02NR08 - Economic Analysis Critical of EPA Proposed Ruling
MRF E-MAIL NEWS
Motorcycle Riders Foundation
P.O. Box 1808
Washington, DC 20013-1808
ECONOMIC ANALYSIS CRITICAL OF EPA PROPOSED RULING
Washington, D.C. - An independent economic analysis made available to the Motorcycle Riders Foundation finds that the Environmental Protection Agency (EPA) failed to meet the requirements of an executive order in its proposed rulemaking on new emissions standards for motorcycles and other engine applications. According to the analysis by the Regulatory Studies Program of the Mercatus Center at George Mason University, the result of that failure is that "policymakers - including those in the Agency - cannot properly assess how the proposed rule will affect the health and welfare of U.S. citizens." While the Mercatus Center study focuses on the "Proposed Rule to Control Emissions From Non-road Large Spark Ignition and Recreation Engines (Marine and Land-Based)" issued by EPA in September 2001, it comments on the street bike issue as well.
The study quotes extensively from a September 2001 letter by the Motorcycle Riders Foundation. That letter states that tougher emissions standards will "hike substantially the costs to consumers of machines with more performance problems when viewed from the motorcyclist's perspective, yet radically reduce if not eliminate the choices available to the community of American motorcyclists to improve them." The study continues: "A true benefit-cost analysis would estimate the loss in consumer welfare described by Mr. Wyld - at least in qualitative terms (if quantitative measures are impractical). Such an analysis would also avoid misinterpreting a loss in consumer welfare as a 'benefit.'"
The executive order in question, E.O. 12688, states that agencies should "select the approaches that maximize the net benefits." "Maximizing net benefits requires an economic benefit-cost analysis," the Mercatus Center study states, which EPA has not conducted for either on- or off-road motorcycles.
MRF has provided a copy of the study to our ally, the American Motorcyclist Association, since the AMA's advocacy includes the off-road community. Copies have also been provided to ABATE of Illinois and ABATE of Ohio, since they have played a leading role in combating proposed new, unreasonable emissions standards. MRF will also mail the 30+-page study to all SMROs that have visited (or plan to visit) Washington and make the study available to any SMRO or MRF member who requests a copy (202-546-0983) or firstname.lastname@example.org.
The Regulatory Studies Program (RSP) of the Mercatus Center at George Mason University studies the impact of regulation on society. As part of its mission, RSP conducts careful and independent analyses employing economic scholarship. Their comment on the proposed emissions standards is independent, does not represent the views of any affected party or special interest group, and does not represent the official position of George Mason University. The study was submitted to the EPA on December 19, 2001.
Observers had expected the EPA to publish the street bike proposed rulemaking in November 2001 and then January 2002. In the wake of intense lobbying by the MRF and State Motorcyclists' Rights Organizations (SMROs) nationwide, the street bike proposed rulemaking remains under review. The visit to Washington, D.C. by ABATE of Michigan this week will be followed by visits to Capitol Hill by ABATE of Illinois, ABATE of Iowa, ABATE of Minnesota, CBA/ABATE of North Carolina, and ABATE of Wisconsin. In addition to concerns regarding health care and the activities of the National Highway Traffic Safety Administration, the SMROs will express their objections to their U.S. Senators and U.S. Representatives regarding needlessly tougher emissions standards. A key element of our stance is economic security - and how proposed EPA restrictions could wipe out tens of thousands of jobs across the nation.
SMROs should plan their visits to Washington, D.C. now by calling 202-546-0983 or by e-mailing email@example.com.
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permitted with attribution. The Motorcycle Riders Foundation, incorporated
in 1987, is an independent, membership-based national motorcyclists' rights organization headquartered in Washington D.C. which operates in
co-partnership with State Motorcyclists' Rights Organizations
nationwide. The MRF is involved in federal and state legislation and
regulation, motorcycling safety education, training, licensing and public
awareness. The MRF provides individual and SMRO member-volunteers with guidance, support and information to protect motorcyclists' rights and
advance motorcycling and its associated lifestyle. The MRF sponsors annual regional and national educational seminars for motorcyclists' rights
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