A National Approach to Waste Tyres: Submission to NEPC February 2003

Transcription

1 A National Approach to Waste Tyres: Submission to NEPC February 2003 Australian Automobile Association GPO Box 1555 Canberra ACT 2601 Phone: Fax:

2 2 AAA response to the Environment Protection and Heritage Council s October 2002 paper: A National Approach to Waste Tyres: Policy Discussion Paper Introduction The AAA welcomes the opportunity to make a submission to the Environment Protection and Heritage Council on the topic of waste tyres. The AAA is the Federal secretariat of the State and Territory motoring clubs, its members being: National Roads and Motorists Association Limited Royal Automobile Club of Victoria (RACV) Ltd Royal Automobile Club of Queensland Limited Royal Automobile Association of South Australia, Inc Royal Automobile Club of Western Australia, (Incorporated) Royal Automobile Club of Tasmania Automobile Association of Northern Territory Inc. and Royal Automobile Club of Australia The AAA represents over 6 million motorists, being the total membership of these clubs and associations. AAA agree that tyre disposal is an important issue that is appropriately addressed at a national level. Improper disposal of tyres results in loss of a valuable resource, and landfill and environmental problems (they provide habitat for vermin and mosquitoes and stockpiles pose fire hazards with consequent air, water and soil pollution risks). Currently there is little incentive for motorists to deliver used tyres for recycling. They are often charged a fee to deliver tyres to waste depots. In remote areas, there is often nowhere for motorists to take their used tyres. Policy Options The Discussion Paper considers three policy options for encouraging greater recycling of used tyres: a take back scheme (manufacturer/ importer takes back and manages the used tyres); a levy-benefit scheme (levy imposed on manufacturer/ importer and benefits given to recyclers and/or collectors); and a tradable certificates scheme (certificates issued to tyre recyclers and purchased from them by the manufacturers/ importers).

3 3 Different approaches are considered for each type of scheme, including voluntary industry schemes, government regulation and a combination of the two. Unfortunately, the Discussion Paper does not provide sufficient information on the impact of the various options on manufacturers, retailers, recyclers, and consumers to make a judgement as to the preferred option. However, AAA submits that in addition to being effective in encouraging the collection and recycling of used tyres, a scheme should ensure that the following outcomes are achieved: - any increase in the price of tyres should be kept to a minimum; - tyre disposal should be free for motorists; and - used tyres need to have sufficient value to discourage illegal dumping by collectors; it should be sufficient in remote areas to cover transport costs. On this basis, a disposal levy on motorists is not supported. It is also worth noting that a disposal levy may provide an incentive for illegal dumping of tyres. Cost to the consumer It is most likely that each of the options would result in an increase in the cost of tyres to the consumer, as the manufacturer/ importer will pass on their additional costs. The AAA is concerned to see that this increased cost is kept to a minimum. When determining targets for the scheme, setting any levy or fee and determining any benefits to be paid, the ultimate cost to the consumer needs to be considered. If the cost of tyres increases significantly, some people might defer their buying of new tyres, thereby increasing the incidence of bald, unsafe tyres. Recycling fees or levies, if any, should only cover the costs of ensuring collection and appropriate reuse or recycling. Life cycle costing, mentioned briefly in the Discussion Paper, is not an appropriate method for determining what might be an appropriate fee or levy. Rather, environmental costs of the production and use stages of tyres should be paid for at these stages to ensure that they send the right signals to the manufacturer (e.g. that costs depend on the degree of energy efficiency in processing) and to the user (e.g. that costs depend on the number of kilometres driven). If environmental costs are covered by an arbitrary figure in an end-of-life levy or fee, they are not related to the actual cost and therefore will not have the desired effect. The Discussion Paper discusses potential targets for the program:

4 4 100 per cent, namely the same number of tyres would be collected as sold/ imported; less than 100 per cent because remote location or illegal dumps may mean that 100 per cent collection is not feasible and/ or viable; and more than 100 per cent, namely more tyres would be collected than are sold/ imported to account for stockpiles and orphan tyres. In our view, a target of 100 per cent or more will mean that consumers are paying for the disposal of more tyres than the ones they purchase. This would not be acceptable. AAA submits that although tyre stockpiles can to some extent be attributable to current drivers (given the life span of a tyre), the imposition on consumers should be kept to a minimum by dealing with the stockpile over an extended period of time. Any levy or fee will need to be regularly reviewed to ensure that consumers are not paying for more than is necessary once the problem of tyre stockpiles is resolved. Safety implications of used and retreaded tyres In determining what benefits might be paid to recyclers of tyres, safety implications must also be taken into account. Tyres are an important safety feature of motor vehicles. Used and retreaded tyres have the potential to compromise safety. Although it would be best from an environmental perspective to re-use tyres as tyres, the fact that their history is not recorded and damage to tyres is not always visible, there are safety implications of re-using them on passenger vehicles. Member organisations recommend that used or retreaded tyres not be used for passenger vehicles. It is, however, recognised that retreaded tyres can reasonably be used on trailers and the un-driven and un-steered wheels of large commercial vehicles. Imported used tyres A large proportion of imported used tyres are unroadworthy (a 2000 RACV survey showed that 40% were unroadworthy). Of those that are roadworthy, many have a limited life span (30% estimated to last only 12 months, RACV 2000). Apart from their potential to compromise road safety, they are essentially another country s landfill, and their short lifespan sees them quickly become part of Australia s waste management problem. For this reason, a recycling scheme will need to cover imported used tyres.

5 5 Tyre Maintenance and Choice of Tyre In addition to the three main policy options, the Discussion Paper briefly mentions some complementary policy options. These include educating consumers about what to look for when buying tyres, and how to care for tyres so as to increase their lifespan. An easily understood, independent assessment of tyre quality would be useful information to consumers. However in addition to tyre life, it would need to cover a range of other factors including safety. Compiling such information is likely to be a costly exercise, especially given that tyre performance is affected by many different factors and can vary from one batch to another (for example, if the quality of the rubber differs). Whether the provision of such information would greatly change the tyre buying practices of motorists is not clear. Educating motorists about tyre maintenance and driving styles is important for extending the life of tyres. From time to time, AAA member clubs provide information on tyres and tyre maintenance to motorists through their magazines and via websites, media releases, brochures and education campaigns. Often the messages given are for reducing fuel consumption and/ or increasing safety. However, they have the same effect of increasing tyre life. For example: Ensure that wheels are properly aligned and the tyres are kept at the correct pressure ; Drive smoothly ; and Be efficient with the amount of driving you do. Market promotion In our view, this issue needs greater consideration, as we believe that there may be significant benefits to be obtained in this area. We are a little surprised that the Discussion Paper does not put this option forward as an explicit one, rather than a complementary option. It seems to us that the starting point for deciding what to do about used tyres is to determine the usefulness of used tyres and whether there is a market for them. If there is no market, then we need to explore why this is the case. If there is some value in used tyres and it seems there is and this is not being adequately exploited (for example, for civil engineering applications), then the impediments to the creation of such a market need to be explored. There may be a role for Government in this area. For example, rather than have motorists pay a disposal levy (as occurs in Western Australia and ACT where the cost is $2 per tyre), the collection costs could be assumed by a Government agency (for example, at recycling depots and land fill areas). These costs could be recovered by sale of the product to those involved in the recycling, or re-use industries. The use of Government recycling depots in this way, would minimise collection costs as they are the most convenient and economic point for motorists to dispose of tyres. This activity may stimulate the private sector to emulate Government and set up similar recycling depots

6 6 for tyres. An industry, or industries, centred around used tyre recycling may develop. The Government could have a further role of stimulating those industries which might make economic use of used tyres, either by research or by legislation (for example, requiring more rubber use in open grade asphalt on road surfaces).