RMA, ISRI oppose Conn. recycling bills

HARTFORD, Conn. (Feb. 24, 2017) — The Rubber Manufacturers Association (RMA) is opposing two bills before the Connecticut General Assembly that would create extended producer responsibility (EPR) systems for tire recycling and for recycling programs in general.

The Institute of Scrap Recycling Industries (ISRI) also opposes the general EPR bill.

Connecticut House Bill 6352, which would establish an EPR for scrap tires in Connecticut, is more draconian than the state's scrap tire situation warrants, the RMA said in Feb. 8 testimony before the Connecticut Joint Environment Committee.

Connecticut has small-scale illegal scrap tire dumping but no program to address it, the association said. The state generates 8 million to 10 million passenger tire equivalents a year, the RMA said, and since the closing of the Exeter Energy L.P. tires-to-energy plant, most Connecticut scrap tires go to Maine and pulp and paper mill fuel.

While the RMA wants to work with Connecticut to create higher-value end-markets for the state's scrap tires, an EPR system is not the way to proceed, the association said.

"An EPR system for managing scrap tires in Connecticut would add costs and bureaucracy without any significant benefit, displacing and bringing inefficiency to a well-functioning free market system," the RMA said.

Costs to Connecticut consumers would go up significantly under an EPR system, and those costs would send them across the border to buy their tires in neighboring states, according to the RMA.

"One rationale for EPR is to take costs off the municipalities," the association said. "Scrap tires generally do not enter the municipal waste stream, as they are generally collected at small tire dealers. Cost savings to municipalities are both minimal and not quantified.

"H.B. 6352 would pose a top-to-bottom overhaul for a system that needs minor adjustments," it said.

The RMA testified in the same committee Feb. 22 against H.B. 7067, which would give the Connecticut Department of Energy and Environmental Protection (DEEP) the authority to mandate EPR systems for any products.

"DEEP would have free rein to choose products for EPR, despite any and all evidence that a given product's end-of-life management is successful," it said. "This grant of regulatory power circumvents the ability to engage in a reasoned, useful debate."

In its testimony, ISRI made similar objections to the bill.

"H.B. 7067 is drafted in such a way that ignores the strength, capabilities and vibrancy of the existing recycling industry," it said.

"Under the proposed framework, when a product is identified for inclusion in a product stewardship program, the manufacturer of that product is put in charge of developing how that product will be recycled," it said.

H.B. 7067 lacks the necessary requirement that DEEP conduct a full market analysis before identifying a product for a stewardship plan, according to ISRI.

"A competitive bidding process that is not tied to other mandatory requirements is essential to ensure the economic efficiency of recycling programs," it said.