WASHINGTON (Nov. 5, 2010—Data collection and market research programs will be helpful in formulating the consumer information portion of the new tire fuel efficiency standard, commenters told the National Highway Traffic Safety Administration.
But the Rubber Manufacturers Association—which first proposed a tire fuel efficiency rule and submitted the most detailed comments—said the program must be designed to obtain the most exact information from consumers as to how they really respond to proposed information labels and categories.
“Discussion should be in the context of example (or hypothetical) tire choices represented with labels, in order to fully understand consumer interpretation,” the RMA told NHTSA in its Nov. 2 comments. “It is critical that consumers' understanding (and misunderstanding) of the rating descriptors and scalings be clearly understood.”
NHTSA issued the 195-page rule March 25, but without the final language on tire testing parameters and consumer information. The agency held a meeting of stakeholders the following day to discuss how to proceed on these issues.
On Sept. 3, NHTSA published a call for comments in the Federal Register, with a supplementary notice Sept. 27. The notices gave interested parties until Nov. 2 to answer specific questions on the two-phase market research the agency planned to gather data toward formulating final plans for the consumer information program.
For the first phase, NHTSA said it planned to establish two eight-member focus groups in three U.S. cities that had yet to be chosen. For the second, it planned up to 25 on-site interviews at tire retail stores across the U.S.
Among other things, the agency asked for comments on whether the information gleaned in the two-phase process would have practical utility; how to enhance the quality, utility and clarity on the information to be gathered; and whether it would be proper to include California in the information gathering process.
In its comments, the RMA said NHTSA was too vague in describing the information it sought from the public. Terms such as “maintenance” and “performance” have very specific meanings when it comes to tires, the association said, and rolling resistance is too technical an issue for non-professionals to discuss easily.
“Motorists generally understand that vehicles with underinflated tires have more rolling drag and get lower gas mileage,” the association said. “Going beyond this in a consumer focus group discussion quickly becomes involved in technical detail that will be lost on typical drivers.”
The RMA said NHTSA should develop a comprehensive set of tire buying scenarios to frame its information gathering efforts. The agency should also ask focus group participants about their previous tire purchases, it said.
“The focus group participants should discuss each of these scenarios in detail and be asked to identify which have characterized their past tire purchases and or which are likely to apply in the future,” it said.
Regarding actual labeling and consumer information proposals, the RMA recommended that focus groups should see only proposed information and labels as NHTSA actually intends them to appear; that they should be asked probing questions, such as how they defined safety and durability as they pertain to tires; and that conclusions on which labels to use should be based on differences observed between different groups, not within the same respondents.
“The ability for a label format to be understood is important,” the RMA said. “However, if the presentation of the information is unappealing or fails to capture consumers' attention, it may not be read.”
The three cities NHTSA chooses for focus groups should be as geographically diverse as possible, with sharply differing climates, the RMA said. But Californians are unlikely to have differing opinions on a tire fuel efficiency consumer information program than consumers in other states despite the pending state standard on tire fuel efficiency, it said.
“To date, California has not promulgated any regulation on tire fuel efficiency,” the association said. “California consumers are likely not aware of the state's efforts to date in developing a proposal, since most hearings and meetings have been with stakeholders.”
Besides the RMA, the only two other commenters in the NHTSA docket as of Nov. 4 were the Tire Industry Association and synthetic rubber manufacturer Lanxess Corp.
TIA said it was pleased NHTSA intended to conduct at least some of its research on-site at tire retail stores.
“TIA would like to emphasize our belief that there is a limited amount of time available to deliver the message that should be a concise explanation of fuel efficiency ratings and the proper tire care necessary to maximize those ratings,” the association said.
“TIA would also state that, in our members and their employees' role as providers of pertinent purchasing information to consumers, it could be viewed as negligent to emphasize one aspect of tire ratings over another (fuel efficiency over traction) as it pertains to safety,” it said.
Lanxess urged NHTSA to finalize the consumer information program as quickly as possible, in anticipation of the European Union requirement to start labeling tires for fuel efficiency, wet grip and rolling noise starting in 2012.