Office of the United States Trade Representative
Attn: William L. Busis
Chair, Section 301 Committee
December 8, 2008
RE: Docket #USTR-2008-0036
Dear Mr. Busis
I am writing you today regarding a matter of extreme importance to the American
public, the proposed import tariffs on European motorcycles between 51cc and
250cc (HTS 8711.2000) and 251cc to 500cc (HTS 8711.3000) in displacement.
We urge you to reject the proposed 100% tariff on the above two product
categories, as it would have disastrous unintended consequences that would
devastate hundreds of local retail businesses and put thousands of American
workers out of work. The proposed product categories are primarily off-highway
oriented motorcycles produced by companies including KTM Sportmotorcycles,
Husqvarna, Aprilia, Beta, Gas-Gas, and BMW. Typically, these are premium
quality motorcycles and are typically sold by small to medium size dealers that
often are single brand shops or European brand specialists. As an example, here
in my local area, there are 3 motorcycle shops, Handlebar Motorsports, Sun Sports Unlimited,
Davis Service Center and Planet Motosports, that sell motorcycles in the two
targeted product categories. These stores, as most in this category, have been in
business for decades and have extremely loyal customers who prefer these brand
motorcycles. KTM in particular enjoys a significant market share in what is
commonly known as the “Enduro” motorcycle category and is an industry leader
in certain model categories. KTM produces a very wide range of specialized
models that their Asian competitors have failed to address. Many of these
European brands are also at the cutting edge of “Clean” technologies and have led
the entire industry towards more environmentally
friendly products.
While we understand the need to devise strategies to ensure American products
such as beef are allowed to be exported to European Union countries and
compete fairly, it is unfair to Americans to wipe out hundreds of businesses and
thousands of jobs in a totally unrelated product category. It is especially ironic
that there are NO American companies of consequence producing competing
motorcycles in these two product categories. The off-highway motorcycle industry
is already struggling today due to the current economic crisis. A 100% tariff on
these products would be a fatal knock-out blow that would be totally unfair to
American businessmen, their employees, and their loyal customers. Please do
NOT add to the economic crisis by bankrupting innocent American businessmen
and putting thousands of their employees out of work.
Respectfully,
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