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Comment 12 for Tire Pressure Regulation (tirepres09) - 15-3.

First NameNathan
Last NameSmith
Email Addressnate@optimalauto.com
AffiliationNate Smith's Optimal Auto Care
Subjecttirepres09
Comment
I too have some concerns about your proposed legislation.

1) You have not adequately addressed the tire temperature issue. 
If all the printed specifications are for cold tires, and if we are
required to inflate only to the vehicle manufacturer's specified
pressure, then any tires we check and inflate when hot will still
be underinflated.  You specifically say not to drop the hot tire
pressure to the cold standard else the tire will be underinflated. 
I suggest that because there is no standard for proper inflation
for a hot tire that this proposed regulation is a fool's quest and
therefore should be abandoned.

2) You have made it impossible for industry to comment on your
proposed "Best Practices" document - prior to adopting this
regulation - since it does not yet exist.  We do not have the
ability to examine and comment on how you propose to address the
issues of non-original tire sizes, non-original wheel sizes,
non-original load ratings, and all temperatures other than cold. 
This is unfair to industry.  I request that you do not proceed with
this regulation until a "best practices" document has been created
and commented upon by industry.

3) It is unclear how an ARD is to handle this proposed regulation
in a number of cases:  
   (a) For example, we do not currently write a work order if a
customer stops by to have us replace a brake light bulb or wiper
blades.  Yes, we do sell them the part, but we do not charge them
any labor charge to install the part they just bought.  Does this
regulation apply in this case?  Clearly we are an ARD and not a
parts store.
   (b) We often have a Body Shop bring us a vehicle to read and
clear airbag codes after they have done a repair.  They do not own
the car and they only want us to perform this one task.  Do we need
to force them to have the tire pressures checked?  They are my
customer, but they do not own the car.

4) Why did you exempt Body Shops?  They will often have a car for
weeks until it is repaired. Shouldn't it be just as important for
them to check that car's tire pressures before releasing it back to
the customer?

Attachment
Original File Name
Date and Time Comment Was Submitted 2010-07-05 10:29:47

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