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The Department of Environmental Affairs’ approved Integrated Industry Waste Tyre Management plan is doomed to be a failure.

The Minister of Water and Environmental Affairs publicly launched this plan, known as Redisa, today at a press briefing in Pretoria.

Despite the existence of another long-standing industry-driven plan on the table, the Minister has:

Effectively given Redisa a monopoly over tyre recycling in South Africa, as manufactures, dealers and importers must become a subscriber to the plan as long as it is the only plan approved by the Minister.
Failed to conduct a regulatory impact assessment to determine what the R2.30 per kg tyre levy will cost the industry and what the related impacts on the industry will be.
Flouted Waste Tyre Regulations by failing to publish the plan in the Government Gazette for a 30-day comment period or bringing it to the attention of relevant organs of state and interested persons.
Over-estimated the number of jobs that can be created in tyre-recycling alone.
Approved a plan that will cost far more than any job creation benefit due to the intended establishment of a complex bureaucracy of up to 150 costly collection sites around South Africa.

The Democratic Alliance will be writing to the Minister asking her to put a halt to the implementation of the approved plan while further consultation with industry stakeholders can be held.

I will in addition be submitting a series of parliamentary questions on the development of this plan, and asking her to respond to and justify what I believe to be the Minister’s flouting of the Waste Tyre Regulations published in 2009 by her own Department.

The Minister, under pressure from the President to create some of the thousands of new jobs that he has committed himself to, lauds the tyre plan as being a massive job creator.

The problem is that the sums do not add up, and the estimated 15 000 jobs promised will not materialise, at least not permanently.

In fact, the structure of the plan, in its push to create such a high number of elusive jobs, will seriously jeopardise the sustainability of the tyre recycling project as it stands.

How the waste collection sites in particular will ever achieve the economies of scale required to be permanently sustainable is unclear. It would make more sense for a system to be established where waste tyres are collected directly from dealers. The Redisa plan could also result in a surge of tyre thefts around the country.

Scaled down ambition with stricter controls would surely have been more likely to succeed, allowing a smaller number of workers and contractors to actually benefit from sustainable jobs.

The Minister would do well to halt implementation of the plan and go back to the drawing board to give proper consideration to all plans that have been submitted to her.