To Members of the Environmental Committees—Senate and House

Re: The Waste Tire Fund

Allowing processors to weigh tires received at their facility, as an alterative to counting tires, will in our opinion remove the only checks and balances this program now has. Weighing tires gives processors a blank check. In our opinion allowing a processor to weigh tires is like saying here’s a key to the bank, the code to the alarm system and the combination to the vault, take whatever you want.

Mr. Thomas Bickham, Undersecretary of the DEQ and Senator Cain have both said the integrity of the manifest will have to be maintained. To us this means they both know tire counts are an important part of this program. We know the DEQ must have verified tire counts in order to maintain the programs integrity. We believe the integrity of the manifest can only be maintained if the tire counts signed for by the tire dealer are verified when they are received at the processors facility.

Here is one example of why weighing tires removes the DEQ’s ability to identify problems:

We send our crew out to pick up tires with a trailer that has the capacity for 1000 tires. Our crew makes five stops that produce five manifests, and picks up a total of 500 tires. They then go by a warehouse where non-program tires from Texas are kept. They load 500 Texas tires. The trailer is then weighed and that weight ticket is attached to the five manifests as the official receiving document for those five manifest. My question is what checks and balances are used to catch the 500 non-program tires from Texas that were just added to the program? In my opinion there would not be a way to catch this fraud without verifying the tire count.

As we have said the solutions to fixing the problems with this program are in fact simple but can be made to look complicated. In our opinion when a processor says that snakes in tires causes his people not to be able to count tires is in fact an attempt to complicate the issues and may cause a smoke screen that attempts to cover the real agenda being pursued by its presenter.

If exemptions are revoked, tire counts are verified, actual inventories are verified by continued visits to each processor facility by the DEQ on the first day of each month, timely audits of the processors monthly request for payment are continued and all processors report the same, no changes will be necessary to make this program work.

Any attempt to change the rules to make it possible to weigh tires received at a processors facility in the place of verifying tire counts will have an adverse effect on this program and will put in jeopardy any stability that could be achieved.

We hope you will vote against any bill that gives the processors an option between weighing tires or counting tires.

Thank you in advance for your help with this matter.

Bill Vincent, CEO

Colt, Inc.

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