¹⁷ The agency notes that it seems likely that the respondents in both of the surveys cited overstated the frequency with which they check tire pressure, particularly given the fact that these surveys were conducted during the height of publicity about tire failures on sport utility vehicles in the late 2000 and early 2001.

¹⁸ For purposes of this discussion, the agency classified pick-up trucks, SUVs, and vans with either P-metric, LT, or flotation tires as light trucks.

¹⁹ In response to the TREAD Act, NHTSA has added new tire related variables and attributes, including tire make, model, recommended tire pressure, actual tire pressure, and tread depth to its crash databases. These new variables will provide more specific tire data for vehicles involved in crashes.

²⁰ These crash databases are the NASS-CDS and the Fatality Analysis Reporting System (FARS).

²¹ Goodyear submitted these data to the docket in a letter dated September 14, 2001. See Docket No. NHTSA-2000-8572-160. OMB criticized NHTSA's application of these data to certain vehicle types in estimating safety benefits for this rulemaking. The agency responds to that criticism below in section VI.F., "Technical Foundation for NHTSA's Safety Benefit Analyses." The Alliance also questioned NHTSA's use of the Goodyear data. The agency explains its use of the Goodyear data below in footnotes 22 and 23, and in the agency's Final Economic Analysis (FEA).

²² For example, the VRTC only tested new tires, not worn tires that are more typical of the tires on most vehicles. In addition, the NHTSA track surface is considered to be aggressive in that it allows for maximum friction with tire surfaces. It is more representative of a new road surface than the worn surfaces experienced by the vast majority of road traffic. The previous Goodyear tests on wet surfaces were conducted on surfaces with .05 inch of standing water. This is more than would typically be encountered under normal wet road driving conditions. The agency expressed concerns with the adequacy of both sets of test data in a memo to the docket. (Docket No. NHTSA-2000-8572-81.)

²³ For example, in its more recent tests Goodyear tested tires with two tread depths: full tread, which is representative of new tires, and half tread, which is representative of worn tires. Goodyear also conducted wet surface tests on surfaces with .02 inch of standing water, which is more representative of typical wet road driving conditions.

²⁴ Docket No. NHTSA-2000-8572-26.

²⁵ The Aerospace Corporation, Evaluation of Techniques for Reducing In-use Automotive Fuel Consumption, June 1978.

²⁶ Docket No. NHTSA-2000-8572-26.

Full Report from the National Highway Traffic Administration (NHTSA), Department of Transportation (DOT)

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