| December
19, 2002 Honorable Senator Don Perata State Capitol, Room 4061 P.O. Box 942848 Sacramento, CA 94248-0001 Re:
AB 2637
Dear Senator Perata: My name is Dennis DeCota. I am the Executive Director of the California Service Station and Automotive Repair Association. We presently have approximately 350 members participating in the state Smog Check Program within the Bay Area. Our membership is very concerned about the implementation of the Enhanced Program as authorized by AB 2637. During testimony on this bill you were predominant in making sure that industry had a say in the implementation of this Enhanced Program. To date the Bureau of Automotive Repair (BAR), which is in charge of the program oversight, has not approached industry. It is very difficult for industry to have any input in any manner with BAR about implementation, as BAR somewhat stonewalls any dialogue that pushes against its own agenda and regulations. I fear that you will experience a huge consumer backlash given the timeframe that has been allotted for the program implementation. There are many factors that you should be aware of. First, there are approximately 1,750
BAR-licensed smog test and repair shops in the Bay Area.
All of those will be required to invest from $30,00 to $60,000 for the
acquisition and installation of new equipment in order to comply with the Enhanced
Program. Unfortunately, there are only two providers left in the state of California from
whom they can buy this mandated equipment. One
is Worldwide and the other is ESP. Both
companies have a poor service rating among their current customers and excessively high
maintenance costs for service contracts after the first year of warranteed use, which run
in the area of from $3000 to $4000 per machine per year. The test-only mandate usurps the
testing revenue from test and repair shops and creates a captive customer for those
test-only stations whose testing charges average 35% higher than those of the test and
repair shops. The California Service Station
and Automotive Repair Association would be happy to share with you our surveys of Southern
California and the Sacramento area on the decline in testing revenue that occurs once the
Enhanced Program implements full cut points for emission reductions and directs more and
more cars to the test-only network. It is
crucial to The second factor is the area of qualified
technicians who can perform the Enhanced Smog Check protocol. Currently, out of the approximately 2900 Bay Area
licensed smog check technicians, 2005 of them (69% of the total workforce) will need a
minimum of thirty-six hours of additional training in order to meet the licensure
requirements for techs to perform the Enhanced Program.
However, there are only a few qualified training programs available to
technicians to get the license updates. The
reality of this situation will necessitate that the licensing requirements be extended for
individuals well into the year 2004. The third area that should be addressed is that the current program, which is approximately five years old, is rapidly becoming antiquated with the ability of high tech companies to develop equipment to test for emissions such as NOx. A company named Hickock Inc. has developed a tester for EGR valves that replaces the need and expense of the costly treadmill device called a dynamometer. The dynamometer garners the lions’ share of the equipment costs of approximately $30,000. This new tester for NOx, which has a White Paper out on it and has been reviewed by the Society of Automotive Engineers, would cost one-tenth the price of a dyno. If this technology can perform and accomplish its stated goal, it would save industry literally hundreds of thousands of dollars in equipment costs and allow the consumer to find a more reasonably priced smog test. Unfortunately, due to the lag in timely appointments to the Inspection and Maintenance Review Committee (IMRC), the legislature has not been made aware of these new methods of reducing emissions at a lower cost. It is only within the last fifteen days that the IMRC has had a meeting as it lacked a quorum. It is most unfortunate that the legislature did not have a method to look into the issue of Enhanced Smog Check in the Bay Area before AB2637 was passed into law. But I firmly believe it is not too late to make necessary changes in order to accommodate consumers and clean the air in California. I would like to set up a meeting with you in your district office with a few of our Association’s members to further explain to you the issues of test-only, technician competency and the real world issues surrounding Enhanced Smog Check in the Bay Area. I thank you for your leadership on this issue. I hope you and your family have happy holidays. Sincerely, Dennis DeCota Executive Director |