Appx E NHTSA Pub Meeting-Tire Fuel Efficiency Consumer Information Research

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NHTSA Public Meeting

Tire Fuel Efficiency
Consumer Information Research

March 26, 2010

Dan Zielinski

Senior Vice President, Public Affairs

Rubber Manufacturers Association

202-682-4846/dzielinski@rma.org

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Tire Fuel Efficiency NPRM

• •Energy Independence and Security Act  

• • –RMA advocated inclusion of national tire fuel efficiency consumer information program 

• •For NHTSA’s rule to be effective RMA believes the program must: 

• Provide information at point of sale;        

• Provide meaningful information that is easy to understand by consumers

• Provide a meaningful rating system, differentiating tire rolling resistance, traction and tread wear performance among appropriate tire choices for the consumer’s existing vehicle

• Be cost effective to minimize the cost effect of this information to consumers.        

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RMA Consumer Research

• •In response to NHTSA’s NPRM, RMA undertook comprehensive consumer research to test a sample of potential tire information formats to provide consumers with information about tire fuel efficiency, traction and tread wear. 

 

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RMA Consumer Research

• •Methodology 

• • –Internet survey – 1,000 participants 

  • –Participants screened using same criteria as NHTSA focus group 

  • –Five formats tested 

 

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RMA Consumer Research

• •RMA tested five tire information formats based upon those initially tested in NHTSA focus group study 

• •Some formats were altered based upon  NHTSA’s focus group research and comments 

 

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RMA Consumer Research

 

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RMA Survey Results

• •The “Stars” format was highest rated among consumers in RMA survey: 

Most Preferred Label

(Asked of n=1,000)

 

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RMA Survey Results

• •While 29% of respondents chose “Thermometer” as their most preferred, this support drops to 19% when respondents are informed that it would not precisely rate tires.  

 

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Effective Rule Helps Consumers; Spurs Industry Innovation

• •An effective program will provide useful information to consumers 

• •Tire makers will have additional incentives to compete for consumers’ attention on particular tire traits 

• •Top end of rating scale should be appropriately high to allow for future innovation 

 

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Concerns – Information Format

• •A paper label attached to replacement tires is impractical and ineffective for consumer information 

• • • •Consumers virtually never see a tire label 

• • • • –Removed or damaged before installation 

      • –Consumers typically see tires after installation 

    • •Consumer access to information prior to purchase decision is important - web, point-of-sale 

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Recommendations for Providing Consumer Information

• •NHTSA should mandate that tire retailers display tire efficiency program poster and make the rating information available to consumers. 

• • –Other forms of information:  

• • • •tire manufacturer brochures, product catalogues 

    • •in-store online access to the NHTSA website 

    • •tire manufacturer or retailer’s website with rating information 

    • •NHTSA-produced tire fuel efficiency program booklet – similar to agency’s UTQGS publication  

• • • • –Provided to tire dealers nationwide at an annual cost of $3,190.  

      • –NHTSA estimates 60,000 tire dealers nationwide.  

      • –Small investment to help educate consumers with tire ratings and assist in more fuel efficient tire purchases 

 

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Concerns – Rating System

• •0-100 scale is not practical 

• • –Implies a misleading level of precision  

  • –Tires within 10-20 points not likely to have significantly different performance 

• •Rolling resistance force will group tire ratings of the same or similar size into a small range of the overall scale, minimizing differentiation   

• •Rolling resistance coefficient is more suitable to provide consumers with range of tire choices within their size range for a given vehicle 

  • –Europe and Japan are implementing rating systems based on rolling resistance coefficient 

 

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Concerns - Research Plan

• •Additional research should test several formats 

• • –NHTSA’s August 19, 2009 survey only tested two formats used in earlier focus group research 

• • • •RMA research shows consumer preference for a “star” categorical format 

  • –Labels, point-of-sale and web-based formats should be tested 

    • •Consumer testing should not be limited to one particular type of information media 

    • •Appropriate mock-ups should be used to gauge preferences 

  • –NHTSA’s August survey was done after NPRM was issued and was not available for comment 

 

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Initial Recommendations – Research Plan

• •Benchmark – Using a benchmark (current UTQG symbols?) as a reference to show whether the alternatives are better than the current design.  

• •Monadic Design - Recommend testing one design variable at a time, within any one style of label, using a monadic design. (Alternatively, if cost is a factor, a sequential monadic design.) 

• •Conclusions - Should be based on differences observed across different cells, not within same respondents.   

 

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Initial Recommendations – Research Plan

• •Rate beyond comprehension - The quantitative research should address "likelihood to be read" or "visually appealing" nature for consumers.  

• •Participant eligibility: 

• • • •Specific for tire purchasing responsibility -- Household decision maker for vehicle maintenance/repair (e.g. oil changes) may not be the same person making tire purchase. 

    • •Participant eligibility -- Exclude those who work in auto, tire or market research industries. 

 

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Concerns – Process

• •Process Concerns 

• • –How will stakeholders be able to comment on NHTSA’s final information format recommendations? 

• • • •Will there be a supplemental or new NPRM? 

 

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Summary

• •Consumers will want to compare performance traits for tires suitable for their vehicle and not to other sizes or types not applicable to their vehicle 

• • –RMA has proposed a sound solution to measure tire fuel efficiency 

  • – RMA has proposed a rating system that consumer research shows is understandable and acceptable 

• • • •“Star” format was most preferred in RMA research 

 

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Summary (cont.)

• •A rating system based upon rolling resistance coefficient will provide consumers with the most practical, useful information 

• •Point of sale information and web-based resources are the best conduits for reaching consumers 

• • –Paper labels on tires are not an effective way to convey information to consumers 

 

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Summary (cont.)

• •Stakeholder ability to provide input on NHTSA’s consumer information research. 

• • –Will further rulemaking notice be required? 

 

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Summary (cont.)

• •RMA will continue to provide NHTSA with well-reasoned and researched comments 

• •Thank you for today’s opportunity for discussion. 

 

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