February 2002

Text of the BSA's Comments on the EPA's Proposed Rulemaking Concerning Snowmobiles

To the Honorable Christine Todd Whitman:

Subject: Nonroad Large Spark Ignition and Recreational Engines Notice of Proposed Rulemaking

I would like to express our comments on the above-referenced rule. We applaud the EPA for beginning to address the serious air and noise pollution and public health problems caused by snowmobiles. However, we believe the proposal, especially as it relates to reducing emissions from all classes of recreational vehicles, noise pollution, and vehicle labeling falls short of what is reasonable.

Founded in 1992, the Backcountry Skiers Alliance (BSA) represents the interests of human-powered winter backcountry users, including skiers, snowshoers, and snowboarders by advocating for the creation, preservation and management of non-motorized areas on public lands. We work to preserve backcountry areas for non-motorized use, promote winter backcountry safety and ethics, and cooperatively resolve conflicts among backcountry users in Colorado. Our membership base is over 500 individuals and 50 outdoor retailer companies.

The proposed regulation that the EPA has issued sets very weak standards for protecting the public and wildlife from the air and noise pollution emitted by snowmobiles. We urge the EPA to issue a regulation that includes stricter controls on air pollution and significant controls on noise pollution. We also urge the EPA to require labeling standards that will allow the consumer to choose a clean burning vehicle.

The current regulation requires a 30% reduction in hydrocarbons and CO by 2006 and 50% by 2010. It also fails to include NOx emissions. This regulation as it stands is very easy to achieve. Snowmobile manufacturers will have to do little to reach these goals. We suggest that there is current technology that will allow manufacturers to do better. For the past two years, the Society of Automotive Engineers has conducted the "Clean Snowmobile Challenge". College students design snowmachines that are cleaner-both in air pollution and noise pollution while not sacrificing performance. In 2001 students from the University of Waterloo modified a machine that was quieter and over 25% more fuel efficient. Emissions were reduced by 63%.

Of the 13 schools who submitted entries, emissions reductions ranged from 49 to 96%. Modifications to the Waterloo entry cost $725. Part of the industry's concern with making a cleaner, quieter snowmobile is the increased cost, which will make it difficult for the consumer to bear. Retail pricing for a snowmobile ranges from approximately $6,000 to $8,000. This 10% increase in cost is unlikely to hurt sales or prevent some consumers from purchasing a machine. Furthermore, if college students can modify a machine for only $725, it is likely that the industry can do better than that.

Most snowmachines are powered by 2-stroke engines that burn a combination of gas and oil. The EPA has determined that 25-30% of this fuel mixture is dumped into the air and onto the snow. The California Air Resources Board concluded that the operation of a 2-stroke engine for ~7 hours generates the equivalent smog-forming pollution as driving a modern car more than 100,000 miles. This is unacceptable. Just ask anyone who has been in a parking lot with a snowmachine while it warms up, on a trail as several machines go by, or better yet, ask a Yellowstone Park Ranger what it's like to wait at the gate when the machines go by.

Secondly, this regulation includes no controls on noise. Human-powered users seek solitude and quiet. This experience is shattered even when snowmobiles are 100's of yards away. The EPA should regulate this noise so that other users can still enjoy their wintertime activities.

Several of the current manufacturers have produced 4-stroke engines. Not only do these machines produce less air pollutants, they are also quieter. In addition, these machines are far more fuel efficient. Though these machines cost more to produce, the consumer will benefit with savings in fuel efficiency.

In addition, this regulation should include labeling of the machines so that consumers can choose based on emissions and noise. There is strong consumer demand for cleaner, quieter machines, and without mandatory labeling, the consumer has to study the specs to determine which machine is clean and quiet. If this is voluntary and only at the point of sale, how does the consumer who is buying a used machine or renting a machine have access to this crucial information? Furthermore, it does not allow a park service official to identify machines that meet specific emissions standards.

If you have ever skied, snowshoed, or played with your kids in the snow near a snowmobile, I think you'd understand the difficulty of fully enjoying the experience. Just putting skis on in a parking lot where a snowmobile is warming up or driving by is an extremely unpleasant experience due to both the fumes and the noise. What is needed is a strong regulation that will protect the environment, wildlife and general public who might recreate in the same area as a snowmobiler. This includes both emissions and noise.

Thanks for your hard work on this issue. Please consider these comments and call us if you would like any clarification or assistance in improving this rulemaking. The Backcountry Skiers Alliance looks forward to working with the EPA in the months ahead to strengthen the proposal.

The BSA presented testimony at an EPA hearing on October 30, 2001 in Denver. Most of the above text summarizes that testimony.