Interpretation ID: aiam0049
Vice President
Secretary and General Counsel
The Firestone Tire & Rubber Company
Akron
Ohio 44317;
Dear Mr. Floberg: Your petition of March 7,1968, requesting a reduction in the high spee performance test (Section S5.5) of Federal Motor Vehicle Safety Standard No. 109 (23 CFR, Part 255) for special heavy gauge tread taxi tires is denied.; While we agree that some taxis are used for low speed intercit operation, many taxis now use high speed freeways for sustained periods of time. With the continuous expansion of freeways in metropolitan areas, the average service speed for taxi tires is certain to increase. In view of this, and because it is impossible to limit the use of taxi type tires to speeds lower than those presently permitted for other passenger vehicles, an amendment to Standard No. 109 exempting the heavy gauge tread tires from the high speed performance requirements, would not be in the interest of safety.; For your future reference enclosed is a copy of *Rule Makin Procedures: Motor vehicle Safety Standards* as published in the *Federal Register (32 F.R. 15818 - 15820). Your attention is directed to S216.31 which sets forth the procedural regulations for petitions for rule making.; Sincerely, John R. Jamieson, Deputy Federal Highway Administrator