8 Recommendations
The following recommendations are based on the proceeding evaluation of:
- the tyre sector in New Zealand - in particular waste disposal, and the environmental and social issues arising from this;
- potential alternative uses of end-of life tyres and barriers to their implementation;
- the performance of the existing TyreTrack scheme - in terms of specific objectives and overall policy goals;
- potential future scenarios (status quo, expanded scheme, and business-to-business arrangements).
At a general level, we recommend the existing TyreTrack scheme be expanded, with further regulatory intervention and economic tools used to encourage the sector to implement commercially viable, alternative end-uses for tyres. We recommend the Ministry for the Environment take leadership on the issue of tyre disposal in New Zealand by developing a scheme which incentivises tyre reuse (essentially a tyre recycling scheme). We are currently at risk of leaving an environmentally unacceptable legacy for the next generation as large volumes of tyres accumulate in our landfills. This situation is exacerbated by the reality that feasible alternative end-uses already exist, and more are continually being developed.
Our specific recommendations are provided as follows. The objectives of these recommendations are to advise on "next steps" in the development of well-designed government support and fiscal or regulatory intervention to resolve the issue of EoL tyres that could be effectively used for alternative purposes. Note that all of the recommendations relate to one, joint sector scheme as opposed to multiple arrangements. The clear message communicated by the tyre sector group was their desire for a collective approach to the issue of used tyres.
8.1 Recommendation 1
The Ministry for the Environment apply the currently preferred product stewardship policy to the tyre sector by developing regulatory and fiscal intervention mechanisms to:
- establish mandatory of TyreTrack, reporting all tyre movements;
- apply an ADF to tyres at point of manufacture and import.
Further we recommend:
1. the revenue from the ADF be managed by the expanded TyreTrack administration on behalf of the industry in general, and specifically for the tyre brands and vehicle importers;
2. ADF revenue be used to develop sustainable end-uses for tyre-derived products.
This recommendation cannot be implemented without further detailed, economic evaluation of the proposed fiscal and regulatory intervention.
This study has allowed for a broad-brush evaluation of the myriad of issues arising from what to do with tyres once they have reached their EoL. It is intended primarily to feed into product stewardship policy development. The above recommendation is for a fiscal intervention to rectify a market that is currently failing due to inappropriate costing of externalities (environmental effects of disposal). This intervention should be examined in more detail.
The following questions have not yet been addressed, and will need to be before the Ministry for the Environment proceeds with the fiscal intervention.
1. What should be the value of the tyre levy?
2. How should a tyre levy be collected?
3. What are the "flow-on" effects in terms of specific costs (eg, increased tyre prices) and market effects (eg, the likely decline in commercially viable small retailers)?
4. How should the funds be administered and allocated?
5. What specific market objectives should the tyre levy induce?
6. How will payment of a tyre levy be enforced and what are the costs?
8.2 Recommendation 2
The Ministry for the Environment carry out further studies to evaluate the implementation of a WDF. These studies should:
- further evaluate the scope of the WDF in terms of products that it applies to;
- determine the organisational infrastructure required to support the WDF (eg, expanding the jurisdiction of a current body such as the Waste Management Institute);
- quantify the potential "market ramification" risks (eg, exacerbating illegal dumping) and ensure the scheme is designed to mitigate these.
As described above, the adoption of the WDF has the potential, which must be guarded against, to exacerbate the existing problem of illegal tyre dumping. The Ministry for the Environment should actively encourage, educate and support local councils to develop bylaws through the Local Government Act to provide for significant penalties for illegal dumping.
Note that the revenue arising from the WDF will gradually decrease over time as fewer tyres are sent to landfill. This decrease should parallel the decrease in enforcement costs discussed above.
8.3 Recommendation 3
The Ministry for the Environment continue to provide support for local and regional councils to limit the illegal dumping of tyres. Mechanisms for this support include:
- enforcement against illegal tyre dumping through the Resource Management Act;
- evaluating the effectiveness of the currently adopted Auckland-based (Waitakere and North Shore) schemes to register waste collectors and how this could be more broadly applied across the country;
- the use of district plans to restrict the numbers of tyres that might be stored on private properties;
- more effective mechanisms for policing and preventing tyre dumping on public and private property, including tighter penalties under the Litter Act;
- encouraging local councils to use existing district plan provisions and environmental field officers to investigate possible illegal tyre dumps and, where possible, prosecute the offenders.
8.4 Recommendation 4
The Ministry for the Environment continue to support development of viable alternative end-uses for tyres. This includes:
- assistance for regional councils on interpretation of the RMA to ensure that the focus is on environmental effects (including atmospheric emissions) rather than prescribing material and energy inputs to processes (eg, the situation at Pacific Steel where new resource consents are required for burning tyres, despite no predicted increase in atmospheric emissions);
- assistance for additional research into the environmental effects of alternative end-uses, including burning tyres as an energy source;
- evaluating further the potential for ongoing use of tyres on farms, as silage pile covers, and therefore the available "resource" for other uses;
- keeping abreast of, and where possible assisting, New Zealand-based developments of alternative end-uses for tyres.
8.5 Recommendation 5
The Ministry for the Environment carry out additional investigations into a possible Product Responsibility Authority which could take the form of an expanded Environmental Choice organisation. The role of this body would be to provide umbrella support across all sectors for improving the environmental performance of products over all life cycle phases including manufacture, use and disposal. It would:
- provide education on all aspects of product environmental performance (eg, the roles of consumers, retailers and landfill operators in adopting environmentally responsible tyre disposal methods);
- coordinate information exchange/learnings/best practice amongst the different sector product stewardship schemes (given the common objective to divert waste from landfill there would be significant common ground to be shared amongst participants on what works and what doesn't etc);
- carry out research into life-cycle impacts of different products in New Zealand and continue to develop specifications for product environmental labels;
- provide support for both government (eg, Govt3) and private sector product procurement initiatives designed to selectively purchase environmentally preferable products.
8.6 Recommendation 6
The Ministry for the Environment continue to work with landfill operators, including private sector operators such as Waste Management, and local councils to develop guidelines for storage and disposal of tyres which are entering landfills.
8.7 Recommendation 7
The Ministry for the Environment support environmentally responsible disposal of tyres, through government procurement programmes such as Govt3 which would allow for preferential purchase from tyre retailers who are using TyreTrack.
