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DOT Race Tires may become illegal (long)

To: <evolution-discussions@yahoogroups.com>, <autox@autox.team.net>
Subject: DOT Race Tires may become illegal (long)
From: "Steven T. Ekstrand" <cyberlaw@earthlink.net>
Date: Fri, 24 May 2002 19:41:36 -0700
I'm hearing a whole lot of speculation and that's all I can offer.  I read
the notice
http://www.nhtsa.dot.gov/cars/rules/rulings/UpgradeTire/Index.html#TireIII

I suspect the upgrade in specifications is not the entire issue.  Our race
tires will probably resist losing a bead and resist heat buildup better than
typical passenger car tires.  Even the road hazard test doesn't seem to
include puncture resistance which is the real difference between Kumho's and
Hoosier's in terms of road worthiness.  The hazard test measures a tires
ability to survive a deforming impact such a pothole or curb and not suffer
belt seperation or some such damage.  I would suspect the Hoosier would do
fine.  The only test that made me wonder a little was the accelerated aging
tests.  They don't seem to know how to do it.  And aging isn't something
race tires were really meant to do.

I'm speculating that the real issue isn't meeting the new specifications.
It is the increased costs associated with testing, complying, and reporting
for each individual tire line, compound, and size.  Every different tire
sold has to go through the certification process, not just a representative
tire for each line or diameter.  And LT tires no longer get an exemption.  I
don't believe it applies to Autocross tires, but many specialty tires for
drag racing and ProStreet type vehicles are LT tires.  I always wondered
why....  Maybe it was to avoid the need to comply with the 109 rules.

I also notice that is lines like the BFG Drag Radial one particular size in
the line has slightly more tread depth than the rest in that diameter.  Is
that the tire size BFG submitted for testing???   If there is some
connection there to the testing, then maybe these new rules would effect
Hoosier more than Kumho.  But that is speculation upon speculation.  I read
the regulations and can't find the answer.  And I read regulations for a
living, and often analyze them for economic impact as a sideline both as an
economic expert/consultant and in academe.

The incremental cost of testing a single tire is listed as $281.  If that
were all there was to it, we could end my line of thinking right now.
Hoosier wants to introduce a new size tire, BAM....  Pay the $281 toll and
release the tire...   Heck, if I could get the tire size I want released,
I'd pay the $281 for them without blinking.  I'm sure I'm not alone on that
one.

But if I listed the cost of testing a tire as $281 based on the breakdown of
costs they listed (the extra hours of an engineer and assistant) I'd be
fired on the spot.  That entry is incomplete, if not disingenuous.

If you're Bridestone or Michelin and you're testing a tire which will
literally sell 100,000's if not millions per individual line and size, then
you've got the testing lab and the staff and you can spread the fixed costs
across such a large base as to make incremental costs sound reasonable.  For
a Hoosier or M&H or Coker (assuming those companies are still independent),
you can't make such a quick dismissal of testing costs.

If nothing else this could make it difficult on manufacturers to develop
their tires.  Every time they want to release a new size they have to go
through the testing and reporting process.  But more important, a compound
change for example, might expose the entire line and every size to retesting
and reporting.  Everything would slow to the lazy pace of the bureaucrat.  I
can hear Friedrich Von Hayek screaming from the grave as we race down the
road to serfdom.   Now add in those Kumho's coming across the Pacific on a
very slow boat to be tested.  Then the approval.  Then the wait for an
opening in the production schedule.  Then a wait for that slow boat to dock.
Then a long slow ride across the Pacific.

If testing is the issue, Kumho might be able to deal with overall testing
cost on existing lines and sizes as a very large tire company (assuming
testing can be done in South Korea).  But they will be hit harder than
Hoosier in terms of developing and improving their race tires.  Anything
which adds a step between the racer and the factory and the racer is always
going to be harder for the Kumho's and Hankook's than the Hoosier's.

Just my hand at wild speculation as we all try to figure out what is being
done to us.  Am I cynical about government regulation and does it bias the
way I approach this new mystery?  Yes!!!  Unabashedly YES!!!  GUILTY!!!!

BTW-Where Hoosier may really suffer in the upgraded specs is not with the
tires we use the most, but in their Bias Ply line which gets some autocross
use, but is really big among some vintage road racers.  The bias ply tires
are also the bread and butter of several VERY small specialty tire makers
for vintage cars.  Also aren't the M&H tires the Vintage BSP folks run a
Bias Ply?  The upgraded specs especially on Road Hazard survivability may be
the death knell for Bias Ply car and LT tires.

And, of course, I could be wrong about EVERYTHING....  It wouldn't be the
first time.

-Steve Ekstrand
Cal Club's Malefic One
www.conemangler.com

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