Comment Log Display

March 25, 2009

To:  Members, California Air Resources Board

RE:  Proposed Regulation for Under Inflated Vehicle Tires: 
        Agenda for March 26, 2009

The California Retailers Association opposes the current proposed
draft regulations for under-inflated vehicle tires, because of the
cost to retail businesses in this time of severe recession, and
because we believe that the objective can be met by a much simpler
regulatory approach. Our association represents retail chains that
provide automotive services and repair, and tire sales and service
facilities, whether attached to retail stores or free-standing.

Summary of Regulation
The proposed regulation will require automotive service providers
to purchase ANSI standard B40.1 compliant tire pressure gauges.
Purchase of �gtire inflation reference manuals�h is also mandated,
as is a tire pressure check on all vehicles brought in for service.
Service providers must document that the check was performed, write
down the actual pressure of the tire and retain records for
potential inspections, audits and enforcement. 

Costs
The staff report predicts a cost of over $100 million per year to
implement the regulation. Costs include the cost of the specific
tire gauges ($25 each), the cost of the manuals ($50 each) and the
additional labor costs of checking the tires and noting the
pressure. Costs will also include the annual ongoing cost of
document retention (a cost particularly for small businesses, which
do not have adequate on-site storage capability and must pay a
document retention service).

Reasons for Opposition
�� It is completely unnecessary for the State to determine that
only one type of tire gauge is permissible. For decades people have
been able to accurately read tire gauges that were not �gANSI
approved�h, and the $25 cost of the gauge is ridiculously high. 
Additionally, these gauges only have a life expectancy of 2 years,
so businesses must continually be replacing them.

�� It is also completely unnecessary for the State to mandate
purchase of a $50 manual for businesses to inform their employees
how to do tire pressure check. It is duplicative because the
recommended tire pressure information is on the tire itself, on the
vehicle door sticker, or is calculable. This is not rocket
science--$50 manuals should NOT be required. Nor should the manuals
have to be �greplaced and/or updated every 3 years�h, as the
regulations state.

Proposed Alternative
The regulation is projected to save California 90 million gallons
of gasoline (and resultant GHG emissions) by 2010, and to prolong
tire life by reducing tire tread wear.  In the spirit of
facilitating the emission reductions per CARB�fS mandate, we offer
the following compromise:

�� Require auto service providers to conduct tire pressure checks
when vehicles are brought in for service.

�� Require documentation to be made at the time the tire pressure
check is conducted, and require this documentation to be retained
for X number of years.

�� Permit auto service providers the option of documenting the
tire pressure check by using their own work order system, or by
using a CARB-provided format for documenting the check. In checking
with our member companies, there are those who want to use a
separate form provided by the State, so as not to have to redo,
reprint, and revise their existing systems. There are other
retailers who do not want to have to keep track of two different
forms and want the ability to add documentation of tire pressure
check to their service performance documentation. Allowing
retailers to choose among these two options provides flexibility
for different retail tradestyles and saves cost to the retailer.

�� Eliminate the requirement for specific gauges and manuals to be
purchased.

We believe this alternative approach secures the desired emission
reduction goals while reducing cost to businesses for compliance.

Thank you for your consideration of our position.

Sincerely,

Pamela Boyd Williams
Senior Vice President
California Retailers Association