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    • Tyre noise: response to the EU public consultation (part 1 of 2)

    Response to the public consultation of the European Commission on outline proposals for a new Regulation on Advanced Safety Features and Tyres

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    1. T&E urges the European Commission to propose, without delay, effective standards to cut noise emissions from passenger and commercial vehicle tyres.
    2. Standards must be applied to original equipment, replacement and retreaded tyres.
    3. Regarding the test methodology, the unnecessary 1dB allowance and practice of rounding down must be scrapped immediately upon entry into force of the regulation.
    4. A flat 71 dB(A) noise limit value for all tyres (C1, C2, C3) must be introduced by 2012. The limit values are technically feasible and need not compromise other characteristics. [1]
    5. The Commission proposes higher limit values for wider tyres. We are concerned about the trend in the market towards wider tyres and believe there is no justification to permit further allowances in noise limit values for extra-wide tyres intended for personal or commercial road use. This would constitute yet another exemption for sports utility vehicles (SUVs) used on Europe’s roads. Only so-called ‘special use tyres’ as defined in the consultation document could be granted an exemption of 2 dB(A) provided the definition is clarified to include only those tyres intended exclusively for off-road use.
    6. Outline limit values must be included for a subsequent phase of tightening by at least 2 dB(A) by 2016. A longer term outlook is preferable in order to give certainty to developers, designers and manufacturers, and further stimulate innovation.
    7. To accompany the second phase of tightening in 2016, the Regulation should outline plans to improve the test methodology in order to more accurately reflect real-world driving behaviour and conditions, including test track specifications.
    8. Tyre labelling must include a noise classification, as well as an energy efficiency rating. The labelling scheme must be compulsory from 2010, as a basis for Member States to introduce (fiscal) incentives in order to stimulate progress before 2012.
    9. A procedure and timetable must be foreseen in the Regulation to regularly review the effectiveness of limit values. The review process should ensure that the limit values stimulate technological developments.
    10. T&E insists that test data is made publicly available via the type approval authorities in a centralised and easily accessible and usable database. This should be a mandatory requirement of the regulation in order to enable further improvements to be made in future based on evidence from a larger data sample. Apart from that, the public has the right to know the levels of noise emissions from different tyres, in the same manner as it can already access information on CO2 emissions from new cars.