[Ducati] Importing a newer bike: Your experience with Ducati NA?

[Alex]

I am working on importing a recent model Ducati that was not sold in 
the USA.  (And yes, I found a transporter to do it reasonably for my 
$100,000 750SS (snicker))

I've already done the homework on the legal issues with DOT and 
EPA.  I've gotten DOT approval.  EPA has requested a manufacturer's 
representative statement that the bike met (past tense) EPA 
regulations on the date of manufacture (in this case, 1994).

I've also done the research to determine that all bikes Ducati made 
for sale in Europe and the USA in '94 met Euro1 specifications.  The 
ones exported to the USA had no additional emissions features added 
(I have verified this with Ducati in Italy, the only difference is 
the EPA stickers).  Thus, pretty much any Ducati motorcycle in its 
original form from that year (Euro1 = 1993-95) is compatible with US 
EPA regulations, they only need the EPA stickers applied.

Now, my question.... I've requested such a letter from Ducati NA 
(USA) and have been flatly told "no."  The reason given was that "EPA 
regulations are changing all the time and we cannot guarantee that 
any particular model meets EPA guidelines.."  This answer is flatly 
off the mark -- EPA clearly says a 1994 vehicle must only meet 1994 
regulations (see EPA form 3520-1) and should be importable as having 
emissions "identical in every material respect to a US version at the 
time of manufacture" (category EE).  In this case, there is a similar 
US version that can be compared (larger engine, but same in every 
other respect -- i have been informed by EPA that this variance is 
acceptable, provided both bikes were manufactured to the same 
emissions specifications, I just need a letter from Ducati NA saying so).

What makes this more frustrating is that I've done the research.  I 
have a huge amount of legal resources at my disposal. (I've cleared 
the bike with DOT/NHTSA regarding the FMVSS variations and they've 
approved the list of modifications needed.)  Does anyone happen to 
have a name of an attorney at Ducati NA so I can talk to them, lawyer 
to lawyer?  I have only dealt with Ducati NA's "customer service" and 
I am sure this is an issue of the bottom person not explaining the 
question well.

I would be very upset to learn that Ducati NA is refusing to help 
Ducati collectors like myself acquire bikes that were never imported 
into the USA (this does not apply to 25+ year old bikes of course, 
they don't need emissions approval).  It does nothing to help their 
image among owners and collectors and it would not hurt them at all 
if it can be conclusively shown the bike as manufactured was EPA compliant.

Anyone?