ITEM 1: This would only…

ITEM 1: This would only further strain the system as it does not change the total tonnage required to be recycled. This would result in haulers putting existing customers on the back burner in order to meet these requirements, resulting in a net-zero impact. Without increasing the total tonnage required to be recycled, PROs and haulers are still going to have to balance the existing quota.

ITEM 2: Allowing tires to go to EFW programs, especially if local to rural Ontario, would alleviate a number of pressures on the recycling system, as this would lower transportation costs, lower transportation emissions, and provide an additional output of tires during peak times.

ITEM 7: This would cause incredible problems in the industry. Ontario based recyclers are already receiving the bulk of the tonnage collected, and they are not able to process all types of tires. There are currently no processors in Ontario that are able to handle OTR tires, and as mine sites continue to start up in the North, more and more Giant OTR tires will be produced with no one where to go, if the tonnages leaving the states are counted as less. Additionally, as mentioned above, if you are doubling the amounts going into Ontario recyclers, quotas will be hit even faster, and you will have an even larger backlog of tires sooner in the year. I believe expanding this to Canadian activities and making it easier for adjacent provinces to be RPRA compliant would be more beneficial to the environment.