Interpretation ID: aiam0808
Vice President
Rubber Manufacturers Association
1346 Connecticut Avenue
N.W.
Washington
D.C. 20036;
Dear Mr. Sears: This is in response to your letter of July 24, 1972, t Mike Peskoe, and your letter of July 25, 1972, to Lawrence Schneider. Your letter of July 24 discusses your dissatisfaction with the present method of amending the Appendices of Standards 109 and 110 and suggest that we meet to discuss with you possible methods of changing this procedure. We will be happy to meet with you to discuss possible other methods of amending the Tables, and if you will contact either Ed Wallace or Mike they will arrange a meeting with you.; In your letter of July 25 you request the legal status of a petitio dated July 4, 1972, from E.T.R.T.O., to amend the Tables of standard 109 and 110 to include a tire size designation and alternative rim sizes which have not been standardized by E.T.R.T.O. The guidelines for amending the Tables, which you cite in you letter, do not require tire size designations and alternative rims to be standardized by the respective associations before inclusion in the Tables. Rather, They require only that the petition indicate whether the tire size designation and rim sizes have been standardized. As a consequence, the size in question (250-15 Radial) and the alternative rim sizes were included in the amendment to the Tables published August 2, 1972 (37 F.R. 15430). If you object to the inclusion of the size designation in the Tables, as you have been informed by phone, your objection with supporting statements should be submitted to NHTSA in writing, within 30 days from publication of the amendment to the Tables.; Yours truly, Richard B. Dyson, Assistant Chief Counsel