URGENT!! Regarding EPA comments on emissions, you can go to:
http://capwiz.com/share/issues/alert/?alertid=69673 "Take Action Now" or
http://www.ama-cycle.org/index.asp "AMA Rapid Response" and submit your
comments on the proposed emissions rule. Pasted below are some additional
thoughts and ideas from actual testimony by Colorado State Parks, ISMA,
and
the AMA in order to customize your comments. You should modify the
information on the form letter to make it "unique". You can copy and paste
excerpts from below into the form letter in order that they are not all
the
same, use the preprinted comments as they are, or submit whatever you feel
comfortable with. I would recommend that after you compose your comments,
print the letter and mail it to: Margaret Borushko (Docket No. A-2000-01),
U.S. Environmental Protection Agency, Office of Transportation and Air
Quality, 2000 Traverwood Drive, Ann Arbor, MI 48105,
borushko.margaret@epa.gov . You may consider sending a copy to:
Subcommittee on National Parks, Recreation & Public Lands, 1333 Longworth
House Office Building, U.S. House of Representatives, Washington, D.C.
20515-6207 parks.subcommittee@mail.house.gov ,
[http://resourcescommittee.house.gov/parks] ; Subcommittee on Forests &
Forest Health, 1337 Longworth House Office Building,
U.S. House of Representatives, Washington, D.C. 20515-6205, e-mail:
Forest.Health@mail.house.gov ,
[http://resourcescommittee.house.gov/forests] ; and Environmental Protection
Agency, 1200 Pennsylvania Avenue, NW, Washington, DC, 20460.

Also copy your e-mail to: NRANPRM@epa.gov and President George Bush:
president@whitehouse.gov . Don't forget to insert your name and address
prior to sending.

You can review the entire document at
http://www.access.gpo.gov/su_docs/fedreg/a011005c.html and scroll down to
Environmental Protection Agency - Proposed Rules - Air pollution control;
new motor vehicles and engines: Nonroad large spark ignition engines and
recreational engines (marine and land-based); emissions control, 51097-51146
[TEXT] [PDF] 51147-51196 [TEXT] [PDF] 51197-51246 [TEXT] [PDF] 51247-51272
[TEXT] [PDF]

Please remember, December 19th is the deadline as of now. Please mark your
calendar and save this message until such time that you can comment. You
may consider printing it to highlight some of the comments you want to make
before proceeding. This is critical and applies not only to snowmobiles
but
ATV's, motorbikes, PWC's, etc.
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Comments on EPA Public Hearing on Snowmobile Emissions
DocketA-2000-1
Colorado Department of Natural Resources
Colorado State Parks
October 30, 2001


Colorado State Parks, a division of the Colorado Department of Natural
Resources, has statutory authority to manage the State's Snowmobile Program
(33-14-102 CRS). The program has been managed with the cooperation of the
Colorado Snowmobile Association since 1977.

In reference to the recently released EPA report on snowmobile emissions,
we
respectfully submit the following comments:

Carbon Monoxide (CO) Levels Near Nonattainment Areas

Page 22 of the report indicates that CO emissions can be a significant
source of ambient CO levels in non-attainment areas. Trails near Fort
Collins and Colorado Springs are cited as possible sources of CO emissions
from snowmobiles.

The nearest snowmobile trails to Fort Collins are the Green Ridge Trail
near
Red Feather Lakes (45 miles) the Long Draw Trail (50 miles) and the Milner
Pass Trail in Rocky Mountain National Park (40 Miles). Except for the Milner
Pass Trail, none of these trails are maintained (groomed) and snowmobile
use
is limited. Based upon limited use and the distance of these trails from
the
Fort Collins area, CO emissions related to snowmobiles is questionable.

In reference to Colorado Springs, the trails in the Buena Vista area would
be the closest (75 miles). These trails are maintained and receive a
substantial amount of use. However, the great distance of the trail system
from the front-range would likely preclude significant amounts of snowmobile
CO emissions in the Colorado Springs area.

Contrary to the EPA report, Colorado Springs is a CO attainment area and
has
been since 1999. The 1999 2000 Report to the Public by the Colorado Air
Quality Control Commission states that
"Colorado springs now has ambient levels of carbon monoxide that are about
half of the federal standard".

In addition, it should be noted that the report indicates that Colorado
will
be seeking "state level redesignation to attainment maintenance status of
Fort Collins for carbon monoxide during calendar year 2000 and 2001." Also
of interest is the fact that air pollution by snowmobiles is not mentioned
in this report.

Impact On The Winter Economy Of Mountian Communities

Snowmobiling is an important factor in the winter economies of many Colorado
mountain communities. The trail systems near these small towns such as
Craig, Creede, Lake City, Rifle, Grand Lake and Walden, are maintained by
local snowmobile clubs and used by Colorado residents as well as visitors
to
the state. A recent economic impact study on motorized recreation in
Colorado by Hazen and Sawyer indicates that the total itemized expenditures
by households participating in snowmobile recreation in Colorado in 2000
was
between $110 to $122 million.

Advances in Engine Technology

The International Snowmobile Manufacturers Association (ISMA) is planning
on
introducing new low-emission engines on certain models produced by its
members. They have indicated that they can meet a 30% reduction in
hydrocarbon (HC) and carbon monoxide (CO) emissions by model year 2006.
Coupled with the fact that only 140,000 units are sold each year and owners
typically use their snowmobile only 12 to 13 weekends per year, cleaner
engines should significantly address the emissions issue.


Thank you for the opportunity to comment on this issue.

/Dave Hause, Colorado State Parks Snowmobile Program Administrator
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ISMA EPA Public Hearing Comments
October 24, 2001

The International Snowmobile Manufacturers Association is a membership
organization whose members are Arctic Cat, Bombardier, Polaris and Yamaha.
The member companies of ISMA design, build and sell over 99% of the
snowmobiles used by American families. Snowmobiling is a fun family sport
and activity that is important for the well being of many Americans. In
addition to providing a great opportunity to enjoy the outdoors during the
cold winter months, the sport of snowmobiling is a most important part of
the economic engine that maintains many northern, rural communities
throughout the snowbelt. Many of the rural economies that are now thriving
are doing so because of the winter tourism dollars that are generated
through the sport of snowmobiling. Our close working relationship with
Visitors and Convention Bureaus and Chambers of Commerce highlight the
importance of this industry to their economic security and interests. Winter
tourism and the related businesses rely on a viable snowmobile industry.

1. ISMA and its members support the continued development of new snowmobile
technologies, with low-emission engine performance.

2. ISMA and its members already have plans to introduce or are introducing
new low-emission engines for certain models.

3. Given the unique performance characteristics of some snowmobile models,
it is likely that low-emissions technology will not have operating
characteristics that are comparable or superior to current engine designs.
There are also some engine families that are simply too small in volume
to
justify the expense associated with meeting the proposed EPA standards,
particularly when one takes into account the absence of air quality
benefits.

4. There is no evidence that snowmobile use actually contributes in any
significant way to ozone or CO nonattainment anywhere in the United States.
ISMA strongly supports the air quality analysis prepared by Sierra Research
and submitted by Polaris. This analysis clearly demonstrates the absence
of
any significant air quality impact from snowmobiles - and therefore the
absence of any legal authority for regulating snowmobiles. Likewise, there
is no other air quality justification. However, recognizing that the
snowmobile category is one of the last unregulated engine sectors, we are
prepared to support an EPA regulation of snowmobile engines provided the
EPA
standards are cost-effective and implemented in a reasonable manner.

5. Although the use of snowmobiles in National Parks should be considered
completely independently of the EPA proposed standards, ISMA and its members
support targeted strategies to assure that snowmobile use in selected
National Parks is suitable. These strategies would include the accelerated
use of low-emissions technology in the rental fleets of vehicles used in
those selected Parks. We do not believe that usage considerations in the
Parks are primarily air quality in nature. EPA's standard-setting should
be
based solely on national air quality considerations.

6. While we are committed to the further development of low-emissions engine
technologies for appropriate snowmobile applications, EPA should take into
account the unique characteristics of the industry. The snowmobile industry
is very different from almost every other category of engine manufacturers
previously regulated by EPA.
A. The snowmobile industry sells only 140,000 units per year.
B. Despite a recent strong economy over the last five years, sales
have declined 17% during that 5 year period.
C. For the vast majority of consumers, a snowmobile is a
discretionary purchase.
D. The average snowmobile owner uses the snowmobile only 12 to 13
weekends a year.
E. Snowmobiles are used exclusively in the winter and primarily
in
rural areas; therefore, their use has almost no impact at all
on
ozone formation in nonattainment areas.

7. ISMA believes we could meet a straightforward, single-tier 30% reduction
of hydrocarbon (HC) and carbon monoxide (CO) emissions by model year 2006.
Indeed, in June of this year, we submitted a specific proposal with simple
administrative provisions that we could support. But the proposed standard,
as currently drafted, is anything but simple and straightforward. By adding
an arbitrary cap for all engine models, a second tier of reductions and
a
variety of complex protocols for demonstrating compliance, the agency has
created enormous uncertainty and made it very doubtful that the industry
could comply with the rule. Just by way of illustration, the cap alone would
compel the industry to spend scarce dollars on numerous existing technology
engine families in an extremely limited period of time. This approach is
in
marked contrast to the principle EPA recognized in its two-stroke
recreational marine rulemaking, that the industry should focus its resources
on developing new, low-emissions technologies for those engine families
that
are most suited for such technologies and not waste resources on existing
technology engines. We should point out that meeting the 30% reduction for
an engine family is not simple - for example, we could not simply use
carburetor enleanment to achieve this level. The cap also completely defeats
the logic of using a corporate average approach, by depriving companies
of
both the flexibility and cost savings associated with an averaging program.
So, while, in principle, we can support a 30% corporate
average reduction for HC and CO, we are gravely concerned that, in practice,
the EPA proposal cannot be met.

8. ISMA does not support the proposed Phase II standards. Although ISMA
members are voluntarily introducing individual engine models that will meet
or outperform the Phase II levels for those snowmobile applications for
which the new technology is suitable, there is no basis for imposing such
levels across the board. Doing so would force the industry to incur material
cost for its small volume models, significantly increasing product price
and
almost certainly resulting in material loss of sales, resulting in some
additional emissions reductions but without yielding any material air
quality benefit. Placing the industry at risk seems particularly
inappropriate at a time when the industry is voluntarily introducing cleaner
engine designs in those models for which the new engine designs are
well-suited.

9. As with the first phase emission reduction target, in principle, ISMA
supports the concept of using voluntary emissions benchmarks to promote
consumer choice at the point of sale and to reward manufacturers for
accelerating the introduction of new low-emissions technologies. This
strategy can be abused in practice, however, if some jurisdictions treat
the
voluntary benchmarks as if they were mandatory standards, such as by
imposing land use restrictions based on the voluntary levels. This risk
is
particularly acute when the industry may not be able to introduce
low-emissions technology in all snowmobile models due to the inability of
such technology to provide the characteristics needed for certain
conditions. If EPA is to continue to develop the idea of voluntary
benchmarks, we believe all stakeholders must commit to respecting the
voluntary nature of these benchmarks. Treating the voluntary benchmarks
as
mandatory or applying snowmobile usage restrictions based on such levels
would be prohibited legally, because it would be contrary to Congress'
explicit direction that standards be national in scope. It would also result
in inappropriately imposing costs not fully considered in EPA's rulemaking.

10. We have several technical concerns about the rule that we will address
in written comments. One is so very fundamental to the rule that we need
to
mention it today. That is the issue of test methods. We understand that
the
agency initiated a limited test method evaluation by Southwest Research.
A
much more significant effort is needed to address the wide range of testing
issues relevant to this rulemaking, including new issues introduced by the
NPRM such as air temperature. Before the industry commits even greater
resources to fleet-wide technology development, we need assurance that the
proposed test method will yield consistent, replicable results and will
not
be biased for or against any particular engine configuration.

11. Although we support a straightforward 30% reduction target for
snowmobiles and the use of voluntary benchmarks to accelerate low-emissions
technology, we believe the proposal as drafted is fundamentally flawed and
could, in practice, inflict serious harm on the snowmobile industry and
on
tourism-dependent rural businesses while delivering no material air quality
benefits. We know this is not the agency's intent, but we feel it is
incumbent on us to alert you to our concerns. We are prepared to work with
the agency to address these deficiencies to ensure that the rule, in
practice, can be simple, straightforward and effective. This will take a
considerable effort. We will submit more detailed written comments during
the comment period.

Thank you.
Edward J. Klim
President, ISMA
--------------------------------------------

October 24, 2001

U.S. Environmental Protection Agency
National Vehicle and Fuels Emission Laboratory
2000 Traverwood
Ann Harbor, MI 48105

Re: Proposed Rulemaking on Emissions from Nonroad Spark Ignition Engines,
Recreational Engines (Marine and Land Based)

Thank you for this opportunity to comment regarding the Notice of Proposed
Rulemaking on the Control of Emissions from Nonroad Large Spark Ignition
Engines and Recreational Engines. Please make my comments part of the public
record for this Rulemaking.

The American Motorcyclist Association (AMA) is a national not-for-profit
organization founded in 1924 and incorporated in Ohio, with more than
260,000 enthusiast members across the nation. As you know, AMA members ride
on-highway and off-highway motorcycles as well as all-terrain vehicles
(ATVs). The continued availability of these machines is vital to the
interests of our members and to the United States economy.

We believe that the EPA s analysis of the contribution of recreational
off-highway vehicles to air pollution is overstated. Indeed, the Advance
Notice of Proposed Rulemaking unfairly compared emissions from off-highway
vehicles to emissions from on-highway vehicles on a one-for-one basis and
quantifies the significance of off-road recreational vehicles emissions
by
expressing them as a percentage of the total emissions from all motor
vehicles. The agency s analysis overstates and misrepresents the
significance of off-highway vehicle emissions.

However, as an advocate of responsible recreation on our public lands the
AMA is supportive of the adoption of emissions standards that can be shown
to be cost-effective, allow for continued and expanded consumer choice and
will utilize existing and future technologies without the establishment
of
design based mandates, such as catalytic converters and evaporative
canisters.

The AMA is pleased that the Proposed Rulemaking proposes an emissions
performance standard rather than a design standard. We believe that a
performance based standard will promote innovation. Manufacturers and their
associated suppliers should be given every opportunity to meet
performance-based standards through research and development. Each
manufacturer s machines are unique in design and appearance and would be
dramatically altered if additional fixtures (e.g. evaporative canisters
or
catalytic converters) that add weight, reduce ground clearance, endanger
the
safety of the rider, or are aesthetically unpleasing were to be mandated.

The Association is disappointed that the proposed rule fails to promote
clean two-stroke engine technology. By setting one emissions standard the
Agency has almost certainly excluded two-stroke powered machines from the
recreational off-highway motorcycle and ATV market. Thus, interrupting the
evolution of the two-stroke power plant.

The AMA has commented previously, and the EPA s own research has confirmed,
that two-stroke powered machines are preferred by enthusiasts because of
their superior performance characteristics. The Agency has acknowledged
that
emerging technologies, though not yet fully developed, may in time allow
two-stroke engine emission performance to be comparable with that of
four-stroke engines. By setting only one emission standard, one that is
beyond the grasp of reliable and available two-stroke engine technology,
the
Agency is in essence forcing the industry to abandon a dependable and
popular technology and forcing consumers to accept what is viewed as an
inferior product. Therefore, the AMA reiterates its request that the EPA
develop an additional emission standard for two-stroke powered off-highway
motorcycles and ATVs. A standard that would promote cleaner two-stroke
technology by setting challenging yet realistic two-stroke emission targets.

As indicated by the EPA, in recent years some manufactures have developed
high-performance four-stroke models, primarily for competition. The AMA
applauds the innovation in engine design that has made four-stroke
performance competitive with that of a two-stroke. But, we believe that
it
is noteworthy that none of these high performance four-strokes have been
sufficiently "clean" to achieve CARB certification. Additionally, they are
only competitive with two-strokes when given a considerable displacement
"handicap" (as much as 100%).

Therefore, we believe that the four-stroke engine in-of-itself should not
be
considered the sole path to emission reduction. The AMA recommends that
the
agency not pursue a course of action that would terminate the availability
of two-stroke motorcycles.

The AMA is pleased to read in the Proposed Rule that the agency plans to
establish separate emissions standards for off-highway motorcycles, ATVs,
and snowmobiles. This is appropriate given the vastly different applications
of each type of machine.

The AMA remains concerned with the availability of competition motorcycles.
Approximately one-third of our members report that their primary interest
in
motorcycling is the direct participation in amateur competition. No doubt,
a
significant draw for many to motorcycling is the accessibility of
competitive equipment. Whereas other motor sports have large financial
barriers to entry, a competitor with a modest "working class" income can
afford a highly competitive motorcycle. This is especially true in "nonroad"
competition, like motocross, hare scrambles, observed trials, etc.

All competitors deserve and need unrestricted access to competitive machines
for sanctioned competition. This point is exemplified by the fact that none
of the motorcycles currently "certified" by the California Air Resources
Board have the power delivery and ultra-low weight characteristics necessary
for the most popular form of "nonroad" racing: motocross.

If competition motorcycles were not available, those wishing to compete
would likely modify available equipment for specialized competition. This
would likely occur at the expense of emissions compliance and, therefore,
be
counterproductive to the goal of this rulemaking, reduced emissions.

The AMA believes that the continuation of an exemption for competition
motorcycles is necessary and vital to the sport of racing; however, we are
willing to work with the EPA, and other interested parties to further refine
the definition of a competition only model.

In closing, I would again like to thank the agency for providing this
opportunity to discuss the various aspects of this Proposed Rulemaking.
We
encourage you to continue an open and public process that involves riders,
manufacturers, suppliers, distributors and all other interested parties.

Sincerely,

Edward W. Moreland
Vice President, Government Relations
American Motorcycle Association

***************************************
( For Legislators purposes )

This message sent by;
Mel Wolf, Immediate Past President
Colorado Snowmobile Association
P.O. Box 886, Loveland, CO 80539
Phone: 970-667-3191
Fax: 970-663-6598
mailto:melwolf@verinet.com