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28th April 2022
Department of industry, Science, Energy and Resources
2022 NGER Scheme: Proposed Updates Consultation
Industry House, 10 Binara Street, Canberra
Canberra, ACT & 2601
To whom it may concern
Re: TSA’s support for the changes to the CO2 emission factor for end-of-life tyres in the NGER Scheme
Tyre Stewardship Australia welcomes the proposed changes to the CO2 emission factor for end-of-life tyres (EOLT) in the National Greenhouse and Energy Reporting (NGER) Scheme. This initiative will encourage replacement of coal with EOLT and potentially bring about reductions in carbon dioxide emissions.
TSA is an Australian Government Accredited Product Stewardship Scheme. It is a voluntary scheme with a mission to collaboratively deliver the sustainable management, recycling and productive use of EOLT. TSA is made up of representatives from across the tyre supply chain and includes tyre retailers, manufacturers, recyclers and collectors.
TSA administers an Australian Competition and Consumer Commission authorised industry framework to effectively reduce the environmental, health and safety impacts of the 460,000 tonnes of tyres that reach the end of their life in Australian each year. Creating viable end markets for EOLT is critical to increasing their recovery in Australia.
Of the 460,000 tonnes of EOLT generated annually in Australia, 370,000 tonnes could be used to replace coal in fuel burning applications. This represents a potential carbon dioxide reduction of 330,000 tonnes and would make a substantial contribution to Australia’s greenhouse gas abatement programme.
Increased use of EOLT as replacement for coal will create much needed new end-markets for EOLT in Australia, support the government’s waste export ban on EOLT, and help achieve the government’s target of 80% recovery rates in all waste streams.
Thank you for the opportunity to make a submission to provide feedback on the National Greenhouse and Energy Reporting (Measurement) Amendment (2022 Update) Determination 2022 Exposure Draft.
Your sincerely
Lina Goodman
CEO, Tyre Stewardship Australia
