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NTWC's
Formal Comments The Honorable Christine Todd Whitman RE: Proposed Rule -- Control of Emissions from Nonroad Large Spark Ignition Engines and Recreational Engines (Marine and Land-Based) [Air Docket A-2000-01] Dear Governor Whitman: The undersigned organizations appreciate the opportunity to present our formal comments on the proposal to control emissions from recreational vehicles and engines and marine engines. We applaud the Agency for beginning to address the serious air and noise pollution and public health problems caused by snowmobiles, off-highway motorcycles, thereafter referred to as dirt bikes, and all-terrain vehicles (ATVs). However, we believe the proposal, especially as it relates to reducing emissions from all classes of recreational vehicles, noise pollution and vehicle labeling, falls far short of the legal requirements in the Clean Air Act. The Problem: Snowmobiles, dirt bikes and ATVs are significant sources of air pollution nationwide and particularly large sources on public lands and in rural areas. The impacts of these machines in rural America is especially significant in light of the EPA's determination that "concentrations [of ozone] in rural areas have risen to levels previously found only in cities." Moreover, the number of off-road vehicles is very large. Based on various industry sources, there are at least 1.6 million snowmobiles, nearly 4 million ATVs and millions more dirt bikes in operation in the United States today. And tens of thousands more machines roll out of dealers' showrooms annually. As the proposal explains, snowmobiles, dirt bikes and ATVs alone account for approximately 10 and 3 percent of nationwide mobile source emissions of hydrocarbons and carbon monoxide, respectively. The average two-stroke motor, which powers about 99 percent of snowmobiles, more than 60 percent of all dirt bikes and one-fifth of all ATVs, produces more smog-forming pollution in one day than the average car does after traveling 100,000 miles. In addition, two-stroke engines produce about 45 times more particulate matter than a diesel engine. On public lands, off-road vehicles can be the largest single source of air pollution. For example, the National Park Service concluded that snowmobiles produce up to 68 percent of Yellowstone National Park's annual carbon monoxide pollution and as much as 90 percent of its total hydrocarbon emissions. The gross amount of pollution from these machines is even more evident when you consider that cars outnumber snowmobiles by about 16 to 1 in Yellowstone. In certain regions where dirt bike use is widespread - BLM lands in the California desert for example - a single dirt bike generates eight times as much carbon monoxide pollution as a car. Growing sales, more widespread use and continued reliance across the industry on out-dated two-stroke technology have combined to produce a worsening air pollution problem. While virtually every other mobile source - from diesel trucks to cars to personal watercraft - has been, or soon will be, getting cleaner, snowmobiles, dirt bikes and ATVs have not. More importantly in terms of this proposal, these vehicles are a larger source of air pollution today than 10 years ago. Based on the Agency's analysis, while highway mobile source carbon monoxide emissions dropped from 62 to 56 percent of total carbon monoxide emissions between 1989 and 1998, nonroad emissions increased from 17 to 22 percent of the total - an increase of nearly 30 percent. It is important to note that the reductions in the highway category occurred while the number of vehicles and miles driven increased significantly. According to the Bureau of Transportation Statistics within the U.S. Department of Transportation, the total number of highway vehicles increased from about 193.1 million in 1990 to approximately 215.5 million in 1998 while miles driven increased from approximately 2.1 trillion to 2.6 trillion. These numbers demonstrate that it possible to reduce pollution at the same time that the number of vehicles and miles driven increase. The adverse health effects associated with carbon monoxide, hydrocarbons, particulates and the host of toxic chemicals common to pollution from off-road vehicles are severe and well-documented, including respiratory disease, cancer and premature death. Moreover, there is a growing body of evidence documenting how riders, public employees and others directly exposed to exhaust are particularly at risk. According to the National Park Service, "[A]ir quality studies at Yellowstone [National Park] have shown that the accumulation of a large number of snowmobiles in a small area, such as entrance stations and parking lots, can result in short-term exposures to very high levels of CO, PM and HC (including toxic organics)."(National Park Service, Air Quality Concerns Related to Snowmobile Usage in National Parks, February 2000) The Park Service's research found that employees working in West Yellowstone express entrance booths had "double the PM exposure as those who worked in the regular lanes." (ibid) The Agency's proposal also addresses how snowmobile operation contributes to higher levels of exposure for riders. For example, EPA's analysis estimate that riders and others who directly breath snowmobile exhaust have benzene exposure levels "two to three orders of magnitude greater than the 1996 national average benzene concentrations." Elements of a Strong Final Rule: In order to protect public health and the environment, a strong final rule should:
The Proposal Falls Short: Based on these criteria, we believe the proposal, especially as it relates to reducing emissions from all classes of recreational vehicles, noise pollution and vehicle labeling, falls far short of the legal requirements in the Clean Air Act. Although we recognize that the EPA is not a land management agency, the undersigned organizations state clearly for the record that decisions about the use of off-road vehicles on public lands and waters must be based on a wide range of factors, including, but not limited to, impacts on air and water quality, other natural resources, wildlife, and public health and safety. Dirt Bikes and ATVs: On the positive side, we believe the Agency is moving in the right direction with the standards proposed for dirt bikes and ATVs. However, the standards would be less protective than ones that already apply to dirt bikes and ATVs in California. In fact, if this proposal were to become final as written, it would allow nearly twice as much pollution than the levels approved by the California Air Resources Board in 1997. We urge the EPA to harmonize final standards for dirt bikes and ATVs by requiring advanced emission control equipment, including catalytic converters, on both types of machines. We understand that EPA has a concern that a small reduction in dirt bike performance could encourage riders to purchase competition bikes that will not include pollution control equipment. First and foremost, it is completely unclear that a more protective standard for dirt bikes than the one proposed would actually impact performance in any discernable way. The proposal offers no evidence to support this assertion. Moreover, there are two separate issues here: 1) the most protective emission standards for dirt bikes and ATVs as required by the Clean Air Act and 2) abuse of the very limited competition exception in the Clean Air Act. It is well known to the Agency and officials in states across the country that many competition bikes are not being used exclusively, or even nominally, for any form of competition. Instead, they are being purchased for general recreational use and, in many cases, equipped with headlights and other equipment required for over-the-road use and then registered illegally. We recognize that EPA does not have authority over the actions of state departments of motor vehicles. However, the Agency does have a role to play in developing a strategy to address abuse of the competition exception in the law. That strategy should not be to propose emission standards below levels that can be readily achieved with existing technology merely because it might be complicated to address what appears to be a growing competition bike loophole. Furthermore, we are concerned that the agency's proposed approach to identifying competition dirt bikes will allow this loophole to continue to be exploited resulting in the sale of tens of thousands of highly polluting motorcycles that should not be generally available under the clear constraints of the Clean Air Act. As you know, Section 216 of the Act excludes any engine "used in a þ vehicle used solely for competition" from the definition of "nonroad engine" and excludes any vehicle "used solely for competition" from the definition of "nonroad vehicle."(emphasis added) In order to qualify for this limited exemption, a vehicle, such as a dirt bike, must be used - not just sold - solely for competition. Under the law, neither the vehicle nor the engine can be used for any noncompetitive purpose. For example, a stock car raced solely on the NASCAR circuit, but not driven occasionally on weekends through neighborhood streets, would qualify for this exemption. However, a dirt bike that is used in organized competition as well as for recreational pursuits should not qualify. As currently structured, the proposal does not appropriately apply the competition exemption because dirt bikes with the characteristics listed (66 Fed. Reg. at 51151) can be - and are routinely - used for purposes other than competition. The proposal should be amended to focus the definition of a competition dirt bike on how the vehicle is used in order to conform with the narrow exemption in Section 216. We are also concerned about permeation losses from ATV fuel tanks and request that EPA address this problem in the final rule. These losses result from the use of fuel tanks in which gasoline evaporates through the skin of the tank itself in the case of plastic tanks, or through apertures such as the filler valve. Snowmobiles: The proposed standards for snowmobiles fall far short of the mark. By the Agency's admission, after the first set of standards are in place in 2006, "[W]hile some advanced technologies, such as two-stroke direct injection and four-stroke engines, would be found on some models, many models would still be equipped with two-stroke engines with relatively minor engine modifications resulting in minimum emissions reductions, while some models may not even have any emission controls."(emphasis added) Then the Agency proposes a second phase for 2010, which it estimates will reduce snowmobile emissions by as much as 50 percent below current baseline levels. However, even this standard will not result in a large-scale transition to four-stroke technology. The proposal acknowledges that "these standards would be met through the application of direct injection two-stroke technology and, to a much lesser extent, four-stroke technology, to cover about half of overall production, with the remaining models utilizing clean carburetion and electronic fuel injection, along with associated engine modifications."(emphasis added) Based on this assessment, it is clear that the overwhelming majority of new snowmobiles produced after 2010 will continue to be powered by some form of two-stroke engine. It defies explanation that a World War II-era technology will continue to dominate this industry more than a full decade into the 21st century. As discussed in more detail below, we also believe the proposed standards are legally deficient. In testimony during EPA's public hearings on the proposal, the International Association on Snowmobile Manufacturers (ISMA) strongly opposed the 2010 standard. However, the Agency should be aware that in the context of other decisions concerning snowmobile use on public lands, the ISMA and its allies are sending a very different signal. A December 2001 fundraising appeal from the BlueRibbon Coalition (BRC) is merely one example. The BRC mailing (copy enclosed) includes a comment letter concerning snowmobile use in Yellowstone National Park. In advocating for continued snowmobile use in the Park, the letter states that "[I] support using the proposed '2010' EPA emission rule for snowmobiles to establish a reasonable emission standard for snowmobiles in national parks, since it would provide for a 50% reduction in HC and CO, rather than having the Park Service create their own rules outside the expertise of the EPA." The cover letter from the BRC includes the following, "Please note, this comment letter has the full support of American Council of Snowmobile Associations, the BlueRibbon Coalition and the International Snowmobile Manufacturers Association."(emphasis added) This double-talk represents a pattern on the part of the industry. The Agency should carefully consider the industry's inconsistency on this issue as it develops the final rule. We also strongly urge the Agency to reassess its conclusions about the assumed benefits associated with advanced two-stroke designs, such as direct injection. Additional research by the California Air Resources Board indicates that particulate matter emissions from direct injection two-strokes are very high. In fact, they are far higher than similar emissions from diesel engines. This finding alone should cause the EPA to reexamine its assumptions. The adverse public health effects associated with exposure to particulates are severe, including premature mortality and aggravation of respiratory and cardiovascular disease. Moreover, particulates are a significant contributor to visibility impairment nationwide. The wide disparity between standards for dirt bikes and ATVs and snowmobiles is difficult to understand. The vehicles use essentially the same engine technology. Two of the four major snowmobile manufacturers are already producing and marketing four-stroke machines. The technology is not a notion in the head of a young engineer, it is rolling off factory assembly lines today. In addition, in an industry where all of the major snowmobile makers also produce ATVs, and in some instances dirt bikes as well, it is impossible to understand why companies can not benefit from advances in four-stroke technology made in ATVs and dirt bikes. The Agency states in the proposal that "four-stroke engines are so prevalent over the last 10 years in [dirt bikes] and ATVs, manufacturers have developed high confidence in four-stroke technology and its application." The snowmobile industry has direct experience with four-stroke technology and advanced engineering concepts that have allowed this technology to dominate the ATV category. It is hard to believe that this extremely sophisticated knowledge is unknown in the snowmobile "wings" of corporate headquarters and engineering departments. Noise: We believe the Agency must use its clear statutory authority under the Public Health and Welfare Act (42 USC 4901) to regulate noise from these vehicles and recreational diesel boats. Noise from dirt bikes, snowmobiles and ATVs is frequently in the range of between 81 and 111 decibels, equivalent to a busy street or a rock concert. Although these vehicles shattered peaceful surroundings across the country, the negative impacts can be most pronounced on public lands and waters. The overwhelming majority of our National Parks and Forests, areas under the jurisdiction of the Bureau of Land Management, and other public lands are naturally quiet and free from the panoply of sounds that dominate our cities and suburban landscapes. Off-road vehicles are one of the single largest sources of noise pollution on public lands. The roar of dirt bikes and ATVs reverberates in the Red Rock Canyons of Utah, across the vast desert ecosystems of the southwest and throughout most National Forests. The high-pitched whine of snowmobiles is a constant presence in many areas of Yellowstone and other National Parks each winter. A survey in Yellowstone determined that snowmobiles could be heard 90% of the time in 8 of 13 most popular sites in the Park. Even areas in which motorized use is prohibited, chiefly wilderness and wilderness study areas, are adversely affected by noisy machines that operate nearby or illegally within these protected natural ecosystems. Coastal regions, lakes and rivers can sound like highways choked with tractor trailer trucks due to constant rumble of diesel engines in boats. The need to proactively address noise pollution is even more important in light of the fact that the proposal would not promote significant conversion of the snowmobile fleet from two-stroke to four-stroke technology. The eighty percent of Americans who visit their public lands for nonmotorized recreation each year would at least enjoy some noise reduction with an across-the-board move to quieter four-stroke machines. If the Agency does not significantly strengthen the proposal as outlined in these comments, it is imperative that it use its clear legal authority - already applied to some types of motorcycles - to reduce noise pollution from all recreational vehicles. Labeling: We are also disappointed that the proposal does not include the consumer-friendly labeling system that our organizations and many others have recommended. We believe a system similar to the one California has developed for personal watercraft and certain marine engines would be most useful to consumers. It utilizes easy-to-understand language and symbols to differentiate between machines and engines based on emissions levels. Although this proposal includes labeling for recreational vehicles, it appears that it will be numbers-based and may or may not include information about the voluntary emissions levels; therefore, it would be less user-friendly than systems already in place. In fact, without information about the voluntary emission limits, consumers would have absolutely no context in which to evaluate the numbers that might appear on a label. In addition, an easy to use labeling system harnesses market forces to encourage the production of cleaner machines. These forces are working successfully today in California and should serve as a model for this proposal. The Proposal Must Be Strengthened Significantly: Legal Authority is Clear - We believe the EPA must significantly strengthen the proposal especially in the areas identified above. Contrary to what some in the off-road vehicle industry have stated in commenting on the advanced notice of proposed rulemaking and during public hearings, we believe the Agency's legal authority to propose much more protective air pollution standards is unquestionable. Section 213 of the Clean Air Act requires the EPA to set air pollution standards that will achieve the greatest degree of emission reduction achievable with technology that will be available, giving appropriate consideration to cost, noise, energy and safety factors. This action is required by the Act if the Agency determines that emissions from certain classes of mobile sources contribute to the failure of one or more regions of the country to achieve attainment standards. The Agency made this determination and clearly articulated the evidence in the findings published on December 7, 2000. In addition, EPA has clear legal authority to take steps to safeguard pristine air quality in class 1 federal areas pursuant to Section 169(A) and (B) of the Clean Air Act. In Section 169(A), Congress set the following national goal: "[p]revention of any future, and the remedying of any existing, impairment of visibility in mandatory class 1 Federal areas which impairment results from manmade air pollution." As the proposal states, the Act and implementing regulations require the Agency to protect visibility in "class 1 areas from localized impacts as well as broader impacts associated with regional haze." Based on the plain language of the law, the EPA has the authority to regulate highly localized sources of pollution when they clearly contribute to degradation of air quality on protected public lands. In this proposal and other analysis, the EPA has concluded that recreational vehicles degrade air quality and contribute to visibility impairment. Other agencies, chiefly the National Park Service, have also determined that air pollution is increasingly impairing visibility on public lands nationwide. The connection between recreational vehicles and visibility impairment is clear and direct. Snowmobiles, dirt bikes and ATVs equipped with two-stroke engines emit extremely high levels of hydrocarbons - up to 250 times more during only 4 hours of operation when compared to a car driven 100 miles. Hydrocarbon, as a major constituent of organic carbon, is one of five major sources of fine particulate matter which causes visibility impairment. In the proposal, EPA has clearly documented how snowmobiles in particular contribute to visibility impairment in a select number of National Parks. We strongly believe that the impact of these machines on visibility is much broader across public lands than this limited analysis demonstrates. We believe that more protective standards for dirt bikes, ATVs and snowmobiles fall well within the EPA's legal authority. First of all, it is questionable if the proposed standard meets the legal requirement in light of the fact that the targeted reductions are not the greatest that could be achieved with technology available today. For example, as stated above, two of the four snowmobile makers are producing four-stroke machines for the coming model year. Four-stroke engines are being installed in snowmobiles today, and the reductions that can be achieved with this technology are dramatically greater than the proposal is designed to achieve. Moving to a more protective standard in and of itself would more reasonably approach the legal requirement. Four-stroke emissions data that is slowly emerging from the snowmobile industry clearly demonstrates that manufacturers are currently capable of reducing pollution much more dramatically than the EPA would require even in 2010. According to Arctic Cat, the company's new four-stroke snowmobile produces 6.32 g/kw-hr of HC and 68.2 g/kw-hr of CO. This HC level is 1/12 as much as the proposal would allow in 2010 while the CO level is 1/3 as high. There is no reason to believe that the other major snowmobile producers will not achieve similar reductions. Second, the Agency would also stand on very firm ground when evaluating stronger standards in light of the secondary issues EPA must consider under Section 213, including cost, energy, noise and safety. Cost-effectiveness -- Converting to four-stroke engines will be cost-effective in terms of overall pollution reductions and for consumers. The snowmobile industry itself has stated that four-stroke machines are affordable. During a snowmobile event in Utah in December 2001, Mark Reece, regional director for Arctic Cat, stated: "They [four-stroke snowmobiles] are plenty fast for touring, they keep the environment clean and they are affordable as well."( Salt Lake Tribune, 12/9/01 - copy enclosed) Furthermore, initial demand for four-stroke snowmobiles indicates that consumers find them highly desirable. The Bangor Daily News recently reported the following: "þ at Arctic Cat in Turner, salespeople rounded up as many of Arctic Cat's cleaner, quieter snowmobiles as they could be trading to other dealers - and they have sold nine of the 11 they were able to get."("Snowmobile sales clean up, Four-stroke engines popular," December 29, 2001 - copy enclosed) The article continues: "'It's [movement to four-stroke technology] the next step forward in snowmobiling. You could see it coming three to four years ago' said Hale [Myron Hale of Country Sports in Caribou], who was waiting for his first four-stroke snowmobile Thursday." (ibid.) The cost per ton of pollution reduction from all of these machines is well below levels in other recently approved rules. In terms of recreational vehicles, emission reductions are also extremely cost-effective. For example, the proposal estimates that carbon monoxide emissions from snowmobiles can be reduced for $50 per ton in 2006. Moreover, after accounting for significant fuel savings, the cost per ton of pollution reduction drops to zero in 2010. The potential savings for consumers that comes with four-stroke technology is perhaps best illustrated with what is happening today with personal watercraft. In a recent article, WatercraftNews magazine reviewed Yahama's new four-stroke personal watercraft. (copy enclosed) In addition to commenting about the power, style and all-around high performance of the machine, the magazine states: "In a 100-hour test conducted by Yamaha, they've shown savings of nearly $1,200 over a competitor's direct injection watercraft."(October 2001, p. 47) It adds that "Yamaha says it has substantially lower operating costs compared to two-stroke direction injection engines."(ibid.) Four-stroke snowmobiles could produce similar savings over the long-term. Maine snowmobile dealer Arno Fichtner explained that the four-stroke engines in the new Arctic Cat snowmobile are so durable "they could outlast three snowmobile frames." ("New quieter snowmobile available in Maine," Bangor Daily News, November 2, 2001 - copy enclosed) This evidence confirms substantial savings associated with using this technology in the off-road vehicle category. Energy -- When considering energy, moving to a more protective standard once again clearly complies with the law. The average four-stroke engine is 35 percent more fuel efficient than the average two-stroke. According to an article in the Bangor Daily News, "[I]n gas mileage, four-strokes get between 30 and 35 miles per gallon, compared with two-strokes, which get 10 to 15 mpg."("Snowmobile sales clean up, Four-stroke engines popular," December 29, 2001) The Agency estimates that total fuel consumption across all covered categories will be reduced by 730 million gallons annually when the proposal is fully phased-in. The total reduction would only be greater with stronger emission standards that would produce large-scale conversion of the snowmobile fleet to four-stroke technology. Noise -- In terms of noise, as discussed above, encouraging more widespread application of four-stroke technology across all recreational vehicles would begin to reduce noise pollution. Although this is clearly beneficial, we believe the Agency should take additional, proactive steps to further reduce harmful and disruptive noise levels, including from diesel recreational boats. Safety -- The industry has already determined that it is safe to produce and sell a wide range of vehicles with four-stroke engines. ATVs and dirt bikes have long used this technology. Yamaha, one of the leaders in personal watercraft development and sales, is producing a new four-stroke jet ski that it believes is safe. Finally, two of the four major snowmobile makers will sell four-stroke machines this season. We believe it is important to address the one safety issue the Agency did raise concerning snowmobiles. The proposal states that snowmobile weight is a safety issue because riders need to be able to pull their machines out of deep snow. We urge the Agency to very carefully examine this issue. Based on our analysis of 45 model year 2001 snowmobiles - excluding models specifically designed for children - the average snowmobile weighs 516.6 pounds. Although some individuals might be capable of safely pulling a quarter-ton machine from a snow drift, we question whether or not this is actually a routine practice and whether or not adding weight with four-stroke technology will really alter this situation. In light of these facts, the safety issue linked to snowmobile weight demands detailed scrutiny. Furthermore, setting performance and emission standards that would result in more widespread use of advanced pollution control technology, such as catalytic converters, in conjunction with four-stroke engines would also favorably comply with these secondary issues. In testimony presented during the Agency's public hearing in Washington, DC, the Manufacturers of Emission Controls Association (MECA) stated: "We strongly believe, however, that significant additional emission reductions from these engines using catalyst-based systems are technologically feasible, cost effective and safe. Quite simply, if EPA's rule is finalized as proposed, an important opportunity to reduce emissions and better protect public health will be lost." We appreciate the opportunity to raise an interrelated issue concerning an exemption from air standards for personal recreational vehicles brought into the United States by foreign nationals. We are curious why the Agency provides a one-year exemption from U.S. standards for foreign nationals traveling with personal snowmobiles or other equipment. U.S. Customs does not maintain a one-year emissions exemption for foreign owned property. Instead, it allows unlimited temporal use of such vehicles, and so we must assume that the rational grounds for the Agency's proposed exemption would be if the Agency has determined that the harm of prolonged use outweighs other actual benefits of longer exemptions. This would appear to be a very reasonable argument, and we assume this is the justification, and request that EPA confirm that this would be the basis for such an exemption. The undersigned organizations look forward to working with the EPA in the months ahead to strengthen the proposal in order to provide greater protection for air quality, human health and public lands and waters. Sincerely, Scott Kovarovics On behalf of: Forest Watch, Montpelier, VT Georgia Forestwatch, Ellijay, GA Klamath Siskiyou Wildlands Center, Ashland, OR Virginia Forestwatch, Wytheville, VA Clinch Coalition, Coeburn, VA Coalition for Jobs and the Environment, Abingdon, VA Devil's Fork Trail Club, Dungannon, VA Citizens of Lee Environmental Action Network, St. Charles, VA Taking Responsibility for the Earth and Environment, Blacksburg, VA Patrick Environmental Awareness Group, Stuart, VA Mountain Lion Foundation, Sacramento, CA Alaska Center for the Environment, Anchorage, AK Winter Wildlands Alliance, Boise, ID Yosemite Area Audubon, Mariposa, CA Western Colorado Congress, Grand Junction, CO Issaquah Alps Trails Club, Issaquah, WA Headwaters Environmental Center, Ashland, OR Center for Sierra Nevada Conservation, Georgetown, CA Butte Environmental Council, Chico, CA Idaho Sporting Congress, Boise, ID Wildlands CPR, Missoula, MT American Lands, Washington, DC Public Employees for Environmental Responsibility The Oregon Natural Desert Association, Bend, OR Idaho Alpine Club, Idaho Falls, ID Eastern Sierra Audubon Society, Bishop, CA Endangered Habitats League, Los Angeles, CA Ilana Levin Snowlands Network, Livermore, CA High Country Citizens' Alliance, Crested Butte, CO Center for Biological Diversity, Tucson, AZ Appalachia - Science in the Public Interest Jumping Frog Research Institute, Angels Camp, CA Natural Resources Defense Council, New York, NY Defenders of Wildlife, Washington, DC National Parks Conservation Association, Washington, DC Quiet Use Coalition, Buena Vista, CO Red Forests, Moab, UT Sierra Nevada Alliance, South Lake Tahoe, CA Washington Wilderness Coalition, Seattle, WA Environmental Defense Center Predator Conservation Alliance, Bozeman, MT The Wilderness Society, Washington, DC Range of Light Group, Sierra Club Minnesotans for Responsible Recreation, Duluth, MN The Fund for Animals, New York, NY Schubert & Associates, Phoenix, AZ **** Read more the about the EPA's Small Engine Rule Read our testimony on the Small Engine Rule
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