03NR01 - MRF Economic Impact Study Confirms High Cost of EPA Proposed Standards
MRF E-MAIL NEWS
Motorcycle Riders Foundation
P.O. Box 1808
Washington, DC 20013-1808
FOR IMMEDIATE RELEASE
Contact: Tom Wyld
January 5, 2003
#03NR01 - MRF Economic Impact Study Confirms High Cost of EPA Proposed Standards
The Motorcycle Riders Foundation's (MRF) commissioned economic impact study of the Environmental Protection Agency's (EPA) proposed emissions standards for street motorcycles confirmed that the costs of these proposed standards will be significant in terms of rider safety, small business, fuel conservation, traffic congestion and road wear. Dr. Garrett Vaughn, a noted economist, completed the study just in time for motorcyclists nationwide to incorporate his findings into their public comments submitted to the EPA.
Thanks to the efforts of the MRF and motorcyclists' rights activists across the country, the deadline for submission of public comments was extended to Tuesday, January 7, 2003. You can submit your comments to the EPA via e-mail at MCNPRM@epa.gov. Be sure to mention Docket A-2000-02 in your correspondence. We encourage all of you and your fellow motorcyclists, friends and family to submit comments regarding these unnecessarily restrictive emissions standards.
The MRF would like to express its gratitude to those concerned individuals and organizations committed to reasonable emissions regulations and the continued health of motorcycling in America for their selfless contributions that made this study possible.
Below is a brief summary of Dr. Vaughn's economic analysis. The study can be downloaded, viewed and printed in its entirety in pdf format at www.mrf.org/pdf/epa_vaughn_study.pdf.
EXECUTIVE SUMMARY - An Economic Analysis of the EPA's Proposed Emission Standards for On-Highway Motorcycles
Prepared for the Motorcycle Riders Foundation by Garrett A. Vaughn, Ph.D., Economic Consultant
1. When realistic cost estimates are used, EPA's proposed emission standards for on-highway motorcycles would cost from $3,500 to more than $7,500 per ton (2001 dollars) - far higher than the per-ton costs of previously implemented mobile source pollution prevention programs.
2. The EPA did not meet its obligations under the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) because its analysis of the proposed emissions considers only motorcycle manufacturers - and especially a handful of large motorcycle manufacturers. EPA never considers the economic impacts that the proposed standards would have on the tens of thousands of small businesses that also belong to the U.S. motorcycle industry: franchised dealers, performance shops and aftermarket suppliers.
3. The EPA ignores the issue of rider safety. None of the major EPA documents that discuss the proposed standards even make a single mention of either "rider safety" or "consumer safety."
4. The EPA's analysis ignores possible impacts of the proposed standards on future motorcycle sales by assuming sales will grow smoothly at 1 percent annually, despite the historical evidence showing that national sales are subject to radical year-to-year swings and despite the long-term downward trend between the early 1980s and the late 1990s (despite the recent upswing in annual sales).
5. The EPA wants to "harmonize" California's proposed emission standards to the other 49 states (regardless of those states' air pollution regulatory needs), but ignores that states 7.7% reduction in motorcycle registrations between 1996 and 2001 when registrations increased by 32.2% in the other 49 states. Even a cursory look at the data suggests that government regulations explain much of the fall in California's motorcycle registrations.
6. The EPA did not meet its obligations under Executive Order 12866 to consider a less stringent alternative to the proposed emission standards. Yet, ample warnings abound that the catalyst-forcing Tier 2 standards will produce negligible environmental benefit at considerable cost to jobs and personal freedom, compared to only a slightly less stringent standard.
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The first motorcyclists' rights
organization to establish a full-time legislative advocacy presence in Washington. The Motorcycle Riders
Foundation is the only Washington voice devoted exclusively to the street
rider. MRF established MRFPAC in the early 1990s to advocate the election of candidates
who would champion the cause of rider safety and rider freedom. MRF proudly claims state
motorcyclists' rights organizations and the very founders of the American rider rights
movement among its leading members. Motorcyclists worldwide can thumb-start their search
for rider rights and safety on the web at www.mrf.org.
© All information contained in this release is copyrighted. Reproduction
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
activists and publishes a bi-monthly newsletter, THE MRF REPORTS.
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