Did you know that your $3 eco-tax for tires sometimes pays for burning those tires? Did you think BC was taking a lead in Product Stewardship and Recycling? Wasn’t the whole idea of the 1991 tire fee to prevent tire fires? Confused? Welcome to environmental policy making in the New Era. It’s pretty much like environmental policy making in every other era.
by Delores Broten
Every time you buy a new tire in British Columbia, you pay a $3 “ecofee” to help deal with those tires when they get old. In the bad old days before the first of BC’s product stewardship experiments, the Financial Incentives for Recycling Scrap Tires (FIRST) program, piles of tires were accumulating everywhere, in and out of landfills. When those tires caught fire, the fires were almost impossible to put out, smouldering for months, layering black smoke and invisible toxics over neighbourhoods. The other main use for old tires was to toss them into logging slash piles or garbage dump burns to sustain the fire. Intentional open air burning was the fate of three-quarters of old tires even for a few years after the FIRST program was introduced.
But open burning of tires releases a wide range of unhealthy air pollutants, from dioxins, benzene and Polyaromatic Hydrocarbons (PAHs) to metals like chromium, mercury and cadmium. By some lucky stroke, these contaminants apparently disappear when the tires are burned more efficiently in cement kilns or pulp mills, with a permit from the Pollution Prevention branch of the Ministry of Water Land and Air Protection (MWLAP).
Does this mean the permit makes a difference? Or maybe the testing isn’t very thorough, maybe the mills’ air pollution control equipment actually works, or maybe there is just too much money at stake.
But this story is supposed to be about recycling. In BC, the massively successful FIRST program now diverts about 90% of scrap tires into recycling. It uses the $3 eco-fee to subsidize the transportation of old tires to recycling plants. FIRST also pays a bonus to recycling companies for the creation of Tire Derived Products (TDP) — blasting mats, boot trays, roofi ng shingles, composters — and a smaller bonus for tires which are processed for burning as Tire Derived Fuel (TDF). That includes 70 cents each for the whole tires stripped of some metal and tossed into the kiln at Tilbury Cement (now Lehigh Northwest).
FIRST costs less to run than it brings in, and the balance goes into general revenue. On its website MWLAP says the money is used to fund its programs, but provides no dollar fi gure for income. Since the tire fee is simply returned by retailers with the sales tax, Rosemary Sutton, administrator of the program at IBM Business Consulting, says no one really knows the income total, except by estimates based on returned tires. One thing, though, is troubling. The more tires are burnt and the less recycled, the more money for general revenue.
There’s a serious side to this story about tires and levies and MWLAP. As natural gas prices rise, BC’s pulp mills are aggressively pursuing alternative fuels which will cut their costs. It’s an environmental bonus for the mills that the addition of coal or tires or railway ties with or without pentachlorophenol, to the mix of wet sludge and wood waste in their boilers creates more stable, and hotter fi res, with potentially lower dioxin emissions.
BC pulp mills need a huge amount of energy, some of which they generate by burning wood waste. The mills’ appetite for rubber to burn could pose a serious threat to BC’s tire recycling companies, which convert about 85% of scrap tires to other products under the shelter of the FIRST program. If the pulp mills get their way, British Columbia will either have to import tires to burn, and/or Western Rubber and other smaller companies will be deprived of their stock, which is already in short supply compared to the companies markets.
In a small scale and very limited three month trial last year, the Powell River mill burned 1490 tonnes of tire chips. In full time full scale burning, one mill alone could consume the TDF from close to a million tires a year. The BC “harvest” of recycled tires in 2002 was 3.5 million tires or about 28,700 tonnes. If BC pulp mills are going to burn tires, they will need to import millions of tires, which are guaranteed Free Trade under NAFTA as a fuel.
According to Helen Spiegelman, who sat on the Advisory Committee for the FIRST program, the picture is further complicated because Californian companies complain that Western Rubber puts up unfair, subsidized competition. They cannot supply rubber from recycled tires for rubberized asphalt highway material as cheaply. FIRST subsidies from the tire levy are provided for transportation and also for rendering of the tires into cheap fuel.
For years BC has boasted of its progressive pollution prevention hierarchy policy – the Five Rs:
1. Reduce at source
2. Reuse
3. Recycle
4. Recover materials and/or energy
5. Manage residuals in an environmentally responsible manner.
However, when activists challenged the Powell River mill’s permit for tire trials, citing that hierarchy, the offi cial in charge of the program, Duncan Ferguson, told the Environmental Appeal Board that TDP, rubber recovered from tires for products, paid a higher credit to processors than TDF, rubber for fuel, because it cost more to make.
He added that TDP might be considered material recovery, equal to TDF. This opens the door to demotion of tire recycling in the Five R hierarchy.
To add to the confusion, the Ministry has no policy that requires the regional offi cers writing the pollution permits to consider the Five R recycling hierarchy. Policy from one department of MWLAP does not necessarily have any impact on the actions of another. As Spiegelman puts it, without some policy consistency, we could easily wind up “burning the furniture to heat the house,” and paying for the privilege too.
On top of all that, the future of FIRST itself is in upheaval. The Ministry has introduced the BC Industry Product Stewardship Business Plan for 2002-2005 with the goal that producers and users should fi nance waste management, rather than the general taxpayer. The Plan enunciates four Key Principles, although with few specifi cs on implementation, auditing or enforcement:
• Producer/user responsibility
• Level playing fi eld — for all brand owners, and access to collection facilities for all consumers
• Results-based — cost effective, measurable and innovative toward pollution prevention with the onus on the producer
• Transparency and accountability — “Industry is accountable to both government and consumers for environmental outcomes and allocation of revenue from fees/ levies.”
The plan notes that the FIRST program fails on all four counts, despite its $3 user-fee and its enormous success in keeping tires out of the landfi ll. Perhaps it is that success which has led to the Ministry’s failure to “replace the FIRST program with an industry product stewardship program…. by March 31, 2003.”
Duncan Ferguson says that the reorganization is the subject of “ongoing discussion with government at high levels,” as well as consultation with the Retail Council of BC and the Rubber Associationof Canada. However no conclusion about a new model has been reached, although government is determined “to devolve” the FIRST program.
In the meantime, Minister Joyce Murray has announced the addition of electronic waste to the Product Stewardship targets.
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[From WS January/February 2004]