Comments on proposed rulemaking.
pg. 76805 of 12/7/2000 Federal Register
Comment on "the cost, corresponding emission reductions, and feasibility of direct fuel injection for two-stroke
engine applications."
Several DFI engine applications are already in series production for US consumption. These include several
Sea-Doo personal watercraft, a line of Mercury Optimax engines, Evinrudes equipped with Ficht technology,
and the newly introduced Nissan/Tohatsu Low Pressured Direct injection outboard engines. These engines
appear to be priced about 20% higher than similarly sized engines that do not meet future emissions regs.
Bombardier claims 75% emissions reduction compared to EPA baseline. However, the consumer not only
gets lower emissions with these engines, but improved performance and decreased fuel consumption on the
order of 30-40%. These other factors could justify the increased price in and of themselves.
The Aprilia DITECH SR 50 motorscooter has been intoduced in Europe to rave reviews. The attached paper
prepared by Synerject this year (see Table 13 on pg. 14 of the attachment) shows that this technology should
probably easily meet current federal standards for motorcycle emissions. The systems described require little
modification to the base vehicle, key components being an engine control unit, recalibrated automotive fuel
injector and regulator, a specially designed fuel pump, air injector and compressor. Because of the simplicity
of the system, Aprilia is only charging about $125 premium for this scooter. Since most parts are off-the-shelf
and available throughout the automotive world, reliablity is also assured. Compared to conversion to
4-strokes, the cost should be much smaller because of the simplicity of the engine (the valves, camshaft, and
means to drive them not required). This technology also claims about 20% fuel consumption reduction over
non-fuel injected 4-stroke (40% over two-stroke).
The recent bankruptcy filing of OMC has been blamed in part on their development of engines to meet tighter
emissions regs. I am sure some industry commenters will point this out. This is just scapegoating and neglects
to point out OMC's series of management blunders, some of which did take place in the development of Ficht
technology and included trying to circumvent another company's patents and doing much of the testing of the
product on the general public.
In summary, the 2-s DFI promises not only to reduce hydrocarbon and carbon emissions about 80%, but to
do so rather inexpensively because of the simplicity of the system. Another major benefit is the significantly
reduced fuel consumption, thereby also significantly reducing carbon dioxide emissions which the EPA may
choose to regulate sometime in the future if climate change becomes a concern in the USA. These emissions
improvements are achieved without exhaust treatment (though these systems are also more tolerant of exhaust
treatment) and eliminate concerns about tampering with the exhaust system. The systems enhance rather than
degrade performance. Limits based on these systems seem natural and would not require more than 5-year
leadtime. The systems are basically designed and only need to be tested on the machines and applications.
As they become more widespread, costs will decrease. DFI is becoming off-the-shelf technology. (minimal
cost, very feasible, large emissions reductions)
Quote from Supertrax magazine Online, 12/99, vol. 11, article 4
(http://supertrax-mag.com/supertrax/articles/1104rv/9912rv.htm), a publication of Supertrax Snowmobiler,
"While this emission stuff does seem a little scary, take heart in the reality that others have gone before us and
survived this scrutiny. The marine industry has been able to comply with stringent EPA standards set out for
them by using a combination of Direct Fuel Injection (DFI) technology on two-stroke engines and the
introduction of four stroke engines in smaller, lower horsepower categories. From what we've seen and
experienced with DFI two stroke engines thus far, we're excited. These clean burning two strokes start, idle
and accelerate better than any engines we've ever operated. In fact, the new generation of DFI outboards
actually run more like four strokes than two cycle engines. An added bonus which can't come too soon to the
snowmobile industry is substantial fuel savings as a result of the increased efficiency of DFI technology."
Perhaps many in the offroad vehicle industry are only waiting for the emissions regs to make them come out
with the superior products.
pg. 78606 (off-highway motorcycles/ATVs)
Comment on "whether EPA should attempt to set standards in a manner that would encourage the
development of clean 2-stroke technology, and if so, how that objective could best be accomplished."
Most definitely, yes. The 2-stroke engine has much better power density (whether talking about power
output/size or power output/mass). As mentioned above, the clean 2-strokes can provide reduced emissions
at about the same cost while preserving the fun. Even better, they achieve significant emissions reduction
without exhaust treatment. Seems that the best way to encourage their dissemination is mentioned in the
proposed rule itself, that is, combine the limits for ATVs and off-highway motorcycles with highway
motorcycles and achieve economies of scale in the development of the engine systems. Therefore, my
comments on appropriate levels for control are in the highway motorcycle section below.
pg. 78608 (Snowmobiles)
Comment on "what level of CO emissions control is feasible and appropriate for snowmobiles, on the cost of
corresponding emissions reduction potential of various strategies, on the lead time needed to achieve new
standards" - this comment also valid for HC emissions on the same page.
It is possible that snowmobile manufacturers have been waiting on emissions regs to commit resources. Very
tight HC emissions limits could preclude use of 2-stroke DFI without catalyst for example (and would
definitely severely damage the industry).
DFI 2-stroke is feasible and reduces both types of emissions by more than 70%. Requirements should be
based on this. The only negative is the additional cost, which may not be significant and is counterbalanced by
the improved performance and fuel economy. See the quote above from a snowmobile magazine; the
technology will probably IMPROVE the snowmobile experience. Lead times may not need to be that
dramatic either, as Bombardier already has DFI on SeaDoo and Arctic Cat has been working on it. The other
major producers have been working on 4-strokes. The 4-strokes will have to use fuel injection to get
significant CO reduction. Since CO is of major concern and snowmobiles are almost all 2-strokes now, it
seems logical to base limits on 2-stroke DFI.
pg. 76813 (highway motorcycles)
Comment on:
"the technological feasibility, cost, and appropriateness of implementing new more stringent emission
standards for highway motorcycles. We also request comment on technologies that might enable reductions in
motorcycle emissions, and the potential magnitude of such reductions. We request comment on the
appropriate time frame for implementing new emission standards for highway motorcycles."
Simply, limits are feasible and can be obtained with small cost, especially if combined with off-highway
motorcycles and ATVs. Most US limits mentioned can be obtained with 2-stroke DFI or 4-stroke engines
even without fuel injection. However, further reductions in CO are also feasible and are proposed in Europe.
A reduction of the federal HC standard from 5 to and HC + NOx standard at 2 or lower is feasible and will
allow development and economies of scale of the clean 2-strokes for all applications. If CO is considered a
concern, a reduction of limits by one-half can easily be met by fuel injection of some type.
Comment on :"all aspects of the California program and whether the California standards are appropriate for a
nationwide federal program. Commenters should address technological feasibility, cost, corresponding
potential emissions reductions, appropriate time frame, structure (e.g., a fleet average approach vs. something
else), and potential advanced emission control technologies associated with California-level standards and with
any other level of standards a commenter may consider appropriate."
The California program currently in existence is/was basically designed to prohibit 2-stroke engines. It is
doubtful that even the small 2-s DFI can meet the HC limit (though of course NOx and CO are much lower
than the limits). This is a serious deficiency because fuel efficiency is not considered nor are the reductions in
other type of pollutants. The proposed HC+NOx limits for larger bikes are more sound and should be
applied to the smaller bikes as well. I personally like the proposed European tier II limits better as world
standards may produce greater economies of scale than California standards, except use HC + NOx instead
of individualizing the limits. These also reduce CO emissions. I also wonder if the reduction of 1.4 g/km
HC+NOx standard to 0.8 g/km will be worth the extra fuel consumption and cost if exhaust treatment is
required. I think standards should be based on what can be achieved with fuel injection without exhaust
treatment, and should not preclude the use of the two-stroke DFI bikes. |
