Tire Efficiency Consumer Information BETA

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Draft Summary

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Moderator, Nov. 25, 11:00 AM

Background: Regulation Room is a new and innovative online environment attempting to increase effective public participation in the rulemaking process. It is operated by the Cornell e-Rulemaking Initiative as a non-governmental research platform, although CeRI works in close collaboration with agencies whose rules are featured. Regulation Room ran a test public participation period from November 12 – 22, 2009 on a proposed National Highway Transportation Safety Administration rule: Tire Fuel Efficiency Consumer Information Program. Although the official comment period had closed for this rule, as part of the beta test of Regulation Room, users were encouraged to learn about, react to, and discuss the proposed rule.

This summary was prepared by the site moderators after the test discussion phase had ended.
Users are invited to review the summary, and suggest additions or changes. If the agency were still accepting public comment on this rule, a final version of the summary would be submitted to the agency through regulations.gov as a formal comment in the rulemaking.

You can suggest changes to this Draft Summary until Friday, December 4, when we will review the suggestions and post a Final Summary, which will conclude the beta test.

Summary of Discussion: NHTSA’s proposed new rating system for tire fuel efficiency, safety/wet traction, and durability/treadwear prompted considerable discussion. Those who liked the proposed ratings believed that (similar to the existing Energy Star ratings on appliances) they would help consumers understand the impact of tire choices on fuel efficiency and make decisions based on what product characteristics are most important to them.

Those who were critical of the proposal had several concerns:  Some users thought that the rating system, as proposed, did not adequately inform consumers about possible trade-offs between fuel efficiency, traction and durability. Of most concern was the trade-off of efficiency and safety. With the proposed label, consumers could not tell how large an increment of safety was being lost if they accepted a lower score on the safety/wet traction scale. On the possible tradeoff between fuel efficiency and durability, one user pointed out that more frequent tire replacement costs could cancel out gas savings, and wanted some metric for evaluating this.

A related concern for several users was that the range of performance within each of the rating scales was unclear, so that it would be difficult for consumers to judge the practical impact of different rating scores. Some wanted NTHSA to provide a way for consumers to translate rating scores into real world tire performance measures. Without this, consumers can’t know what the difference between, for example, a score of 40 and 100 really means. One user cautioned that point differences would probably not have the same significance on all three scales; as this user noted, the meaning of point differentials would depend on the distribution of data for the particular characteristic.

A related concern was how the ratings would relate to minimum acceptable performance standards for each of the three criteria. Some users suggested an Energy-Star like system that includes an absolute minimum threshold that the product must satisfy for each criterion. One user thought it would be helpful for dealers to have available, for consumer inspection, actual samples of tire materials corresponding to different rating scores. One user, who favored the proposed ratings, nonetheless expressed concern about whether the ratings would be accurate, noting that there has at times been controversy about accuracy of the Energy Star ratings.

Some users felt that the entire program was misguided – wasting resources to create information that no one would look at or understand. Several users disagreed. Some felt that the information would be broadly used; others thought that this was a relatively low cost way for government to provide information to those who would use it, even if they were a small subset of tire buyers. One user was concerned that choosing fuel efficient tires over safer tires could result in liability. Another proposed that heavily marketing fuel efficient tires would be a better strategy, since this user believed that consumers were already overloaded with information.

On design of the label, users in general agreed with NHTSA’s focus groups that bar graphs were the best format – and found unhelpfully confusing the label that combined all three ratings in a triangular graphic.

With respect to limiting the new consumer education program to replacement tires, users understood that NHTSA was doing this because of directives in the Energy Independence and Security Act. However, many tire consumers replace tires with whatever brand and model was original equipment with the car, so some users felt that having the label on new tires might be more important than labeling replacement tires. One user expressed the hope that the omission of new tires would be remedied in the next round of greenhouse emissions legislation.

Users had several ideas on additional ways to disseminate the new rating information. These included: requiring tire retailers to have printouts of rating information available in the store, so that consumers who can’t, or don’t, do research on NHTSA’s website before going shopping could still have the option of doing some brand/model comparison; one user suggested requiring retailers to have a computer kiosk at which users could access the NHTSA site, perhaps with the requirement tied to retail volume. Both of these suggestions would respond to concerns that the comparative information would be unavailable to consumers without reliable Internet access. Since consumers will often be buying replacement tires on very short notice (e.g., immediately replacing a flat tire, or needing tires for the vehicle to pass inspection), the design and content of the required retail poster will be very important, since this may be the only information most consumers get.

General Statistics: During the test commenting period, the site moderators posted 9 blog posts and the site received 37 comments from 21 users. This included 3 comments from 2 users that were lost due to an unrecognized design anomaly, which was immediately remedied. A total of 917 people visited Regulation Room, which got 18,939 page views during the beta.

105 visitors registered as subscribers (users). All users responded to a survey question at registration asking if they had ever submitted a comment in a federal rulemaking. 100% responded that they had never submitted a comment in a federal rulemaking.

A second survey question, which appeared the first time a subscriber submitted a comment, asked them to describe their interest in the rule. 24 subscribers responded to this question: 18 identifying themselves as consumers; 1 as a tire retailer; 1 as a researcher; and 4 as (unspecified) “other.”