CAA files official comments on California proposed storage rules
The California Autobody Association (CAA) submitted its official comments to the Bureau of Automotive Repair (BAR) on a proposed storage regulation citing three concerns and possible solutions.
According to the comments, the Bureau’s plans to conduct a survey to set pricing is a regulatory overreach. The association additionally contends that a one-business-day notification requirement is unrealistic for repair businesses and a mandatory three days of free storage exceeds BAR’s authority.
The comments were sent Dec. 17 by CAA and on behalf of other state associations including the Automotive Service Councils of California, the California Automotive Business Coalition and the California Tire Dealers Association.
BAR is collecting public comments on the changes until the end of the year. The bureau has been working on the language for years and has held multiple workshops following the passage of Assembly Bill 1263 in 2023, which granted BAR authority to address the subject.
BAR’s proposed regulation would allow BAR to conduct a survey on storage fees charged by collision shops. The results of the survey would be posted as a search tool on BAR’s website for the public to use.
“This constitutes regulatory overreach and exceeds BAR’s statutory authority, as businesses are generally free to set their own prices,” the CAA comments say. “The concern is heightened because publicly releasing these survey results would effectively influence—or even set—storage rates across the automotive repair industry.”
Setting or influencing prices through public surveys undermines the state’s reliance on market competition to determine rates, the comments add.
“When a regulatory agency publishes pricing benchmarks, even indirectly, businesses may feel compelled to conform to those figures, resulting in de facto price controls. This can artificially suppress or standardize rates in regions with widely varying costs of doing business,” the comments says. “In addition, publicly posting industry rates may inadvertently facilitate price coordination or discourage natural market competition. When businesses know that BAR publishes an “average” rate, they may cluster around that figure to avoid regulatory scrutiny, reducing competitive pricing and raising potential antitrust concerns.”
An alternative would be for BAR to continue conducting informal storage-rate surveys for the purpose of responding to consumer complaints and determining whether individual storage charges are fair and reasonable. However, the information should remain confidential and not be publicly released, CAA’s comments say.
Another portion of the regulation proposes collision shops should notify a customer within one business day that a repair will be declined.
CAA argues that the requirement is unrealistic and may increase operational costs for repair businesses, ultimately leading to higher consumer prices.
“Automotive repair dealers—especially small and medium-sized shops—manage a high volume of vehicles while simultaneously handling diagnostics, repairs, insurance communications, parts sourcing, customer inquiries, and day-to-day administrative tasks,” the comments say.
A 24-hour timetable leaves little time for repair facilities to review the vehicle’s condition, determine repair feasibility, contact the customer or insurer for clarification and document the reasons for declining the repair, CAA comments say.
“This requirement forces repair dealers to reorganize workflow and assign staff solely to monitor incoming vehicles and issue notices,” the comments say. “As a result, shops would face higher labor costs for additional administrative work, and new compliance tracking systems, software, or procedures. These burdens are unnecessary, particularly when the regulation identifies no demonstrated consumer harm that would warrant such an accelerated notification timeline.”
CAA has requested BAR extend the timeframe to a three-business day notification periods. This would reduce the need for constant monitoring of incoming vehicles.
BAR’s proposal also would require shops give customers no less than three business days after completion of the teardown and receipt of the estimate before storage fees would begin.
“This imposes a direct financial burden on automotive repair dealers unrelated to BAR’s statutory purpose,” CAA’s comments state. “BAR’s authority is derived from the Automotive Repair Act. While the Act authorizes BAR to require estimates, disclosures, and repair authorizations, it does not authorize BAR to mandate minimum periods of free storage. Implementing a mandatory free-service requirement crosses into price regulation—a domain that requires explicit legislative authority.”
It adds that storage is a costly service involving property, insurance, security, labor and liability exposure.
“Imposing a blanket three-day free-storage mandate may therefore be considered excessive, or constitutionally problematic,” the comments say. “BAR is exceeding its authority by imposing what is effectively a price control without legislative approval.”
CAA asks that BAR rework the proposal to allow automotive repair dealers to determine how many days, if any, should lapse after completion of the teardown and delivery of the estimate.
“This approach preserves consumer protection while respecting statutory limits and the financial realities faced by repair shops,” the comments say.
To submit a comment to BAR, email Holly Helsing at [email protected] or Tessa Miller at [email protected]. Or send a letter to either of them at the Bureau of Automotive Repair, 10949 North Mather Blvd., Rancho Cordova, California, 95670.
The California Autobody Association is also collecting comments to send to BAR. Any concerns can be emailed to Jack Molodanof at [email protected]
In January 2025 Patrick Dorais, BAR chief, and Mathew Gibson, BAR program manager, gave an overview of the proposed regulations at the Society of Collision Repair Specialists (SCRS) Open Board Meeting. Dorais and colleagues will return to again present during the SCRS Open Meeting in Palm Springs, CA on Tuesday, January 20, 2026. California collision businesses are encouraged to attend
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Photo courtesy of CAA