For the Environment Committee
Testimony of Alicea Charamut, River Steward
February 22, 2018

Testimony on RB 5128 – An Act Concerning Beneficial End Uses for Discarded Tires and the Efficacy of Tire Hauling Licenses or Permits

Aside from the submittal date, HB 5128 is the same bill as HB 869 passed by the Environment Committee in 2015. HB 869 began as a bill to establish a tire stewardship program but this committee wanted more information. Thus HB 869 became a study directed at DEEP. This bill then passed the Senate but was never called in the House for a vote.

However, DEEP proactively provided a report to this Committee in 2016 titled, “Long_Term_Management_Options_for_Scrap_Tires_Generated_in_Connecticut” as well as a supplement summarizing the scrap tire management programs in Maryland, Michigan and Texas which I have attached to this testimony.

The following is the conclusion of this report:

Of the three discussed management options for scrap tires, EPR is the most likely to achieve the best outcomes for illegal dumping, job creation and recycling/environmental benefit. Based on the experiences of Ontario and British Columbia, EPR is comparable in costs when factoring in fees paid for disposal and fees to support a state tire program. The current market-based program for disposal of tires fosters illegal dumping by reacting to increased disposal fees caused by shifting market conditions. By placing a mandate to recycle to the greatest extent possible, EPR will create private sector jobs by providing a secure feedstock to businesses that recycle tires. Creating a state program specifically for tires would require establishing a tire fee to provide funding yet without the efficiencies of an EPR program. Programs in Ontario and British Columbia demonstrate that EPR can effectively and efficiently manage scrap tires through recycling at a reasonable cost, and eliminate illegal dumping while creating private sector jobs. Existing EPR programs for ewaste, paint and mattresses in Connecticut have been enthusiastically embraced by most municipalities for relieving financial burdens, facilitating collection and reducing illegal dumping.

In 2017, HB 6352 – An Act Establishing a Tire Stewardship Program was introduced to this committee. The original bill was stricken and replaced by a bill that would require DEEP to establish a hauler license. A hauler licensing program would require the development of a new program within DEEP, an agency that is already grossly under-resourced. This is aside from the fact that DEEP’s report was clear that state-run programs such as this are not effective at reducing illegal dumping and that Tire Stewardship programs are more effective in creating jobs, reducing (if not eliminating) illegal dumping and increasing recycling rates cost in a cost effective manner.

The way Connecticut currently treats scrap tires is a recipe for illegal dumping and this will continue until disposal of tires is free and easy. Government and industry are not working to create safe and innovative ways to reuse tires. This means that scrap tires are a cost to consumers and municipalities and have less and less value to haulers and processers, which means they are piling up and ending up in our rivers. Each year during our Source to Sea Cleanup, an annual river cleanup of the entire Connecticut River watershed, volunteers pull out an average of 700 tires each year from the Connecticut River and its tributaries. CRC would love to get out of the business of pulling tires out of rivers. We have witnessed the success of the Mattress and Paint Stewardship Programs and are confident that a Tire Stewardship Program will not only solve the issue of illegal dumping of tires, but also bring economic development to the state by encouraging scrap tire processors and businesses that use scrap tire in innovative and beneficial ways to establish here in Connecticut