|MRF E-MAIL NEWS Motorcycle Riders Foundation
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EPA Updating Noise Emission Standards
The Motorcycle Riders Foundation (MRF) has learned that the US Environmental Protection Agency (EPA) is updating the regulation that governs all motorcycle noise emissions. The EPA has sent a letter to various private companies located in the USA, that import or build motorcycle exhausts intended for use in the USA, asking the companies to disclose sensitive financial and business plan information, as well as trade secrets.
The EPA claims that it must update the regulation because of “technical changes that have occurred since the last update of the rule”. Current law has decibels capped at 83 for motorcycles built since 1983. It is not clear from the letter which direction they will pursue, but in the past, any time the EPA “updated” anything it meant that the regulations got stricter. Reading between the lines shows that the EPA will likely lower the decibel limit for motorcycles, not increase it.
The 5 page questionnaire asks for some very sensitive information such as; overall value of the company, part numbers of items built and or sold, testing techniques, will the company pass on the costs of more testing to the customer and so on.
The MRF is arranging a meeting with the EPA to clarify exactly what is going on here.
If you or anyone you know has received this letter, please put them in touch with the MRF so that they can join the coalition to ensure that this does not put in place any hardships for the American rider.
Contents of the letter to manufacturers follows.
Should you want to view the questionnaire click here: http://www.mrf.org/pdf/EPA_questionnaire_June2010.pdf
(Manufacturer specific information and MRF edits
appear in bold italic to protect the identity of the MRF’s source)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
Office of Air and Radiation
June 1, 2010
BY CERTIFIED MAIL
Dear Mr. XXXXXXX:
The U.S. Environmental Protection Agency (EPA) is considering revisions to its motorcycle noise emissions regulations (Code of Federal Regulations, Title 40, Part 205, Subparts D and E, promulgated December 31, 1980) to address technological changes that have occurred since the current regulations were developed. As part of this process, we are collecting information on the types and models of motorcycles and mopeds manufactured in or imported for sale in the United States. We are also collecting information on motorcycle and moped exhaust systems that are manufactured or imported for sale in the United States; this includes companies that manufacturer (sic) OEM exhaust systems for their newly manufactured motorcycles and/or mopeds and/or for retail sale and those companies that manufacture motorcycle and moped exhaust systems for aftermarket sales only. Also, in order to estimate the impacts of any increases in manufacturing and/or product costs due to possible required changes in design and testing costs, we are collecting information on sales volumes, prices and the costs of manufacture.
This letter is to request completion of the enclosed questionnaire by the (name and address of manufacturing company) by June 23, 2010. The purpose of this questionnaire is to determine the products produced, approximate production volumes, production costs, testing processes and testing costs, and sales prices for your facility.
Your company may assert a business confidentiality claim covering part or all of the information. Information covered by such a claim will be disclosed by EPA only to the extent and by procedures set forth in 40 CFR Part 2, Subpart B. You should clearly identify such pieces of information at the time it is submitted, using a cover sheet, stamped or typed legend, or label indicating that the information is company confidential, proprietary, or trade secret. If no such claim accompanies the information when it is received by the EPA, it may be made available to the public by EPA without further notice. It is EPA’s policy that compliance provides sufficient protection for the rights of submitters of priveleged information.
We have designated EC/R as an authorized representative of the Agency. As an authorized representative of EPA, EC/R is subject to the provisions of 42 U.S.C. 7414(c) respecting confidentiality of methods or processes entitled to protection as trade secrets. The EC/R contract with the EPA is EP-D-09-051.
Your assistance in this very important matter will be greatly appreciated. If you have any questions regarding this request, please contact me at (EPA phone number) or (EPA email address) or (EPA official) at (EPA phone number) or (EPA email address).