Comment Log Display

July 18, 2013      

Sent via FAX and Posted to OHRV 2013 Comment Section              


California Air Resources Board 
1001 "I" Street 
Sacramento, CA 95814
FAX:  916.445.5025

Re: OHRV 2013 - Proposed Regulation Order -Off-Highway Recreational
Vehicles: Evaporative Emission Control, Title 13, California Code
of Regulations – July 24 Public Comment and July 25 Hearing

Dear California Air Resources Board:

As a small business owner, OHV recreation professional, and member
of the OHV user community, I am deeply concerned about the
potential negative impacts of the proposed regulation order for
Off-Highway Recreational Vehicles (OHRV): Evaporative Emission
Control, Title 13, California Code of Regulations (Order).   As you
know, OHRV refers to off-road motorcycles, all-terrain vehicles,
off-road sport vehicles, off-road utility vehicles, and sand cars. 
The Order will impact the production of said vehicles starting in
2018.

I just became aware of the Order two days ago after receiving a
call from a concerned member of the OHV community.  Due to a large
number of other OHV-related projects on my desk and the late
notice, I will not be able to produce a detailed analysis of the
Order for the July 24 comment period deadline nor attend the July
25 hearing.

Since this proposed Order could have a significant impact on OHV
recreation and related businesses, I contacted the California State
Park Off-Highway Motor Vehicle Recreation Division (Division) after
learning about the proposed Order to see if they had given any
input into the proposal.  Division stated they just found out about
this proposed Order on Monday, July 15 and had not been consulted
by CARB, a sister agency.

Here are my initial concerns about the proposed Order which are
hereby submitted in time to meet the July 24 public comment period
deadline.

Impacts to Competition (Red Sticker) Off-Road Motorcycles
Impacts to “Red Sticker” Riding Seasons
Impacts to Competition Events Including Amateur Events 
Drastic Increase in Cost of Production (all OHRVs) 
Reduction or Elimination of Certain Lines of OHRVs/Loss of Consumer
Choice
Fiscal Impacts to OHRV Dealerships
Failure to Consult with Division
Fiscal Impact to Local Economies
Questionable Staff Analysis of Economic Impact to OHRV Recreation
Questionable Staff Analysis of Environmental Benefit 
Over Optimistic View of Future OHMVR Sales





Based on my aforementioned concerns, I respectfully request the
following:


Postpone Order/Rule and extend the public comment period until CARB
consults with Division scientists and resource professionals to
“ground-truth” CARB staff assumptions related to projected OHRV
sales or usage, economic impacts to OHV-related businesses, impacts
to competition events, impacts to red sticker riding seasons or
usage, or environmental benefits of the rule. 

Thanks in advance for your consideration of this request.

Don

Don Amador
555 Honey Lane
Oakley, CA 94561
Email: damador@cwo.com

cc: Governor Jerry Brown
      Senator Mark DeSaulnier
      Assembly Member Jim Frazier
      CA State Parks OHMVR Division