Karen Asp
Senior Environmental Planner
Gartner Lee Limited
kasp@gartnerlee.com
Burnaby, British Columbia

Dear Ms. Asp:

On behalf of Retail Council of Canada (RCC), and our members operating in British Columbia, we appreciate the opportunity to comment on the addendum to add a retailer registration requirement to the proposed schedule for tires, as brought forward by the British Columbia Ministry of Environment.

RCC supports the proposal to add a retailer registration requirement to the pending tire schedule to the recycling regulation. The original intent of adding a tire schedule to the regulation is to transfer the existing used tire recycling program, Financial Incentives for Recycling Scrap Tires (FIRST), to industry leadership. This addendum represents an extension of the government's commitment to transfer the FIRST Program to industry leadership.

The FIRST Program is a retail-based funding model and currently contains a retailer compliance requirement, which has been an essential feature of the program and should remain in the new industry-managed program to ensure a level playing field. In addition to RCC, The Rubber Association of Canada and the Western Canada Tire Dealers Association endorse the proposed retailer registration requirement.

RCC is actively involved with Tire Stewardship British Columbia (TSBC) and worked closely with The Rubber Association of Canada and the Western Canada Tire Dealers Association in its establishment. TSBC is an industry not-for-profit organization which was created for the purpose of accepting the transfer of the FIRST Program to industry stewardship, and to thereafter manage the scrap tire diversion program in British Columbia. By adding a retailer compliance requirement to the tire schedule, TSBC is provided with an important measure of assurance that British Columbia's new industry-led scrap tire program will be viable.

Once again, thank you for the opportunity to comment on the British Columbia Ministry of Environment's proposal to add a retailer registration requirement to the proposed schedule for tires. If you require any further information or clarification, please do not hesitate to contact me at (888) 373-8245; e-mail: rkagan@retailcouncil.org.

Sincerely,

Rachel Kagan
National Manager, Government Relations (Environment)

cc: Tire Stewardship British Columbia
RCC Environment Committee