BILL ANALYSIS                                                                                                                                                                                                    

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          Date of Hearing:  June 14, 2016


                                   Ed Chau, Chair

          778 (Allen) - As Amended June 9, 2016

          SENATE VOTE:  22-12

          SUBJECT:  Automotive repair:  oil changes:  notification to  

          SUMMARY:  Requires oil change shops to register as Automotive  
          Repair Dealers (ARDs) with the Department of Consumer Affairs'  
          Bureau of Automotive Repair (BAR), and further requires ARDs  
          that recommend to consumers the date or mileage for the next oil  
          change to follow the oil drain interval specified in the vehicle  
          manufacturer's published maintenance schedule, with certain  
          exceptions.  Specifically, this bill: 

          1)Deletes oil replacement and vehicle lubrication from the list  
            of vehicle maintenance services that are excluded from the  
            definitions of "repair of motor vehicles" and "automotive  
            technician" so that oil replacement and vehicle lubrication  
            are considered a "repair" under current law. 

          2)Requires oil change shops to register as ARDs with BAR, as a  
            practical result of redefining oil replacement and vehicle  
            lubrication as vehicle "repairs." 


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          3)Requires an ARD that performs an oil change and recommends a  
            date or mileage for an oil drain interval to follow the  
            vehicle manufacturer published maintenance schedule.

          4)Allows an ARD to make a recommendation that deviates from the  
            published maintenance schedule if the ARD notes the basis for  
            the deviation on the final invoice or a document attached to  
            the invoice.  

          5)Specifies that the bill does not prohibit a customer from  
            selecting an oil change interval of their own choice. 

          6)Defines the terms "recommended" and "recommendation" to mean  
            any written recommendation including, but not limited to, a  
            window sticker, a key tag, or by programming the settings in  
            the vehicle's oil life indicator, but clarifies that resetting  
            a preset or nonprogrammable oil life indicator or monitor does  
            not constitute a "recommendation."

          7)Requires an ARD that performs an oil change to include the  
            following statutory disclosure on the final invoice or  
            document attached to the final invoice:  "It is important to  
            change your oil at the proper intervals. Your vehicle  
            manufacturer publishes oil change intervals in your owner's  
            manual and on the manufacturer's website."

          8)Makes legislative findings and declarations of legislative  


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            intent regarding the environmental protection and consumer  
            protection benefits of these provisions. 

          EXISTING LAW:  

          1) Establishes the Automotive Repair Act (ARA) and BAR under the  
             supervision and control of the Director of the Department of  
             Consumer Affairs (DCA) for the purpose of regulating the  
             business of automotive repair. (Business and Professions Code  
             (BPC) Section 9880, et seq.)

          2) Defines an "automotive repair dealer" (ARD) as "a person who,  
             for compensation, engages in the business of repairing or  
             diagnosing malfunctions of motor vehicles."  (BPC 9880.1(a))

          3) Defines the "repair of motor vehicles" to mean "all  
             maintenance of, and repairs to, motor vehicles," except the  

             a)   Repairing tires; 

             b)   Changing tires; 


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             c)   Lubricating vehicles; 

             d)   Installing light bulbs, batteries, windshield wiper  
               blades, and other minor accessories; 

             e)   Cleaning, adjusting, and replacing spark plugs;

             f)   Replacing fan belts, oil, and air filters; and 

             g)   Other minor services the Director of DCA determines to  
               be customarily performed by a gasoline service station.   
               (BPC 9880.1(e))

          1) Requires ARDs to do all of the following:

             a)   Register with BAR annually, which includes paying a $200  
               annual registration fee per ARD facility location in the  
               state.  (BPC 9884-9884.6, 9886.3);

             b)   Post a sign at each location containing a notice that  
               customers have the right to request and receive any car  
               parts that were replaced as part of the service and the  
               phone number and website address of BAR  (BPC 9884.17);  

             c)   Provide an estimate of parts and labor before performing  
               services  (BPC 9884.9); 

             d)   Provide an invoice after performing services  (BPC  
               9884.8); and


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             e)   Maintain its transaction records for three years.  (BPC  

          2) Requires "auto body repair shops," as defined, to register  
             with BAR using the ARD registration form but indicating that  
             the shop is registering as an "auto body repair shop" not an  
             ARD.  (BPC 9889.51 - 9889.52)
          3) Exempts wholesale parts suppliers from BAR registration, but  
             requires wholesale parts suppliers to provide customers with  
             a "written description of the services to be performed" and a  
             notice to each customer stating that the business is not  
             regulated by BAR and including BAR's toll-free consumer phone  
             number.  (BPC 9880.2(d))

          4) Makes a violation of the ARD provisions of ARA, which include  
             among other things prohibitions on making untrue or  
             misleading statements; committing fraud or gross negligence;  
             and willful disregard for accepted trade standards for good  
             and workmanlike repair; a misdemeanor punishable by a fine of  
             up to $1,000 or six months imprisonment, or both.  (BPC  
             9884.7 and 9889.20)

          5) Authorizes BAR to promulgate regulations and to enforce  
             violations of the ARA against registered and unregistered  
             ARDs by: investigating on its own initiative or in response  
             to a consumer complaint; gathering evidence of violations;  
             suggesting measures to compensate for damages suffered;  
             issuing citations and notices of abatement; pursuing  
             administrative disciplinary proceedings against registered  
             ARDs (and unregistered ARDs who in BAR's opinion should be  
             registered); pursuing disciplinary proceedings against a  
             registered ARDs, including registration denial, suspension,  
             revocation or probation proceedings using the administrative  
             hearing process; pursuing injunctive relief against  
             registered and unregistered ARDs in superior court; and  


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             filing criminal charges with the district attorney or city  
             attorney against a registered or unregistered ARD.  (BPC  
             9882.(a), 9882.5, 9884.7, 9882.12-9882.15, 9884.19, 9884.22)

          6) Gives the Director of DCA the discretion to remove a service  
             designation as "minor" if the Director finds that the service  
             "requires mechanical expertise, has given rise to a high  
             incidence of fraud or deceptive practices or involves a part  
             of the vehicle essential to its safe operation."  (BPC  

          7) Defines "automotive technician" as an "employee of an  
             automotive repair dealer or is that dealer, if the employer  
             or dealer repairs motor vehicles and who for salary or wage  
             performs maintenance, diagnostics, repair, removal, or  
             installation of any integral component parts of an engine,  
             driveline, chassis or body of any vehicle, but excluding  
             repairing tires, changing tires, lubricating vehicles,  
             installing light bulbs, batteries, windshield wiper blades,  
             and other minor accessories; cleaning, replacing fan belts,  
             oil and air filters; and other minor services which the  
             director, by regulation, determines are customarily performed  
             by a gasoline service station."  [Emphasis added]  (BPC  

          FISCAL EFFECT:  According to the Senate Appropriations Committee  
          analysis of a prior (April 20, 2015) version of this bill,  
          "unknown costs, possibly in the hundreds of thousands of  
          dollars, from the General Fund and various special funds for  
          increased automotive oil costs for the state's automotive  



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           1)Purpose of this bill  .  This bill is intended to protect  
            consumers and the environment by ensuring that all drivers  
            receive accurate information about when they need to change  
            the oil in their cars, so they can avoid needless oil changes,  
            save time and money, and reduce oil waste.  The bill would  
            prohibit auto dealers, repair shops, and maintenance shops  
            from using window stickers and other written reminders that  
            recommend oil changes more frequently than the vehicle  
            manufacturer recommends.  This bill is sponsored by  
            Californians Against Waste.

           2)Author's statement  .  According to the author, "For decades,  
            drivers have been told that taking proper care of their  
            vehicle means getting the oil changed every three months or  
            3,000 miles. While this may have been true 30 years ago,  
            advances in motor oil and engine technology have allowed  
            drivers to extend oil change intervals greatly.  Most vehicles  
            built since 2000 call for an oil change at intervals of 7,500  
            [miles] or greater.  Further, many new vehicles require the  
            use [of] high quality motor oil that can last 10,000 or even  
            25,000 miles between changes. 

            "Most busy car owners rarely read their owner's manuals; and  
            therefore, have no idea how often they should change their  
            oil.  They simply follow the windshield reminder sticker,  
            which stubbornly insists on following the outdated 3,000 miles  
            change interval.  In fact, a 2012 survey by CalRecycle  
            indicated almost 10 million Californians change their motor  
            oil every 3,000 miles or less.  This means Californians are  
            unnecessarily wasting money and needlessly wasting oil simply  
            because they are cautiously following the recommendations of  
            their repair dealer.  [This bill] will finally put an end to  
            this wasteful practice by requiring automotive repair dealers  
            to follow the manufacturer's maintenance schedule when  
            recommending how soon to return for the next oil change.


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            "The bill also ensures that all shops that perform oil changes  
            will be regulated by the Bureau of Automotive Repair (BAR),  
            leveling the playing field for millions of small businesses  
            that are currently registered and regulated. This will ensure  
            all shops follow the statutory and regulatory requirements in  
            place to protect customers from fraud and overselling of parts  
            or service."  

           3)Automotive oil changes and recommended change intervals .   
            Changing the oil in a motor vehicle is necessary to protect  
            the engine, keeping vital engine parts well lubricated so that  
            they do not overheat or wear too quickly.  An engine cannot  
            function without it and going too long between oil changes can  
            cause permanent damage to an engine over time.  Depending on  
            the vehicle and the type of oil used, the intervals for  
            required oil changes vary.  Many newer models require an oil  
            change every 5,000 miles and some models require a change  
            every 15,000 miles.

          Oil change information is located in a vehicle owner's manual  
            and many automakers post their manuals online.  In addition,  
            CalRecycle has an easily accessible, interactive webpage where  
            consumers can see how often they should change oil based on  
            the make, model, and year of the car.

            Automaker oil change recommendations differ depending on  
            driving conditions as well as car make, model and year.   
            According to car manufacturers, for driving conditions  
            sometimes called "severe" (e.g. extensive idling or stop and  
            go traffic; extreme weather or humidity; repeated  
            short-distance trips of less than five miles; or towing a  
            trailer or hauling heavy materials), the manufacturer  
            recommends oil should be changed more frequently or at shorter  
            mileage intervals than for conditions considered normal or  

            Some automakers have installed oil life monitors in their  
            vehicles with varying capabilities - the basic versions are  


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            maintenance reminders based on mileage while the more advanced  
            systems take information from various sensors throughout the  
            vehicle and use an algorithm to predict the life of the oil.   
            These systems are calibrated to work with the  
            factory-recommended oil.  Although these systems take the  
            guess work out of knowing when the next oil service should be,  
            many consumers have preconceived notions about oil change  
            intervals, such as all cars need oil changed every 3,000  

           4)Protecting consumers and the environment  .  According to an  
            article published by Edmunds, a web-based automotive  
            information provider, a Jiffy Lube customer who buys high  
            quality oil but follows the window sticker recommendation of  
            "three months or 3,000 miles" would waste $369 and 15.2 quarts  
            of useable oil every year.  Over five years of the car's life  
            and 60,000 miles of driving, this would amount to $1,847 and  
            125 quarts of wasted oil.  ("Stop Changing Your Oil! Breaking  
            the 3,000 Mile Habit" Edmunds, April 23, 2013.)

            While California has a motor oil collection and recycling  
            program, only about half of used oil is recycled.  In February  
            2016, the California Department of Resources Recycling and  
            Recovery (CalRecycle) released a report entitled "Used Oil  
            Life Cycle Assessment Report to the Legislature" which  
            examined the agency's oil recycling program and suggested  
            improvements to decrease the amount of oil negatively  
            impacting the environment. One of the policy recommendations  
            in the report includes "Service stations that change customer  
            oil would be required to indicate the next recommended oil  
            change service based on the manufacturer's recommended drain  
            interval for their particular vehicle (windshield reminder  
            stickers) rather than the typical 3,000 miles."  According to  
            CalRecycle, "Changing motor oil according to the manufacturer  
            specifications would reduce motor-oil demand in California by  
            about 10 million gallons a year."  


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            This bill would adopt CalRecycle's policy recommendation by  
            requiring all car repair and oil change shops to make oil  
            change recommendations based on the manufacturer's published  
            maintenance schedule. Specifically, this bill requires car  
            repair and maintenance shops to make recommendations for oil  
            changes based on the specific vehicle manufacturer's published  
            oil change interval for a given car, rather than using a  
            one-size-fits-all sticker or notice that recommends "three  
            months or 3,000 miles."  If the shop makes a recommendation  
            that deviates from the manufacturer's published schedule, then  
            this bill requires the shop to write basis for that deviation  
            on the customer's invoice, or on a document attached to the  

            The bill also requires shops to educate consumers about the  
            vehicle manufacturer's published intervals by including the  
            following statement on every oil change invoice:  "It is  
            important to change your oil at the proper intervals.  Your  
            vehicle manufacturer publishes oil change intervals in your  
            owner's manual and on the manufacturer's website."

           5)How will this bill be enforced  ?  Under current law, new car  
            dealers as well as independent car dealers that service and  
            repair cars have to register with BAR as ARDs.  However,  
            so-called "oil change shops" that only provide "vehicle  
            maintenance" services, such as oil changes and lubrication, do  
            not have to register as ARDs because the services they provide  
            are not defined as "repairs" in statute - raising the question  
            of how these provisions would be evenly enforced.


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            In response, this bill changes the statutory definitions of  
            "repair" and "automotive technician" to include oil changes  
            and vehicle lubrication, which would effectively require all  
            oil change shops to register with BAR as ARDs and be subject  
            to BAR oversight if this bill becomes law. 

            The author contends that oil change shops should be required  
            to register as ARDs because this gives BAR direct authority to  
            enforce these provisions against all businesses in California  
            that provide oil change services.  The author also argues that  
            this bill ensures an even playing field for all businesses  
            because BAR will have the same enforcement authority against  
            all businesses that change oil in California. 

            Current law allows BAR to investigate and cite registered and  
            unregistered ARDs, pursue administrative remedies such as  
            fines and registration revocation, and file criminal charges  
            in superior court against ARDs.  Current law makes it a  
            misdemeanor for an ARD to violate any of ARA's provisions.   
            Because this bill amends ARA, a violation of this bill would  
            be a misdemeanor.

            Interestingly, ARA specifically prohibits ARDs from making  
            untrue or misleading statements or committing fraud.  Some  
            industry representatives contend that even without this bill,  
            BAR could already pursue an action for making misleading  
            statements or fraud against a registered ARD that places a  
            sticker on every car or prints a notice on every invoice  
            telling consumers to return for service within 3 months or  
            3,000 miles.  

           6)Does this bill step into the debate over whether BAR should  
            regulate car maintenance shops?   In recent years, BAR and the  
            Legislature have grappled with the question of whether vehicle  


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            maintenance services, such as oil changes and tire repairs,  
            should be regulated by BAR.  In its 2014 sunset review  
            hearing, BAR suggested that because of advances in automotive  
            technology, many car maintenance services now require  
            specialized repair skills and may require the removal of  
            automotive systems, engine components, and electrical  

            AB 1665 (Jones) of 2014 would have deleted the repair and  
            changing tires from the list of excluded minor services, but  
            the bill was vetoed by the Governor in order to give BAR the  
            opportunity to include more stakeholder input and decide which  
            other automotive repair services require regulation.  In 2015,  
            BAR held an industry workshop where industry stakeholders and  
            BAR representatives discussed a range of issues including  
            major/minor services, compliance with advertising  
            requirements, and the definition of roadside services.  

            This year the Legislature is also considering AB 873 (Jones),  
            which is sponsored by DCA and currently pending in the Senate  
            Business, Professions and Economic Development Committee.  AB  
            873 requires the Director of DCA to promulgate regulations by  
            2018 that would revise the list of services excluded from the  
            current statutory definition of "repair."  AB 873 would also  
            give DCA the authority to update that list to keep up with  

            This bill proposes changing the definition of "repair" in  
            statute to specifically include oil changes and vehicle  
            lubrication services, so that if this bill were passed and  
            signed, on January 1, 2017, all shops - including oil change  
            shops - would have to comply with the bill and be subject to  
            BAR enforcement actions if they do not. 

            If both AB 873 and this bill are signed into law, DCA could  


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            theoretically adopt regulations that again change the  
            definition of repair to specify that oil changes are "minor"  
            repairs, eliminating the need for oil change shops to be  
            registered with and regulated by BAR.  However, this is  
            unlikely given BAR's suggestion at its sunset review hearing,  
            as noted above, that many services now excluded from the  
            definition of "repair" should be included due to advances in  
            car technology.  

           7)What would the impact of BAR oversight be  ?  Representatives of  
            the oil change industry, who oppose this bill, contend that  
            requiring oil change shops to register with BAR as ARDs is  
            unnecessary and unfair, given that they do not diagnose and  
            repair malfunctioning vehicles, but rather simply provide  
            maintenance services, such as oil changes.  

          Supporters of the bill contend that without BAR oversight and  
            BAR's ability to discipline ARDs through the administrative  
            hearing process, it would be difficult to enforce the  
            provisions of this bill because BAR would have to rely on an  
            overworked city attorney or district attorney to pursue an  
            action in criminal court to enforce these provisions.  Absent  
            egregious circumstances, a violation of this bill likely would  
            not make it to the top of a city attorney's or D.A.'s priority  
            list of cases to pursue. 
           8)Oil change industry arguments against BAR oversight  .  From a  
            business standpoint, oil change industry representatives have  
            underscored that it would be difficult to stay in business if  
            they are required to register as ARDs because profit margins  
            in the industry are very small, approximately 10%.  Similar to  
            some other industries, such as the supermarket industry, the  
                                      oil change industry business model is based on the ability to  
            serve a high volume of consumers at a very small profit  


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          Oil change industry representatives also contend that  
            registration as an ARD would trigger a 40% increase in  
            liability insurance costs alone, due to being officially  
            categorized as a "repair" shop which carries a much higher  
            risk for liability insurance purposes.  

          In addition, the cost of creating new systems to prepare printed  
            estimates of "parts and labor" before each oil or lubrication  
            service, and the cost of annual registration of $200 for each  
            shop location each year, would further reduce already narrow  
            margins, according to industry representatives.
           9)Discussions over the exact form of regulatory oversight may  
            continue  .  In its current version, this bill requires oil  
            change shops to register with BAR as ARDs.  If the bill passes  
            this Committee, it will be heard next in the Assembly Business  
            & Professions Committee, which has been working with BAR and  
            the industry on potentially developing a new regulatory scheme  
            for minor repair and maintenance services.  

          The author's office has stated an interest in continuing the  
            conversation with stakeholders on how best to balance the need  
            to enforce this bill across all businesses that provide oil  
            change services and the potential impact this bill could have  
            if oil change shops in California have to register with BAR as  
            "repair" shops, i.e., ARDs.  One option under consideration is  
            whether a new registration category should be added, so that  
            oil change shops could simply register as "maintenance  
            service" shops rather than ARDs. 

           10)Arguments in support  .  According to the bill's sponsor,  
            Californians Against Waste, "Used motor oil, which is  
            insoluble and contains heavy metals and toxic chemicals, if  
            improperly disposed can enter our oceans and fresh waters via  
            the storm water systems, endangering humans, fish and  
            wildlife.  In addition, one gallon of used motor oil can foul  
            the taste of 1 million gallons of water. This hazardous waste  


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            is also often burned as fuel, creating dangerous air  
            pollution.  While California has a motor oil collection and  
            recycling program, source reduction makes the best  
            environmental and economic sense. In addition to saving  
            consumers money by reducing oil changes, [this bill] will  
            reduce greenhouse gas emissions by reducing our consumption of  

          According to Consumers for Auto Reliability and Safety, "Oil  
            technology has changed enormously over the last 30 years  
            making the 3,000 mile oil change unnecessary in nearly all  
            vehicles. The majority of automakers today call for oil  
            changes at either 7,500 or 10,000 miles, and the interval can  
            go as high as 15,000 miles in some cars. And yet, a 2012  
            survey by CalRecycle indicates almost 10 million Californians  
            change their motor oil every 3,000 miles or less.  It is for  
            this very reason that CalRecycle launched their "Check Your  
            Number" campaign to encourage drivers to rethink their current  
            driving habits and only change the motor oil as needed.  While  
            consumer education is important, many maintenance facilities,  
            including those specializing in oil changes, continue to  
            promote the old standards, perpetuating the myth. It is  
            particularly important that the bill apply equally to  
            currently unlicensed facilities that perform oil changes, and  
            require them to properly register with the Bureau of  
            Automotive Repair, become licensed, and comply with all  
            applicable laws.  Given the stakes involved, ensuring  
            compliance with environmental and consumer protections is  
            important enough to warrant uniform licensing and uniform  
            enforcement of the law."

           11)Arguments in opposition  .  The Automotive Oil Change  
            Association (AOCA), which represents the lube and oil change  
            industry, including 54 California companies at two hundred  
            locations, states that it "must respectfully oppose SB 778  


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            unless amended to protect the existence of true automotive  
            maintenance providers (AMPs) by creating a specific category  
            to distinguish them from repair facilities.  Failure to do so  
            would be catastrophic for AMPs' business model and ultimately  
            result in significant increases in consumer costs and time  
            spent trying to obtain basic preventive automotive maintenance  

            "The current exception for preventative maintenance services,  
            including oil changes, in the Automotive Repair Act of 1971,  
            represents a core principal of that Act, which is to protect  
            and promote consumer access to the preventative maintenance  
            services historically associated with full service gasoline  
            stations at the time the Act was written.  Checking and  
            changing oil was the hallmark of that maintenance category. 

            "Failure to create a separate AMP category will destroy a  
            highly effective business model that provides services  
            consumers need most, faster, in more convenient locations, and  
            at less cost than typical repair industry competitors. In  
            order to accomplish this, AMPs generally operate on a 7-10%  
            profit margin?[P]ushing AMPs to become "automotive repair  
            dealers" would also change their risk category for insurance  
            purposes, raising their total rates up to 40%.
            ?As the name indicates, AMPs do only automotive maintenance  
            services associated with fluid and filter changes, fluid  
            treatments, and belt and windshield wiper blade replacement-a  
            nearly identical category of the core preventative maintenance  
            services originally recognized as deserving exception in the  

           12)Related legislation  .  AB 873 (Jones) deletes the current list  
            of minor repairs exempted from registration with BAR,  


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            effective January 1, 2018, and requires the Director of DCA,  
            prior to January 1, 2018, to adopt regulations defining a new  
            list; excludes propulsive batteries from the current list of  
            minor services; and excludes motor clubs and operators of tow  
            trucks from the definition of roadside services.  AB 873 is  
            currently pending in the Senate Business, Professions and  
            Economic Development Committee.

            AB 1174 (Bonilla) would require BAR to adopt regulations on  
            its complaint, investigation, and mediation process and would  
            require BAR to track and retain data on every mediation  
            attempted and completed for each ARD.  The bill also would  
            require BAR to study the feasibility, effectiveness, and  
            impact of requiring all service workers who are employed by  
            ARDs to be licensed or certified by BAR and report to the  
            Legislature on this by July 1, 2018.  AB 1174 is currently  
            pending in the Senate Business, Professions and Economic  
            Development Committee.

           13)Prior legislation  .  AB 1665 (Jones) of 2014 would have  
            deleted "repairing tires" and "changing tires" from the list  
            of repair services exempt from registration as an automotive  
            repair dealer under the BAR.  It would have also required an  
            ARD to be capable of diagnosing and servicing vehicles, as  
            specified.  AB 1665 was vetoed by Governor Brown.

            SB 202 (Galgiani) of 2013 would have deleted repairing and  
            changing tires from the list of repair services exempt from  
            registration as an automotive repair dealer under the BAR.   
            However, it would have excluded tire services provided by or  
            on behalf of a motor club holding a specified certificate of  
            authority or an operator of a tow truck owned or operated by a  
            person or entity possessing a valid motor carrier permit from  
            the definitions of "repair of motor vehicles" and "automotive  


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            technician."  SB 202 was held in the Assembly Appropriations  

            AB 2065 (Galgiani) of 2012 was similar to SB 202 (Galgiani) of  
            2013. AB 2065 was held in the Assembly Appropriations  

            SB 546 (Lowenthal), Chapter 353, Statutes of 2009, made broad  
            changes to the California Oil Recycling Enhancement Act to  
            encourage the best re-use of used oil and reduce air pollution  
            from the use of used oil, including: raising the fee paid by  
            lubricating oil manufacturers from $0.16 to $0.26 per gallon;  
            increasing the incentives paid for recycling used oil;  
            increasing the testing requirements for used oil transporters;  
            and requiring a life-cycle analysis of used oil.

           14)Double-referral  .  This bill was double-referred to the  
            Assembly Business & Professions Committee, where it will be  
            heard if passed by this Committee. 




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          Californians Against Waste (sponsor)

          Biosynthetic Technologies

          California League of Conservation Voters

          California Product Stewardship Council


          CarMax Auto Superstores

          Clean Water Action

          Consumer Federation of California

          Consumers for Auto Reliability and Safety


          Natural Resources Defense Council

          Sierra Club California

          Solid Waste Association of North America


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          Automotive Oil Change Association (AOCA)

          Auto Care Association

          California Automotive Wholesalers' Association

          Integrated Services, Inc.

          Service Station Dealers of America and Allied Trades

          Tire Industry Association

          802 individuals 

          Analysis Prepared by:Jennie Bretschneider / P. & C.P. / (916)  


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