Tire Pressure Monitoring System -Outage Rates and Repair Costs (TPMS-ORRC)

On behalf of the members of the Alliance of Automobile Manufacturers, Inc. (Alliance), this responds to the National Highway Traffic Safety Administration (NHTSA or agency) Federal Register notice referenced above which seeks Office of Management and Budget (OMB) approval to collect information on outage rates and repair costs of tire pressure monitoring systems. With this submission, the Alliance acknowledges the effort of the agency to base its regulatory actions on sound science and data. The Alliance urges the Agency to use the data collected in conducting a robust regulatory impact analysis that will determine whether benefits of updating Federal Motor Vehicle Safety Standard 138 outweigh the costs. Additionally, the Alliance asserts that NHTSA regulations should provide flexibility to auto manufacturers by setting forth performance-based standards. The Fixing America's Surface Transportation (FAST) Act states that the revised requirements shall not contain any provision that has the effect of prohibiting the availability of direct or indirect tire pressure monitoring systems. The Alliance looks forward to the results of the proposed information collection on TPMS and welcomes an opportunity to provide information and technical support through an agency Request for Comments.