In 2015, ISRI testified against extended producer responsibility (EPR) model bills in Connecticut and Vermont that would have placed control of the tire recycling industry in the hands of tire manufacturers.
While those bills were defeated, similar language has returned with Connecticut HB 6325 (currently a shell bill with no body text) and Connecticut HB 6352, focusing on producers, not recyclers, as the party that would control tire recycling under its model. If you have questions about these bills or would like to assist ISRI in opposing them, please contact Danielle Waterfield.
HB 6352 assumes (based on no evidence given the nature of other EPR programs across the states) that EPR can function effectively with little to no government oversight, and even tasks producers to "minimize public sector involvement in the management of discarded tires." The closest recyclers come to a being included is an offhand mention that producers must notify the Department of Energy and Environmental Protection (DEEP) if they change the "processing facilities" that they use. We've included a summary of the major points below:
- Producers have their own definition, as do tire generators (retailers, garages, and dealerships) as “covered entities,” but tire recyclers are not included aside from a single reference to notifying DEEP of “a change to the processing facilities to be used.”
- "Recycling" is defined as "any process in which discarded products, components, and by-products may lose their original identity or form as they are transformed into new, usable or marketable materials. “Recycling” does not include the use of incineration for energy recovery".
- Beginning July 1, 2018, producers must submit plans for CT DEEP approval that minimize public sector involvement and provide for free and convenient drop-off opportunities, free collection, storage, and transport for municipal transfer stations, and producer-financed management and recycling. Producers set their own goals and financing structures.
- “Recycling shall be preferred over any other disposal method to the extent that recycling is technologically feasible and economically practical.”
- Beginning October 15, 2008, producers must report the tonnage collected, the tonnage diverted to recycling, a summary of their public education activities, an evaluation of the program's effectiveness in meeting goals, and recommendations.
- Covered entities may not charge for the receipt of tires.
In addition to these bills, Connecticut is also considering HB 7067
, a general EPR framework bill that would give the state's Commissioner of Energy and Environmental Protection (DEEP) unbridled authority to set up so-called extended producer responsibility (EPR) programs for any object or substance identified in regulations. New England Chapter President Greg Mitko testified
against the bill on February 21, citing multiple issues including market distortions and flow control.