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to Position Papers Listing
Statement of the Motorcycle Riders Foundation on
New Street Motorcycle Emissions Regulations Proposed
by the Environmental Protection Agency at a Public Hearing
on Docket A-2000-02 in Ann Arbor, Michigan on September
by the Environmental Protection Agency (EPA) Administrator
on July 25, 2002, the Notice of Proposed Rulemaking on
"Control of Emissions from Spark Ignition…Highway Motorcycles"
imposes needlessly stringent new limit values on street
motorcycles. Inaccurately classing our bikes as "recreational"
and dismissing - without documentation - the legitimate
concerns of the motorcycle riding public regarding rider
safety and motorcycle performance, EPA grossly overestimates
the degree to which street bikes contribute to the total
motor vehicle pollution inventory and grossly underestimates
the cost per bike of the new controls.
performance is tantamount to motorcycle safety; rider
safety depends on the bike's ability to out-accelerate
and out-brake passenger cars. Our safety also depends
on the bike's ability to deliver smooth power at low speed
and idle in traffic without generating excessive heat
that exposes the rider to dangerous fatigue. EPA's brief
comment on these concerns (such as horsepower and torque
comparisons of some unnamed motorcycles - without so much
as a footnote) does not approach even a superficial answer
to these legitimate questions. From the perspective of
the motorcycle rider, the performance and safety concerns
are real, and EPA has not adequately addressed them.
Riders Foundation requests that the deadline for public
comment be extended to January 8, 2003. Much of the "documentation"
that the EPA assembled to justify this rule (for example,
the Regulatory Support Document) is, in fact, not documentation
at all. The Motorcycle Riders Foundation and motorcyclists
generally need time to study the limited documentation
that is available and request, receive and study the documentation
that is simply not now available. In responding to letters
from our members, the EPA staff has ridiculed our members
for not providing adequate documentation. Without showing
the same discourtesy you have shown us, we citizens of
the United States request time to request and study your
documentation. No pressing legal or public health issue
prevents you from granting this extension and your rule's
complexity and its potential for small business devastation
are reasons enough to grant this extension.
national advocate devoted exclusively to the interests
of the street motorcyclists, the Motorcycle Riders Foundation
has been immersed in the regulatory process involved in
this proposed rulemaking for nearly two years. While we
will have more to say in writing during the public comment
period, nothing - repeat, nothing - in the proposed rule
or in its regulatory support documentation changes the
positions and concerns we expressed in our response to
the agency's Advanced Notice of Proposed Rulemaking some
18 months ago.
the briefest possible terms, it is the position of the
Motorcycle Riders Foundation that the EPA's proposed rulemaking
on highway motorcycles will ban venerated classic engine
families and destroy a vast cottage industry of small
businesses in the United States - from small-volume motorcycle
makers to the aftermarket.
costs of this unnecessary regulation will be the loss
of tens of thousands of jobs and a radical reduction in
motorcycling in America. The unavoidable result of this
regulatory zeal will be an increase in fuel consumption,
traffic congestion and air pollution.
succeeds in finalizing this rule as proposed, one thing
is certain: the control of American motorcycling will
pass from the hands of riders to the hands of automotive
manufacturers and firms who may have corporate partnerships
with automotive manufacturers.
you for listening.
Prepared by: Thomas C. Wyld, Vice President-Government
Motorcycle Riders Foundation
by: John Silk, MRF Representative, ABATE of Michigan