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Emission Standards for Recreational Vehicles |
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December 17, 2001 Margaret Borusko Attention: Docket A-2000-01 Dear Ms. Borusko, I am writing to you to comment on the Proposed Emission Standards for Cleaner Recreational Vehicles that appeared in the October 5, 2001 issue of the Federal Register. I submit these comments on behalf of the Adirondack Mountain Club and the New York - New Jersey Trail Conference. The Adirondack Mountain Club and the NY – NJ Trail Conference are outdoor recreation and conservation organizations that represent over 100,000 hikers and backpackers in New York and New Jersey. Our organizations also belong to a national coalition called Hikers For Clean Air. The recreational vehicles covered by this proposal are significant sources of air pollution in both states and the nation at large. Their operation on public lands, parks and recreation areas has caused serious degradation of the ambient air quality of these precious lands. The health benefits sought by many muscle powered hikers and skiers have been seriously compromised by high level and toxicity of the emissions generated by these recreational vehicles. We have yet to comprehensively evaluate the likely harm to the ecological communities in those parks and natural areas. The EPA’s own recent research documents the compelling need to substantially reduce these harmful tailpipe emissions. Snowmobiles, all terrain vehicles (ATVs) and trailbikes account for about 13 percent of mobile source hydrocarbon (HC) emissions, 6 percent of mobile source carbon monoxide emissions and 3 percent of mobile source oxides of nitrogen emissions. Recreational vehicles by themselves account for some 10 percent of national mobile-source HC emissions and about 3 percent of national mobile-source CO emissions. If left unregulated, these engines will contribute 33 percent of national mobile source HC emissions, 9 percent of CO emissions, 9 percent of NOx emissions, and 2 percent of PM emissions in 2020. Emissions from snowmobile, all terrain vehicle and off-road motorcycle engines account for approximately 10 percent of HC and 3 percent of CO total mobile source emissions nationwide. EPA’s own studies estimate that ATVs emit more than 381,000 tons of hydrocarbons (HC), 1,860,000 tons of carbon monoxide (CO), and 11,000 tons of oxides of nitrogen (NOx) each year across the United States. These emissions help form smog and contain toxic compounds such as benzene, reducing them would benefit our health and the environment. EPA studies also indicate that snowmobiles emit more than 200,000 tons of hydrocarbons (HC) and 531,000 tons of carbon monoxide (CO) each year across the United States. The EPA’s own analysis shows that off-highway motorcycles emit more than 134,000 tons of hydrocarbons (HC), 181,000 tons of carbon monoxide (CO), and 1,000 tons of oxides of nitrogen (NOx) each year across the United States. The sheer volume of these unremediated emissions is staggering. These emissions contribute to ambient concentrations of CO, air toxics, and fine particulate matter that are largely responsible for visibility impairment at our state and national parks. On an individual basis, all terrain vehicles and trailbikes have very high emission rates. A two-stroke ATV or off-road motorcycle can emit as much pollution in one hour as over 30 automobiles operating for one hour. Similarly, a snowmobile can emit as much as nearly 100 automobiles. Fine particulate matter (PM) is the major cause of reduced visibility in parts of the United States, including many of our national parks. Snowmobiles and all terrain vehicles contribute to ambient PM levels directly, through PM in their emissions, and indirectly, through their emissions of organic carbon, especially NOx and SOx. Additionally, these NOx and SOx emissions cause acid deposition and smog, contributing to the chemical alteration of waters and soils in the Adirondacks, Catskills and Hudson Highlands. In particular, HC emissions from snowmobiles in the winter months can contribute significantly to the organic carbon fraction of fine particles that are largely responsible for visibility impairment. In Yellowstone National Park, a park has had high snowmobile usage during the winter months, snowmobile HC emissions exceeded 500 tons per year, as much as several large stationary sources, and account for nearly 65 percent of annual HC emissions in this popular park. Emissions from these recreational engines contain several EPA designated Mobile Source Air Toxics, including benzene, 1,3-butadiene, formaldehyde, acetaldehyde, and acrolein. Popular ATV and snowmobile riding areas on public lands can become air toxic "hot spots." The EPA must act now to promulgate strong standards to ensure that our national and state parks will be healthful places to recreate in the future. Delay or weak standards will continue the serious deterioration of ambient air quality of many of our public parks where these recreational vehicles are popular. The past decade has witnessed a rapid development of recreational vehicle technology. Powerful, high-speed snowmobiles with electronic ignition and warming systems have reinvigorated what was a declining sport. The all terrain vehicle (ATV) has evolved from a dangerous, high maintenance triwheeler to a highly popular, reliable and stable four-wheel product. Sales are booming. The ATV industry leader Honda is representative of this commercial success. American Honda's ATV sales soared in 2000, ending the year at 211,152, an increase of 29.6%. Honda exceeded the ATV industry's healthy growth rate of 18.8%. Manufactured by the same companies who produce all-terrain vehicles and jetskiis, snowmobiles represent one of the largest markets of the motorized recreation industry. Approximately 2.3 million snowmobiles are in use today with annual sales of 165,000 units. Approximately 180,000 snowmobiles travel in the U.S. National Park System each year in the lower 48 States. The EPA must act decisively in 2002 to regulate the impact of ATVs and snowmobiles to the environment. Off-road vehicles and snowmobiles contribute disproportionately to smog, haze and air pollution in mountain regions. According to the California Air Resources Board, off-road motorcycles and ATVs produce 118 times as much smog-forming pollutants as modern automobiles on a per-mile basis. Off-road motorcycles and all terrain vehicles are comprised of 2 and 4-stroke models. Many current snowmobiles and some ATVs have 2 stroke engines that emit 10 times the amount of smog precursors as comparable 4-stroke engines for each mile of travel. Some 90 percent of the estimated 34 tons of smog precursors such as nitrogen oxides and polycyclic aromatic hydrocarbons (PAHs) currently emitted each day by off-road motorcycles and ATVs comes from 2-stroke engines. Your agency estimates that 25-30% of the fuel used by the two-stroke engines of ATVs and snowmobiles, enters the environment as unburned exhaust. The EPA estimated snowmobiles and ATVs produce 1.1 million tons of hydrocarbons a year, or 15 percent of all that emitted from all mobile sources, including cars and trucks. By 2010, that share is expected to rise to 19 percent. For comparison, cars and trucks produce 4.5 million tons of hydrocarbons, the principal ingredient in the creation of summer smog and haze. ADK and the NY – NJ Trail Conference believe the proposed emission standards are a good beginning, but need to be strengthened and the regulatory timetable for full implementation and compliance shortened. The proposed emission controls should be strengthened to mandate that manufacturers replace 2-stroke ATV and snowmobile models with more efficient 4- stroke engines. In particular, the proposed standards for snowmobiles need to be strengthened considerably to ensure that the snowmobile industry acts to replace all two-stroke models with 4 stroke versions by 2004. The cleaner, more fuel efficient four-stroke engine technology already exists and production changes could be rapidly implemented if mandated today by the EPA. The EPA should mandate the use of advanced technologies such as electronic fuel injection and catalytic converters to attain the best (technologically) feasible emission levels. The EPA should synchronize emission standards for trailbikes with ATVs and require catalytic converters on both types of recreational vehicles. The EPA should address the issue of the noise levels of these recreational vehicles. The EPA has ample regulatory authority under the Public Health and Welfare Act to amend these standards to regulate and reduce the noise levels of these recreation machines. Today, much more efficient muffler and sound reduction technology is available to the recreational vehicle industry. Opponents of these long overdue environmental safeguards cite cost and performance compromises as reasons for the EPA to weaken these standards. The EPA should categorically reject these arguments. The statutory provisions of the Clean Air Act require these measures to be strengthened, not weakened. The mandate of the Clean Air Act requires that the EPA place a much higher priority on air quality improvement relative to the play performance concerns of ATV, trailbike and snowmobile enthusiasts. For us, the opportunity to breath clean air as we ski or snowshoe in a public park is far more vital than a snowmobile operator’s desire for quicker acceleration from dirty two-stroke engine. We urge you to strengthen and implement these recreational vehicle emission reduction regulations without delay. Thank you for the opportunity to comment on these vitally important federal air quality regulations and standards. Very truly yours, Neil F. Woodworth |
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