For Immediate Release

(Ottawa: January 17, 2000) The memorandum of agreement between Environment Canada and the Canadian Marine Manufacturers Association, announced at the Coliseum building in Toronto today, is nothing more than a sham. It was cooked up behind closed doors without proper consultation and will allow offshore marine engine manufactures to dump highly polluting 2-stroke engines in Canada.

"The Coliseum is a fitting location for this announcement. We're definitely being thrown to the lions," said John Bennett, Director Atmosphere and Energy, Sierra Club of Canada. "The environmental standards are too low and Canadian buyers will be misled by US EPA stickers," he continued.

To understand the game being played by Environment Canada and the engine manufacturers you must understand the EPA regulation in the United States and the differences between the U.S. and Canadian outboard motor market.

The EPA rules

The agreement announced today allows the import of any outboard engine approved by the EPA under its 1996 regulation. However, the EPA uses a corporate averaging system which "allows them (manufactures) to build some engines to emission levels lower than the emission standard and some engines to emission levels higher than the standard provided the corporate average is at or below the standard. Therefore the EPA approves both extremely polluting 2-stroke engines and less polluting 4-stroke engines as part of a group of products. Under the terms of the agreement announced today, no such corporate averaging is required in Canada.

The Canadian Outboard Market

The EPA regulation will have some impact in the United States because the American market is dominated by the more powerful and less polluting 4-stroke engines. The Canadian market is dominated by the 2-stroke engine that is as much as 20 times more polluting than 4-stroke engine. Therefore, the engine manufacturers, while living up to the terms of the agreement and selling only engines approved by the EPA, will be allowed to continue selling the more highly polluting 2-stroke engines in Canada and there will be very little change in the amount of air and water pollution from outboard motors in Canada.

In addition, the EPA itself does not expect to achieve its target of 75% reduction in air pollution from outboard motors until 2025.

Environment Canada negotiated secretly with the Canadian Marine Manufacturers Association avoiding input from any other parties. Further, using a memorandum of agreement rather than establishing a regulation under the Environmental Protection Act there is not even an opportunity to comment.

The Sierra Club learned of these negotiations on January 6, 2000, from a concerned citizen who indicated an announcement was pending.

"We followed up by contacting Environment Canada to determine whether discussions with the Marine Manufacturers Association were in fact taking place and if an announcement was pending. An Environment Canada official in a telephone conversation confirmed there had been discussions, but denied there were any announcements planned in the near future," said Mr. Bennett.

"This deal should be torn up and thrown away and Environment Canada should conduct proper public consultations with all the stakeholders and come up with a plan and regulations that will begin protecting Canadians from the effects of air and water pollution," concluded Mr. Bennett.

For more information:
Sierra Club of Canada, (613) 241-4611
 

FACT SHEET

Concerns with the Marine Manufacturers’ Memorandum of Understanding on Outboard Engine Emissions

The Marine Manufacturers’ Association is an industry advocacy group that negotiated the memorandum of understanding (MOU).

There are three major flaws with Marine Manufacturers’ MOU:

Environmental Standards

The emission reduction targets are too low and fail to address the air and water pollution caused by two-stroke engines. The US Environmental Protection Agency (EPA) recognizes several benefits of four-stroke marine engines when compared with two-stroke engines. These benefits are:

The MOU fails to acknowledge the environmental superiority of four-stroke engines when compared with two-stroke engines. Two-stroke outboard engines are a major cause of pollution in Canada. Individually. none of these motors meet the emission reduction requirements.

Although the MOU adopts 1996 US EPA regulations. the US EPA only requires a gradual 75% reduction in emissions for a manufacturer’s entire product tine. These limits will not he achieved until the 2006 model year. An emission reduction of 95% from current levels would be more beneficial to Canada’s aquatic environment.

Recent studies have shown that two-stroke outboards cause up to 95X more air pollution and up to 97% more water pollution than four-stroke engines.

Canada’s Outboard Manufacturers Are Not Forced to Comply With US EPA Average Emissions

The US EPA certification process is based on a system that averages emissions of engines sold in the USA. High polluting two-stroke motors are averaged against clean burning four-stroke engines. According to the US regulation. compliance is achieved if negative credits from over-polluting models (two-stroke engines) equal or are less thin the positive credits from clean burning models (four-stroke engines) for any given model year.

If the average of a marine manufacturers product line is a positive number an EPA certificate of conformity may be affixed to that company’s entire line of engines, including high polluting two-stroke engines.

The MOU states that engines sold in Canada require a US EPA sticker but it does not force Canadian manufacturers to adopt the averaging provision. In Canada the majority of marine motors sold are high polluting. two-stroke engines. Because the US EPA emission averages will not apply to sales in Canada, marine manufacturers will be allowed to sell high polluting motors on the Canadian market at a much higher ratio than would be permitted in the USA. In Canada, the US EPA environmental standards will not be met.

The US EPA Stickers on Canadian Outboards Misleads Canadian Consumers

The MOU has the effect of providing an implied environmental endorsement for polluting two-stroke engines sold in the Canadian market. Consumers assume that the EPA sticker on the model they are purchasing indicates that that individual model is in compliance with environmental standards. That is not the case.

The MOU permits, in fact require, marine manufacturers to label all of their engines with EPA stickers. The environmental sticker placed on an engine will not reflect that individual engine’s environmental standard. The sticker represents the US averaged environmental standard for all engines of that manufacturer.

Canadian consumers will assume that the EPA sticker on the model they are purchasing indicates that that model is in compliance with the same environmental standards in Canada when. in fact it may not be.

Research has shown that Canadians will be much more likely to not purchase high pollution engines it they are informed about the environmental damage they cause. The MOU will not give them the required information - it will imply that many of the engines are environmentally friendlier when they are not.

Finally, all conventional 2-stroke outboard engines carry an implied “environmentally friendly” endorsement despite the fact that they are a major source of air and water pollution.
 

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