First Name | Don |
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Last Name | Amador |
Email Address | damador@cwo.com |
Affiliation | |
Subject | OHRV 2013 Proposed Rule |
Comment | 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 |
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Date and Time Comment Was Submitted | 2013-07-18 07:20:01 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.