Comment submitted by Gregg Carpenter, President, Carpenter Metal Solutions, Inc.

To whom it may concern: Regarding the proposed changes to the definition of Solid Waste: Specifically as regards "Scrap Metal” or Metal Recyclables I write to strongly discourage the attempt to regulate and or define Scrap Metal as a hazardous waste. In addition several proposals as I understand them would have catastrophic effects upon US Competitiveness, overall recycle rates, and consumer costs associated with such ridicules bureaucratic red tape. Scrap Metal is a multi hundred Billon dollar commodity that would not be the case if it were in fact a hazardous waste. We have many regulations in place at the state level governing truly hazardous waste, should the EPA move forward with this usurpation of a commodity, it will devastate hundreds of thousands of folks working from a Mom and Pop small 2-3 man machine shop, the entire recycling industry, and on to many large Mills, and Smelters., The cost of raw Steel, Aluminum, and other industrial metals will sky rocket, as everyone will be forced to pass through their new overhead. That is the sickening thing about this entire attempt; it does NOTHING to protect the environment, only creates administrative overhead, and kill value. In grades of metals with very low or marginal value, those industries will be hurt the worse, This would include some of the items we need to recycle the worst, namely Lead Acid Batteries., This proposal, will single handedly cause for the dumping and burying of what will be hundreds of tons of lead. Please do not proceed with this devastating overreach. Gregg Carpenter President Carpenter Metal Solutions, Inc.