Publications

Table of Contents

• Introduction
• Summing Up
  • Major Policy Options
  • Complementary Policy Options
• General comments by stakeholders
• Take Back Option
• Waste Avoidance Options
  • Waste Avoidance Option 1: Purchase Decisions
  • Waste Avoidance Option 2: Tyre Maintenance
  • Waste Avoidance Option 3: Importation of Used Tyres
• Reducing Inappropriate Disposal
  • Reducing Inappropriate Disposal Option 1: Tracking Scheme
  • Reducing Inappropriate Disposal Option 2: National Uniform Regulation
  • Reducing Inappropriate Disposal Option 3: Payment for Waste Tyres at Point of Receival
  • Reducing Inappropriate Disposal Option 4: Environmental Rating Scheme for Tyre Dealers
• Improved Value for Waste Tyres - Managing the Resource (ie the supply side)
  • Managing the Resource Option 1: Legislative Support for Tied Agreements
  • Managing the Resource Option 2: Centralised Market Scheme
  • Managing the Resource Sub-Option 2.1: Free Market Operation
  • Managing the Resource Sub-Option 2.2: Manager retains strict control
  • Managing the Resource Sub-Option 2.3: Sale of Waste Tyres from a Managed Pool
• Improved Value for Waste Tyres - 'Industry Assistance' (ie the Demand Side)
  • Industry Assistance Option 1: Direct Regulation in Regard to Products
  • Industry Assistance Option 2: Direct Assistance to Recyclers
  • Industry Assistance Option 3: Controls on landfill
  • Industry Assistance Option 4: Market Promotion
  • Industry Assistance Option 5: Government Purchasing Policies
  • Industry Assistance Option 6: Funding for Research and Development
• Funding Options
  • Funding Option 1: Disbursements from Consolidated Fund (Government pays)
  • Funding Option 2: Levy (at point of manufacture/import)
• Other Major Issues or Options Raised
• Appendix A
  • A National Approach to Waste Tyres - Invitation for Comment
• Appendix B
  • Submissions Received

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Introduction

This document is a summary of industry, community and government submissions on the consultant's report 'A National Approach to Waste Tyres' prepared by Atech Group Pty Ltd. The report was released for broad consultation in July 2001. Over 230 hard copies of the report were provided to stakeholders with copies also available on the Environment Australia website.

The report investigated and analysed the scope and nature of the waste tyre problem in Australia and assessed options to address the problem. The report was in two parts:

• Part 1 was a comprehensive overview of the tyre manufacturing and import sector, including a quantification of the number of waste tyres being generated annually in Australia. Part 1 also examined various re-use, recycling and disposal options.
• Part 2 examined various options for addressing the waste tyre problem nationally. In particular it addressed issues such as waste avoidance, reducing inappropriate tyre disposal, improving value from waste tyres and resource security for re-use and recycling options.

A copy of the Invitation for Comment and Guide to Submissions is included at Appendix A. A list of submissions received is at Appendix B.

Submissions on Part 2 of the report are the focus of the current document. Comments have been grouped according to the policy option being considered. Some submissions were quite lengthy and went into fine detail on design issues on various options. While such design issues are important, at this time we have focussed on stakeholder views on options and other issues that are immediately relevant at this stage of the process and have left the detailed design issues for later consideration.

The comments and views expressed in submissions will be taken into account in developing any national policy approach.

The views and opinions in this document do not necessarily reflect those of the Commonwealth Government or the Minister for the Environment and Heritage.

Any enquiries in relation to the current document can be made to Leigh West on (02) 6274 1678 or leigh.west@environment.gov.au. Copies of the consultant's report 'A National Approach to Waste Tyres' and further copies of the current document are available at www.ea.gov.au/industry/waste/awr/tyres.html or in hard copy from Leigh West.

Summing Up

For the most part stakeholders supported the need for a national approach to address the waste tyre problem and most argued that a product stewardship/extended producer responsibility approach was appropriate. There are several key issues that were identified in the consultancy report 'A National Approach to Waste Tyres' and the submissions received. These include:

• Access to waste tyre resources for various re-use/re-processing applications;
• Resource security for excisting and emerging re-use/re-processing applications;
• Supply of waste tyres nationally is significantly greater than demand (hence a significant quantity is going to landfill or being disposed of inappropriately);
• The need to improve the value of waste tyres; and
• Particular problems relating to waste tyres in remote and regional areas including agricultural, mining and earthmoving tyres.

These key issues were considered in formulating the various policy options discussed and analysed in the consultancy report.

It can be argued that there are two main categories of options to address the waste tyre issue. That is,

• Major policy options that are designed to have a significant and broad impact on the waste tyre problem; and
• Complementary policy options targeted at specific aspects of the waste tyre problem (eg programs targeting tyre maintenance).

Major Policy Options

The major policy options that have been identified and discussed to date are:

• A take-back requirement for producers and importers;
• A levy/benefit scheme - a levy is either imposed at the point of manufacture/import or at the point of sale and the proceeds fund programs which may include a scheme where benefits are paid to those involved in the waste tyre industry (eg recyclers, retreaders, waste tyre collectors/transporters etc);
• A centralised market scheme or payment at point of receival scheme (which may be funded from a levy or otherwise); and
• A tradeable certificate scheme (which has not yet been considered in detail).

In each case detailed design work would need to be undertaken before any policy was implemented.

Of these options a levy/benefit scheme attracted the most comment and support from stakeholders making submissions. A take back scheme had some support whilst centralised market schemes attracted the most opposition on the basis of potentially setting up a monopoly situation.

Complementary Policy Options

There were various complementary policy options canvassed in the consultancy report. Further work would be required to determine if individual options are likely to be effective, are feasible and also represent value for money. Readers should refer to individual options for a summing up of stakeholder views.

General comments by stakeholders

Summary of Submissions:

• Most submissions were generally supportive of the need for a national approach but there was a strong message that differences between and individual characteristics of jurisdictions needed to be considered and taken into account.
• A product stewardship approach was explicitly favoured by some.
• Recognition that the improved value of waste tyres and addressing resource security should be key considerations in any policy approach.
• Of particular importance is the differing views on 'waste to energy/co-processing' applications versus other (as argued in some submissions) 'higher' value uses. This debate will be of critical importance in designing policy instruments.

Submissions Received:

Submission	Comments
National Approach
Various	Submission explicitly supported the need for a national approach.
EPA Victoria	A national system is unlikely to be beneficial primarily due to different circumstances between States and Territories.
EPA Victoria	Report fails to demonstrate how proposed national options would result in improved environmental outcomes compared with excisting State based schemes or industry initiatives.
Eco Waste	A national approach, co ordinated and managed by the Commonwealth via supporting legislation in the jurisdictions is essential.
DEP WA	Generally supportive of a national approach because of cost, legislative and resource benefits derived from uniformity. However, some options in the report are more conducive to a national approach than others.
Rrecycle Aust.	National approach is required to stop transporting the problem from one area or State/Territory to another.
Total Environment Centre	A national approach is suitable if it embraces best practice and not the lowest common denominator.
NSW Waste Boards	A national approach would provide direction and consistency to the country as a whole within a common market territory. Would maintain a level playing field for Australian industry.
Rrecycle Aust.	Comprehensive report addressing an issue that needs urgent attention by all levels of government and industry and for all parties to put aside their self interests.
Devote (Encore)	Initiatives should be driven, administered and funded by the Commonwealth Government.
Geocycle	Implementation of any national approach must be managed at the State/Territory level so that regional issues can be properly addressed.
NSW Waste Boards	Reuse and recycling opportunities may be best handled on a State/Territory basis to reflect regional and local market conditions and issues.
DEP WA	Need to be mindful of differences between States and Territories in terms of population density, size and current tyre waste management strategies.
NSW Waste Boards	Monitoring of any national approach may best be handled by State/Territory entities while enforcement for national companies may best be handled at the national level on the advice and data provided by States/Territories.
EPA Victoria	Different State and Territory regimes (as set out in part 1) are not considered where policy options are explored. Limited information on the possible impacts of proposed policy options on States and Territories.
ATMA	State and Territory regulators have worked cooperatively with industry to facilitate commercial solutions. Any Commonwealth initiatives should be tailored to ensure this cooperation continues.

Submission	Comments
Local Government issues
Stanthorpe Council	Council concerns about large and growing stockpiles and how to eliminate them.
LGA Qld	Local Government bears considerable burden with waste tyres. Local Government (esp in rural and regional areas) does not have the resources to effectively dispose of huge stockpiles of waste tyres currently at landfill sites. Financial assistance is required.

Submission	Comments
General Strategies
Brisbane City Council	Three major issues need to be addressed: Develop manufacturing/processing industry for recycled rubber products Guarantee supply of waste resource for recyclers/re-users Increase demand for recycled products
Devote (Encore)	Key objectives in order of priority should be: Elimination of illegal and inappropriate disposal of tyres Provide stimulus for expanding recycling activities by way of market development assistance. Defray costs of producing recycled tyre products and cost of accessing markets. Encourage waste avoidance through public awareness.
South Pacific Tyres	Considerations to be addressed: Lack of a legislated national approach Low value of waste tyres which will continually influence the ability to move them around to areas where they can be used Imported used tyres
ACT No Waste	Industry operated levy scheme with appropriate support from government appears the most appropriate approach.
Cement Industry Federation	Given complexity of the waste tyre issue, a range of policy options is needed.
Devote (Encore)	A combination of initiatives is necessary to deliver desired outcomes.
Discriminex	This submission refers generally to a three concept approach to dealing with waste tyres but was not detailed because of concerns about intellectual property.
Cement Industry Federation	Vital that recovery operators, recyclers and re-processors are able to re-capture the full cost of their capital investments and ongoing operating costs.
NSW Waste Boards	Does not support the establishment of any controlling body (either government, industry or manufacturer based) that would establish a monopoly position in the marketing or physical control of tyres.
Geocycle	Retail markets tend to allow a limited level of recycled materials to be blended with virgin materials. If there is high level of recovery of wastes there is a potential for creating stockpiles of partially treated wastes.
Rrecycle Aust.	Long term strategy is required (ie 20 years or more) and direct responsibility to all participants, including the originators being the petrochemical industry.
Rrecycle Aust.	Approach should not be limited to tyres. It should also address thermoplastics (plastics industry).
Total Environment Centre	Voluntary participation by the tyre industry in NSW wasn't successful. Was also under-resourced.
Hervey Bay Council	Short time frames for commenting considering the size of report.
EPA Victoria	Jurisdictions have been given inadequate time to consider and evaluate the implications of the report and have been unable to adequately consult with their stakeholders.

Submission	Comments
Product Stewardship
PM&C	Has no firm view at this stage other than to comment that a stewardship model seems to offer some advantages.
C&R Tyre Recycling	Development of a commercially sustainable free market approach with responsibility placed on tyre manufacturers and importers to support transition of tyres into products and materials of commercial value.
Total Environment Centre	Supports extended producer responsibility/product stewardship approach. The program should also anticipate future waste avoidance and producer roles.
Eco Waste	OEMs (original equipment manufacturers eg car manufacturers) should be more closely engaged in this strategy since tyre manufacturers respond to specifications and requirements of OEMs.

Submission	Comments
Market Failure ­ Improved Value
Rrecycle Aust.	Longer term aim should be to give waste tyres a positive value.
Total Environment Centre	Need for a robust regulatory framework that gives waste tyres a financial and social value.
WMAA (Energy from Waste Divn).	Current lack of optimum resource recovery from tyres is the basic market failure that any product stewardship arrangements must address.
Eco Waste	The appropriate approach is to develop strategies, systems and infrastructure to recover the full resource value of waste tyres and not simply treat it as a waste management problem.

Submission	Comments
Further research/information
EPA NSW	A number of the options in the report are likely to present implementation problems or policy issues for some jurisdictions. They are complex and will require additional research and thought before they can be framed as concrete proposals for consideration.
Brisbane City Council	Before sustainable markets for waste tyres can be developed, accurate data is necessary. Starting point is to compel manufacturers, importers and distributors to provide details on tyres produced or sold and where tyres are sold. This at least will put potential tonnages of tyre waste in particular localities. Markets will be more likely to invest the capital necessary to assist with recycling and re-manufacture if they have that data.
ATMA	Data in report can only be regarded as general estimates. Without a national strategy in place, no accurate data can be compiled on the types and volumes of tyres entering the market and hence being scrapped.
Rrecycle Aust.	Need to pay attention to what is happening in UK and USA where they are moving away from tyre derived fuels and in the UK where banning of disposing of tyres to landfill is imminent.

Submission	Comments
Specific Re-Use Options
ATMA	Critical factor is to provide resource security to large-scale operations in sufficient volume and over an appropriate period of the operation of such enterprises. Otherwise, investment required to initiate such projects will not be made. There is also a need to facilitate resource security for large-scale, low-value added uses which at the same time keeps the door open for excisting and new reprocessors to grow and exploit the value adding potential of waste tyres. A national approach is necessary to achieve that resource security.
Torpey Associates	Landfill, waste to energy and some new applications all have a continuing residue and pollution impact upon the environment. A national approach should be based on total recycling of waste and environmental impact even if it is considered that methods such as pyrolysis are currently financially marginal. This does not preclude other processes but endeavours to achieve absolute results.
Geocycle	Notes that use of tyres in cement industry (co-processing) is both a waste to energy and a recycling activity (contribution of steel in tyres to raw material requirements) and so should be seen as such within the context of the waste management hierarchy.
Cement Industry Federation	Resource recovery of waste tyres in co-processing operations (eg cement industry) should be acknowledged in the broader context of material recovery and avoidance of fossil fuels.
Cement Industry Federation	It is critical that policy options facilitate short term management of waste tyres in addition to creating opportunities for orderly waste tyre markets to develop over time. The recycling of waste tyres as kiln fuel and mineral recovery supports both long and short term policy options.
Cement Industry Federation	Cement industry is pursuing an on-going strategy of reducing fossil fuel use through use of alternative fuels. Use of waste tyres is an important part of this approach.
Total Environment Centre	Aim should be optimum resource recovery (re-use or recycling into new products, rather than energy recovery) and resource savings achieved at initial production points. Storage may be the best option until resource recovery technology is available.
WMAA (Energy from Waste Divn).	Whilst energy recovery is infinitely preferable to tyres going to landfill, energy recovery still only recovers some 3-5% of the readily available resource value. Energy recovery will play an important role in the mix of options, it should only be for that fraction of waste tyres for which no higher resource value application is available.
WMAA (Energy from Waste Divn).	Tyres have a fraction that is easily recovered (usually the tread strip) and that whilst many processes will recover rubber crumb from the entire casing, many partially processed or damaged casings are expected to be available for energy recovery. Selected energy recovery should be established to accept residuals from tyre processing, rather than as specialty whole tyre handling systems. This is particularly important in the long term as competition increases for whole waste tyres.
Eco Waste	Investment in new value recovery facilities requires a reliable source of waste tyres. This resource security must ultimately be underwritten by the market realities such that if a specific system or facility only recovers a small portion of the inherent value from the available resource then the resource security could and should be at risk from the product or process that can recover the greater net value from the same feedstock. This is particularly important when considering the energy recovery option. To handle fluctuations in supply and demand the energy sector should manage their needs for supplementary or alternative fuels ­ taking tyres as and when they are available and other high calorific residuals when they are not. Submission also raises issues about feed systems and discouragement of whole tyre feed systems.

Take Back Option

Description of Option:

Producer (manufacturer or importer) is required to be responsible for managing the product once it has reached the post-consumer stage. This could include provision for a Producer Responsibility Organisation.

Summary of Submissions:

• Support and opposition approximately balanced.
• Initial opposition from tyre manufacturers/importers but subsequently they have indicated their willingness to consider this idea further.
• If a take back approach is adopted, the design must ensure it doesn't duplicate or create inefficiencies for excisting systems.

Submissions Received:

Submission	Comments
Supports Take-Back
C&R Tyre Recycling	Support the role of manufacturers and importers in Extended Producer Responsibility (EPR).
Rrecycle Aust.	Support ­ tyre manufacturers have access to technology to greatly improve wear life of tyres and build casings capable of multiple retreads but have no incentive to do so. This option forces manufacturers to reassess their manufacturing processes by taking responsibility for the products they produce.
Rrecycle Aust.	New industries and opportunities would offset any purported negative aspects that tyre manufacturers may put forward (eg job losses, expensive).
Total Environment Centre	Take back schemes should be encouraged with experience benchmarked from other industries (eg milk crate returns, pallet returns etc).
DEP WA	Favour a take back scheme as it places the onus for development, management and funding of solutions to tyre producers and importers and not government. Exact nature would need to be discussed and successful overseas models analysed. Producers should undertake the establishment and management of PROs.
DEP WA	With appropriate legislative framework this option could be effective and have positive flow on effects on other issues such as importation of waste tyres and illegal disposal.
DEP WA	Legislation that requires all tyres to bear the manufacturers name would assist as producers would know they were responsible should their tyres be illegally dumped. If consumers didn't have to pay to dispose of tyres they would be less likely to dispose of them illegally. Manufacturers would be required to prove they were meeting their take back targets and so may choose to implement a tracking system to prove this.
Devote (Encore)	In principal a 'take back' scheme, when combined with a national tracking scheme, may provide a good option for increased control over the disposal of waste tyres.
LGA Qld	The only real solution. Will ensure that the responsibility of producers is extended, providing encouragement for the minimisation of impacts from waste tyres while removing the disposal burden from Local Government.

Submission	Comments
Opposes Take-Back
NSW Waste Boards	Take back not supported as tyre producers have no direct interest in recovering waste tyres. Enforced take back has the potential to be more inefficient (environmentally, socially, and on a cost basis) than established infrastructure. Could also be negative to creation of a free market for waste tyres.
Eco Waste	Enthusiasm of the tyre industry to resolve the waste tyre problem obviates the need for inefficient, force fit solutions such as take back in its purist form.
DEP WA	Possible that a take back scheme may impact local recyclers as producers may transport their own waste tyres to a few central recyclers, causing other recyclers to become unviable.
South Pacific Tyres	Opposed ­ would require inappropriate infrastructure changes within the tyre manufacturing industry. Would not be effective and current market conditions would make it unworkable.
ATMA	Original submission stated that a take back scheme cannot operate successfully citing that tyre manufacturers and importers cannot operate their core business activities whilst, at the same time, assume physical responsibility for the recovery of waste tyres. The best role for manufacturers and importers is in facilitating the solution, rather than achieving it themselves. HOWEVER, Subsequent meeting with EA clarified take back schemes and how it can encompass the use of producer responsibility organisations rather than each individual tyre manufacturer/importer being physically responsible for 'their' waste tyres. In subsequent correspondence, submitter noted the subjective view within industry of the use of the term take back. They are supportive of a suitably constructed scheme that achieves the objectives of a 'take-back' scheme provided it has the full support of industry. Discussion also included the idea of having legislative backup in terms of a compulsory take back requirement for all manufacturers and importers unless they were part of a PRO or had other approved/appropriate mechanisms in place.
ATMA	There are numerous large and small importers and a diverse market for tyres. Financial cost and practical difficulties involved in enforcing any take back scheme are monumental and unnecessary in achieving the final objectives of waste tyre management. However, submission supports setting up a Producer Responsibility Organisation (which is one of the possibilities under a take back scheme).

Submission	Comments
Producer Responsibility Organisations
C&R Tyre Recycling	Producer Responsibility Organisations (PROs) places responsibility a step further away from manufacturers as shown in NSW with recent Industry Waste Reduction Plan.
NSW Waste Boards	Transference of responsibility to a PRO is not supported as the response from the producer must be a direct responsibility. Producer is best placed to consider and assess the impacts at all stages in the life cycle of a product.
NSW Waste Boards	Based on experience in trying to setting up industry association for recovered and recycled paper, a PRO may require access to commercial in confidence information which producers would be reluctant to reveal.

Submission	Comments
Design Issues for Take-Back
C&R Tyre Recycling	Needs to ensure it doesn't duplicate or create inefficiencies in current collection, processing and re-use/recycling systems. Should support current uses and establish greater demand for products.
DEP WA	Some sort of outcomes based legislation would be required. Concerns raised in report on direct regulation of take back are acknowledged but other avenues should be explored.
DEP WA	Producers could be required under a take back scheme to take a certain percentage of their tyres to a recycling function and this target could increase over the years.
Devote (Encore)	Any take back scheme should incorporate the licensing of a limited number of collection agencies in each state or region. There would need to be stringent license controls to ensure the integrity of the tracking and take back schemes.
LGA Qld	A tracking scheme is necessary for a take back scheme to be successful. Without tracking scheme any take back scheme will be open to abuse.
MTAA	Supports a take-back scheme but has concerns regarding establishment. Has to be fair and equitable and so has to capture: Australian new tyre manufacturers Importers of new tyres Importers of second hand tyres New and used motor vehicle importers (incl importers of specialist and enthusiast vehicles) Importers of motor vehicle parts (eg second hand engines) which use waste tyres as padding during transport

Waste Avoidance Options

Waste Avoidance Option 1: Purchase Decisions

Description of Option:

Provision of comparative information for customers on expected tyre life and on retreads so that customers may choose the tyre liable to give a longer life.

Summary of Submissions:

• Support for more information for consumers from stakeholders across various interests.
• Opposition on the basis of cost effectiveness - will the investment give an appropriate return in terms of reduction of waste?
• Uniform Tire Quality Grading System roused some interest but there are some design concerns (cost of testing, importance of communication strategy).
• Recognition of information already available from manufacturers.

Submissions Received:

Submission	Comments
Supports program
C&R Tyre Recycling	Support for programs sponsored by manufacturers and importers as part of EPR.
Total Environment Centre	Waste avoidance requires more factual accessible information from the tyre industry to assist consumers to make an informed product choice.
ACT No Waste	Support the provision of better consumer information, but not on retreads for passenger vehicles due to safety issues.
Cement Industry Federation	The education of consumers and users to the impact of their purchase decision and proper tyre maintenance appear to be the more practical approaches to waste avoidance. Other options such as uniform tyre grading systems or mandatory regulations, may involve large expenditure for little change in consumer behaviour.
NSW Waste Boards	Positive support. Education programs should be sponsored by manufacturers and importers under EPR.
Eco Waste	Retailers should be a vital (even primary) source of information for customers including tyre maintenance issues, relative merits of wear v. traction v. longevity v. price and provide transparency regarding any disposal fee added to customer invoices.
Eco Waste	Strategy should be pursued through a centrally managed Product Stewardship Scheme.
EPA Victoria	Waste avoidance policy options are of preliminary interest but require further consideration and discussion. Commonwealth could assist in establishing programs that provide information to consumers on tyre life, tyre maintenance and retreads and through national research on improved market development opportunities and on recycling options for waste tyres.
Devote (Encore)	Supports public awareness programs to encourage waste avoidance.
ATMA	Scheme could set up and ensure compliance with Codes of Practice and Industry Guidelines aimed at giving consumers the most up-to-date, complete and useful assistance in the purchase of replacement tyres.

Submission	Comments
Opposes or Has Concerns
DEP WA	Success of uniform tyre grading systems and other public awareness campaigns does not appear to be substantial and so could only be used as a secondary strategy.
DEP WA	Evidence suggests that tyre producers are not in favour of a tyre grading system and would not participate in a voluntary scheme. Scheme would have to be mandatory requiring legislation and enforcement.
DEP WA	Cost of public awareness campaigns, testing of tyres, development of legislation and enforcement cannot be justified by the small reduction in waste that may result from better public awareness.
South Pacific Tyres	Southern Pacific Tyres has always been willing to give the consumer informed choice for tyres manufactured by SPT.

Submission	Comments
Design Issues
Rrecycle Aust.	A greater level of consumer education is required in relation to the benefits of various tyre types. It is likely that this would be undertaken by manufacturers in order to pursue market share, in the case of a take-back option. Market forces should be allowed to dictate the direction and pace of this but may require some form of incentive to promote such a program.
ATMA	The Uniform Tire Quality Grading System cannot be used in Australia. Something similar could be investigated and applied but would require a concerted public relations campaign to inform tyre consumers of the need to properly maintain tyres and to be selective in the choice of tyres.
MTAA	A Uniform Tire Quality Grading System (such as in the US) is a worthy one but have concerns that the stringent and costly procedures required to test tyres for grading may have a severe impact on the Australian tyre manufacturing industry. Any such scheme would have to ensure it didn't disadvantage domestic producers.

Waste Avoidance Option 2: Tyre Maintenance

Description of Option:

To address the relationship between proper tyre maintenance and longer tyre life. Programs to improve the awareness of vehicle owners on benefits of proper tyre maintenance (either one-on-one with drivers or media education campaign).

Summary of Submissions:

• Strong support across a range of stakeholders.
• Opposition on the basis of cost effectiveness - will the investment give an appropriate return in terms of reduction of waste?

Submissions Received:

Submission	Comments
Supports education program
C&R Tyre Recycling	Support for programs sponsored by manufacturers and importers as part of EPR
Total Environment Centre	Waste avoidance requires consumers to be more aware of the benefits of tyre maintenance.
ACT No Waste	Supports a tyre maintenance education program to ensure that tyre life is maximised.
Cement Industry Federation	The education of consumers and users to the impact of their purchase decision and proper tyre maintenance appear to be the more practical approaches to waste avoidance.
Cement Industry Federation	Education about proper tyre maintenance could be extended from public awareness campaigns to include large organisations and government agencies.
NSW Waste Boards	Positive support. Education programs should be sponsored by manufacturers and importers under EPR.
Eco Waste	Strategy should be pursued through a centrally managed Product Stewardship Scheme.
Devote (Encore)	Supports public awareness programs to encourage waste avoidance.
ATMA	Essential that any scheme focuses on properly educating consumers on tyre maintenance. Could be funded from the pool of funds derived from an advanced recycling fee.
MTAA	Meaningful uses of funds collected by a levy including educating consumers in tyre maintenance to increase the service life of tyres.

Submission	Comments
Opposes
DEP WA	Would probably only make a minimal impact on consumer behaviour and the number of waste tyres. Given resources required to fund these campaigns it is felt that this option is not efficient.
EPA SA	Unlikely community would be willing to pay for information they believe they already know or can easily access in the vehicle handbook.

Submission	Comments
Design Issues
Cement Industry Federation	Active industry promotion of the benefits from proper tyre maintenance should be acknowledged.
EPA Victoria	Waste avoidance policy options are of preliminary interest but require further consideration and discussion. Commonwealth could assist in establishing programs that provide information to consumers on tyre life, tyre maintenance and retreads and through national research on improved market development opportunities and on recycling options for waste tyres.
South Pacific Tyres	Qualified support ­ this is not the appropriate forum ­ it would be better as a part of a road safety campaign.

Waste Avoidance Option 3: Importation of Used Tyres

Description of Option:

To address importation of used tyres that may be unsuitable for use as a tyre or retreading and so equate to importation of waste tyres. Could include total ban on imports or quality controls on imports (eg meet roadworthiness or suitability for retreading).

Summary of Submissions:

• Appears to be broad support across all stakeholder groups that discouraging imports of 2nd hand tyres that aren't suitable for use or retreading is required.
• Most support is for some form of ban on imports. Others argue that a levy placed on all tyres could dissuade import of 2nd hand tyres (as it would make it economically unviable).
• Could also address issues through tightening Australia's minimum tread depth requirements.

Submissions Received:

Submission	Comments
Ban On Imports
C&R Tyre Recycling	Support banning of used tyre imports that aren't suitable for use or retreading.
Rrecycle Aust.	Australia shouldn't be a dumping ground for other countries' waste unless we have a viable and effective means of dealing with it and gain an economic benefit.
Rrecycle Aust.	Until economic benefits can be gained from imported waste tyres, the import of 2nd hand tyres should be banned except for retreading purposes. Where so, they must be of a size and condition suitable for retreading. Alternatively, a large levy to discourage imports.
Stanthorpe Council	Supports a total ban on the import of used tyres.
ACT No Waste	Controls on imports (either bans or restrictions) are supported to stop dumping of 'almost waste' tyres in Australia.
NSW Waste Boards	Importation of used tyres with nil value would classify them as waste and therefore should not be allowed to be imported. However, if they are imported, the importer becomes responsible for their fate under EPR and should inherit the full financial and environmental responsibilities of importing these products (thus minimising the number of nil value imported tyres).
DEP WA	Support legislation to cease importation of tyres which have no value, although significant resources would be needed to monitor and enforce this legislation.
South Pacific Tyres	Support for banning of importation of used tyres to ensure that all economic benefits that derive from a viable local tyre industry are maximised. Would reduce the number of tyres processed per year and increase the average life of a tyre in Australia.
EPA NSW	Supports further consideration to restrict imports of unusable used tyres.

Submission	Comments
Levy on Imports and Other Measures
C&R Tyre Recycling	Levy imported used tyres at equivalent to highest level waste disposal rates to reflect imposed cost of product disposal.
ATMA	A PRO could fund safety campaigns to encourage consumers to avoid imported used tyres inappropriate for use on Australian motor vehicles.
MTAA	Importation of low quality used tyres needs to be addressed. Australia's minimum tread depth requirements are less stringent that those of other countries, resulting in many tyres with short tread lives being dumped in Australian market.
EPA SA	Generally importation of used tyres should be discouraged especially those not suitable for retreading. If a levy is applied it should be imposed on locally produced and all imported tyres to maintain a level playing field. If tyres are retreaded then a rebate can be paid.

Submission	Comments
Other comments
C&N Ruggeiro	Many tyre dealers still export used tyres overseas.
Eco Waste	Strategy should be pursued through a centrally managed Product Stewardship Scheme.

Reducing Inappropriate Disposal

Reducing Inappropriate Disposal Option 1: Tracking Scheme

Description of Option:

To reduce inappropriate disposal practices by requiring documentary evidence of all waste tyre movements (ie a tracking scheme).

Summary of Submissions:

• A tracking scheme is supported by mostly 'industry' stakeholders, especially (in some cases) linkages with a take back scheme. Also could draw on models (esp SA) already in place.
• Opposition mostly from mostly 'government' interests on the basis of administratively difficult, costly and that it will not necessarily increase tyre re-use opportunities. Some argue that illegal disposal of waste tyres would be better addressed if waste tyres are made more valuable and hence a tracking scheme would be unnecessary.

Submissions Received:

Submission	Comments
Supports Tracking System
C&R Tyre Recycling	Support but is only necessary due to ineffective regulatory systems currently in place.
Rrecycle Aust.	Tracking system is most cost efficient means of managing this aspect of the waste tyre problem. Benefits to adopting South Australian model with some fine-tuning to cater for different issues nationally.
Cement Industry Federation	Supports a tyre tracking system that is administered by local EPAs would provide closer control of the tracking system. Many States/Territories already operate waste tracking systems which could be extended to include waste tyres.
Devote (Encore)	Support a national tracking scheme.
Devote (Encore)	In principal a 'take back' scheme, when combined with a national tracking scheme, may provide a good option for increased control over the disposal of waste tyres.
LGA Qld	A tracking scheme is necessary for a take back scheme to be successful. Without tracking scheme any take back scheme will be open to abuse. Will also provide adequate baseline data to enable the development of informed strategies in relation to waste minimisation and market development for recycled waste tyres.

Submission	Comments
Opposes Tracking System
Qld EPA	Providing tyres with a value by way of a levy obviates the need for costly tracking arrangements.
Qld EPA	Tracking is not a panacea and systems only work where the generator fills in the tracking form in the first instance.
Qld EPA	Tracking does not remove the opportunity or the motive to operate outside of the system, particularly for smaller and random generators.
Brisbane City Council	Waste tracking is relatively high in costs and requires waste tyre operators to be registered or licensed. If smaller operators are not required to register, then what is the point of tracking?
ACT No Waste	Question the value of a tracking system ­ administratively difficult and costly for little gain.
NSW Waste Boards	Not supported. Only necessary if there is ineffective regulatory systems in place to control illegal dumping. Generally illegal dumping is detected but not prosecuted. Tracking system will only reveal the magnitude of the problem. Cost would be disproportionally high to the benefits and may better be handled by other measures.
Eco Waste	Option will be unnecessary if payments are made at the point of receival (see option 3).
DEP WA	Tracking system would generate large amounts of paperwork and raise administrative issues. More supportive of options which make tyres more valuable and thus allows natural market forces to discourage illegal disposal.
DEP WA	Not supported as the sole method for waste tyre management as it places cost on government and doesn't encourage innovative solutions or producer responsibility.
EPA NSW	Not a cost effective option.
MTAA	Money would be better spent on reducing scrap and encouraging the use of waste tyres than on any expensive tracking system. If waste tyres acquire value they would not be dumped and would therefore not require tracking.

Submission	Comments
Design Issues
C&N Ruggiero	Will not work unless all States join.
C&R Tyre Recycling	Exemptions may be applicable in regions where sufficient demand exists for waste tyres generated.
Hervey Bay Council	Qld has introduced legislation on waste tracking where tyres will become a trackable waste from 1 July 2002. A national approach should complement and enhance the State provisions.
Brisbane City Council	Who will operate and administer a tracking process?
Cement Industry Federation	All used tyre collectors and all businesses processing waste tyres should be registered and licensed. Tyre retailers and re-sellers should be required to use only licensed tyre collectors and tyre collectors should be required to transport tyres only to appropriately licensed premises.
Cement Industry Federation	Regular auditing and compliance requirements of the system will ensure the administration and functionality of tracking systems is maintained and has integrity. Illegal dumping or disposal of waste tyres, or transportation of tyres outside the tracking system should be heavily penalised and rigorously enforced.
Cement Industry Federation	Licensing should be affordable and 'user friendly' to avoid creating barriers to market entry. Licensing should be consistent across all States and Territories to ensure common standards of storage and handling of waste tyres.
Cement Industry Federation	Could be funded from a levy on new tyres or payment of a bond or guarantee by waste tyre collectors.
ATMA	May be necessary for a national tracking system to be introduced. Inconsistencies, gaps and anomalies between jurisdictions are to be avoided and would require cooperation between jurisdictions any PRO established.
EPA SA	Estimated cost for 2 full time inspectors appears high and it would need to be determined if 2 full time inspectors would be required.

Submission	Comments
Other Concerns
DEP WA	Tracking system would be effective in reducing inappropriate disposal and based on SA experience, is feasible. But this option does not encourage the development of more appropriate options for waste tyres than disposal which is the priority.
South Pacific Tyres	Support but is not workable (evidence NSW scheme).
EPA SA	The information required on waste tyre movements should be currently available from each jurisdiction, as consignment numbers have to be issued for movement of tyres between States and Territories (as per the National Environment Protection Measure for the Movement of Controlled Waste).

Reducing Inappropriate Disposal Option 2: National Uniform Regulation

Description of Option:

Uniform regulations and management and enforcement arrangements for waste tyres across all jurisdictions (including licensing/registration for collectors, landfill arrangements etc).

Summary of Submissions:

• Support generally across 'industry' stakeholders for uniform regulations across States and Territories.
• Opposition mainly from 'government' interests especially on the basis of the difficulties and time it would take to achieve uniformity and if uniformity is appropriate.

Submissions Received:

Submission	Comments
Supports National Uniform Regulation
C&R Tyre Recycling	Support ­ consistent regulation is needed across Australia.
Rrecycle Aust.	There is a need for uniform legislation in that conditions don't vary to any great extent around the country, other than the volumes involved.
Rrecycle Aust.	All operators should be licensed or registered which will discourage inappropriate practices.
Cement Industry Federation	Supports national uniform regulation and could include uniform penalties for unlicensed waste tyre transport and disposal and restrictions on the number of waste tyres going to landfill.
DEP WA	Pros and cons for national regulation. Potential benefits in terms of cross border movements and the sharing of resource requirements. But involves loss of individuality for each State/Territory and ability to tailor strategies to suit that particular area and its issues.
Devote (Encore)	Support resources and powers for regulative authorities, combined with increased penalties in respect of illegal disposal of tyres.
South Pacific Tyres	Support ­ uniform regulations are required to make any scheme workable. Problems could be encountered if there is a lack of resources especially at inception stage (esp legal resources).
ATMA	Differences between legislative regimes set up by individual State and Territory administrations for regulating waste tyres must be addressed in setting up a national strategy also some mechanism for identifying cross-border movements of tyres. However, there is no need for the introduction of national or uniform legislation in relation to tracking, transportation, storage or disposal.

Submission	Comments
Opposes National Uniform Regulation
NSW Waste Boards	Unclear what type of regulations. In any case, uniform regulations is idealistic and require all States/Territories and local authorities to have uniform regulations. Very lengthy implementation time frame. Also complications with related classifications of other waste materials.
DEP WA	Pros and cons for national regulation. Potential benefits in terms of cross border movements and the sharing of resource requirements. But involves loss of individuality for each State/Territory and ability to tailor strategies to suit that particular area and its issues.

Submission	Comments
Other Approaches
Brisbane City Council	While there is some need for regulation to be put in place, the development of market forces is the preferred option.
ACT No Waste	Support consistency but question whether regulation is the way to go if an industry organised scheme works effectively.
DEP WA	May work for some options in the report and not for others. Perhaps a solution to develop national guidelines which are then legislated by the States/Territories.
EPA SA	No evidence in the consultancy report to suggest that less densely populated States and Territories are handling the waste issues any differently to other States.

Reducing Inappropriate Disposal Option 3: Payment for Waste Tyres at Point of Receival

Description of Option:

Guaranteed payment at point of delivery - could be to a centralised facility or to approved receival facilities. Price paid for tyres could be constant or could be supported by a differential benefit scheme.

Summary of Submissions:

• Some support in that it changes incentives for waste tyre collectors/transporters to take tyres to a place where they can be paid. Could also encourage clean up of some illegal dumps.
• Opposition on basis that it would substantially impact on some user's ability to continue using waste tyres. Some other opposition on the basis of administrative difficulties.
• Many design issues would need to be sorted out (government v. industry run, how it would be funded, commercial sustainability because supply of waste tyres exceeds supply at present).

Submissions Received:

Submission	Comments
Supports Payment at Point of Receival
C&R Tyre Recycling	Supported but may be idealistic as the commercial sustainability of payment for tyres is not feasible until demand for tyres matches or exceeds supply.
ACT No Waste	Support this approach but such a scheme would be best if organised by industry.

Submission	Comments
Opposes Payment at Point of Receival
Rrecycle Aust.	Doesn't believe there are benefits in a central point of receival. Who owns and manages such receival points, how they are funded and additional transport costs.
Cement Industry Federation	Not supported ­ could substantially impact on some industry's ability to continue using waste tyres for resource recovery. At present waste tyres have a negative economic value, when waste tyres are collected there is still a cost associated with recycling or recovery practices. This policy option would require reimbursement to recyclers of such payments (recognising transport and collection costs and processing costs) so they could continue as viable operators. But coordination of such a scheme (reimbursement, levy and payment at point of delivery) would be administratively difficult.
DEP WA	Would probably be effective but would require government to fund proposal and would cause significant administrative issues. Would prefer a take back scheme.
South Pacific Tyres	Difficult to administer.

Submission	Comments
Design Issues
Qld EPA	How is the 'payment of point of delivery' acquired and by what mechanism the funds are distributed or accounted?
NSW Waste Boards	Neutral but support in principle depending on more information (eg how point of receival is classified, operated, owned and the disposal of tyres is affected.) Changes financial incentives from transport for disposal to transport for receival that encourages proper and legal disposal of waste tyres. Under EPR could be funded by producers (directly or via a levy).
NSW Waste Boards	Currently some tyre dealers are charging consumers more for tyre disposal than actual costs. By re-directing the incentive to payment at a re-user/recycling receival site, the payment might be more controlled and more truly reflect the actual costs of receipt and disposal.
Eco Waste	Collection sector could be stimulated to change if the majority of their income was obtained at the point of delivery/receival for the tyres rather than at the point of pick up giving them an incentive to take tyres to the preferred destination. Collectors could be rewarded for the tyres brought to a central point ­ initially this payment could be made from a levy/benefit scheme and subsequently (say after a transitional period of 4 to 5 years) from the realised value for the reprocessed tyres.
Eco Waste	Collectors would be encouraged to not only collect as many tyres as possible, but a benefit structure could be loaded to initially to encourage the 'rediscovery' of historical stocks in illegal repositories.

Reducing Inappropriate Disposal Option 4: Environmental Rating Scheme for Tyre Dealers

Description of Option:

Rating of tyre dealers according to their waste tyre management practices (rating could be a straight accreditation scheme or a higher rating for dealers who ensured their waste tyres went to high value management practices).

Summary of Submissions:

• Whilst some submissions have identified that such a scheme could be funded through various mechanisms there is mostly opposition to a rating scheme. Some argue that the small resultant impact on illegal or inappropriate disposal would not warrant the investment.
• Would require substantial regulation and enforcement systems (including both retailers and collectors) and would need retailer and consumer education.

Submissions Received:

Submission	Comments
Supports Rating Scheme
ATMA	Does not oppose this option. Could be set up as part of a PRO, coupled with dealer's support of and participation in the PRO or otherwise acceptable tyre recycling practices.
ACT No Waste	Option may have some merit provided that the rating system is not administratively complex and it stands up under scrutiny (eg it must ensure the rating reflects the final end use and be supported with auditing of practices). Preferable if industry operated.

Submission	Comments
Opposes Rating Scheme
C&R Tyre Recycling	Idealistic and unmanageable on a national scale.
Qld EPA	This type of scheme is not suited to the retail tyre industry.
Cement Industry Federation	Does not overcome the security of supply issues. Benefit of this scheme would require substantial retailer and consumer education without demonstrated results. Rating system would need to take account of the social benefit of solving the waste tyre problem.
NSW Waste Boards	Rating scheme may be subjective and ineffective in long term to meet the intended outcomes. Other EPR mechanisms may be more effective. System costs would need to be funded. Administration of rating and auditing would need to be independent of the tyre industry for credibility.
DEP WA	Places additional pressure and time on tyre dealers and it is not proven customers would consider environmental rating when purchasing. A lot of effort for perhaps little difference in illegal disposal.
South Pacific Tyres	Opposed ­ unlikely to be effective as tyres are a commodity purchase in the main.

Submission	Comments
Design Issues
C&R Tyre Recycling	Would need to be funded and managed by manufacturers and importers.
Rrecycle Aust.	Idea is premature but may have greater merit at a later stage. Not currently cost effective and would mean little to consumers. Education of consumers needs to be the first stage.
Gold Coast City Council	Revenue from a levy system could also be used to fund an environmental rating scheme.
Qld EPA	What are likely costs and methods of administration?
DEP WA	Even if voluntary but to ensure that rating is right and that dealers are doing the right thing it would require government to regulate and enforce it. Also need to monitor and enforce down the line with collectors to make sure they are doing the right thing.

Improved Value for Waste Tyres - Managing the Resource (ie the supply side)

Managing the Resource Option 1: Legislative Support for Tied Agreements

Description of Option:

To address concerns about resource security for waste tyre recyclers, this option considers legislative support for guaranteed supply.

Summary of Submissions:

• Whilst resource security was a major concern across many submissions there was mostly opposition to legislative support for tied agreements. Main opposition was voiced on the basis of such agreements being anti-competitive, may restrict innovation and could hinder responses to market forces.

Submissions Received:

Submission	Comments
Supports Legislative Support for Tied Agreements
South Pacific Tyres	Support ­ good option for forming basis for new industries and investment.
ACT No Waste	Limited support as unlikely to encourage competitive alternatives.

Submission	Comments
Opposes Legislative Support for Tied Agreements
C&R Tyre Recycling	Not supported ­ Government should not play a direct role.
Qld EPA	Not supported ­ is at odds with national competition policy and loss of flexibility in supporting over the horizon best practice end-uses.
Cement Industry Federation	Would ensure security of supply issues but restricts the market for waste tyre re-use and recovery by not providing the flexibility in response mechanisms for the long term.
Cement Industry Federation	A legislative approach would address supply issues but not address the investment and ongoing costs involved with recycling and recovery of waste tyres (eg capital, operating, maintenance costs).
NSW Waste Boards	Not supported ­ is anti-competitive in reducing options for new ideas and higher value added resource use initiatives.
NSW Waste Boards	Inflexible legislation may not be appropriate for a flexible market structure in a developing re-use/recycling industry.
DEP WA	Not supported ­ requires government to manipulate market forces which could impede innovation. Also government may be liable to pay compensation if the guaranteed tyres are not supplied.
DEP WA	Not feasible in remote and smaller population centres (eg Perth) as they may have insufficient tyres to keep more than a couple of businesses running.

Submission	Comments
Design Issues
Recycling Resolutions	Would require to sign a contract with Councils or Shires of 5 to 10 years to make operation viable (large quantity and constant supply).
Geocycle	Whatever mechanism used must have long term security as most recycling or co-processing options have a high capital cost. Operators must have confidence in ongoing access to tyres ­ if not, they won't enter the market.
Brisbane City Council	Retailers, tyre collectors etc must support recyclers/re-users by ensuring consistent supply of quality waste tyres.

Managing the Resource Option 2: Centralised Market Scheme

Description of Option:

To set up a centralised market scheme to allow easier access to the waste tyre resource. Could be of various forms - see sub-options described below. Also issue needs to be considered if there can be trades outside of the central facility.

Summary of Submissions:

• Most of the concerns about a centralised market scheme (under each of the three sub-options) relate to establishing a monopoly situation (whether the scheme is managed by the government or industry).
• Also some concerns as to who carries the risk since adequate markets for waste tyres do not exist presently.
• Some support as an appropriate way of managing waste tyres but would have to be done in a way to manage supply fluctuations and guaranteed supply to approved end users. Other arguments are that it could be feasible as part of a take back scheme and managed by producers and importers.
• Two stakeholders proposed an industry run and managed centralised scheme funded from a voluntary industry levy (with legislative back up for an excise scheme for those not choosing to contribute). Payment to tyre collectors/transporters to encourage use of the facility but with no benefits paid to recyclers.
• Many design issues would need to be considered including physical management of large stockpiles of tyres, transport issues and the need for networks of facilities, current collection and storage facilities becoming part of the network.

Managing the Resource Sub-Option 2.1: Free Market Operation

Description of Option:

Central market operating like a stock exchange with bids for buying and selling of tyres lodged. Manager of facility has no power over price of waste tyres bought or sold and has no vetting role on trades - the manager's role is restricted to managing the buy-sell process (ie an administrative role)

Submissions Received:

Submission	Comments
Supports
C&R Tyre Recycling	Supported ­ free market is the only sustainable commercial position

Submission	Comments
Opposes
Qld EPA	Not supported ­ model assumes that scrap tyres have a positive value when scrap tyres have negative worth.
Qld EPA	It is not the role of government to interfere in the marketplace and assume the role of picking winners.
Cement Industry Federation	Free market operation would not necessarily ensure that tyre disposal is diverted from landfill operations.
NSW Waste Boards	Does not support the establishment of any controlling body (either government, industry or manufacturer based) that would establish a monopoly position in the marketing or physical control of tyres.
NSW Waste Boards	Overall not supportive of centralised market scheme as it generates monopoly conditions. Assumes adequate markets exist when they don't currently. Who covers the risk in this option (government, industry)?
Devote (Encore)	Central collection arrangement is not workable or cost effective. At this point there is no shortage of tyre supply to support any waste recovery initiatives. Should new commercial applications emerge, the market forces will deliver the tyres.
EPA NSW	Co ordinated Government or industry involvement in any centralised market scheme is inappropriate.

Submission	Comments
Design Issues
Recycling Resolutions	Tyres delivered to a central depot (eg council or shire waste depots) with an all weather working area is a preferred requirement for this operation to facilitate use of mobile shredders. Tyres also need to be divided into major categories.
ACT No Waste	While this approach may have some value in terms of the physical management there are always risks with large stockpiles of tyres and this approach may involve considerable transport issues particularly for regional and rural areas. It may therefore be better to be a network of facilities.
DEP WA	Option is feasible as part of take back scheme provided the holding facility and administrative scheme were developed and managed by the producers. Government should not be involved.

Managing the Resource Sub-Option 2.2: Manager retains strict control

Description of Option:

Manager has both an administrative and policy/judgement role with a power to vet all potential trades and may extend to directing tyres to specific destinations or uses.

Submissions Received:

Submission	Comments
Supports
South Pacific Tyres	Support ­ good option for forming basis for new industries and investment.

Submission	Comments
Opposes
C&R Tyre Recycling	Not supported ­ establishment of a monopoly would develop especially to the detriment for small to medium areas of re-use/recycling industry.
C&R Tyre Recycling	Not supported ­ control could alter the development of new markets.
C&R Tyre Recycling	Not supported ­ would add an additional administration into current infrastructure.
Qld EPA	Not supported ­ model assumes that scrap tyres have a positive value when scrap tyres have negative worth.
Qld EPA	It is not the role of government to interfere in the marketplace and assume the role of picking winners.
NSW Waste Boards	Does not support the establishment of any controlling body (either government, industry or manufacturer based) that would establish a monopoly position in the marketing or physical control of tyres.
NSW Waste Boards	Overall not supportive of centralised market scheme as it generates monopoly conditions. Assumes adequate markets exist when they don't currently. Who covers the risk in this option (government, industry)?
Devote (Encore)	Central collection arrangement is not workable or cost effective. At this point there is no shortage of tyre supply to support any waste recovery initiatives. Should new commercial applications emerge, the market forces will deliver the tyres.
EPA NSW	Co ordinated Government or industry involvement in any centralised market scheme is inappropriate.

Submission	Comments
Design Issues
Recycling Resolutions	Tyres delivered to a central depot (eg council or shire waste depots) with an all weather working area is a preferred requirement for this operation to facilitate use of mobile shredders. Tyres also need to be divided into major categories.
ACT No Waste	While this approach may have some value in terms of the physical management there are always risks with large stockpiles of tyres and this approach may involve considerable transport issues particularly for regional and rural areas. It may therefore be better to be a network of facilities.
Cement Industry Federation	Centralised market approach seems to be most appropriate way to manage waste tyre market but would require maintaining significant quantities of waste tyres to be stockpiled to manage the supply fluctuations. Current collection and storage facilities could become part of registered facilities but consideration should be given to location of storage facilities to minimise transportation costs.
Cement Industry Federation	To maintain security of supply to end users, allocation from the central pool should be based on a guaranteed minimum to approved end users. In longer term, as demand balances the supply for tyres an administrator may be necessary.
DEP WA	Option is feasible as part of take back scheme provided the holding facility and administrative scheme were developed and managed by the producers. Government should not be involved.

Managing the Resource Sub-Option 2.3: Sale of Waste Tyres from a Managed Pool

Description of Option:

Intermediate between first two sub-options where the manager controls the supply side (ie administers the collection and transport of waste tyres). Sale of tyres from this pool would then be on a competitive bid basis (ie market forces) but could be some provision for longer term contracts.

Submissions Received:

Submission	Comments
Supports
ATMA	Supports an industry managed Producer Responsibility Organisation. Favours this option from the 3 sub-options for a centralised market.
Eco Waste	Proposes a central handling facility.
DEP WA	Option is feasible as part of take back scheme provided the holding facility and administrative scheme were developed and managed by the producers. Government should not be involved.

Submission	Comments
Opposes
C&R Tyre Recycling	Not supported ­ establishment of a monopoly would develop especially to the detriment for small to medium areas of re-use/recycling industry.
C&R Tyre Recycling	Not supported ­ control could alter the development of new markets.
C&R Tyre Recycling	Not supported ­ would add an additional administration into current infrastructure.
Qld EPA	Not supported ­ model assumes that scrap tyres have a positive value when scrap tyres have negative worth.
Qld EPA	It is not the role of government to interfere in the marketplace and assume the role of picking winners.
Cement Industry Federation	Would not be viable in the current market, as waste tyres have a negative economic value. Also this option would not only deter current resource recovery practices but also not promote or differentiate between current and new recycling and resource recovery operations from landfill disposal options.
NSW Waste Boards	Does not support the establishment of any controlling body (either government, industry or manufacturer based) that would establish a monopoly position in the marketing or physical control of tyres.
NSW Waste Boards	Overall not supportive of centralised market scheme as it generates monopoly conditions. Assumes adequate markets exist when they don't currently. Who covers the risk in this option (government, industry)? Admin and systems costs would apply.
Devote (Encore)	Central collection arrangement is not workable or cost effective. At this point there is no shortage of tyre supply to support any waste recovery initiatives. Should new commercial applications emerge, the market forces will deliver the tyres.
South Pacific Tyres	May encounter problems if there is a lack of resources at inception stage and in continuing operation.
EPA NSW	Co ordinated Government or industry involvement in any centralised market scheme is inappropriate.

Submission	Comments
Design Issues
C&R Tyre Recycling	Who would provide the management ­ government, industry or independent?
Recycling Resolutions	Tyres delivered to a central depot (eg council of shire waste depots) with an all weather working area is a preferred requirement for this operation to facilitate use of mobile shredders. Tyres also need to be divided into major categories.
ACT No Waste	While this approach may have some value in terms of the physical management there are always risks with large stockpiles of tyres and this approach may involve considerable transport issues particularly for regional and rural areas. It may therefore be better to be a network of facilities.
Eco Waste	Proposes a central handling facility (called FORDS - First Point of Receival/Distribution/Storage). Perhaps 10 to 20 facilities nationally. Collectors rewarded for the tyres they bring in. Central storage facility would be a supply and demand buffer between fluctuating demand of the recyclers, reprocessors and actual supply of waste tyres. Redistribution of tyres to recyclers and reprocessors would be to the highest bidder or the provision of contracted resource security to end users. Would be able to direct certain tyres directly to contracted end users to avoid unnecessary double handling in certain circumstances. Funded from a levy placed on tyre manufacturers and importers for a period of around 4 to 5 years after which it should be fully self funding (see also comments against payment at point of delivery option).
ATMA	Payment by PRO to tyre transporters for tyres delivered at point of delivery is essential to give incentive for transporters to use the facility. Also may motivate transporters to access excisting tyre stockpiles or dumps. Some payment should also be passed back to used tyre operators who support the facility.
ATMA	However central holding facility and system of incentives paid to tyre transporters and operators only need to operate for a limited period (say 5 to 10 years), sufficient to trigger appropriate market mechanisms.
ATMA	Must structure the central facility to ensure that no monopoly situation is created. Large-scale users will require resource security via contracts over a sufficient period to warrant requisite capital investment. Even in the presence of long term contracts the scheme should allow access by other end-users where they can outbid large-scale users without jeopardising excisting contractual arrangements with the central facility (ie need to strike a balance between large-scale user and innovative small scale enterprises).
ATMA	Operation of the centralised facility would be let out to tender.
ATMA	Storage of large numbers of tyres is not inherently risky ­ is a matter of appropriate management.
ATMA	Size, location and interrelation of centralised facilities would be determined on a case by case basis by the PRO in conjunction with the successful tenderer who operates the facilities.
ATMA	Other than the excise back up provisions no legislation is necessary to facilitate administration of a PRO scheme.

Improved Value for Waste Tyres - 'Industry Assistance' (ie the Demand Side)

Industry Assistance Option 1: Direct Regulation in Regard to Products

Description of Option:

Direct regulation options that could include a range of options: producers making information available to customers on each type of tyre, minimum standards for products, bans on certain products or processes.

Summary of Submissions:

• An approach to encourage increased use of recycled waste tyres suggested by two stakeholders relates to recycled content in new tyres whether it is required by government regulation or 'driven' by vehicle manufacturers.
• Arguments against were based on cost effectiveness and it if is appropriate for governments to intervene in the market in this manner.

Submissions Received:

Submission	Comments
Support/Design Issues
Torpey Associates	Economic viability of pyrolysis depends on the sale of the component parts of the process and sale of the carbon black. This limitation can be overcome by the manufacturers purchasing and re-using this material in the production of new tyres (eg a percentage of this material mixed with new material). Manufacturers will claim this may create other problems but government could decree say 20% of carbon black be recycled and give an incentive (eg tax break, subsidy). Pyrolysis process can be an economic proposition.
Eco Waste	Within the context of product stewardship the OEMs (original equipment manufacturers eg car manufacturers) have the opportunity to specify or give preferred status to products with recycled content as long as there is no significant price or performance penalty. Tyre manufacturers will simply respond to the needs and requirements of OEMs.
DEP WA	Legislation that requires all tyres to bear the manufacturers name would assist as producers would know they were responsible should their tyres be illegally dumped.

Submission	Comments
Opposed
C&R Tyre Recycling	Not supported ­ would require government to determine what are good and bad product options.
C&R Tyre Recycling	Not supported ­ may constrain the development of innovative products/processes
Qld EPA	Not supported ­ it is not appropriate for government to intervene in the market in this way. Regulation doesn't reward excellence and stifles innovation.
ACT No Waste	The costs v. potential benefits needs to be carefully considered as this approach could be expensive and/or ineffective. Therefore other options should be considered with direct regulation only if other approaches fail to deliver an appropriate outcome.
NSW Waste Boards	Not supported. Would require a government monopoly approach, disincentive to innovation. Government would need to carry any risk. Cost implications to the system.
South Pacific Tyres	Opposed ­ disadvantages would be too great to be effective, no matter what resources are used.

Industry Assistance Option 2: Direct Assistance to Recyclers

Description of Option:

Divert tyres from landfill and inappropriate disposal in the form of unit benefits paid to recyclers (could be a variable benefit depending on the re-use option) or direct funding (eg grants) in response to specific requests for funding.

Summary of Submissions:

• One of the most commented upon options with mostly supportive comments as well as comments relating to design issues that need to be taken into account.
• Support was mainly on the basis of giving waste tyres a positive economic value. Opposition on the basis of:
  • providing subsidies and the market distortions this may introduce (the market should determine which use waste tyres go to); and
  • that assistance to recyclers will tend to be reflected in lower market prices for recycled products and yet price has not been identified as an issue or market failure.
• Beneficiaries
  • Of those who supported direct assistance there was also a strong message that any policy should consider all stages of the process, including tyre retailers, collectors/transporters, recyclers, retreaders and may also include local governments being able to access the funds.
  • Submissions also covered assistance to specific activities; these ranged from assistance to proven technology to assistance to kick start new players and for new processes and assistance to relocate excisting operations to regional areas, from assistance to activities that reprocessed tyres into new usable compounds or products to assistance based on the value recovered and/or added to assistance for material and energy recovery activities.
• Level and type of benefit
  • If there is to be a variable benefit scheme, there was recognition that more research is needed into what the relative benefits should be and what the basis of that should be (eg waste hierarchy, life cycle assessment, some other form of economic modelling, a methodology that incorporates social issues).
  • Consideration will need to be given as to what is the appropriate 'unit' of benefit - weight v. number of tyres v. category of tyre (or some hybrid scheme).
• Sunset Clauses
  • Where the issue of duration of the scheme was raised there was a strong message that it should only be for a fixed period of time and should be removed once markets were established. Most submissions were silent on the issue of a sunset clause.
• Administration
  • Where the issue of management of the scheme was raised there was a common theme of an administrative body comprising government and industry.
  • ATO considers that they are well placed if a government based levy benefit scheme is being contemplated. ATO also identified some key issues that need to be considered in designing such a scheme.
  • Differences between jurisdictions and their differing needs should be taken into account in administrative arrangements and the disbursement of any funds.
• More work, analysis and research is required if a tradeable certificate scheme is to be considered.
• A take back scheme is an alternative whereby producers/importers are required to take a certain proportion of their waste tyres to a recycling function and that this could be an increasing target.

Submissions Received:

Submission	Comments
Supports
C&R Tyre Recycling	Strong support ­ most appropriate mechanism to enhance commercial sustainability of reuse/recycling.
Geocycle	Ideal sees recovered tyres as having a positive economic value, transportation, handling, pre-treatment, operating and capital equipment costs generally prevent this. Hence processor needs an assisted revenue stream as there are currently inadequate returns.
Qld EPA	Supported ­ it focuses on product stewardship principles and addresses the weakest link in the supply chain ­ the transaction between the generator and the transporter/collector.
NSW Waste Boards	Strong support ­ appropriate mechanism to enhance commercial sustainability of re-use/recycling.

Submission	Comments
Opposes
Eco Waste	Assistance should go to establishing a central holding facility and not directly to re-processors, who will not need subsidies to be viable, even to start up if the assured resource flow is available under contract.
Eco Waste	If payments are made directly to reprocessors or granulators, they will tend to reflect the subsidy in the market price for their products and pricing of products made from recycled materials has not been identified as a critical factor or specific market failure.
DEP WA	Opposes concept of subsidy payments as they distort the market and pose problems in the equitable classification of various recycling options.
South Pacific Tyres	Opposed ­ disadvantages would be too great for policy to be effective.
ATMA	Apart from payments to used tyre operators and transporters, assistance to recyclers and other end users creates unnecessary and intractable problems (eg making decisions re preferring one use over another). The market place should determine which use.

Submission	Comments
Design Issues ­ Beneficiaries of Assistance
Rrecycle Aust.	Assistance should only apply to proven technology and involving reprocessing waste tyres into new usable compounds or products (ie not to processes that move or breakdown tyres from one condition to another.)
Gold Coast City Council	Could incorporate payments to collectors on production of evidence of tyres being disposed of at a recognised source of recycling/waste to energy production.
Stanthorpe Council	Supports this option and should be applied at point of manufacture or point of sale. Councils or tyre retailers could then apply for levy monies to dispose of tyres.
Brisbane City Council	A start-up fund will probably be necessary to kick-start new players or promote excisting operations. Funds also need to be allocated to entice the development of new processes or relocation of excisting operations to regional areas, to reduce long range transportation issues and extend the capture rate.
Torpey Associates	For tyres to be tracked from manufacture to disposal, responsibility needs to remain with one body (eg manufacturer or recycler). Could be achieved by manufacturer transferring the right and responsibility of disposal to a tyre recycler. Suggest following system: Recycling fee included in sale price per tyre (collected by ATO) ­ 100% Recycling fee paid to tyre retailer when tyre is returned/collected ­ 20% Recycling fee paid to recycler upon collection from retailer ­ 20% Recycling fee paid to recycler upon recycling and disposal of tyre components ­ 40% Recycling fee paid to manufacturer per tyre using recycled carbon black ­ 20% (or could be a sliding scale of 0 to 20% depending on amount of recycled material in new tyre). Each stage of process is rewarded.
Cement Industry Federation	Provision of a subsidy to recyclers etc should also consider the role of the collector.
NSW Waste Boards	Re-users/recyclers must receive maximum benefit. Benefits also should be paid to retreaders as this retains a significant part of tyre in the market.
Devote (Encore)	A portion of funds generated from a levy should be quarantined for supporting waste recovery activities. Could include: A processing subsidy, payable against the value recovered, and/or added, by the manufacturer Market development assistance Product development assistance
Devote (Encore)	A tyre bounty, payable to the licensed agent from the levy pool, would defray the retailer's waste disposal cost and reduce the financial incentive for illegal disposal.
MTAA	Meaningful uses of funds collected by a levy: Encourage recycling by way of subsidisation Encourage research into better and more effective ways of recycling of scrap tyres Prevent dumping of tyres Prevent storage of large numbers of scrap tyres Educate consumers in tyre maintenance to increase the service life of tyres.

Submission	Comments
Design Issues ­ Level and Type of Benefit
Qld EPA	The need for government to make a decision on level of benefits is not a drawback ­ it is an opportunity to reward those who sit higher on the waste management hierarchy.
Qld EPA	Economic modelling will largely remove uncertainty about the level of unit benefit.
Cement Industry Federation	Supports. However, key concern is that a range of options for recovering energy and materials from tyres should be encouraged and that these options should be supported equally. If relative benefits are being considered, the waste hierarchy is inadequate as the sole means of assessment ­ a life cycle assessment would provide a more useful framework. Local and practical issues as well as economic and social factors should also be taken into account.
Cement Industry Federation	Any funding appropriation from a levy should be based on a per weight basis rather than per tyre number ensuring a higher level of accountability and traceability. Can be achieved from weighbridge docketing and other excisting infrastructure.
ATO	ATO has the capacity to administer both a collection payment systems based on either value based, weight based or a mixture of units.

Submission	Comments
Design Issues ­ Sunset Clauses
Qld EPA	Levy may only need to be interim and can be removed once re-use and recycling ventures are sustainable.
ACT No Waste	Providing assistance to establish suitable reprocessing alternatives has merit but care needs to be taken to ensure that it is not a long-term requirement and does not unduly distort the operation of the market.
Cement Industry Federation	Payment of a subsidy or benefit should be implemented with a sunset clause to avoid undue distortions in the market favouring solutions that do not have long-term commercial or environmental merit. The duration of the sunset clause would effectively determine the barrier to market entry.
DEP WA	If a subsidy was introduced it should be for a definite period only (eg 5 years).

Submission	Comments
Design Issues ­ Administration
Rrecycle Aust.	Independent assessment board established made up of industry representatives in order to assess applications for funding.
Gold Coast City Council	A management body necessary to manage and distribute funds and to guide the scheme. May need to include Govt reps, from MTAs and industry (manufacturers, importers and re-users/recyclers).
MTAA	Administration of and disbursement of funds from a tyre levy pool of funds, should be by both industry and government representation.
MTAA	Waste tyre disposal problems vary between jurisdictions so funds from a waste tyre levy may need to be disbursed on a jurisdiction basis to ensure most efficient methods.
ATO	If a levy benefit arrangement is preferred the ATO is well placed (subject to resourcing requirements) to administer both the collection and payment responsibilities because of its considerable experience and established systems for excise collection and associated payments.

Submission	Comments
Design Issues ­ General
C&R Tyre Recycling	Should be designed to give maximum support to reusers/recyclers to assist viability and market growth.
Hervey Bay Council	R&D and industry assistance could assist re-use/recycling operators with new ideas.
ATO	Recommend that particular attention be directed to following issues when designing a collections and payments regime: Unit of measure for levy collections and grants payments Defining the circumstances under which levy exemptions should apply Agreeing the policy parameters that will guide the application of the PSA system to retreads Industry compliance and reporting requirements Consultation with industry on administrative arrangements Licensing and penalties arrangements, if required Initiatives to engage rural and remote stakeholders Relationship between waste tyre collections and management/recycling operations, particularly with regard to incentive payments; and Relative values of waste management options, and how they might be reflected in scales of payment.
ATO	Preferred timetable for implementation of a levy-benefit scheme would be 12 months to ensure optimal industry consultation and appropriate communication strategies. However, 6 months is a possibility.

Submission	Comments
Other Approaches
DEP WA	Other approaches such as the issue of certificates may be more favourable but would require further investigation.
ATMA	Doesn't see any benefit of a certificate scheme, in making direct grants to recyclers or reprocessors, or in market promotions for particular products.
EPA SA	Tradeable certificates has been suggested as an option. More information is required on what it intends to achieve and how it will be enforced. Potential problem arises with issuing tradeable certificates to retreaders/recyclers/energy users who are also tyre manufacturers/importers.
DEP WA	Alternatively, producers could be required under a take back scheme to take a certain percentage of their tyres to a recycling function and this target could increase over the years. Would assist recyclers without need for government to allocate and manage a subsidy.

Industry Assistance Option 3: Controls on landfill

Description of Option:

Diverting waste tyres from landfills to re-use options through either banning tyres from landfill or raising gate fees.

Summary of Submissions:

• Some support for greater controls on landfill but most recognise the possible resulting problem of illegal dumping given that inadequate markets exist for waste tyres. This is particularly a problem with rural or remote areas or enforcing controls in unmanned landfill sites.

Submissions Received:

Submission	Comments
Supports Controls of Landfill
Gold Coast City Council	Availability of cheap/free landfills in some areas may be an impediment to recycling.
Total Environment Centre	Costs of disposal to landfill needs to be prohibitively high or preferably a complete ban on tyres to landfill.
ACT No Waste	Landfill charges are a major factor in the effective management of waste tyres and the appropriate use of these is supported. However, inappropriate charges can result in illegal dumping, particularly in rural areas or transportation to areas where charges are lower.
Cement Industry Federation	Consideration should be given to short term increased landfill gate fees. Could enable further development of recycling and recovery operations and may facilitate entry of new operators.
DEP WA	Supports this option but may have to implement higher gate fees gradually as alternatives to landfilling became available. Although does have the potential to increase illegal disposal.

Submission	Comments
Opposes Controls of Landfill
C&N Ruggiero	Most tyres placed in landfill when shredded are not suitable for recycling
C&R Tyre Recycling	Not supported ­ would increase the level of illegal dumping.
Qld EPA	Not supported ­ impossible to enforce as most rural landfill sites are not secure and without cheaper disposal options, encourages illegal disposal.
Qld EPA	Landfill bans have been shown to increase illegal disposal.
Stanthorpe Council	Council recently introduced a disposal cost on waste tyres but fears they will face an illegal dumping problem.
Brisbane City Council	Preventing disposal to landfill may increase illegal dumping. If a levy is to be introduced, a portion of that levy should be utilised to assist in regulatory control of illegal dumping of tyres. Current regulatory force would be incapable of policing and detecting an increase in illegal dumping of tyres.
NSW Waste Boards	Not supported ­ not sustainable until demand for materials exceeds supply. Could lead to accelerated dumping. May be an option for the future when alternative use options to landfill are available.
South Pacific Tyres	Opposed unless as an adjunct to a viable scheme. As a stand alone it would contribute to illegal disposal.

Submission	Comments
Design Issues
Hervey Bay Council	Many councils in Qld are running unmanned landfills. These landfills can be targets as a cheap disposal site. Tracking system in Qld should help but also need assistance in the form of a specialised investigating team circulating throughout the State.
Geocycle	Landfill pricing does not adequately fund long-term remediation, replacement or treatment costs. This makes consumer assisted funding of recycling options and conservation of resources more attractive in the long term.
DEP WA	Gate fees within each jurisdiction would need to be consistent ­ is of particular importance for adjacent jurisdictions.
ATMA	Matter best left to States and Territories. However, some instrumentalities may cede waste tyre landfill management responsibilities to a PRO.
EPA SA	Cannot be imposed from a national level, as each State and Territory has the responsibility for regulating landfills. A common approach would need to be agreed and implemented by all jurisdictions which would be difficult given different legislative issues in each jurisdiction.

Industry Assistance Option 4: Market Promotion

Description of Option:

Market promotion activities that could include market research and analysis, demonstration projects etc.

Summary of Submissions:

• Of the submissions commenting on this option, there was support for a market promotion program that could be funded from a levy on industry or funded by government.
• Opposition was on the grounds of likely effectiveness, cost and that it should be the responsibility of individual businesses.

Submissions Received:

Submission	Comments
Supports Market Promotion Program
C&R Tyre Recycling	Support ­ for increased community and industry awareness in form of education, market and product development incentives.
Rrecycle Aust.	Waste management is about education and changing attitudes of individuals and organisations. Such changes are generational changes so need to provide educational programs that equip future generations with the tools to deal with such problems.
Qld EPA	Supported but is subordinate to other measures and is unlikely to have any significant impact.
ACT No Waste	Establishing markets for recycled products is necessary to sustain recovery operations and this is therefore a necessary and important activity that should be encouraged and supported.
Brisbane City Council	Recyclers/re-users must be convinced that a consistent, long-term demand exists for their products before they invest in re-processing ventures.
NSW Waste Boards	Support for education, communication, market and product development, R&D grants funded from an industry levy or by government.

Submission	Comments
Opposes Market Promotion Program
DEP WA	Money that would be required for this option is not justified. Should be responsibility of individual businesses.
DEP WA	Take back scheme requiring producers to direct waste tyres to recyclers, then recyclers would become more viable.

Submission	Comments
Design Issues
C&R Tyre Recycling	Funded by industry under EPR and government under community support for waste reduction initiatives.
Gold Coast City Council	Revenue from a levy system could also be used to fund market promotion and education programs.
Devote (Encore)	A portion of funds generated from a levy should be quarantined for supporting waste recovery activities. Could include: A processing subsidy, payable against the value recovered, and/or added, by the manufacturer Market development assistance Product development assistance

Industry Assistance Option 5: Government Purchasing Policies

Description of Option:

Specific requirements for governments to favour products made from waste tyres rather than virgin materials or to fit retreads to government vehicles.

Summary of Submissions:

• Of those submissions making comments on this option there was mostly support.
• Could include large organisations in addition to government.
• This type of requirement could be of particular use in road building applications.
• Some concerns over retreads - some believe there are safety implications and may also impact on warranties of vehicles.

Submissions Received:

Submission	Comments
Supports Government Purchasing Policies
C&R Tyre Recycling	Support ­ a much greater level of commitment is required by government at all levels as current programs aren't changing purchasing patterns in most areas.
Rrecycle Aust.	Government (and large organisations) should promote a cultural change through its own purchasing policies.
Qld EPA	Supported but requires the support of other measures.
ACT No Waste	As a major purchaser it is important that governments lead by example and purchase recycled products where price and performance are comparable.
Brisbane City Council	Government purchasing programs must be developed to support recyclers and re-processors.
NSW Waste Boards	Current processes in place in NSW.
Eco Waste	Infant industry support in the form of say increased tenders for rubberised asphalt applications would be useful as would a preference for government vehicles with 10-15% recycled crumb in their tyres.
DEP WA	Supports ­ could be effective in encouraging use of waste tyre recycled products.
Devote (Encore)	Would be of great assistance in expanding markets for recycled products (eg specification of recycled crumb rubber in road repair and road-building works)
South Pacific Tyres	Neutral but may impact if it includes a policy on recycled material in new tyres.

Submission	Comments
Has Concerns
NSW Waste Boards	Would need greater commitment in implementation and some further support for research to transfer from using excisting materials to using tyre derived products.
EPA SA	SA Government supports use of recycled products. However, has some concerns about effect on fleet car warranties of using retreaded tyres and in regard to safety and reliability. Risk assessment would need to be undertaken.

Industry Assistance Option 6: Funding for Research and Development

Description of Option:

Funding for research and development where the benefit is of sufficient public benefit (vis-à-vis private benefit).

Summary of Submissions:

• A reasonable amount of support for R&D funded from a levy or by government or tax breaks.
• Opposition on the basis that individual businesses should fund this type of activity themselves especially if they are gaining a competitive advantage. Otherwise they should use excisting incentives.

Submissions Received:

Submission	Comments
Supports Funding for Research and Development
C&R Tyre Recycling	Support for R&D grants.
C&R Tyre Recycling	Funded by industry under EPR and government under community support for waste reduction initiatives.
Hervey Bay Council	R&D and industry assistance could assist re-use/recycling operators with new ideas.
Qld EPA	Supported but requires the support of other measures.
Qld EPA	Success in the R&D field could mean removal or reduction of any industry levy in the future as scrap tyres acquire a real intrinsic value.
ACT No Waste	R&D is important to develop a broad base of suitable technologies and products for used tyres and provision of assistance in the area is supported.
Cement Industry Federation	Supported. Application of this funding should not be restricted to new practices but also include improvement of current practices.
NSW Waste Boards	Support for education, communication, market and product development, R&D grants funded from an industry levy or by government.
Eco Waste	Transitional support for certain R&D issues would be useful. Targeted to support initial bulk market needs (civil applications, asphalt, crumbing/granulating techniques and surface activation technologies) before venturing too soon into rubber recovery/pyrolysis areas.
Devote (Encore)	A portion of funds generated from a levy should be quarantined for supporting waste recovery activities. Could include: A processing subsidy, payable against the value recovered, and/or added, by the manufacturer Market development assistance Product development assistance
Devote (Encore)	R&D and 'start up' investments should be encouraged via non-industry funded grants or tax breaks.
South Pacific Tyres	Qualified support ­ could be effective as such funding would give impetus to exploring new methods of recycling. Currently margins are small, so R&D consequently small.
MTAA	Meaningful uses of funds collected by a levy would include encouraging research into better and more effective ways of recycling of scrap tyres

Submission	Comments
Opposes Funding for Research and Development
DEP WA	Not supported ­ benefits of developing new tyres which are easier to recycle, have a longer life etc would give a company a competitive advantage and therefore the commercial benefits would allow companies to fund their own research.
DEP WA	Under a take back scheme producers would be encouraged to fund research into better products as they would be responsible for their waste tyres.
ATMA	No direct role for a PRO in facilitating research. Best left to individual entities to utilise excisting incentives.

Funding Options

Funding Option 1: Disbursements from Consolidated Fund (Government pays)

Description of Option:

Funding for options to be derived from Consolidated Revenue (ie through general revenue from taxpayers)

Summary of Submissions:

• Very few submissions commented on this option directly. Those that did were mostly against government funding arguing that it was not consistent with a product stewardship approach.
• Far more submissions commented on the levy option (see below) and were broadly in favour of such an approach.

Submissions Received:

Submission	Comments
Supports Government Funding
Devote (Encore)	Initiatives should be driven, administered and funded by the Commonwealth Government.

Submission	Comments
Opposes Government Funding
Rrecycle Aust.	Not supported as it does not put the responsibility back into the community nor promote cultural change.
ACT No Waste	This approach is not supported as it does not apply user pays and would not be an industry initiative but rather a government applied regime.
NSW Waste Boards	Not supported as it is not in line with EPR.

Submission	Comments
Has Concerns
Qld EPA	Is unclear how Consolidated Fund obtains it funding and what level of funding is required.
South Pacific Tyres	Neutral but difficult to administer.

Funding Option 2: Levy (at point of manufacture/import)

Description of Option:

A levy on tyres at either point of manufacture/import, point of sale or point of disposal. Various forms of levy could also exist including based on value, per tyre or by weight. Operation of the levy could be through Commonwealth government, by State/Territory governments, or via an industry-operated scheme.

Summary of Submissions:

• A heavily commented upon option with most submissions supportive of a levy to fund any program especially being consistent with the product stewardship philosophy.
• Point of levy
  • Most support was for a levy imposed at the point of manufacture or import rather than at the point of sale.
  • One stakeholder supports the levy at point of sale whilst another argues that one at point of sale as not addressing backyard tyre sellers.
  • ATO says that a levy at either point of imposition is feasible.
• Weight vs. unit based levy
  • Various views on this issue ranging from a levy based on EPU to based on weight to based on size categories of tyres to some hybrid scheme of weight and unit.
  • ATO says that a system based on value, weight or a mixture of units is feasible. No submission received from Australian Customs Office but subsequently advised by Customs that they would only be able to deal with by units of tyres but could include units within tyre categories (eg trucks, passengers etc)
• Which Tyres?
  • Of those who commented on this issue there was a clear message that locally retreaded tyres should not be levied on the basis that they will have already been levied as 'new' tyres and is also keeping the tyre being re-used.
  • The application of a unit or weight based levy on used imported tyres would have the effect of discouraging their import. A levy would have a similar effect on demand for cheap low performance tyres.
  • Levy should also be applied to tyres on locally produced new vehicles and on new and used imported vehicles.
• Government vs. industry scheme
  • From the submissions that commented on this issue there was no support for a state based scheme.
  • There is divergence on the issue of an industry voluntary levy versus a government mandatory levy. Some have argued that an industry scheme wouldn't work because of concerns over participation of all importers and manufacturers. Others strongly support an industry operated scheme. A hybrid scheme is another suggestion with the levy being collected by a central national agency but disbursements and programs being the responsibility of producers and importers. Others have argued that the administrative role should be shared between government and industry.
  • One submission has strongly argued for an industry scheme with legislative back-up for an excise to be charged to those who don't 'voluntarily' participate in the industry scheme.
• Current Retail Levy
  • From the submissions that commented on this issue there was concern about disposal charges currently being charged by some tyre retailers and that consumers don't get 'hit' twice.
• More detailed work (including modelling) is required into the design of this policy option. ATO also identified some key issues that need to be considered in designing such a scheme.

Submissions Received:

Submission	Comments
Supports Levy
Rrecycle Aust.	Reinforces the responsibilities of the manufacturers/importers in terms of product stewardship and ensures all participants contribute financially.
Rrecycle Aust.	Would have the benefit of sending appropriate signals in terms of waste management to the community.
Qld EPA	A levy of some kind is essential if we are to make any real inroads into improved scrap tyre management nationally.
NSW Waste Boards	Positive support to fund many of the initiatives covered in the report. Still many questions to be answered.

Submission	Comments
Opposes Levy
DEP WA	Not support any options which require levies to fund them. Disappointed that report only discusses levies as a funding option. Past experiences have indicated admin difficulties, high resourcing requirements and problems with timely distribution of money. Would like to see EPR schemes implemented where funding and solutions are the responsibility of producers and importers and government provides necessary legislative support and targets.

Submission	Comments
Design Issues ­ Point of Levy
Qld EPA	A levy paid at the top of the supply chain has many advantages over one paid at the retail or disposal point.
Qld EPA	Levies charged to consumers by tyre dealers/retailers is not supported.
Stanthorpe Council	Supports this option and should be applied at point of manufacture or point of sale. Councils or tyre retailers could then apply for levy monies to dispose of tyres.
Eco Waste	A levy (or an advanced recycling fee) should be applied at the point of manufacture/import and should be managed over a transitional period to fund recovery of historical and current stocks, initial R&D, education and information campaigns, and set up costs for a central holding facility.
Devote (Encore)	Support a levy payable on production or importation of new tyres.
South Pacific Tyres	Support if levy is at point of sale. Could be effective ­ ensures a level playing field and impetus for reducing costs.
MTAA	A levy at the retail level overlooks the fact that it would not affect 'backyard' tyre sellers or unscrupulous operators who operate questionably or illegally. Also a risk that consumers may make a political issue out of the levy, arguing that it is a further impost on the cost of running a motor vehicle.
MTAA	Supports a levy at the point of manufacture or importation.
ATO	Levy could be feasibly imposed at point of manufacture/importation or sale.

Submission	Comments
Design Issues ­ Weight vs. Unit Based Levy
Qld EPA	An EPU based levy is supported. A weight or EPU based levy is more equitable. A tyre manufacturer wouldn't ordinarily modify tyre design to attract a lower levy as levy would not exceed 2% of total tyre value.
ACT No Waste	Applying a weight-based levy appears problematic and may be better applied by sizes (eg small passenger, large passenger, small or large truck, earthmoving etc).
Cement Industry Federation	Any funding appropriation from a levy should be based on a per weight basis rather than per tyre number ensuring a higher level of accountability and traceability. Can be achieved from weighbridge docketing and other excisting infrastructure.
Eco Waste	Levy should be applied by the specific units that define the problem. Should therefore reflect a per casing component and an additional fraction by weight. May need to be larger at the beginning to finance cost of recovering historical stocks and then be reduced.
ATMA	Advanced recycling fee set on basis of tyre categories as used for Customs purposes rather than weight.
ATO	ATO has the capacity to administer both a collection payment systems based on either value based, weight based or a mixture of units.

Submission	Comments
Design Issues ­ Levy on What Tyres?
Qld EPA	Levy applied at the same rate on the size or weight of tyre is proportionally higher on imported second-hand or cheap new tyres. This will help drive waste avoidance measures and the end of the import of worthless second-hand tyres. Equity issues are met as lower cost tyres have a higher proportional disposal cost.
Qld EPA	Applying a levy to retreads is not supported.
Qld EPA	Exempting retreads from the levy will not make them more attractive to consumers than new tyres, as claimed. A $2 or $3 levy on a new tyre will go unnoticed by consumers and therefore have no impact on product choice. Levy will be undistinguishable by most consumers ­ price fluctuations and marketing strategies will act to hide the levy and its impact.
Qld EPA	A weight based levy will have the advantage of making cheap, low performance tyres proportionally more expensive than better quality tyres. A levy will direct motorists to better performance tyres, give a stimulus to local manufacturing at the expense of 2nd hand imports, and promote waste hierarchy through increasing waste avoidance.
Qld EPA	Tyres fitted to imported vehicles should be levied.
Qld EPA	Need to resolve what will happen with excisting scrap tyres and the impact of those tyres entering the recycling system once scrap tyres acquire some value.
ACT No Waste	Levy should not be applied to retreads as retreading is keeping the tyre being reused and the levy would have already been paid when originally sold. Funding from the levy should be used when the retread is finally ready for recycling/disposal.
Eco Waste	Levy should not be applied to retreads until they present for final end of service life value recovery.
Devote (Encore)	Imported second hand tyres should attract higher penalty due to shorter life span. Locally retreaded tyres should be exempt from levy.
ATMA	Supports an advanced recycling fee on replacement tyres as well as tyres on new vehicles manufactured in Australia and tyres on imported new and used vehicles entering Australian market.
ATMA	Advanced recycling fee should not be applied to retreads.
EPA SA	Applying levy to new tyres and not to retreaded tyres will increase price difference between the two products. Market sensitivity analysis is required as it is unclear whether this will affect uptake of retreaded tyres.

Submission	Comments
Design Issues ­ National vs. State/Territory vs. Industry Based
Qld EPA	Various state-based schemes are possible but the focus of this report is to pursue a national approach.
Qld EPA	Difficult to see if an industry based scheme would be successful. Issues include admin costs, need for participation by all importers and manufacturers, linkages with State/Territory legislation covering transport and recycling of tyres. Not convinced that all industry members would willingly participate.
ACT No Waste	Strongly support the establishment of an industry operated scheme ­ best applied at the point of sale for tyre sales and be included on all imported tyres and new vehicles.
ACT No Waste	State operated scheme is not supported as this appears impractical.
Eco Waste	Levy should be collected by a central national agency and accumulated in a dedicated fund. Could be managed by the producers and importers or at least administered by a representative Council against some clearly articulated objectives.
MTAA	Administration of and disbursement of funds from a tyre levy pool of funds, should be by both industry and government representation.
ATMA	Support is for an industry based and industry managed fund with necessary legislative backup for those who don't voluntarily contribute to the scheme.
ATMA	Any fund is best operated and managed by the producers themselves, rather than legislated for by Government and/or imposed or administered from outside. A mechanism must be chosen which ensures that all producers are required to contribute fairly and equally to the fund.
ATMA	Legislative underpinning is required for an advanced recycling fee to encourage all originators of tyres to contribute equally and fairly to a 'voluntary' fund or else submit to a fall-back excise scheme. Fund would used to set up, manage and operate central holding facilities (PRO) and support other aims of the PRO. Exemption from the excise would be provided for any manufacturer or importer who has subscribed to the PRO. Funds from the "Excise" pool (as opposed to the Advanced Recycling Fee pool) could be administered by Environment Australia for national waste tyre management initiatives (although majority are likely to contribute to the voluntary scheme). Could be set at a higher rate than the Advanced Recycling Fee reflecting admin costs.
ATMA	Opposition to a levy collected and administered by government where the tyre industry has limited control of the fund. In such circumstances, would not support any waste management proposal as outlined in their submission.
EPA SA	Report states that it is difficult to make an industry scheme mandatory. This difficulty is under-stated as demonstrated by the National Packaging Covenant which has had to be underpinned by national legislation and this has been more difficult to accomplish than initially expected.
ATO	If a levy benefit arrangement is preferred the ATO is well placed (subject to resourcing requirements) to administer both the collection and payment responsibilities because of its considerable experience and established systems for excise collection and associated payments.

Submission	Comments
Design Issues ­ Current Disposal Charges
Geocycle	System for funding must ensure that the consumer doesn't pay twice ­ once through a levy and through a direct charge by the retailer in addition to any levy.
Rrecycle Aust.	Raised concerns about current disposal charges being charged by some retailers to consumers. Sometimes it is incorrectly badged as having a legislative basis. In some cases only a small proportion is being passed on to collectors ­ it can promote illegal dumping but promoted to community under guise of responsible waste management.
Rrecycle Aust.	Could tap into current retailer imposed disposal charges involving registering and licensing key participants (including retailers). Carriers would collect waste tyres from retailers free of charge and transport them to registered facilities. Wholesalers would take responsibility for the levy. Central independent body ensures all funds directed to dealing with waste tyre problem. Could also fund some grants to support new and excisting technology.
Gold Coast City Council	Current disposal levy charged by some operators ­ where retailers don't participate in scheme, they leave customers to dispose of own tyres that may be dumped. A compulsory levy on manufacturers/importers is considered to be an appropriate way of avoiding this.
ACT No Waste	To resolve the issue of waste tyres requires funding and currently consumers are paying for disposal of tyres at the point of retail but in many cases this money is not travelling with the tyre.
Cement Industry Federation	As a levy is likely to be passed on to tyre consumers it is important that current disposal fees by retailers are not charged in addition to the levy. Could be achieved by compulsory disclosure of levy information by the retailer to the consumer of a receipt labelling system.

Submission	Comments
Design Issues ­ General
Brisbane City Council	If a levy is to be introduced, a portion of that levy should be utilised to assist in regulatory control of illegal dumping of tyres. Current regulatory force would be incapable of policing and detecting an increase in illegal dumping of tyres.
Cement Industry Federation	Supports a levy system that is nationally applied and must ensure the integrity of appropriated funds. Could be used to fund policy options for waste tyre re-use and recovery as well as waste avoidance options and a tracking system.
EPA NSW	No in-principle opposition but a great deal more work will be needed to develop the idea so that meaningful consultation can occur (eg how the levy will be applied, access to levy funds, expenditure of surplus funds and review periods). Also further modelling and impact assessment of options needs to be undertaken.
ATMA	A PRO could commence its operations in the major capital cities and deal primarily with passenger tyres and to some degree with light truck and truck and bus tyres but continue to work for solutions to waste tyres for mining, agricultural and general manufacturing and service industries.
ATO	Development of a Product Stewardship scheme for tyres could draw on the PSA for oil model, with some legislative adjustment to address identified shortcomings and to tailor the detail of the system to meet the particular characteristics of the tyre industry.
ATO	Recommend that particular attention be directed to following issues when designing a collections and payments regime: Unit of measure for levy collections and grants payments Defining the circumstances under which levy exemptions should apply Agreeing the policy parameters that will guide the application of the PSA system to retreads Industry compliance and reporting requirements Consultation with industry on administrative arrangements Licensing and penalties arrangements, if required Initiatives to engage rural and remote stakeholders Relationship between waste tyre collections and management/recycling operations, particularly with regard to incentive payments; and Relative values of waste management options, and how they might be reflected in scales of payment.
ATO	Preferred timetable for implementation of a levy-benefit scheme would be 12 months to ensure optimal industry consultation and appropriate communication strategies. However, 6 months is a possibility.

Other Major Issues or Options Raised

Summary of Submissions:

Other issues raised included:

• Concern over roadside litter of blown or disintegrated tyres (road 'alligators').
• Option of use of bonds or guarantees from waste tyre operators.
• Assistance is required to eliminate excisting waste tyre stockpiles.
• Utilising industry bodies (eg trucking organisations) to reduce inappropriate disposal.

Submissions Received:

Submission	Comments
Hervey Bay Council	Concerned over growing problems of blown and disintegrated tyres, mainly from trucks, which litter the roadside. Unsightly but also a safety concern for motorists.
Geocycle	Enforcement of responsible behaviour through bonds or guarantees on registered operators in the waste tyre industry.
Geocycle	Ensure maximum capture of waste tyres at tyre retail outlets. Retailers have major influence on consumers and what happens to the waste tyre once it is removed from a vehicle.
Total Environment Centre	Supports a government sponsored accreditation program whereby goods and services can be given a waste reduction rating (eg similar to energy rating system for electricals). Organisations could also be rated based on overall waste reduction efficiencies. An annual public report will ensure transparency of the process.
Stanthorpe Council	Consideration should be given for assistance to eliminate excisting stockpiles of waste tyres.
Brisbane City Council	Various engineering applications and manufacturing processes do not lend themselves to use recycled material. This could have serious ramifications in regard to being able to fully develop markets. It may be necessary to investigate various Standards and Specifications for a range of products to identify any issues.
Torpey Associates	Limitations of pyrolysis (purity and VOC content of the carbon black and residuals of other metals in the tyre steel) can be overcome by mixing with virgin carbon black whilst the residuals within the steel can be further processed to achieve the desired result.
Torpey Associates	Real benefit of pyrolysis is that it recycles the complete tyre and through reuse of these components in tyre manufacture may actually reduce the cost of tyre manufacture. This would allow a recycling levy to be incorporated within the wholesale price of a tyre without increasing the retail cost of tyres to consumers or decreasing profit margins of tyre manufacturers. Issues of imported tyres would have to be considered.
WMAA (Energy from Waste Divn).	Waste Management Association of Australia (Energy for Waste Division) has developed draft guidelines for Energy for Waste Project Development.
EPA SA	Options to reduce inappropriate disposal ­ utilising industry bodies and schemes to which truck drivers and fleet vehicles may be members (eg Trucksafe) are additional options that should be examined in relation to this issue.

Appendix A

A National Approach to Waste Tyres - Invitation for Comment

Environment Australia is seeking your comments on the attached report 'A National Approach to Waste Tyres'.

The consultancy report has been prepared by Atech Group. The aim of the project was to investigate and analyse the scope and nature of the waste tyre problem in Australia and to assess options to address the problem.

The report is in two parts.

• Part 1 is a comprehensive overview of the tyre manufacturing and import sector, including a quantification of the number of waste tyres being generated annually in Australia. Part 1 also examines various re-use, recycling and disposal options.
• Part 2 examines various options for addressing the waste tyre problem nationally. In particular it addresses issues such as waste avoidance, reducing inappropriate tyre disposal, improving value from waste tyres and resource security for re-use and recycling options.

The report is a lengthy document. Interested organisations and individuals may wish to focus on Part 2 of the report, as this will be the focus of any ongoing policy work.

Organisations and individuals are invited to make a submission to the Automotive Waste Resources Section, Environment Australia. Written submissions should be provided by Friday 27 July 2001 to:

Ms Leigh West
Assistant Director, Automotive Waste Resources
Sustainable Industries Branch
Environment Australia
GPO Box 787
CANBERRA ACT 2601
(02) 6274 1678 (phone)
(02) 6274 1640 (fax)

Taking into account the views and comments of interested parties, our aim is to develop a national policy approach. Comments received may be consolidated into a publicly available document.

Further copies of the consultancy report are available on-line at the Environment Australia Internet website at www.deh.gov.au/industry/waste/awr/tyres.html or by telephoning Leigh West (02) 6274 1678.

Guide to Submissions

Part 1 - Background to the Tyre and Rubber Industry

Any feedback on Part 1 of the report should focus on correcting factual and/or attribution errors. In providing comments, please indicate the relevant section number in the report.

Part 2 - Analysis of Policy Options

Environment Australia is particularly interested in your comments on Part 2 of the report. To help you in this, the attached table summarises the options considered in the consultancy report.

Environment Australia is particularly interested in:

• Your views on the need for a national approach to address the waste tyre problem.
• Support of, or opposition to, any or each of the options.
• The impact (neutral, positive or detrimental) of options on your interests.
• The effectiveness, efficiency and feasibility of options.
• The existence of circumstances, barriers or arrangements (legislative, market, administrative, technological etc) that may make an option unworkable or ineffective.
• How any option may be improved.
• Any option that hasn't been considered.

In making comments please set out the basis for your views/conclusions and indicate the relevant section number in the report.

We would appreciate it if you would complete the attached Organisation Details page and return it with your submission.

Organisation Details

(Please complete this page and return with your submission)

Organisation name: ..................

Postal Address: ..................

Contact name: ..................

Position in organisation: ..................

Phone: ( ) ..................

Fax: ( ) ..................

Email address: ..................

Type of organisation (tick appropriate box/es):

New Tyre Manufacturer/Importer/Exporter
Used Tyre Importer/Exporter
Motor Vehicle Manufacturer/Importer/Exporter
Automobile Organisation
Tyre User (fleet owners, trucking organisations, transport industry, mining etc)
Tyre Retailer
Tyre Collector
Retreader
Waste to Energy Use
Other Tyre Re-user/Recycler (include brief description of product(s) produced or processing undertaken)
..................
Conservation/ Community Organisation
State/Territory Government
Local Government
Waste Board/Landfill Manager
Commonwealth Government
Other (please specify)

Appendix B

Submissions Received

Sub. No.	Individual/Organisation	Location	Type of Organisation
1	C & N Ruggiero Pty Ltd	Vic	Tyre Collector/Shredder
2	C&R Tyre Recycling	NSW	Tyre Recycler/Re-User
3	Hervey Bay Council	Qld	Local Government
4	Geocycle Pty Ltd	Qld	Tyre Collector, Waste to Energy Use, Tyre Re-User/Recycler (co-processing)
5	Rrecycle Australia Pty Ltd	NSW	Tyre Re-User/Recycler
6	Department of Prime Minister and Cabinet (PM&C)	N/A	Commonwealth Government
7	Recycling Resolutions	NSW	Tyre Re-User/Recycler
8	Gold Coast City Council	Qld	Local Government
9	Discriminex Pty Ltd	Qld	Tyre Re-User/Recycler
10	Queensland EPA	Qld	State/Territory Government
11	Total Environment Centre	NSW	Conservation/Community Organisation/NGO
12	Stanthorpe Shire Council	Qld	Local Government
13	Torpey Associates Pty Ltd	NSW	Tyre Re-user/Recycler ­ pyrolysis
14	Brisbane City Council	Qld	Local Government
15	ACT No Waste (Department of Urban Services)	ACT	State/Territory Government
16	Cement Industry Federation	N/A	Waste to Energy (co-processing)
17	NSW Waste Boards	NSW	Waste Board
18	Waste Management Association of Australia (WMAA) (Energy from Waste Division)	NSW	Other
19	Eco Waste	NSW	Other
20	Department of Environmental Protection, WA	WA	State/Territory Government
21	EPA Victoria	Vic	State/Territory Government
22	Devote Pty Ltd (Encore Rubber and TyreCycle)	Vic	Tyre Re-user/Recycler
23	South Pacific Tyres	Vic	New Tyre Manufacturer/Importer/Exporter
24	Local Government Association of Queensland (LGA Qld)	Qld	Local Government
25	Australian Tyre Manufacturers' Association (ATMA)	N/A	New Tyre Manufacturer/Importer/Exporter
26	EPA, NSW	NSW	State/Territory Government
27	Motor Trades Association of Australia (MTAA)	N/A	Other
28	Environment Protection Agency, SA	SA	State/Territory Government
29	Australian Taxation Office (ATO)	N/A	Commonwealth Government