with others. About twenty percent of the 2002 and 2003 motor-
cycles certified by manufacturers to emission standards already incorpo-
rate catalytic converters. We project that this will increase to about 50
percent when the second Tier of standards takes effect in 2010. Our
Regulatory Impact Analysis contains a detailed discussion of the tech-
nologies expected to be used to meet the proposed standards. At this
time small volume manufacturers are required only to meet the Tier 1
standard, which is achievable without the use of catalytic converters.
The Tier 1 standard for small manufacturers takes effect in the 2008
model year.
Will new highway motorcycle emission standards
affect motorcycles on the road today?
The new regulations will only affect new motorcycles produced for the
2006 and later model years. Anything manufactured prior to the 2006
model year will not be affected and will remain legal to own and operate.
EPA generally provides several years of lead time between publication
of a final rule and the effective date of new standards. Thus, new stan-
dards for motorcycles will not have any effect on motorcycles purchased
prior to the 2006 model year.
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Does the term "useful life" mean that my motorcycle
must be scrapped or turned over to the government
after certain mileage limits are reached?
EPA uses the term "useful life" to describe the period (usually years and/
or miles) over which the manufacturer must demonstrate the effective-
ness of the emission control system. For example, the "useful life" of
current passenger cars is 10 years or 100,000 miles, whichever occurs
first. It does not mean that a vehicle is no longer useful or that the vehicle
must be scrapped once these limits are reached. The term has no effect on
the owners' ability to ride or keep their motorcycles for as long as they
want.
The current useful life for motorcycles with engines over 279cc is 5 years
or 30,000 kilometers (about 18,640 miles), whichever first occurs. In the
proposed rule we requested comment on whether this is a representative
number, or whether motorcycles are driven longer and last longer relative
to twenty years ago when these numbers were established. Although we
suspect that motorcycles and their emission controls frequently last more
than 30,000 kilometers, the final rule does not make any changes to the
useful life definitions.
Are motorcycles a less-polluting alternative to cars
and SUVs?
In fact, motorcycles produce more harmful emissions per mile than a car,
or even a large SUV. The current federal motorcycle standard for hydro-
carbon emissions is about 90 times the hydrocarbon standard for today's
passenger cars. Although many of today's motorcycles will actually meet
the current California standards, the California hydrocarbon standard is
still 18 to 24 times the current federal passenger car limit, depending on
the displacement of the motorcycle engine.
Beginning in 2004, all passenger cars, light trucks, and SUVs will be
required to meet even more stringent standards. When these standards
become effective, new SUVs will be meeting hydrocarbon standards
about 95 percent cleaner than today's typical motorcycle.
The current certified emission levels of motorcycles, cars, and trucks are
available in the EPA Annual Certification Test Results Report on EPA's
Web site at: www.epa.gov/otaq/crttst.htm. These emission tests are
performed by the vehicle manufacturers. For example, the following
comparisons can be made from the data on this Web site (these vehicles
do not represent either the best or the worst emissions within their ve-
hicle type):
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Zv'JZ Model
Year Vehicle
Hydrocarbon
Emissions
(grams per mile)
Cars and Trucks
Ford
Expedition
4WD
0.15
Dodge
Durango
4WD
0.073
Subaru
Forester
AWD
0.048
Motorcycles
Yamaha
YZF-R6
4.19
Honda
VTX1800C
0.48
BMW
R1200C
0.97
Would new emission standards make it illegal to
customize my motorcycle?
Many motorcycle owners personalize their motorcycles. Indeed, this is
one of the joys of owning a motorcycle, and owners take their freedom
to customize motorcycles very seriously. We are not changing existing
provisions of section 203(a) of the Clean Air Act, as established in
1977, which states that it is illegal "for any person to remove or render
inoperative any device or element of design installed on or in a motor
vehicle or motor vehicle engine in compliance with regulations under
this title...after such sale and delivery to the ultimate purchaser...". In
other words, owners of motor vehicles cannot legally make modifica-
tions that cause the emissions to exceed the applicable emissions stan-
dards, and they cannot remove or disable emission control devices
installed by the manufacturer.
We use the term "tampering" to refer specifically to actions that are
illegal under section 203 of the Clean Air Act; the term, and the prohibi-
tion, do not apply generally to the wide range of things that a motor-
cycle enthusiast can do to legally personalize their vehicle, only to
actions that cause the emissions to exceed the standards. The new
emissions standards do not change this "tampering" prohibition. In fact,
it is not within EPAs ability or discretion to change this statutory prohi-
bition, which Congress put in place more than 20 years ago. Owners are
still free generally to customize their motorcycles in any way, as long as
they do not disable emission controls or cause the motorcycle to exceed
the emission standards.
A July 2002 EPA Press Release stated that "Motorcycle owners may
make cosmetic changes such as the color and chrome." This was inter-
preted by some owners as meaning that they could only change "color
and chrome," and the motorcycling community quickly picked up this as
a rallying cry and suggested that EPA was attempting to limit the ways
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in which a motorcycle could be customized. In fact, there are many
things beyond "color and chrome" that a motorcycle owner can legally
modify, and this list of legal modifications will not change as a result of
this final rule. We cannot be more clear about this: the laws regarding
what you can and can not do to your motorcycle will be the same under
the new emission standards as they are today.
How much will new emission controls cost?
Your cost for emission controls depends on the control technologies
used, manufacturing processes, the size of the manufacturer, and other
issues. We estimate increased costs on average of about $30 per motor-
cycle for the 2006-2009 model year standards, then an incremental $45
for the 2010 model year standards. The average cost of a 2002 motor-
cycle was approximately $10,000. As noted above, the 2010 standards
do not apply to small manufacturers. In addition, research and develop-
ment costs for small manufacturers will be partially or even mostly
borne by the engine manufacturers that supply engines to the small
motorcycle manufacturers.
How will the new emission controls affect
performance?
When advanced emission controls such as catalytic converters were
initially suggested for passenger cars there was a great deal of suspicion
regarding the impacts on performance and safety. Today cars are meet-
ing the lowest emission levels in history, yet performance is at unprec-
edented high levels. Since 1981, the average vehicle today has 93
percent more horsepower and is 29 percent faster in going from 0 to 60
miles per hour. These improvements have occurred even in the context
of the trend towards heavier sport utility vehicles.
Likewise, motorcycle manufacturers have been unanimous in telling us
that the performance of future motorcycles will be equal to or better than
current motorcycles. Advancements in engine technologies in recent
years should allow the use of new emission control technologies with
little to no impact on performance. Motorcycles meeting the new stan-
dards should perform as well or better than current motorcycles. The use
of some of these technologies, such as fuel injection, may even improve
reliability, fuel consumption, and some aspects of performance. These
advancements are already being seen today. Consider the redesigned
2003 Yamaha YZF-R6, a 600cc high performance motorcycle in the
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highly competitive middleweight super-sport/racing category. Relative to
the 2002 model, the 2003 YZF-R6 is eight pounds lighter, several horse-
power stronger, is being very well-reviewed in the press, and has about
one quarter the emissions of the 2002 federal model (0.6 g/km HC in
2003 versus 2.6 g/km HC in 2002). It's also being sold at the same price
as the 2002 model. Emission-related improvements for 2003 include the
addition of fuel injection and a catalytic converter. Even with the addi-
tion of a catalytic converter, the use of advanced materials enables the
exhaust system of the 2003 model to be more than two pounds lighter
than the 2002 model.
There are numerous other examples that demonstrate that better emis-
sions can go hand-in-hand with better performance, and as more 2004
and later motorcycles are introduced this will become even more clear. It
may be more difficult to achieve results as dramatic as in the Yamaha
cited above for some motorcycles, but we place significant weight on
what we have heard from the manufacturers, who have significant
technical expertise and are clearly highly qualified to address this issue.
How will these controls affect safety?
Some people have expressed concern about the high temperatures from
catalytic converters posing a safety hazard to motorcycle riders. It is a
fact of motorcycling that riders are in close proximity to their engine and
exhaust system, both of which can generate enough heat to cause severe
burns whether or not a catalytic converter is present. Manufacturers have
always had to consider how to best protect riders from extremes of
exhaust and engine heat, and in recent years they have had to consider
catalytic converters in the equation as well. Manufacturers clearly do not
want to build and market an unsafe product, and we believe that if they
thought catalytic converters would result in injuries to their customers
they would have objected strongly to their use. In fact, however, they
unanimously stated that motorcycles complying with the new standards
would be as safe as motorcycles are today. Although we place a great
deal of weight on what the manufacturers tell us regarding these con-
cerns, our ultimate response to these concerns is based on several other
factors as well.
Current Catalytic converters are found on all motorcycle categories - cruisers,
U.S. Use of touring, sport touring, sport and super sport, standard, and even many
Catalytic scooters - and on motorcycles from at least 16 manufacturers represented
Converters in the United States. Near one fifth of motorcycles sold in recent years in
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Worldwide
Use of
Catalytic
Converters
Analysis of
Consumer
Complaints
and
Defects
Investigations
the United States (or near 100,000 per year) have been equipped with the
emission control devices, meaning that there are likely near 200,000 or
more motorcycles with catalysts on the road today. This level of penetra-
tion results in hundreds of millions of miles of riding experience per year.
This significant real-world experience has produced no indication that
catalytic converters present a danger to motorcyclists.
Catalyst technology has been applied to more than 15 million two- and
three-wheelers worldwide, and some nations are far more dependent on
both motorcycles and catalytic converters than the United States. In some
of these nations, it is not unusual to see two-up riding with riders in all
manners of clothing, yet these nations have not reported any problems
with the use of catalytic converters.
We analyzed 2000 consumer complaints regarding motorcycles filed with
the National Highway Traffic Safety Administration's Office of Defects
Investigation. Of these 2000, 28 were specific to exhaust system compo-
nents, and seven of these were specifically regarding heat from the
exhaust pipe. We were able to determine that two of the seven motor-
cycles did not have catalytic converters, another two clearly did have
catalysts, and the remaining three could not be determined. Two com-
plaints did involve some personal injury. In one case the injury resulted
from a motorcycle without a catalyst. In the other case we could not
determine whether a catalytic converter was on the motorcycle, but the
consumer's description of the problem indicated that it was occurring
along a section of the exhaust pipe far from where a converter would be,
if present.
Another two complaints were regarding motorcycles with catalysts,
although these complaints noted damage to clothing and not injury to the
rider. In summary, we do not believe that the data available from NHTSA
demonstrates that a catalytic converter constitutes a significant safety
risk. These complaints represent a minority of the near six million motor-
cycles on the road in the United States today, which would not be the
case if there was a generalized problem with excessive heat from cata-
lyst-equipped motorcycles.
How will the rule affect the motorcycle aftermarket
industry?
New emission standards, which are directed at manufacturers of new
motorcycles, will not cause the demise of the motorcycle aftermarket
industry. Automobiles have now had catalytic converters and other
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emission controls for decades, yet a robust automobile aftermarket
continues to thrive. The aftermarket parts industry is a substantial part of
the motorcycle industry and can readily and successfully adapt to any
changes that might result from this rule. The motorcycle aftermarket has
had to abide by the tampering prohibition since the standards were first
implemented, and there is no evidence that this has had any effect on the
viability or growth of the aftermarket.
The motorcycle aftermarket successfully adapted to the disappearance of
2-stroke engines and the appearance of 4-stroke engines in street bikes
which occurred in the 1980s. We have neither found nor been provided
with any evidence that the motorcycle aftermarket will be affected to any
significant degree by new emission standards. In addition, we believe
that the vast majority of aftermarket items have nothing to do with
emissions, and will thus be unaffected. There is no reason to believe that
parts manufacturers and designers will not design and offer compliant
parts where there is a demand for such parts. Finally, there are currently
tampering prohibitions regarding noise control equipment on motor-
cycles, and even though it is very common to install aftermarket exhaust
pipes on street bikes, the market for aftermarket exhaust systems contin-
ues to thrive and does not appear to be harmed or otherwise restricted by
these existing prohibitions.
How closely do the new rules follow the California
rules?
The new rules directly parallel the California model with several excep-
tions. First, we proposed regulations to control permeation emissions - a
type of evaporative emission in which fuel is lost through permeation of
plastic fuel tanks and fuel hoses. California currently has more stringent
evaporative emission control regulations, which in some cases require
the use of a charcoal canister on the motorcycle to receive fuel vapors.
We expect California to maintain these provisions. Second, we proposed
standards for motorcycles with engines less than 50cc displacement. Like
the current federal regulations, California does not regulate these two-
wheelers, though we expect they will ultimately choose to harmonize
with federal regulations for these vehicles. Third, we proposed to alter
the timing, making federal standards effective after manufacturers have
had two years of experience meeting new emission limits in California.
There are other more subtle differences as well. For example, under the
emissions averaging program, we allow motorcycles to emit up to 5.0
grams/kilometer hydrocarbons + nitrogen oxides (HC+NOx) during the
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period of 2006-2009, after which the "cap" becomes harmonized with
California's 2.5 gram/kilometer upper limit. California does not provide
such an "interim" cap during the comparable time period; instead their
upper limit goes right to 2.5 grams/kilometer HC+NOx. We are also
optionally allowing averaging of emissions between and within each of
the three motorcycle classes, whereas California only allows averaging
in the context of the Class III standards (greater than 279cc).
What are the differences between EPA's proposed
rule and the final rule?
There are very few differences between the proposed and final rules. The
final rule has some provisions not seen in the proposal to address kit and
custom motorcycles. For example, we are expanding the currently
available display exemption to make it easier for small manufacturers to
build and sell custom motorcycles without coming into conflict with the
regulatory requirements. Today, motorcycles cannot be sold without a
certificate of conformity with emission standards from the EPA. The new
provisions remove this burden for small numbers of these high-custom
motorcycles which are built for show and display purposes and are
unlikely to spend much time on the road.
What are the most significant differences between
the new rule and the pre-existing rules?
We consider several aspects of the new regulations to be a significant
improvement relative to the current rules. First, we are reducing the
emission standards to levels that are consistent with the capabilities of
technology today. No one can reasonably argue with the fact that the
existing standards—set by a final rule that was signed by the EPA Ad-
ministrator 27 years ago—make sense in the context of the technological
advancements since that last action. Second, we are incorporating NOx
in the new standards. NOx is an ozone precursor, and as such has been
regulated in automobiles for decades. Third, the new program makes the
transition from a program where every motorcycle had to meet a speci-
fied emission limit to an averaging program, in which manufacturers
have the flexibility to balance more polluting motorcycles with less
polluting ones as long as their overall fleet meets a given average emis-
sions limit.
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Where can I get more information?
Keep an eye on the EPA highway motorcycle Web page (www.epa.gov/
otaq/roadbike.htm) for more information and any developments. For
further information, please contact the Assessment and Standards Divi-
sion at:
U.S. Environmental Protection Agency
Office of Transportation and Air Quality
2000 Traverwood Drive
Ann Arbor, MI 48105
Voicemail: (734)214-4636
E-mail: ASDInfo@epa.gov
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