March 24, 2020
Mr. Matt Hayden
Deputy Assistant Secretary, Private Sector Office
Office of Partnership & Engagement
Department of Homeland Security
Mr. Daniel Kroese
Associate Director, National Risk Management Center
Cybersecurity and Infrastructure Security Agency (CISA),
Department of Homeland Security
Dear Mr. Hayden and Mr. Kroese:
On behalf of Cars.com, our 1,500 employees and the 20,000 automobile dealers that we serve, we respectfully request that you clarify that automotive sales and leasing activities are deemed “Essential Businesses.” We appreciate the prior guidance, issued on March 19, 2020, related to the essential nature of automotive service and repair, and agree that those activities are key needs during this time. Under this narrow request, for the reasons set out below, we merely ask that the current guidance related to automotive repair and maintenance facilities be expanded to include sales and leasing of automobiles.
Automobile sales and leases — not just service and repair — are essential to supply chains to ensure that essential and critical entities; federal, state and local governments; hospital and medical workers, first responders; delivery fleets; individual transport; small freight deliveries and all the other activities that DHS, and the state and local governments that have followed its lead, have identified as those “that need to be able to operate resiliently during the COVID-19 pandemic response.” These individuals, businesses and government entities often have the need to replace a vehicle immediately or to add an additional vehicle — needs that cannot be satisfied by simply servicing or repairing an existing vehicle. The National Automobile Dealers Association has estimated that there are approximately 500,000 automotive purchases annually by “Essential Critical Infrastructure Workers,” a number that is bound to increase during the course of this pandemic as public transportation and ride-hailing options become less acceptable or even unavailable.
We cannot express strongly enough the need for federal guidance on this issue. The presence of potentially divergent standards among all 50 states presents inexplicable challenges for the automotive industry and the constituencies we serve. We appreciate the prior guidance, issued on March 19, 2020, declaring the essential nature of automotive service and repair, and agree that those activities continue to be essential, but the current guidance must be expanded to include sales and leasing of automobiles in addition to repairs and service.
We recognize the unprecedented nature of the COVID-19 pandemic and the strain it is placing on our country, its public health resources, businesses of all sizes and the economy as a whole. To that end, we as a company would like to do our part for the nation, consumers and dealers we serve by asking that DHS clarify that automobile dealerships should be permitted to remain operational when “shelter-in-place” or “work-from-home” orders are instituted by jurisdictions across America, which can be done while still honoring all appropriate steps to fight this pandemic properly and aggressively. We believe that sales and leasing activity can take place in full compliance with social distancing and all the best practices designed to minimize the spread of the coronavirus. Digital access to vehicle inventories and specifications has become a key part of motor vehicle purchases with the advancement of the internet and availability of online inventory. We expect this activity to continue. But, due to specific federal, state and local laws requiring in-person contact — like identification verification and “wet signature” requirements — certain limited components of motor vehicle transactions must be done in person, but even those requirements can be fulfilled with appropriate social distancing.
Some states have already put guidelines in place for automobile sales amid social distancing orders including, but not limited to:
- Requiring that sales be by appointment only and limiting the ratio of customers to available salespeople.
- Showrooms restricting entry to anyone not having a scheduled appointment with a salesperson. Anyone not meeting with a salesperson should be asked to wait outside.
- Hand sanitizers and latex gloves should be available within the dealership for those consumers visiting for any reason (sales, parts or service). If any test drives are conducted, vehicles should be cleaned in accordance with guidance provided by the state Department of Transportation.
- The reorganization of service departments should be done to ensure that working technicians can keep a safe social distance from their co-workers. A process should also be developed so that technicians can acquire parts from the parts department while maintaining proper spacing.
- Dealers should determine which departments (if any) would be able to work remotely. If none may work remotely, dealers should consider the possibility of workforce reduction by department in proportion with the reduced number of sales remaining once sales by appointments and adjusted service schedules have been implemented.
- For any transactions utilizing credit card payment, the employee should present a credit card scanner to customer for “swiping” so that the employee does not take physical possession of the credit card.
- Dealership sanitizing procedures should be placed in a visible area of the dealership as a reminder to remaining employees of what is required of them during this time.
Given the foregoing and the goal to avoid spreading COVID-19, we absolutely recognize the need for appropriate modifications to the traditional automobile sales model as indicated above. We feel equally resolute in the notion that automobile sales can and should continue with appropriate modifications as a service to the general public and our communities at large.
We are proud to echo the voices of the National Automobile Dealers Association, National Association of Minority Automobile Dealers, Alliance for Automotive Innovation, American International Automobile Dealers Association and the American Truck Dealers in their letter of March 23, 2020. They similarly asked President Trump for guidance requesting “that the previously issued Guidance by the DHS and CISA be amended to include — and that any future Executive Order issued by you include — the sale or leasing of light-, medium- and heavy-duty vehicles by dealers as an “essential service” that should be permitted during the crisis, provided that the sales are conducted in a safe and sanitary manner that protects the health and safety of the general public and our members’ customers and employees.”
We appreciate your consideration of this request and would be available for further discussion related to this issue at your convenience. You can reach me directly at firstname.lastname@example.org.
Thank you for the endless efforts of you and your team during this unprecedented time in American history.
Alex Vetter, CEO
A NYSE Listed Company