Comment Log Display

Dear California Air Resource Board Members, and all other concerned
parties.

I am writing to express serious concerns about the impact of the
proposed mandated warranty extension, and all previously-mandated
emissions warranty extensions, on the future of the independent
automotive aftermarket, and of the well-being of the automotive
technicians working on these vehicles. In addition, these warranty
extensions will have a significant effect on the solvency of the
car manufacturers, and ultimately on the prices that automobiles
can be offered to the consumer.

The continued trend of mandatory extensions of emissions
warranties in California will result in driving the cost of new
cars up, while restricting the consumer to using only new car
dealers for warranty service. This will cause a massive loss in
routine maintenance and other service repair revenue to the shops
that would ordinarily receive the business, and effectively
prevent them from doing emissions repair for the covered vehicles.
The subsequent lack of service options will cause a backlog in
service, further exacerbating the problem. Unfortunately, by the
time anyone realizes what has happened, the industry as we know it
today could be gone.

Consumers who have convenient access to quality auto service are
much more likely to maintain their vehicles and in turn keep their
vehicle emissions low, even between smog checks. A solid
infrastructure of both dealers and independent repair shops is
good for the country from both an economic and an environmental
standpoint, and is a critical part of maintaining clean air, in
addition to a solid economy. Your actions threaten the very
existence of this industry and directly clash with your stated
goals in your Information Availability rules.

The threat is so significant that over 60% of iATN (a network of
nearly 50,000 automotive professionals) members polled (see
attached) consider the advent of the 15/150 warranty to be a
threat to the very future of the Automotive Aftermarket. These
members are the very people affected by previous emissions
warranty extensions and they should certainly know.

Your actions, both now and previously, seem to imply a belief that
the vehicle will be better maintained by the consumer if it is
under warranty through the car manufacturer. You must have some
statistical data or research to back this assumption, but I have
not see it presented. This is especially critical, considering the
potential effect on the thousands of small businesses, repair
shops, technicians, and consumers, who will all be negatively
impacted by these changes if you are wrong.

Is there a new study on the impact on California small businesses,
and the California consumer as a result of the proposed mandated
warranty extensions? The previous study results, while arguable,
no longer apply due to the increase in the number of potentially
covered vehicles.

What about the impact of these vehicles going out of warranty in
an environment where an entire industry had no incentive (demand)
to tool up on the vehicle since they were warranteed for 150k? How
will the emissions be impacted when that fleet hits the
aftermarket?

Expecting the consumer to keep their vehicle properly maintained
and repaired seems reasonable. Placing their responsibility on the
car manufacturer and their dealer repair facilities exclusively,
will effectively destroy the existing aftermarket infrastructure.
Currently, the independent automotive repair shops are
instrumental in helping to maintain a very large portion of our
country's mobile fleet, and assist in supporting a large segment
of our economy. The destruction of this industry can't be good for
California.

Continually extending the length of mandated automotive warranties
will ultimately cause vehicle prices to go up considerably. If the
OE is forced to warranty vehicles for 15 years, the cost of this
must be passed on to the consumer. The impact on the car
companies, the consumer, and the automotive aftermarket could be
catastrophic. Does CARB expect that these companies, some of whom
are already on the verge of bankruptcy, are going to redesign the
way they build vehicles in order to prepare for this unknown
expense anytime in the near future? Can you imagine the cost in
1991 dollars if GM were forced to cover emissions failures on a
1991 Buick 15 years after it was sold, and the eventual, and
extreme cost to the consumers who purchase new cars in the future?
This expense must be passed on to the consumer. This older fleet is
currently maintained primarily by the aftermarket industry which
you aim to take out of the picture.

These repairs are currently done at a relatively reasonable cost.
The aftermarket industry is supported by the large number of
consumers who choose this option for their vehicle maintenance.
What will the world look like when that industry is not available
for the older fleet?

What the consumer probably does not realize is that these mandated
warranties will add considerable cost to the vehicles they purchase
in the future.  And, to make things worse, some consumers purchase
an extended warranty never knowing they were forced to pay for the
cost of a built-in mandatory warranty for many of the same things
covered by the optional warranty they paid for.

A large percentage of new car buyers will not keep a car for 15
years or 150k miles. These consumers are forced to pay for
warranty repairs for the next owner, even if they know they will
not be keeping the car. What about the impact on the fixed income
community, many of whom will not need a 15 year warranty, and
surely should not be forced to buy one?

What about consumer choice on this issue? Why not give them the
option to pay for their own warranty (one where they can go to any
shop they please) if they wish, or simply pay for the repairs, if
they prefer not to purchase this government mandated insurance?

There is no question that we need a program that requires vehicle
owners to responsibly and properly maintain and repair their
vehicles. The additional cost of this warranty punishes those very
people who do just that. Properly maintained vehicles are less
likely to need longer warranties in the first place.

Perhaps I am missing something, a study, or some kind of proof
that the CARB has that validates this action. An action that has
the potential to damage or even destroy an industry, and in turn
negatively impact a very large segment of our economy, demands
serious substantiation. If this data exists I have been unable to
locate it.

This industry has stepped up to help clean the air on many
occasions. I am sure that most would love nothing more than to
continue to participate in partnering with the CARB in keeping the
air clean, and in keeping the economy growing. We cannot do this if
we are no longer in business. It would be a sad day in American
history to see the Independent Automotive Repair business
regulated out of existence, in the false hope that somehow this
would be good for the environment, the economy, or the citizens of
California. Most Californians very much enjoy their cars, and their
freedom to have them serviced and maintained where they wish.

I would like to end this letter with a very important quote:

"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"

This quote is directly from YOUR Motor Vehicle Service Information
rule.

How can the CARB recognize the critical needs of the automotive
aftermarket in regard to access to emissions service information,
and the importance of the aftermarket segment having the
information and parts to diagnose and repair these systems, and
then on the other hand effectively exclude that very same market
segment from even working on the very same systems covered in the
rule?

Forcing consumers to take their emissions repair work to OEM
repair facilities exclusively, in addition to all the other
concerns above, negates the benefits of your very own Vehicle
Service Information rule by effectively locking out the
aftermarket from the majority of repairs covered by that rule.

Submitted respectfully for your consideration.

Thank you.

Brent Black 
President and Founder 
International Automotive Technicians' Network 
Brea, California