Standard 1. A 3 year sales…

Standard 1. A 3 year sales average is ok. 0.85 adjustment factor is a bit low as is 60%by weight recovery...they can do better. On large tires over 39 inches I'm certain that recovery could easily be 95%. And a carry over to the next year is just asking for administration nightmares and fraud. Keep it simple. You make a tire, you recover a tire.

Standard 2. Is an extremely important component to the whole mechanism and there must be collection points in all communities. 100% of them. Your paper only suggests collection in communities over 1000. How do you treat those of us under 1000? 10 Tires per day from one person. I don't know what you envisage but if someone is bringing in ten tires a day for multiple days then you had better find out why. If its a transportation business ok, but if it is a private citizen then something is wrong. Managing tires Utilizing 85% of the recaptured tires is fine as long as the 15% left doesn't go into a municipal landfill; it must be co-ordinated into a central landfill for all tire remnants.

Overall, 100% of Ontario communities must be considered in recapturing used tires....at least 90% to start. And that is all tires not just the ones over 39 inch rim size. They all fill up landfills. And this must not be dumped upon one retail outlet, they must work together to fulfill the requirements. And certainly any garage, depot, service centre, that installs tires must be included in the capture and collection and be paid by the consortium of producers for their time and effort for the capture and collection.

[Original Comment ID: 211568]