First Name | Pamela |
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Last Name | Williams |
Email Address | cra@calretailers.com |
Affiliation | |
Subject | Proposed Regulation for Under Inflated Vehicle Tires: |
Comment | 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 manualsh 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 approvedh, 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 yearsh, 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 CARBfS 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 |
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Date and Time Comment Was Submitted | 2009-03-25 12:03:12 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.