Washington legislation targets replacement tire rolling resistance

OLYMPIA, Wash.—The Washington State Legislature recently introduced a pair of bills intended to bolster its electric vehicle infrastructure ahead of the power train transition. In the process, however, it has taken aim at replacement tires, placing particular focus on rolling resistance.

Senate Bill 6304 passed through the Senate Transportation Committee Feb. 5 and is due for a floor vote no later than Tuesday.

House Bill 2262, which contained similar language around replacement tire performance, failed to make it out of the House Transportation Committee, which last met in executive session on Feb. 5.

As written, the remaining bill directs the Washington State Department of Commerce to establish energy efficiency standards for passenger car and light truck replacement tires. In doing so, it gives Commerce the authority to:

• create a database of replacement tires being sold in the state;
• establish a rating system for energy efficiency of replacement tires based on their rolling resistance coefficients (RRCs);
• set procedures for testing replacement tire energy efficiency;
• establish minimum energy efficiency standards for replacement tires based on RRCs;
• restrict the sale of tires that do meet the efficiency performance standards; and
• issue fines to manufacturers and retailers selling tires that do not meet the efficiency requirements.

At its core, the language in the Washington proposal is reminiscent of California Assembly Bill 844, which seeks to bolster vehicle range and fuel efficiency by establishing minimum RRC standards for tires.

However, unlike AB 844, the proposed Washington legislation is not solely focused on replacement tire efficiency. Instead, Washington looks to align its electrification transition efforts across 10 state agencies as directed by the Move Ahead Washington transportation package that legislators passed in 2022.

Tracey Norberg, U.S. Tire Manufacturers Association executive vice president and general counsel—in speaking in opposition to the tire-related language in the two new Washington proposals—emphasized that the association and its member companies are not opposed to tire efficiency standards.

"We have been actively engaged on this issue since 2002 and support national and North American standards on tire performance and safety, including tire efficiency," Norberg told the Senate Transportation Committee during a Feb. 1 hearing. "We recognize the vital role that tires play in vehicle fuel economy and really support this action at the federal level."

The major concern surrounding passage of the proposed state legislation is the impact it could have on consumer choice, Norberg and Jennifer Ziegler, a representative of Les Schwab Tire Centers, told both the Washington House and Senate Transportation Committees in recent weeks.

"If we are talking about very aggressive levels of rolling resistance in reductions, what we are doing is removing the lower tiers out of the market," Norberg told the House Transportation Committee on Jan. 24. "Right now, we have probably four tiers. Tier 1 being the top flagship brands, Tier 2 being the secondary brands and 3 and 4 being the brands that are being targeted toward budget-minded consumers.

"And it is those lower tiers that we are talking about removing (if the proposal is implemented)."

Ziegler echoed the concern during the Senate Transportation Committee's Feb. 1 hearing.

"Fundamentally, Les Schwab is focused on customer choice," Ziegler said. "So depending on the efficiency standards that would be adopted under the provisions of this legislation, you have the potential to eliminate a significant amount of tires that would be available for customers to choose from."

Replacement tires are designed for performance. And tire makers take pride in working to optimize—and balance—key performance characteristics with new technologies and designs that also enhance safety.

Still, different tire models are designed to optimize certain characteristics, meaning that there could be slight tradeoffs in certain performance aspects when you emphasize one in particular. As the technology improves, the characteristic balance is better, but not all tires perform the same.

Ziegler raised concerns about the expectations the legislation could set forth, especially if it relies on California's data, which is the basis for AB 844.

"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."