Comment Log Display

 Under your proposed compliance requirements to check and inflate
the tires when performing ANY automotive maintenance or repair
service is impracticable and cost prohibitive.  Any properly
managed fleet performs the air pressure inflation during all
scheduled maintenance; weather is meets or exceeds the vehicle
manufacturer’s recommendations.  Our fleet, a public agency fleet,
that includes public works, police and fire vehicles, performs tire
maintenance and inflation during each of our scheduled maintenance
every 2,500 miles.  Our issue is the repair service, criteria in
the regulation for compliance requirement as some of our vehicles
have frequent “repair service” that are unrelated to tire or
vehicle maintenance, I.E. Emergency light repairs, Mobile Data
Computer modems off line, gun lock, GPS locators not working, trunk
key broken, fuel cap missing, to name a small segment of fleet
related activities unrelated to tire maintenance.  The expectation
to check the inflation of all tires, when performing ANY repair
service would not achieve the reduction of green house gases this
regulation seeks, as these vehicles tires already are already
properly inflated as a result of proper maintenance procedures and
a well managed fleet operation.