WASHINGTON-Again, it was Michelin North America vs. the rest of the tire industry in final comments to the National Highway Traffic Safety Administration on whether to institute a rolling resistance grade in the Uniform Tire Quality Grading System. A fuel economy/rolling resistance grade would violateNHTSA's mandate, add more than $100 million in needless compliance costs and not result in any fuel savings or pollution reduction, opponents argued. But Michelin and its consultant, Energy and Environmental Analysis (EEA) Inc., said such criticism was misleading and misguided.
Among those objecting to the proposal was the National Tire Dealers & Retreaders Association.
The NTDRA shared the concerns of the American Retreaders Association that NHTSA didn't bother to determine the retreadability of low-rolling-resistance casings. It said the agency also showed little thought to the effect a rolling resistance grade might have on ``small entities'' such as tire dealers and private-branders.
One of President Clinton's own executive orders, according to the NTDRA, states that any new regulation must be required by law, be necessary to interpret the law, or fulfill a compelling public need.
``. . . NHTSA's proposed use of a low-rolling-resistance grade fails this test on all three counts,'' the association said.
Leading the tire companies' opposition was Multinational Business Services (MBS) Inc., a consulting firm which objected to the proposed grade on technical, trade and cost-benefit grounds.
Although many tire makers have no objection to eliminating the current UTQG temperature resistance grade, it would be inappropriate to replace it with a rolling resistance grade, MBS said.
``(I)t is not appropriate for NHTSA to equate heat buildup due to speed, and heat generation due to rolling resistance,'' MBS said, citing high-performance tires, which are heat-resistant but have high rolling resistance.
MBS also quoted agency officials on the futility of ``a widespread, expensive publicity campaign'' to promote interest in tire grading.
The cost of retooling tire molds, revising paper labels and testing tires to accommodate a rolling resistance grade is conservatively estimated at $110 million to $125 million, according to MBS.
The most common polymer for low-rolling-resistance treads-``solution SBR'' or SSBR-is available in the U.S. only from Bridgestone/Firestone Inc. or from foreign suppliers, according to MBS. Moreover, the increased demand for imported SSBR would impair the U.S. balance of trade, MBS said.
Michelin responded to accusations made at a July 28 public hearing. Cooper Tire & Rubber Co., for example, reiterated in its final comment its position that NHTSA does not have authority to establish any standards which don't bear directly on safety.
Michelin said that even if Cooper was right, Michelin still ``contends that the fuel savings and the associated reduction in global warming gases provide more than a sufficient basis to conclude that this rule is safety-oriented in its protection of public health.''
EEA said Michelin's finding that a 5-percent reduction in rolling resistance results in a 1-percent fuel savings is accurate for cars made in 1985 and after.
The ratio is slightly lower for older vehicles, ``(but) if the DOT estimates of tire costs are correct, then the regulation will be very cost-effective even at the lowest end of the range,'' the consulting company said.