Cycle News - Archive Issues - 1970's

fusing and conflicting ordinances in state and local jurisdictions. But beyond that, we can find very little favorable to say about EPA's proposals for establishing a standard. What EPA has developed is an in flationary and unreasonable plan for reducing motorcycle noise . Further. more, that plan, if adopted , would not achieve significant results, nor would it confront excessive motorcycle noise at its source, and EPA has admitted that fact . EPA's plan will create significant cost increases for motorcycle purchasers and it will do practically nothing to curb excessive noise. Even by EPA 's own data , 88% of the motorcyclists in America today , amounting to about 6,000 ,000 people, own , ride , and maintain quiet motorcycles , at 83 dB(A) or less. A motorcycle noise problem does exist , but it is the result of a few motorcycle owners who modify or fail to maintain their exhaust systems. However, consider the fact that nothing in the plan will discourage this minority from purchasing a new motorcycle at EPA's inflated costs , then cutting the silencers : off of it. The extent of this punishment is best shown graphically (refer to Chart A). Over the last few years, manufacturers of motorcycles have lowered the noise , emissions of their product from 92 decibels to 83 decibels. According to one major manufacturer, this has added a maximum of $34 to the cost of the product. ' According to EPA's own data, compliance with the agency's plan at the current status quo level of 83 decibels, will ad $16 more to the cost of new ' motorcycles. This amounts to industry-wide costs of $25 million dollars that will be passed on to the consumer. That $25 million dollars achieves no noise reduction benefits, and is , presumably the cost of EPA assuring itself that the industry is complying with the status quo. Once we move to EPA's next level of compliance, at 80 decibels, we have tacked $52 onto the price of a new motorcycle. You can see how rapidly 'the cost curve shoots upward. At 78 decibels the consumer will pay an additional $140. ' However, let us consider the fact that I have presented information from EPA's own calculations. In public testimony most of the manufacturers disagreed, some placing estimated 'costs of compliance as high as $400 per motorcycle, and that estimation was based, a year ago , on 1978 dollars. The Council on Wage and Price Stability also disagrees, and sees the possibility for a , $350 million dollar annualized cost , which translates to about $375 per new vehicle. Incidentally, the broken line is there to clarify that there is not actually a reduction from current cost pass-ons to EPA's $16 starting cost . The $16 EPA increase is in addition to the price the consumer has already paid for noise reduction. Let us now compare this inflationary curve against actual noise reduction benefits (refer to Chart B) . To do this, you must be aware that decibels are units on a logarithmic scale . A reduction from 100 to 97 decibels, for example, is not a 3% reduction of sound energy. It is a 50% reo duction. Noise is reduced by half for every three decibels. Consequently, recent industry noise reduction from 92 to 83 decibels represent a reduction in sound energy of about 88% . To move to 80 decibels, we are reducing noise by only 6% from the original 92 dB(A) level; to 78 decibels, only about an additional I ~. The reductions provided by , the EPA plan are negligible when laid against the inflationary curve. That is what we have in this illustration. Notice how the decibel line flattens out; how the dollar accelerates upward. , This kind of alarming comparison of costs versus benefits is what led the Council on Wage and Price Stability to attack EPA's plan.iand to conclude that the only reasonable standard that would balance costs versus benefits is 83 decibels; 80 decibels at the very outside. ,/ Each year AMA conducts a govern· ment relations attitude survey among our members. This year we incorporated the question , "If I thought it would get the government and the public off my back, I would:" The responses were the following: I would accept nationwide noise standards, .. .but not if they would add to the price of a new motorcycle: 47.7% .v. lf they would add up to $50: 18.9% .. .iftheywould add $50 to $100: 6.6% ... if they would add $100 to $200: , 1.4% As you can see: the level of consumer acceptance drops off rapidly beyond the $50 figure. 1 find this to be a very interesting response, because it ' independently supports, on a level of consumer acceptance, what Council on Wage and Price Stability economists found through scientific method, using the widely accepted Nelson methodology; namely, that any reduction beyond 83 dB(A) has questionable value; any beyond 80 dB(A) is intolerable and totally unjustifiable. ' Wehave met with the EPA staff to point out these facts . 1 regret to inform you that in our last meeting with EPA, we were told , "Inflation isn't our problernl" I will not name the ranking staff member who said that because it is not my desire to become persona in my value judgements of this agency. I am sure that he was speaking legalistically, referring to tile prime objective that Congress has mandated for the agency. However, I must suspect that President Carter would be greatly displeased to hear any employee of any federal agency express such a state, ment at this point in time.' 'spea king legalistically or otherwise. . Ladies and gentlemen, in practically every area or environmental concern, this government has had to step back and take a hard look at compromises between its environmental aspirations and the economic realities. I need not tell you the number of regulations, timetables, and standards ' that have been relaxed this year. I need to remind you of the necessary moves being taken toward deregulation in many areas . These adjustments are the results of new and realistic assessments and an awareness of the fact that what may have been viewed as acceptable trade-offs five years ago, when EPA started development of its proposed motorcycle noise regulations, are not acceptable trade-offs today. . You, as elected leaders of this nation, are well aware of that , and we would not remind you of it today had we the smallest conviction that EPA ' ca red about our problem from the consumer's point of view, or had listened to what we have tried to tell them. . Throughout public comment on these . proposed regulations, you will find "hammer" and "bludgeoning" imagery. As one commenter said, "These regulations are the classic example of swatting a fly with a sledgehammer." I would add that it may well be a gold-plated sledgehammer, originally estimated by $200 million per year, recently revised by EPA upwards to $224 million per year, and pegged by ~OWPS at up to $350 million per year. ' And this ' money, which will come right out of the pocket of the American motorcycle owner, whom I might add is relying more and The AMA's Ed Youngblood listens as Harley-Davidson Chairman John Davidson delivers his address against proposed EPA noise regulations. more upon his vehicle because it uses, less gasoline, will provide little or no benefits in actual environmental noise reduction. For these re~sons we appeal to you today to help us convince EPA of its disastrous course. We feel the agency has not listened to us. Surely, it will listen to you. Thank you. Below are highlights ofJohn Davidson s address. Before 'examining the- impact the EPA noise proposals could have on Harley-Davidson, let me fill you in on the scope of our operations. . . We currently have facilities in three locations. Our main offices and engine transmission assembly plant are located in Milwaukee. We have another plant in Tomahawk, Wisconsin, which produces fiberglass components. Together these operations employ about 2,000 people, with a monthly payroll of $3.7 million. Another sizeable operation is our final assembly plant in York, Pennsylvania. This 'facility employs 1,700 workers, with a monthly payroll of $2.3 million. In ' 1978, total Harley-Davidson .revenues ' were some $228 million. Another significant component in our business is our distribution system. Currently, there are 752 independent, franchised Harley-Davidson dealers, involving some 4 ,200 jobs . 1978 revenues for these dealer operations are estimated at more than $323 million. Thus, there are some 8,000 HarleyDavidson generated jobs that could be directly affected by federal noise regulation. However, these same jobs would also be much affected , if the EEA took no action at all, since many states have or are considering their -own noise regulations that are different than the proposed federal standards. Thus, I urge you in no way to con'sid er our challenge of the severity of _ the federal proposals as a call for elimination of federal action altogether.· Harley-Davidson fully supports a federal standard and we only take issue with the severity of. the proposed standards. ' Let's look into each of these areas individually. , In calling for an 83 decibel maximum noiseoutput by January 1, 1980, 80 decibels by 1982 and 78 decibels for 1985, the EPA has failed to show just reason why these levels are necessary at the manufacturer level or what the benefits are that accrue to the public. In fact, we cannot find statistical evidence any place in the notice of proposed rulemaking that stringent controls at the manufacturer level will benefit the public, other than through what a small minority of the "po pula tion would vaguely label as noise annoyance. It should be noted that when we're talking about a reduction in decibel output, we're not talking about a , straight linear progression based on a scale of 100. Decibels are based on logarithms, and as such, a small numerical difference represents a much larger physical difference. For example, a reduction from an 83 decibel level to 80 represents a 50 percent decrease in the sound a person hears. To give you an overall idea of how decibels relate to noise levels, we con-duct ed some tests on a few household items with the following results: Item ' .A !!... Electric food slicer 85 dB(A) 30" Electric Shaver 92 dB(A) I" Hair dryer 96 dB(A) I" , EPA repeatedly uses two main criteria for determining the annoyance from motorcycle noise - speech interferences and sleep disturbances, but the numbers used to determing occurrences of these annoyances are not based on normal survey methods. The analysis contained in the background document to the NPRM is based on assumptions about actual motorcycle noise during normal operation on a hypothetical public. (Harley-Davidson maintains that theoretical analysis is not justified in view of the importance of these regulations to our business.) Another, assumpion involves the ac tual test procedure. Under ,the proposals , testing is done through basically a full-throttle pass· by test. Perhaps the agency is assuming that the majority of motorcycle riders ac celerate at full throttle, which naturally produces the most noise . However, motorcycles in traffic do not noticeably vary from the normal acceleration pattern of other vehicles surrounding them . Typically, motorcycles meeting an 83 decibel level at full throttle in the low to mid 70 decibel range under normal traffic 'circum stances· well in -line with other traffic noise. Then there is the matter of numbers. , According to Motor Vehicle Manufacturers' Association and Motorcycle Industry Council statistics compiled for 1975, there were 132 million cars (Continued on page 43) 19

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