By Robert L. Redding, Jr.
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ASA supports the EPA's service information proposed rule. But ASA has suggested some changes it believes will enhance the new rule. Moreover, if the rule is not enforced, it will not be effective.
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The U.S. Environmental Protection Agency (EPA) published its proposed on-board diagnostic service information rule June 8, 2001. Then, the EPA held a public hearing in Ann Arbor, Mich., July 25 to receive oral testimony on the rule. Bill Haas, the Automotive Service Association's Mechanical Division manager, testified at the public hearing. And ASA submitted formal comments to the EPA Aug. 27.
The EPA's first service information rule was finalized August 1995. At the time, the EPA had made a formal presentation about FedWorld and information availability at an ASA Congress of Automotive Repair and Service (CARS) meeting in Las Vegas. The rule also contained a substantial amount of language concerning establishing a reasonable cost for this information. Unfortunately, FedWorld was not successful and the issue of “reasonable cost” has yet to be resolved.
At ASA's 1997 Annual Convention, leaders discussed the possibility of a second service information rule with the EPA. Since that time the National Service Information Task Force has been established. Its purpose is to develop an industry solution to the service information problem. Its membership includes independent repairers, new car dealers and the original equipment manufacturers (OEMs). Reps. Joe Barton, R-Texas, and Edolphus Towns, D-N.Y., have also introduced The Motor Vehicle Owner's Right to Repair Act of 2001. Although ASA believes these are positive steps toward assuring adequate information for independents to repair vehicles, clearly the issue has not been resolved to date.
The EPA's service information proposal takes the industry in a more formal manner to the halfway point of resolution. If this rule becomes final in its current form and is enforced by the EPA, it should leave only the non-emissions issue for the aftermarket to pursue. ASA supports the EPA's service information proposed rule. The following are some of the comments on suggested changes that ASA believes will enhance the new rule. At the onset, the final rule must provide the administrator with sufficient flexibility to prepare for even more advanced vehicle technologies and information dissemination systems. This rule should not have to be revisited.
Three overriding themes run throughout ASA's oral and written comments:
- Will the Web sites be user-friendly?
- Will the access costs be reasonable?
- Will the rule be enforced?
Information needed to start the vehicle if it is equipped with “an anti-theft system or other systems” is important, but only of value if the OEM provides it in a timely manner. ASA believes this time period must be mandated by the EPA in the regulation. ASA requested a mandatory “same-day-as-the-repair” response be included in the final service information regulation.
ASA believes the training provision is a major step for our industry. The present-day methods of obtaining adequate training are no longer viable. If independents are unable to obtain the most current and innovative training opportunities, they will not remain competitive and will provide an inadequate transition to OBD II inspection and maintenance programs. ASA is already participating in the EPA's On-Board Diagnostics Stakeholder Workgroup. Part of the mission of this group is to provide “education and support to the repair and inspections and maintenance (I/M) testing community.” Without training, the program may have a worse future than I/M programs faced after the 1990 Clean Air Act Amendments.
The method of information dissemination will be closely monitored after the finalization of this rule. Although many of the OEM Web sites are being showcased in various forums across the country, the jury is still out on how easy the sites will be to use as information sources and - of equal importance - how expensive their structure will be. Clearly these higher costs are pushing our industry to more specialization but at least in one OEM case, the cost structure for both emissions and non-emissions information will eliminate that make of vehicle from even the independent specialist.
Many mechanical repairers are not connected to the World Wide Web at present. These new information avenues will force these shop owners to purchase new computer equipment and Internet connection services. Accurate information as to hardware and software needs will be an early, critical piece of this regulation. The OEMs must be held to strict guidelines in providing information for new computer users with reference to the needs for their particular Web site.
The Automotive Service Association also encouraged the EPA to tighten its language concerning third party information providers. The EPA is reminded that this rule only applies to emissions information. Even if these sites proved to eliminate the need for third party providers, it does not assure any additional resource for non-emissions information. If third party providers are impacted economically, it could diminish the resources the aftermarket needs to survive from a broader perspective.
ASA suggested to the EPA a “fair and reasonable cost” structure and reminded the agency that these new costs for the independents will be in addition to what we are paying for non-emissions information.
At the public hearing and in the comments, ASA stressed the continuing difficulty of acquiring some OEM tools. ASA is hopeful that the EPA will better police this part of the information dilemma.
Finally, if the rule is not enforced, it will not be effective. ASA and other members of the aftermarket must continue to provide the EPA information as to what parts of this new information system are effective and those that are not.
