HB 3297 & SB 2102 Implementation & Vehicle I/M Program Updates - Rule Project Number 2024-013-114-AI

Comment From: Gary Hartig

7/29/24 @ 3:15 PM

I do believe the inspection fee should go up to $28.50, the price for inspections have not gone up since they started program. Inflation has grown, labor costs have grown and rents have grown, increase fee will will help shots stay open. If these are...↓

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Comment From: Jose Garcia

7/29/24 @ 2:59 PM

The state of Texas has been raising the licensing fees. The state of Texas has been dramatically raising property taxes fees. Our local government can not control inflation. TECQ is very well aware that fees must increase. Do your job.

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Comment From: Brandi Bird

7/29/24 @ 2:37 PM

I want to commend TCEQ staff for the proposed rulemaking and for taking comment on raising the emissions inspection fee up to $28.50. It's very important for the public to understand that the emissions inspection program is an opt-in program provid...↓

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Comment From: Javier Jaimes

7/29/24 @ 10:36 AM

I'm in favor to increase the emissions fee, cost for maintenance and repair on our analyzer is expensive and also supplies like paper and ink.

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Comment From: ALEX PINEDA

7/29/24 @ 9:03 AM

WE NEED $39.99 EMISSION PRICE TO COVER PHONE CALL, PAPER, TONER, LABOR AND STATE MACHINE MAITENANCE OR PAYMENTS.

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Comment From: Amir Mirza

7/29/24 @ 7:32 AM

18.50 obd2 emissions fee for the DFW Metroplex and the Greater Houston Area was established in 2001, and was negotiated together with the $7.00 safety inspection fee for a combined fee of $25.50. According to the bureau of labor statistics and using ...↓their CPI Inflation Calculator, $18.50 in April of 2001 would be worth $32.86 today in 2024, and the combined $25.50 fee would be worth $45.29. The costs of operating an inspection station- rent, property taxes, electricity, insurance, supplies and labor have all risen significantly in the past 23 years, and never more dramatically than in the last 3 years.
The opportunity cost of utilizing an automotive oil change or repair bay to perform emissions inspections has never been higher. This is driving many stations to reduce the hours that they offer inspections or drop out completely.
For inspection only facilities the situation is even more dire. With continued increases in all the above mentioned expenses, and a revenue line that has not changed in 20+ years, survival is growing harder by the day. If the fee structure is not sufficient to support these inspection only stations, there will likely be nobody willing to dedicate the resources to pick up that additional inspection volume, and the problem many motorist are facing in the Austin area will become a statewide problem for all counties under the emissions testing mandate.
The not to exceed $28.50 pricing concept would create more competition and would likely encourage more new inspection stations to open and more existing stations to add additional machines and inspectors. In a busy and hectic world people value their free time more than ever and are increasingly willing to pay more for convenience.
TSIA was involved in the negotiations with the DPS and TCEQ in late 2000 and early 2001. The end result was a net inspection fee to the station of $32.50 for a dyno/safety test and $25.50 for an obd2/safety. The state felt that a 1000 dynos were needed in both DFW and Houston to avoid long lines and extended drive times. With these reasonable fees and some encouragement from TSIA the industry stepped up and delivered and there has never been an issue in DFW or Houston with finding a convenient station or long wait times. I am extremely confident that with a reasonable fee the industry will again deliver and motorists in all emissions counties will have quick and convenient access to an emissions testing facility.

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Comment From: Rafael Gonzslez

7/29/24 @ 6:06 AM

I am in agreement to raise emission fee. You should consider to make all of texas emission county to help mom and pop businesses that are going to closed down this year
Thank you

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Comment From: Michael Reardon

7/28/24 @ 7:07 PM

The current inspection fee was set in 1995. $25.50 is the current fee, $18.50 for emissions and $7.00 for safety. Today's dollars of $18.50 is now worth $38.14. That should be the new fee.

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Comment From: JOE BLANCO

7/28/24 @ 4:51 PM

FIRST OF ALL YOU NEED A COLLEGE COURSE AND AND LAW DEGREE TO UNDERSTAND ALL THE GRAFTS AND RULES SUBMITTED IN THE REPORT WHO HAS THE TIME TO DO SO. THE STATE DOES NOT REALIZE THE THE TIME AND COST EXPENDED WHEN CUSTOMERS FUMBLING TRU THEIR PHONES TO ...↓

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Comment From: Earl Fernandez

7/28/24 @ 11:51 AM

The inspection fees are long overdue for a raise. In fact, I am for Texas, raising the "fixed price" of inspections to $100. This would allow the inspection station's owners and management to determine the appropriate price competition based on their...↓

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Comment From: Greg Cole

7/26/24 @ 5:11 PM

The $18.50 obd2 emissions fee for the DFW Metroplex and the Greater Houston Area was established in 2001, and was negotiated together with the $7.00 safety inspection fee for a combined fee of $25.50. According to the bureau of labor statistics and u...↓sing their CPI Inflation Calculator, $18.50 in April of 2001 would be worth $32.86 today in 2024, and the combined $25.50 fee would be worth $45.29. The costs of operating an inspection station- rent, property taxes, electricity, insurance, supplies and labor have all risen significantly in the past 23 years, and never more dramatically than in the last 3 years.

The opportunity cost of utilizing an automotive oil change or repair bay to perform emissions inspections has never been higher. This is driving many stations to reduce the hours that they offer inspections or drop out completely.

For inspection only facilities the situation is even more dire. With continued increases in all the above mentioned expenses, and a revenue line that has not changed in 20+ years, survival is growing harder by the day. If the fee structure is not sufficient to support these inspection only stations, there will likely be nobody willing to dedicate the resources to pick up that additional inspection volume, and the problem many motorist are facing in the Austin area will become a statewide problem for all counties under the emissions testing mandate.

The not to exceed $28.50 pricing concept would create more competition and would likely encourage more new inspection stations to open and more existing stations to add additional machines and inspectors. In a busy and hectic world people value their free time more than ever and are increasingly willing to pay more for convenience.

TSIA was involved in the negotiations with the DPS and TCEQ in late 2000 and early 2001. The end result was a net inspection fee to the station of $32.50 for a dyno/safety test and $25.50 for an obd2/safety. The state felt that a 1000 dynos were needed in both DFW and Houston to avoid long lines and extended drive times. With these reasonable fees and some encouragement from TSIA the industry stepped up and delivered and there has never been an issue in DFW or Houston with finding a convenient station or long wait times. I am extremely confident that with a reasonable fee the industry will again deliver and motorists in all emissions counties will have quick and convenient access to an emissions testing facility.

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Comment From: Maleah Forbes

7/26/24 @ 12:51 PM

Please keep driving as safe as possible by continuing safety inspections and consider raising the fee so that competent and professional technicians are able to make a living by performing inspections.

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Comment From: Darryl Forbes

7/26/24 @ 12:22 PM

My personal opinion is it should be raised to $39.99 for personal vehicles

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Comment From: Grant Smith

7/26/24 @ 11:40 AM

My name is Grant Smith. We have had an inspection only business since 1985 with multiple locations in the Houston area. It is no secret that labor and operating expenses have increased greatly. We have been asked by some of our customers why we have...↓

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Comment From: john taylor

7/25/24 @ 2:16 PM

increase to 30.00 dollars or at least remain the same.station owners have never had an increase even though everthing has increased

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Comment From: Mona Wakim

7/25/24 @ 12:51 PM

In favor of raising the fee

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Comment From: Kevin Hackler

7/25/24 @ 12:22 PM

Inspection fees have never been equitable to the time required to do one. Unless you're doing inspections only, inspections can be a momentum killer. The state doing away with safety inspections was nothing but a method to reassign the fee, through v...↓

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Comment From: Nigel Saldanha

7/25/24 @ 12:21 PM

Inspection fees have stayed stagnant since I got into the Auto Repair business in 2012. During that time my technician wages have more than tripled, my rent has gone over 25% and so has the cost of my utilities and consumables. I often joke with our ...↓

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Comment From: Frank Jasper

7/25/24 @ 12:17 PM

With little to no increase over many years, there is no use for stations to help the state with keeping the Texas air clean. State does not prioritize the service it seems. There is no incentive to continue. Eventually the state will have to pay to h...↓

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Comment From: david terry

7/25/24 @ 11:46 AM

The cost of living has increased over 26 %. Wages have increased more than that. The emission fee has remained the same. When stations begin to drop the program, the remaining stations will become overloaded.

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Comment From: Kelly Adams

7/25/24 @ 11:34 AM

I do think in order for the shop not to take a huge hit for our time, paying machine fees and repairs on the state equipment the fee should stay the same or be raised.

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Comment From: Nasser Haghighatjoo

7/25/24 @ 11:28 AM

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Comment From: Jack Tomlinson

7/25/24 @ 11:07 AM

if the rate does not change we will no longer be able to perform this service for the state or for customers. due to labor cost and equipment and state guide lines this service must be at 25.00 or higher

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Comment From: ALEX PINEDA

7/25/24 @ 11:06 AM

WE NEED A GOOD BASE EMISSION FEE TO PAY FOR PHONE CALLS, TONER, PAPER, MACHINE MAINTENANCE AND LABOR.

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Comment From: Richard Morin

7/25/24 @ 10:50 AM

I do believe the state inspection price should be raised. If you figure out how much it cost a shop to do one inspection the time of the tech doing it and what you're paying that tech and equipment cost and upkeep is all on the shop. The 25.50 we cha...↓

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Comment From: Zareena Mohiuddin

7/25/24 @ 10:47 AM

I think the state inspection fee is too low to even run a shop. The shop is required to have utilities, payroll for the inspector, rent and maintenance. Therefore I request the authorities to kindly step in and make sure that the price is reasonable ...↓

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Comment From: Antony Sdao

7/25/24 @ 10:38 AM

Given the fact the cost to do business and cost of labor has gone up 10x since when the program came out - Labor rates have gone from 50 per hour to over 200 and techs are double to triple ? Theis should DOUBLE at minimum!

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Comment From: Bill Williams

7/24/24 @ 8:28 PM

I own vehicle inspection stations in the Houston, Harris County area that perform vehicle inspections only. This location does no repairs and no oil changes.

One of my locations is the 3rd highest volume inspection station in Harris County. Based o...↓

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Comment From: WILLIAM SCHWARTZ

7/23/24 @ 10:03 PM

Public Comment of William Schwartz, Owner of Sticker Express LLC

I am a CPA and for over 10 years I have owned a small chain of three inspection only shops in Austin. I am also a Texas State Inspection Association board member. Because of my back...↓ground, I have a lot of insight into the economics of the inspection business.

It has become very hard to get an inspection in Austin because there is an ever growing supply and demand imbalance caused by the inspection price of $18.50 being too low to make inspections a worthwhile business, especially for repair or lube shops. This causes drivers to waste hours calling and visiting multiple places in order to find an inspection. The current rulemaking proposes to set the inspection price at the same inadequate $18.50 statewide. Not only will you perpetuate the growing problem in Austin but you will create a bigger problem in Dallas and Houston where rent is more expensive.

You don't have to believe me though. In preparing this, I discovered several website threads discussing the problem. One is titled "Why are car inspections so impossible to get in Austin?". On these sites and in reviews my customers have posted, drivers are talking about needing 2 days and 5 to 7 stops to find an inspection. Every one of these drivers would gladly pay an extra $7-$10 to avoid this hassle. Also your own surveys done for the last 6 years have called for an inspection price in excess of $22 with the most recent one specifying $28.50.

Still don't believe prices need to increase? Since I am an accountant, let's look at the numbers in the Austin market. Between 2019 and 2023 population growth in Austin was 19%. The number of inspection places doing at least one inspection dropped 12%. The market share of inspection only places like mine rose from 19% to 24% or 382,000 inspections. The numbers make it clear that fewer repair and lube shops are doing inspections and those that remain are cutting back. Auto repair and lube shops are using their space and labor for more profitable services.

The only mitigating factor that will make the business of doing inspections more economical is that in 2025 we will no longer be doing most of what is now considered the safety part of the inspection. Some tasks of the safety inspections are being transferred to the emissions inspection. Unfortunately these economies are very minimal. A portion of the emissions inspection process is time spent waiting for the analyzer (inspection computer) to extract the emissions data from the vehicle and transmit it to the state database. As a result, most of the safety inspection is done while waiting for the analyzer to complete its processes. As we will still have to wait on this process we will be gaining very little time from not doing the safety inspection. I have performed time motion studies in my shops and the reduction in inspection time is about 10%.

At $18.50, I will not be renewing any of my leases. Myself and I suspect all other inspection only places will go out of business in a couple of years. Do you think the repair and lube guys in Austin will be able to absorb 382,000 more inspections when they have already been cutting back? It will be essentially impossible for everyone to get an inspection at that point. The problem will not just be in Austin but also in Dallas, Houston and San Antonio.

Millions of people not being able to get their car inspected or registrations renewed will cause a myriad of other problems. No inspections mean no or delayed vehicle registration fees for the counties/state. It means increased hassle for the police in ticketing cars with expired registrations. It means bad press as the problem grows more acute and drivers grow more frustrated. I could go on but will spare you.

If I learned anything from Econ 101 in college, it is that any price that is not set by the free market will cause some kind of supply and demand imbalance because no regulator is as efficient as the market. Luckily, inspection prices can be set by the market since the rules specify for you to set a maximum price. If you set the price at a maximum of $28.50 you will create a market economy where the supply and demand will naturally be in sync. More inspectors will enter the market and competition will create discounting so the true price for an inspection will be set by the market and the cost of doing business in a particular area. It also gives you about 10 years before inflation necessitates the need to address the fee again.

Please listen to your own survey results and your economics instructors. Set the maximum price at $28.50.

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Comment From: Jamal Seyan

7/23/24 @ 11:02 AM

It's very important to coop the state inception for safety for all

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Comment From: Ryan Evans

7/22/24 @ 11:58 PM

Inspectors will be losing their jobs if we cannot increase the charge for inspections. It's a painful process we are all going through because of the politics behind the safety inspection program removal. I trust the TCEQ will come to a logical concl...↓

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Comment From: Sohail Khan

7/22/24 @ 9:58 PM

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Comment From: Prakash Kanthi

7/21/24 @ 7:56 AM

The inspection test fees should atleast be $50 for it to make it a business worthy solution for inspection station operators.

I can't hire anyone for less than $20/hr and the amount of schedule hazard I go through needs a dedicated service advisor t...↓

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Comment From: Kalen Isas

7/20/24 @ 6:42 PM

The cost of operating continuously goes up, but the fee has stayed the same and now with safety going away, it's going to be even worse on the business owners. The fee should be raised

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Comment From: luis bustillos

7/19/24 @ 12:15 PM

the actual total time that is spent to perform an emissions test from start to finish,and the equipment cost and maintenance fees should be considered for inspection cost on customer.emissions test fee should be a minn of $30.00

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Comment From: BILLY DUETT

7/19/24 @ 10:54 AM

I HAVE BEEN IN THE INSPECTION PROGRAM SINCE IT'S START. THERE HAVE BEEN NO RAISES IN THE FEE AND WITH THE LOSS OF THE SAFETY TEST, I BELEIVE THER WILL BE SIGNIFICANT LOSE OF STATIONS. ONLY BECAUSE AS THE OWNER OF MY BUSSINESS I DO MOST OF THE INSPE...↓

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Comment From: Juan Rivas

7/18/24 @ 6:03 PM

I believe that a raise in what stations can charge would be beneficial to help provide a better paid inspector which would make a better quality experience for your inspection visit, also this would benefit station in keeping their equipment check an...↓

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Comment From: Pierre Elbayeh

7/18/24 @ 5:35 PM

I am an inspection station owner it is very important to keep this program efficient and contibute to the safety of our roads to increase the inspection fees so we can afford good inspectos and to meet the rise of the cost of living. It is very hard...↓

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Comment From: Greg Lambert

7/18/24 @ 4:31 PM

hays county seems clueless on this subject,San Marcos is the city that should be looking into the matter,with students there are 120,000 people in this small town

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Comment From: Jenni Carter

7/18/24 @ 12:02 PM

My company has been doing inspections since 2005. During this time I have watched property taxes rise, insurance premiums sky rocket, hourly rates to pay our inspectors have tripled, even the cost of a pack of paper has doubled. Not once since I have...↓

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Comment From: James Goff

7/18/24 @ 11:53 AM

As a station owner, I strongly encourage lawmakers to allow us to increase the price of emissions testing. There has not been a price increase since I entered this business in 2016, but the cost of the machines, repair and maintenance, paper, ink an...↓

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Comment From: Deanne Soulis

7/16/24 @ 4:47 PM

This comment is in reference to the$10.00 inspection fee increase resulting in a total fee of 28.50.

The cost to run an inspection only Station has increased measurable over the last 20 years, but the last 3.5 years has many stations in desperate ne...↓

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Comment From: Scott Palmer

7/11/24 @ 9:35 AM

Texas has never raised emission inspection fees, but cost to inspection facilities have skyrocketed. Increased labor cost, internet cost, lease cost, mortgage interest rates, property taxes and electric rates all contribute to increased cost to perfo...↓

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Comment From: steven yarbrough

7/10/24 @ 9:05 AM

i feel the fees should be raised to help shop owners maintain the machines that they have to obtain to be able to do a state inspection.

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Comment From: Johnny Sutton

7/10/24 @ 8:28 AM

My son and I ran an inspection station, JackRabbit Inspections for over a year and we enjoyed the work and the clients. However, the pay was not sufficient to stay in business. I think the amount of money paid for inspections should be valued much ...↓

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Comment From: Kalen Isas

7/10/24 @ 1:00 AM

Everything has gone up in price, state fees, machine cost, utilities, rent, compensation, etc. but the fee has stayed the same. It's time for the fee to be at least $30.

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Comment From: Rupert Torres

7/09/24 @ 8:35 PM

It is very important and tremendous need to increase the Emission Test fee. Inflation is going from bad to worst. All the prices to run a shop have gone up, including rent, paper, ink, wages, analyzer parts, analyzer service fees, internet, etc. The ...↓

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Comment From: ALEX PINEDA

7/09/24 @ 6:24 PM

WE NEED HIGHER FEES SO WE CAN MAINTAIN THE MACHINE, PAPER, TONER, PHONE CALLS PER VEHICLE AND TECHNICIAN LABOR. THANK YOU, ALEX PINEDA tiretuneandbrakemasters.com

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Comment From: Craig Zale

7/09/24 @ 2:26 PM

My comments are two part,
1. Removing the safety inspections seems counterproductive for safer highways. More bald tires, poor lighting from non working safety lights,worn wipers causing a loss of visibility during less safe driving conditions. Someo...↓

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Comment From: Hyun Choi

7/09/24 @ 1:42 PM

Costs are rising across the board, including labor, insurance, and overhead. This necessitates an increase in the emissions fee.

We should consider raising the fee back to $39.75, the level it was before the two-step, one-sticker program. It's chal...↓

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Comment From: Sal Elissa

7/09/24 @ 1:31 PM

In our small shop we do about 4500 inspection a year that is about $31k less. Can't afford a good inspector and machine running cost and maintenance. Fee has to go up.

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Comment From: Troy Strege

7/09/24 @ 1:27 PM

I feel the safety part of the inspection is more critical then emissions side of things. Also with the increase of the monthly lease of the machine has gone up employee wages has increased but not the price of the state inspections. No real reward ...↓

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Comment From: Brandon Murphy

7/09/24 @ 12:26 PM

My small shop does roughly 5,800 inspections in a year. I employ a full time inspector to meet that demand. The reduction from $25.50 to $18.50 is approximately a $40,000 loss. That loss almost eliminates that full time inspectors salary. The job sti...↓

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Comment From: LEWIS CLARK

7/09/24 @ 12:19 PM

I think a fair price would be at $25 for emissions. We would be doing a diagnostic check for the customer. It would also be affordable for employment.

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Comment From: Danny Mickan

7/08/24 @ 2:25 PM

I feel the emission test fee should be set to $28.50. This is a fair amount that would allow emission inspection stations to make a fair profit. This would also allow for inspectors to spend more time with customers who have questions or fail the tes...↓

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Comment From: Arun Balakrishnan

6/28/24 @ 9:32 AM

As an employer of multiple inspection stations across the state it is important part of our business, and with the ever increasing number of unregistered and costs of labor increasing the costs helps keep us afloat.

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Comment From: JoJo Heselmeyer

6/24/24 @ 11:05 PM

Attached you will find an excerpt from the 2024 Fee Analysis Study regarding the break-even cost model. In this cost model it highlights the inadequacy of the current fee. As an example, the percentage of stations above break even (including equipm...↓

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Comment From: Zain Islam

6/24/24 @ 6:06 PM

inspection price needs to be increased to at least $50 so that station owners can afford the overhead expenses and labor cost. We won't survive if they take away the $7 safety test fee.

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Comment From: Ross Newberry

6/24/24 @ 7:45 AM

After robbing small business of the measly $7.00 made off safety inspections, and robbing EVERYONE of their basic right to safety, I would highly suggest raising the remaining emissions fee by at least $12 if you want to have any shops continue perfo...↓

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Comment From: yolanda clem

6/24/24 @ 7:44 AM

Inspection fee has remained unchanged since 2005. A rate increase to at least $26 is justified for the service providers to retain certified inspectors. Labor costs have doubled in the last 10 years. Also, material and overhead have increased signifi...↓

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Comment From: Anonymous Anonymous

6/22/24 @ 8:47 AM

The community is already struggling enough without the state implementing higher fees to line their own pockets. Then you turn around and get rid of the most important part of the test which ensures safe vehicles on the roadway. The emissions test li...↓

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Comment From: Nauman Amin

6/21/24 @ 8:46 PM

Current inspection fee is a joke. It should be increased to $50 at least.

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Comment From: Jimmie Moten

6/21/24 @ 3:41 PM

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Comment From: J Vaquera

6/21/24 @ 3:38 PM

Emission prices do need to be raised to cover the increase cost of the machine/maintence, labor, and supplies.

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Comment From: TIRE TUNE AND BRAKE MASTERS

6/21/24 @ 2:48 PM

WE NEED TO RAISE THE EMISSION TEST TO COVER ALL MACHINE EQUIPMENT, MAINTENANCE, SUPPLIES AND LABOR.

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Comment From: Saady Hussain

6/21/24 @ 2:26 PM

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Comment From: Fidel Elkabchi

6/21/24 @ 2:16 PM

Hello My Name Is Fidel Elkabchi and I'm the owner of Pit Stop Lube Centers. If nothing is done to raise the price of Emmisions we will be looking at closing our shops that have been open for 25 years due to the fact of lost revenue. We can not soak u...↓

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Comment From: Saady Hussain

6/21/24 @ 2:05 PM

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Comment From: steven yarbrough

6/21/24 @ 1:46 PM

rates on emmision test should be raised as for the cost of everything goes up it is time for this to go up we have to maintain the machines and make sure they work properly so we should be able to charge more to help with that

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Comment From: Saleem Zazay

6/21/24 @ 1:30 PM

I support raising the emissions inspection fee. With rising costs for equipment, rent, utilities, and wages, it has become very difficult for my business to stay afloat. It's about time to adjust the fee to reflect these increased expenses and ensure...↓

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Comment From: Mustafa Shabak

6/21/24 @ 1:22 PM

I support raising the emissions inspection fees to $40 per inspection. These fees have never been increased, and it's overdue. In today's world, we face rising costs across the board, and this should be treated the same. Inspection stations have face...↓

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Comment From: sabry Ayoub

6/21/24 @ 12:42 PM

We medd to increase the feed due to current inflation rate which reflected on increase utility expenses , lease and labor rate

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Comment From: Javaid Ahmad

6/21/24 @ 12:39 PM

The inspection fee is totally unrealistic. The cost of labor, utilities, rent and overhead has gone up significantly. It is extremely difficult to find licensed inspectors to work for even20./hr. Also eliminating safety inspections was a bad decisio...↓

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Comment From: Connie Gomez

6/21/24 @ 12:21 PM

I am been doing state inspections for almost 18 years and can't imagine not raising cost of emissions inspection so I can pay for the two computers I lease plus GDIM fees.
There's no way my company will survive

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Comment From: Serena Saul

6/21/24 @ 12:20 PM

I feel the inspection fee needs to be raised and I also feel we do not need to do away with safety I recently was hit by someone with no brakes . This is going to be a lot worse once safety goes away I feel safety is for every person on the road and ...↓

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Comment From: Chris Prokopeas

6/21/24 @ 12:17 PM

I would like TCEQ to consider raising the emission inspection fees because of increased labor costs, maintenance costs, testing equipment costs, and building costs.

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Comment From: JAMES FREEMAN

6/21/24 @ 12:08 PM

THE PRICE OF INSPECTIONS NEED TO BE RAISED TO REFLECT THE EVERY GROWING INCREASED COST OF BUSINESS. THE COST INCLUDE HIGHER EMPLOYEE COST, HIGHER OPERATING COST AND HIGHER WARRANTY COST.

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