Citizen's Air Watch * Cupertino, CA *
408 973 1085
Mr. David Roberti, CIWMB
8800 Cal Center Drive
Sacramento, CA 95826
Re: California Waste Tire Program: Evaluation and
Dear Mr. Robert
West Valley Citizen's Air Watch (WVCAW) is a citizen group organized
to monitor air quality issues and promote true recycling of used
tires. We have conducted extensive research into the area of pollution
emissions from burning tires for fuel in cement kilns and into the
true recycling options for used/"scrap" tires.
Due to work committments, members of WVCAW are unable to attend the
meeting on Monday, Oct. 4, at the IWMB. Our purpose in attending
would be to share insightful and learned letters opposing tire burning
as an option for utilizing used tires, which was sent to the IWMB by
the Sierra Club and Dr. Seymour Schwartz.
We are hopeful that you, as a new member of the Board, will take a
fresh look at this issue and not be unduly influenced by the outdated
approaches to this issue. Burning tires for fuel is taking a step
backwards. California should be leading the nation in promoting and
supporting true recycling and source reduction, not tire burning for
* Burning tires for fuel is not recycling. It is a waste of a
valuable resource, the synthetic rubber, which can be put to many
* It is a waste of energy as it takes around 7 times more
energy to manufacture a new tire as the amount of energy obtained from
burning a tire for fuel.
* It is a cheap form of fuel for industry and an expensive
health cost to the citizens living in communities with cement
* Burning tires for fuel should be phased out over a three to four
year period starting in January.
* Tires are required by California law to be chipped into
pieces. Only illegal tire piles store or bury whole tires which lead
to issues of mosquitoes, etc. The legislature is working on
legislation to control disposal of used tires. Dr. Schwartz recommends
a rebate for turning in used tires which would go a long way towards
eliminating illegal disposal of tires. Rewarding turning in of tires
will be cheaper in the long run than trying to track down and fine
* The IWMB has done *nothing* to enhance or promote source
reduction. The IWMB is required by PRC 40051 to do so as the top of
the hierarchy. This is a good law which is being ignored by the IWMB.
Dr. Schwartz recommends and we heartily concur, that new cars sold in
California be required to contain tires rated to last at least 100,000
miles. This will go a long way to reduce the waste stream of
* Rubberized Asphalt Concrete can use most or even all of the 30
million used tires generated each year in California. RAC is being
used successfully in various states and especially in Los Angeles
County. It takes 1/2 the material, lasts two, three, four or more
times as long as conventional pavement, requires significantly less
maintenance, is quieter -- anywhere from 5 to 60 % quieter -- saves
the communities money over the long run and to top it off, the tires
of the vehicles that drive on it last longer. Using the Green Book
formula, the success rate has been astounding.
* A Northern California RAC center should be opened this year.
The Southern California RAC Center is proving to provide an invaluable
service to those communities wanting to utilize RAC on their highways
and in training companies to successfully learn how to apply RAC.
* The Board's same old approach to promote and further
increase the burning of tires for fuel instead of moving forward to
promoting the above mentioned solutions is not acceptable and reflects
a calcification of thinking at best and the undue influence of the
tire burning industries at worst.
* We are disappointed to once again read between the lines of the
Report to see the main result of this Report will once again be to
I refer you to the many reports and letters we and others have sent
detailing the increased carcinogenic, mutagenic and teratogenic
consequences of adding tire chips to the fuel mixture in cement kilns.
See especially the letter from Dr. Neil Carman, certainly one of the
foremost authorities on tire burning and synthetic rubber. See also
the Citizen's Review Panel of Scientists who reviewed the fatally
flawed, Dames and Moore Report funded by the CIWMB to show that tire
burning is not a significant health risk and miserably failed to do
Citizens for a Better Environment , Silicon Valley Toxics Coalition
and other groups have reviewed the emission data from the test burns
comparing burning coal to burning coal with tire chips. The results
are that a toxic soup of additional hazardous emissions from these
plants are being put into the air we breathe. Help us to stop this
Before finalizing the recommendations for the Waste Tire Program, we
are urging you to read the letters regarding the "California
Waste Tire Program: Evaluation and Recommendations" sent to the
CIWMB by Bonnie Holmes-Gen on behalf of the Sierra Club on 4/27/99 and
the letter from Dr. Seymour I. Schwartz, Pr ofessor, Environmental
Science and Policy, UC Davis, dated August 31, 1999.
Your throughful consideration on this matter is appreciated by the
residents of this great state.
Working together to keep California clean,
for members of West Valley Citizen's Air Watch