OPINION – IS CA RED STICKER PLAN THE FINAL STRAW?
By Don Amador
March 8, 2019
According to the California Air Resources Board (CARB) update
on Proposed OHRV Regulatory Amendments presented at the California Off-Highway
Motor Vehicle Recreation Commission
Meeting held in Palmdale, California on March 1, 2019,
today starts a 45-day public comment period on their PROPOSED AMENDMENTS TO THE
RED STICKER PROGRAM FOR OFF-HIGHWAY RECREATIONAL VEHICLES.
LINK TO CARB OHV COMMISSION PRESENTATION
LINK TO CARB 78 PAGE PROPOSED AMENDMENTS TO THE RED
STICKER PROGRAM FOR OFF-HIGHWAY RECREATIONAL VEHICLES (scroll down to staff
report on webpage)
First, I and other OHV stakeholders have appreciated the
collaborative and cooperative attitude of CARB staff since this particular
process started in 2013. Over the years,
they stated that a BAN of competition motorcycles is not being considered nor
is it a goal. CARB staff had also made it clear that they want to work with us
(OEMs, aftermarket, dealers, user groups) in this review process with an end
goal of presenting the CARB board with some “common sense” proposals to address
red sticker motorcycle emissions with a special focus on evaporative/diurnal
emissions.
However in my view, the report falls short of achieving that
common sense objective. Rather, it
continues to rely on incomplete data sets or misguided
understanding of what “competition” means to affected riders, land managers,
rural economies, OHV dealerships, law enforcement of OHV policies, conservation/restoration
efforts, trail ethic education programs, and organized OHV clubs and/or motorcycle
competition sanctioning bodies.
Over the years, motorcycle competition stakeholders have
stated – to both the EPA and CARB - that “practice riding” (building strength
and muscle memory, tuning the motorcycle, learning to navigate in various
terrains, etc.) on both public and private lands is a critical component of
competition motorcycle riding just as practice driving is important to
long-distance trophy truck racers and similar non-motorcycle competitors.
Unfortunately, it appears our efforts to communicate the
importance of riders having access to meaningful practice for competition
events on private, local, state, and federal lands is not being captured by EPA
and CARB.
At this point, I believe the collective weight of the
proposal could have an unintended and devastating impact on competition events,
riders, and other related stakeholders including land management agencies in
the State of California.
Competition motorcycle events (and practice) on public
lands such as enduros or trials on Forest Service lands and GP and/or Hare
Scrambles at BLM areas or state park units have been - and should continue to
be -legitimate, appropriate, and important activities on public lands.
As some of you know, there is a growing national movement
of public land-based competition events being relocated to private land
venues. This reality in many parts of
the country is being driven by a number of compounding factors which include; excessive
government permit fees, burdensome red-tape permitting process, and complicated
stipulations associated with trying to run an event on public lands.
My concern if the report is adopted as written is that it
could be the “regulatory straw” that breaks the competition “camel’s back” by
driving legitimate competition use and practice off of public lands and onto
private lands. Rather than being an environmentally sound proposal it could
pave the way for functional deregulation (no sticker fees to cover OHV-related resource
management, LE, restoration of damaged lands or VIN#s) of competition vehicles which
have been (and should continue to be) an important OHV partner that stands in
support of sustainable OHV recreation management on public lands.
Driving competition events and practice off of public
lands is not acceptable.
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