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Comment 25 for Emission Warranty Info. Reporting and Recall Regulations and Emission Test Procedures (recall06) - 45 Day.

First NameKevin
Last NameMcCartney
Email Addresscrashh@prodigy.net
Affiliation
SubjectWarranty vs Repair Assistance
Comment
The state bases most of it’s justification for a "super warranty"
on it’s failures to win judgements against the Original Equipment
Manufacturers (OEM). This seems to indicate that the OEMs will win
similar judgements concerning warranty coverage of catalytic
converters, EGR systems and other emission control systems. 

A much more effective alternative exists. The state has very
effective low income repair assistance program (LIRAP) that
successfully reduces emissions in a very efficient and cost
effective manor without any potential for legal challenges to
eliminate positive results. The state also has a very popular
program that allows consumers to voluntarily pay a fee at the time
of new car purchases to avoid future smog inspection expenses.
Clearly, consumers are willing to pay the state to reduce their
future emission related expenses.

A state-controlled program that allows consumers to choose ANY
state approved repair shop best handles high mileage emission
repairs. The state then has control over what gets repaired
without legal challenges. Licensed technicians under strict
oversight and direct approval of state employees perform the
repairs. Any super warranty option will be subject to legal
challenges that the state has a well-established history of
loosing. And, any repairs that actually are performed under a
super warranty program would be legally performed by technicians
that do NOT posses the state required smog license.

Consumers will NOT be well served by a super warranty that causes
them to be redirected to a dealership who charges them diagnostic
fees only to confirm that the needed repair is not covered under
the super warranty. A state run system similar to the very
successful LIRAP program would allow consumers to have
emission-related repairs performed with great efficiency and
competence by their choice of state approved service providers. 

Phosphorous poisoning is a leading cause of catalyst failure.
Phosphorous poisoning is believed to be responsible for over 90%
of catalyst failures under existing warranty and and even higher
percentage of higher mileage catalyst failures. Sulfur, sulfated
ash and zinc also damage catalysts. But, this is ignored by
consumers and California BAR has refused to convey this
information to technicians (other states have informed technicians
through newsletters, etc). The vast majority of consumers,
technicians and service managers (including dealerships) are
ignorant of the many compounds in readily available automotive
products that will and do degrade catalytic converters. 

The catalytic converters that degraded due to phosphorous or other
common contamination would not be covered under the existing super
warranty proposal. Likewise, EGR failures and deposit related
failures would often NOT be covered under this super warranty
because such failures are often prevented by the use of OEM
approved fuels. California clean air would be far better served by
outlawing substandard fuels lubricants and lubricant products that
are linked to the majority of emission system failures. 

A Super warranty would NOT cover most catalyst and EGR system
failures because most such failures are caused by the use of OEM
prohibited products. Catalytic converters in properly functioning
cars eliminate about 99% of harmful exhaust emissions. A typical
1000 PPM NOx is reduced to 10 PPM by normal catalyst reduction. A
super warranty that excludes that is useless if the OEM can argue
that the catalyst failure was caused by the use of prohibited
compounds (Phosphorous, sulfur, sulfated ash, zinc, chlorine, etc
– all commonly used by consumers, shops and dealerships)

Attachment
Original File Name
Date and Time Comment Was Submitted 2006-12-06 11:50:28

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