"Much of the regulatory discussion that has gone on on this issue has been in California and relies on one California study," Ziegler said. "We would point out to you that California study is not definitive on things like wet traction, safety issues or even on the sustainability and the life of these tires.
"For instance, on the longevity of these tires, the study actually says that the less rolling resistance tires do not necessarily correlate to a shorter tire life."
At least one study—a survey conducted last year by J.D. Power—showed that OE EV tires, designed in part to maximize EV range, were wearing much more quickly than consumers expected.
If passed, however, the Washington legislation would emphasize the optimization of rolling resistance performance by establishing minimum RRC standards. And they could be standards that many tires on the market today would not meet.
So the legislation, as written, would require those tires to be pulled from retail stores.
That, Norberg argues, is what limits the consumer's ability to choose a tire with the characteristics that matter most to them—even if that characteristic is cost.
"Rolling resistance can be reduced in a number of ways," Norberg said during the Jan. 24 hearing. "First of all, by tire compounding. Second, by the actual tread and the tire architecture. And third, by weight."
USTMA members, she told the committee, prefer to invest in new and innovative technologies to achieve lower rolling resistance levels, and then couple those with innovative tire design. And while they are making strides in this area, the development of new technologies takes time and resources. So those technologies often are first implemented in premium products.
By quickly implementing aggressive rolling resistance standards, it is likely that lower tier tire brands and models that do not have these technologies—those that coincidentally are more affordable—are most likely to be eliminated from sale in Washington.
Moreover, she said, there is concern from USTMA members about how offshore competitors would go about meeting the stringent RRC standards.
"Our manufacturers use advanced technologies through tread compounding that helps reduce rolling resistance without decreasing wet traction," Norberg said. "And that is much more advanced technology that we do not always see with our offshore competitors."
If offshore tire makers fill the affordability void by bringing to the market tires that meet the stringent RRC standards through the easiest path possible, it could result in the sale of tires that are neither optimally safe or sustainable.
"The easiest way to reduce rolling resistance," Norberg said, "is to reduce tread depth, which will … reduce wet traction performance, it will reduce tire life and it will increase scrap tire generation."