Transcript of Oral Testimony by U.S. Tire Manufacturers Association at the California Energy Commission Business Meeting on Replacement Tire Efficiency Program, August 17, 2026.

^{Video Courtesy: California Energy Commission} 

Tracey Norberg, Executive Vice President and General Counsel, U.S. Tire Manufacturers Association: 
Good morning. My name is Tracey Norberg. I'm Executive Vice President and General Counsel of the U.S. Tire Manufacturers Association. Thank you for the opportunity to comment on the proposed tire efficiency regulation.
USTMA manufacturers operate 55 facilities across 16 states, and we support nearly a million jobs nationwide. We have engaged in this rulemaking from the beginning, and we appear today in a constructive spirit.
We share the Commission's goals of improving energy efficiency and providing consumers with meaningful performance information. We also recognize that there are real and quantifiable performance trade-offs for tires among rolling resistance, tread life, and wet traction, and that these trade-offs can have downstream consequences, including increased scrap tire generation and higher replacement costs for consumers.
These trade-offs can be particularly pronounced for certain categories, and so today I will highlight where we believe the proposal can be strengthened, and we will submit written comments for the record next week.
First of all, applicability. We urge the Commission to exempt original equipment tires sold as replacements. These tires are developed to precise vehicle-specific safety specifications, and USTMA member companies are often contractually obligated to provide them in the aftermarket. We also recommend excluding street-legal race tires, which are not designed for sustained road use.
Second, with respect to light truck tires, we want to highlight that the proposed wet traction test, the ISO 23671, was developed and validated for passenger car tires only. It has not been validated for LT tires, and applying it to LT tires would produce unreliable results.
We recommend, therefore, deferring the LT tire requirements until an appropriate test methodology can be studied, validated, and adopted.
Third, I'd like to address tires for use in severe snow conditions. We recommend a single, clear definition based on the objective ASTM F1805 performance threshold and the presence of a three-peak mountain snowflake marking to indicate tires for use in severe snow conditions, and that these tires should be exempt from the regulation. They are treated currently in the proposal differently depending on which document you look at, and we encourage the Commission to unify that approach.
Fourth, compliance framework. The regulation should include a tire family certification structure, which would allow representative testing across groups of tires that share common design characteristics, along with explicit measurement tolerances for rolling resistance and wet grip.
These are consistent with international standards and protect accurate information.
Fifth, enforcement. An uneven enforcement environment harms companies that are doing the right thing in complying with the regulation. We recommend that CEC implement clear market surveillance and enforcement mechanisms, ensuring all tires allowed for sale in Phase 1 are fully compliant with both recommended minimum performance standards and the rating requirements. And we urge the U.S. Customs and Border Protection to establish enforcement mechanisms.
Last, we do encourage the Commission to build in a review of the Phase 1 program before implementing Phase 2.
We do remain committed to working with the Commission staff as it works to produce a regulation that is technically sound, practically enforceable, and equitable for all market participants. Thank you.