First Name | Terry |
---|---|
Last Name | Leveille |
Email Address | terry@caltirereport.com |
Affiliation | Rep. California Tire Dealers Association |
Subject | Proposed Amendments to the Regulation to Reduce Greenhouse Gas Emissions from Vehicles Ope |
Comment | 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 |
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Date and Time Comment Was Submitted | 2009-11-09 10:19:16 |
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