SDORC president Ed Stovin recently submitted the following comments on the proposed red sticker regulations to the California Air Resources Board:
Scott Monday
Staff Air Pollution Specialist
California Air Resources Board
Engineering and Regulation Development Section
1927 13th St. Sacramento, CA 95811
Re: Comments Regarding Latest Red Sticker Program Regulations
Dear Specialist Monday:
The San Diego Off-Road Coalition would like to comment on the California Air Resources Board proposed changes to the current red sticker program. We thank CARB for the opportunity to comment and for keeping the air in California clean.
Many of our members own red sticker motorcycles (myself included) and we are concerned about the fate of our bikes and future opportunities to own high quality racing motorcycles. I attended the workshop in El Monte on May 16 and I appreciate the staff’s willingness to discuss the proposal with the public.
When a change in regulation is proposed, the agency in charge needs to make decisions based on facts and good science. I would like to point out some areas in which CARB’s data may be questioned.
The handout from the workshop starts with the purpose and need, that California has the worst air quality in the country. California is a very large state and vast areas within it have very clean air. The greater Los Angeles area is known for having bad air quality. There are no red sticker off-road areas in the greater Los Angeles area unless you go far to the eastern edge. Because the wind in this region almost always blows to the east, red sticker emissions contribute almost nothing to the air quality problem in LA.
I took the survey on red sticker bike usage and I ride in places where red sticker bikes are used and from my own personal experience, red sticker bikes contribute an extremely small amount of air pollution. When I go to a race or practice, there are usually no more than 20 bikes running on the track at any given time. This would be on weekends; on weekdays there would be much less usage of these bikes. The survey itself seemed to try to get riders to overestimate the amount of actual running time when at a track or riding area. In 2016 there were over 2 million cars sold, but there were only about 5,000 red sticker bikes sold. It feels like CARB is trying to solve a problem that does not actually exist. Worse, the so-called solution will hurt manufacturers, dealers and riders of red sticker bikes.
There are two types of emissions in question, tailpipe and evaporative. In your evaporative page, you say that red sticker carbureted bikes release 15 to 26 grams per day. The average carburetor holds about that much fuel. What you fail to understand that almost all riders turn off their gas valve after riding. I own 15 motorcycles now and have owned about 60 in my life; only 6 have been fuel injected. In my experience, it typically takes a couple months for a carburetor float bowl to go dry, so I don’t understand where this high amount comes from. Even if a float bowl were to evaporate in one day, with the fuel valve off, no more fuel would evaporate in the following days. This is very misleading.
There is a chart with the population of red sticker bikes that goes from year 2000 to 2040. I don’t see how you can make any kind of estimate of motorcycle sales more than 20 years into the future. How does the red sticker population rise decades after the program is stopped?
You say you want to accelerate development of zero emissions OHRVs. I suggest you work on mountain bicycle sales to achieve this. I am the one who brought up the generator next to the electric motorcycle. Unless electric bikes are plugged into solar panels, they will be making emissions somewhere.
We are opposed to prohibiting racing motorcycles from being operated on public land. It will have large economic consequences on many people and not really affect air quality significantly. While that is our position, I would like to comment on your proposals.
In the proposal, you want to end red sticker sales in 2022 and begin categories 1 and 2 sales. I believe many manufacturers work in five-year cycles to design and build bikes. May I suggest you allow at least one more year of red sticker sales? The six years with category 1 and 2 sales is a generous way to allow manufacturers to ease into building cleaner bikes.
You talked about fleet averaging. What is the definition of a fleet? Just motorcycles or all off-road vehicles made by a manufacturer? Many customers are looking for an off-road vehicle experience and may decide between a motorcycle, ATV or side by side. I believe all these should be part of a fleet.
How to deal with competition vehicles is going to be quite a challenge. I hope I can be a part of this process. I was unable to get into the teleconference workshop you had last week. I hope I can participate in future ones. Please make sure my email ([email protected]) is added to the list when meetings or workshops are planned.
I appreciate current red sticker bikes being grandfathered in and having their seasons removed. I would like to know the precise definition of “grandfathered” in this case. Will they get green stickers once the DMV finishes off their red sticker supply? Why do we have to wait seven years for the seasonal restrictions to be lifted in 2025? Why not lift the restrictions at the beginning of 2022 when red stickers will officially end?
I understand CARB wanting to control emissions on public land. While I can understand CARB regulating activity on State-owned land (like SVRAs), I would like to know how CARB has the authority to regulate vehicle emissions on federally-owned land, like BLM and National Forests?
It appears that in compiling the information for this project, CARB has made many assumptions. I feel these assumptions make it look as though this action is going to make the air a lot cleaner. I believe that in the real world, this plan will not change air quality significantly, but will hurt a lot of people who just want to sell and ride high performance motorcycles.
While we are talking about off-road vehicles and fuel, I have used the so-called “approved” fuel cans. My experience is that they spill when being used and do not pour very well. I would like to see CARB test these cans by filling bikes with them while inside the little emissions rooms you have. I think you will see the problems we have with these cans. Compare them to the unapproved cans that pour very well. I hope we can make headway in approving cans that pour both cleanly and easily.
Thank you for allowing me to comment,
Ed Stovin
President, San Diego Off-Road Coalition