Comment submitted by David Coleman, Bridgestone Retail Operations, LLC

Comment on Proposed Rule for Identification of Non-Hazardous Secondary Materials That Are Solid Waste; 75 Fed. Reg. 107; June 4, 2010; Docket No. EPA-HQ-RCRA-2008-0329 Have auto work done at a neighborhood tire battery and automotive service business which could possibly not provide service due to this rule. The economic turn down has hurt my community, parent company Bridgestone, and myself and family. Rule would raise costs and negatively impact ability to properly handle scrap tires by hurting established markets. We treat our scrap tires as a useful commodity, assuring that they are carefully stored, and having them delivered into beneficial end use markets. Since used oil can be treated as a secondary fuel, there is no reason that scrap tires also could not be treated similarly. Finally, the management approach originally described in the EPA’s Advanced Notice of Proposed Rulemaking is the approach the Agency should take. Thank you,