Tire recycling is a vitally important business in today's Pennsylvania, both environmentally and economically, and has been featured on both the Discovery Channel's Dirty Jobs and PCN's Tours. Tire recycling can be a profitable business, but depending on the nature of the products produced or tires used, the margins can be very small making tire businesses rely on quantity to keep them operating in the black. For refiners and end users, it can be difficult to find the feedstock they need to produce a finished product, which causes them to look outside the state or country to meet their needs. Those businesses that do not rely on the quantity of tires have discovered economic stability through a niche market, by delivering high quality products to serve their customers with specific needs.

To utilize a hard to process and dispose of commodity, those in the tire industry employ a mix of technology and innovation. Tires are difficult to break down as they are made to last and incorporate a mix of rubber, steel wire, fiber, and even newer materials like Kevlar, that are designed to last tens of thousands of miles and withstand the rigors and abuses of paved highways and roads. To that extent, tires are buoyant, collect and hold water and are heavy, averaging 20 pounds for a passenger and 50 pounds and up for a truck tire. For decades, tires have been looked at as a problem, but more recently, the focus has been on not simply developing products that incorporate recycled rubber, but rather promoting the value added aspects of this commodity as one that improves existing products and standard materials. Testing and evaluation is constantly taking place not only to find new uses, but to improve the quality of current goods in a constantly evolving and demanding marketplace.

The subject of waste tire recycling is far from new in Pennsylvania, and despite regional market dynamics and the successful use of different products, the state is unique from others in many cases. Because of the Commonwealth's climate, geography, transportation network, collection logistics, and processing infrastructure, recycled rubber products have met with varying success. In addition, the costs to produce the same tire product based on transportation, seasonal supply factors, re-use of generate by-products, layers of process and refining, end use value, infrastructure costs, and types of tires used differ considerably. These factors make the number of tires in certain projects difficult to determine, complicate project analysis, and skew state-to-state comparisons.

Tires have been viewed as a waste and as a recyclable, and many recycling and reuse options have been viewed with pessimism. While recycling and reuse is encouraged for items such as glass containers, newspapers, corrugated cardboard, office paper, aluminum cans, steel cans, plastics and leaf waste, waste tires often fall under the public's radar as a recyclable. Although tire recycling is important and encouraged by the Department of Environmental Protection (DEP), it is also regulated as residual waste. Permits are required for tire storage, transport, and processing, as well as for air quality. Despite improvements over the years, a stigma surrounding tires still exists and many of their uses are viewed skeptically. A tire is something that meets the road, not as something that a child plays on or is used in the home.

Pennsylvania has been performing well in both market development and tire clean-up, the two most important aspects surrounding this issue. The Commonwealth generates approximately 12 million tires annually, or roughly one tire per year for every resident, while nearly 10 million tires lay on piles throughout the state. The piles are decreasing as successful enforcement and remediation projects have combined to ease a potential problem that for decades has scarred our landscape and posed health and fire hazards. Progress is being made, but there is still work to be done. Since the lapse of Act 190 of 1996 monies, tire clean-up has suffered from inconsistent appropriations, a slowed pace of remediation, and a lack of continuity. The primary responsibility for tires fall under DEP's Bureau of Waste Management, which carries out enforcement and oversees clean-up, but other bureaus and agencies have been given authority over certain areas, contributing to the lack of a unified message. Many funds were established while others were tapped to fund tire pile clean-ups. General fund monies, permit fees and fines, and penalties together comprise the available resources. Pennsylvania levies a one dollar per tire fee on the purchase of new tires, but that money goes exclusively to the Public Transportation Assistance Fund, which supports mass transit, limiting the potential benefits that many other states with fees, that support tire clean-up or recycling, enjoy.

Currently, most tire related funds have a zero balance, making clean-up money scarce and grant money non-existent. The tire recycling industry in Pennsylvania is strong, and the creative uses for tires are growing. All of the annually generated tires are being consumed, and it is clear that the piles on the ground, while a finite problem, will persist without a commitment of time and investment of money. It is not practical for the industry to clean-up the tire piles on their own, nor would those tires meet their quality needs, which limit their potential uses.

In many cases, when tires are discussed, the focus is on recycling and reuse, environmental benefits, and economic growth. Creative uses for scrap tires have been looked at by The Pennsylvania Department of Transportation (PennDOT) dating back to the 1960s. Additionally, there has been a consolidated effort by the state, since the late 1980's to recycle and purchase recycled rubber products. What is new, however, is the number of uses, the professionalism of the processors and manufacturers, the commitment of the industry to quality, and the technology to process and refine tires. Industry leaders have made significant investments in their businesses and have overcome many obstacles to product use, but this and other factors can keep prices higher than standard materials. The cost factor is difficult to overcome which can further inhibit waste tire use, as is the case with state purchasing. Even in the case of improved performance and longevity, higher costs for future savings is a tough sell.

Many state agencies have sponsored pilot projects using recycled rubber products, but few programs have resulted in any sustained usage. In most cases, cost was the significant factor in their decision to discontinue use, regardless of performance. In the case of PennDOT, it has the ability to use significant amounts of rubber through not only asphalt, but other civil engineering applications as well. However, where rubber has its best performance is often when it is used in lesser amounts. Early testing of rubber modified asphalt, at 10 to 15 percent replacement of the standard materials, had significant problems. However, newer technologies that incorporate less than five percent replacement of standard materials have performed well. These mixtures with only a small percentage of rubber use few tires and in most cases, no tires from tire piles due to quality specifications.

PennDOT officials continue to show little interest to testing new rubber modified products due, in part, to their past experiences of higher costs and mixed performance, but they have not completely given up on rubber. Through a Memorandum Of Understanding (MOU) with DEP, new rubber modified product testing is done annually, specifications are updated, and evaluations of new projects and materials are made. This is important because many local governments rely on PennDOT's research and specifications. Private contractors performing work for PennDOT can also suggest alternate materials and utilize provisional specifications, but few contractors take advantage of these options. Allowing PennDOT's maintenance district personnel to work with contractors to incorporate materials, like rubber, into their projects has been more productive than dictating from their central office. All that being said, it is unfair to think that PennDOT, or any one department's use of recycled rubber in pilot projects, would have a significant impact on product markets or reducing tire piles. Only sustained use will accomplish those goals. It is also unrealistic for the state to pay a cost prohibitive amount for any recyclable just to feel good about recyclable content purchasing.

Despite all the good things the tire recycling industry has done since 1996 including reducing the number of tires on piles throughout the Commonwealth from 36 million to near 10 million, the developing new tire derived products, and increasing use of new technology that makes the delivery of higher quality products feasible, negative experiences continue to be associated with waste tires. These experiences include: tire fires around the state producing plumes of black smoke and residual runoff; tire piles becoming breeding grounds for mosquitoes which can carry the West Nile Virus; and many of the early tire products, including RA, not performing well or being prohibitively expensive. In many cases, it is those experiences that continue to resonate with many individuals around the state and in government, leading to the continued view that tires are a waste and not a recyclable commodity.

Over the last ten years, the state has made a significant investment of time and money in tire clean-up, regulation, and enforcement. Several significant pieces of legislation have enabled this to take place and helped to establish the current Commonwealth policy towards waste tires. The steps that have been taken include: remediation of existing tire piles; a crackdown on collecting, hauling, and processing tires to prevent the creation of additional piles; funding of various grants from DEP and Department of Community and Economic Development (DCED) to assist qualified businesses expand their processing capacity, invest in refining infrastructure, and enter new markets; and the establishment of government purchase guidelines and incentives for the use of recycled rubber products. In some cases, however, there seems to be a disconnect between executive policy and program management. As uses for tires are promoted and money is appropriated for tire clean-up, progress is still slow to clean-up the tire piles. Despite millions of dollars and dozens of new uses for tires over the last ten years, there are still tires on the ground, markets still have the capacity to expand and grow, and the state has room to expand its use of tire-derived products.

While it is good policy to clean-up tire piles and get them to positive end uses, it is a difficult balance to remediate and regulate tires while promoting their re-use and sustaining the markets that support this industry. Tires not bound for recycling or reuse pose a risk, so getting annually generated tires in the hands of licensed users is just as important as tire clean-up. Strengthening Pennsylvania's landfill laws, which currently ban whole tires, to ban all tires has been discussed as competition for tires is stretched to the limit. Existing waste tire businesses are operating below capacity because they cannot get enough tires or feedstock, and demand for waste tires will only grow as businesses grow and new companies enter the tire marketplace. Some processors are forced to import tires, and with the limited uses of pile tires, a landfill ban or collection requirement may be the key to future industry growth. Regardless of demand, it is unlikely that the industry will clean-up piles on their own due to the limited uses for these tires and the costs to recover them exceeding their business margins.

The best way to deal with clean and dirty tires is a matter of opinion, just like the funding priority, clean-up plan, and sustainable markets development. One thing that is easy to see are the raw data, specifically on tire clean-up and spending. Compiling numbers of waste tires for annual use is difficult, and tracking tires across the various uses, as well as imports, exports and landfills is equally a challenge. Stockpiled tire numbers are estimates as are clean-up numbers, which are based on truck weight and Passenger Tire Equivalents (PTEs). All these factors combine to make an already complicated issue even more complex.

Setting public policy is a mix of strategy, actions, and priorities to meet a set of goals. Legislative priorities have been divided into short and long terms goals. While reducing the tire piles and growing the tire recycling industries in the state are short-term goals that have been met, there has been no long-term planning. For example, tire piles are a finite problem, but there is no blueprint in place to reach the ultimate goal of cleaning up all remaining tires on the ground. Since tires will continue to enter the recycling stream annually, and policies designed to sustain and grow the markets and recycling infrastructure in Pennsylvania are needed. As funds are stretched tighter and it becomes difficult to raise fees and taxes to support specific projects, businesses and the state will be forced to seek creative ways to solve tire problems.

Despite some inconsistencies in the data between DEP and tire industry groups, some things are clear: markets are performing well and tire piles are not growing. In the court of public opinion, some say piles need to be cleaned-up faster, and some in the industry say they want to enter different market sectors. No one can dispute the devastating environmental impact that tires can have when on the ground, but it is unreasonable to create false markets based on subsidies or for the state to purchase recycled products that are not cost competitive. What will decide this issue is the decision to either make the investment to get tires cleaned-up as fast as possible while not disrupting the markets or to maintain the status quo. While this report is not going to solve all the challenges set forth over decades of dealing with scrap tires, it will provide policy options to make simple, yet focused changes to the current tire clean-up program, marketing efforts, and funding disparity.

The tire issue is still evolving in Pennsylvania, and what once represented a problem and a waste now represents promise and a commodity. Resolutions to this issue are still moving forward, and while it may not be fast enough for some, progress is being made. Rewriting this path is neither prudent nor wise, but there are issues that need to be resolved to make this progress more efficient and sustained. Tires need to be a constant presence on the radar screen of DEP and the General Assembly in order to prevent the inconsistencies of the past. Based on these conclusions, several policy options/recommendations have been made, to accomplish the goals of eliminating all waste tire piles, creating and expanding upon the uses for and quality of tire derived products, and sustaining market growth to prevent the reemergence of any tire problems in the Commonwealth. A list of policy options/recommendations can be found on page 84 of the printed report.