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Comment 2 for Vapor Recovery Certification and Test Procedures (evr11) - 15-2.

First NameMichael
Last NameFriedman
Email Addressezflonozzle@gmail.com
AffiliationCalifornia Nozzle Manufacturer
Subjectevr11 front end warranty
Comment
There is no one-year warranty requirement for replacement sub parts
(spout, boot, and face seal) in this draft of CP-201. Attached to
this submission is a response letter from CARB to EZ flo nozzle. 
At that time the CP-201 regulations in effect were adopted prior to
the CP-201 draft disapproved by OAL. In the attached documents, at
the top of page 3 CARB admitted EZ flo was correct and they would
contact nozzle manufactures and require them to implement a one
year warranty on the above mentioned products.  This has never
happened and Franklin Fueling was recently re-certified without the
requirement of a one year warranty. Additionally no other
manufacturer has modified there warranty to include spout, boot,
and face seal as CARB stated they would require.  If CARB wanted to
implement this warranty then it should be included in the new draft
of CP-201 disapproved by OAL but there is no such requirement in
either the previous CP-201 regulations or current draft submitted
to OAL.  

Attachment www.arb.ca.gov/lists/evr11/7-oal_1-3.pdf
Original File Nameoal 1-3.pdf
Date and Time Comment Was Submitted 2012-11-12 15:39:11

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