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Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. Does SJCEHD's August 19, 2010 response apply to Tuff Boy under its current <br /> classification as a non-tire dealer? <br /> Further comments based on discussion held on October 19, 2010. <br /> a. SJCEHD confirmed that the storage of new tires is acceptable without limitations. <br /> 8. Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> As a tire dealer, will SJCEHD allow "maintenance ready used tires" to be row stacked <br /> into a portable over-the-road-highway van trailer as detailed on drawing #2 attached to <br /> reduce the chance of theft or vandalism? <br /> SJCEHD response to Tuff Boy on August 19, 2010. <br /> Tuff Boy will be allowed to stack "maintenance ready used tire" in rows that are not more <br /> than two rows wide in over-tne-road-highway trailers. However, in order for such tires to <br /> not be counted as part of the 1,500 waste tire limit, (1) the tires must stacked as just <br /> described and (2) be ready for resale which includes having the trailer being easily <br /> accessible, having sufficient lighting for inspection of each tire, and having a safe <br /> method of access and egress during normal business hours. <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. As part of the Tuff Boy letter sent to SJCEHD on August 11, 2010, two (2) drawings <br /> were enclosed demonstrating the method of storage. One drawing shows an 18" <br /> aisle down the center of a portable over-the-road-highway van trailer to access and <br /> view the stored tires in the van. Will this method of storage satisfy the storage <br /> requirements as defined by T14CCR Sections 17353 and 17354? <br /> Further comments based on discussion held on October 19, 2010. <br /> a. On August 11, 2010, Tuff Boy submitted two (2) drawings to SJCEHD demonstrating <br /> two (2) different methods of storing good useable tires. SJCEHD commented that <br /> the two (2) proposed methods of storing used tires are acceptable with certain <br /> limitations as detailed in the "discussion of Tuff Boy Goals" <br /> section of this letter. <br /> 9. Tuff Boy question submitted to SJCEHD on August 11, 2010. <br /> Since Tuff Boy does not expect to ever have over 250 true "waste" tires staged for <br /> disposal on site at any one time, is there any other business designation that might more <br /> appropriately fit Tuff Boy's business operation rather than the "tire dealer category" <br /> proposed by SHCEHD? <br /> SJCEHD response to Tuff Boy on August 19, 2010. <br /> The EHD has the understanding that Tuff Boy Trailer Sales Inc. sells tire as a normal <br /> part of their business. That is why the classification of "tire dealer" most appropriately <br /> fits the business operation of Tuff Boy as it pertains to tires. <br /> Additional comments/questions by Tuff Boy submitted to SJCEHD on <br /> October 01, 2010: <br /> a. Although Tuff Boy does indeed sell tires as part of its normal business, it is not the <br /> primary part of its business. It may be important to note that the majority portion of <br /> the "maintenance ready used tires" anticipated to be stored on site are not available <br /> for sale. In fact, a significant quantity of "maintenance ready used tires" will be kept <br /> on hand and serve as the rotating service inventory for customer-owned trailer fleets <br /> totaling 2,500 trailers and under contract with Tuff Boy to maintain. <br /> 6 <br />