Comment Log Display

California Air Resources Board
c/o Clerk of the Board
1001 I Street
Sacramento, California 95814


Re:  Notice of public hearing to consider amendments to
California’s emission warranty information reporting and recall
regulations and emission test procedures

Dear Members of the California Air Resources Board:

The Independent Automotive Professionals Association (IAPA)
opposed the above referenced proposed rulemaking that would change
the way CARB staff addresses emissions parts in California. The
IAPA members are dedicated independent automotive repair shop
owners and aftermarket parts distributors both wholesale and
retail.

 This pending rule will ruin our businesses and livelihoods.  The
CARB staff through a commissioned study completed by the RAND
Corporation stated that if the pending regulation is implemented
it will have a significant impact on the automotive aftermarket by
2010 and will cost our business segment millions of dollars in
revenue.  It will have a negative impact on our economic survival
in California and will impact other departments’ revenue such as
the Employment Development Department, Franchise Tax Board, State
Board of Equalization and Bureau of Automotive Repair.  Several of
our members have attended the hearing in Bakersfield and the
workshops held by the department and we are really dismayed that
the CARB staff has totally dismissed our concerns in this matter.

Your Board has heard from many members of the industry that there
is no evidence extending the warranty will provide any real
benefit to the consumer.  And you will give the new car dealers an
unfair advantage over the independent repair segment of the
industry, should you decide to pass the proposed regulation.  Most
of the independent repair facilities invest thousands of dollars
each year to remain current with the changing technology, so we
have a true vested interest in repairing and servicing today’s
automobiles.      

Also, your Board must be fully aware CARB does not have the
authority to extend the warranty beyond the current 3 year/50,000
mile warranty which is the current statute in California.  Even if
you do pass this pending regulation, this whole process will end up
in the courts and the only segment of the California population
that will get hurt is the consumer.  The price of the vehicles
will rise just due to the cost of the litigation alone.  It is
unheard of to require a manufacturer to warranty any product
beyond its useful life.    Most automobile owners do not keep a
vehicle for 15 years, yet they will be paying the price of the
warranty for the second and third owners in the initial purchase.

Please really think about what this pending legislation will do
not only to the new car manufacturers but the consumers and the
aftermarket industry.  Please VOTE NO on the proposed amendments
to extending the emission warranty regulations.

Sincerely,


Michael Self