State
of
California
AIR
RESOURCES
BOARD
STAFF
REPORT:
INITIAL
STATEMENT
OF
REASONS
PROPOSED
AMENDMENTS
TO
THE
CALIFORNIA
ON­
ROAD
MOTORCYCLE
REGULATION
Date
of
Release:
October
23,
1998
Scheduled
for
Consideration:
December
10,
1998
Mobile
Source
Control
Division
9528
Telstar
Avenue
El
Monte,
California
91731
This
report
has
been
prepared
by
the
staff
of
the
California
Air
Resources
Board.
Publication
does
not
signify
that
the
contents
reflect
the
views
and
policies
of
the
Air
Resources
Board,
nor
does
mention
of
trade
names
or
commercial
products
constitute
endorsement
or
recommendation
for
use.
ACKNOWLEDGMENTS
The
ARB
staff
extend
their
appreciation
to
the
staffs
of
BMW,
Harley­
Davidson,
Honda,
Kawasaki,
Suzuki,
Triumph,
and
Yamaha,
for
providing
technical
data
and
feedback
on
our
proposals
under
an
ambitious
rulemaking
schedule.
We
would
also
like
to
thank
the
members
of
the
Manufacturers
of
Emission
Controls
Association,
who
provided
valuable
data
on
the
current
and
emerging
state
of
emissions
control
technologies.
Moreover,
we
thank
the
Motorcycle
Industry
Council,
the
California
Motorcycle
Dealers
Association,
and
the
American
Motorcyclist
Association,
for
facilitating
discussions
with
their
members.
We
are
particularly
grateful
to
the
Motorcycle
Industry
Council,
for
the
feedback
the
Council
provided
from
small­
volume­
manufacturer
members
and
for
the
extensive
statistical
data
and
analyses
provided,
which
helped
refine
the
emissions
inventory.
i
TABLE
OF
CONTENTS
Page
EXECUTIVE
SUMMARY
1
1.
INTRODUCTION
I­
1
II.
BACKGROUND
II­
1
A.
Vehicle
Classes
II­
1
2.
History
of
the
Existing
Regulation
II­
1
A.
Current
Emission
Limits
II­
2
B.
On­
Road
Motorcycle
Emissions
II­
2
III.
RULE
DEVELOPMENT
PROCESS
AND
PUBLIC
OUTREACH
EFFORTS
III­
1
A.
Individual
Meetings
III­
1
B.
Meetings
with
Industry
Trade
and
Motorcycle
Riders'
Groups
III­
3
C.
Public
Workshops
III­
3
IV.
SUMMARY
OF
PROPOSED
AMENDMENTS
IV­
1
A.
Tier­
1/
Tier­
2
Exhaust
Emission
Standards
IV­
1
B.
Corporate
Averaging
IV­
3
C.
Small
Volume
Manufacturer
Provision
IV­
4
V.
TECHNOLOGICAL
FEASIBILITY
OF
PROPOSED
STANDARDS
V­
1
A.
Analysis
Methodology
V­
1
3.
Meeting
the
Tier­
1
Standard:
Engine
Modifications
and
V­
2
Other
Non­
Catalyst
Technologies
to
Reduce
Engine­
Out
Emissions
4.
Meeting
the
Tier­
2
Standard:
Using
Engine
Systems
and
V­
5
Catalytic
Converters
5.
Safety
V­
10
VI.
COMMERCIAL
FEASIBILITY
AND
ECONOMIC
IMPACTS
OF
PROPOSED
STANDARDS
VI­
1
1.
Summary
of
Economic
Impacts
VI­
1
2.
Legal
Requirements
VI­
1
3.
Businesses
Affected
VI­
2
4.
Potential
Impacts
on
California
Businesses
VI­
3
5.
Potential
Impacts
on
Business
Competitiveness
VI­
5
6.
Potential
Impacts
on
Employment
VI­
5
7.
Potential
Impact
on
Business
Creation,
Elimination,
or
Expansion
VI­
5
8.
Potential
Impacts
on
Consumers
VI­
6
9.
Economic
Impacts
on
California
State
or
Local
Agencies
VI­
6
10.
Cost­
Effectiveness
of
the
Proposed
Standards
VI­
7
ii
TABLE
OF
CONTENTS
(
cont.)

Page
VII.
ENVIRONMENTAL
IMPACTS
OF
PROPOSED
AMENDMENTS
VII­
1
1.
Projected
Benefits
VII­
1
2.
Potential
Mitigating
Factors
VII­
2
VIII.
ANALYSIS
OF
REGULATORY
ALTERNATIVES
VIII­
1
1.
Adopt
No
New
Standards
VIII­
1
2.
Adopt
Less
Stringent
Standards
VIII­
2
3.
Adopt
More
Stringent
Standards
VIII­
2
4.
Conclusions
VIII­
3
IX.
OUTSTANDING
ISSUES
IX­
1
1.
Magnitude
of
Reductions
and
Appropriateness
of
Obtaining
the
Reductions
from
On­
road
Motorcycles
IX­
1
2.
Certainty
in
Development
of
Tier­
2
Compliant
Technology
IX­
2
3.
Potential
Impacts
on
Program
Effectiveness
from
Equipment
Tampering
IX­
3
X.
FUTURE
ACTIVITIES
X­
1
A.
Further
Refinement
of
the
Emissions
Inventory
X­
1
4.
2006
Progress
Review
X­
1
REFERENCES
APPENDIX
A:
Proposed
Amendments
to
the
On­
Road
Motorcycle
Regulation
APPENDIX
B:
Requests
for
Consultation,
Requests
for
Information
APPENDIX
C:
Meeting
&
Workshop
Notices,
Attendees'
Lists
iii
LIST
OF
TABLES
Title
Page
Table
II­
1.
Motorcycle
Classes
by
Engine
Displacement
II­
1
Table
II­
2.
Official
Statewide
Inventory
&
Updated
Staff
Emission
Estimates
for
On­
road
Motorcycles
II­
2
Table
III­
1.
Individual
Meetings
with
Medium/
High­
Volume
III­
1
Motorcycle
Manufacturers
Table
III­
2.
Small­
Volume
Manufacturers
&
Parts
Suppliers
III­
2
Contacted
by
ARB
Staff
Table
IV­
1.
Multipliers
to
Encourage
Early
Compliance
with
the
Proposed
Tier­
2
Standard
and
Beyond
IV­
4
Table
V­
1.
Breakdown
of
HC
Certification
Levels
by
Technology
and
Market
Share
V­
5
Table
VI­
1.
Major
Manufacturers
in
the
Motorcycle
Industry
VI­
2
Table
VI­
2.
Component
Costs
to
Comply
with
Staff
Proposal
(
Relative
to
1998
Models)
VI­
10
Table
VI­
3.
Estimated
Advanced
Vehicle
Technology
Research
Costs
VI­
12
Table
VI­
4.
Estimated
Vehicle
Development
Costs
VI­
13
Table
VI­
5.
Estimated
Capital
Recovery
Costs
VI­
13
Table
VI­
6.
Estimated
Dealer
Costs
VI­
14
Table
VI­
7.
Incremental
Cost
of
Staff
Proposal
Over
Cost
of
Current
Standard
VI­
15
Table
VII­
1.
2010
On­
Road
Motorcycle
Statewide
and
SoCAB
Emission
Inventories
VII­
2
Table
VII­
2.
Projected
Tier­
1
and
Tier­
2
HC+
NOx
Emission
Benefits
VII­
2
1
EXECUTIVE
SUMMARY
In
1994,
the
Air
Resources
Board
(
ARB)
approved
a
revision
to
the
State
Implementation
Plan
that
contains
clean
air
strategies
needed
to
meet
the
health­
based,
1­
hour
federal
ozone
air
quality
standard
("
ozone
SIP").
The
ozone
SIP
includes
measures
to
reduce
emissions
from
mobile
sources
under
State
control
(
including
cars,
heavy­
duty
trucks,
off­
road
equipment),
as
well
as
federal
assignments
to
control
emissions
from
sources
under
exclusive
or
practical
federal
control
(
such
as
airplanes,
marine
vessels,
and
locomotives).
The
ozone
SIP
also
relies
upon
the
development
of
additional
technology
measures
(
the
mobile
source
"
black
box")
to
provide
additional
emission
reductions
needed
for
attainment
in
the
South
Coast
Air
Basin.

Although
on­
road
motorcycles
have
been
regulated
since
1978,
the
1994
ozone
SIP
does
not
include
specific
new
control
measures
for
on­
road
motorcycles.
The
staff's
proposal
to
further
reduce
emissions
from
on­
road
motorcycles
is
a
new
measure
reflecting
reasonably
available
and
emerging
technologies.
The
staff's
proposal
offers
additional,
cost­
effective
emission
reductions
which
will
further
progress
toward
meeting
the
federal
ambient
standard
for
ozone.
The
additional
emission
reductions
will
also
contribute
to
continued
progress
toward
meeting
State
and
new
federal
air
quality
standards
for
ozone
and
particulate
matter.

On­
road
motorcycles
represent
a
source
of
potential
emission
reductions
because
motorcycles
emit
from
10
to
15
times
more
pollutants
per
mile
traveled
than
current
model
cars.
This
is
because
the
existing
on­
road
motorcycle
regulation
reflects
emission
controls
that
are
about
15
or
more
years
old.
Therefore,
we
approached
this
rulemaking
with
the
goal
of
developing
standards
that
reflect
up­
to­
date,
reasonably
available,
and
demonstrated
control
technologies,
as
well
as
emerging
technologies.

The
staff's
proposal
affects
all
new,
Class
III
motorcycles
produced
after
the
specified
compliance
dates.
In
this
rulemaking,
Class
III
includes
those
on­
road
motorcycles
which
have
an
engine
displacement
of
280
cubic
centimeters
or
greater.
The
proposal
includes
a
two­
tier
set
of
standards
which
progressively
lower
exhaust
emissions
of
hydrocarbons
(
HC)
and
oxides
of
nitrogen
(
NOx).
We
are
not
proposing
to
regulate
motorcycle
carbon
monoxide
(
CO)
or
evaporative
emissions
beyond
the
existing
requirements.

In
the
short
term,
the
proposed
Tier­
1
HC+
NOx
standard
of
1.4
g/
km
HC+
NOx
reflects
the
goal
of
achieving
emission
reductions
that
could
be
met
with
reasonably
available
control
technologies,
primarily
involving
engine
modifications
rather
than
catalytic
converters.
We
are
proposing
that
the
Tier­
1
standard
be
effective
for
the
2004
model
year.
A
number
of
existing
engine
families
already
comply
with
this
standard
or
would
need
relatively
simple
modifications
to
comply.
In
other
cases,
the
manufacturers
will
need
to
use
control
technologies
that
are
available
but
are
not
yet
used
on
their
particular
vehicles
(
e.
g.,
electronic
fuel
injection
to
replace
carburetors,
changes
to
cam
lobes/
timing,
etc.).
For
the
most
part,
manufacturers
will
not
need
to
use
advanced
technologies
such
as
close­
coupled,
closed­
loop
three
way
catalysts.
Because
advanced
technologies
are
generally
not
needed
to
meet
the
Tier­
1
standard,
manufacturers
will
2
be
able
to
gradually
replace
at
lower
cost
their
older,
higher­
polluting
engine
families
with
those
modified
to
emit
less.

In
the
long
term,
we
are
proposing
a
Tier­
2
HC+
NOx
standard
of
0.8
g/
km
that
will
ensure
manufacturers
will
continue
to
advance
the
status
of
control
technologies.
We
are
proposing
the
Tier­
2
standard
to
be
effective
by
the
2008
model
year.
This
standard
will
present
some
challenges
for
manufacturers;
however,
several
manufacturers
are
already
using
some
of
the
technologies
that
will
be
needed
to
meet
this
standard.
One
manufacturer
already
uses
closedloop
three­
way
catalysts
on
several
of
its
product
lines.
Other
manufacturers
have
products
in
the
market
with
emission
levels
close
to
the
Tier­
2
standards
using
two­
way
catalysts,
fuel
injection,
secondary
pulse­
air
injection,
and
other
engine
modifications.
We
expect
manufacturers
to
optimize
these
existing
advanced
technologies
and
others
to
meet
the
Tier­
2
standard
in
the
nine
years
that
remain
before
the
standard
takes
effect.

Although
the
Tier­
1
standard
will
achieve
some
reductions,
the
majority
of
emission
reductions
to
be
gained
by
this
rulemaking
will
come
from
the
implementation
of
the
Tier­
2
standard.
We
estimate
the
full
implementation
of
these
two
standards
will
reduce
HC+
NOx
emissions
by
approximately
1.3
TPD
by
2010,
and
2.9
TPD
by
2020.
We
based
our
estimates
of
the
proposal's
benefits
on
an
updated
emission
inventory
which
includes
various
refinements
provided
by
the
Motorcycle
Industry
Council
(
MIC)
and
data
from
ARB's
in­
use
compliance
program,
certification
database,
and
the
current
surveillance
project.
Because
the
Tier­
2
standard
achieves
most
of
the
expected
benefits
from
this
rulemaking,
that
standard
plays
a
critical
role
in
the
overall
effectiveness
of
the
proposed
amended
motorcycle
regulation.

While
they
are
challenging,
the
proposed
standards
are
not
only
technologically
feasible,
they
are
also
commercially
feasible
and
cost­
effective.
For
the
Tier­
1
standard,
we
estimate
a
sales­
weighted
average
production
cost
increase
of
up
to
$
44
per
motorcycle
relative
to
a
new
1998
motorcycle.
This
reflects
research
and
development,
capital
recovery,
dealership
costs,
and
the
use
of
engine
modifications
such
as
replacing
carburetors
with
fuel
injection.
With
the
increased
use
of
catalytic
converters,
the
Tier­
2
standard
should
result
in
a
sales­
weighted
average
production
cost
increase
of
about
$
97
per
motorcycle
relative
to
a
new
1998
motorcycle.
Thus,
the
overall
sales­
weighted
average
production
cost
increase
we
estimate
for
this
rulemaking
is
less
than
$
100
per
motorcycle
upon
full
implementation
of
the
standards.
However,
some
of
the
cost
increases
consumers
may
experience
will
likely
be
offset
to
a
degree
by
savings
resulting
from
better
fuel
management
and
less
required
maintenance.
Based
on
the
expected
emission
reductions,
this
cost
increase
translates
to
an
overall
cost­
effectiveness
ranging
from
about
$
3.00
to
$
5.60
per
pound
of
HC+
NOx
reduced,
which
is
within
the
range
of
other
emission
control
measure
costs.

We
expect
the
proposed
two­
tier
standards
will
have
economic
impacts
primarily
on
six
major
manufacturers
(
BMW,
Harley­
Davidson,
Honda,
Kawasaki,
Suzuki,
and
Yamaha),
all
headquartered
outside
of
California.
Because
of
the
relatively
long
timeframe
manufacturers
will
have
for
meeting
the
standards,
we
expect
little
or
no
economic
impacts
to
distributors
or
3
retailers;
the
2004
and
2008
timeframes
should
provide
adequate
time
for
these
businesses
to
adapt
their
marketing
plans
and
adjust
their
inventories
accordingly.
We
expect
some
economic
benefits
for
manufacturers
of
components
that
help
meet
the
standards,
as
they
increase
both
their
production
of
such
components
and
their
workforce
to
meet
the
demand.
The
standards
should
also
benefit
companies
that
test
engines
or
provide
consultation
to
those
manufacturers
that
outsource
those
types
of
activities.

While
we
expect
little
or
no
impacts
to
low­
volume
manufacturers
from
the
Tier­
1
standard,
we
believe
the
Tier­
2
standard
would
significantly
impact
the
small­
volume
manufacturers.
For
the
purposes
of
this
rulemaking,
we
are
defining
small­
volume
manufacturers
as
those
which
sell
no
more
than
1,000
Class
I,
II,
and
III
motorcycles
(
combined)
in
California
for
a
model
year.
These
small­
volume
manufacturers
collectively
represent
less
than
5%
of
the
total
market
for
new
motorcycles
in
California.
As
such,
they
generally
have
neither
the
financial
nor
technical
resources
to
develop
engine
families
that
can
meet
the
Tier­
2
standard.
On
the
other
hand,
even
the
small­
volume
manufacturers
should
be
able
to
apply
existing,
reasonably
available
and
demonstrated
technology
to
meet
the
Tier­
1
standard
by
2008.
Therefore,
the
staff
proposes
to
apply
the
2004
Tier­
1
standard
to
all
manufacturers
(
with
four
additional
years
to
2008
for
the
small­
volume
manufacturers)
and
to
exempt
small­
volume
manufacturers
from
the
Tier­
2
standard.

To
provide
incentives
for
early
compliance
with
the
Tier­
2
standard,
staff
is
proposing
a
set
of
multiplier
factors
that
provide
extra
credit
to
manufacturers
that
introduce
motorcycles
which
meet
the
Tier­
2
standard
earlier
than
the
2008
model
year.
Based
on
our
belief
that
at
least
some
of
the
manufacturers
can
reach
levels
significantly
lower
than
the
Tier­
2
standard,
we
are
also
proposing
a
set
of
multipliers
for
early
introduction
of
motorcycles
certified
at
0.4
g/
km
HC+
NOx
or
less.
Use
of
these
credits
will
make
it
easier
for
a
manufacturer
to
comply
with
the
corporate
emissions
average
standard
in
2008.

Based
on
the
commercial
and
technological
feasibility
of
the
standards,
as
well
as
the
projected
emission
benefits,
we
recommend
that
the
Board
adopt
the
staff
proposal.
­
1
I.

INTRODUCTION
Significant
strides
have
been
made
toward
improving
California's
air
quality.
Nonetheless,
regions
throughout
California
continue
to
exceed
health­
based
state
and
federal
air
quality
standards.
Areas
exceeding
the
State
and
federal
1­
hour
ozone
standard
include
the
South
Coast
Air
Basin,
San
Diego
County,
the
San
Joaquin
Valley,
the
Southeast
Desert,
the
Broader
Sacramento
area
and
Ventura
County.
As
the
new
federal
eight­
hour
ozone
standard
is
implemented,
more
areas
of
the
State
are
likely
to
be
designated
as
nonattainment
for
groundlevel
ozone.

Created
by
the
photochemical
reaction
of
reactive
organic
gases
(
ROG)
and
oxides
of
nitrogen
(
NOx),
ozone
causes
harmful
respiratory
effects
including
lung
damage,
chest
pain,
coughing,
and
shortness
of
breath.
Ozone
is
particularly
harmful
to
children,
the
elderly,
athletes,
and
persons
with
compromised
respiratory
systems.
Other
environmental
effects
from
ozone
include
substantial
damage
to
crops,
buildings,
and
other
structures.

In
addition,
ozone
precursors
contribute
to
ambient
levels
of
respirable
particulate
matter
(
PM10).
NOx
reacts
in
the
atmosphere
to
form
part
of
the
nitrate
fraction
in
PM10.
ROG
emissions
resulting
from
incomplete
combustion
also
contribute
to
PM10
formation
through
condensation
or
other
atmospheric
processes.
Thus,
reductions
in
ozone
precursors,
particularly
NOx,
will
be
crucial
to
meeting
existing
state
and
federal
PM10
standards,
as
well
as
the
new
federal
standards
for
fine
particulate
matter
(
PM2.5).

California's
plan
for
achieving
the
federal
1­
hour
ozone
standard
is
contained
in
the
California
State
Implementation
Plan
for
Ozone
(
ozone
SIP)
that
was
approved
by
the
Board
in
1994.
A
significant
part
of
the
ozone
SIP
pertains
to
the
control
of
mobile
sources,
which
are
estimated
to
account
for
approximately
70
percent
of
ozone
precursor
emissions
statewide.
The
ozone
SIP
calls
for
new
measures
to
cut
ozone
precursor
emissions
from
mobile
sources
to
half
of
what
the
emissions
would
be
under
existing
regulations.

Beyond
the
specific
measures
identified
when
it
was
adopted,
the
ozone
SIP
for
the
South
Coast
Air
Basin
(
an
extreme
ozone­
nonattainment
area)
relies
on
the
development
of
additional
technology
measures
as
allowed
in
Section
182(
e)(
5)
of
the
Clean
Air
Act
Amendments
of
1990.
Under
the
so­
called
"
black
box"
provisions
of
Section
182(
e)(
5),
the
ozone
SIP
calls
for
additional
motor
source
emission
reductions
in
the
South
Coast
Air
Basin
of
approximately
75
tons
per
day
(
tpd)
ROG
plus
NOx.
These
reduction
commitments,
while
not
assigned
to
a
specific
mobile
source
sector,
must
nevertheless
be
met
for
the
South
Coast
Air
Basin
to
attain
the
federal
ozone
air
quality
standard
by
the
required
2010
deadline.
­
2
ARB
staff
have
identified
on­
road
motorcycles
as
a
technologically­
feasible,
cost­
effective
source
of
additional
emission
reductions.
The
additional
emission
reductions
would
cover
shortfalls
in
defined
ARB
measures
and
make
progress
on
the
black
box.
Although
the
South
Coast
Air
Basin
is
the
only
area
of
the
State
with
a
black
box,
the
emission
reductions
are
needed
statewide.
The
proposed
on­
road
motorcycle
regulation
will
help
achieve
and
maintain
the
federal
1­
hour
ozone
standard
in
regions
such
as
the
San
Joaquin
Valley
and
the
Sacramento
area;
the
federal
8­
hour
ozone
and
particulate
matter
standards
in
a
number
of
areas;
and
the
State
ozone
and
particulate
matter
standards
throughout
California.

This
Staff
Report
is
organized
to
demonstrate
the
commercial
and
technological
feasibility
of
the
staff's
proposal,
as
well
as
its
cost­
effectiveness
and
benefits.
Chapter
II
provides
background
information
as
well
as
a
discussion
of
the
current
on­
road
motorcycle
regulation.
Chapter
III
describes
the
rulemaking
process
staff
used
to
develop
the
proposal,
including
the
staff's
public
outreach
efforts.
Chapter
IV
provides
a
plain
English
discussion
of
the
proposed
amendments
to
the
regulation,
as
shown
in
Appendix
A.
Chapter
V
discusses
the
technological
feasibility
of
the
proposed
standards,
while
Chapters
VI
and
VII
demonstrate
the
commercial
feasibility
and
economic
and
environmental
impacts
we
expect
from
the
proposal.
Chapter
VIII
compares
regulatory
alternatives
we
evaluated
prior
to
presenting
our
proposal
to
the
Board.
Chapter
IX
discusses
the
main
outstanding
issues
raised
during
the
rulemaking.
Finally,
Chapter
X
outlines
some
of
the
future
activities
ARB
staff
plan
to
undertake
in
the
future,
either
as
a
formal
part
of
this
proposal
or
as
a
follow­
up
to
some
of
the
concerns
raised
by
affected
stakeholders.
­
1
II.

BACKGROUND
A.
Vehicle
Classes
Motorcycles
come
in
various
configurations
using
two­
wheeled,
three­
wheeled,
and
even
four­
wheeled
designs.
However,
for
the
purposes
of
this
report,
motorcycles
for
the
most
part
are
two­
wheeled,
self­
powered
vehicles.
The
key
parameter
that
distinguishes
a
motorcycle
from
a
moped
is
the
engine
displacement:
a
moped
has
an
engine
displacement
of
less
than
50
cubic
centimeters
(
cc),
while
motorcycle
engines
displace
50
cc
or
greater.
In
California,
engine
displacement
is
used
to
further
categorize
motorcycles,
as
shown
in
Table
II­
1.

Table
II­
1.
Motorcycle
Classes
by
Engine
Displacement
Motorcycle
Class
Engine
Displacement,
(
cubic
centimeters)

Class
I
50
to
169
cc
Class
II
170
to
279
cc
Class
III
280
cc
and
greater
The
current
market
in
California
strongly
favors
the
larger
displacement
Class
III
motorcycles;
over
90%
of
all
new
motorcycles
sold
in
California
are
in
this
category.
These
include
street­
legal
versions
of
racing
bikes
("
sport"
bikes),
heavily
outfitted
highway
"
cruisers,"
and
the
retro/
neo­
classically
styled
"
custom"
bikes.
Most,
if
not
all,
of
the
projected
growth
in
new
motorcycle
sales
are
expected
in
the
Class
III
sector.
Because
of
this,
we
focused
our
rulemaking
efforts
on
this
particular
subcategory.

2.
History
of
the
Existing
Regulation
The
ARB
adopted
the
first
on­
road
motorcycle
regulation
in
1975.
See
Title
13,
California
Code
of
Regulations,
Section
1958.
The
regulation
established
exhaust
and
evaporative
emission
standards
for
HC
and
CO
beginning
with
the
1978
model
year.
Depending
on
the
motorcycle
engine
size,
the
original
HC
exhaust
standards
ranged
from
5.0
grams
per
kilometer
(
g/
km)
to
14.0
g/
km.

In
1984,
the
ARB
amended
the
model
year
1985
HC
exhaust
standard
to
give
manufacturers
more
flexibility.
The
new
standards
for
model
year
1985
and
beyond
focused
on
the
Class
III
category
(
280
cc
and
above):
280
to
699
cc
engines
were
limited
to
1.0
g/
km
for
model
years,
while
700
cc
and
larger
motorcycles
were
limited
to
1.4
g/
km
HC.
The
ARB
­
2
established
provisions
to
allow
manufacturers
to
meet
these
limits
on
a
"
corporate
average"
basis,
with
no
individual
engine
family
allowed
to
exceed
2.5
g/
km
HC.
Additionally,
in
1984
the
Board
directed
the
ARB
staff
to
revisit
the
regulation
when
catalytic
and
other
emissions
control
technologies
had
matured
to
the
point
that
it
would
be
feasible
to
apply
these
technologies
to
on­
road
motorcycles.
(
ARB,
1984)
Significant
strides
in
controlling
emissions
from
internal
combustion
engines
have
taken
place
since
then,
with
developments
in
the
automotive
sector
gradually
being
applied
to
motorcycles.
This
is
particularly
true
in
Europe
and
Asia,
where
engine
modifications,
fuel
injection,
secondary
pulseair
injection,
and
catalytic
converters
are
used
in
significant
numbers
of
on­
road
motorcycles.
On
the
other
hand,
the
ARB
emission
standards
for
motorcycles
have
not
kept
pace
with
the
rate
at
which
emission
control
technologies
have
developed.
Therefore,
ARB
staff
believe
it
is
appropriate
to
amend
the
existing
standards
to
the
proposed
levels,
which
reflect
the
use
of
reasonably
available
technologies.

3.
Current
Emission
Limits
As
noted
previously,
Class
III
motorcycles
are
currently
subject
to
one
of
two
HC­
only
limits,
depending
on
engine
size:
1.0
g/
km
for
engines
from
280
to
699
cc,
and
1.4
g/
km
for
700
cc
or
greater
engines.
No
more
than
2.0
grams
per
test
of
HC
evaporative
emissions
are
allowed
under
the
test
procedure
specified
in
the
regulation.
The
regulation
does
not
currently
limit
emissions
of
oxides
of
nitrogen
(
NOx).
It
should
also
be
noted
that
on­
road
motorcycles
are
currently
exempted
from
the
inspection
and
maintenance
program
(
i.
e.,
the
"
Smog
Check"
program)
which
automobiles
and
other
vehicles
undergo
on
a
regular
basis.
See
13
CCR
1958.

4.
On­
Road
Motorcycle
Emissions
The
current
official
emissions
inventory
for
on­
road
motorcycles
is
based
on
outdated
U.
S.
EPA
data
and
is
therefore
subject
to
uncertainty.
There
is
some
evidence
which
indicates
the
official
inventory
may
overestimate
statewide
emissions
from
on­
road
motorcycles.
ARB
staff
have
therefore
developed
an
updated
and
improved
emissions
inventory
for
these
vehicles.

The
ARB
staff­
updated
inventory
and
the
current
official
inventory
(
ARB,
1995)
are
shown
in
Table
II­
2
for
comparison.
Even
with
the
updated
information,
Table
II­
2
clearly
shows
that
on­
road
motorcycles
represent
a
significant
source
of
ozone
precursor
emissions.

Table
II­
2.
Official
Statewide
Inventory
&
Updated
Staff
Emission
Estimates
for
On­
Road
Motorcycles
Baseline
Inventory
for
2010,
TPD
Ozone
Precursor
Official
Inventory
Current
ARB
Staff
Estimate
HC
9.6
4.6
NOx
4.9
3.1
HC+
NOx
14.5
7.7
­
3
Note:
Official
inventory
based
on
EMFAC7G.
Current
ARB
staff
estimate
based
on
7G
revised
with
usage
statistics
from
MIC;
recent
DMV
vehicle
motorcycle
registrations;
updated
parameters
from
7X
(
internally­
available
draft
EMFAC);
and
data
from
ARB's
in­
use
compliance
program,
certification
database,
and
current
surveillance
project.
­
1
III.

RULE
DEVELOPMENT
PROCESS
AND
PUBLIC
OUTREACH
EFFORTS
1.
Individual
Meetings
Because
only
six
manufacturers
represent
over
95%
of
all
new
motorcycle
sales
in
California,
we
began
this
rulemaking
process
with
the
goal
of
meeting
individually
with
those
companies:
BMW,
Harley­
Davidson,
Honda,
Kawasaki,
Suzuki,
and
Yamaha.
We
took
this
approach
because:
(
1)
given
the
diversity
of
company
locations,
it
was
more
efficient
to
meet
individually
than
meeting
as
a
group,
(
2)
as
large
companies
and
market
leaders,
these
manufacturers
were
presumed
to
have
the
financial
and
technical
resources
to
investigate
the
feasibility
of
the
staff's
proposals,
and
(
3)
individual
meetings
are
more
conducive
to
a
frank
and
open
discussion
of
the
proposals,
proprietary
information,
and
associated
issues.
On
numerous
occasions,
we
asked
to
meet
with
manufacturers
and
other
stakeholders
in
writing
and
by
telephone
(
see
Appendix
B);
the
dates
we
met
with
each
manufacturer
are
shown
in
Table
III­
1.
After
every
meeting,
we
reiterated
our
openness
to
discussing
any
issues
the
manufacturers
raised
and
to
meet
again
as
often
as
they
desired.

Table
III­
1.
Individual
Meetings
with
Medium/
High­
Volume
Motorcycle
Manufacturers
Manufacturer
Meeting
Dates
in
1998
BMW
April
27,
May
27
Harley­
Davidson
April
29,
July
17,
Sept.
1
Honda
March
24,
May
22,
July
21
Kawasaki
March
13
Suzuki
March
2
Yamaha
March
3,
June
18
In
addition
to
meeting
with
the
large
manufacturers,
we
took
reasonable
actions
to
meet
with
and
present
our
proposals
to
smaller
companies.
First,
we
phoned
and
mailed
written
requests
for
meetings
to
several
small­
volume
manufacturers,
with
a
particular
emphasis
on
companies
located
in
California
(
Ryden,
1998);
these
companies
are
shown
in
Table
III­
2.
Only
one
small­
volume
manufacturer,
Triumph
(
located
in
England),
agreed
to
meet
individually
with
staff.
The
three
meetings
we
had
with
Triumph
were
very
informative
because
they
provided
insight
into
issues
and
concerns
particular
to
the
small­
volume
manufacturers.
­
2
Table
III­
2.
Small­
Volume
Manufacturers
&
Parts
Suppliers
Contacted
by
ARB
Staff
Aprilia
Motorcycles
Goodman
Motorcycles
Corp.
MuZ
of
North
America
American
Motorcycle
Manufacturing,
Inc.
Impuls
International,
Inc.
Panzer
Motorcycle
Works
ATK
America
Indian
Motorcycle
Manufacturing,
Inc.
Polaris
Industries,
Inc.

California
Motorcycle
Company
KTM
Sportmotorcycle
USA,
Inc.
Whizzer
Motorbike
Ducati
North
America,
Inc.
Moto
Point
Due
to
the
apparent
lack
of
interest
in
meeting
individually
with
us,
we
arranged
to
meet
collectively
with
smaller
manufacturers
on
May
5,
1998,
with
the
help
of
the
Motorcycle
Industry
Council
(
MIC)
and
K.
H.
Wolf
Consulting
(
an
established
consultant
to
small­
volume
motorcycle
manufacturers).
Approximately
35
stakeholders,
most
of
whom
are
located
in
Southern
California,
were
scheduled
to
attend
the
meeting
in
El
Monte,
California.
However,
only
11
industry
representatives
attended
(
see
Appendix
C).
Despite
the
low
attendance,
we
reiterated
to
the
MIC
and
K.
H.
Wolf
Consulting
our
willingness
to
meet
with
the
small­
volume
manufacturers
whenever
they
desired.

At
the
individual
and
group
meetings,
we
provided
the
attendees
with
the
basis
for
our
proposal.
We
discussed
our
initial
proposed
standard
of
0.2
g/
km
HC+
NOx,
which
was
based
on
information
provided
by
members
of
the
Manufacturers
of
Emission
Controls
Association
(
MECA),
a
preliminary
literature
search
we
had
conducted,
and
certification
and
in­
use
emissions
data
for
several
engine
families.
During
each
meeting,
we
made
it
clear
that
we
were
initially
proposing
0.2
g/
km
HC+
NOx
primarily
to
determine
the
lower
bound
of
achievable
emissions,
which
in
turn
helps
to
identify
the
various
issues
such
as
costs,
impacts
on
performance,
and
time
needed
to
comply.
Essentially,
the
initial
0.2
g/
km
proposed
limit
served
as
a
"
discussion
point"
to
help
frame
these
issues
and
to
focus
the
attendees'
efforts
on
determining
what
emission
levels
are
achievable.

To
solicit
additional
information,
we
gave
each
manufacturer
a
confidential,
companyspecific
questionnaire
designed
to
help
us
determine
what
is
technically
and
commercially
feasible,
both
on
a
per­
company
and
industry­
wide
basis.
Four
of
the
six
manufacturers
provided
responses
to
the
questionnaire,
which
we
then
discussed
with
them
in
follow­
up
meetings.
The
responses
to
these
questionnaires,
along
with
subsequent
discussions
we
had
with
the
manufacturers
and
at
the
public
workshops,
helped
to
establish
the
staff's
current
proposal
using
two­
tier
standards.
­
3
2.
Meetings
with
Industry
Trade
and
Motorcycle
Riders'
Groups
We
met
with
several
industry
trade
and
motorcycle
riders'
groups
to
solicit
comments
on
our
proposal
before
we
held
our
first
public
workshop.
We
held
two
meetings
with
the
Motorcycle
Industry
Council
(
MIC),
with
a
special
emphasis
on
refining
the
existing
emissions
inventory
using
MIC's
extensive
market
and
demographics
database.
To
illustrate,
our
initial
inventory
at
the
start
of
this
rulemaking
process
showed
approximately
9.6
tpd
HC
and
4.9
tpd
NOx
statewide
emissions
from
on­
road
motorcycles,
based
on
computer
runs
using
the
EMFAC7G
model.
We
initially
ran
this
model
using
the
built­
in
U.
S.
EPA
assumptions
and
parameters
dating
back
to
the
1970s,
which
were
clearly
outdated.
With
the
MIC's
data,
we
were
able
to
refine
the
inventory
to
better
reflect
vehicle
miles
traveled
(
VMT)
and
other
vehicle
activity
data.
Our
best
estimate
at
this
point
shows
statewide
emissions
of
approximately
4.6
tpd
HC
and
3.1
tpd
NOx.
Our
cooperative
efforts
with
the
MIC
to
further
refine
the
inventory
will
continue
in
the
future
as
better
data
become
available
(
see
Chapter
X).

In
addition
to
meeting
with
the
MIC,
we
also
met
with
the
California
Motorcycle
Dealers
Association
and
the
American
Motorcyclist
Association
to
discuss
their
concerns
about
the
proposal.
Their
concerns
mainly
involved
the
proposed
standards'
possible
impacts
on
driveability,
cost,
and
availability
of
product
lines.
We
discussed
the
staff
proposal
and
emphasized
that
the
standards
are
strictly
performance­
based;
that
is,
manufacturers
can
sell
any
engine
family
based
on
any
design
as
long
as
the
motorcycles
meet
the
standards.
Because
our
analysis
shows
the
standards
are
feasible
and
cost­
effective,
we
discussed
our
expectation
that
manufacturers
would
be
able
to
offer
the
same
variety
of
motorcycle
engine
families
that
are
available
today.
We
also
reiterated
our
goal
of
working
with
the
manufacturers
to
develop
standards
which
will
not
have
significant
impacts
on
cost,
horsepower,
driveability,
aesthetics,
rider
safety,
and
any
other
concerns
riders
and
dealers
have.
Finally,
we
discussed
the
need
to
reduce
or
minimize
the
rate
of
equipment
tampering
by
consumers.

3.
Public
Workshops
Based
on
our
individual
and
group
meetings
with
stakeholders,
we
revised
our
original
proposal
of
a
single
0.2
g/
km
HC+
NOx
to
a
progressive,
dual­
standard
proposal.
We
revised
our
proposal
three
times
to
reflect
a
better
understanding
of
the
challenges
involved
and
to
address
industry's
concerns.
At
the
first
workshop
on
July
1,
1998,
we
proposed
a
revised
set
of
standards
for
further
discussion:
a
Tier­
1
standard
between
0.6
and
0.8
g/
km
HC+
NOx,
effective
between
2004;
and
a
Tier­
2
standard
between
0.3
and
0.4
g/
km,
effective
2008.
(
ARB,
1998a)
The
ranges
in
proposed
emission
limits
reflected
the
need
for
additional
information
at
that
time.
From
subsequent
meetings,
we
were
better
able
to
project
a
new
set
of
standards
and
expected
compliance
dates.
Therefore,
we
further
revised
our
proposal,
which
we
discussed
with
stakeholders
at
a
second
workshop
on
October
7,
1998
(
ARB,
1998b):
a
1.2
g/
km
HC+
NOx
Tier­
1
standard
effective
for
Model
Year
2004
and
a
0.4
g/
km
HC+
NOx
Tier­
2
standard
effective
for
Model
Year
2008.
­
4
Based
on
further
input
obtained
from
stakeholders
at
this
workshop,
we
developed
our
final
proposal:
a
1.4
g/
km
HC+
NOx
Tier­
1
standard
effective
for
Model
Year
2004
and
a
0.8
g/
km
HC+
NOx
Tier­
2
standard
effective
for
Model
Year
2008.
Our
final
proposal
also
provides
small­
volume
manufacturers
additional
time
(
to
Model
Year
2008)
to
comply
with
the
Tier­
1
standard
of
1.4
g/
km
HC+
NOx,
with
no
subsequent
standard.
The
small­
volume
manufacturer
provision
is
similar
to
the
MIC's
suggested
provision
and
reflects
a
careful
balancing
between
three
competing
factors:
(
1)
the
fact
that
these
companies
lack
the
capital
to
conduct
the
necessary
research
and
development
to
meet
the
more­
stringent
Tier­
2
standard,
(
2)
the
need
to
avoid
giving
small
manufacturers
an
unfair
competitive
advantage
over
manufacturers
who
are
subject
to
the
Tier­
2
standard,
and
(
3)
the
need
to
achieve
equitable
and
feasible
reductions
from
all
on­
road
motorcycles.
­
1
IV.

SUMMARY
OF
PROPOSED
AMENDMENTS
1.
Tier­
1/
Tier­
2
Exhaust
Emission
Standards
As
noted
previously,
our
proposal
applies
to
Class
III
motorcycles
(
those
with
engine
displacement
of
280
cc
or
greater).
The
vast
majority
of
new
motorcycle
sales
in
California
(
over
90%)
are
in
the
Class
III
sector
(
MIC
Statistical
Annual,
p.
1;
projected
1998
sales
from
ARB
onroad
motorcycle
certification
database);
all
available
sales
trends
and
projections
strongly
indicate
that
nearly
all
sales
growth
for
the
foreseeable
future
will
remain
in
the
Class
III
sector.
(
Id.)
Therefore,
it
is
reasonable
to
assume
that
new,
lower
emission
standards
for
Class
III
motorcycles
will
achieve
the
most
emission
benefits
at
the
least
cost.
Motorcycles
with
engines
smaller
than
280
cc
will
remain
subject
to
the
existing
1.0
g/
km
HC
and
12
g/
km
CO
standards.

Unlike
the
existing
regulation,
the
ARB
staff's
proposal
would
regulate
both
HC
and
NOx
emissions.
Because
both
pollutants
are
ozone
precursors,
the
proposal
would
reduce
ozone
formation
from
motorcycle
emissions
more
effectively
than
the
existing
HC­
only
standard.
Moreover,
the
staff's
proposed
combined
HC+
NOx
standards
provide
more
flexibility
to
manufacturers
than
individual
HC
and
NOx
standards
would.
This
added
flexibility
results
from
the
manufacturers'
ability
to
balance
HC
versus
NOx
emissions
in
each
engine
family;
because
HC
and
NOx
emissions
are
inversely
proportional,
companies
can
use
this
balancing
to
help
meet
their
performance
goals
while
optimizing
reductions
in
HC
and
NOx
levels.

The
second
main
difference
is
the
proposal's
use
of
a
two­
tier
set
of
standards.
Under
the
existing
regulation,
manufacturers
only
had
to
meet
standards
that
were
developed
in
the
late
1970s
and
early
1980s.
As
a
result,
manufacturers
have
not
had
a
strong
incentive
to
modernize
their
emissions
control
technologies
at
the
same
pace
as
automobiles
and
other
motor
vehicles.
Our
proposal
applies
a
two­
stage
set
of
standards
to
avoid
a
similar
stagnation
of
control
technology
development
and
to
progressively
reduce
emissions
over
the
next
20
years.

The
first
tier
standard
(
Tier­
1)
of
1.4
g/
km
HC+
NOx
would
apply
to
Class
III
model
years
2004
through
2007.
As
noted
previously
and
in
Chapter
V,
staff
is
proposing
the
Tier­
1
standard
at
a
level
which
is
achievable
with
reasonably
available
and
demonstrated
emission
controls
without
relying
on
catalytic
after­
treatment.
That
is,
we
are
proposing
the
1.4
g/
km
standard
so
that
manufacturers
can
meet
it
by
reducing
their
engine­
out
emissions
using
mostly
engine
systems
(
fuel
injection,
pulse
air
injection,
valve
overlap
changes,
etc.),
rather
than
relying
on
catalytic
after­
treatment
of
the
exhaust.
It
is
important
to
note
that
the
proposed
Tier­
1
standard
is
very
close
to
the
MIC's
recommended
1.5
g/
km
Tier­
1
and
1.2
g/
km
Tier­
2
standards
(
MIC,
9/
98),
and
it
is
identical
to
Harley­
Davidson's
recommended
1.4
g/
km
HC+
NOx
standard
for
the
2004
model
year.
(
Hoelter,
1998)
­
2
The
proposed
second
tier
standard
(
Tier­
2)
would
limit
emissions
to
0.8
g/
km
HC+
NOx.
This
proposed
standard
will
apply
to
model
years
2008
and
beyond.
As
discussed
in
Chapter
V,
this
standard
represents
some
challenges
to
industry,
but
available
information
strongly
indicate
that
this
is
a
commercially
and
technologically
feasible
emissions
level.
We
expect
manufacturers
to
modify
and
optimize
existing
technologies
to
achieve
this
level.
Technologies
that
will
help
meet
this
standard
include
computerized
fuel
injection;
high­
efficiency,
closed­
loop,
two
or
threeway
catalytic
converters;
precise
air­
fuel
(
A/
F)
ratio
controls;
programmed
secondary
pulse­
air
injection;
low­
thermal
capacity
exhaust
pipes;
and
other
technologies
which
are
available
today
or
in
the
foreseeable
near­
future.

We
are
proposing
the
0.8
g/
km
Tier­
2
standard
to
address
several
issues,
one
of
which
is
the
consumer
tampering
issue
raised
by
industry
during
this
rulemaking
(
see
Chapter
IX,
"
Outstanding
Issues").
Basically,
the
industry
is
concerned
that
standards
which
result
in
the
widespread
use
of
catalysts
will
achieve
less
benefits
than
projected
due
to
consumer
tampering
or
migration/
tourism
of
non­
California­
compliant
motorcycles
from
other
states.
On
some
motorcycle
lines,
particularly
with
certain
custom
and
sport
bikes,
consumer
tampering
is
projected
to
occur
at
rates
of
34%
or
greater
(
MIC,
1998).
Such
tampering,
which
can
involve
the
replacement
of
exhaust
pipes
that
may
include
the
catalytic
converter,
can
offset
some
of
the
emission
benefits
to
be
achieved
by
the
proposed
standards.
Migration
or
tourism
involving
49­
state
motorcycles
can
also
impact
projected
emission
benefits
to
the
extent
that
manufacturers
bifurcate
their
production
into
California­
only
and
49­
state
motorcycles.

Our
proposed
0.8
g/
km
Tier­
2
standard
addresses
both
of
these
concerns.
The
1998
ARB
on­
road
motorcycle
certification
database
shows
that
about
one­
third
of
new
motorcycle
sales
are
in
the
sport
bike
category;
the
MIC
stated
that
this
category
is
most
likely
to
experience
the
highest
levels
of
tampering
due
to
the
consumers'
desire
to
maximize
horsepower
(
e.
g.,
removal
of
exhaust
after­
treatment
equipment).
Based
on
our
review
of
the
motorcycles
in
the
1998
certification
database,
we
project
that
about
40%
of
the
market
can
be
left
at
the
1.4
g/
km
noncatalyst
based
level
(
i.
e.,
no
additional
modifications
needed
after
the
Tier­
1
level),
while
the
remaining
60%
would
likely
use
catalytic
converters
to
certify
at
0.4
g/
km
HC+
NOx,
or
a
similar
level.
Under
corporate
averaging,
manufacturers
will
be
able
to
sell
higher­
emitting
motorcycle
lines,
such
as
sport
bikes,
to
those
consumers
who
are
most
likely
to
tamper
with
their
motorcycles,
while
selling
catalyst­
based
motorcycle
models,
such
as
cruisers,
to
consumers
who
are
less
likely
to
tamper
with
the
equipment.
Therefore,
with
corporate
averaging
at
0.8
g/
km
Tier­
1
standard,
the
effects
of
consumer
tampering
and
migration
of
higher­
emitting,
49­
state
motorcycles
can
be
reduced.
­
3
2.
Corporate
Averaging
To
provide
flexibility
in
meeting
the
standards,
we
are
proposing
to
maintain
the
corporate
averaging
provisions
in
the
existing
regulation
for
HC
and
NOx.
To
ensure
that
no
backsliding
on
the
existing
standards
can
occur,
we
propose
to
modify
the
existing
"
cap"
that
applies
to
individual
engine
families
so
that:
(
1)
it
is
expressed
in
HC+
NOx
grams
per
kilometer,
and
(
2)
it
decreases
when
the
standards
decrease
from
Tier­
1
to
Tier­
2.

Under
the
existing
corporate
averaging
provisions,
manufacturers
can
balance
the
certified
emissions
of
their
motorcycles
so
that
the
sales­
weighted
average
certified
emissions
level
meets
the
applicable
standard.
This
means
that
some
engine
families
may
have
emissions
below
the
standards,
while
others
have
emissions
higher
than
the
standards.
For
enforcement
purposes,
manufacturers
are
required
to
specify
a
certification
limit
for
each
engine
family.
For
example,
one
of
a
manufacturer's
Class
III
engine
families
may
be
certified
as
emitting
1.7
g/
km
HC;
this
is
allowable
if
the
average
of
all
the
manufacturer's
engine
families
meets
the
currently
applicable
1.4
or
1.0
g/
km
HC
standard.

To
maintain
equity,
the
Board
also
adopted
a
not­
to­
exceed
cap
of
2.5
g/
km
HC
for
all
individual
engine
families
under
the
existing
regulation's
corporate
averaging
provision.
Because
the
2.5
g/
km
HC­
only
standard
was
the
standard
in
effect
before
corporate
averaging
was
adopted,
the
2.5
g/
km
cap
prevents
manufacturers
from
selling
motorcycles
under
corporate
averaging
with
emissions
that
are
higher
than
the
previous
standard,
which
would
give
such
manufacturers
a
potentially
unfair
performance
and
competitive
advantage.
Based
on
this
reasoning,
we
are
proposing
a
similar
cap.
Thus,
for
both
Tier­
1
and
Tier­
2
standards,
we
are
proposing
a
cap
on
individual
engine
families
of
2.5
g/
km
HC+
NOx.

To
encourage
early
compliance,
we
are
also
proposing
incentives
in
the
corporate
averaging
provisions.
We
believe
such
incentives
will
help
manufacturers
decide
to
take
whatever
risks
are
involved
in
introducing
new,
catalyst­
based,
Tier­
2
compliant
motorcycles
earlier
than
required
by
the
staff's
proposal.
In
addition,
we
believe
some
manufacturers
can
reduce
emissions
even
further
than
required
by
the
Tier­
2
standard;
we
would
like
to
encourage
the
early
introduction
of
these
very
low­
emission
vehicles.
The
proposal
provides
incentives
for
early
compliance
by
assigning
specific
multiplier
factors
based
on
how
early
a
manufacturer
produces
a
Tier­
2
compliant
motorcycle
and
a
motorcycle
certified
at
0.4
g/
km
HC+
NOx
;
these
multipliers
are
shown
in
Table
IV­
1.

Because
we
expect
the
Tier­
2
technologies
to
become
more
widespread
as
2008
approaches,
the
multipliers
decrease
linearly
in
value
from
2004
until
2008,
when
the
early
compliance
incentive
would
no
longer
have
any
value
(
i.
e.,
the
multiplier
has
a
value
of
1.0).
As
shown
in
Table
IV­
1,
each
unit
of
Tier­
2
early
compliant
motorcycles
(
those
certified
at
0.8
g/
km
HC+
NOx)
would
count
as
X
motorcycles
at
0.8
g/
km
HC+
NOx
for
purposes
of
corporate
averaging
in
2008,
where
X
is
1.5
for
those
motorcycles
sold
during
model
years
(
MY)
1999
through
2004,
1.375
for
those
sold
in
MY
2005,
1.250
for
those
sold
in
MY
2006,
1.125
for
­
4
those
sold
in
MY
2007,
and
1.0
for
those
sold
in
MY
2008
and
subsequent.
A
similar
set
of
multipliers
is
shown
in
Table
IV­
1
for
pre­
MY
2008
motorcycles
certified
at
0.4
g/
km
HC+
NOx.

Table
IV­
1.
Multipliers
to
Encourage
Early
Compliance
with
the
Proposed
Tier­
2
Standard
and
Beyond
Multiplier
(
X)
for
Use
in
MY
2008
Corporate
Averaging
Model
Year
Sold
Early
Tier­
2
Compliant
Certified
at
0.4
g/
km
HC+
NOx
1999
through
2004
1.5
3.0
2005
1.375
2.5
2006
1.250
2.0
2007
1.125
1.5
2008
and
subsequent
1.0
1.0
Note:
Early
Tier­
2
compliant
and
0.4
g/
km
certified
motorcycles
are
counted
cumulatively
toward
the
MY
2008
corporate
average
3.
Small­
Volume
Manufacturer
Provision
Small
volume
manufacturers
collectively
represent
3%
of
new
motorcycle
sales
in
California
(
MIC
1997
Motorcycle
Statistical
Annual,
p.
4).
From
our
discussions
with
small­
volume
manufacturers,
it
became
apparent
that
the
proposed
Tier­
2
standard
represents
a
significant,
potentially
infeasible
limit
for
these
manufacturers.
Unlike
their
higher­
volume
competitors,
small­
volume
manufacturers
generally
lack
the
financial
and
technical
resources
to
undertake
the
necessary
research
and
development
(
R&
D)
effort
to
meet
the
Tier­
2
standard.
Even
if
a
small­
volume
manufacturer
did
have
sufficient
R&
D
and
financial
resources
to
investigate
compliant
technologies,
their
low
sales­
volume
in
California
generally
would
not
justify
such
expenditures;
most,
if
not
all,
small­
volume
manufacturers
we
contacted
indicated
they
would
simply
pull
out
of
the
California
market.

While
small­
volume
manufacturers
are
expected
to
have
difficulty
in
meeting
the
Tier­
2
standard,
we
believe
the
Tier­
1
standard's
reliance
on
engine
systems
would
justify
applying
the
Tier­
1
standard
to
these
companies,
especially
if
given
additional
lead
time
to
2008.
As
discussed
in
Chapter
V,
the
Tier­
1
standard
focuses
on
the
application
of
reasonably
available
technologies
that
reduce
engine­
out
emissions.
These
technologies
include
replacement
of
carburetors
with
fuel
injection
and
relatively
simple
changes
to
the
engine
timing,
cams,
valves,
or
combustion
chambers.
We
estimate
a
sales­
weighted
average
production
cost
increase
for
the
entire
industry
of
about
$
44
per
motorcycle
under
the
Tier­
1
standard
(
see
Chapter
VI).
Because
small­
volume
manufacturers
produce
fewer
motorcycles
over
which
to
spread
their
costs,
we
expect
the
average
production
cost
increase
per
motorcycle
to
be
somewhat
higher
for
these
manufacturers.
However,
since
typical
Class
III
motorcycles
retail
for
about
$
7,600,
we
would
not
expect
a
­
5
production
cost
increase
on
the
order
of
$
44
per
unit
to
significantly
dampen
motorcycle
sales,
even
sales
for
small­
volume
manufacturers.

Based
on
the
considerations
discussed
above,
we
are
proposing
that
the
current
standards
remain
in
effect
for
small­
volume
manufacturers
until
model
year
2008,
when
the
1.4
g/
km
HC+
NOx
Tier­
1
standard
would
become
effective
for
those
companies.
With
this
proposal,
the
standards
maintain
equity
by
requiring
all
manufacturers
to
reduce
their
emissions
to
the
extent
feasible,
given
their
relative
ability
to
apply
the
necessary
control
technologies
and
their
market
share
in
California.
The
small­
volume
manufacturers'
provision
is
supported
by
small­
volume
members
of
the
MIC,
as
well
as
the
larger
volume
manufacturers.
­
1
V.

TECHNOLOGICAL
FEASIBILITY
OF
PROPOSED
STANDARDS
1.
Analysis
Methodology
To
determine
the
technical
feasibility
of
the
proposed
standards,
we
used
a
variety
of
sources
to
evaluate
the
current
and
foreseeable
emission
control
technologies
for
motorcycles.
While
no
single
source
of
information
was
conclusive
in
determining
the
proposal's
feasibility,
the
use
of
multiple
sources
of
information
helped
provide
cross­
checks
on
technology
claims
and
ensured
that
the
proposal
is
based
on
sound
and
credible
developments
in
motorcycle
technology.
This
section
describes
the
various
sources
of
information
that
provide
the
technical
basis
for
the
staff's
proposal.
Subsequent
sections
in
this
chapter
will
then
describe
the
technologies
we
expect
manufacturers
will
use
to
meet
the
proposed
limits.

First,
we
looked
at
ARB's
certification
data
to
determine
the
current
state
of
emission
levels
and,
in
particular,
what
combinations
of
technologies
are
being
used
to
achieve
those
emission
levels.
This
provided
the
most
direct
evidence
of
the
technologies
that
are
reasonably
available
and
already
demonstrated
as
feasible.
We
then
conducted
an
extensive
literature
search,
including
Internet
searches,
to
extract
the
latest
technical
reports
applicable
to
current
and
projected
motorcycle
emission
controls.
This
part
of
the
analysis
included
a
patent
search
for
recently
published
inventions;
while
we
were
unable
to
access
the
German
Patent
Office's
Internet
site
for
a
variety
of
reasons,
we
were
able
to
download
abstracts
of
relevant
patents
in
the
patent
offices
of
the
U.
S.
and
Japan.
We
also
held
numerous
discussions
with
engineers
from
the
six
major
manufacturers,
Triumph,
and
members
of
the
Manufacturers
of
Emission
Controls
Association
(
MECA).
Finally,
we
relied
on
our
best
engineering
judgment
to
verify
the
technical
soundness
of
proposed
control
techniques.

In
our
analysis,
we
evaluated
only
those
technologies
which
manufacturers
already
use
on
motorcycles
or
have
a
high
probability
for
mass­
market
application.
Thus,
we
did
not
evaluate
electric
or
hybrid­
electric
drives,
non­
gasoline­
based
power
plants,
electrically­
heated
catalysts,
and
other
exotic
technologies
being
investigated
for
use
on
automobiles.
The
pollution
control
techniques
we
evaluated
can
be
separated
into
two
categories:
those
which
do
not
use
catalytic
converters
(
e.
g.,
engine
modifications
and
secondary
pulse­
air
injection)
and
those
that
use
catalytic
converters
(
non­
honeycombed
"
Hot
Tubes,"
two­
way
and
three­
way
catalysts).
With
the
available
information,
we
conclude
that
manufacturers
can
comply
with
the
Tier­
1
standard
primarily
with
non­
catalytic
engine
modifications
and
secondary
pulse
air
injection,
using
lowefficiency
catalytic
converters
only
for
some
of
the
higher­
polluting
engine
families.
This
conclusion
is
consistent
with
the
MIC's
findings
that
an
HC+
NOx
level
close
to
staff's
Tier­
1
proposal
is
feasible
using
non­
catalytic
engine
systems
and
simple
pulse­
air
injection.
For
the
Tier­
2
standard,
we
conclude
that
manufacturers
will
use
some
combination
of
engine
modifications,
programmed
secondary
pulse­
air
injection,
and
a
high­
efficiency
three­
way
catalyst.
­
2
2.
Meeting
the
Tier­
1
Standard:
Engine
Modifications
and
Other
Non­
Catalyst
Technologies
to
Reduce
Engine­
Out
Emissions
Motorcycle
engines
come
in
a
wide
variety
of
designs.
Most
have
one
to
four
cylinders
(
at
least
one
manufacturer
is
currently
producing
six
cylinder
motorcycles).
These
engines
also
come
in
different
configurations
(
e.
g.,
45
to
90
degree
V­
twins,
3­
cylinder
transverse,
2­
cylinder
longitudinal
opposed).
In
addition,
engines
can
be
differentiated
by
the
performance
characteristics
they
emphasize;
e.
g.,
some
engine
families
produce
high
horsepower
at
high
revolutions
per
minute
(
rpm),
while
others
feature
high
torque
at
relatively
low
rpm.
As
a
result
of
this
diversity,
different
types
of
engine
systems
and
modifications
have
been
developed.
From
these,
manufacturers
can
select
different
combinations
of
available
technologies
that
are
appropriate
for
their
particular
engine
configurations.
In
this
section,
we
will
discuss
the
various
types
of
non­
catalytic
techniques
available
for
reducing
emissions,
focusing
mainly
on
engine
modifications
and
secondary
pulse­
air
injection.
It
is
important
to
note
that
this
discussion
is
not
inclusive
of
all
engine
modifications
possible,
nor
is
it
intended
to
show
that
all
of
these
modifications
can
be
applied
the
same
way
to
all
engine
families.

While
manufacturers
will
use
various
means
to
meet
the
Tier­
1
standard,
there
are
four
basic
types
of
existing,
non­
catalyst­
based,
emission
control
systems
available
to
manufacturers.
The
most
important
of
these
is
the
use
of
secondary
pulse­
air
injection.
Other
engine
modifications
and
systems
include
more
precise
fuel
control,
better
fuel
atomization
and
delivery,
and
reduced
engine­
out
emission
levels
from
engine
changes.
The
combinations
of
low­
emission
technologies
ultimately
chosen
by
motorcycle
manufacturers
are
dependent
on
the
engine­
out
emission
levels
of
the
vehicle,
the
effectiveness
of
the
prior
emission
control
system,
and
individual
manufacturer
preferences.

Secondary
pulse­
air
injection,
as
demonstrated
on
current
motorcycles,
is
applied
using
a
passive
system
(
i.
e.,
no
air
pump
involved)
that
takes
advantage
of
the
flow
of
gases
("
pulse")
in
the
exhaust
pipes
to
draw
in
fresh
air
that
further
combusts
unburned
hydrocarbons
in
the
exhaust.
Engine
modifications
include
a
variety
of
techniques
designed
to
improve
fuel
delivery
or
atomization;
promote
"
swirl"
(
horizontal
currents)
and
"
tumble"
(
vertical
currents);
maintain
tight
control
on
air­
to­
fuel
(
A/
F)
ratios;
stabilize
combustion
(
especially
in
lean
A/
F
mixtures);
optimize
valve
timing;
and
retard
ignition
timing.

Secondary
Pulse­
Air
Injection
This
technique
involves
the
introduction
of
fresh
air
into
the
exhaust
pipe
immediately
after
the
gases
exist
the
engine.
The
extra
air
causes
further
combustion
to
occur,
thereby
controlling
more
of
the
hydrocarbons
that
escape
the
combustion
chamber.
This
type
of
system
is
relatively
inexpensive
and
uncomplicated
because
it
does
not
require
an
air
pump;
air
is
drawn
into
the
exhaust
through
a
one­
way
reed
valve
due
to
the
pulses
of
negative
pressure
inside
the
exhaust
pipe.
Secondary
pulse­
air
injection
is
one
of
the
most
effective
non­
catalytic,
emissions
control
technologies;
compared
to
engines
without
the
system,
reductions
of
10­
40%
for
HC
are
­
3
possible
with
pulse­
air
injection.
(
ACEM,
p.
20,
1998)
Thirty­
five
of
the
87
engine
families
certified
for
sale
in
California
this
year
already
employ
secondary
pulse­
air
injection
to
help
meet
the
current
standard.
We
anticipate
most
of
the
remaining
engine
families
will
use
this
technique
to
help
meet
the
Tier­
1
and
Tier­
2
standards.

Improving
Fuel
Delivery
and
Atomization
This
emissions
control
technique
primarily
involves
the
replacement
of
carburetors,
currently
used
on
most
motorcycles,
with
more
precise
fuel
injection
systems.
There
are
several
types
of
fuel
injection
systems
and
components
manufacturers
can
choose.
The
most
likely
type
of
fuel
injection
manufacturers
will
choose
to
help
meet
the
Tier­
1
standard
is
sequential
multipoint
fuel
injection
(
SFI).

Unlike
conventional
multi­
point
fuel
injection
systems
that
deliver
fuel
continuously
or
to
paired
injectors
at
the
same
time,
sequential
fuel
injection
can
deliver
fuel
precisely
when
needed
by
each
cylinder.
With
less
than
optimum
fuel
injection
timing,
fuel
puddling
and
intake­
manifold
wall
wetting
can
occur,
both
of
which
hinder
complete
combustion.
Use
of
sequential­
fuel­
injection
systems
help
especially
in
reducing
cold
start
emissions
when
fuel
puddling
and
wall
wetting
are
more
likely
to
occur
and
emissions
are
highest.

Motorcycle
manufacturers
are
already
beginning
to
use
sequential
fuel
injection
(
SFI).
Of
the
97
motorcycle
engine
families
certified
for
sale
in
California
this
year,
7
employ
SFI
systems.
We
anticipate
increased
applications
of
this
or
similar
fuel
injection
systems
to
achieve
the
more
precise
fuel
delivery
needed
to
help
meet
the
Tier­
1
and
Tier­
2
standards.

Engine
Modifications
Emission
performance
can
also
be
improved
by
reducing
crevice
volumes
in
the
combustion
chamber.
Unburned
fuel
can
be
trapped
momentarily
in
crevice
volumes
before
being
subsequently
released.
Since
trapped
and
re­
released
fuel
can
increase
engine­
out
emissions,
the
elimination
of
crevice
volumes
would
be
beneficial
to
emission
performance.
To
reduce
crevice
volumes,
manufacturers
can
evaluate
the
feasibility
of
designing
engines
with
pistons
that
have
reduced,
top
"
land
heights"
(
the
distance
between
the
top
of
the
piston
and
the
first
ring).

Lubrication
oil
which
leaks
into
the
combustion
chamber
also
has
a
detrimental
effect
on
emission
performance
since
the
heavier
hydrocarbons
in
oil
do
not
oxidize
as
readily
as
those
in
gasoline
and
some
components
in
lubricating
oil
may
tend
to
foul
the
catalyst
and
reduce
its
effectiveness.
Also,
oil
in
the
combustion
chamber
may
trap
HC
and
later
release
the
HC
unburned.
To
reduce
oil
consumption,
manufacturers
can
tighten
the
tolerances
and
improve
the
surface
finish
on
cylinders
and
pistons,
piston
ring
design
and
materials,
and
exhaust
valve
stem
seals
to
prevent
excessive
leakage
of
lubricating
oil
into
the
combustion
chamber.
­
4
Increasing
valve
overlap
is
another
engine
modification
that
can
help
reduce
emissions.
This
technique
helps
reduce
NOx
generation
in
the
combustion
chamber
by
essentially
providing
passive
exhaust
gas
recirculation
(
EGR).
When
the
engine
is
undergoing
its
pumping
cycle,
small
amounts
of
combusted
gases
flow
past
the
intake
valve
at
the
start
of
the
intake
cycle.
This
creates
what
is
essentially
a
passive
EGR
flow,
which
is
then
either
drawn
back
into
the
cylinder
or
into
another
cylinder
through
the
intake
manifold
during
the
intake
stroke.
These
combusted
gases,
when
combined
with
the
fresh
air/
fuel
mixture
in
the
cylinder,
help
reduce
peak
combustion
temperatures
and
NOx
levels.
This
technique
can
be
effected
by
making
changes
to
cam
timing
and
intake
manifold
design
to
optimize
NOx
reduction
while
minimizing
impacts
to
HC
emissions.

Current
State
of
Emission
Controls
Secondary
pulse­
air
injection
and
engine
modifications
already
play
important
parts
in
reducing
emission
levels;
we
expect
increased
uses
of
these
techniques
to
help
meet
the
Tier­
1
standard.
Direct
evidence
of
the
extent
these
technologies
can
help
manufacturers
meet
the
Tier­
1
standard
can
be
found
in
the
ARB
on­
road
motorcycle
certification
database.
This
database
is
comprised
of
publicly­
available
certification
emission
levels
and
confidential
data
reported
by
the
manufacturers
pursuant
to
existing
requirements.

From
ARB's
certification
data,
we
find
that
43
of
87
(
49%)
Class
III
engine
families
certified
for
Model
Year
1998
already
had
HC
levels
ranging
from
0.23
to
0.89
g/
km.
Our
discussions
with
manufacturers
indicate
that
typical
NOx
levels
range
from
about
0.5
to
0.7
g/
km.
Therefore,
these
43
engine
families
could
be
certified
for
HC+
NOx
levels
at
about
0.9
to
1.6
g/
km
(
using
the
higher
0.7
g/
km
value),
primarily
by
using
engine
modifications
and
secondary
pulse­
air
injection.
Even
at
the
1.6
g/
km
level,
the
certification
data
show
that
it
is
not
necessary
for
widespread
applications
of
advanced,
high­
efficiency,
two­
way
or
three­
way
catalysts
to
meet
staff's
proposed
1.4
g/
km
HC+
NOx
Tier­
1
limit
(
i.
e.,
high­
efficiency
catalysts
are
generally
not
needed
to
achieve
a
13%
reduction
in
emissions,
which
lowering
emissions
from
1.6
g/
km
to
1.4
g/
km
would
require).

Table
V­
1
shows
the
breakdown
of
technologies
used
by
the
manufacturers
of
the
43
engine
families
noted
previously.
As
Table
V­
1
demonstrates,
only
2
engine
families
using
lowefficiency
three­
way
catalysts
for
certification
at
or
near
ARB
staff's
proposed
Tier­
1
limit.
The
remaining
41
engine
families
certify
at
or
near
staff's
proposal
using
simpler,
less
costly
engine
modifications
and
secondary
pulse­
air
injection;
only
five
of
these
employ
a
two­
way
catalyst.
More
importantly,
Table
V­
1
shows
that
the
43
engine
families
represent
approximately
60%
of
the
1998
market.
Thus,
significantly
more
than
half
the
current
number
of
new
motorcycles
sold
in
the
State
already
meet
or
will
likely
meet
the
Tier­
1
proposal
with
relatively
simple
engine
modifications
and
secondary
pulse­
air
injection.
­
5
Table
V­
1.
Breakdown
of
HC
Certification
Levels
by
Technology
and
Market
Share
Number
of
Engine
Families
Using
Specified
Technology
Certified
HC
g/
km
Total
Number
Engine
Families
Market
Share
of
Class
III
Sales
(%
by
units)
Engine
Modifications
Pulse
Air
Injection
2­
Way
Ox­
Cat
3­
Way
Cat.

0.23
to
0.5
10
12%
4
6
2
0
0.51
to
0.7
16
15%
10
7
2
0
0.71
to
0.89
17
33%
14
2
2
2
Total
43
60%
28
15
6
2
Notes:
(
1)
"
Number
of
Engine
Families
Using
Specified
Technology"
columns
do
not
add
up
to
"
Total
Number
of
Engine
Families"
column
due
to
overlapping
use
of
different
technologies
(
e.
g.,
engine
that
uses
modifications,
pulse­
air,
and
2­
way
ox­
cat
is
counted
three
times,
one
for
each
column)
(
2)
"
Engine
Modifications"
include
all
forms
of
fuel
injection,
electronic
control
modules,
etc.
Source:
1998
ARB
On­
Road
Motorcycle
Certification
Database
The
manufacturers'
ability
to
meet
the
proposed
Tier­
1
standard
of
1.4
g/
km
HC+
NOx
using
optimized
versions
of
currently
available,
non­
catalyst
technologies
is
further
documented
by
information
obtained
from
the
Motorcycle
Industry
Council.
According
to
the
MIC,
"
the
best
non­
catalyst
engine
families
can
meet
a
sales­
weighted
HC+
NOx
standard
of
1.3
g/
km"
(
1.0
g/
km
plus
a
30%
compliance
margin
to
account
for
variabilities
due
to
manufacturing,
testing,
supplied
parts,
etc.;
note
that
MIC
reported
0.9
g/
km,
which
appears
to
be
mathematically
incorrect).
[
emphasis
in
original]
(
MIC,
October
1998)
Therefore,
taking
into
account
the
more
difficult­
tocontrol
engine
families,
the
staff's
proposed
Tier­
1
standard
of
1.4
g/
km
HC+
NOx
appears
to
be
reasonably
achievable
by
the
industry
without
the
widespread
use
of
catalysts.

3.
Meeting
the
Tier­
2
Standard:
Using
Engine
Systems
and
Catalytic
Converters
According
to
the
MIC,
"
with
further
refinement
of
fuel
metering
and
air
injection,
a
more
stringent
level
(
beyond
Tier­
1)
of
1.2
g/
km
HC+
NOx
is
achievable
for
full­
range
manufacturers...
without
the
widespread
use
of
catalysts"
(
i.
e.,
0.9
g/
km
HC+
NOx
plus
a
30%
compliance
margin;
note
that
MIC
reported
0.8
g/
km,
which
appears
to
be
mathematically
incorrect).
(
MIC,
October
1998)
To
achieve
the
Tier­
2
standard
from
this
level,
manufacturers
would
need
to
reduce
their
corporate
average
emissions
to
approximately
0.6
g/
km
HC+
NOx
(
accounting
for
a
30%
compliance
margin).
Decreasing
average
emissions
from
0.9
to
0.6
g/
km
HC+
NOx
requires
an
average
reduction
of
about
33%
in
HC+
NOx.
This
reduction
is
well
within
the
capabilities
of
existing
three­
way
catalytic
converters,
which
in
current
motorcycles
have
been
reported
as
achieving
a
60
to
85%
reduction
in
HC
and
NOx.
(
BMW,
April
1998;
MBNet,
August
1998)
Due
to
the
high
emission
reduction
capability
of
three­
way
catalysts,
we
expect
manufacturers
to
apply
this
technology
only
to
the
extent
necessary
and
will
therefore
be
able
to
offer
a
range
of
non­
catalyst
and
catalyst­
based
motorcycles
to
consumers
in
2008.
­
6
To
meet
the
Tier­
2
standard
for
HC+
NOx,
manufacturers
will
likely
use
more
advanced
engine
modifications
and
secondary
air
injection.
Specifically,
we
believe
manufacturers
will
use
computer­
controlled
secondary
pulse­
air
injection
(
i.
e.,
the
injection
valve
would
be
connected
to
a
computer­
controlled
solenoid).
In
addition
to
these
systems,
manufacturers
will
probably
need
to
use
catalytic
converters
on
some
motorcycles
to
meet
the
Tier­
2
standards.
There
are
two
types
of
catalytic
converters
currently
in
use:
two­
way
catalysts
(
which
controls
only
HC
and
CO)
and
three­
way
catalysts
(
which
controls
HC,
CO,
and
NOx).
Under
the
Tier­
2
standard,
manufacturers
will
need
to
minimize
levels
of
both
HC
and
NOx.
Therefore,
to
the
extent
catalysts
are
used,
manufacturers
will
likely
use
a
three­
way
catalyst
in
addition
to
engine
modifications
and
computer­
controlled,
secondary
pulse­
air
injection.

The
following
section
will
discuss
methods
that
manufacturers
will
likely
explore
for
maximizing
the
effectiveness
of
fuel
delivery
systems
and
three­
way
catalysts
while
minimizing
impacts
on
performance
and
cost.
Many
of
these
technologies
have
been
successfully
used
in
automobiles
and
will
likely
be
transferred
to
motorcycle
applications.

Technologies
for
Improving
Fuel
Control
As
discussed
previously,
improving
fuel
control
and
delivery
provides
emission
benefits
by
helping
to
reduce
engine­
out
emissions
and
minimizing
the
exhaust
variability
which
the
catalytic
converter
experiences.
One
method
for
improving
fuel
control
is
to
provide
enhanced
feedback
to
the
computer­
controlled
fuel
injection
system
through
the
use
of
heated
oxygen
sensors.
Heated
oxygen
sensors
(
HO2S)
are
located
in
the
exhaust
manifold
to
monitor
the
amount
of
oxygen
in
the
exhaust
stream
and
provide
feedback
to
the
electronic
control
module
(
ECM).
These
sensors
allow
the
fuel
control
system
to
maintain
a
tighter
band
around
the
stoichiometric
A/
F
ratio
than
conventional
O2
sensors.
In
this
way,
HO2S
assist
vehicles
in
achieving
precise
control
of
the
A/
F
ratio
and
thereby
enhance
the
overall
emissions
performance
of
the
engine.

In
order
to
further
improve
fuel
control,
some
motorcycles
with
electronic
controls
may
utilize
software
algorithms
to
perform
individual
cylinder
fuel
control.
While
dual
oxygen
sensor
systems
are
capable
of
maintaining
A/
F
ratios
within
a
narrow
range,
some
manufacturers
may
desire
even
more
precise
control
to
meet
their
performance
needs.
On
typical
applications,
fuel
control
is
modified
whenever
the
O2S
determines
that
the
combined
A/
F
of
all
cylinders
in
the
engine
or
engine
bank
is
"
too
far"
from
stoichiometric.
The
needed
fuel
modifications
(
i.
e.,
inject
more
or
less
fuel)
are
then
applied
to
all
cylinders
simultaneously.
Although
this
fuel
control
method
will
maintain
the
"
bulk"
A/
F
for
the
entire
engine
or
engine
bank
around
stoichiometric,
it
would
not
be
capable
of
correcting
for
individual
cylinder
A/
F
deviations
that
can
result
from
differences
in
manufacturing
tolerances,
wear
of
injectors,
or
other
factors.

With
individual
cylinder
fuel
control,
A/
F
variation
among
cylinders
will
be
diminished,
thereby
further
improving
the
effectiveness
of
the
emission
controls.
By
modeling
the
behavior
of
the
exhaust
gases
in
the
exhaust
manifold
and
using
software
algorithms
to
predict
individual
cylinder
A/
F,
a
feedback
fuel
control
system
for
individual
cylinders
can
be
developed.
Except
for
­
7
the
replacement
of
the
conventional
front
O2S
with
an
HO2S
sensor
and
a
more
powerful
engine
control
computer,
no
additional
hardware
is
needed
in
order
to
achieve
individual
cylinder
fuel
control.
Software
changes
and
the
use
of
mathematical
models
of
exhaust
gas
mixing
behavior
are
required
to
perform
this
operation.
Sensors
and
the
improved
software
needed
to
achieve
individual
cylinder
fuel
control
are
currently
being
used
by
at
least
2
automobile
manufacturers
on
1998
model
year
vehicles;
because
these
components
are
relatively
small
in
size,
we
believe
there
is
potential
to
apply
this
technology
to
on­
road
motorcycles.

In
order
to
maintain
good
driveability,
responsive
performance,
and
optimum
emission
control,
fluctuations
of
the
A/
F
must
remain
small
under
all
driving
conditions
including
transient
operation.
Virtually
all
current
fuel
systems
in
automobiles
incorporate
an
adaptive
fuel
control
system
that
automatically
adjusts
the
system
for
component
wear,
varying
environmental
conditions,
varying
fuel
composition,
etc.,
to
more
closely
maintain
proper
fuel
control
under
various
operating
conditions.
For
some
fuel
control
systems
today,
this
adaptation
process
affects
only
steady­
state
operating
conditions
(
i.
e.,
constant
or
slowly
changing
throttle
conditions).
However,
most
vehicles
are
now
being
introduced
with
adaptation
during
"
transient"
conditions
(
e.
g.,
rapidly
changing
throttle,
purging
of
the
evaporative
system).

Accurate
fuel
control
during
transient
driving
conditions
has
traditionally
been
difficult
because
of
the
inaccuracies
in
predicting
the
air
and
fuel
flow
under
rapidly
changing
throttle
conditions.
Because
of
air
and
fuel
dynamics
(
fuel
evaporation
in
the
intake
manifold
and
air
flow
behavior)
and
the
time
delay
between
the
air
flow
measurement
and
the
injection
of
the
calculated
fuel
mass,
temporarily
lean
A/
F
ratios
can
occur
during
transient
driving
conditions
that
can
cause
engine
hesitation,
poor
driveability
and
primarily
an
increase
in
NOx
emissions.
However,
by
utilizing
fuel
and
air
mass
modeling,
vehicles
with
adaptive
transient
fuel
control
are
more
capable
of
maintaining
accurate,
precise
fuel
control
under
all
operating
conditions.
Virtually
all
cars
sold
in
California
will
incorporate
adaptive
transient
fuel
control
software;
motorcycles
with
computer
controlled
fuel
injection
can
also
benefit
from
this
technique
at
a
low
cost.

Technologies
for
Improving
Catalyst
Performance
Catalyst
Enhancements.
Three­
way
catalytic
converters
traditionally
utilize
rhodium
and
platinum
as
the
catalytic
material
to
control
the
emissions
of
all
three
major
pollutants
(
hydrocarbons
(
HC),
CO,
NOx).
Although
this
type
of
catalyst
is
very
effective
at
converting
exhaust
pollutants,
rhodium,
which
is
primarily
used
to
convert
NOx,
tends
to
thermally
deteriorate
at
temperatures
significantly
lower
than
platinum.
Recent
advances
in
palladium
and
tri­
metal
(
i.
e.,
palladium­
platinum­
rhodium)
catalyst
technology,
however,
have
improved
both
the
light­
off
performance
(
light­
off
is
defined
as
the
catalyst
bed
temperature
where
pollutant
conversion
reaches
50%
efficiency)
(
Mazda,
1998;
Degussa,
1998)
and
high
temperature
durability
over
previous
catalysts
(
SAE
980042,
980672).
In
addition,
other
refinements
to
catalyst
technology,
such
as
higher
cell
density
substrates
and
adding
a
second
layer
of
catalyst
washcoat
to
the
substrate
(
dual­
layered
washcoats),
have
further
improved
catalyst
performance
from
just
a
year
ago.
­
8
Typical
cell
densities
for
conventional
catalysts
used
in
motorcycles
are
less
than
300
cells
per
square
inch
(
cpsi).
To
meet
the
Tier­
2
standard,
we
expect
manufacturers
to
use
catalysts
with
cell
densities
of
300
to
400
cpsi.
If
catalyst
volume
is
maintained
at
the
same
level
(
we
assume
volumes
of
up
to
60%
of
engine
displacement),
using
a
higher
density
catalyst
effectively
increases
the
amount
of
surface
area
available
for
reacting
with
pollutants.
Catalyst
manufacturers
have
been
able
to
increase
cell
density
by
using
thinner
walls
between
each
cell
without
increasing
thermal
mass
(
and
detrimentally
affecting
catalyst
light­
off)
or
sacrificing
durability
and
performance.
(
SAE,
1998;
SAE
980670,
980420)

In
addition
to
increasing
catalyst
volume
and
cell
density,
staff
believes
that
increased
catalyst
loading
and
improved
catalyst
washcoats
will
help
manufacturers
meet
the
Tier­
2
standard.
In
general,
increased
precious
metal
loading
(
up
to
a
certain
point)
will
reduce
exhaust
emissions
because
it
increases
the
opportunities
for
pollutants
to
be
converted
to
harmless
constituents.
The
extent
to
which
precious
metal
loading
is
increased
will
be
dependent
upon
the
precious
metals
used
and
other
catalyst
design
parameters.
We
believe
recent
developments
in
palladium/
rhodium
catalysts
are
very
promising
since
rhodium
is
very
efficient
at
converting
NOx,
and
catalyst
suppliers
have
been
investigating
methods
to
increase
the
amount
of
rhodium
in
catalysts
for
improved
NOx
conversion.
(
Mazda,
1998;
Degussa,
1998;
SAE
980666,
980667)

Double
layer
technologies
allow
optimization
of
each
individual
precious
metal
used
in
the
washcoat.
This
technology
can
provide
reduction
of
undesired
metal­
metal
or
metal­
base
oxide
interactions
while
allowing
desirable
interactions.
Industry
studies
have
shown
that
durability
and
pollutant
conversion
efficiencies
are
enhanced
with
double
layer
washcoats.
These
recent
improvements
in
catalysts
can
help
manufacturers
meet
the
Tier­
2
standard
at
reduced
cost
relative
to
older
three­
way
catalysts.

There
is
some
indication
that
palladium/
rhodium
catalysts
are
thermally
more
sensitive
than
other
catalyst
technologies
(
i.
e.,
palladium­
only)
and
would
deteriorate
more
noticeably
with
mileage.
However,
based
on
discussions
with
some
suppliers
and
ARB
test
results
on
automobiles
using
these
catalysts,
we
believe
that
improved
washcoat
designs
(
e.
g.,
double­
layer
washcoats)
will
reduce
thermal
deterioration
on
these
catalysts.

New
washcoat
formulations
are
now
thermally
stable
up
to
1050
o
C.
This
is
a
significant
improvement
from
conventional
washcoats,
which
are
stable
only
up
to
about
900
oC.
With
the
improvements
in
light­
off
capability,
catalysts
may
not
need
to
be
placed
as
close
to
the
engine
as
previously
thought.
However,
if
placement
closer
to
the
engine
is
required
for
better
emission
performance,
improved
catalysts
based
on
the
enhancements
described
above
would
be
more
capable
of
surviving
the
higher
temperature
environment
without
deteriorating.
The
improved
resistance
to
thermal
degradation
will
allow
closer
placement
to
the
engines
where
feasible,
thereby
providing
more
heat
to
the
catalyst
and
allowing
them
to
become
effective
quickly.
­
9
Improved
Catalyst
Light­
off
with
Computer­
Controlled
Secondary
Air
Injection
(
SAI)
and
Retarded
Spark
Timing.
It
is
well
established
that
a
warmed­
up
catalyst
is
very
effective
at
converting
exhaust
pollutants.
Recent
tests
on
advanced
catalyst
systems
in
automobiles
have
shown
that
over
90%
of
emissions
during
the
Federal
Test
Procedure
(
FTP)
are
now
emitted
during
the
first
two
minutes
of
testing
after
engine
start
up.
Similarly,
the
highest
emissions
from
a
motorcycle
occur
shortly
after
start
up.
Although
improvements
in
catalyst
technology
have
helped
reduce
catalyst
light­
off
times,
there
are
several
methods
to
provide
additional
heat
to
the
catalyst.
Retarding
the
ignition
spark
timing
and
computer­
controlled,
secondary
air
injection
have
been
shown
to
increase
the
heat
provided
to
the
catalyst,
thereby
improving
its
cold­
start
effectiveness.
Several
motorcycle
manufacturers
are
investigating
these
techniques
for
application
to
their
vehicles.

Catalyst
System
Changes.
In
addition
to
using
computer­
controlled
SAI
and
retarded
spark
timing
to
increase
the
heat
provided
to
the
catalyst,
some
vehicles
may
employ
warm­
up,
pre­
catalysts
to
reduce
the
size
of
their
main
catalytic
converters.
Palladium­
only
warm­
up
catalysts
(
also
known
as
"
pipe
catalysts"
or
"
Hot
Tubes")
using
ceramic
or
metallic
substrates
may
be
added
to
further
decrease
warm­
up
times
and
improve
emission
performance.
Although
metallic
substrates
are
usually
more
expensive
than
ceramic
substrates,
some
manufacturers
and
suppliers
believe
metallic
substrates
may
require
less
precious
metal
loading
than
ceramic
substrates
due
to
the
reduced
light­
off
times
they
provide.

While
nearly
all
catalysts
in
use
today
are
applied
on
a
honeycomb
substrate,
there
are
new
developments
that
indicate
potential
benefits
from
using
other
substrate
structures
such
as
an
open­
cell
foam.
Ultramet
is
developing
a
silicon
carbide
open­
cell
foam
substrate
for
use
in
catalytic
converters
("
UltraCat").
Its
reported
advantages
include
a
radial
flow
design
(
for
increased
contact
with
the
exhaust
gas),
fast­
lightoff
capability,
uniform
heating
throughout
the
substrate,
high
resistance
to
thermal
degradation,
and
lower
pressure
drop
(
for
minimal
reduction
in
horsepower).
(
SAE
980669)
While
more
work
needs
to
be
done
to
commercialize
this
technology,
our
discussions
with
Ultramet
indicate
that
this
system
has
potential
for
use
in
motorcycles,
which
may
be
realized
over
the
next
ten
years
before
the
Tier­
2
standard
becomes
effective.

Heat­
Optimized
Exhaust
Pipe.
Improving
insulation
of
the
exhaust
system
is
another
method
of
furnishing
heat
to
the
catalyst.
Similar
to
close­
coupled
catalysts,
the
principle
behind
insulating
the
exhaust
system
is
to
conserve
the
heat
generated
in
the
engine
for
aiding
catalyst
warm­
up.
Through
the
use
of
laminated
thin­
wall
exhaust
pipes,
less
heat
will
be
lost
in
the
exhaust
system,
enabling
quicker
catalyst
light­
off.
(
SAE
980937)
As
an
added
benefit,
the
use
of
insulated
exhaust
pipes
will
also
reduce
exhaust
noise.
Increasing
numbers
of
manufacturers
are
expected
to
utilize
air­
gap
exhaust
manifolds
(
i.
e.,
manifolds
with
metal
inner
and
outer
walls
and
an
insulating
layer
of
air
sandwiched
between
them)
for
further
heat
conservation.
­
10
Engine
Calibration
Techniques
Besides
the
hardware
modifications
described
above,
motorcycle
manufacturers
may
borrow
from
other
current
automobile
techniques.
These
include
using
engine
calibration
changes
such
as
a
brief
period
of
substantial
ignition
retard,
increased
cold
idling
speed,
and
leaner
air­
fuel
mixtures
to
quickly
provide
heat
to
a
catalyst
after
cold­
starts.
Only
software
modifications
are
required
for
an
engine
which
already
uses
a
computer
to
control
the
fuel
delivery
and
other
engine
systems.
For
these
engines,
calibration
modifications
provide
manufacturers
with
an
inexpensive
method
to
quickly
achieve
light­
off
of
catalytic
converters.
When
combined
with
pre­
catalysts,
computer­
controlled
SAI,
and
the
other
heat
conservation
techniques
described
above,
engine
calibration
techniques
may
be
very
effective
at
providing
the
required
heat
to
the
catalyst
for
achieving
the
Tier­
2
standard.
These
techniques
are
currently
in
use
on
most
low
emission
vehicle
(
LEV)
automobiles
and
may
have
applications
in
on­
road
motorcycles.

4.
Safety
The
primary
safety
issue
regarding
the
proposed
standards
is
the
safety
of
the
rider
in
close
proximity
to
hot
exhaust
pipes
and
the
catalytic
converter.
Since
the
Tier­
2
standard
will
likely
result
in
the
use
of
catalytic
converters
on
some
motorcycles,
protecting
the
rider
from
excessive
heat
is
a
concern
for
manufacturers.
Reducing
the
temperature
of
exhaust
gases
is
not
desirable,
because
doing
so
will
reduce
the
effectiveness
of
the
catalyst.
Fortunately,
most
solutions
that
address
this
concern
use
relatively
uncomplicated
shielding
approaches.
Examples
include
exterior
pipe
covers
that
slip
over
existing
pipes,
shielded
foot
rests,
and
similar
components.
(
Harley­
Davidson
1998
Parts
Catalog;
U.
S.
Patent#
s
4,023,821;
4,699,232;
4,955,193)
Motorcycle
manufacturers
can
also
take
other
approaches.
Some
manufacturers
currently
place
the
catalytic
converter
under
the
motorbike
to
keep
it
away
from
the
rider.
Other
manufacturers
will
likely
use
double­
pipe
exhaust
systems
that
aim
to
reduce
heat
loss
(
so
the
exhaust
gases
remain
hot
prior
to
reaching
the
catalyst)
while
staying
cooler
on
the
exterior.
(
Japan
Patent#
08082214)
Based
on
these
approaches,
we
conclude
that
problems
with
heat
management
and
rider
safety
are
not
insurmountable
within
the
nine­
year
timeframe
provided.
­
0
VI.

COMMERCIAL
FEASIBILITY
AND
ECONOMIC
IMPACTS
OF
PROPOSED
STANDARDS
We
conducted
an
extensive
impacts
analysis
to
evaluate
the
commercial
feasibility
of
the
proposed
standards
and
their
potential
economic
impacts.
To
meet
the
requirements
of
applicable
statutes,
we
have
organized
this
section
to
summarize
the
economic
impacts;
describe
the
legal
requirements
for
this
analysis;
identify
businesses
potentially
affected;
discuss
the
projected
economic
impacts
on
California
businesses,
consumers,
and
State
or
local
agencies;
and
compare
the
cost­
effectiveness
of
the
proposed
standards
with
other
ARB­
adopted
measures.

1.
Summary
of
Economic
Impacts
Overall,
we
do
not
expect
the
proposed
regulation
to
impose
a
significant
cost
burden
on
motorcycle
manufacturers.
We
expect
the
proposed
two­
tier
standards
will
primarily
impact
six
major
manufacturers
(
BMW,
Harley­
Davidson,
Honda,
Kawasaki,
Suzuki,
and
Yamaha),
all
headquartered
outside
of
California.
Some
manufacturers,
however,
may
have
small
operations
in
California.
There
are
also
very
small,
custom
motorcycle
builders
that
have
total
production
runs
on
the
order
of
100
units
per
year;
at
least
one
of
these
custom
builders
is
located
in
California.

We
estimate
the
average
annual
costs
of
the
proposed
regulation
to
be
around
$
1.4
million
in
2004
and
$
3.2
million
in
2008.
We
expect
these
costs
to
be
passed
on
fully
to
motorcycle
purchasers,
resulting
in
a
0.6
percent
increase
in
2004
in
the
average
retail
price
of
a
motorcycle,
relative
to
the
1998
average
price
of
$
7,600
per
motorcycle.
The
average
retail
price
of
a
1998
motorcycle
is
expected
to
increase
by
1.3
percent
upon
full
implementation
of
the
Tier­
2
standard
in
2008.
A
price
increase
of
this
magnitude
is
generally
not
expected
to
significantly
dampen
the
demand
for
motorcycles.
As
a
result,
we
conclude
that
the
proposed
regulation
will
impose
no
noticeable
adverse
impacts
on
California
competitiveness,
employment,
and
business
status.
Furthermore,
the
proposed
regulation
is
not
a
major
regulation
under
Health
and
Safety
Code
section
57005
because
the
regulation's
impacts
on
California
businesses
do
not
exceed
ten
million
dollars
in
a
single
year.

2.
Legal
Requirements
Section
11346.3
of
the
Government
Code
requires
State
agencies
to
assess
the
potential
for
adverse
economic
impacts
on
California
business
enterprises
and
individuals
when
proposing
to
adopt
or
amend
any
administrative
regulation.
The
assessment
shall
include
a
consideration
of
the
impact
of
the
proposed
regulation
on
California
jobs;
business
expansion,
elimination,
or
creation;
and
the
ability
of
California
businesses
to
compete.
­
1
Also,
section
11346.5
of
the
Government
Code
requires
State
agencies
to
estimate
the
cost
or
savings
to
any
State
or
local
agency
and
school
district
in
accordance
with
instructions
adopted
by
the
Department
of
Finance.
The
estimate
shall
include
any
nondiscretionary
cost
or
savings
to
local
agencies
and
the
cost
or
savings
in
federal
funding
to
the
State.

Health
and
Safety
Code
section
57005
requires
the
ARB
to
perform
a
cost
analysis
of
alternatives
to
the
proposed
regulation
under
specified
circumstances.
The
analysis
is
required
when
the
proposed
regulation
is
a
major
regulation,
which
is
defined
as
a
regulation
that
will
have
a
potential
cost
to
California
business
enterprises
in
an
amount
exceeding
ten
million
dollars
in
any
single
year.

3.
Businesses
Affected
Any
business
involved
in
manufacturing
and
use
of
on­
road
motorcycles
would
potentially
be
affected
by
the
proposed
regulation.
Also
potentially
affected
are
businesses
which
supply
parts
to
these
manufacturers
and
companies
which
sell
or
service
motorcycles
in
California.
The
focus
of
this
analysis,
however,
will
be
on
the
on­
road
motorcycle
manufacturers
because
these
businesses
would
be
directly
affected
by
the
proposed
regulation.
These
manufacturers
are
classified
in
the
industry
identified
by
Standard
Industrial
Classification
(
SIC)
3750
and
new
North
American
Industry
Classification
(
NAICS)
336991.

The
motorcycle
industry
consists
primarily
of
six
major
manufacturers
worldwide.
These
manufacturers
control
over
95
percent
of
the
market
share
in
California;
the
balance
is
controlled
by
a
number
of
small­
volume
manufacturers.
None
of
the
major
manufacturers
is
located
in
California,
although
some
may
have
limited
operations
in
California.
Table
VI.
1
provides
a
list
of
the
major
companies
in
the
motorcycle
industry
along
with
their
respective
1996
U.
S.
market
shares.

Table
VI­
1.
Major
Manufacturers
in
the
Motorcycle
Industry
Company
1996
Market
Share
Honda
29.5%

Harley­
Davidson
25.4%

Kawasaki
14.3%

Yamaha
13.4%

Suzuki
13.4%

BMW
1.5%

All
Others
2.5%

Source:
1997
Motorcycle
Statistical
Annual,
Motorcycle
Industry
Council
Inc.,
Irvine,
­
2
California,
January
1997.

4.
Potential
Impacts
on
California
Businesses
Manufacturers
We
expect
the
proposed
standards
to
impose
additional
costs
on
manufacturers
of
on­
road
motorcycles.
A
detailed
analysis
of
these
costs
is
provided
in
the
section
J
of
this
chapter
(
Cost­
Effectiveness).
The
cost
analysis
shows
that
the
proposed
regulation
will
increase
average
annual
costs
of
manufacturing
motorcycles
by
about
$
1.4
million
when
the
Tier­
1
standard
becomes
effective
in
2004
and
by
$
3.2
million
when
the
Tier­
2
standards
become
effective
in
2008.
The
bulk
of
the
cost
increase
will
be
born
by
a
small
number
of
major
manufacturers.
Under
the
staff's
proposal,
small­
volume
manufacturers
will
be
subject
only
to
the
Tier­
1
standard.
These
smallvolume
manufacturers
are
unlikely
to
spend
any
of
their
own
resources
on
developing
new
technology;
they
are
more
likely
to
rely
on
their
suppliers
for
the
technology
to
comply
with
the
regulation.
Costs
incurred
by
small­
volume
manufacturers
will
principally
be
spent
on
engine
calibration
and
compliance
assurance.

Small­
volume
manufacturers
usually
tend
to
fill
special
niches
in
the
market,
in
which
price
may
not
be
the
primary
factor
to
induce
a
product
sale.
Factors
such
as
a
product's
unique
features
and
superior
service
may
be
more
important
to
customers
than
the
product
price.
In
such
a
market,
because
consumers
are
less
sensitive
to
price
changes,
manufacturers
are
also
likely
to
pass
on
the
cost
increase
to
consumers.
Major
manufacturers
are
also
likely
to
pass
on
the
cost
increase
to
consumers
in
the
long
run
if
they
are
unable
to
lower
their
production
costs.
However,
because
of
the
long
lead
times
involved
(
5
years
for
Tier­
1,
9
years
for
Tier­
2),
it
is
more
likely
that
manufacturers
would
be
able
to
make
the
required
adjustments
cost­
effectively.
As
a
result,
we
do
not
expect
the
regulation
to
have
a
noticeable
adverse
impact
on
affected
major
and
small­
volume
manufacturers.

Aftermarket
Parts
Manufacturers
and
Distributors
There
are
a
number
of
manufacturers
and
distributors
that
specialize
in
aftermarket
parts
for
on­
road
motorcycles,
some
of
which
are
located
in
California.
According
to
the
MIC
1997
Statistical
Annual,
the
on­
road
aftermarket
parts
and
accessories
industry
comprises
a
significant
fraction
of
overall
motorcycle­
related
sales.
Companies
in
this
sector
manufacture
aftermarket
engine
parts,
electronic
control
modules,
exhaust
systems,
and
other
parts
for
both
do­
it­
yourself
(
DIY)
and
original
equipment
manufacturer
(
OEM)
applications;
the
fraction
of
aftermarket
sales
comprising
DIY
versus
OEM
supply
is
unknown
to
staff.

Because
of
the
technologies
we
expect
will
be
used
to
comply
with
the
proposed
standards,
the
staff
proposal
may
impact
the
aftermarket
manufacturers
and
distributors
in
two
ways.
First,
we
anticipate
that
the
original
equipment
manufacturers
(
OEM)
will
use
more
tamper­
resistant
or
more
durable
designs
to
maintain
reduced
emissions
for
the
30,000
km
durability
requirement.
Tamper­
resistant
or
more
durable
designs
may
reduce
demand
for
­
3
aftermarket
parts
intended
to
be
added
by
the
consumer,
thereby
potentially
decreasing
aftermarket
manufacturer
sales.
A
second
potential
impact
may
result
as
aftermarket
parts
manufacturers
incur
costs
when
designing
new
parts
that
will
comply
with
the
staff's
proposed
standards.

To
minimize
these
impacts,
we
have
proposed
the
Tier­
2
standard
at
a
level
which
we
believe
will
address
tampering
by
consumers
(
see
Chapter
IV).
As
discussed
in
section
J
of
this
chapter,
we
believe
the
proposed
0.8
g/
km
HC+
NOx
Tier­
2
standard
will
result
in
catalysts
being
applied
to
a
portion
of
the
market,
while
the
remaining
portion
will
comply
primarily
with
engine
modifications
and
secondary
pulse­
air
injection.
Because
OE
manufacturers
will
be
able
to
sell
both
catalyst
and
non­
catalyst­
based
motorcycles,
aftermarket
parts
manufacturers
will
still
be
able
to
produce
parts
for
both
types
of
motorcycles.
Moreover,
these
manufacturers
will
need
to
design
and
produce
catalyst­
based
parts
for
only
a
portion
of
the
market,
rather
than
all
motorcycles.
Thus,
the
proposed
Tier­
2
standard
should
help
to
minimize
the
costs
incurred
by
aftermarket
parts
manufacturers
and
distributors.

Retailers
We
do
not
expect
retailers
to
be
significantly
affected
by
the
proposed
regulation.
Most
motorcycle
manufacturers
and
distributors
sell
their
products
through
franchised
and
nonfranchised
outlets.
Franchised
outlets
are
engaged
in
selling
new
motorcycles,
scooters,
or
allterrain
vehicles,
while
non­
franchised
outlets
specialize
in
selling
motorcycle­
related
parts,
accessories,
riding
apparel,
used
vehicles
or
service.
(
MIC
1997
Statistical
Annual,
p.
8)
In
1997,
California
had
1,147
motorcycle
retail
outlets,
of
which
293
were
franchised
outlets
and
854
were
non­
franchised
outlets.
(
MIC
1997
Statistical
Annual,
p.
7)

These
outlets
are
not
affected
directly
by
the
proposed
regulation.
However,
they
may
be
impacted
indirectly
by
the
regulation
if
the
increased
price
of
new
motorcycles
reduces
sales
volume,
thereby
resulting
in
a
reduction
of
revenues
for
franchised
outlets.
Non­
franchised
outlets
may
also
experience
a
reduction
in
their
revenues
if
the
regulation
results
in
improved
durability
of
new
motorcycles,
which
would
reduce
the
need
for
services
and
aftermarket
parts.
These
indirect
impacts
are
unlikely
to
be
significant
because
the
regulation
is
expected
to
cause
about
an
overall
1.3
percent
increase
in
the
$
7,600
price
of
an
average
new
1998
motorcycle
upon
full
implementation
in
2008.
(
MIC
1997
Statistical
Annual,
p.
1)
Even
under
a
worst­
case
scenario
where
all
regulatory
costs
are
spread
over
California
sales
instead
of
national
sales
(
i.
e.,
all
manufacturers
produce
a
separate
California
and
49­
state
motorcycle),
we
expect
the
regulation
to
increase
the
average
motorcycle
price
by
only
2.6
percent.
A
price
increase
of
this
magnitude
is
not
expected
to
dampen
the
demand
for
motorcycles
significantly;
indeed,
it
is
generally
recognized
that
price
increases
up
to
10
percent
would
not
significantly
reduce
sales.
(
ACEM
at
48).
­
4
5.
Potential
Impacts
on
Business
Competitiveness
For
various
reasons,
the
proposed
regulation
should
have
no
significant
impacts
on
the
ability
of
California
manufacturers
to
compete
with
manufacturers
of
similar
products
in
other
states.
First,
all
manufacturers
that
produce
motorcycles
for
sale
in
California
are
subject
to
the
proposed
regulation
regardless
of
their
location.
Thus,
manufacturers
in
Japan,
Germany,
or
in
the
U.
S.
all
have
to
meet
the
same
requirements
that
a
California
manufacturer
would
need
to
meet.
Moreover,
none
of
these
major
manufacturers
is
located
in
California,
although
they
may
have
some
operations
in
California.
Finally,
we
expect
the
proposed
standards
to
cause
a
negligible
increase
in
the
retail
price
of
the
average
motorcycle,
which
is
unlikely
to
dampen
the
demand
for
motorcycles
in
California.

6.
Potential
Impacts
on
Employment
California
companies
do
not
manufacture
motorcycles
and
account
for
only
a
small
share
of
manufacturing
employment
for
aftermarket
motorcycle
parts.
According
to
the
U.
S.
Department
of
Commerce,
California
employment
in
the
industry
(
SIC
3750),
which
includes
establishments
primarily
involved
in
manufacturing
motorcycles,
bicycles,
tricycles,
and
similar
equipment
and
parts,
was
slightly
over
2,300
in
1995
or
about
0.1
percent
of
the
total
manufacturing
jobs
in
California.
These
employees
working
in
131
establishments
generated
approximately
$
64
million
in
payroll.
Only
five
establishments
had
between
100
to
500
employees;
the
remainder
had
less
than
100
employees
each.
The
proposed
regulation
is
unlikely
to
cause
a
noticeable
change
in
employment
for
these
manufacturers
because
they
are
likely
to
pass
on
the
bulk
of
the
cost
increase
to
consumers.
A
few
manufacturers
engaged
in
manufacturing
emissions
control
and
fuel
management
components
may
actually
hire
more
employees
if
they
experience
an
increase
in
demand
for
their
products.

According
to
the
Motorcycle
Industry
Council,
there
were
1,141
motorcycle
retail
outlets
in
California,
employing
an
estimated
7,600
employees
with
an
annual
payroll
of
about
$
167
million
in
1997.
(
MIC
1997
Statistical
Annual,
p.
7).
From
earlier
discussions,
we
would
not
expect
these
employees
to
be
adversely
affected
because
a
small
price
increase
is
unlikely
to
dampen
demand
for
motorcycles
in
California.
Therefore,
the
staff's
proposal
should
have
no
noticeable
impact
on
California
employment
because
of
the
marginal
contribution
of
the
industry
to
the
California
economy.

7.
Potential
Impact
on
Business
Creation,
Elimination,
or
Expansion
According
to
the
MIC,
the
California
motorcycle
industry
sold
about
37,500
motorcycles
with
a
retail
value
of
approximately
$
283
million
in
1996.
(
MIC
1997
Statistical
Annual,
p.
6).
The
industry's
contribution
to
the
California
economy
was
estimated
to
be
around
$
950
million,
which
includes
retail
sales
of
motorcycles
(
new
and
used);
parts
and
accessories;
dealer
servicing;
product
advertising;
vehicle
financing
charges;
insurance
premiums;
dealer
personnel
salaries;
state
sales
and
dealer
personal
income
taxes;
and
vehicle
registration
fees.
(
MIC
1997
Statistical
­
5
Annual,
pp.
7­
8).
Although
this
is
a
sizable
industry,
its
contribution
to
the
one
trillion
dollar
California
economy
is
relatively
small.
Moreover,
the
direct
impact
of
the
proposed
regulation
would
be
on
that
part
of
the
industry
which
is
engaged
in
the
manufacturing
of
motorcycles.
These
manufacturers
are
all
located
outside
of
California.
A
few
emissions
control
and
fuel
management
component
manufacturers,
however,
are
located
in
California.
These
manufacturers
may
actually
benefit
from
the
proposed
regulation
if
motorcycle
manufacturers
purchase
more
of
their
products.
This
would,
in
turn,
result
in
an
expansion
of
those
businesses.

As
discussed
earlier,
we
do
not
expect
the
proposed
regulation
to
have
a
noticeable
impact
on
motorcycle
retail
outlets.
We
estimated
the
proposal's
cost
impact
to
be
about
a
1.3
percent
increase
in
the
average
retail
price
of
a
motorcycle
(
relative
to
1998),
which
is
not
expected
to
significantly
dampen
the
demand
for
motorcycles.
As
a
result,
the
proposed
regulation
should
not
cause
a
noticeable
change
in
the
status
of
California
businesses.

8.
Potential
Impacts
on
Consumers
The
potential
impact
of
the
proposed
regulation
on
retail
prices
of
motorcycles
depends
on
the
ability
of
manufacturers
to
pass
on
the
cost
increase
to
consumers.
Assuming
that
manufacturers
are
able
to
pass
on
the
entire
costs
of
compliance
to
motorcycle
purchasers,
staff
estimate
that
the
average
price
of
a
motorcycle
(
relative
to
1998)
would
increase
by
about
$
44
per
bike
when
the
Tier­
1
standard
takes
effect
in
2004
and
by
about
$
97
per
bike
when
the
Tier­
2
standard
take
effect
in
2008.
This
represents
an
average
increase
of
about
1.3
percent
in
the
typical
motorcycle
retail
price
of
about
$
7,600.
(
MIC
1997
Statistical
Annual,
p.
7).
A
price
increase
of
this
magnitude
is
not
expected
to
have
a
significant
impact
on
the
demand
for
motorcycles
in
California.
(
ACEM,
p.
48).

The
price
increase
may
actually
be
negligible
compared
to
the
performance
advantages
that
new
motorcycles
will
offer
to
consumers.
Improved
engine
durability
due
to
engine
modifications
employed
to
meet
the
standards
would
potentially
reduce
the
need
for
parts
and
services,
resulting
in
cost
savings
to
consumers.
Additional
savings
may
also
occur
due
to
the
improvement
in
fuel­
delivery
systems
(
i.
e.,
fuel
injection).

9.
Economic
Impacts
on
California
State
or
Local
Agencies
We
do
not
expect
the
staff's
proposal
to
have
any
impact
on
State
or
local
agencies
because
no
public
agencies
in
the
State
are
involved
in
the
manufacturer
or
sale
of
affected
onroad
motorcycles.
While
various
police
departments
and
the
California
Highway
Patrol
do
purchase
motorcycles
for
official
use,
they
would
not
experience
any
impacts
because
Vehicle
Code
section
27156.2
exempts
vehicles
used
by
peace
officers
from
the
requirement
for
pollution
control
devices.
Thus,
the
regulation
will
not
adversely
impact
State
or
local
agencies.
­
6
J.
Cost­
Effectiveness
of
the
Proposed
Standards
Methodology
and
Assumptions
We
began
our
analysis
by
defining
the
systems
and
technologies
likely
to
be
used
by
manufacturers
to
meet
the
proposed
Tier­
1
and
Tier­
2
limits.
To
do
this,
we
held
discussions
with
engineers
from
the
motorcycle
manufacturers
and
emission
control
suppliers.
We
also
reviewed
the
literature
and
ARB's
motorcycle
certification
database
to
determine
what
technologies
are
in
place
in
current
motorbikes.
Finally,
we
relied
on
ARB's
more
than
20
years
experience
with
automotive
and
motorcycle
emission
controls
and
our
best
engineering
judgment
to
ensure
that
the
assumed
technologies
and
cost
figures
are
realistic.
From
this
process,
we
determined
the
most
likely
emission
control
technologies
that
would
be
needed
to
meet
the
proposed
model
year
2004
and
2008
requirements.

We
should
note
that
some
manufacturers
do
not
entirely
agree
with
the
technologies
or
combination
of
technologies
we
determined
will
help
meet
the
proposed
limits.
However,
our
experience
with
motor
vehicle
manufacturers
generally
shows
that
industry
tends
to
overestimate
the
level
of
technology
and
amount
of
hardware
needed
to
meet
standards
proposed
by
ARB
in
the
past.
(
ARB,
1998c).
During
this
rulemaking,
our
technical
discussions
with
motorcycle
manufacturers
indicated
that
these
companies
may
also
be
overestimating
the
technologies
needed
to
meet
our
proposal.
While
it
is
true
that
some
individual
engine
families
may
be
more
difficult
to
control
than
others,
our
technical
analysis
shows
that
engine
families
in
general
are
similar
enough
to
enable
reasonably
accurate
predictions
as
to
what
technologies
will
be
needed.
Therefore,
the
cost
estimates
shown
in
this
section
represent
our
best
engineering
judgment
and
apply
to
typical
motorcycles
that
need
to
be
modified
to
meet
the
standards;
on
an
individual
basis,
manufacturers
may
experience
higher
or
lower
costs
than
those
shown
here.

In
general,
the
cost
to
manufacturers
for
the
individual
components
in
each
of
the
systems
currently
under
development
are
fairly
well
established.
Once
we
defined
and
determined
the
emission
systems
and
their
costs,
our
assessment
of
non­
hardware
fixed
and
variable
costs
to
manufacturers
becomes
less
clear
since
these
costs
are
closely
guarded
by
individual
manufacturers;
such
costs
may
vary
significantly
within
the
industry.
Besides
the
cost
of
hardware,
the
ARB
staff
considered
additional
variable
costs
including
costs
of
assembly,
shipping
and
warranty.
Further,
fixed
support
costs
(
research,
legal
and
administrative),
investment
recovery
(
machinery
and
equipment
to
manufacture
the
parts,
assembly
plant
changes,
vehicle
development,
and
costs
of
capital
recovery)
and
dealer
costs
(
dealership
operating
costs
and
costs
of
capital
recovery)
were
also
included
in
our
analysis.
Our
estimates
of
these
costs
were
based
on
our
extensive
experience
with
motor
vehicle
regulations
and
confidential
discussions
with
manufacturers
and
suppliers.
­
7
Analysis
In
performing
this
cost
study,
we
departed
from
industry
practice
of
assigning
a
fixed
percentage
of
the
manufacturer's
variable
cost
to
cover
indirect
costs
(
which
include
research,
legal,
and
administrative
costs).
Rather,
we
analyzed
where
such
long
term
costs
would
actually
occur,
at
both
the
manufacturer
and
dealer
levels.
The
reference
vehicles
for
this
cost
study
are
model
year
1998
California
motorcycles
for
which
certification
data
were
available
to
permit
a
detailed
evaluation
of
the
specific
technologies
used.
Our
analysis
evaluated
both
subgroups
comprising
the
Class
III
motorcycle
category
­­
those
with
engine
displacements
between
280
and
699
cc,
and
those
with
engine
displacement
of
700
cc
and
greater.

Tables
VI­
2
thru
VI­
7
provide
additional
information
on
the
cost
figures
and
assumptions
used
in
our
analysis,
which
are
discussed
in
more
detail
as
follows.

Variable
Costs
In
this
section
the
cost
of
new
parts
added,
additional
assembly
operations,
any
increases
in
the
cost
of
shipping
parts
and
any
new
warranty
implications
are
addressed.

Cost
of
Parts:
Proposed
1.4
g/
km
HC+
NOx
Tier­
1
standard
The
California
1998
on­
road
motorcycle
certification
data
indicate
that
the
sales­
weighted
average
emissions
of
class
III
1998
motorcycles
with
engine
displacements
greater
than
700
cc
(
which
constitute
most
of
the
class
III
fleet)
is
approximately
0.9
g/
km
HC,
well
below
the
current
1.4
g/
km
HC­
only
corporate
fleet
average
requirement.
Although
data
regarding
NOx
emissions
associated
with
these
motorcycles
are
scarce,
ARB's
limited
in­
use
testing
data
and
confidential
information
provided
to
the
ARB
by
some
motorcycle
manufacturers
indicate
that
NOx
emissions
are
typically
very
low
relative
to
HC
emissions
for
motorcycles.
Therefore,
we
estimate
that
only
some
harder­
to­
control
motorcycles
would
require
changing
from
a
carbureted
system
to
a
computer­
controlled
fuel
injection
system
in
order
to
meet
the
proposed
standard.

For
motorcycles
which
need
to
be
fitted
with
a
fuel
injection
system,
we
accounted
for
the
costs
associated
with
adding
a
control
computer,
fuel
injectors,
fuel
pump,
pressure
regulator,
airflow
sensor,
crank
position
sensor
and
throttle
position
sensor.
From
these
added
costs,
we
subtracted
the
savings
that
would
result
from
not
installing
a
carburetor
system.
Motorcycles
equipped
with
fuel
injection
systems
are
less
likely
to
be
tampered
with
and,
consequently,
yield
better
emission
performance
relative
to
carbureted
systems.

Other
motorcycles
in
the
certification
database
appear
likely
to
meet
the
proposed
standards
with
only
minor
modifications
to
existing
systems,
with
virtually
no
additional
hardware.
To
be
conservative,
we
assumed
nearly
all
motorcycles
would
employ,
at
a
minimum,
a
simple
pulse­
air
injection
system,
which
involves
a
fresh
air
hose
to
the
exhaust
with
a
check­
valve
to
prevent
backflow.
­
8
Cost
of
Parts:
Proposed
0.8
g/
km
HC+
NOx
Tier­
2
standard
As
noted
previously,
the
0.8
g/
km
HC+
NOx
Tier­
2
proposed
standard
is
based
on
our
expectation
that
about
40%
of
the
market
would
not
need
catalytic
converters
to
meet
the
Tier­
2
standard
(
i.
e.,
they
would
essentially
remain
at
1.0
to
1.4
g/
km
HC+
NOx
levels);
the
remaining
portion
of
the
market
would
then
use
catalytic
converters
and
other
modifications
to
achieve
emissions
down
to
0.4
g/
km
HC+
NOx
levels
or
even
lower.
We
expect
the
overall
result
will
achieve
the
0.8
g/
km
HC+
NOx
level
on
a
corporate
average
basis.
This
is
important
to
note,
since
not
all
on­
road
motorcycles
are
expected
to
incur
the
cost
for
parts
needed
to
meet
the
0.8
g/
km
standard.

For
those
motorcycles
that
will
need
equipment
beyond
the
Tier­
1
level,
our
discussions
with
motorcycle
manufacturers,
component
suppliers,
and
other
industry
experts
indicate
that
such
motorcycles
would
require
either
an
oxidation
catalyst
or,
in
some
cases,
a
three­
way
catalyst
and
a
fuel­
injection
system
to
meet
a
0.8
g/
km
HC+
NOx
standard.
These
motorcycles
would
also
need
to
be
equipped
with
heated
oxygen
sensor(
s)
to
provide
feedback
to
the
fuelinjection
system.
These
sensors
would
be
needed
to
maintain
engine­
out
emissions
close
to
stoichiometric
to
maximize
emission
performance
of
the
three­
way
catalysts.
Some
vehicles
may
also
require
high
cell
density
catalysts
to
meet
emission
targets
and
allow
for
head­
room.
Typically,
catalysts
that
would
be
used
on
motorcycles
are
expected
to
be
metallic
catalysts
(
although
some
catalyst
manufacturers
are
pursuing
ceramic
catalysts
for
motorcycles)
and
are
estimated
to
cost
approximately
$
100
per
liter.
Also,
we
expect
motorcycles
meeting
this
standard
to
use
a
more
sophisticated,
programmed
pulse­
air
system,
in
which
air
flow
to
the
exhaust
system
is
controlled
by
a
solenoid
valve
linked
to
the
engine
computer.

Table
VI­
2
provides
detailed
breakdowns
of
component
usage
and
costs
for
the
emission
control
systems
needed
to
meet
the
staff's
proposal.
The
costs
were
calculated
by
projecting
the
specified
components
over
the
portion
of
the
new
motorcycle
fleet
which
we
believe
would
need
such
equipment.
Since
the
Tier­
1
standard
is
based
primarily
on
non­
catalyst
technologies,
Table
VI­
2
shows
the
added
costs
for
a
fuel
injection
system,
engine
modifications,
and
simple
pulse­
air
injection;
the
cost
savings
from
not
installing
a
carburetor
system
are
also
shown
as
negative
costs.
For
the
Tier­
2
standard,
we
added
the
costs
to
equip
half
of
the
new
motorcycle
fleet
with
heated
oxygen
sensors;
fuel
injection;
three­
way
catalysts;
engine
modifications;
and
computercontrolled
pulse­
air
injection.
We
also
subtracted
the
cost
savings
from
not
installing
two­
way
catalysts
and
carburetors,
as
shown.
­
9
Table
VI­
2.
Component
Costs
to
Comply
with
Staff
Proposal
(
Relative
to
1998
Models)

Tier­
1:
1.4
g/
km
HC+
NOx
Engine
Displacement
280
to
699
cc
Engine
Displacement
>
700
cc
Emission
Control
Technology
Estimated
Cost
($)
[
A]
1998
Use
Rate
(%)
[
B]
Use
Rate
to
meet
Std.
(%)
[
C]
Compnt
Cost
($)
[
D]
Estimated
Cost
($)
[
E]
1998
Use
Rate
(%)
[
F]
Use
Rate
to
meet
Std.
(%)
[
G]
Compnt
Cost
($)
[
H]

Heated
O2
Sensor
12
0
0
0
12
3
3
0
Fuel
Injection
System
(
1)
150
0
28
42
150
15
44
43.50
Carburetor(
s)
108
100
72
­
30.24
108
85
59
­
28.08
Oxidation
Catalyst
20
13
13
0
25
28
28
0
Three­
Way
Catalyst(
s)
27
0
0
0
27
3
3
0
Engine
Modifications
(
2)
0
24
24
0
10
29
100
7.10
Pulse­
Air
(
3)
8
75
100
2
8
33
100
5.36
Total
Incremental
Component
Cost,
$
13.76
27.88
Tier­
2:
0.8
g/
km
HC+
NOx
Engine
Displacement
280
to
699
cc
Engine
Displacement
>
700
cc
Emission
Control
Technology
Estimated
Cost
($)
[
A]
1998
Use
Rate
(%)
[
B]
Use
Rate
to
meet
Std.
(%)
[
C]
Compnt.
Cost
($)
[
D]
Estimated
Cost
($)
[
E]
1998
Use
Rate
(%)
[
F]
Use
Rate
to
meet
Std.
(%)
[
G]
Compnt.
Cost
($)
[
H]

Heated
O2S
(
4)
18
0
100
18
18
3
100
17.46
Fuel
Injection
System
(
5)
150
0
60
90.00
150
15
60
67.50
Carburetor(
s)
108
100
40
­
64.80
108
85
40
­
48.60
Oxidation
Catalyst
20
13
0
­
2.60
25
28
0
­
7
Three­
Way
Catalyst(
s)
(
6)
27
0
60
16.20
53
3
60
30.21
Engine
Modifications
(
7)
0
24
24
0
20
29
100
14.20
Pulse­
Air
(
8)
12
75
100
3
12
33
100
8.04
Total
Incremental
Component
Cost,
$
59.80
81.81
Notes:
Column
[
D]
=
[
A]
x
(([
B]
­
[
C])/
100),
Column
[
H]
=
[
E]
x
(([
F]
­
[
G])/
100)
(
1)
Fuel
injection
system
cost
includes
cost
of
fuel
injector(
s),
ECM,
fuel
pressure
regulator,
higher
pressure
pump,
crank­
position
sensor,
air­
flow
sensor
and
throttle
position
sensor
(
2)
Engine
modifications
could
include
revised
piston
ring
land
height,
revised
head
gaskets
to
reduce
crevice
volumes,
etc.
(
3)
This
system
involves
a
hose
to
the
exhaust
with
a
check
valve
to
prevent
backflow,
plus
a
silencer.
(
4)
We
assumed
half
of
new
motorcycles
would
use
two
oxygen
sensors
(
one
for
each
bank),
while
remainder
would
use
one
sensor;
estimated
cost
for
each
sensor
is
$
12.
(
5)
Fuel
injection
system
cost
includes
cost
of
fuel
injector(
s),
ECM,
fuel
pressure
regulator,
higher
pressure
pump,
crank­
position
sensor,
air­
flow
sensor
and
throttle
position
sensor
(
6)
High
cpsi
advanced
catalyst;
we
assumed
catalyst
volume
of
40%
engine
displacement
for
280­
669cc
(
sales­
wtd
avg.
600cc)
and
70%
engine
displacement
for
>
700cc
(
sales­
wtd
avg.
1200cc),
catalyst
cost
of
$
100/
liter.
(
7)
Engine
modifications
could
include
reduced
crevice
volumes,
changes
for
greater
cylinder
mixing,
dual
spark
plugs,
etc.
­
10
(
8)
More
sophisticated
pulse­
air
injection
where
air
injection
is
computer
controlled
by
solenoid
valve
linked
to
the
ECM.

Cost
of
Assembly,
Shipping,
&
Warranty
Installation
of
fuel
injection
and
a
pulse
air
system
would
require
additional
assembly
time
and
would
result
in
additional
labor
costs.
We
estimated
it
would
take
an
additional
three
minutes
to
install
the
fuel
injection
system
during
production,
including
the
additional
sensors,
and
an
additional
minute
to
install
the
pulse
air
system.
The
additional
assembly
costs
were
estimated
using
a
labor
cost
of
$
60
per
hour.

Those
motorcycles
equipped
with
fuel
injection
system
and
catalysts
would
also
incur
additional
shipping
costs.
The
cost
was
estimated
to
be
approximately
$
2.00
for
all
of
the
additional
components
of
a
fuel
injection
system
and
$
1.00
for
a
catalyst
system.

Motorcycles
will
increasingly
use
fuel
injection
strategies
to
meet
the
proposed
standards.
ARB
staff
believe
that
motorcycles
utilizing
fuel
injection
systems
are
less
prone
to
warranty
problems
when
compared
to
today's
carbureted
systems.
We
therefore
believe
fuel
injection
systems
will
provide
an
overall
cost
savings
under
this
category.
Further,
manufacturers
that
use
catalysts
to
meet
the
standards
are
not
expected
to
incur
any
significant
additional
warranty
costs,
since
currently
available
catalyst
technology
has
been
demonstrated
to
be
durable
well
beyond
the
30,000
km
useful
life
specified
for
on­
road
motorcycles.

Support
(
Fixed)
Costs
Support
costs
affecting
the
retail
price
of
meeting
new
emission
requirements
include
research
costs,
legal
coverage
for
new
issues,
and
administrative
increases.

Research
Costs
Manufacturers
have
until
2003
to
meet
the
proposed
1.4
g/
km
standard
and
until
2008
to
meet
the
0.8
g/
km
standard.
Providing
a
long
lead­
time
permits
considerable
cost
savings
for
industry.
Incorporation
of
the
required
changes
can
take
place
systematically
within
the
existing
new
motorcycle
development
process
without
incurring
redesign
to
accommodate
unplanned
revisions
due
to
frequently
changing
emission
requirements.

Despite
the
cost
savings
permitted
by
setting
long
range
standards,
allocation
of
some
additional
cost
to
manufacturers
for
performing
advance
system
development
work
is
justified
when
engineering
new
types
of
technologies.
Consequently,
we
added
development
costs
that
include
personnel,
overhead
and
other
miscellaneous
costs
for
new
technologies
such
as
fuel
injection
systems
and
advanced
three­
way
catalysts.
Allowance
was
also
made
for
the
cost
of
a
fleet
of
advanced­
development
motorcycles
for
use
as
technology
test­
beds.
Each
motorcycle
used
for
advanced­
development
research
was
assumed
to
cost
$
40,000.
Details
of
this
assessment
are
shown
in
Table
VI­
3.
It
is
common
industry
practice
to
assign
development
costs
of
new
technologies
over
the
entire
product
line
(
rather
than
just
the
products
on
which
the
technology(
ies)
is
used)
and
to
recoup
these
over
a
reasonable
period
of
time.
Therefore,
for
the
purpose
of
this
study,
the
costs
incurred
under
this
category
were
distributed
over
15,000
vehicles
per
year
(
which
is
the
typical
national
volume
for
most
major
motorcycle
manufacturers)
for
a
total
of
15
years.
­
11
Table
VI­
3.
Estimated
Advanced
Vehicle
Technology
Research
Costs
(
1)

Engineering
Staff
for
Technology
Development
Engineering
Staff
Cost
(
2)
Development
Motorcycles
Cost
(
3)
Additional
Equipment
(
4)
Cost
per
Vehicle
(
5)
Emission
Control
Technology
(
person­
yrs)
[
A]
(
person­
hrs)
[
B]
(
in
$)
[
C]
(
in
$)
[
D]
(
in
$)
[
E]
($/
vehicle)
[
F]

3­
way
catalyst
evaluation
4
8320
499,200
120,000
50,000
2.97
Fuel­
injection
strategies
4
8320
499,200
120,000
50,000
2.97
Engine
modifications
4
8320
499,200
120,000
50,000
3.29
Total
9.23
Notes:
[
F]
=
([
C]
+
[
D]
+
[
E])/(
15,000
bikes/
yr
x
15
yr);
[
C]
=
[
B]
x
$
60/
hr;
[
B]
=
[
A]
x
8
hr/
day
x
260
day/
yr
(
1)
For
advance
engineering
work
in
contrast
to
vehicle
calibration
or
certification
work
(
2)
Development
cost
includes
personnel,
overhead
and
other
miscellaneous
costs
at
a
total
rate
of
$
60/
hr.
(
3)
Cost
distributed
over
15,000
vehicles
per
year
for
total
of
15
years.
(
4)
Cost
added
to
cover
new
test
equipment,
prototype
parts,
and
emissions
testing
costs.

Legal
and
Administrative
Costs
The
technologies
for
meeting
the
staff's
proposal
are
essentially
motorcycle
applications
of
automotive
technologies
that
have
been
in
use
for
almost
two
decades.
Because
these
systems
are
relatively
well
understood,
it
is
reasonable
to
assume
that
the
most
likely
hardware
to
be
used
for
meeting
the
standards
will
not
introduce
liability
issues
or
administrative
cost
increases.
Consequently,
no
extra
costs
under
this
category
have
been
included.

Investment
Recovery
This
portion
of
the
cost
analysis
includes
accounting
for
machinery
and
equipment
to
manufacture
parts,
assembly
plant
changes
(
automation),
vehicle
development
(
engineering),
and
the
cost
of
capital
recovery.

Machinery
and
Equipment
to
Manufacture
Parts
Because
virtually
all
of
the
new
components
will
be
produced
by
suppliers,
the
costs
of
machinery
and
equipment
to
manufacture
the
parts
needed
to
meet
the
standards
are
already
included
in
the
component
costs.
­
12
Assembly
Plant
Changes
(
Automation)

The
primary
changes
from
an
assembly
point
of
view
are
in
the
exhaust
system
configuration.
Because
exhaust
systems
are
usually
installed
as
an
assembly,
current
assembly
plant
operations
should
not
be
affected
by
the
use
of
exhaust
systems
designed
to
meet
the
standards.

Vehicle
Development
Once
the
vehicle
development
program
is
transferred
from
the
advanced
engineering
team,
calibration
and
certification
engineers
complete
the
emission
control
system
design
process.
We
added
motorcycle
development
costs
for
the
facility,
equipment
and
personnel
for
an
additional
motorcycle
dynamometer,
as
shown
in
Table
VI­
4.
Such
equipment
would
be
used
for
the
optimization
of
fuel
injection
systems
and
three­
way
catalysts
on
new
model
motorcycles.
We
again
amortized
these
costs
over
15,000
motorcycles
per
year
for
15
years.

Table
VI­
4.
Estimated
Vehicle
Development
Costs
(
1)

Engineering
Staff
for
Vehicle
Development
Engineering
Staff
Cost
(
2)
Facility
Cost
Additional
Equipment
(
3)
Cost/
Vehicle
(
4)

Facility
(
person­
yrs)
[
A]
(
person­
hrs)
[
B]
(
in
$)
[
C]
(
in
$)
[
D]
(
in
$)
[
E]
(
in
$/
vehicle)
[
F]

Motorcycle
Dynamometer
3
6240
374,400
200,000
100,000
3.00
Total
3.00
Notes:
[
F]
=
([
C]
+
[
D]
+
[
E])/(
15,000
bikes/
yr
x
15
yr);
[
C]
=
[
B]
x
$
60/
hr;
[
B]
=
[
A]
x
8
hr/
day
x
260
day/
yr
(
1)
For
vehicle
calibration
or
certification
effort
(
2)
Development
cost
includes
personnel,
overhead
and
other
miscellaneous
costs
at
a
total
rate
of
$
60/
hr.
(
3)
Cost
distributed
over
15,000
vehicles
per
year
for
total
of
15
years.
(
4)
Additional
equipment
cost
covers
more
sophisticated
emission
measurement
equipment
and
emission
testing
costs.

Capital
Recovery
The
cost
of
capital
recovery
(
return
on
investment)
was
calculated
at
six
percent
of
the
total
costs
to
the
manufacturer.
At
least
one
large­
volume
automobile
manufacturer
employs
such
an
approach
to
calculate
the
cost
of
capital
recovery.
Table
VI­
5
shows
the
staff's
estimated
cost
of
capital
recovery
based
on
this
methodology.

Table
VI­
5.
Estimated
Capital
Recovery
Costs
Capital
Recovery
(
6%
of
Total
Manufacturer
Costs),
in
dollars
Engine
Displacement
(
280
to
699
cc)
Engine
Displacement
(>
700
cc)

Tier­
1
1.65
2.50
­
13
Capital
Recovery
(
6%
of
Total
Manufacturer
Costs),
in
dollars
Tier­
1
4.32
5.64
Dealer
Costs
Dealership
costs
include
accounting
for
operating
costs
and
the
cost
of
capital
recovery.
Since
the
price
of
the
motorcycle
would
likely
increase
due
to
the
proposed
standards,
it
is
appropriate
to
account
for
the
additional
interest
that
the
dealer
would
pay
for
financing
the
cost
of
the
motorcycle
and
to
cover
the
commission
sales
persons
will
receive
as
well.
An
interest
rate
of
six
percent
was
assumed
on
the
incremental
cost,
and
on
average,
motorcycles
were
presumed
to
remain
in
the
dealership
inventory
for
one
quarter.
The
increased
commission
paid
to
sales
persons
was
calculated
at
three
percent
of
the
differential
wholesale
price.
Dealer
costs
based
on
these
assumptions
are
shown
in
Table
VI­
6.

Table
VI­
6.
Estimated
Dealer
Costs
Operating
Cost
(
in
$)
Cost
of
Capital
Recovery
(
in
$)

Engine
280
to
699
cc
Engine
>
700
cc
Engine
280
to
699
cc
Engine
>
700
cc
Tier­
1
0.87
1.32
0.45
0.68
Tier­
2
2.29
2.99
1.55
1.19
Incremental
Cost
of
the
Proposed
Standards
For
each
proposed
HC+
NOx
standard,
the
incremental
cost
is
the
sum
of
the
individual
variable,
support,
investment
recovery,
and
capital
recovery
costs
for
the
manufacturer
plus
the
dealership
costs.
Tables
VI­
7
shows
the
incremental
costs
to
the
consumer
of
the
proposed
1.4
g/
km
and
0.8
g/
km
standards,
respectively;
incremental
costs
shown
are
relative
to
a
new
1998
motorcycle.
­
14
Table
VI­
7.
Incremental
Cost
of
Staff
Proposal
Over
Cost
of
Current
Standard
Tier­
1
Compliance
Level:
1.4
g/
km
HC+
NOx
Cost
(
in
$)

Type
of
Cost
Specific
Engine
280
to
699
cc
Engine
>
700
cc
Manufacturer
Variable
Costs
Components
Assembly,
Warranty,
Shipping
13.76
3.00
27.88
3.00
Manufacturer
Support
Costs
Research
Legal,
Administrative
9.23
0.00
9.23
0.00
Manufacturer
Investment
Recovery
Costs
Machinery
&
Equipment
Assembly
Plant
Changes
Vehicle
Development
0.00
0.00
1.50
0.00
0.00
1.50
Manufacturer
Capital
Recovery
Costs
N/
A
1.65
2.50
Dealership
Costs
Operating
Costs
Capital
Recovery
0.87
0.45
1.32
0.68
Total
Incremental
Cost
to
Consumer,
$
30.46
46.11
Tier­
2
Compliance
Level:
0.8
g/
km
HC+
NOx
Cost
(
in
$)

Type
of
Cost
Specific
Engine
280
to
699
cc
Engine
>
700
cc
Manufacturer
Variable
Costs
Components
Assembly,
Warranty,
Shipping
59.80
7.00
81.81
7.00
Manufacturer
Support
Costs
Research
Legal,
Administrative
9.23
0.00
9.23
0.00
Manufacturer
Investment
Recovery
Costs
Machinery
&
Equipment
Assembly
Plant
Changes
Vehicle
Development
0.00
0.00
3.00
0.00
0.00
3.00
Manufacturer
Capital
Recovery
Costs
N/
A
4.32
5.64
Dealership
Costs
Operating
Costs
Capital
Recovery
2.29
1.19
2.99
1.55
Total
Incremental
Cost
to
Consumer,
$
75.65
99.68
Note:
Sales­
weighted
Average
(
SWA)
Incremental
Cost
Increase
=
(
Inc.
Cost
280­
699cc)*(
0.10)+(
Inc.
Cost
700cc+)*(
0.90)
Example:
SWA
Incremental
Cost
to
Consumer
for
Tier­
2
=
(
75.65)*(
0.10)+(
99.68)*(
0.90)
=
97
Cost­
effectiveness
of
Proposed
Motorcycle
Standards
Summary
To
determine
the
proposal's
cost­
effectiveness,
we
first
calculated
the
exhaust
emission
benefits
of
the
proposed
motorcycle
standards
(
relative
to
the
corresponding
1998
California
motorcycle)
using
the
EMFAC7G
emission
model.
We
then
calculated
the
cost­
effectiveness
by
dividing
the
total
incremental
cost
to
the
consumer
by
the
total
ROG
and
NOx
emission
reductions.
As
shown
in
Table
VI­
10,
the
estimated
overall
cost­
effectiveness
ranges
from
about
­
15
$
3
per
pound
to
about
$
5.60
per
pound
of
HC
and
NOx
reduced,
which
compares
favorably
with
other
ARB­
adopted
emission
control
measures.
Cost­
effectiveness
of
a
California­
only
0.8
g/
km
Motorcycle
In
performing
the
cost
analysis,
we
assumed
that
each
manufacturer
would
produce
a
"
national"
motorcycle
meeting
a
0.8
g/
km
HC+
NOx
standard
(
i.
e.,
a
50­
state
motorcycle)
rather
than
a
California­
only
motorcycle
meeting
the
0.8
g/
km
standard
in
2008.
This
assumption
is
reasonable
for
most
cases
because
the
production
of
a
50­
state
motorcycle
helps
to
achieve
economies
of
scale
by
distributing
the
costs
over
a
larger
fleet,
thereby
reducing
the
cost
increases
on
individual
motorcycles.
Similarly,
the
automobile
industry
agreed
to
produce
a
"
national
LEV,"
resulting
in
50­
state
vehicles
that
were
only
slightly
higher
in
cost
than
LEV­
Tier
I
vehicles,
while
still
providing
significant
emission
reductions.
We
believe
that
such
an
approach
would
not
only
allow
manufacturers
to
meet
the
0.8
g/
km
standard
in
a
cost­
effective
manner,
but
it
would
also
contribute
to
California's
air
quality
by
alleviating
the
traditional
concerns
of
migration
of
non­
California­
compliant
motorcycles
from
other
states
to
California,
either
permanently
or
due
to
tourism.

On
the
other
hand,
some
manufacturers
believe
that
a
0.8
g/
km
standard
could
cause
manufacturers
to
produce
California­
only
and
49­
state
motorcycles.
To
determine
the
impacts
to
the
proposal's
cost­
effectiveness
under
such
a
"
worst­
case"
scenario,
we
performed
a
separate
analysis
using
the
total
incremental
cost
to
the
consumer
of
a
California­
only
0.8
g/
km
motorcycle.
In
that
analysis,
we
estimated
that
the
incremental
hardware
cost
would
double
to
account
for
California
production
volumes
being
significantly
smaller
than
national
volumes.
Also,
the
research
and
vehicle
development
costs
were
amortized
over
a
California
volume
instead
of
over
a
national
volume.
Under
this
scenario,
we
estimated
the
incremental
cost
to
consumers
of
a
California­
only
0.8
g/
km
motorcycle
standard
to
be
$
200,
with
a
corresponding
costeffectiveness
of
$
5.60
per
pound
of
HC
and
NOx
emissions
reduced.
Thus,
even
under
a
worstcase
scenario,
the
cost­
effectiveness
of
the
proposal
is
still
of
the
same
order
of
magnitude
as
other
recently
adopted
emission
control
measures.
­
1
VII.

ENVIRONMENTAL
IMPACTS
OF
PROPOSED
AMENDMENTS
1.
Projected
Benefits
It
is
well
established
that,
for
California,
reductions
in
hydrocarbon
(
HC)
and
oxides
of
nitrogen
(
NOx)
emissions
will
lower
ambient
ozone
levels.
(
Note:
for
purposes
of
this
discussion,
HC
is
equivalent
to
"
reactive
organic
gas"
or
ROG).
Hydrocarbons
and
NOx
also
undergo
transformations
in
the
air
to
form
particulate
matter
(
PM).
Therefore,
the
staff's
proposal
to
reduce
HC
and
NOx
levels
from
motorcycles
will
provide
environmental
benefits
primarily
from
the
reduction
of
ozone
and
PM.

California's
plan
for
achieving
the
one­
hour
federal
ambient
ozone
standard
is
contained
in
the
State
Implementation
Plan
for
Ozone
(
ozone
SIP),
approved
by
the
Board
in
1994.
In
essence,
the
ozone
SIP
contains
all
the
measures
and
commitments
which,
collectively,
would
reduce
ozone
precursor
emissions
to
the
levels
needed
to
attain
the
ozone
standard.
For
the
South
Coast
Air
Basin
(
SoCAB),
in
addition
to
the
specific
measures
defined
in
the
ozone
SIP,
additional
emission
reductions
of
approximately
75
tons
per
day
(
tpd)
of
ROG
and
NOx
are
needed
to
attain
the
1­
hour
federal
ozone
standard.
These
additional
emission
reductions
are
often
referred
to
as
the
mobile
source
"
black
box."
The
staff's
proposed
amendments
will
help
cover
shortfalls
in
defined
ARB
measures
and
make
progress
toward
the
black
box.

Although
the
SoCAB
is
the
only
area
in
the
State
with
a
black
box,
the
emission
reductions
from
the
staff's
proposal
are
needed
statewide.
The
proposed
on­
road
motorcycle
amendments
will
help
achieve
and
maintain
the
federal
1­
hour
ozone
standard
in
regions
such
as
the
San
Joaquin
Valley
and
the
Sacramento
area;
the
federal
8­
hour
ozone
and
particulate
matter
standards
in
a
number
of
areas;
and
the
State
ozone
and
particulate
matter
standards
throughout
California.

In
the
current
official
inventory
for
2010,
statewide
on­
road
motorcycle
emissions
account
for
14.5
tpd
of
ROG
and
NOx
emissions,
as
shown
in
Table
VII­
1.
Under
the
1994
SIP,
on­
road
motorcycles
account
for
6.29
tpd
of
ROG
and
NOx
emissions
in
the
SoCAB.
However,
ARB
has
continued
to
improve
the
inventory
through
surveys,
emissions
testing,
and
updated
usage
data
provided
by
industry
representatives.
As
seen
in
the
table,
the
staff's
current
updated
estimates
for
statewide
and
SoCAB
2010
motorcycle
emissions
are
lower
than
the
official
inventories
for
that
year.
These
changes
are
due
to
revised
activity
data
and
emission
factors.
­
2
Table
VII­
1.
2010
On­
Road
Motorcycle
Statewide
&
SoCAB
Emission
Inventories
(
TPD)

Statewide
Inventory
ARB
Staff­
Updated
Estimate*

Pollutant
Current
Official
Inventory
Baseline
With
Staff
Proposal
ROG
(
HC)
9.6
4.6
3.8
NOx
4.9
3.1
2.6
SoCAB
Inventory
ARB
Staff­
Updated
Estimate*

Pollutant
Current
Official
Inventory
Baseline
With
Staff
Proposal
ROG
(
HC)
4.2
1.9
1.6
NOx
2.1
1.3
1.1
*
Based
on
refinements
to
the
inventory
using
updated
data
from
the
MIC;
DMV
registrations;
updated
parameters
from
EMFAC7X;
and
data
from
ARB
testing,
certification,
and
current
surveillance
project.

Table
VII­
2
shows
the
estimated
statewide
and
SoCAB
emission
benefits
from
this
rulemaking.
Using
the
emission
model
EMFAC7G
as
modified
with
revised
activity
data
(
MIC,
March
1998)
and
emission
factors,
we
project
the
new
standards
will
reduce
statewide
HC+
NOx
emissions
by
1.3
tpd
in
2010
and
by
2.9
tpd
in
2020.
Similarly,
we
project
the
new
standards
will
reduce
SoCAB
HC+
NOx
emissions
by
0.47
tpd
in
2010
and
1.0
tpd
in
2020.
The
higher
emission
benefits
in
the
long­
term
reflect
the
relatively
long
lifetime
of
motorcycles
(
estimated
at
14
years)
and
the
resulting
low
turnover;
therefore,
we
do
not
project
full
fleet
turnover
to
the
Tier­
2
standard
until
around
2020.
These
new
reductions
would
help
cover
shortfalls
in
defined
ARB
measures
and
make
progress
toward
the
black
box.

Table
VII­
2.
Projected
Tier­
1
and
Tier­
2
HC+
NOx
Emission
Benefits
Statewide
Reductions,
TPD
SoCAB
Reductions,
TPD
Pollutant
Year
=
2010
2020
2010
2020
HC
0.85
2.0
0.30
0.71
NOx
0.48
0.91
0.17
0.32
Basis:
modified
EMFAC7G,
assumes
34%
tampering
rate
(
MIC,
8/
98)

2.
Potential
Mitigating
Factors
The
MIC
claims
that
standards
which
force
the
widespread
use
of
catalytic
converters
will
reduce
or
even
negate
the
projected
emission
reductions
because
of
resultant
consumer
tampering
and
migration/
tourism
of
49­
state
motorcycles
into
California.
Given
the
incomplete
data
on
these
activities,
it
is
difficult
to
project
with
any
certainty
what
effects
they
may
have
on
the
staff
­
3
proposal's
benefits.
However,
as
discussed
in
Chapters
V
and
VI,
we
do
not
expect
our
proposal
to
result
in
the
widespread
use
of
catalysts;
rather,
we
expect
catalysts
will
be
used
only
in
selected
product
lines
to
the
extent
necessary
under
the
corporate
averaging
provision.
Thus,
our
proposal
should
minimize
whatever
mitigating
impacts
these
activities
may
have,
if
any.

Tampering.
The
MIC
provided
data
from
tampering
surveys
it
conducts
every
five
years.
(
MIC,
August
1998).
Because
they
were
designed
to
address
noise
ordinances,
the
surveys
provide
data
pertaining
only
to
the
tampering
of
exhaust
equipment
(
primarily
the
removal
or
replacement
of
mufflers)
and
therefore
give
an
incomplete
picture
of
typical
tampering
and
its
effects.
Even
with
this
limitation,
the
surveys
do
suggest
that
tampering
rates
may
be
on
the
order
of
34%
(
i.
e.,
34
out
of
every
100
motorcycle
riders
across
the
U.
S.
have
tampered
with
their
exhaust
equipment).
The
MIC
believes
that
such
surveys,
and
its
experiences
with
consumers,
suggest
tampering
which
affects
emission
levels
may
be
an
intractable
problem.
(
MIC,
October
1998b)
Indeed,
the
MIC
believes
that
emission
standards
which
force
manufacturers
to
install
catalytic
converters
on
all
or
nearly
all
motorcycles
will
exacerbate
current
tampering
rates,
i.
e.,
riders
will
more
likely
modify
their
vehicles
to
remove
the
catalysts
for
"
improved"
performance.

We
strongly
disagree
that
tampering
is
necessarily
an
intractable
problem.
As
we
noted
in
Chapter
II,
on­
road
motorcycles
are
currently
exempt
from
the
regular
inspection
and
maintenance
(
I&
M
or
"
Smog
Check")
requirements
that
apply
to
automobiles
and
other
vehicles.
While
tampering
that
affects
the
emission
levels
is
already
prohibited
under
existing
California
law
(
Vehicle
Code
27156),
enforcement
of
those
requirements
is
limited.
Thus,
one
cannot
conclude
that
tampering
is
an
inherent
and
intractable
activity
associated
with
motorcycles;
indeed,
it
is
more
likely
that
tampering
rates
are
inversely
proportional
to
the
level
of
enforcement,
and
that
improved
monitoring
of
the
emissions
control
equipment
installed
by
the
manufacturers
would
significantly
reduce
tampering
rates.

At
current
enforcement
levels,
motorcycles
are
essentially
at
the
same
state
that
automobiles
were
in
when
computerized
controls
and
catalysts
were
first
placed
on
cars.
At
that
time,
car
owners
also
tampered
with
the
emission
controls
in
the
mistaken
belief
that
improved
performance
would
result.
However,
our
experience
shows
that,
as
consumers
acclimated
to
the
new
technologies,
tampering
became
limited
to
certain
sectors
of
the
population.
In
addition,
as
engine
systems
become
more
"
high­
tech"
and
optimized
with
emission
controls
(
and
improved
performance),
whatever
performance
benefits
consumers
perceive
from
tampering
should
decrease.
Based
on
our
experiences
with
automobiles,
we
expect
that
the
majority
of
motorcycle
riders
will
become
accustomed
to
emission
controls,
resulting
in
decreased
tampering
rates
and
improved
effectiveness
of
the
staff's
proposal
over
time.
Moreover,
improved
consumer
education
or
enforcement
of
anti­
tampering
requirements
should
help
consumers
to
better
understand
the
purpose
and
benefits
of
the
emission
controls.
As
we
discuss
in
Chapter
X,
we
will
be
working
with
the
MIC
and
other
stakeholders
to
determine
the
best
methods
to
improve
consumer
education
and
reduce
tampering
rates.
­
4
Finally,
it
is
important
to
note
that
the
emission
benefits
we
project
for
this
rulemaking
already
incorporate
the
34%
tampering
rate
cited
by
the
MIC.
While
the
MIC's
survey
data
is
inconclusive
with
regard
to
engine
systems
tampering,
we
incorporated
the
34%
tampering
rate
in
our
projections
to
be
conservative.
Thus,
even
if
we
assume
that
tampering
affects
emission
levels
in
proportion
to
the
documented
tampering
rates,
we
still
project
the
staff
proposal
will
achieve
emission
reductions
that
will
help
ensure
continued
progress
toward
meeting
the
State
and
federal
air
quality
standards.

Migration
&
Tourism.
The
MIC
also
claims
that
migration
and
tourism
of
49­
state
motorcycles
into
California
will
offset,
to
a
large
degree,
the
emission
reductions
from
standards
that
force
the
widespread
use
of
catalytic
converters.
(
MIC,
Sept.
1998;
MIC,
Oct.
1998b)
Essentially,
the
MIC
believes
that
catalyst­
forcing
standards
will
result
in
a
bifurcation
of
motorcycle
production,
with
manufacturers
making
separate
lines
of
California­
only
and
49­
state
motorcycles.
Consequently,
49­
state
motorcycles
(
with
their
higher
allowable
emissions)
will
impact
the
projected
benefits
from
staff's
proposal,
either
by
migrating
into
California
or
from
temporary
visits.

While
the
exact
impacts
migration
and
tourism
may
have
on
overall
emission
levels
are
unclear,
we
believe
our
proposal
will
minimize
whatever
impacts
such
activities
may
have,
if
any.
As
stated
previously,
the
staff's
proposal
does
not
require
the
widespread
use
of
advanced
catalysts,
but
rather
should
result
in
the
use
of
catalysts
only
on
selected
product
lines.
Because
of
this,
we
believe
that,
for
most
manufacturers,
a
fully
bifurcated
California­
only
versus
49­
state
motorcycle
production
scenario
is
unlikely.
Thus,
our
proposal
should
reduce
the
potential
for
49­
state
motorcycles
to
adversely
impact
statewide
emission
levels
through
migration
or
tourism.

Current
ARB
certification
data
and
established
economic
principles
also
support
this
belief.
According
to
the
1998
certification
database,
some
manufacturers
produce
California­
only
and
49­
state
motorcycles,
while
others
produce
50­
state
motorcycles.
Manufacturers
who
currently
produce
50­
state
motorcycles
do
so
even
though
the
existing
California
emission
standards
are
3
to
5
times
more
stringent
than
the
current
federal
5
g/
km
HC­
only
standard.
(
See
Title
40,
Code
of
Federal
Regulations,
Part
86,
Subpart
E).
The
fact
that
these
manufacturers
produce
a
50­
state
motorcycle
despite
the
difference
in
State
and
federal
emission
requirements
strongly
suggests
there
are
significant
economic
advantages
to
producing
a
50­
state
motorcycle
(
e.
g.,
economies
of
scale,
reduced
distribution
costs,
production
uniformity).
We
expect
the
economic
advantages
from
producing
a
uniform,
50­
state
motorcycle
will
remain
in
effect
for
manufacturers
under
the
staff's
proposal.
­
1
VIII.

ANALYSIS
OF
REGULATORY
ALTERNATIVES
Health
and
Safety
Code
section
57005
requires
the
ARB
to
perform
a
cost
analysis
of
alternatives
to
the
proposed
regulation
under
specified
circumstances.
The
analysis
is
required
when
the
proposed
regulation
is
a
major
regulation,
which
is
defined
as
a
regulation
that
will
have
a
potential
cost
to
California
business
enterprises
in
an
amount
exceeding
ten
million
dollars
in
any
single
year.
As
discussed
in
Chapter
VI,
we
determined
that
the
annual
cost
of
the
staff's
proposal
will
be
approximately
$
1.3
million
in
2004
and
$
3.2
million
in
2008.
Thus,
the
staff's
proposal
is
not
a
major
regulation
under
Health
and
Safety
Code
section
57005.
Nevertheless,
we
recognize
the
importance
of
evaluating
alternatives
to
the
proposal
which
can
achieve
equivalent
reductions
within
the
same
timeframe
and
at
equal
or
less
cost
than
the
staff's
proposal.
We
therefore
considered
the
following
regulatory
alternatives
to
the
proposed
amendments.
Compared
to
these
alternatives,
our
current
proposal
represents
a
fair
and
workable
approach
to
achieving
significant
emission
reductions
with
reasonable
costs
to
industry
and
consumers.

1.
Adopt
No
New
Standards
As
discussed
previously,
essentially
all
possible
control
measures
which
the
ARB
determines
are
technologically
and
commercially
feasible
must
be
implemented
to
meet
the
SIP
requirements.
A
commitment
to
amend
the
current
on­
road
motorcycle
regulation
was
not
a
formal
part
of
the
SIP
when
it
was
adopted
in
1994,
primarily
because
the
ARB
believed
at
that
time
that
sufficient
reductions
could
be
achieved
from
the
commitments
already
in
the
SIP.
However,
we
have
subsequently
determined
that
additional
control
measures
need
to
be
implemented
in
order
to
meet
the
SIP
commitments
and
contribute
to
achieving
other
air
quality
standards.
This
is
especially
true
for
meeting
the
so­
called
SIP
"
black
box"
commitment.
Lowering
the
on­
road
motorcycle
emission
standards
will
help
fulfill
that
commitment.
Without
the
emission
reductions
to
be
achieved
with
the
proposed
standards,
the
SIP
requirements
will
either
not
be
met
or
will
need
to
be
achieved
at
the
expense
of
other
vehicular
categories.

From
an
equity
standpoint,
amending
the
existing
motorcycle
limits
as
staff
proposes
will
bring
this
segment
of
the
motor
vehicle
industry
up
to
date
with
technological
improvements
that
have
been
used
extensively
by
automobiles,
trucks,
and
other
motor
vehicles
for
many
years.
It
is
important
to
recall
that
the
original
motorcycle
regulation
was
adopted
in
the
late
1970s
and
was
last
amended
in
1984.
Since
then,
automobiles
and
other
motor
vehicles
have
been
required
to
use
cutting­
edge
emission
control
technologies.
Thus,
we
believe
it
is
appropriate
to
ask
the
motorcycle
industry
to
help
reduce
air
pollution
along
with
other,
more­
heavily­
regulated
motor
vehicle
categories.
­
2
2.
Adopt
Less
Stringent
Standards
As
discussed
in
Chapter
V,
we
evaluated
two
industry
proposals:
a
proposal
from
one
of
the
six
major
manufacturers
and
the
other
from
the
Motorcycle
Industry
Council.
Both
of
these
proposals
are
less
stringent
than
our
proposal
and
would
achieve
significantly
less
emission
reductions.
The
manufacturer's
proposal,
a
1.4
g/
km
HC+
NOx
standard
for
Model
Year
2004,
is
identical
to
our
Tier­
1
proposal
of
1.4
g/
km.
However,
this
industry
proposal
lacks
a
second­
tier
standard.
Instead,
the
proposal
relies
on
a
mid­
course
technology
review
as
a
pre­
requisite
to
the
adoption
of
a
second­
tier
standard.
Thus,
this
industry
proposal
provides
little
or
no
incentive
for
manufacturers
to
begin
their
R&
D
efforts
now
toward
meeting
a
more
challenging,
second­
tier
standard
that
achieves
greater
reductions.
From
a
benefits
standpoint,
we
project
this
proposal
would
achieve
about
0.6
tpd
HC+
NOx
statewide
reduction
by
2010,
which
rises
marginally
to
about
0.7
tpd
HC+
NOx
reduction
by
2020
(
primarily
from
projected
sales
growth).

Unlike
the
manufacturer's
proposal,
the
Motorcycle
Industry
Council
proposes
a
two­
tier
approach
similar
to
ARB
staff's
proposal.
The
MIC's
proposed
first­
tier
standard
of
1.5
g/
km
HC+
NOx
is
based
on
the
use
of
engine
modifications
without
catalytic
converters,
an
approach
also
used
in
ARB
staff's
first­
tier
proposal.
However,
the
MIC's
proposed
second­
tier
standard
of
1.2
g/
km
HC+
NOx
by
2008
achieves
significantly
less
reductions
than
ARB
staff's
proposal
of
0.8
g/
km.
To
illustrate,
the
MIC's
proposal
would
reduce
the
2010
statewide
inventory
by
about
0.7
tpd
HC+
NOx,
as
compared
to
ARB
staff's
proposal,
which
we
expect
will
reduce
the
inventory
by
about
1.3
tpd.
The
difference
is
even
more
significant
when
the
proposals'
benefits
are
projected
further
into
the
future
(
to
account
for
full
fleet
turnover).
By
2020,
the
MIC's
proposal
would
reduce
statewide
HC+
NOx
emissions
by
about
1.2
tpd,
whereas
the
staff's
proposal
would
reduce
emissions
by
about
2.9
tpd.
Thus,
the
MIC's
proposal
would
provide
significantly
less
reductions
than
ARB
staff's
proposal.

3.
Adopt
More
Stringent
Standards
At
the
beginning
of
this
rulemaking,
we
proposed
a
single,
0.2
g/
km
HC+
NOx
standard
designed
to
reduce
HC
and
NOx
emissions
by
about
90%
and
80%,
respectively.
This
proposal
probably
represents
the
lower
bound
on
exhaust
emissions
that
can
be
achieved
through
extensive
use
of
"
conventional"
technologies
used
in
automobiles
and
some
motorcycles:
three­
way,
closecoupled
closed­
loop
catalytic
converters,
secondary
air
injection,
electronic
fuel
injection,
and
other
engine
modifications.
We
based
this
proposal
on
literature
searches
and
several
discussions
with
members
of
the
Manufacturers
of
Emission
Controls
Association
(
MECA).
While
a
0.2
g/
km
or
some
lower
HC+
NOx
limit
is
technically
feasible,
it
would
be
very
challenging
to
manufacturers
and
probably
not
be
cost­
effective.
Therefore,
we
ultimately
rejected
this
standard
because,
with
current
and
foreseeable
technologies,
it
is
likely
to
have
some
significant
impacts
on
various
parameters
that
are
important
to
manufacturers
and
consumers,
including
cost,
driveability,
safety,
and
aesthetics.
­
3
As
discussed
in
Chapter
III,
our
proposal
underwent
several
revisions
before
arriving
at
the
current
proposal.
At
the
first
workshop
in
July
1998,
we
proposed
another
set
of
standards
which
were
more
stringent
than
the
current
proposal
(
a
0.6­
0.8
g/
km
HC+
NOx
Tier­
1
limit
and
a
0.3­
0.4
g/
km
Tier­
2
limit).
Based
on
further
technical
discussions
with
industry
representatives
and
information
obtained
during
and
subsequent
to
the
second
public
workshop
in
October
1998,
we
revised
our
proposal
two
more
times
prior
to
the
current
proposed
limits.
Our
analysis
indicated
these
earlier­
proposed
standards
are
feasible
but
more
costly
than
the
current
proposal.
Thus,
staff
underwent
an
extensive
three­
step
revision
process
in
which
we
evaluated
three,
more
stringent
proposals
before
arriving
at
the
current
proposed
limits.

D.
Conclusions
We
evaluated
a
variety
of
regulatory
alternatives
and
found
that
the
current
proposal
represents
a
reasonable
balance
of
potential
emission
benefits,
use
of
demonstrated
and
emerging
technologies,
and
minimized
economic
impacts.
­
1
IX.

OUTSTANDING
ISSUES
Staff
presented
the
essential
elements
of
the
proposed
amendments
through
two
public
workshops
and
numerous
individual
meetings
with
stakeholders.
The
proposed
Tier­
1
standard,
the
need
for
a
Tier­
2
standard,
the
corporate
averaging
provision
and
the
small­
volumemanufacturer
provision
are
generally
consistent
with
industry
views.
However,
some
issues
did
arise
with
regard
to
the
magnitude
of
projected
emission
reductions
and
the
appropriateness
of
obtaining
such
reductions
from
this
vehicular
category;
the
certainty
of
Tier­
2
compliant
technology
development;
and
the
potential
impacts
equipment
tampering
by
consumers
may
have
on
the
projected
emission
reductions.
These
issues
are
discussed
as
follows.

1.
Magnitude
of
Reductions
and
Appropriateness
of
Obtaining
the
Reductions
from
On­
road
Motorcycles
The
Motorcycle
Industry
Council
has
raised
concerns
regarding
the
relative
magnitude
of
the
emission
reductions
to
be
achieved
with
staff's
proposal.
As
noted
in
Chapter
VII,
the
projected
HC+
NOx
emission
reductions
upon
full
implementation
of
staff's
proposal
are
1.3
tpd
by
2010
and
2.9
tpd
by
2020.
Essentially,
the
issue
raised
by
the
MIC
is
whether
the
magnitude
of
these
emission
reductions
justifies
obtaining
such
reductions
from
the
on­
road
motorcycle
category,
rather
than
from
another
source.
As
discussed
below,
the
air
pollution
situation
in
California
requires
the
ARB
to
consider
all
possible
ways
to
reduce
emissions
from
all
sources
and
adopt
those
measures
which
reduce
emissions
cost­
effectively.
Moreover,
equity
requires
that
we
ask
all
industries
and
activities,
which
contribute
to
the
air
pollution
problem,
to
also
contribute
to
the
overall
solution.

In
previous
chapters
of
this
report,
we
discussed
the
need
to
achieve
emission
reductions
from
every
feasible
source
to
meet
the
SIP
commitments.
After
several
decades
of
regulatory
programs,
it
is
generally
recognized
that
the
"
easy
and
large"
reductions
from
a
few,
very
visible
source
categories
have
already
been
achieved
(
e.
g.,
cars,
refineries,
smokestacks).
Future
incremental
reductions
will
be
achieved
from
many
smaller
sources
with
greater
effort.
For
example,
automobiles
have
already
been
required
to
achieve
emission
reductions
of
nearly
95%
or
more
relative
to
their
pre­
regulatory
levels
in
the
1960s.
However,
as
vehicle
miles
traveled
(
VMT)
increases
and
emission
control
technologies
progress,
we
continue
to
seek
the
most
feasible
reductions
we
can
achieve
from
cars
and
other
sources.
The
recently
proposed
amendments
to
the
Low
Emission
Vehicle
(
LEV)
and
Zero
Emissions
Vehicle
(
ZEV)
regulations
strive
to
reduce
automobile
emissions
even
further.
Other
categories,
such
as
off­
road
motorcycles,
heavy­
duty
trucks,
and
utility
engines
have
also
been
recently
regulated
and
required
to
reduce
emissions.
­
2
To
further
illustrate
the
need
to
achieve
all
feasible
reductions,
we
note
that
the
ARB
has
recently
regulated
very
small
emission
sources
which,
traditionally,
had
never
been
required
to
reduce
ozone
precursor
emissions.
A
prime
example
of
this
is
the
ARB's
consumer
products
program,
which
is
designed
to
reduce
emissions
of
hydrocarbons
from
solvent­
containing
products
used
by
consumers
and
businesses.

The
most
recent
amendments
to
the
consumer
products
regulation
("
Mid­
Term
Measures"
or
Phase
III)
added
25
new
hydrocarbon
limits
on
18
individual
categories
of
consumer
products,
ranging
from
automotive
rubbing
compounds
to
wasp
and
hornet
insecticides.
(
Title
17,
CCR,
sections
94507­­
94517).
Of
these
25
limits,
21
had
emission
reductions
that
were
less
than
the
tonnage
reductions
projected
for
on­
road
motorcycles
under
the
staff's
proposal.
Indeed,
14
of
these
21
limits
had
projected
statewide
emission
reductions
of
500
pounds
per
day
(
0.25
tpd)
or
less
by
2005.
(
ARB,
June
1997).
Moreover,
the
annual
cost
of
reducing
consumer
product
emissions
was
projected
to
be
up
to
ten
times
higher
than
the
cost
projected
for
the
staff's
proposal
for
motorcycles.
(
Id.
at
Vol­
II,
Ch­
VIII,
p.
17).
It
is
clear
that
most
of
these
consumer
product
categories
have
reduction
potentials
lower
than
the
on­
motorcycle
category
under
staff's
proposal.
However,
the
fact
that
consumer
products
are
regulated
in
California
provides
direct
evidence
of
the
need
to
evaluate
all
possible
sources
of
ozone
and
PM
precursor
emissions
to
achieve
whatever
reductions
are
feasible
and
cost­
effective.

When
the
ARB
adopts
measures
to
reduce
emissions,
the
primary
goal
of
such
efforts
is
to
achieve
the
most
reductions
that
the
affected
industry
can
cost­
effectively
implement.
Through
careful
balancing
of
industry,
environmental,
and
consumer
needs,
the
ARB
establishes
standards
that
maximize
reductions
while
minimizing
impacts.
Since
all
the
"
easy"
reductions
have
already
been
achieved,
and
measures
under
development
are
achieving
maximum
reductions
at
increasing
costs,
it
is
difficult
to
see
what
sources
are
left
that
have
not
already
been
regulated
and
can
replace
the
reductions
we
are
seeking
from
on­
road
motorcycles.
Even
if
such
new
or
alreadyregulated
sources
were
identified,
reductions
from
on­
road
motorcycles
and
all
other
feasible
sources
would
still
be
required,
given
the
very
large
magnitude
of
reductions
needed
to
meet
State
and
federal
air
quality
standards.

2.
Certainty
in
Development
of
Tier­
2
Compliant
Technology
Some
concern
has
been
raised
regarding
the
development
of
Tier­
2
compliant
technology.
Specifically,
some
industry
members
have
raised
the
issue
of
whether
advanced
emission
controls
can
ever
be
implemented
for
some
motorcycles.
It
is
generally
recognized
that,
given
no
other
constraints,
engine
systems
and
catalysts
are
currently
available
which
can
meet
the
proposed
Tier­
2
standard
and
even
lower
levels.
(
MIC,
Oct.
1998a)
However,
under
real­
world
conditions,
manufacturers
have
to
balance
available
technology
with
costs
and
constraints
unique
to
motorcycles.
We
recognize
that
motorcycles
are
not
automobiles
and
have
unique
challenges
with
regard
to
limited
space
available
for
installing
emission
controls,
vibrational
stresses,
rider
safety,
and
cost
impacts.
We
are
also
aware
that
installing
emission
controls
on
a
motorcycle
­
3
while
maintaining
acceptable
aesthetic
qualities
will
challenge
manufacturers
on
at
least
some
product
lines.

We
designed
our
Tier­
2
proposed
standard
to
address
these
and
other
concerns.
As
stated
previously,
the
Tier­
2
standard
is
expected
to
result
in
the
use
of
catalysts
on
selected
product
lines,
rather
than
on
most
motorcycles.
Thus,
the
universal
application
of
catalytic
converters
will
not
be
required;
manufacturers
would
need
to
expend
their
R&
D
resources
on
engine
systems
and
pulse­
air
technology,
with
efforts
spent
to
develop
catalysts
only
to
the
extent
required
under
corporate
averaging
to
reach
an
average
level
of
0.8
g/
km
HC+
NOx.
As
discussed
earlier,
we
expect
a
maximum
of
60%
of
the
market
would
need
to
use
catalytic
converters.
Given
that
advanced
engine
systems
and
catalytic
converters
have
already
been
demonstrated
on
commercially­
available
motorcycles
for
several
years,
we
believe
manufacturers
can
meet
the
challenges
of
designing
and
installing
the
necessary
equipment
within
the
next
9
years.

Even
for
motorcycles
on
which
catalysts
are
required,
the
catalyst
and
associated
equipment
is
challenging
but
not
impossible,
and
successful
catalyst
use
has
already
been
demonstrated
on
nearly
all
BMW
motorcycles
(
BMW,
1998),
some
Japanese
product
lines,
and
even
one
Harley­
Davidson
line.
Unlike
engine
modifications,
secondary
pulse­
air
injection,
and
other
engine
system
changes
we
expect,
catalytic
converters
will
require
some
effort
to
installed
in
an
acceptable
manner.
Riders
will
need
to
be
protected
from
the
catalyst's
heat
and,
when
catalyst
visibility
would
be
undesirable,
some
effort
will
be
required
to
install
the
catalysts
within
the
muffler
system,
under
the
engine,
or
elsewhere
where
it
would
not
be
visible.
Vibrational
and
other
engine
stresses
will
require
careful
placement
of
the
catalyst
to
balance
the
need
to
maintain
heat
input
from
the
engine
versus
the
need
to
minimize
stresses
on
the
catalyst.
These
and
other
challenges
have
already
been
met
by
manufacturers
on
some
existing
motorcycles,
and
we
anticipate
they
will
be
able
to
resolve
any
design
and
installation
issues
with
the
remaining
motorcycles
within
the
next
9
years.

3.
Potential
Impacts
on
Program
Effectiveness
from
Equipment
Tampering
From
anecdotal
information
and
limited
surveillance
data,
we
know
that
a
portion
of
the
motorcycle
riding
population
tampers
or
has
tampered
with
(
i.
e.,
removed,
replaced,
or
modified)
the
original
equipment
on
their
motorcycles.
Such
tampering
includes
changes
that
can
be
detrimental
or
beneficial
to
the
motorcycle's
emission
levels.
These
activities
frequently
involve
the
replacement
of
exhaust
systems,
carburetor
jet
modifications,
"
tweaking"
of
the
electronic
controls,
removal
of
catalytic
converters,
or
other
activities
that
may
have
potential
negative
(
or
positive)
impacts
on
emission
levels.
According
to
the
MIC's
limited
data
on
exhaust­
only
tampering,
consumer
tampering
may
be
on
the
order
of
34
percent.
(
MIC,
Oct.
1998a)

As
discussed
in
Chapter
X
("
Future
Activities"),
we
plan
to
work
closely
with
the
MIC
and
other
stakeholders
to
comprehensively
document
tampering
rates
and
the
effects
tampering
has
on
emission
levels.
We
anticipate
our
cooperative
efforts
will
help
identify
the
sector(
s)
of
the
rider
population
which
tampers
with
original
equipment
on
motorcycles.
Through
improved
­
4
consumer
education
and,
if
necessary,
increased
enforcement
of
existing
anti­
tampering
statutes,
we
hope
to
better
quantify
and
ultimately
reduce
whatever
tampering
is
occurring.
We
also
plan
to
work
closely
with
manufacturers
to
ensure
that
their
Tier­
1
and
Tier­
2
compliant
technologies
are
as
tamper­
resistant
as
possible.
Current
European
regulations
require
tamper­
proof
designs
to
address
noise
concerns,
which
we
will
be
evaluating
as
a
model
for
any
tamper­
resistant
requirements
that
may
be
necessary
to
maximize
the
effectiveness
of
the
staff's
proposal.
(
Directive
97/
24/
EC,
1997)
­
1
X.

FUTURE
ACTIVITIES
1.
Further
Refinement
of
the
Emissions
Inventory
As
noted
earlier,
the
Motorcycle
Industry
Council
was
instrumental
in
refining
the
emissions
inventory.
Further
efforts
will
enable
staff
to
continue
refining
the
inventory
as
better
data
become
available.
First,
we
will
work
with
the
MIC
and
other
industry
representatives
to
refine
vehicle
activity
data
and
deterioration
factors.
We
will
also
discuss
with
the
MIC
the
feasibility
of
improving
its
5­
year
survey
of
equipment
tampering
to
better
gauge
the
rates
of
illegal
engine
modifications
and
exhaust
system
tampering.
Finally,
we
will
discuss
with
industry
representatives
the
most
effective
methods
for
identifying
and
discouraging
illegal
tampering,
which
would
benefit
the
proposal's
emission
reductions.
We
look
forward
to
coordinating
our
efforts
with
the
MIC
and
other
industry
representatives.

As
with
virtually
all
other
sources
of
air
pollution,
the
on­
road
motorcycle
emissions
inventory
will
undergo
refinements
in
the
future
as
we
gain
a
better
understanding
of
the
factors
that
influence
emissions
from
this
category.
This
continual
improvement
in
emissions
data
is
a
natural
result
of
better
surveys,
testing,
enforcement,
and
other
means
of
information
gathering.
The
ARB
staff
are
committed
to
refining
the
inventory
for
all
sources
of
emissions
as
more
accurate
information
becomes
available.
It
should
be
emphasized,
however,
that
this
refinement
is
an
on­
going
process
which
should
not
preclude
the
adoption
of
control
measures
based
on
the
best
data
currently
available
to
staff.
The
staff's
proposal,
its
commercial
and
economic
impacts,
and
its
benefits
were
all
evaluated
based
on
the
best
available
data,
much
of
which
was
supplied
by
the
MIC
and
other
industry
representatives.
Therefore,
the
staff's
proposal
represents
the
most
reasonable
set
of
standards
given
our
current
understanding
of
the
on­
road
motorcycle
industry,
the
technologies
needed
to
reduce
emissions,
and
consumer
behavior
patterns
that
affect
emissions.

2.
2006
Progress
Review
Our
discussions
with
manufacturers
and
suppliers,
as
well
as
our
review
of
the
1998
ARB
on­
road
motorcycle
certification
database,
strongly
support
our
belief
that
manufacturers
will
be
able
to
comply
with
both
Tier­
1
and
Tier­
2
standards
in
the
time
provided.
In
particular,
the
proposed
Tier­
2
standard
of
0.8
g/
km
HC+
NOx
and
the
corporate
averaging
provision
give
manufacturers
increased
flexibility
in
deciding
which
engine
families
will
need
catalytic
converters
and
which
can
do
without
catalysts.
To
ensure
that
manufacturers
are
adequately
progressing
in
their
efforts
to
comply,
we
will
be
conducting
a
mid­
course
status
review.
Because
the
Tier­
1
standard
is
based
on
the
widespread
use
of
reasonably
available
and
demonstrated
engine
modifications,
we
do
not
believe
a
technology
review
prior
to
2004
is
necessary.
Moreover,
we
believe
manufacturers
will
soon
begin
to
spend
the
bulk
of
their
R&
D
efforts
to
meet
the
Tier­
2
standard.
We
are
therefore
proposing
a
progress
review
in
2006
to:
­
2
(
1)
evaluate
the
success,
cost,
and
consumer
acceptance
of
engine
modifications
employed
to
meet
Tier­
1,
and
(
2)
review
and
discuss
manufacturers'
efforts
to
meet
Tier­
2,
which
at
that
point
should
be
well
under
way.
We
believe
a
2006
progress
review
will
provide
sufficient
time
for
mid­
course
corrections
if
needed
to
address
unforeseen
circumstances.
REFERENCES
Title
13,
California
Code
of
Regulations,
section
1958.

Resolution
84­
11,
Air
Resources
Board,
Agenda
Item
Nos.
84­
6­
4
&
84­
7­
1
(
April
26,
1984).

Air
Resources
Board,
"
The
California
State
Implementation
Plan
for
Ozone,"
Volumes
I­
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November
1994.

Air
Resources
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"
1995
Estimated
Annual
Average
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Statewide,"
(
visited
10/
16/
98)
<
http://
www.
arb.
ca.
gov/
ceidars/
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Air
Resources
Board,
EMFAC7G
(
one
of
the
four
computer
models
comprising
the
Motor
Vehicle
Emission
Inventory
(
MVEI)
Models,
the
others
being
CALIMFAC,
WEIGHT,
and
BURDEN),
(
last
modified
10/
1/
98)
<
http://
www.
arb.
ca.
gov/
msei/
mvei/
program.
exe>.

Letter
from
James
R.
Ryden,
Administrative
Law
Judge,
Air
Resources
Board,
to
William
C.
Robb,
II,
American
Motorcycling
Manufacturing
(
March
17,
1998).

Air
Resources
Board,
"
Revisiting
the
On­
Road
Motorcycle
Regulation,"
Public
Workshop
Slide
Presentation,
El
Monte,
CA
(
July
1,
1998a).

Air
Resources
Board,
"
Revisiting
the
On­
Road
Motorcycle
Regulation,"
Public
Workshop
#
2
Slide
Presentation,
El
Monte,
CA
(
October
7,
1998b).

Tim
Hoelter,
Vice­
President­
International
Trade
and
Regulatory
Affairs,
Harley­
Davidson,
Address
at
ARB
Public
Workshop
#
2
"
Revisiting
the
On­
Road
Motorcycle
Regulation,"
(
October
7,
1998).

"
1997
Motorcycle
Statistical
Annual,"
Motorcycle
Industry
Council
(
MIC),
January
1997.

"
The
Motorcycle
Industry
in
Europe,"
ACEM
Pollution
Research
Programme
on
Motorcycles,
ACEM
Pollution
Working
Group,
March
1998.

"
Motorcycle
Industry
Council
Proposal
for
Revising
Exhaust
Emission
Standards
for
On­
Road
Motorcycles,"
MIC
Presentation
to
the
California
Air
Resources
Board,
p.
3
(
October
7,
1998a).

BMW,
"
Info
Box
­
Technical
Encyclopedia,"
p.
2,
(
visited
4/
13/
98)
<
http://
www.
bike.
bmw.
com/
english/
infobox/
lexicon/
c.
html>.

MBNet,
"[
Yamaha]
GTS1000A
Development
Concept,"
p.
3,
<
http://
www.
mbnet.
mb.
ca/~
neelin/
motorcycle/
concept.
html>.
Mazda,
"
Mazda
Develops
New
Three­
Way
Catalyst
 
Further
Reduces
Pollutants
in
Exhaust
Emissions,"
p.
1,
(
visited
7/
24/
98)
<
http://
www.
e.
mazda.
co.
jp./
Publicity/
9803/
980317.
html>.
Degussa,
"
What's
New,"
pp.
1­
2,
(
visited
7/
24/
98)
<
http://
www.
degussa.
com/
html/
2_
18_
98_
2.
html>.

R.
J.
Locker,
C.
B.
Sawyer,
and
P.
S.
Schmitt,
"
Demonstration
of
High
Temperature
Durability
for
Oval
Ceramic
Catalytic
Converters­
2,"
Society
of
Automotive
Engineers
(
SAE)
Paper
No.
980042
(
1998).

R.
N.
Carter,
et
al.,
"
Laboratory
Evaluation
of
Ultra­
Short
Metal
Monolith
Catalyst,"
SAE
Paper
No.
980672
(
1998).

SAE
Virtual
Press
Room,
"
Emitec,
Toyota
Develop
Revolutionary
Foil
to
Reduce
Automotive
Emissions,"
(
visited
7/
28/
98)
<
http://
www.
eisbrenner.
com/
vpr/
v_
emitec.
htm>
(
February
23,
1998).

B.
Williamson,
J.
Nunan,
and
K.
Andersen,
Allied
Signal
Environmental
Catalysts,
and
J.
M.
Best,
Delphi
Energy
&
Energy
Management,
"
Fatigue
and
Performance
Data
for
Advanced
Thin
Wall
Ceramic
Catalysts,"
SAE
Paper
No.
980670
(
1998).

R.
Brück,
et
al.,
"
New
Ultra
Thin
Wall
Metal
Catalysts
for
Close­
Coupled
Applications,"
SAE
Paper
No.
980420
(
February
23,
1998).

Y.
Song,
J.
Jang,
and
G.
Yeo,
Hyundai
Motor
Company,
and
J.
Lee,
Heesung
Engelhard
Company,
"
Development
of
Single
Coated
Pd/
Rh
Three
Way
Catalyst
for
CCC
Applications,"
SAE
Paper
No.
980666
(
1998).

S.
Taniguchi,
T.
Yoshikawa,
and
M.
Horiuchi,
International
Catalyst
Technology
Company;
D.
Lindner
and
L.
Mu mann,
Degussa
AG;
and
M.
Jenkin,
International
Catalyst
Technology;
"
New
Low
Cost
and
High
Performance
Catalyst­
Single
Layer
Pd/
Rh
Catalyst
Development,"
SAE
Paper
No.
980669
(
February
23­
26,
1998).

N.
Kishi,
et
al.,
"
Development
of
the
Ultra
Low
Heat
Capacity
and
High
Insulating
(
ULOC)
Exhaust
Manifold
for
ULEV,"
SAE
Paper
No.
980937
(
February
1998).

Harley­
Davidson
1998
Parts
Catalog.

Ellaird,
John
H.,
"
Heat
shielding
foot
rest
for
attachment
to
a
motorcycle
exhaust
system,"
U.
S.
Patent
#
4,023,821
(
May
17,
1977).

H.
Nebu,
K.
Komura,
and
T.
Yamada,
"
Exhaust
pipe
cover
for
motorcycles,"
U.
S.
Patent
#
4,699,232
(
October
13,
1987).
H.
W.
Hoeptner,
III,
"
Adjustable
shield
for
motorcycle
exhaust
pipe,"
U.
S.
Patent
#
4,955,193
(
September
11,
1990).

O.
Fumihiro,
"
Exhaust
Pipe
Structure
of
Motorcycle,"
Japan
Patent
#
08082214
(
March
26,
1996).

Air
Resources
Board,
"
Staff
Report:
Initial
Statement
of
Reasons
 
Proposed
Amendments
to
California
Exhaust
and
Evaporative
Emission
Standards
and
Test
Procedures
for
Passenger
Cars,
Light­
Duty
Trucks
and
Medium­
Duty
Vehicles
`
LEV
II'
and
Proposed
Amendments
to
California
Motor
Vehicle
Certification
Assembly
Line
and
In­
Use
Test
Requirement
`
CAP
2000',"
p.
II­
55
(
September
18,
1998).

Letter
from
Pamela
Amette,
Vice­
President,
MIC,
to
James
R.
Ryden,
Administrative
Law
Judge,
ARB
(
August
14,
1998).

Thomas
C.
Austin,
Sierra
Research
representing
the
MIC,
Address
at
ARB
Public
Workshop
#
2
"
Revisiting
the
On­
Road
Motorcycle
Regulation,"
(
October
7,
1998).

Air
Resources
Board,
"
Initial
Statement
of
Reasons
for
Proposed
Amendments
to
the
California
Consumer
Products
Regulation,"
Volume
II,
Chapter
III,
pp.
4­
6,
(
June
6,
1997).

BMW,
Motorcycle
Specifications,
(
visited
7/
28/
98)
<
http://
www.
bmwusacycles.
com/
machines>.

European
Commission
Council
Directive
97/
24/
EC,
art.
1,
1997
O.
J.
(
L
226)
79.
APPENDIX
A:
PROPOSED
AMENDMENTS
TO
THE
ON­
ROAD
MOTORCYCLE
REGULATION
Proposed
Regulation
Order
Amend
Title
13,
California
Code
of
Regulations,
section
1958
to
read
as
follows:

[
Note:
Proposed
amendments
for
this
rulemaking
are
shown
in
bold
underlined
text
to
indicate
additions
and
strikeout
to
indicate
deletions.]

§
1958.
Exhaust
Emission
Standards
and
Test
Procedures
 
Motorcycles
Manufactured
on
or
after
January
1,
1978.

(
a)
This
section
shall
be
applicable
to
motorcycles
produced
on
or
after
January
1,
1978.
Motorcycles
are
excluded
from
the
requirements
of
this
section
if:

(
1)
The
engine
displacement
is
less
than
50
cubic
centimeters,
or
(
2)
An
80
kilogram
(
176
pound)
driver
cannot:

(
A)
start
from
a
dead
stop
using
only
the
engine,
or
(
B)
exceed
a
maximum
speed
of
40
kilometers
per
hour
(
24.9
miles
per
hour)
on
a
level
paved
surface.
(
b)
Exhaust
emissions
from
new
street­
use
motorcycles,
subject
to
registration
and
sold
and
registered
in
this
state,
shall
not
exceed:

Exhaust
Emission
Table
of
Standards
(
grams
per
kilometer)

Exhaust
Emission
Standards
(
grams
per
kilometer)
Model­
Year
Engine
Displacement
(
in
cubic
centimeters)
Hydrocarbon
(
HC)
+
Oxides
of
Nitrogen
(
NOx)
Carbon
Monoxide
1978
to
1979
50
to
less
than
170
5.0
(
HC
only)
17
1978
to
1979
170
to
less
than
750
5.0
+
0.0155(
D­
170)*
(
HC
only)
17
1978
to
1979
750
or
greater
14
(
HC
only)
17
1980
to
1981
All
(
50
cc
or
larger)
5.0
(
HC
only)
17
1982
and
subsequent
50
cc
to
279
cc
1.0
(
HC
only)
12
1982
through
1985
(
manufactured
prior
to
March
1,
1985)
280
cc
or
greater
2.5
(
HC
only)
12
1985
(
manufactured
after
February
28,
1985)
through
1987
280
cc
or
greater
1.4
(
HC
only),
applied
as
a
corporate
average,
**
provided
that
each
engine
family
shall
have
only
one
applicable
standard
12
1988
and
subsequent
through
2003
280
cc
to
699
cc
1.0
(
HC
only),
applied
as
a
corporate
average,
**
provided
that
each
engine
family
shall
have
only
one
applicable
standard
12
1988
and
subsequent
through
2003
700
cc
or
greater
1.4
(
HC
only),
applied
as
a
corporate
average,
**
provided
that
each
engine
family
shall
have
only
one
applicable
standard
12
2004
through
2007
280
cc
or
greater
1.4
(
HC
+
NOx),
applied
as
a
corporate
average,
**
provided
that
each
engine
family
shall
have
only
one
applicable
standard
12
2008
and
subsequent
280
cc
or
greater
0.8
(
HC
+
NOx),
applied
as
a
corporate
average,
**
provided
that
each
engine
family
shall
have
only
one
applicable
standard
12
*
D
=
engine
displacement
of
motorcycles
in
cubic
centimeters.
**
Compliance
with
a
standard
to
be
applied
as
a
"
corporate
average"
shall
be
determined
as
follows:
where,

n
=
Class
III
motorcycle
engine
families
(
engines
with
displacement
of
280
cc
or
greater
manufactured
after
February
28,
1985).

PRODjx
=
Number
of
units
of
Class
III
engine
family
j
produced
for
sale
in
California
in
model
year
x
STDjx
=
The
manufacturer
designated
HC
or
HC
+
NOx
emission
standard,
whichever
applies,
for
engine
family
j
in
model
year
x,
which
shall
be
determined
by
the
manufacturer
subject
to
the
following
conditions:

(
1)
no
individual
engine
family
exhaust
emission
standard
shall
exceed
2.5
g/
km,
and
(
1)
for
Model
Year
1988
through
2003
motorcycles
with
engine
displacement
of
280
cc
or
greater,
no
individual
engine
family
exhaust
emission
standard
shall
exceed
2.5
g/
km
HC,
and
(
2)
for
Model
Year
2004
and
subsequent
motorcycles
with
engine
displacement
of
280
cc
or
greater,
no
individual
engine
family
exhaust
emission
standard
shall
exceed
2.5
g/
km
HC+
NOx,
and
(
3)
no
engine
family
designation
or
engine
family
exhaust
emission
standard
shall
be
amended
in
a
model
year
after
the
engine
family
is
certified
for
the
model
year,
and
(
4)
prior
to
sale
or
offering
for
sale
in
California,
each
engine
family
shall
be
certified
in
accordance
with
Section
1958(
c)
and
shall
be
required
to
meet
the
manufacturer's
designated
HC
or
HC
+
NOx
standard,
whichever
applies,
as
a
condition
of
the
certification
Executive
Order.
Prior
to
certification
the
manufacturer
shall
also
submit
estimated
production
volumes
for
each
engine
family
to
be
offered
for
sale
in
California.

STDCa
=
A
manufacturer's
corporate
average
HC
or
HC
+
NOx
exhaust
emissions,
whichever
applies,
from
those
California
motorcycles
subject
to
the
California
corporate
average
HC
or
HC
+
NOx
exhaust
emission
standard,
as
established
by
an
Executive
Order
certifying
the
California
production
for
the
model
year.
This
order
must
be
obtained
prior
to
the
issuance
of
certification
Executive
Orders
for
individual
engine
families
for
the
model
year
and
shall
include
but
not
be
limited
to
the
following
requirements:

(
1)
During
the
manufacturer's
production
year,
for
each
engine
family,
the
manufacturer
shall
provide
the
following
information
to
the
Executive
Officer
within
30
days
after
the
last
day
in
each
calendar
quarter:
(
aA)
vehicle
identification
numbers
and
an
explanation
of
the
identification
code;
(
bB)
the
total
number
of
vehicles
produced
for
sale
in
California
and
their
applicable
designated
emissions
standards.

(
2)
The
manufacturer's
average
HC
or
HC
+
NOx
exhaust
emissions,
whichever
applies,
shall
meet
the
applicable
corporate
average
standard
at
the
end
of
the
manufacturer's
production
for
the
model
year.

[
Note:
No
changes
are
proposed
for
Section
1958(
b)(
3)
through
(
e)]

(
f)
(
1)
Small
Volume
Manufacturers:
Exhaust
emission
standards
for
from
Class
III
motorcycles
of
small
volume
manufacturers
shall
not
be
exceeded
are
as
follows:

(
A)
For
Model
Year
1984
through
2007,
no
motorcycle
shall
emit
more
than
2.5
grams
per
kilometer
hydrocarbon
for
the
1984,
1985,
1986,
and
1987
model
years;
(
B)
For
Model
Year
2008
and
subsequent,
no
motorcycle
shall
exceed
1.4
grams
per
kilometer
HC
+
NOx.

To
obtain
certification
as
a
small
volume
manufacturer
pursuant
to
this
subsection,
the
manufacturer
shall
submit
product
information
and
estimated
sales
data
with
the
certification
application
for
each
engine
family
sold
in
California.
As
a
condition
of
obtaining
certification
as
a
small
volume
manufacturer,
the
manufacturer
shall
submit
annually
to
the
state
board
Executive
Officer
a
summary
of
its
efforts
and
progress
toward
meeting
more
stringent
hydrocarbon
HC
+
NOx
exhaust
emission
standards.
The
summary
shall
include
a
description
of
the
manufacturer's
current
hydrocarbon
HC
+
NOx
emission
control
development
status,
along
with
supporting
test
data,
and
future
planned
development
work.

(
2)
For
purposes
of
this
subsection
(
f)(
1)(
A),
a
small
volume
manufacturer
is
one
which
sells
less
than
5,000
new
Class
I,
II,
and
III
motorcycles
per
model
year
in
California.
For
purposes
of
subsection
(
f)(
1)(
B),
a
small
volume
manufacturer
is
one
which
sells
no
more
than
1,000
new
Class
I,
II,
and
III
(
combined)
motorcycles
in
model
year
2004
or
any
subsequent
model
year
in
California.
(
g)
Early­
Compliance
Credits
Manufacturers
which
sell
Class
III
motorcycles
in
California
certified
as
meeting
either
a
0.8
g/
km
or
0.4
g/
km
HC+
NOx
level
prior
to
Model
Year
2008
can
receive
credits
for
use
in
the
Model
Year
2008
corporate
average
upon
written
approval
by
the
Executive
Officer.
Each
unit
of
Class
III
motorcycle
sold
between
Model
Years
1999
and
2008
and
which
meets
the
requirements
of
this
subsection
shall
be
multiplied
by
whichever
X
multiplier
applies,
as
shown
in
the
following
table:

Table
of
Multipliers
to
Encourage
Early
Compliance
with
the
Proposed
Tier­
2
Standard
and
Beyond
Multiplier
(
X)
for
Use
in
MY
2008
Corporate
Averaging
Model
Year
Sold
Early
Tier­
2
Compliant
Certified
at
0.4
g/
km
HC+
NOx
1999
through
2004
1.5
3.0
2005
1.375
2.5
2006
1.250
2.0
2007
1.125
1.5
2008
and
subsequent
1.0
1.0
Note:
Each
unit
of
early
Tier­
2
compliant
and
0.4
g/
km
certified
motorcycles
is
counted
cumulatively
toward
the
MY
2008
corporate
average.

Note:
Authority
cited:
Sections
39600,
39601,
43013,
43101,
43104,
and
43107,
Health
and
Safety
Code.
Reference:
Sections
39002,
39003,
43000,
43013,
43100,
43101,
43104,
and
43107,
Health
and
Safety
Code;
and
Cal.
Stats.
83,
Ch.
103.
APPENDIX
B:
REQUESTS
FOR
CONSULTATION,
REQUESTS
FOR
INFORMATION
APPENDIX
C:
MEETING
&
WORKSHOP
NOTICES,
ATTENDEES'
LISTS
Attendees
of
Small­
Volume
Manufacturers
Group
Meeting
(
May
5,
1998)

Tom
Cates
Mark
Boyer
(
MFC)

J.
C.
Delaney
Robert
Lounsbury
(
RAM
Inc.)

Pamela
Amette
(
MIC)
Lloyd
Lounsbury
(
RAM
Inc.)

Kathleen
Wolf
J.
C.
Coker
(
CEE)

Heath
Glennon
Bill
Sterman
(
Powerparts
Inc.)

Kraig
Kavanagh
(
Ultra
Cycles)

Attendees
of
Public
Workshop
#
1
(
July
1,
1998)

Tim
Hurley
(
Pure
Steel
of
America)
Jeff
Shetler
(
Kawasaki)

Lee
Chapin
(
Mikuni
American
Corp.)
Kathleen
Wolf
(
K.
H.
Wolf
Consulting)

Mihael
Tyrrell
(
Honda)
Pamela
Amette
(
MIC)

David
Raney
(
Honda)
Ken
Boyd
(
Engine
Electronics,
Inc.)

Scott
Maas
(
Excelsior
Henderson
Motorcycle)
Edward
Michel
(
Harley­
Davidson)

William
Freedman
(
McCutchen,
Doyle,
et
al.)
Robert
Alsip
(
Suzuki)

Dana
Bell
(
AMA)
Thomas
Austin
(
Sierra
Research)

Dale
McKinnon
(
MECA)
Peterson
Publishing
Thomas
Pugh
(
Yamaha)
John
Paliwoda
(
CMDA)

SEMA
CA
Motorcycle
Company
Attendees
of
Public
Workshop
#
2
(
October
7,
1998)

Don
Fuller
Jeff
Noonan
(
JE
Pistons)

Ken
Bush
(
Suzuki)
Jeff
Shetler
(
Kawasaki)

Jeff
Link
(
Suzuki)
Tom
Pugh
(
Yamaha)

Kathleen
Wolf
Ryan
Tovatt
(
Tovatt
Engineering)

Tim
Hoelter
(
Harley­
Davidson)
Dave
Oakleaf
(
D­
37
AMA
Off­
Road
DLO)

Mike
Spencer
Rick
Rothman
(
McCutchen,
Doyle,
et
al.)

Bob
Alsip
(
Suzuki)
Kerry
Bryant
(
White
Brothers)

Tom
Austin
(
Sierra
Research)
J.
C.
Delaney
Kevin
Wood
(
Summit
Industries)
David
Raney
(
Honda)

John
Paliwoda
(
CMDA)
David
Koshork
(
DynoJet
Research)

Mike
Edmonton
(
Advanced
Fuel
Technologies)
Gary
Higgins
(
Honda)

Wm
(
Red)
Edmonton
(
Adv.
Fuel
Technologies)
Dana
Bell
(
AMA)

Pamela
Amette
(
MIC)
Harold
Soens
(
AMA­
D­
38)

Edward
Michel
(
Harley­
Davidson)
Mark
Boyer
(
Boyer
Syndicate)
Lit­
Mian
Chan
(
EF
&
EE)
Bill
Dart
(
AMA
District
36)

Jerry
Coker
(
CEE)
Tom
Cates
(
K
&
N
Eng.)
