Northern CA Fire Mechanics Associaton - Comment

Twimc: The proposal for tire regulation updates is long overdue. That being said, I note a crucial item that needs to be addressed. Your reference to "Commercial Vehicles" requires clarification. Governmental agencies throughout the Country have self determined that all Governmental vehicles are not for Commercial use and therefore are not considered Commercial Vehicles and not subject to the regulations. I recommend that you expand the wording to include: For the purposes of this Regulation, alll vehicles operating within the confines of the US borders (50 states) that meet the weight qualifications of "Class" of vehicle be considered meeting "Commercial Vehicle" standards. Consider a single 2-axle chassis with a GVWR of 40,000# traversing the roadways of the US at breakneck speeds and severe actions of acceleration, braking and steering running on tires that agencies consider exempt. A simple clarification as to ALL vehicles within the 10K and above rating are considered "Commercial Vehicles" for the purposes of this Regulation. Vocation need not be mentioned. Respectfully submitted, Anthony D. Bulygo California Fire Chief's Association Northern Mechanics Section Northern CA Fire Mechanics Association Staff Member