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00For your information, s are typically 14/32 tread thickne% can be legally operated in California until they wear down to 2/32 tread thickness. In addition, once tires have reached a tread'ffiickne�s of 2/32 thick, those tires can be sent back to a tire supplier, who will install a new 14/3 : retread top cap onto the original worn down tire casing It is also important to note that tires and retreading are expensive! To maximize the life of a tire, regular inspections are necessary. This involves analyzing air pressures, measuring tire diameters and tread thicknesses, and looking for irregular wear patterns that are beginning to develop on the tire. Following this analysis, a typical maintenance facility, utilizing best sustainable work practices, will rotate tires as necessary to extend tire life and minimize waste. This involves the rotation of tire inventories that are mounted on wheels. At any one time, there are a number of tires/wheels that are in rotation for reinstallation on trucks, trailers and dollies. When a new set of tires and wheels are installer on a trailer set (typically twelve per set) the majority of the tires and wheels being removed are scheduled to be reinstalled on a different set of trailers or similar equipment. In a typical scenario, the twelve tires/wheels removed are categorized by size, sorted into groups based on radial or bias ply construction, rated by remaining tread depth, tire height and other characteristics making them suitable for reinstallation. Tires that fail to meet reinstallation standards are dismounted from the wheel and deemed to be waste tires or returned to a tire supplier for retreading. The waste tires are stored for pick up by an authorized tire recycler. The reusable tire and wheel assembles are sorted and matched to other tires that meet the same specifications These tires are reinstalled on other trailers. Naturally, as tires are assigned to a trailer, the assignment is based upon the expected usage of the trailer. More aggressive usage would warrant new tires, less aggressive usage would warrant tires that have been previously used. Many of the marginal tires are reinstalled on equipment destined for an off-road or low mileage use application. The tire inventory is managed to maximize the lifetime use of the tread. Nothing is wasted, and when a tire completes this cycle, it is truly a waste tire. In this effort, Tuff Boy practices careful conservation of resources that will limit the amount of waste generated resulting from the tire operation. Currently, Tuff Boy Sales services fleets totaling nearly 2.500 trailers, utilizing in excess of 12,500 tires. During peak season (such as the day that Mr. Escotto visited our facility) Tuff Boy may be in the midst of rotating, matching and reinstalling tires on as much as 10% of the serviced fleets. During the off season, the number of tires/wheels in the inventory match/rotation program would be less. However, at any one time, the number of true waste tires stands at a very small percentage of the tires in the tire rotating inventory. Indeed the number of true waste tires would not exceed a maximum of 250 during the peak season. Having provided this description of the, Tuff Boy Sales, Inc. operation, I believe that you can understand that your classification of all tires in our facility as "waste tires" is flawed. It is Tuff Boy's wish and expectation that armed with this description of our operation, the SJCEHD, would re-inspect our facility to determine which tires are destined for reinstallation and which tires are truly waste tires. 2