The only integrity a fee-based program has is the relationship between the tire count and the weight of tires processed.

PTE is a passenger tire equivalent.

Processed weight divided by the number of PTE’s processed gives an average weight per PTE.

How to arrive at total PTE’s shown on the report for month being averaged:

With 20 years of experience figuring weights in this manner, the average weight per PTE has been somewhere between 18 and 22 lbs.

The average number would be different if the numbers in the formula are changed, but it makes no difference what numbers you use in the formula, as long as all processors in the program are using the same formula, their averages will be in the same range.

The manifest is important as a paper trail to tract eligible and ineligible tires in the system, but I can tell you that if I wanted to cheat the system, the easiest way is to add tires that are not shown on a manifest or by adding processed rubber from other sources to the mix. This would enable me to increase my total weight and therefore I could increase my request for payments from the fund for the month being reported.

For example, if I wanted to cheat the program, since I know the agency does not check my average weight per tire:

•  I could bring in un-manifested tires to my facility from other states, shred those tires with my manifested tires, and no one would know the difference.

• I could cheat the program by weighing the same load of tire material several times while taking it to market.

• I could cheat the program by having a friend in the trucking business, say someone who hauls sugar cane. I could ask them to weigh their loads and bring me their weight tickets. I could then send those weight tickets in with my report each month for payment.

• I could cheat the program by creating a fictitious number for an inventory that does not exist. I could use this non-existence inventory to create my own average weight per pte after adding un-manifested tires or processed tire material to my monthly request for payment.

I’m sure there are many more ways to cheat the program, but I believe the loop hole being afforded the processors by not being held accountable for average weight per pte, might have the largest negative impact on the fund.

It is important to watch the transporters, the people who bring ineligible tires to the processor, but it’s more important to have a handle on the processor who is the only one in the program that has the ability to collect money from the fund for those ineligible tires.

I am concerned about some of the changes I see being considered. If I wanted to be dishonest with the program, the changes being proposed would not only give me as a processor more ways to cheat the system, but would give me a completive edge over those who participate honestly in the system.

FOR EXAMPLE:

The changes being proposed by the agency need to be made, but I believe the sequence should be changed. Controlling the processors should be implemented first. If the proper checks and balances are put in place, there might not be a need for other changes.

I believe that some of the rule changes will cause illegal dumping. The most cost-effective place to handle a scrap tire is when it is removed from the tire dealer’s store. If tires end up in fields and ditches around Louisiana, it will cause an even greater burden on the fund.

To increase the average weight per PTE by 1lb., add 5% to your 20 lb. average weight.

FOR EXAMPLE:

        100,000 PTE @ 20 lbs. = 2,000,000 lbs.

                            @ 21 lbs. = 2,100,000 lbs.

                                                 100,000 lbs. = 5% = 5000 PTE’S