Comments re: Used Tires Program Plan
As a grassroots environmental organization and registered charity, Lake Ontario Waterkeeper’s goal is to restore and protect this watershed's natural resources, while contributing to its aesthetic, social, recreational and economic values. In working towards this goal, Lake Ontario Waterkeeper has gained experience researching, compiling evidence and litigating on issues related to the industrial burning of tires for fuel, or Tire Derived Fuels (TDF).
As a co-applicant in the recent case, Dawber v. Ontario (Ministry of the Environment), Lake Ontario Waterkeeper worked with a number of experts to gather and prepare evidence on the potential environmental effects of burning tires in cement kilns, one of the commonly proposed uses of TDF. This experience puts Lake Ontario Waterkeeper in the unique position of being a grassroots organization, highly connected and responsive on a local level, with an extensive portfolio of expert evidence and thorough research on the effects and implications of burning tires as fuel. The following comments draw on that research experience and expertise.
Recommendations
In light of the above commentary, Lake Ontario Waterkeeper submits the following recommendations:
Ontario Tire Stewardship’s plan must explicitly exclude Tire Derived Fuel as a legitimate disposal option.
The Used Tire Program Plan must exclude TDF as an option for tires exported to other jurisdictions.
The Ministry of the Environment should implement its proposed ban on tire incineration.
Read the entire comment submitted to the Ministry of the Environment here