California Bureau of Automotive Repair Public Workshop – February 12, 2018

California Bureau of Automotive Repair Public Workshop – February 12, 2018


good morning I want to welcome everyone to the Bureau of automotive repair my name is Patrick dray chief of the Bureau of automotive repair and this is a regulatory workshop dedicated to proposed regulation that we would appreciate some feedback on its kind of package that we’ve been shopping around for the better part of and work shopping and working with interested parties and various stakeholders for the better part of year your year and a half it all began following some legislation that did not become law a B 873 was introduced by Assemblymember Jones Brian Jones thank you and that bill although was signed in by the governor and reached his desk and was signed by the governor did not become law as it was joined to another bill Senate bill 778 that the governor vetoed so the bureau following on the heels of that and the governor’s veto message on the one bill pointing to a b 873 the bureau took upon itself to look at how we might be able to do this without legislation some of the in the spirit of that legislation try and address some of the things that it was looking at doing with respect to exemptions and potentially streamlining the estimate process for certain services so we’ve have been this latest iteration removed some of the exemptions that we were initially contemplating because it appeared to us that the various stakeholders couldn’t reach agreement where there was no consent real consensus except that there might have been consensus in the sense that some of those regulations shouldn’t be pursued and I won’t get into or elaborate on that but it was our determination following some of our latest attempts to bring the parties together that maybe we should peel that back for a little bit and take a look at maybe a simpler approach to some in particular one aspect that was addressed in the AV 873 legislation dealing with roadside services so we’re gonna move forward with that proposal that was in that bill that the governor pointed to in his veto message of the other bill that appeared does not have any real opposition and we our language in this regulatory proposal mirrors that language that was in that bill as it relates to that item and then we have a another area that we are looking to provide some regulatory relief if you will to certain procedures and services performed by some of the quick lube oil change operations that are currently registered with the Bureau of automotive repair as automotive repair dealers so I’m going to turn it over with that brief introduction of where we are and how we got here to our coordinator on this particular package Brian Clark who’s kind of wrestling with a cold it appears so bearing with him a little bit but I appreciate his being able to make it into the workshop today and he’ll run through a few slides and then what we hope to do is open it up for some comment and some discussion we’re scheduled till about 12:30 today and do not intend to go beyond that as I have a an appointment after that but we are webcast and those who are listening in can certainly participate even though they are not physically in attendance the email address is bar meeting at DCA dot CA govt and someone is monitoring that I’m not sure I’m looking around the room there he is Thank You Sergey but again that email address is bar meeting at DCA CA govt and we’ll check from time to time to see if there’s any comments or questions through the webcast all right Bryan any questions before we get started with the presentation okay thank you today’s presentation discussing the roadside services and result revised estimate requirements the roadside services portion of it will be a revision to section 30 303 to the definition section to exempt roadside services from the definition of repair of Motor Vehicles and requirements will be to section 33 53 in an essence what it will do it will exempt from the estimate requirements lubrication oil and local changes and also what we’re calling pre service inspection services those two things will be exempt from the estimate requirement diving into the roadside services portion recently adopted by regulations specifically article 6.1 set fourth registration operation advertisement requirements for automotive repair dealers that do not have a registered place of business and use a motor vehicle to transport an automotive repair technician tools and equipment to perform repairs in regards to article 6.1 motor clubs and independent tow truck operators have voiced concern that the roadside services they provide may be construed as requiring a Rd registration it was not bars intent to require roadside service providers to register as a Rd s as a result the proposed regulatory exemption would mirror the definition of roadside services contain an AV 873 in regards a specific language by regulation 3303 H would be revised to exempt the following from the definition of repair of Motor Vehicles roadside services performed upon a motor vehicle for the purpose of transporting the vehicle or just to permit it to be operated under its own power by or on behalf of a motor club holding a certificate of authority to pursuant to chapter 2 commencing with section 1 tu-160 a part 5 of division 2 of the insurance code or by an operator of a tow truck as defined in Section 6 1 5 of the vehicle code that is owned or operated by a person or entity who possesses a valid motor carrier permit as described in section 3 4 6 2 0 of the vehicle code and is enrolled in the basic inspection of terminals program as described in section 3 4 5 0 1.1 2 of the vehicle code in regards to the revisions there will be no changes to the existing regulatory exemptions for repair of human habitation portion of recreational vehicles or for transmission fluid changes moving on to the revised estimate requirements pursuant to current regulatory requirements AR DS unlike exempt service stations must generate an initial estimate to perform lubrication engine oil and filter services to undertake and to undertake pre service inspection procedures comments received by bar from AR DS and automotive repair industry organizations assert that requiring AR DS to generate estimates prior to performing the above-mentioned services and procedures as unnecessary wastes time and resources delays the provision of these maintenance services and is confusing the customers as a result the proposed revisions to bar regulations section 3 3 5 3 will permit AR DS to perform the following services and procedures without first having to generate an estimate chassis lubrication engine oil and filter services and pre service inspection procedures all other work is subject to the estimate and authorization requirements of BP C chapter 20 point 3 article 3 and bar regulations chapter 7 I’m sorry chapter one article 7 turning to the specific exemptions in regards to lubrication engine oil and filter services an estimate would not be necessary to lubricate the vehicles chassis change the engine oil change the engine oil filter and the removal and reinstallation of any caps covers plugs and lids necessary to perform the chassis lubrication oil change or filter service or oil filter change excuse me in order for the estimate for these services the estimate requirement for these services do not apply the following conditions have to be in place the prices for chassis lubrication oil change in oil filter change services must be displayed in the place and manner conspicuous to all customers at the facility where the services are being performed and a written estimate is not required but the ard must obtain the customers authorization prior to performing any of these services and in this regard and oral authorization would be acceptable moving on to pre service inspection an estimate would not be necessary to perform one or more of the following proceed a visual inspection of the condition of the vehicle the checking of levels and condition of the vehicles fluids a visual inspection of the engine air filter and cabin air filter the retrieval of diagnostic trouble codes the checking of tire pressure and the testing of batteries not to include propulsion batteries for the exemption to apply to these preens service inspection services they have to be performed free of charge and they cannot require the disassembly of the vehicle or removal of its components with the exception of the removal and reinstallation of a vehicle’s engine air filter cabin air filter and any caps covers plugs and lids necessary to conduct the procedure also a written estimate is not required however you must obtain an ard must obtain a customer’s authorization prior to performing any of the aforementioned procedures and similar to the fluid oil change the filter oral authorization would be accepted [Music] all right thank you Brian I think we’re at the point where we’ll open it up for public comments please just by way of procedure and because we are being webcast we’ll have to share the four mics here so please yeah good to test them they I think they’re all in good working order but just state your name and the organization’s or organization that you’re representing thank you councils of California Cali ABC in the California Auto Body Association thanks for the presentation Brian let me just ask you on page two the recently adopted regulations for mobile for the mobile AR DS were adopted just recently and then you’ve got a statement here that says that the motor clubs and independent tow truck drivers tow truck operators have voiced concerns I mean what what have those regulations done to them what what are the issues there I guess and the need for this right now I think during the process of those regulations we heard some concerns and worked with the towing operations providers to make sure that those regulations didn’t but I think there was still a a voiced concern that didn’t bring them into the regulatory framework of the Bureau of automotive repair and then so this regulation is definitely an attempt to clarify with or without those regulations though personally I had made a commitment following the legislation EBA 73 to try and work through some of the provisions that were in that bill because I quite frankly felt like legislation wasn’t necessarily needed obviously we we got to a point where the bill did not become law even though was general consensus because it got to the governor’s desk then it should become law we got to the point where because of the double joinder of it to the other bill that was vetoed we were stuck with her we were stuck with not having something that everybody and had reached agreement on become a provision that did not become law so we thought that we could do some things regulatory early speaking to try and get to that same that same point yeah because that definition was in place but it was contingent upon the unlicensed unregistered folks being regulated by BA R even though it was a maintenance provider status but this was contingent upon some other pieces I’m just wondering I guess I just needed to understand why is this necessary now is something going on with the tow truck operators that they feel like they have to register with be are there been any cases or anything like that that there’s a need for this section right now so that’s that’s what I’m asking is is this really necessary right now is it something and I know my good friends here at triple o maybe you’re from sure maybe they could help answer that some of the question is really we do not have any cases okay but I would I would think regulatory clarity is something that all of us in this room would agree is needed and I’m all for that I’m in support of that and you know it was seemingly an issue when it got included in a bill I I think we were all in agreement that yeah we want to make sure that if there is any confusion about this area that we we could address it through legislation or through regulation which we have pretty broad authority to try and address so it was our attempt to try and carry out that that goal in California do want to make clarify and correct a couple of things this isn’t some new issue that’s just arisen in the last couple of months and it’s not even actually related to I think the importantly mobile repair regs that were done by this body this has been a question for an extended period of time and it wasn’t it wasn’t contingent on other pieces of a late move this is been in the legislature for more than five years this language has been around for at least that it’s been presented it’s been approved it’s been dissected it’s been reviewed it’s been the governor twice he signed it the last time the joining of the two together the dispute frankly on the oil changes is of about a six month vintage and it’s just kind of we would say an accident of circumstances that they put together I think there was a misunderstanding at least on the part of one author what your thought was going to be happening and what he thought was going to move forward with with his bill but in terms of this particular language that this this has been the subject of an exhausted number of meetings I remember a 40-person meeting with you where we kind of went through it for hours and I think people understanding the whole point of this reg this piece and the other piece is is regulatory clarity for everybody so we know what’s going on so that’s that’s what I would add to that legitimate conversation I appreciate the comments there the slide that did say that we did get some concern I think there were a few comments raised during the mobile service mobile will be ard advertising regulations I can’t remember exactly what they were turned but when they got adopted or before they got adopted there were some concerns that we got and we know this isn’t going to bring you into the regulatory fold it was kind of a trust us we are going to be moving on the back end of this adoption of the mobile ard advertising regulations with some regulations that clearly spell out the exemption that we’ve that were operating under today like frankly there’s nothing on the books the bar has no intention of regulating towing operations that are out there doing a service for consumers and myself included as a triple-a member providing services to those who are in need of some assistance when their vehicle breaks down this is Tim Chang with the Auto Club of Southern California and I just want to build on what you just said as we understood the mobile VR dreg those were those were brought forth because there was concern that there were mobile repair persons operating on like Craigslist and other things that were going out they’ve never garage and they were going out and specifically doing repairs that were jacking up cars and getting them crawling under them and actually doing repairs and so that was the concern we expressed with those regs is that we not inadvertently get tangled up within that problem and I think these records so may I just follow up now and thanks for the clarity but in terms of the language itself I know that this is has been in a couple of bills over the years but as as my good friends at triple-a know that a year in politics is a lifetime I know that there’s been concerns about internet platform providers out there that are conducting business and maybe without an ard and one of the and and I don’t think anyone has any concern with tow truck operators providing emergency type services if you know urgent type services so if someone breaks down you know repairing the tire replacing the tire someone loses their key in the middle of night in a mall or something like that they need help or someone has a dead battery go charge if you can’t charge it you end up selling them a battery emergency type services that are urgent one of the things that we have asked or at least talked about in this current language is that it needs to be tightened up a but to limit it to emergency type services versus non-emergency type services where someone could have their service done by a tow truck operator that may not be urgent in other words maybe they need to have a repair maybe they want the battery replaced and the car has there’s a dead there’s a car in the garage maybe that has a dead battery they set up an appointment of a couple weeks down the line non-emergency in that type of scenario I would think that the that the the tow truck operator if they’re going to get into the repair business they should be registered with ard so one of the things that I had suggested was the tighten of the language to make sure it’s limited to roadside services are limited to urgent emergency type services that was one of the suggestions I had if you want to put up the language up there I can show you what what our specific proposal was it’s on page three of the presentation what we had what we had requested was right after where it says roadside roadside services performed upon a motor vehicle for the purposes of transporting the vehicle or to permit it to be operate under its own power that that second sentence there – or that second phrase to permit it to be operated under its own power is so broad we had suggested tightening it up to maybe read in case in cases of emergency to permit it to be operated under its own power so that was one of the suggestions we had to sort of tighten up the language to make sure this doesn’t create a loophole for future maybe internet providers who may operate through a tow truck to conduct repairs and and so we’re concerned about potential loopholes down the line you referenced the batteries which were already as you know exempt under the statute correct they would be exempt like that me that probably was a bad example but if there was a another type of repair that does fall under the ard you know going to someone’s home and doing a brake job let’s say they would we I guess the concern would be that they would use a tow truck to go to someone’s house in a non-emergency situation and repair the brakes and not have to be under this provision and not not have to be registered with a as an ard I am so I’m just throwing that out for discussion I know I know that’s I guess it would be am I at some point in conflict with the definition of repairing motor vehicles if they were doing some kind of never doing a brake job for example I don’t know why anyone would want to spend hours doing a brake job when they have probably hours of work towing vehicles potentially but probably in some cases a lot easier and maybe even profitable I don’t even know the business side of it but yeah at some point it would run into conflict with our if we have we had a towing operation that was preparing cars on the side it seems to me it would be in conflict with other provisions in our laws that well the concern is if this exemption as is goes through than someone with a tow truck can do a Rd type of repairs based on that second provision that I quoted that that’s the concern I did we don’t want it to be a loophole that and and so I don’t see it that way because we still have the repair of motor vehicles that would be precluded if you look at the second half of that revisional these are folks that are fully invested in the towing industry that’s what they do they purchase this equipment the idea that someone could could kind of toggle back and forth to this kind of a thing doesn’t make a lot of sense I’m not sure how you would even pull that off I’ve never actually been to a repair shop that didn’t say the magic words we’ll have to order the part all of that sort of thing we we haven’t heard of a single example of this happening and also I don’t understand what the emergency thing means I mean what what’s an emergency who decides do we do we bring some more uncertainty to it so I leave you somewhere I’m gonna say I’m sorry I can’t I can’t take the two seconds to fix your problem this this these kinds of suggestions have been made for multiple years in the Legislative environment and they have been uniformly rejected they have never been adopted there’s no showing of a problem and we the language should remain the way that it is any others on this particular section of the proposal I mean quite honestly let me think what I was just saying we don’t have any problem oh yeah and you Mike my Planning Group with Les Schwab okay thank you I want to make sure we got that on the record thank you Mike yeah from bars perspective it was making good on it on what seemed to be agreement at the time the pill that to the governor’s desk and was signed so we mirrored I don’t think there’s a word that has changed actually I think we tried to streamline it and just felt like that there were some things streamlined some of the wording and came back I think following an earlier workshop just let’s just keep it simple and follow what was in that bill we beat 73 when it got to the governor this language is at least four to five years old more comments on this section have a none how about moving on to the next section dealing with the estimate revisions I think in the case of the oil excuse me the chassis moved the oil change in the oil filter change Brian categorized it as an exemption from the written estimate requirements I think we’re kind of the mindset that this is a substitute because a fourth a written estimate requirement that you are as long as it’s you get that authorization it can be oral as long as it’s conspicuously posted in the shop for all to see all consumers that we’re kind of seeing that as a substitute for the written estimate requirement not necessarily exempting anyone from that requirement it’s an adequate substitute most people know what the price of an oil changes they do it on a regular schedule regularly scheduled some do it as frequently as 3,000 miles some do it every 5,000 miles 7,500 miles and then some depending on the make model of the vehicle and in model year of the vehicle and driving conditions and so on and so forth as one of our other regulatory packages is attempting to address that surface interval schedule so we felt like this was an adequate substitute for the written estimate requirement and then there are procedures that are done that we call kind of pre service inspection procedures where we actually say an estimate is not necessary but that’s because they would be done free of charge to the consumer and many have said that we do all these things you know the moment the car is driven and we start checking the fluid level how can you write an estimate when you don’t know what kind of fluid what kind of oil that car takes how many quarts are needed so on and so forth so it did put the the ARD performing that all change service in a an awkward position of having to bring some of the customer into the office write up an estimate for something they had known they didn’t hadn’t even had a chance to look at but with with respect to the condition and the kinds of fluids in the vehicle and from that came up a list of other similar features or pre service inspection procedures done free of charge by many of our operators registers performing oil change services my comments on that section at regulatory relief provision of this proposal with this include are we valid and subsections aids or six under B this would be 33 33 53 estimate work order requirements a and B right Mike Mike Flanagan and rush one higher centers okay I’m number five the checking of tire pressure they thought that perhaps you can check the tire pressure but also you if needed you’re gonna have to maybe inflate it to would it be necessary to also say checking of tire pressure and inflating and them tire if needed just think it’s clearer inflation and deflation yeah perhaps yeah the next one is perhaps adding a new 7 Brian for free les schwab if there’s a bad tire they said well we just want us to put on the spare and the person will say yeah I can’t afford a new tire now so they’ll take off the bad tire stick it in the trunk and put on a spare so we’re thinking maybe something about replacing a tire with the vehicles spare tire it’s just a service that’s currently done for free that’s on now since they took a look at this now I’m going to jump a little bit here let’s go back to 3303 they just were curious about number two does anybody really change transmission fluid at roadside or anything like that where did how did that originate some song system wrecked an existing exemption yeah wonder how it started somewhere back in the old days perhaps Precambrian Model T Ford wait a second the act didn’t come into being into it 74 yeah I came about the late 90s if it would followed the history of it and we actually had to do some research of it on our own this is Pat a chief of the Bureau came about when there was an effort to mobilize tests only smokecheck providers quite honestly that’s when there was a move on the part of the state to enhance its smog program and it was a requirement to separate testing from repair all in response to federal EPA requirements and and I think they were at the time I was around them but I don’t have that that good of memory on some of this but there was some work with the smog check industry which were all test and repair providers at the time to kind of to move some of those providers more focused on the inspection side of the business as opposed to the repair side of the business that they would drop that repairs license to become licensed as test only providers if they had other services that they could do that could be wanted qualified as non repair so transmission fluid change and there’s a description of what that means in where it says transmission fluid change means changing the transmission fluid without removing the transmission pan or changing the transmission filter and that was done in the late 90s around 97 98 and in 97 and it was again to loud test only small check providers an opportunity to do something that could not be qualified as repair they were just curious yeah then our last issue they asked if I’d be so lucky to ask another question [Music] there are a number of clients that Rob has that our commercial accounts and everything that they’ll provide us in contract ok so they’re assumption is that that’s a whole different ballgame because you have an existing contract similar like triple-a has with its clients those clients have been a contract with an insurance company and they’re gonna provide so much service and so they’re in a commercial setting where you have a contract for services and they just want to make sure that that that that business is really kind of outside of this or doesn’t get included Brian or how would how does all this affect existing commercial or future commercial service contracts Oh point one D which is the statute or I’m sorry he is an echo that’s a statutory definition of repair of Motor Vehicles and excludes those repairs me pursuant to a commercial business reason Oh beautiful but section was adding him DMP code yeah that’s a PPC section nine eight eight zero point one e as a deco term was that thirty nine eighty eight no nine eight eight zero of one more gotcha subdivision of the business of business code that’s pretty right on thank you very much that’s sorrow that’s oh yeah Jack yeah Jack hold on again so exceptions you got a and B B is the pre-existing and pre-existing or not pre-existing but pre-inspection pre-service inspections and we had a workshop on those and we talked about that and the the need for it was and the downside was the consumer doesn’t pay anything it was free it’s a free service so there wasn’t gonna be much risk there if they didn’t they just gave a verbal authorization now a is pretty significant change because now the way I understand it is that if someone posts and a conspicuous some prices the consumer can pick and choose and that can be all done I mean if it’s limited to the engine oil and filter to a verbal authorization so you’re gonna get into a he said she said thing potentially one of the questions that came up is that the existing a or DS do provide an estimate for all these other services so if a customer comes in and they want to oil change and they want a brake job say let’s just use those two examples so in that scenario in theory the way you’ve got it written they can right enough for the brake job but they don’t need to write it up for the oil change right I mean that’s that creates a potential May night I guess by default I would recommend they’d have to write it all up if they’re doing two jobs because otherwise you’re gonna have it you know an estimate for a great job and a verbal on an oil change that doesn’t make much sense that way have you guys talked about that and how you envision that occurring because I could see some confusion or some potential issues with that issue I would throw it to Brian well I guess maybe there’s a way to address it I don’t I haven’t kind of catch me on the fly here is just if they came in for an oil change I think this is what we were thinking if they came in for something else and an oil change maybe your comment makes sense to maybe maybe not treat that the same I don’t know I’m just kind of thinking about it I think we were thinking that they come in for an oil change that’s the stated purpose not for a laundry list of services I think that would the least of which would include an oil change they might have other services that they’re providing I would think and you’ve kind of alluded to it that it would make sense to write it all up yeah that’s what I would recommend but again I didn’t know I just wanted to vet it out a little bit hear how it would work in practice here because the last thing that you know my folks want complaints here you know right I mean and then you get a complaint at vieira says well you didn’t write this up you didn’t write this up and they just want so well look at the language and maybe there’s a way to kind of explicitly treat it as the former of the two examples that I raised the one where you’re coming in just for an oil change yeah and I know that I noticed there was no cap in terms of the prices cuz you know there’s going to be and you’ve got oil change but some you know with some of these exotic vehicles from these vehicles you’ve got synthetic fluid it’s not a 2990 it could be 69 79 even higher depending on the vehicle – so there isn’t really any kind of cap here and it does become he said she said thing that I potentially here and I just curious from the enforcement standpoint how is that gonna just working it through how is that going to work so so let’s just say you know customer comes in says yeah I saw on the board I wanted this and they you know I wanted this with the synthetic and then they say no it was something different how how’re the ard is going to be able to defend themselves in front of a VAR representative when they’re there is it how is that how do you envision that going because a lot of this is going to be verbal now and nothing at riding anyone in the room no I don’t know we haven’t worked at any of this through at this point yeah obviously we had in regards to this was that’s you know you have that signage in your facility and for oil changes you’re not breaking out it’s not annoying as one price for the materials and then there’s a separate charge for the labors left with a brake job would be so come the board or whatever the signage would in effect be the estimate that would be the written estimate and then because it’s an all-inclusive price and then if you are going to add you know additional quarts of oil you know for the different levels of oil you know synthetic replied would be you know you could put those prices on there and then that would function as the the the real estimate so then you could provide that to the customer utilizing that identifying this is what you know this these are the prices this is your total and then they could authorize that and it wouldn’t have to be written because it’s all up on the board you know the situations where there’s more to it you know the years you know with exotic vehicles if there’s no special things you need to do it’s going to push the price up and it’s not on the board then yes you would have to revert to the standard estimate requirement to provide them with a written estimate for that so do I hear you right by the Sam selling so hearing you right there is if I have a statement they’re $39.99 oil change and there is any variance from that extra quarts of oil synthetic oil or any item that’s not listed on the board you fought over the original contract yes okay that that was I mean that’s was how we kind of talked it over but in terms of I mean the final product I don’t want to say you know what I don’t want to pigeonhole ourselves so to speak and say this is you know this is exactly the way it would be but I mean that’s the way we envision it like so if you had you know if you need an item you know like my vehicle needs five quarts of oil so they always charge me for an extra core but if it’s on there you know an extra quart of oil is X dollars then you could identify it means it was an idea to pigeonhole in anyway sense but it is just clarification that was the whole idea following your train of clarification yeah and if we maybe come back we go written that’s about it yeah cuz I’m just trying to envision how this plays out because I know you don’t regulate the unlicensed the you know how that you know what the issues are but if I come in as a consumer and I point to the you know 39.95 and and then the person across the desk assumes that you know there’s this an assumption there’s five courts there they may need an extra court like you mentioned with your car what happens then I mean to you oh well it’s thirty nine ninety five but you know we didn’t know you need another course so that’s extra now just I can see that can generate some complaints right I mean you know they’re gonna say we’ll wait a minute he told me thirty nine ninety five now he says they didn’t know it needed an extra court maybe you know a particular vehicle how that would play out those are the kinds of questions that I’m asking since we’re here in a workshop how how would it play out yeah I think if it’s up there on the board there’s some loose someone said it’s like ordering a pizza you go in and order the one item pizza you know what the price is you know what it is for two items you know you know you know what it is car because you know well we’re just talking about in the courts your normal and then we have one others special oil whatever this and they manufacture sevens and harmonies we’ve got all these products and people offer them I think the intent the signage should have all the disclaimers and there should be communication between the customer and the ARD exactly what they’re getting I you but I think what his point is at what moment does it go from wearable to written well based on the language in the Reg if they’re just doing the oil change they can do that without a written estimate once they get something outside of the oil filter will change or 39.99 is four four quarts of oil and filter change and it does not require a written estimate we are saying is if there’s an extra port or needed and that is not listed on the board does it go to Britain it’s a yes now that point you would because it’s not listed on our list if that synthetic one is 160 9.99 does it go to British it seems like it would in that kind in that case yeah and then that would follow track I’d be extra pepperoni we now want to come that came from someone in the industry so I was on my analogy I was sharing it we’re making an assumption the sign is just going to have one generic price with one kind of oil if the shop offers synthetic synthetic len or different packages they should include that on the signage and then the customer will agree to it based on their par if they don’t know how much corn oil the car holds they maybe should figure that out don’t think it’s going to lend itself to more complaints than we currently have I mean that that’s the same stuff we could potentially be dealing with today under our current written estimate requirements commenter someone coming to the table from the oil change and then when the oil change is done they say they disagree and they didn’t sign for that and so to assume that an oil change is something that everybody just understands and we I think Scottie said earlier that you know we do it often right you know but but vehicles change the requirements change this conversation is a real conversation index of you know for General Motors these are concerns and these are concerns for us is that we want to be able to make sure that we are abiding by the regulation but we also want to make sure that other companies are as well and then we’re all under the sink you know same rules so to speak and I do believe that this this is written here it’s very controversial for customers I personally hold the position of customer experience manager for our franchise we have we about 450,000 whoa changes a year and I can tell you firsthand that this is a concern for us well I guess one thing we would like to point out is these are you don’t have it’s not a requirement that you not generate an estimate if you feel that it’s best to do that then for oil change then about there is no prohibition against generate an estimate either for the loyal the lubrication engine oil filter services or for the pre service inspection procedures that’s great however but what that doesn’t do is protect the consumer at all and and it does certainly doesn’t protect the business so if I choose not to or of another company not too it certainly doesn’t put us in the same playing field and and what it does is is from an industry standpoint which I’ve been in for 25 years is that it doesn’t make us look look good it puts different standards for different brands out there thank you for the comment are there are other comments Sergi anyone on the webcast okay that’s again that addresses bar meeting at DC AC a govt for anyone listening in on the on the webcast no one else I guess for a good alright we will adjourn the workshop it is now 11:50 a.m. thank you all for attending it’s very helpful and good seeing everyone here at events like this will continue to hold workshops as we develop proposals that we want feedback on what we’re always going to want feedback some of them are probably less controversial and do not require a workshop but most of our regulatory matters will will be scheduling workshops for to get input on prior to part of submitting them to our department for review and then ultimately before filing them with the Office of Administrative Law oal so thank you very much for your attendance and we look forward to seeing you at the next one thank you you


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