Comment Log Display

Mr. James Goldstene
Executive Director
California Air Resources Board
1001 “I” Street
Sacramento, CA 95814
 
November 9, 2009
 
Proposed Amendments to the Regulation to Reduce Greenhouse Gas
Emissions from Vehicles Operating with Under Inflated Tires
 
Dear Mr. Goldstene:
 
I am writing on behalf of the California Tire Dealers Association,
which represents several hundred small and independent tire
retailers throughout the state.  While we applaud a number of
changes the ARB has made in the latest draft of the proposed
regulation, we still must take issue with portions of Section 95550
of Article 1, Chapter 1, Subchapter 10, Division 3, Title,
California Code of Regulations.
 
·         A number of our members use the portable "pencil" gauges
that are easily accessible and clip to a worker's shirt.  These
gauges are generally accurate to +/- 4 psi.  We support a change in
Section 95550 (d) (1) (C) from the +/- 2 psi standard.


·         Section 95550 (c) (14) "Unsafe Tires."  While we support
the proposal for Auto Service Providers not to inflate unsafe
tires, in the definition portion of the regulation, Section 95550
(c), it refers to tire "age" as one of the reasons that tires
become unsafe.  That issue is the subject of significant debate,
lawsuits, and legislation.  Since NHTSA has promised further
testing on the issue, and since the cause of a tire becoming unsafe
is not pertinent to the definition, we suggest you simply eliminate
the controversial issue of tire "age" as a causal factor and
suggest the following wording for Section 95550 (c) 14:

"Unsafe Tires" means any tire considered unsafe in accordance with
standard industry practices, due to tire tread wear, age, tread
irregularity, or damage.  Examples include any tire with exposed
ply or cord, sidewall crack, bulge, knot, or ply separation.


·         A minor correction is needed for Section 95550 (d) (3)
with its reference to definition (13) rather than (14):  (B) the
tires are determined by the automotive service provider to be
unsafe, as defined in § 95550 (c) (13) (14); or


Thank you for the opportunity to comment on this important
regulation.
 
Sincerely,
 
Terry Leveille
President, TL & Associates
 
cc:  Ejnar Fink-Jensen, Executive Director, CTDA-North
     Ed Cohn, Executive Director, CTDA-South