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Costs – Catalyst technology can be cost-effectively applied to highway motorcycles. Certainly, the cost of catalyst technology presented no roadblock to adopting or implementing catalyst-based motorcycle and moped standards in countries such as Taiwan, Thailand, China, and India where per capita income is much less than in the United States. Experience in countries with motorcycle emission control programs has shown that the costs of catalyst-based systems range from as low as $5 to up to about $100, depending on a variety of factors including the engine size, level of engine out emissions, level of the standards, packaging considerations, and the sales volume of catalyst systems.

Proposed Class III Standards

MECA supports EPA’s proposal to harmonize the level of the federal standards for Class

III motorcycles with California’s standards, but we believe delaying the implementation date for the Tier 2 standards by two years is unnecessary. With regard to the Tier 2 standards, EPA notes in the proposal that one manufacturer has already been certified at levels meeting the 2008 California Tier 2 standard. Given the extensive experience and proven track record of catalyst technology in motorcycle applications, the continuing advances in automotive catalyst technology, which EPA rightfully points out can be applied to motorcycle applications, and the six-year lead time before the California Tier 2 standards go into effect, delaying the federal Tier

2 standards an additional two years cannot be justified on the basis of technological feasibility.

As EPA notes in the proposal, ARB will review in 2006 the technological progress in meeting the 2008 California Tier 2 standards and EPA will actively participate in that process. If EPA should conclude based on that review that manufacturers will be unable to meet the Tier 2 standards nationwide in 2008, the Agency could at that time propose a delay in implementing the federal Tier 2 standards.

MECA also believes EPA’s suggestion to extend the useful life requirements for Class III motorcycles to 40,000 km is technologically feasible. As discussed above, catalyst technology has demonstrated excellent durability in motorcycle applications. In automotive applications,


September 17, 2002

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