Jetskis

To: americanlands-list@igc.topica.com

From: Steve Holmer wafcdc@americanlands.org>
Subject: Comment to stop ORV pollution
Date: Tue, 8 Jan 2002 20:20:29 +0000
Reply-To: wafcdc@americanlands.org

To: All Activists

From: Alix Davidson, Recreation Campaigner
Date: January 8, 2002

Stop Air and Noise Pollution from Off Road Vehicles
Write the Environmental Protection Agency Today
The U.S. Environmental Protection Agency (EPA) recently issued a proposal to reduce air pollution from snowmobiles, dirt bikes and all-terrain vehicles (ATVs). This proposal sets weak standards - especially for snowmobiles - and will not substantially reduce air and noise pollution from off-road vehicles unless strengthened significantly. To make matters worse, during recent public hearings in Washington and Denver, the off-road industry presented a united front opposing the proposal as too stringent, and made it clear it would submit "many, many comments" against it. Contact the EPA today -NRANPRM@epa.gov - to urge the agency to do more to reduce harmful air and noise pollution from these machines.
The deadline for comments is January 18th! Dirty Machines - Dirt bikes, ATVs and snowmobiles are a major source of air and noise pollution nationwide. Most of these machines are powered by antiquated two-stroke engines that burn a combination of gas and oil. According to the EPA, the average two-stroke dumps 25 to 30 percent of its fuel unburned into the air and water. The California Air Resources Board concluded that operating a two-stroke motor for about 7 hours generates as much smog-forming pollution as driving a modern car more than100,000 miles. The EPA estimates that dirt bikes, snowmobiles and ATVs alone produce 10 percent of all hydrocarbon pollution from vehicles nationwide. Air pollution from these machines also threatens public health and has been directly linked to respiratory disease, cancer and premature death.Polluting Public Lands - Off-road vehicles are a major source of pollution on public lands. In Yellowstone National Park, although cars outnumber snowmobiles 16 to 1, snowmobiles produce as much as 68% of the Park's annual carbon monoxide pollution and up to 90% of all hydrocarbon emissions. The average dirt bike traveling across BLM lands in the west generates 8 times as much air pollution as the average car. Pollution controls are also needed because these machines are impairing visibility in national parks, wilderness areas and other public lands across the country.

Weak Proposal - The EPA has taken a step in the right direction by proposing to reduce pollution from these machines - a step that's long overdue. However, the proposal issued on September 14 falls far short because:

1) It fails to encourage a rapid transition from dirty two-stroke to cleaner, more fuel-efficient four-stroke engines, especially in nowmobiles.

2) It fails to address noise pollution from machines that are as loud as a busy street.

3) It does not include a labeling system that would give consumers user-friendly information about emissions to help them make more informed choices between machines.These standards can be much stronger. Four-stroke technology is widely available today in off-road vehicles. In fact, two of the four major snowmobile manufacturers are already making and promoting four-stroke machines. Nevertheless, the snowmobile industry pressured the EPA to issue a weak proposal and has made it clear it will fight even the very modest pollution controls under consideration.

TAKE ACTION -- Contact the EPA before December 19, 2001 and urge the agency to:

1) Substantially strengthen the proposed standards for snowmobiles inorder to quickly and completely phase-out dirty two-stroke snowmobiles;
2) Harmonize proposed standards for dirt bikes with ATVs by requiring catalytic converters on both machines;
3) Use its legal authority to reduce noise pollution from all machines;
4) Establish a mandatory, multi-tiered labeling system that gives consumers easily understandable information about vehicle emissions; and
5) Require particle filters on all diesel boats to protect public health. Contact Information:
In all comments, reference "Docket A-2000-01."
Send electronic comments to: NRANPRM@epa.gov
Send written comments to: The Honorable Christine Todd Whitman, c/o Margaret Borushko, U.S. EPA, National Vehicle and Fuels Emission
Laboratory, 2000 Traverwood, Ann Arbor, MI 48105.

A sample letter is below- please modify before using.

Dear Governor Whitman:
I urge the Environmental Protection Agency to use its clear legal authority to substantially revise its proposal to control air pollution from recreational vehicles and engines in order to provide stronger protection for air quality, human health and the environment. Dirt bikes, snowmobiles and all-terrain vehicles (ATVs) are a significant source of air pollution nationwide and particularly large sources on public lands and in rural areas. As the proposal explains, these machines alone account for approximately 10 percent of nationwide mobile source emissions of hydrocarbons. While virtually every other vehicle has been, or soon will be, getting cleaner, snowmobiles, dirt bikes and ATVs have not. In fact, these vehicles are a larger source of air pollution today than 10 years ago. On public lands, off-road vehicles can be the largest single source of air pollution. For example, although cars outnumber snowmobiles by about 16 to 1 in Yellowstone National Park, the National Park Service has concluded that snowmobiles produce up to 68 percent of the Park's annual carbon monoxide pollution and as much as 90 percent of its total hydrocarbon emissions. The adverse health effects associated with carbon monoxide, hydrocarbons, fine particles and the host of toxic chemicals, including benzene, common to pollution from off-road vehicles are severe and well-documented, including respiratory disease, cancer and premature death. Riders, public employees and others directly in the path of these machines are particularly at risk for high-level exposure to harmful emissions. Moreover, the health of millions of Americans is negatively impacted as pollution from these machines travels hundreds of miles to communities from coast to coast. In order to provide stronger protection for public health and theenvironment, the EPA should revise the proposal by:
1) setting more protective air standards for snowmobiles in order to encourage a rapid and complete transition from dirty two-stroke to cleaner, more fuel-efficient four-stroke engine technology; 2) harmonizing emission standards for dirt bikes with ATVs by requiring catalytic converters on both machines; 3) proactively using its authority under the Public Health and Welfare Act to reduce harmful noise pollution; 4) instituting a mandatory, multi-tiered labeling system that will provider prospective purchasers with user-friendly information about vehicle emissions; and 5) requiring particle filters on all diesel boats.

The EPA has very clear legal authority - and an unquestionable legal responsibility -- to issue final standards that will more significantly reduce air pollution than would be achieved under the proposal. Section 213 of the Clean Air Act requires the Agency to issue standards that will achieve the greatest degree of emission reductions achievable with technology that will be available. The proposal as written does not meet this standard. Technology available today, including four-stroke engines, catalytic converters and other advanced emission control equipment, can reduce pollution much more significantly while remaining cost-effective and safe. Four-stroke technology is already widely used in ATVs and many dirt bikes. Moreover, two of the four major snowmobile manufacturers are producing four-stroke machines. In spite of the widespread availability of this technology today, the proposal would allow continued large-scale production of two-stroke snowmobiles for the indefinite future.
In addition, Section 169 of the Clean Air Act gives EPA clear authority to protect and improve pristine air quality in class 1 federal areas, including National Parks and wilderness areas. Off-road vehicles are impairing air quality and visibility in National Parks and other public lands in part because they emit very high levels of hydrocarbons - as much as 250 times more on a vehicle-by-vehicle basis when compared to a modern car. The adverse impacts on visibility and air quality are not limited to National Parks and wilderness, but extend to National Forests and regions under the jurisdiction of the Bureau of Land Management where the use of dirt bikes, ATVs and snowmobiles is widespread and growing. Finally, more protective standards will also be cost-effective, reduce energy consumption and help to cut harmful noise pollution.

Air pollution is a national problem - not only an urban problem. The EPA has clearly documented that snowmobiles, dirt bikes and ATVs contribute significantly to this problem, and that contribution has actually increased. I urge the EPA to revise its proposal in order to strengthen protection for air quality, public health and the environment.

Sincerely,

Steve Holmer
Campaign Coordinator
American Lands
726 7th Street SE Washington, D.C. 20003
202/547-9105 / 202-547-9213 fax
mailto:wafcdc@americanlands.org
http://www.americanlands.org