Comment Log Display

 
 
   


To Whom It May Concern: 

As an independent automotive repair shop owner in the State of
California, I am contacting you in regard to the December 7, 2006,
Public Hearing to Consider Amendments to California's Emission
Warranty Information Reporting and Recall Regulations and Emission
Test Procedures. I am concerned with several aspects of the
proposed rule changes. 

Of the existing regulations that need to be improved upon, your
staff identified three specific aspects: 

The proof required to demonstrate violations of ARB's emission
standards or test procedures; 
The corrective actions available to ARB to address the violations;

The way emissions warranty information is reported to ARB. 
As part of the “Corrective Action”, ARB staff state, “Depending on
the type of the defective emission-control component and whether or
not OBD is able to detect the problem, corrective action would be
either the recall of all affected vehicles or the extension of the
emission warranty for that specific component.” 
However, in the staff evaluation of the Potential Impacts on Other
Businesses, the report states “The proposed amendments should have
minimal impact on the independent service and repair industry and
aftermarket parts manufacturers since the proposal deals with
relatively new vehicles and engines that are still within their
certified useful life period.” 

Any expansion of the vehicle warranty status will negatively
impact my business and other independent repairers in the State of
California. I believe this is a major change in the vehicle
warranty and a major rulemaking initiative. I implore the ARB to
conduct a thorough economic analysis of this proposal's impact on
the California independent repair industry. This proposal will
have a negative impact on small businesses, the economy of our
state and should be rejected.