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Comment 16 for Emission Warranty Info. Reporting and Recall Regulations and Emission Test Procedures (recall06) - 45 Day.

First NameScott
Last NameBrown
Email Addressscott@connieanddicks.com
AffiliationIndependent Automotive Service Provider
SubjectConcerns regarding the proposed extended warranties
Comment
I am first concerned about your conclusion that this proposal would
have little to no economic impact on small businesses in
California. Where is the public record on this study?


Second, extending the warranty threatens the very livelihood of an
entire industry (the automotive aftermarket repair industry) with
no data to show that extending the warranty will improve air
quality in any substantial way. According to the CARB "Motor
Vehicle Service Information Rule"  it states the following: 

"to ensure that independent service facilities and aftermarket
parts companies have access to information and tools necessary to
diagnose and repair emissions-related malfunctions and produce
emissions-related replacement parts for California Vehicles"

If the fleet is under warranty for 15 years / 150k mi then how and
why would we want to continue to tool up for these vehicles when it
is likely that we will never see them?


In fact is is my experience that customers who do not have long
warranties are more likely to maintain their vehicles better than
those with the warranty, over the life of the car, which is far
more likely to prevent excessive emissions. Preventing failure by
proper maintenance (better maintenance than the manufacturer
prescribes) is more appealing based upon the inconvenience alone.


In closing I ask that you look at this from my perspective. We are
an important piece to this puzzle.


Regards,


Scott Brown
Connie & Dick's Service Center Inc.
150 Olive Street
Claremont, CA 91711

Attachment
Original File Name
Date and Time Comment Was Submitted 2006-12-06 08:55:24

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