Ninety per cent of the 11 million or so scrap tires generated each year in Ontario are “recovered.” This sounds impressive until one looks beneath the surface. Companies that recycle tires are facing tire shortages as their potential feedstock is, in fact, either buried or burned as tire-derived fuel (TDF).
In July 2007 the Recycling Council of Ontario (RCO) facilitated a scrap tire diversion workshop that painted a bleak picture of scrap tire recycling in Ontario. Turns out, the majority of scrap tires collected in the province are sent to the end-uses that charge the lowest tip fees to receive tires. Typically this means tires are sent to landfill whole (amazingly, there is no ban on sending scrap tires to landfill in Ontario) or they’re shredded into a couple of pieces and used as “daily landfill cover.” Alternatively, they’re exported out of the province for burning as TDF.
Meanwhile, a number of Ontario rubber recycling companies that produce value-added products (e.g., automotive moldings, blast mats, playground surfacing, rubberized asphalt, roof shingles, etc.) are struggling. Their value-added production is inherently more costly than the competing disposal alternatives.
If you think government policy encourage the 3Rs hierarchy for tires, you’re wrong. The government is making it easier to burn the tires.
Lafarge plans to burn TDF at its cement plant in Bath, Ontario and received approval to do so in late 2006. Local community groups, ENGOs and the rock band The Tragically Hip won the right to appeal Lafarge’s approval. Lafarge took steps to challenge the validity of a hearing in early September 2007, but the case is nonetheless proceeding. The outcome is far from certain.
Lafarge’s certificate of approval would allow it to burn the equivalent of 2.5 million tires annually. A number of commentators in the RCO workshop noted that the economics of TDF for cement production are extremely favorable (as it displaces more costly fuels such as natural gas and coal); the concern is that over time TDF will become the sole use of scrap tires in Ontario, and the tire recyclers will be put out of business.
So, what’s the alternative?
Recognizing the superior environmental and energy lifecycle of rubber-to-rubber recycling, a number of jurisdictions with scrap tire stewardship programs are emphasizing higher-order uses for recovered scrap rubber.
For instance, the European Tyre and Rubber Manufacturer’s Association (ETRMA) reporting in July 2007 that of the 3.2 million tonnes of used tires generated in the EU in 2006, 12 per cent were retreaded (i.e., reused) while 32 per cent were sent to TDF. The association noted that the EU-wide landfill ban has driven the EU rubber recycling rate to 34 per cent — an increase of 23 per cent above the last decade.
The ETRMA notes that the increase in recycling is due to producer responsibility rgimes by which manufacturers have organized, “…ecologically sound recovery treatment of end-of-life tyres through the most economical solutions. They are able to develop a high-level knowledge of technologies and they invest in R&D programs to develop new sustainable recovery routes.”
In contrast, Ontario continues to flounder.
Consider the period between 1989 and 1993. Ontario saw the introduction of a $5/tire tax in 1989, a 14 million tire stockpile fire in 1990 in Hagersville, then the rescinding of the tire tax in 1993. Of the approximately $155 million collected through the tire tax, only $6 to $8 million was used to promote tire recycling.
In 2005, Ontario Tire Stewardship (OTS) — a stewardship organization led by the Rubber Association of Canada and mass merchants — proposed charging a $3.65 “fee” on tire consumers, to be levied under a tire stewardship plan. The OTS plan would have seen just four per cent of the total $37.6 million in fees collected annually from tire consumers used to provide financial incentives to rubber recyclers. The proposed fee underpinning the plan was found to be unconstitutional (it was deemed to be a tax) and was withdrawn by Waste Diversion Ontario for “further work.”
During the RCO workshop a number of recurring themes arose related to preventing tire stockpiles and the promotion of higher-order tire recycling. These included a province-wide ban on landfill of scrap tires and building on the effective provincial recovery system through a system of financial incentives for recycling scrap tires. Some suggested that end-users of rubber products (e.g., municipalities that pave roads, automobile manufacturers requiring rubber components or home consumers buying shingles, mats, etc.) be given incentives to buy recycled (thus partially driving demand and partially offsetting higher production costs). Others suggested that recyclers be given direct tonnage-based financial incentives to be able to better compete for scrap tires. Some suggested a system for generating revenues to fund the financial incentives.
Again, opinion differed, with some parties favoring manufacturer or producer responsibility whereby brand owners and first importers of tires cover financial incentive system costs, and others calling for a dedicated fixed per-tire surcharge levied on each scrap tire collected from consumers by tire retailers.
The policy elements are simple; what’s missing is the political will to make sure that Ontario scrap tire recyclers are given the opportunity to squeeze the most environmental and economic value of each scrap tire generated in the province. Let’s hope the next stewardship plan for scrap tires achieves that, and not just burning.
Usman Valiante is principal of the Corporate Policy Group in Orangeville, Ontario. Contact Usman at email@example.com