RMA takes wait-and-see stance on Massachusetts low rolling resistance bill

June 16, 2005

The Massachusetts legislature is holding hearings on HB 3314, a state bill that would replicate a measure passed in California in 2003 to create a "tire efficiency program" centered around low rolling resistance requirements.

The Rubber Manufacturers Association (RMA) is asking the legislature to postpone consideration of the House bill for two reasons:

1. California is only at the early stages of the mandated tire testing authorized by Assembly Bill 844, which was signed into law in 2003 (tire testing also is required by the Massachusetts bill).

2. The National Academy of Sciences is also looking at tire rolling resistance issues and the performance trade-offs that come with maximizing lower tire rolling resistance.

"Enacting the legislation now would force Massachusetts to replicate the same testing process that California has begun at a cost of $400,000 to date," says Dan Zielinski, vice president of communications for the RMA. That figure is expected to rise, he added.

In December 2004, the California Energy Commission (CEC), in cooperation with the Integrated Waste Management Board, approved work on a study that will serve as the basis for an eventual tire fuel efficiency reporting system and minimum efficiency standards.

A key concern to both of these agencies is that future fuel economy improvement does not come at the expense of tire life.

The 18-month, $400,000 contract with Smithers Scientific Services Inc. will examine tire characteristics such as longevity, safety and ease of recycling. It also will establish a database of findings.

The study will be the basis for adopting low rolling resistance tire regulations, which will rely heavily on industry and public input. The legislative proceedings are expected to start in July 2006.

California Assembly Bill 844 gave the CEC authority to adopt fuel efficiency labeling and ratings standards for all replacement tires sold in the state beginning in 2008. The law also requires that rolling resistance data be made easily accessible to anyone purchasing tires.

In Massachusetts, a number of tire industry representatives testified against HB 3314 at a June 7 legislative hearing. They included Tracey Norberg, the RMA's vice president for environment and resource recovery; and representatives of the New England Tire and Service Station Association (NETSA), including NETSA President Neil Schlossberg of Myers Tire Supply in Randolph, Mass., and Tony Koles of Montvale Tire in Melrose, Mass.

(The Massachusetts Public Interest Research Group, a consumer watchdog organization, was the only organization to testify in favor of the legislation at the hearing.)

Here is a transcript of Norberg's testimony before the Massachusetts Joint Committee on Telecommunications, Utilities and Energy.

"House Bill 3314 considers setting minimum energy efficiency standards and establishing an efficiency program for replacement tires. Tires do play a limited role in overall vehicle fuel economy. However, improving tire efficiency can have negative effects on other tire performances. Other governmental groups are researching these issues now.

"In fact, the issue is so complex that the United States Congress has enlisted the National Academy of Sciences (NAS) to determine if the potential for fuel savings from lower rolling resistance in tires outweighs the environmental and safety impacts that result from the effects on other tire performance parameters. Additionally, California is conducting research and studies on the relationships among rolling resistance and other key tire performance parameters, notably safety and tread wear. In light of these two studies, RMA simply asks that Massachusetts postpone any action in this area until better data are available upon which to make sound policy choices.

"Tire energy efficiency, commonly referred to as tire 'rolling resistance,' contributes to vehicle fuel economy. Vehicle fuel efficiency is affected by many different vehicle components. According to the U.S. Department of Energy, only about 15% of the energy in the fuel that goes into a car's gas tank is used to move a car down the road or use other valuable components, like power steering. The largest cost to vehicle fuel energy, 62%, is lost to engine friction, and other related engine losses. Just idling at stoplights or in heavy traffic loses 17%. In contrast, on the order of 4% is lost to tire rolling resistance.

"In turn, the rolling resistance of a tire is influenced by many factors. These factors include tire inflation pressure, load and speed of the vehicle, tire condition, environmental and road conditions and tire design. When tires are designed to maximize lower rolling resistance, the performance of wet and dry traction is reduced. When a tire is designed to maximize traction, rolling resistance increases. Tires also wear out faster when rolling resistance is reduced, thus increasing the number of scrap tires created per mile driven and exacerbating scrap tire management issues. There is a fundamental relationship between rolling resistance, traction and tread wear and one characteristic cannot be maximized without affecting the others.

"The tire industry has made great strides in improving tire rolling resistance. However, there is no one test to measure rolling resistance performance. Key ongoing governmental activities are geared toward assessing the available test methods and collecting more robust data in the areas of tire rolling resistance, fuel economy and other crucial tire performance parameters.

"In 2003, the California legislature passed and the governor signed into law Assembly Bill (AB) 844. AB 844 is virtually identical to the bill currently before this committee, BH 3314. California AB 844 mandates that the California Energy Commission (CEC) create a replacement tire efficiency program. This program consists of two main components: a tire efficiency rating system and the development of minimum efficiency standards. Minimum tire efficiency standards under the law must be technically feasible and cost effective to the consumer, cannot not adversely affect tire safety, cannot not adversely affect average tire life, and cannot not adversely affect the state’s scrap tire program.

"California is conducting a $400,000 tire testing program pursuant to AB 844, using a testing firm with significant tire expertise. CEC is assessing test methods for measuring rolling resistance, testing over 100 tires for rolling resistance to establish a database of rolling resistance values for various original equipment and replacement tires and studying the relationships among rolling resistance, fuel economy, traction and tread wear. The CEC study will provide necessary information to better inform policy makers on the issues and tradeoffs surrounding tire rolling resistance and vehicle fuel economy.

"Second, on the Federal level, by direction of the U.S. Congress, the National Highway Traffic Safety Administration (NHTSA) has commissioned the National Academy of Sciences (NAS) to conduct a study of rolling resistance and its relationship to vehicle fuel economy and other key tire performance parameters. The study is scheduled for completion by January 2006. In order to complete the study, the National Academy of Sciences Transportation Research Board has convened a panel of experts in the areas of tire design and performance, fuel economy, vehicle dynamics, economics and other related disciplines. The committee is holding meetings and assessing the available information in the public domain, including peer-reviewed scientific literature, information submitted during the process and government data, including that compiled by the California Energy Commission. This process will evaluate the state of the art with respect to tire rolling resistance, vehicle fuel economy and other tire performances. The study also will provide policymakers with additional critical information upon which to make informed policy choices and assess whether tire it is technically feasible and cost effective to set tire efficiency standards regulating rolling resistance performance without compromising tire safety or tire wear performance of replacement tires.

"The tire industry believes that all aspects of tires should be considered before invoking a tire efficiency standard. As described above, significant activities are underway both by the state of California and the National Academy of Sciences that will greatly enhance the state of knowledge regarding tire rolling resistance and enable decision makers to understand the potential consequences of setting minimum tire efficiency standards. In a recent report on vehicle fuel economy, The National Academy of Sciences said it best: 'Continued advances in tire and wheel technologies are directed toward reducing rolling resistance without compromising handling, comfort, and braking. Improvements of about 1 to 1.5% are considered possible. The impacts on performance, comfort, durability, and safety, however, must be evaluated.'

"Now, I will address potential unintended consequences of hasty policymaking in this area. First, tire safety must be preserved. Tire manufacturers will never maximize tire rolling resistance performance in a way that compromises tire safety. However, rolling resistance improvements do have traction performance implications. Consequently, the relationship between rolling resistance and safety performance must be represented by data in order to avoid setting a standard that would in essence require unsafe traction levels. This type of standard would not be in the public interest and would not be technically feasible, since tire manufacturers would be unable to manufacture compliant tires.

"Second, the Massachusetts scrap tire management situation must not be worsened due to a new tire efficiency standard. Currently Massachusetts has approximately 10 million scrap tires in stockpiles around the state. In addition, according to RMA data, Massachusetts generates over six million scrap tires annually, while the only scrap tire market in the state can consume only bias-ply tires, a small percentage of the tires generated by Massachusetts annually. The vast majority of scrap tires generated annually is exported to neighboring states. Massachusetts continues to have no comprehensive program in place to develop scrap tire markets in the state or remediate those scrap tires currently in stockpiles. Increasing the number of scrap tires generated annually by setting a tire efficiency standard could increase the scrap tire challenges faced by the State.

"Rather than a new -- but uncertain -- program on rolling resistance, one option that Massachusetts could consider to improve tire efficiency is to develop and conduct a tire care and maintenance public education campaign. Proper tire inflation pressure plays a crucial role in achieving lower rolling resistance and good vehicle fuel economy.

"In fact, tires that are only 5 to 7 psi underinflated can increase fuel consumption by 10%. A NHTSA study found that 27% of cars and 32% of light trucks in the U.S. have at least one significantly under inflated tire (8 psi). Even the best tire fuel efficiency program can only hope to accomplish a slight reduction in rolling resistance. Encouraging motorists to keep their tires properly inflated could have a far greater impact on fuel economy.

"RMA is committed to a multi-million dollar, multi-year education campaign to increase public awareness about proper tire maintenance. The campaign 'Be Tire Smart -- Do your PART' focuses on four mportant tire maintenance activities -- pressure, alignment, rotation and tread. Originally designed to promote tire safety, the RMA campaign also promotes concepts that would achieve environmental benefits. Maintaining proper tire inflation pressure, in particular, will help to promote improved fuel economy and longer tire life. Key factors in the longer tread life equation are proper inflation and proper alignment, both of which promote even tread wear and longer tire life.

"RMA has many partners in its campaign that provide valuable avenues for sharing the tire safety message with the public. Among those partners are the American Automobile Association (AAA) and scores of tire dealers, retailers, and associations nationwide. In addition, NHTSA has its own tire safety campaign that shares a message consistent with RMA's called, 'What's Your PSI?'

"The key benefits of the RMA campaign include the fact that it can be implemented immediately. RMA materials can be made available to Massachusetts for its use in developing a campaign for the State. Its effects do not require consumers to buy new tires, or in fact spend any significant money. Consequently, greater public awareness about proper tire maintenance has the potential to have a far greater impact on fuel economy than any rolling resistance program would.

"Therefore, RMA recommends that Massachusetts delay consideration of HB 3314 until the completion of the California and NAS work. Acting before these critical activities are completed will cause Massachusetts to undertake duplicative study in an area where very limited research is available currently. Furthermore, a standard set in the absence of key analyses could lead to unwanted and unintended consequences. Instead, RMA suggests that the state develop a comprehensive program to address the 10 million tires stockpiled in the state, as well as a campaign to address tire inflation in Massachusetts. In this manner, Massachusetts can save fuel and address scrap tire management issues."

(The Massachusetts legislative session lasts until July 2006. Should the bill be reported favorably by the Joint Committee on Telecommunications, Utilities and Energy, it would then be referred to the Ways and Means Committee due to the fiscal impact on the state.)