Summary of Recommendations
We recommend that the Government implement the following 'core', high priority improvements as soon as possible, and regardless of which options for further strengthening the regime (if any) are adopted:
- Develop recommended standards for tyre piles on private land and encourage councils to include them in their District Plans.
- Review the Litter Act:
- Is it the right piece of legislation to use to stop illegal dumping?
- What level should penalties be set at?
- Is there a need for a new offence to be defined in relation to the dumping of large quantities of waste?
- Discuss with councils how to fund the removal of tyres from public land, and
from private land where it is impractical to pursue the landowner.
- Is a central government funding warranted?
- Check whether landfills are refusing to accept whole tyres (rather than arranging to quarter them themselves). If necessary, encourage councils to avoid this.
- Encourage industry to establish a 'quality mark' regime or something similar for collection, transformation and storage activities.
- Encourage councils to introduce tyre mono-fills.
In our view, these changes will go well down the track to addressing the weaknesses we have identified in the current EOL tyre management regime.
But actions to further strengthen the storage and disposal regime may still be warranted. If the Government chooses to do so, we would recommend that it initially pursue either:
- Option B: Government subsidisation of collection, transformation and disposal activities; or
- Option D: a voluntary industry approach.
If these prove ineffective we would then suggest that a formal extended producer responsibility scheme be considered.
Lastly, the Government may also want to do more to encourage greater recycling of EOL tyres. We recommend that a number of modest steps be taken as soon as possible:
- Continue to identify possible recyclers and recycling options.
- Encourage promising recyclers to pursue existing sources of funding and support (such as through FRST and NZTE.
- Undertake further analysis of the likely patterns of supply and demand for EOL tyres, and determine whether there is a need for intervention to ensure security of supply for the most promising recycling options.
- Work to gain a greater understanding of the factors that make the most promising recycling options uneconomic, and the extent of subsidy that would be needed.
- Undertake an assessment to determine whether subsidisation of recycling activities is likely to provide a net national benefit.
If the Government chooses to subsidise recycling activity, we recommend that it tender the right to access any subsidy against criteria relating to each project's financial viability and the broader economic, environmental and social benefits it offers.
