Comment Log Display

November 2, 2009



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

RE: Proposed Amendments to Regulation to Reduce Greenhouse Gas
Emissions from vehicles Operating with for Under Inflated Tires

Dear Clerk:

	On behalf of the Automotive Service Councils of California
(ASCCA), we are writing to provide comments to the proposed
amendments to the Proposed Amendments to Regulation to Reduce
Greenhouse Gas Emissions from Vehicles Operating with Under
Inflated Tires. The ASCCA is a statewide organization that
represents 1,000 automotive repair facilities, including smog
shops.

	We appreciate the revisions and modifications that were made to
these latest proposed regulations based upon our letter dated March
20, 2009.  The ASCCA has the following additional comments and
suggestions:

1)	The proposed regulations should apply to all automotive service
providers registered with the Bureau of Automotive Repair (BAR)
that perform automotive repair services.

2)	The proposed regulations are not clear as to whether the
service provider must check inflation of vehicle tires while the
tire is “hot” or wait for a period of time and check when the tire
is “cold”. This concern was raised in prior correspondence and at
the Air Resources Board workshops. It still has not been adequately
addressed in the proposed amended regulations.

3)	The proposed regulation does not address the issue of oversized
tires as well as the modification of a vehicle to accommodate such.
 We request that this matter be addressed in the proposed
regulations.
 

4)	As you are well aware, the BAR has regulatory oversight of the
automotive repair dealers in the state.  BAR has the expertise and
personnel to properly oversee the enforcement of these proposed
regulation rather than the Air Resources Board. As such, we request
that the BAR act as the authorized representative to enforce this
regulation under existing law, that the proposed amended
regulations reflect such enforcement and that Section 95550 (e) be
deleted in its entirety.

5)	Under current law, the BAR requires that an automotive repair
dealer obtain authorization from the customer before performing any
diagnoses or repairs on vehicle.  These regulations do not address
the situation whereby a customer refuses, for whatever reason, to
provide authorization to the automotive repair dealer to have the
tires checked and inflated. We further recommend that a specific
exemption be included for such an instance and that such be
reflected on the vehicle service invoice.

	ASCCA believes that unless the above concerns are adequately
addressed in the proposed regulations, the tire inflation program
may not end up reducing greenhouse gas emissions and, in fact, may
be more detrimental to the environment than beneficial.

Thank you for your consideration.

Sincerely,

 
Jackie A. Miller
Executive Director for
Larry Nobriga, Chair, Government Affairs Committee

CC:	Glenn Davis, President
	ASCCA Board of Directors
	ASCCA Government Affairs Committee
	Jack Molodanof, ASCCA legislative advocate