West Valley 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 Recommendations

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that you, as a new member of the Board, will take a fresh look at this issue and not be unduly influenced by the outdated approaches to this issue.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 fuel.

* Burning tires for fuel is not recycling. It is a waste of a valuable resource, the synthetic rubber, which can be put to many uses.
*  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 kilns.
* 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 tire dumpers.
*  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 tires.
* 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 promote TDF.
*  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 so.
* WVCAW, 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 from continuing.

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,
        Joyce Eden, for members of West Valley Citizen's Air Watch