MRF Position Papers

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Signed 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.

Motorcycle 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.

The Motorcycle 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.

As the 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.

Put in 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.

The direct 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.

If EPA 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.

I thank you for listening.

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