EPA Emission Control

Statement of Celina Montorfano, Alliance Policy Manager

American Hiking Society

Testimony before the U.S. Environmental Protection Agency

Regarding the Control of Emissions from Nonroad Engines and Recreational Engines Proposed Rule

Docket No. A-2000-28

October 24, 2001

Dulles, Virginia

Thank you for the opportunity to testify on the Environmental Protection Agency’s Emission Standards for New Nonroad and Recreational Engines. I am Celina Montorfano, Alliance Policy Manager for American Hiking Society (AHS), the only national recreation-based conservation organization dedicated to establishing, protecting, and maintaining foot trails in America. With over 10,000 individual members and 150 member trail clubs, we represent more than half a million outdoorspeople and serve as the voice of the American hiker.

American Hiking is also a founding member of the Hikers for Clean Air (HCA) coalition, a newly organized partnership of U.S. hiking clubs, including Adirondack Mountain Club, Appalachian Mountain Club, Appalachian Trail Conference, NY-NJ Trail Conference, and the Potomac Appalachian Trail Club. This coalition strives to promote public awareness and support in the nation's hiking community for legislation and regulatory initiatives to significantly reduce air pollutants in order to preserve and restore the hiking experience, protect the natural environment, safeguard health and safety, and improve aesthetics along the nation's trails.

We are deeply concerned about the diminished air quality in the nation today, especially in national parks and wilderness areas. Emissions from nonroad and recreational engines constitute a significant source of air pollution, contributing to impaired visibility, threats to human/hiker health, and degradation of the natural areas 73 million hikers (according to the National Survey on Recreation and the Environment 2000) venture out to see and experience each year. We urge you to support strong emissions controls on nonroad and recreational engines to improve and restore the visibility and ecological integrity of our national parks and wilderness areas and protect the health of hikers, all-terrain vehicle (ATV) and nonroad engine users, and other recreationists nationwide.

Visibility

One of a hiker’s best rewards when reaching a summit or ridgeline is a majestic and scenic view. However, hikers cannot see the same view today as they could decades ago because of the dirty haze created by fine particulate pollution. Emissions from recreational vehicles, particularly snowmobiles, operating in rural areas, national parks, and forests contribute to ambient particulate matter--a leading component of visibility impairment. Impaired visibility has become common in the Appalachian and Rocky Mountains and at national parks in Arizona, California, and Texas. In Virginia’s Shenandoah National Park, summer visibility has dropped from about 90 to less than 20 miles. Great Smoky Mountains holds the record for the worst air quality of any national park with views on some summer days reduced from miles to feet. On some of the more severely polluted days in the Grand Canyon, the North Rim is barely visible from the South Rim, only 10 miles away.

Human/Hiker Health

Hikers head to the mountains to commune with nature, seeking quiet and fresh clean air, but what they find in many areas places their health in jeopardy. Mountain air polluted by fine particles comprised of acid aerosols damages the lungs of active adults and children and is especially harmful to anyone with asthma or other respiratory disorders. Research indicates that tiny airborne soot particles can trigger death by sudden heart attack. In 1999, ozone pollution in the Smokies violated federal health standards on fifty-two summer days (the peak hiking season) and was worse than most US cities including Houston and Washington, D.C. Elevated ozone concentrations is a serious public health concern nationwide, and chronic exposure may cause permanent lung damage. Ozone levels at 17 of our national parks have increased.

Two-stroke engines emit dangerous levels of carbon monoxide, hydrocarbons, fine particles, MTBE (methyl tertiary butyl ether), and other toxic chemicals such as benzene and toluene. Exposure to some of these pollutants causes, exacerbates, or contributes to asthma and other respiratory illnesses, cardiovascular disease, cancer, and premature death. Exposure can also result in diminished cognitive functions and aerobic capacity. Emissions are especially hazardous to users of these engines and vehicles as well as those who may be in close proximity to them for extended periods such as park employees. In Yellowstone National Park, for example, snowmobiles generate up to 90% of the park’s hydrocarbon emissions and nearly 70% of the carbon monoxide pollution. Park rangers exposed to high levels of snowmobile exhaust frequently suffer from symptoms of carbon monoxide poisoning.

Ecological Implications

Two-stroke engines discharge between 25-30% of their gas-oil mixture unburned directly into the environment, contaminating the air, ground, and waterways, and poisoning plant life and fish. The emissions from off-road vehicles contain a host of toxic chemicals that pollute the air and water and injure, kill, and potentially mutate plants, animals, fish and microscopic marine life.

Ozone adversely affects vegetation and forest growth, causing noticeable foliage damage and reduced growth in plants. Plants become more susceptible to disease, insect attack, harsh weather and other environmental stresses.

Nonroad/recreational engine emissions contribute to acid rain/deposition, which destroys natural habitat and alters fragile ecosystems in mountain environments, especially the forests and streams of the Appalachian and Smoky Mountains and the alpine meadows of the Colorado Front Range. Research shows that acid deposition alters the chemical composition of mountain soils, leaching nutrients such as calcium and magnesium from the earth and releasing toxic levels of aluminum in soil, lakes, and streams. Acid rain is killing trees and damaging plants, and the acidification of streams kills fish and other aquatic life, notably in the Northeast and the entire Appalachian range. Air pollution is now considered one of the greatest threats to some of our nation’s most treasured national parks such as Shenandoah and Great Smoky Mountains.

Specific Comments on the Proposed Rule

While we commend the EPA for its efforts to address the serious effects of nonroad and recreational engine emissions, we urge the agency to strengthen the proposed rule by incorporating the following elements:

Switch from two-stroke to four-stroke engines. The emissions from recreational engines are astonishing. A two-stroke ATV or motorcycle can emit as much pollution in one hour as over 30 automobiles operating for one hour, while a snowmobile can emit nearly as much as 100 automobiles in an hour. A two-stroke engine operating for seven hours produces the same amount of smog-forming pollutants as an automobile being driven over 100,000 miles.

The rule as proposed allows inefficient two-stroke engines to continue to be manufactured and sold for several years. The rule should strengthen performance standards to encourage a more timely phase-out of the dirty two-stroke engine in favor of the much more efficient four-stroke engine in all vehicle categories, especially the heavily polluting snowmobile, to substantially reduce air and noise pollution. Significantly cleaner four-stroke technology is readily available today. Two of the major snowmobile manufacturers have already begun to produce and promote cleaner four-stroke engines.

Environmental labeling. EPA should require a multi-tiered labeling system, such as California's program for marine engines, that clearly distinguishes recreational machines based on emissions so that consumers can make informed and responsible choices among products. This relatively simple and affordable measure would not only benefit customers but would greatly assist land managers in regulating and enforcing emissions standards on sensitive lands.

Noise. Noise levels from off-road vehicles--equivalent to a busy street or rock concert-- create disturbances on our public lands, where many people, particularly hikers, value quiet and solitude. Excessive noise is increasingly harmful to human health and wildlife and can disrupt wildlife reproductive patterns and habitat use. We urge EPA to use its authority to regulate the noise pollution from all machines.

Enforceability. EPA needs to ensure that engines, once in use, continue to comply with the new standards.

Cost effectiveness. EPA notes that consumer savings resulting from reduced fuel consumption and engine maintenance would largely offset the costs of compliance, given the application of more energy efficient technologies. The cost of reducing a ton of air pollution under the proposal is less than the cost for other pollution control programs (e.g. SUVs and light trucks). EPA must reject unsubstantiated industry claims of cost concerns.

Mopeds, mini-bikes, and scooters. EPA should include emissions standards for these vehicles, in addition to the vehicles already covered. The EPA should include mopeds, scooters, and mini-bikes in this rule as they are powered by the same old two-stroke engines, and the EPA should regulate noise from all of these sources.

Conclusion

Strong implementation of the proposed nonroad and recreational engines emissions controls is critical to help restore the ecological vitality of our nation’s precious national parks and wilderness areas and protect the health of millions of hikers, all-terrain vehicle and nonroad engine users, and other recreationists nationwide.