Thursday 13 July 2023

Comment by Editor, Robin Bradley

Exhaust anti-tampering regulations


There are several interesting and potentially very important news items that are worth careful consideration in this month's edition of International Dealer News.

However, there are three that I would like to specifically draw your attention to. All three are about issues that have already had an elephantine gestation period, but are now edging slowly forwards.

The news that the Japanese 'Big Four' manufacturers are finding common cause on an issue is to be welcomed. Following the formal involvement of three of them in the Swappable Battery Consortium, it has now been announced that they are to collaborate on research into something that is, admittedly, less likely to yield commercially scalable results anytime soon, and that is the Holy Grail of emissions-free hydrogen power PTW engines. This is definitely "one to follow".

A second subject to read as much about as possible, and one very close to my hear, is that of E-fuels - potentially a relatively simple and straight forward pathway to zero emissions transport solutions in terms of the chemistry, and one that has unbelievably positive implications for the ongoing use of existing vehicles and infrastructure.

"may his lights always shine"

It isn't the chemistry that is the problem, but the energy required to drive the chemistry. However, with vast swathes of the planet enduring more sunshine than they know what to with, those who presently pump hydrocarbons for us all from underground could make a ferociously profitable long-term living from simply harvesting that which occurs above ground, perpetually, to synthesise 'clean/green' hydrocarbons for the burning thereof.

It is heavily ironic that it was German scientists and the nascent German automotive giants that did much to pioneer the science of 'Synth-Gas', especially in the early 20th century inter-war years, and that now it is that same German automotive powerhouse that has led the pressure that has finally forced the EU to accept that internal combustion engines powered by 'zero emissions' petroleum or other E-fuels will be allowed to have a place in a mixed palette of solutions in the post 2035 energy solutions landscape.

In the short term, however, perhaps the most important news this month surrounds the role that ACEM and IMMA and their members have had in taking ownership of how exhaust noise emissions should be regulated. Working in collaboration with a selection of leading aftermarket exhaust manufacturers (see front cover story), a suite of industry generated, rather than bureaucrat imposed, anti-tampering measures is now headed towards adoption details to follow later this year.

Constantly battling to 'square difficult circles' (because motorcyclists are citizens too), ACEM has progressively and successfully been getting out in front of how the noise and other emissions levels of motorcycles are regulated and controlled for more than a decade now. Since the 1990s, maximum permitted noise levels, and how they are to be enforced, have been defined through EU derived European type approval requirements.

As part of the solution to address the issues that this can cause for motorcycle and aftermarket exhaust manufacturers, riders and the dealers they buy from, ACEM appears to have succeeded in squaring one of the most difficult of circles. 

Namely, how to arrive at a viable approach to regulation that brings the industry along for the ride with a package of measures that actually do what is required by politicians and non-riding consumers, and their anointed bureaucrats, without burning the house down.

The background to the initiative involves knowing, in some detail, about the structure of how the EU arrives at motorcycle exhaust noise (and some other vehicle technical) regulations. For sound level and anti-tampering rules governing motorcycle exhaust silencers, the EU type approval framework Regulation 168/2013 mandates the application of UNECE (United Nations Economic Commission for Europe) Regulations no. 92 (aftermarket silencers) and no. 41 (original motorcycle).

These Regulations were developed and are maintained by the Working Party Noise and Tyres (Groupe Rapporteur Bruit et Pneumatiques - GRBP) under the World Forum for the harmonisation of vehicle regulations (WP.29), operating within the UNECE.

In December 2022, ACEM presented the guidelines to national type approval authorities at a stakeholder meeting organised by the European Commission. Following an informal approval by authorities at EU level, the International Motorcycle Manufacturers' Association (IMMA) introduced the guidelines in February 2023 at GRBP. The document is expected be adopted at the next GRBP session in September 2023.

"This initiative has been jointly developed within the motorcycle sector by ACEM, IMMA and the named motorcycle exhaust manufacturers. The ACEM membership includes 18 manufacturing companies - BMW Motorrad, Bombardier Recreational Products (BRP), Ducati Motor Holding, Harley-Davidson, Honda, Kawasaki, KTM, KYMCO, MV Agusta, Peugeot Scooters, Piaggio, Polaris Industries, Qooder, Royal Enfield, Suzuki, Triumph Motorcycles, Yamaha and Zero Motorcycles. ACEM also represents 18 motorcycle industry associations in 17 different European countries".

ACEM notes that about 300,000 jobs depend on the L-category industry in Europe - based on a 2019 study, there are more than 39 million motorcycles and scooters on Europe's roads (the 'Circulating Park'). In recent years, the EU has been mandated to ensure that any proposed new regulations do not adversely affect the motorcycle industry in Europe, and, in fact, to support efforts to promote two wheels as part of the available range of environmentally-friendly transport solutions.

All hail 'Wim the Mighty' - his Imperial Holiness, former EU Rapporteur for Motorcycles, Dutch EPP MEP Wim van de Camp, "may his lights always shine"! 

IMMA, as the voice of the global motorcycle industry, has a membership of Powered Two- and Three-Wheeler (PTW) manufacturers' associations from Australia, Brazil, Canada, Europe, India, Indonesia, Japan, Malaysia, the Philippines, Taiwan, Thailand, USA and Vietnam.

IMMA "promotes solutions for safe, sustainable, socially responsible and economically viable motorcycling. IMMA advances inclusive policies and engages in the development and progressive harmonisation of vehicle requirements in global forums. IMMA is based in Geneva, Switzerland".

The GRBP (Groupe Rapporteur Bruit et Pneumatiques) is a subsidiary body of the World Forum for Harmonization of Vehicle Regulations (WP.29) that prepares regulatory proposals on vehicle noise and tyres for consideration and adoption by WP.29. Tyre noise was added to the (formerly) GRB brief to create GRBP in 2018. This followed the conversion of the former Working Party on Brakes and Running Gear (GRRF) into a new Working Party on Automated/Autonomous and Connected Vehicles (GRVA), also in 2018.

Confused? It's not surprising. The basic 'need to know' is that these days there are valid and rational technical and engineering, rather than overtly opinion-driven political processes at work in order to arrive at the regulations that shape the motorcycle and dozens, if not hundreds, of other specialty industries in Europe.

To develop those requirements, GRBP conducts research and analysis and convenes twice a year (officially), entrusting informal groups with specific problems that need to be solved urgently, or that require special expertise. 

More than 100 experts participate in the sessions of GRBP. The Working Party is open to governmental experts from any member country of the United Nations, and to any regional economic integration organisation set up by member countries of the United Nations, and to experts of governmental organisations. Experts of non-governmental organisations (NGOs) may participate in a consultative capacity. Final decisions are taken by government representatives by vote at the World Forum (WP.29) level. The work of GRBP experts is transparent - all agendas, working documents and reports are openly accessible on the Internet.

The ACEM press release - "Guidelines on anti-tampering rules for motorcycle exhaust silencers" - can be found at the ACEM website, along with the ACEM position paper - "Transport sustainability, sound emissions and noise".