July 15, 2021
Federal Trade Commission
Office of the Secretary
600 Pennsylvania Avenue NW
Suite CC-5610 (Annex B)
Washington, DC 20580
Re: Proposed FTC Policy Statement on Repair Restrictions
To whom it may concern:
RDO Equipment Co., appreciates the opportunity to provide comment to the Federal Trade Commission (“FTC”) in advance of the Commission’s July 21, 2021, open meeting.
RDO is a 53-year-old, family-owned distributor of agriculture, construction, environmental, irrigation, positioning, and surveying equipment. Based in Fargo, North Dakota, we operate in nine states. Our locations tend to be in rural areas, where we provide
well-paying jobs to more than 2700 employees from Ada, MN to Hermiston, OR to Watsonville, CA.
RDO is concerned with the FTC’s plans to adopt a policy statement on July 21 supporting so-called “right to repair.” In our view, right to repair mandates, as applied to our industry, are a solution in search of a problem because what
is implied in this mandate is already being done.
We currently provide our customers, upon request, with diagnostic information, tools, parts and other means to repair the equipment. However, mandating right to repair could permit the public to have unfettered access to embedded coding in machinery that
is necessary to meet government-mandated safety and environmental standards, inviting tampering of these important functions and endangering equipment operators.
RDO invests significant resources in qualified technicians and training and developing their skill set to repair the equipment’s sophisticated technology and safety features. We employ more than 1500 workers in our service and parts department,
generating significant economic opportunities in rural and agricultural communities.
If the FTC requires unfettered access to the operating software on the products we sell, it will open the door for modification of government-mandated emissions controls, safety measures designed to protect operators and the public, and proprietary machine
operation and performance controls. Customers of heavy machinery do not need this to repair their own equipment, nor are they demanding it. The only reason someone would want this type of access is to circumvent safety and emissions standards.
I wish to thank the FTC for fulfilling its mission to protect consumers particularly regarding safety issues and considering these comments.
Chief Operating Officer