Emissions Targets – Really A Sound Issue

Europe – ACEM the European Association of Motorcycle Manufacturers (ACEM) has published a position paper on requirements to apply amendments to a European Regulation.

The regulation is the Approval and market surveillance of two- or three-wheel vehicles and quadricycles regulations which we dealt with previously as Right To Ride EU . It was implemented in 2013 and referred to the type-approval of new motorcycles.

Since then the European Commission (mainly through a stakeholder working group, Motor Cycle Working Group (MCWG), comprised of the motorcycle industry rider groups and government representatives), has been “working” on the details of application of the Acts within the regulation and the requirements set down to implement certain amendments to the regulation.

Part of this is the scheduled introduction of new Euro 5 emission standards for 2020, sound level test procedure and limit values.  This is how sound from a motorcycle is measured and thus the decibel level that can be measured to ensure compliance to type approval.

Simply (if ever anything could be simple), manufacturers shall ensure that vehicles are designed, constructed and assembled so as to minimise the impact on the environment, the gaseous pollutants and particulate matter, plus the sound or noise the bike emits.

Apart from looking at ACEM’s position on amending emissions in the regulation, we take a look at problems that are facing motorcyclists in terms of emissions requirements for daily riding on public roads.

Motorcycles Targeted Charging Emissions

As we know cities across Europe have or are planning to introduce low emission zones that see vehicles having to pay charges to travel within these zones, these include London and Paris.

Widely debated/discussed/publicised is London’s plan to introduce a ULEZ (Ultra Low Emission Zone) which would be applied 24 hours a day, 7 days a week every day of the year, including weekends and public holidays, with exemption for historic vehicles. This is where all vehicles will need to meet exhaust emission standards (ULEZ standards) or pay a daily charge. This is within the present London congestion zone which now sees motorcycle exempt from charges for travelling in the zone.

Currently for motorcycles, London’s plan would see a £12.50 charge to travel in the zone for those bikes built before the Euro 3 emission standards (2007).

This charge is seen as disproportionate, as all vehicles will be charged the same amount as cars, vans, trucks etc while others say riders should not be charged any amount because of the congestion, environmental, accessibility, cost benefit, low income friendly usage that motorcycles can provide.

One aspect of motorcycle usage has been seen as a means of personalised motorised transport, that is cheap and affordable especially for those on a lower income. This is still perpetuated by black and white news reels of – mainly male riders – in smog polluted cities – wearing flat caps, riding British made bikes to labour intensive or menial jobs.

Perhaps those introducing the rules and regulations of access to city and urban areas have the perception of dirty, noisy, oil dripping bikes, an issue which appears to remain with some legislators and politicians even today.

Ongoing on street demonstrations and attempts to challenge the ULEZ proposed charges to persuade authorities and their leaders to lower or exempt motorcycles from charges continue from rider groups.

The French Factor

In Paris and other French cities environmental zones have been created the first in 2016 or are being proposed where vehicles must pay for a Crit’Ar Vignette badge – Air Quality Certificate to travel in these zones or face a penalty charge.

For motorcycles – motorized two-wheelers, three-wheelers, and light four-wheelers having been registered before 1st June 2000, along with other vehicles, a Crit’Air badge will not be issued, therefore effectively an entry ban is in place – Monday to Friday between 8 am and 8 pm.

The Crit’Air badge is available in different colours each one showing which Euro emission standard your vehicle belongs in, which then means your vehicle could be excluded from travelling in a zone.

There are exemptions for example in Paris for what are described as “old timers”, however according to the Crit’Ar website in the cities of Grenoble and Lyon, there are no exceptions for vintage cars at present. “It is even emphasised that vintage cars will also be punished if they enter the metropolitan areas of Grenoble and Lyon during air pollution peaks. This is particularly bitter, as in the case of Grenoble this also affects the main highway to the south.”

The cost of the Crit’Air badge in France is €3.62 with postage to other parts of the EU or Switzerland bring the cost up to around €4.21 – to include postage. The Air Quality Certificate is valid as long as the vehicle retains the same environmental classification throughout its lifetime and as long as the badge remains legible.

Compared to London the French aren’t doing too badly!

The French riders’ organisation FFMC (Angry French Bikers) who have protested against these charges, have stated,

“Political and social pressure is intensifying to defend road safety, living together in the most limited pollution and noise possible, while preserving vital mobility in the modern world. At the same time, new technologies are developing (…). While the new technologies bring significant advances to improve safety and reduce environmental pollution (…), they also cause significant social changes”

“Concerned about environmental issues, aware of the need for an energy transition to preserve future generations and committed to the freedom of choice of modes of transport, the FFMC takes into account new technologies and mobility issues while preserving the predominance of humans, their freedom and independence.”

The French riders are very passionate and determined…

For UK riders, this environmental adaption will either include purchasing a motorcycle with “better” environmental credentials, public transport, walking, cycling, all or some of which are not always viable with the alternative in the case of London, of paying £12.50 a day.  However, the fundamental argument, as demonstrated from other studies in Europe, is that motorcycles use far less travel time and are far less likely to be held up in traffic jams.

Thus, in real terms, the pre Euro 3 motorcycles would pollute less in comparison with four wheeled vehicles that are compliant with the later 4 and 5 Euro standards, especially diesel fuelled vehicles, simply because they are not standing idle for the lengths of time that cars, vans, lorries and buses are.

Swedish Example

It is not all doom and gloom for motorcycle access to cities in Europe as the Swedish Motorcyclists Association (SMC) announced recently that their government sees motorcycles and mopeds as a smart, functional and environmentally friendly vehicle that help to make the air cleaner and urban environment better in the cities. Which also contribute to reduced congestion, increased accessibility, and contribute to sustainable cities.

The Swedish Government is allowing cities to introduce environmental zones the “highest” zone which only allows access for light cars, light trucks and light buses powered by electricity or hydrogen will also include motorcycles and mopeds.

Now all that needs sorted out is the city of Stockholm, which has introduced one of the world’s highest parking fees for motorcycles and mopeds, without any kind of investigation or impact assessment for the citizens.

Compared to London and France the Swedes have never had it so good!

What we can see however from the motorcycle industry representatives ACEM is that emission wise, “Over the last decades motorcycles have achieved remarkable progress in enhancing their environmental performances. Through manufacturers’ continued R&D investments, today’s motorcycles have better fuel efficiency levels than in the past.

Since 1999 motorcycles have steadily reduced their overall emissions through the introduction of Euro emission steps that has saw manufacturers meeting standards of reduced emissions: – Euro 1 1999 – Euro 2 2003 – Euro 3 2006 – Euro 4 2016 and now for Euro 5 in 2020.

“Vehicle emissions – including sound levels – have also been drastically reduced over the years, while the improvement of gasoline engines and the launch of new electric and hybrid models in the market clearly show that the industry is committed to making a valuable contribution to the environmental sustainability of Europe’s transport systems.”

The point we are trying to make is that motorcycles and their emissions or lack of, coupled with other benefits are seen by different authorities with different agendas to clean up their cities and how inclusive motorcycles and their riders are by degree.

Commitment – Environmental Steps

From the start of the year ACEM has produced two position papers, the first in February 2018 – Riding in a 21st century environment – the motorcycle industry’s commitment to the environment – the second in May 2018 – The implementation of the Euro 5 environmental step

The first paper presents, “How the industry views the role of its products in enhancing the environmental sustainability of transport and how it contributes to achieving this goal, when it comes to pollutant emissions, climate change, noise levels and the controlled use of hazardous substances.”

That role being set out as, “From congested super-cities such as Paris, London or Rome to the most remote places of the European Union, hundreds of thousands of European citizens use these vehicles on a daily basis to get to their jobs on time, to get back home, to move around swiftly for professional purposes or simply to enjoy the feelings and emotions that these vehicles offer.

In effect, motorcycles play an important role in our modern lives: whilst police forces, paramedics and breakdown services use them in emergency situations, motorcycles are also used for the delivery of services and goods, the provision of leisure and tourism opportunities, and are a good solution to reduce congestion levels in urban and peri-urban environments and to compensate for the lack of public transport in remote areas.”

This paper also looks at addressing continuous environmental challenges including sound emissions, periodic roadworthiness, inspections and roadside checks and offering suggestions for policy makers and comments, “Mainstream motorcycling into transport policies. Inclusive motorcycling policies should be developed by European and national policy-makers. They should recognise that motorcycles are a key means of transport, particularly in cities. They can fit in climate change mitigation strategies and therefore should be duly taken into consideration in transport planning.”

It is well worth a read even if just to update yourself on the advancement of the reduction of motorcycle emissions.

Euro 5 amendment EC proposal

The second paper is really what we are looking at, as it looks to the future as emission standards “tighten” towards the introduction of Euro 5 emission standards in 2020.

The motorcycle industry is striving to meet future regulations to comply with quieter and quieter overall sound reduction.

The paper, “represents the opinion of the motorcycle industry in Europe regarding the implementation of the new Euro 5 standard which, as usual when new standards are introduced, will require the modification and redesign of many vehicle components, including engines.”

This regulation was responsible for introducing Euro 4 emissions for motorcycles in 2016 and since then the industry and rider organisations have been looking at the introduction of Euro 5 emissions with the European Commission included in a Motor Cycle Working Group (MCWG) in Brussels.

ACEM says regarding amending the regulation that, “At the time of the adoption of this Regulation, the European Parliament and the Council requested the European Commission to re-evaluate the feasibility of this further environmental step closer to its application date. On this basis, the European Commission performed a comprehensive effects study, taking into account issues encountered by approval authorities and stakeholders in applying the Regulation to date. On this basis, the European Commission is now proposing modifications and clarifications to ensure its smooth application.”

ACEM adds, “The adoption of the amending Regulation should not be delayed in order to provide the Industry and the Member States authorities sufficient time to correctly implement the Euro 5 requirements for new vehicle types.”

On-Board Diagnostic (OBD) – ACEM sets out its concerns on the requirement to install a Stage II On-Board Diagnostic system (OBD) that includes environmental measurements.

Agreeing with the European Commission that some of the more stringent requirements are delayed until 2024, with an extension exemption to the Enduro (L3e-AxE) and Trial (L3e-AxT) motorcycle subcategories which are in place for Mopeds (L1e and L2e categories).

Durability – Durability is a requirement for manufacturers to state the, “ability of components and systems to last so that the environmental performance can still be met after a set mileage so that vehicle functional safety is ensured, if the vehicle is used under normal or intended circumstances and serviced in accordance with the manufacturer’s recommendations”.

The regulation uses a mathematical durability procedure, “the emission result of a vehicle run-in over a minimum distance of 100 km of use is multiplied by a mathematical deterioration factor.” which the European Commission proposed to phase out by the end of 2024, ACEM state that it, “can accept the proposed increased run-in distance.” originally set in the regulation, as far as we can ascertain as 35.000km, which the European Commission has proposed.

The procedure to replace this a bench ageing procedure which is, “already well established and accepted as a robust method for determining the degradation of emissions control systems in other motor vehicles.”

To go into this would take several more hours but suffice to say this is important as we have already discussed emission zones introduced in cities that are setting out the requirements on what emission levels a motorcycle fits into to.

For London that is Euro 3 introduced in 2006.  Could the UK see emission testing for motorcycles at MoT time to prove continued emissions levels after durability levels have run out?

Tailpipe Emissions Limits – the emission of gaseous pollutants and particulate matter at the tailpipe of the vehicle and their limit values – range of emission levels.

ACEM agrees with maintaining of the limit values as, “Euro 5 limits for L-category vehicles are numerically identical to those for Euro 6 cars.”. They have called for in agreement with the recommendation and proposal of the European Commission to, “postpone the application of Euro 5 emissions limits for certain L-category vehicles.”

(L6e-B, L2eU, L3e-AxT and L3e-AxE) Light quadricycles, 3 wheeled utility mopeds, Trial motorcycles and Enduro motorcycles in consideration, “the total yearly emissions of these niche vehicles (these vehicles represent less than 1% of the total L-category vehicle fleet), ACEM calls on the co-legislators to extend the proposed postponement to 2024”.

ACEM say that, “Postponement is essential for the manufacturers of these vehicles, which are mainly SMEs, as they require more lead time to ensure a smooth, cost effective and non-business-disruptive transition” and “this would give also further clarity in the application of the type-approval framework by aligning dates with the OBD II requirements above.”

Finally – On Sound Level Limits

While there may not be much interest in the previous technical issues, the mention of “tampering” with sound levels will have many riders pricking up their ears.

ACEM states that it, “Supports the EC proposal to remove inconsistencies in the date of application of the sound level limits for Euro 5 in Annex IV to Regulation (EU) No 168/2013. These should be clarified to ensure that the existing limits (Euro 4) stay applicable until the new limits for Euro 5 can be established.”

Looking at this annex in the regulation we can see that varies dates of introduction are set out for different categories of motorcycle tied in with a different date for some categories on global vehicle regulations at the UNECE – United Nations Economic Commission for Europe (WP 29).

These are:

Regulation No. 9 – Noise of three-wheeled vehicles

Regulation No. 41 – Noise emissions of motorcycles

Regulation No. 63 – Noise emissions of mopeds

Regulation No. 92 – Replacement exhaust silencing systems (RESS) for motorcycles

Also, the testing/measurement of sound/noise for new type approved motorcycles is being changed, including what appears to be a reduction in permitted decibel levels, with work on this reported through the previously mentioned European Commission MCWG.

Although the industry has to cope with producing a motorcycle that is technically “legal and safe” at the point of sale the issue of motorcycle noise for motorcyclists and now they are perceived by the general public, legislators and politicians has been an ongoing saga.

Since being involved in motorcycling, the saga of loud motorcycles has always been a “negative” issue for motorcycling and what we are looking at is the fitting of “illegal” aftermarket exhausts or tampering with original exhausts.

The Loud Pipes – Silent Running

To prove that point, in the UK parliament in November 2017 Lord Laird asked a question regarding motorcycle noise:

“To ask Her Majesty’s Government what proposals they have to reduce the noise level of motorcycles on public roads.”

The reply from Baroness Sugg was:

“Technical standards for noise from new motorcycles are set at an International level by both the European Union (EU) and the United Nations Economic Commission for Europe (UNECE). These provisions were updated in 2014 and took effect for new machines from 2016.

The European Commission is planning to introduce new legislation concerning emissions and noise from motorcycles. An independent research-based investigation is currently underway to establish the noise limits and these are expected to take effect in 2020. We anticipate these will be implemented through the UNECE where the UK will continue to play a key role beyond our withdrawal from the EU.

The motorcycle industry is represented at the UNECE discussions and Department for Transport officials also hold routine discussions with them outside this forum.”

Two issues involved are here in this answer and question. The perception of motorcycles being noisy, whether Lord Laird was referring to motorcycles fitted with after market or modified “loud exhausts” , the ongoing development of standards and Brexit, which we wrote about in November 2016 – The Brexit Bike. We will be having another look at Brexit as ACEM have published a position paper on the exit of the United Kingdom from the European Union.

We would agree with the Federation of European Motorcyclists Associations (FEMA) General Secretary, Dolf Willigers, when he stated in an article Sound is a sensitive issue in our motorcycle world?

“Also, without being moralistic, I want to raise awareness that sound can change to noise. In the perception of one person this happens a bit sooner than in the perception of another person.

Too much noise leads to annoyance, health complaints and eventually to counter measures, like closing off roads or even towns for motorcycles. We have seen this already in the Netherlands and Germany.

That will hurt us all. For FEMA the standards do not need to be lowered again, but from excessive noise everybody suffers, we riders as well. Think about that before you remove that dB-killer or if you mount an illegal exhaust pipe.”

The issue in our minds is around the perceived noise, which is bad, what is sound, perceived by motorcyclists as good as riders’ change, remove, replace or tamper either whole exhaust systems or parts of the system – headers – catalyst – end cans – availability of “illegal” after market replacements – engine management etc.

Dare we mention “Loud Pipes Save Lives”.

Ingrained Belief, Faith and Philosophy

We can always remember – Loud Pipes Saves Lives – as an acceptable ingrained belief, faith and philosophy in the statement itself, from riders and certain rider organisations. Times have changed and riders now have different viewpoints on whether they do save lives – the debate rages on!

As far back as 2003 the American Motorcyclist Association (AMA) and the Motorcycle Riders Foundation (MRF) agreed that excessive motorcycle noise is a serious issue in some communities, that it may become an issue in many more, and that the potential exists for it to affect motorcyclists’ rights nationwide.

The Motorcycle Action Group (MAG) in the UK in its recent members magazine “The Road” (54-55) asked two  questions “contentious stuff”  following their FEMA representative’s attendance at an all-day conference at a joint international working group with FEMA – FIM (Federation Internationale de Motocyclisme) – FIVA (Federation Internationale de Vehicules Anciens):

“Should riders argue for greater enforcement of current noise regulations to reduce the number of illegal exhaust systems being used on public roads, and possibly damaging the image of motorcyclists?”

“Should we try to make loud exhausts as unacceptable as smoking in an enclosed space or even dare to compare illegal pipe users to drink-drivers, where drinking and driving, even though it was frowned upon, was once an acceptable activity. Perhaps this strategy would reduce unwanted noise and show authorities that we actively encourage and support compliance. “

Our answer is to both these questions is no!

Especially as we wrote to Lord Laird and Baroness Sugg, to which we received a reply from the Department for Transport (DfT):

“Under the Road Vehicles (Construction and Use) Regulations 1986, as amended, motorcycles are required to meet strict noise limits before they are permitted to enter into service. Once in service, Regulation 54 requires exhausts and silencers to be maintained in good working order and not altered so as to increase noise. In addition, replacement exhaust silencers are required to be marked to show compliance with European or British Standard noise limits and silencers intended for off road use have to be marked to indicate this. Silencers that are totally unmarked, do not show a European or British Standard noise mark, or are marked “not for road use”, may not be used on the road.”

“During the MOT test, exhausts and silencers are checked and a machine should fail if it emits noise that is unreasonably higher than a similar one fitted with a silencer in average condition or if the silencer or the exhaust does not have a marking suitable for the age or use of the machine. Outside the MOT the police have powers to take action under Regulation 54, if they suspect the exhaust has been altered, or under Regulation 97, if the machine is making excessive noise which could be avoided through reasonable driver care.”

“The police also have powers to address noise nuisance under the Police Reform Act 2002 and the Crime and Disorder Act 1998. We recommend that these problems should be drawn to the attention of the police to ensure they are given an appropriate priority.”

As we knew there is sufficient enforcement in place and why would you want to “demonise” motorcyclists and encourage specific targeting and profiling of riders out on the public road?

FEMA viewpoint on this, the text of which was published in the UK’s British Motorcyclists Federation (BMF) members magazine from a FEMA meeting in October 2017:

“All were in agreement that the “loud pipes saves lives” argument was obsolete – and the idea was universally condemned by delegates”

Pollution has many aspects, not just noxious gases but also noise.  How these are regulated and controlled is a point of discussion as set out in this article.  The issue really is how we as riders deal with these problems of modern day life.

They exist, they are not going away, so do we adapt?

Or maybe we just need to find a way to fit in?

Smart guy/girl who has the answer.