TIA, RMA submit comments on NHTSA proposals
With the deadline to submit comments approaching, both the Tire Industry Association (TIA) and Rubber Manufacturers Association (RMA) let the government know where they stand on its proposed tire fuel efficiency consumer information regulations.
The National Highway Traffic Safety Administration (NHTSA) had given respondents until midnight on Aug. 21, 2009, to respond to its Notice of Proposed Rulemaking (NPRM).
In a letter to NHTSA, TIA Executive Vice President Roy Littlefield outlined why he believed TIA was the best entity to run the agency's proposed national tire maintenance consumer education program.
1. "While NHTSA’s NPRM focuses on a point-of-sale poster to educate consumers about tire fuel efficiency ratings, TIA contends that, based onTIA’s experience representing tire retailers, a poster or pamphlet should be a component, but not the core feature of the campaign."
2. "The Notice does not even mention the dialogue between the salesperson and the consumer as a viable means of education. TIA proposes to bridge this “communication gap” by embarking on a comprehensive course of training to tire sellers, in addition to a massive public outreach campaign in order to keep tire maintenance in consumers’ minds."
3."TIA has a strong, established history of working with the tire manufacturers and other automotive aftermarket groups to develop a consensus on educational efforts."
4. "Under NHTSA’s direct supervision and advisement, TIA would create and implement a program to engage the consumer in person-to-person education from a trained sales force, based on its current training models which are used to educate tire technicians on a variety of maintenance and diagnostic techniques."
(For more information, see "NHTSA lists ideas for consumer education program" at http://www.moderntiredealer.com/News/Story/2009/06/NHTSA-lists-ideas-for-consumer-education-program.aspx.)
According to Littlefield, TIA has "the history, resources and expertise to make this important consumer education effort a success."
"We also have a history of working together with many different aftermarket organizations -- not to mention the tire manufacturers -- to formulate a successful consumer education effort. TIA and its members know consumers and how to reach them. We have the know-how and a long track record of working with, and being supported by the relevant industry representatives."
In its written comments to NHTSA regarding the government's tire fuel efficiency ratings proposal, the RMA said its members believe that to establish "effective consumer information requirements regarding tire efficiency," the program must meet the following criteria:
* Provide information at point of sale;
* Provide meaningful information that is easy to understand by consumers;
* Provide a wide range of tire efficiency choices across the rating scale to each consumer about replacement tire choices appropriate for the consumer’s existing vehicle;
* Be cost effective to minimize the cost effect of this information to consumers.
RMA supports a five category rating system that it says "maximizes the tire efficiency choices across the rating scale."
"Since consumers shopping for replacement tires are limited in their tire selections by requirements of their existing vehicle, it is important to design a rating system that maximizes the tire efficiency choices across the rating scale for each consumer," wrote the RMA. "The appeal of a rating system will depend on whether a consumer has 'good' choices appropriate for his vehicle across the rating scale."
In June, NHTSA proposed a tire fuel efficiency rating system that would be printed on a paper label on every replacement passenger tire sold in the United States. The rating system would rank tire fuel efficiency on a 0-100 point scale. The proposed rule also would rate wet traction capability and tread wear.
(For more information, see "New tire label would include fuel economy info" at http://www.moderntiredealer.com/News/Story/2009/06/New-tire-label-would-include-fuel-economy-info.aspx, and "More on NHTSA's tire fuel efficiency ratings proposal" at http://www.moderntiredealer.com/News/Story/2009/06/Rule-would-force-tiremakers-to-submit-fuel-efficiency-data-to-NHTSA.aspx.)
“The proposed rating scale gives consumers an illusory view of the tire efficiency choices available to them for their vehicle and does not assist consumers in purchasing fuel efficient tires for their vehicle,” the RMA wrote. “On the other hand, this rating approach encourages consumers to purchase smaller tires and could promote the purchase of tires with inadequate load-carrying capacity to safely carry the load of the vehicle.
"Although many tire dealers would discourage and in many cases would not sell a tire with a rated load capacity insufficient for the vehicle, NHTSA should not promote a system that could lead to this type of safety concern.”
RMA said that NHTSA should develop a system that promotes tire efficiency, regardless of vehicle class.
Although RMA is in favor of the provision to create a tire fuel efficiency consumer information program, it expressed opposition to the propose tire rating system label as a means of providing point of sale information to consumers. It proposes that NHTSA "mandate that tire retailers have the rating information available to consumers in the dealer showroom or waiting area," and recommends NHTSA "give tire retailers options for making this information available and require that each retailer choose one or more options that suits their business model and needs.
"Options could include: tire manufacturer brochures, tire manufacturer product catalogues, in-store online access to the NHTSA Web site, tire manufacturer Web sites or the tire retailer’s Web site containing the rating information,” the RMA stated.
NHTSA will review the comments before publishing a response in the Federal Register.