Ref. No: MSC-98-07

Dear Sir or Madam:

You are invited to a public workshop to discuss amendments we are proposing to the existing motorcycle regulation (Title 13, California Code of Regulations, Section 1958). As you may know, California continues to have high levels of air pollution known as "smog." Federal and State laws require the ARB to implement programs to reduce smog-forming pollutants as expeditiously as possible. On-road motorcycles are currently subject to emission standards which reflect technologies that are about 15 years old. Based on recent technology developments, the ARB has identified on-road motorcycles as a potential source of additional, cost-effective emission reductions. Therefore, these proposed amendments, combined with other programs under development for a wide variety of vehicular and non-vehicular pollutant sources, are intended to reduce smog-forming emissions to the levels required by Federal and State law.

Our goal is to establish on-road motorcycle emission standards that incorporate current and developing emission control technologies while minimizing the regulation's impacts on consumers, retailers, and manufacturers. We also would like to discuss any alternative strategies which will achieve equivalent emission reductions from on-road motorcycles. For your information, we have provided the following discussion to put the proposed amendments in context with other air pollution control programs under development throughout the State.

As noted earlier, California still has the worst air pollution in the nation despite significant progress made over the last 50 years. Substantial reductions in reactive organic gases (ROG) and oxides of nitrogen (NOx) are needed to meet health-based standards for ground-level ozone and particulate matter. This is particularly true in the South Coast Air Quality Management District (SCAQMD), which covers Los Angeles County, Orange County, and other highly populated areas in southern California.

With the primary goal of assisting the SCAQMD in meeting the air quality standards by 2010, the ARB adopted the State Implementation Plan (SIP) in 1994. Under the SIP, the ARB has committed to a comprehensive long-term plan that coordinates regulatory activities with the U.S. EPA, the local air districts, and the Department of Pesticide Regulation. The SIP includes control measures that are designed to reduce smog-forming pollutants from a broad range of sources, including motor vehicles, locomotives, utility engines, airplanes, stationary facilities, coatings, consumer products, and agricultural pesticides.

Many of the SIP measures call for very stringent reductions. For instance, the consumer products measures commit ARB to an overall ROG reduction of 85% from this category, or about 62 tons per day in the South Coast Air Basin. The measures relating to light-duty vehicles call for cumulative control efficiencies up to nearly 100% control (e.g., the zero emission vehicle, or ZEV standard, essentially allows no ozone-precursor emissions from a specified percentage of the new car fleet from major manufacturers by 2010). For its part, the SCAQMD adopted in its Air Quality Management Plan (AQMP) very stringent measures that, in many cases, call for the reduction of ozone precursor emissions by 80-95% from current levels. One example is the category of architectural coatings, for which the district has committed a reduction of 93% from current levels. Another example is the category of solvent degreasers; the district had committed to an 80% reduction in ROG emissions, but actually achieved a 91% reduction when the regulation was adopted in July 1997 (for a total of 40 tons ROG per day reduction).

For ARB and the U.S. EPA, the SIP contains formal commitments to reduce mobile source emissions under 16 control measures covering vehicles such as passenger cars; light, medium, and heavy duty trucks; airplanes; locomotives; and ships, boats, and other pleasure craft (e.g., "jet-skis"). While the reductions from these measures are formal commitments, the SIP is flexible in that the reductions may be obtained under alternative strategies if the commitments prove to be infeasible for a particular emissions category. To date, we found after the SIP's adoption that several control measures are not feasible, will not yield the anticipated reductions in ROG and NOx, or will cost significantly more than expected. We are therefore seeking to supplement these measures with emission reductions from sources which are not yet formally part of the SIP.

To this end, we are evaluating the feasibility of reducing emissions from on-road motorcycles. Technical advances in the many years since the adoption of the original on-road motorcycle regulation indicate significant and cost-effective reductions are feasible from these vehicles. Developments in engine management controls and catalytic converter technologies similar to those found in existing automobiles can be adapted to substantially reduce current motorcycle emissions.

Because you are a stakeholder in California business and environmental programs, your input is important to us. Therefore, we are holding this workshop to discuss our proposals with you and any concerns or suggestions you may have. The workshop will be held at the following date and location:

We plan to finalize our proposals for the Board's consideration and adoption at the October 22-23, 1998, Board Hearing in Sacramento, California.

I look forward to discussing our proposals with you. If you have any questions, please contact James Ryden, Administrative Law Judge, at (916) 324-7346, or Floyd Vergara, Staff Air Pollution Specialist, at (916) 327-1503.

Other Items for Discussion:

• Possibility of a Phased-In Compliance Schedule

• Alternative Methods to Insure Long-Term Emission Control Durability / Reduced Deterioration