First Name | Jackie |
---|---|
Last Name | Miller |
Email Address | jmiller@amgroup.us |
Affiliation | Automotive Service Councils of CA |
Subject | Regulation re Under Inflated Tires |
Comment | 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 |
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Date and Time Comment Was Submitted | 2009-11-03 11:18:13 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.