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Bunker Silo Covers: Know What You Are Buying When Replacing Tire Inventory

By: Karl Czymmek, Cornell CALS PRO-DAIRY

New York Farm Bureau with support from Northeast Dairy Producers Association and PRO-DAIRY continue to work with NYS DEC to address challenges with the new regulations for waste tire usage. While discussions continue and progress is being made, the implementation deadline (May 2018) is approaching and many farms are taking steps to comply. We should appreciate that DEC has indicated a willingness to use enforcement discretion, meaning there will be some level of flexibility in the enforcement of this regulation, at least initially. But the lack of suitable replacement options and uncertainty about what to do with existing tire stocks on farms as well as costs for all of this present serious challenges and are part of the ongoing discussion agenda with DEC.     

Caution: It is important to understand that radial tire sidewalls may contain protruding wires that present a hazard to workers and could penetrate plastic covers and contribute metal into the feed supply. Consider if this risk is worth taking with your herd. Bias ply sidewalls without wires can be purchased, but supply and availability are reported to be limited. One producer reports noticing an increase in hardware disease after cutting a number of radial tires in half, and cases declined substantially after eliminating those from use on the bunker. We are also hearing that some receivers of used tires require them to be clean - not simply rain clean, but hosed off. To avoid rejected loads, be sure you know the requirements before sending old tires for disposal. Be aware that burning and on-farm burial of used tires is not legal.  

For more general information on the topic, see the article Reducing Mosquito Breeding Sites When Using Tires as Anchors for Silo Covers.

Additional information is also provided by NYFB below.

Waste Tire Update from NYFB - Enforcement Discretion

On March 1, 2018, the NYS Department of Environmental Conservation issued an Enforcement Discretion Letter regarding the enforcement of Part 360 as it relates to waste tires used on bunk silos. The letter provides for an additional year, until May 3, 2019, for DEC to provide enforcement discretion for farmers who are in compliance with either Part 360.12 (c)(2)(iv) or BUD 1137-0-00.

The DEC letter states:

"This is to advise you, that subject to the terms set forth in this letter, the New York State Department of Environmental Conservation ("DEC" or "Department") will exercise its authority to utilize enforcement discretion with respect to certain provisions of 6 NYCRR Part 360, Part 361, Part 364 and Part 365 of the newly enacted Part 360 Series. The DEC will exercise this authority regarding the above provisions until either May 3, 2019 or an amendment to the present rule is promulgated, whichever is earlier. All other provisions of the Part 360 Series remain in effect and will be enforced.

Waste tires used to secure tarpaulins
The new Part 360 Series, which addresses the use of waste tires to secure tarpaulins in common weather protection practices, requires adjustments to better suit the needs of the agricultural community. The Department will utilize its enforcement discretion with respect to the enforcement of 6 NYCRR Subpart 361-6, as long as the use of waste tires to secure tarpaulins is done in accordance with the pre-determined beneficial use found at Part 360.12(c)(2)(iv) or BUD 1137-0-00, dated December 4, 2014, which permits the use of waste tires to anchor plastic film or other cover material for corn
silage, haylage or other agricultural feeds if certain conditions are met.”

Part 360.12(c)(2)(iv) states the following: (iv) waste tires required to secure tarpaulins in common weather protection practices such as agricultural storage covers and salt pile protection, provided the number of passenger tire equivalents used does not exceed 0.25 passenger tire equivalents per square foot of cover or bunker area, and whole tires are cut in half or have sufficient number of holes drilled in them to prevent retention of water;

BUD 1137-0-00 states the following:

Therefore, the Department has determined that the use of waste tires for bunker silos on agricultural operations is a legitimate beneficial use pursuant to 6 NYCRR 360-1.15(d). This determination applies to any farm in New York State. The BUD is subject to the following conditions:

  1. This BUD applies when the waste tires are received at the farm. The amount of waste tires received cannot exceed the amount needed for bunker silos. Any waste tires that are not used for bunker silos for a period of more than 18 months must be removed from the farm.
  2. Procedures (such as drilling holes in the waste tires), must be in place to minimize standing water and insect breeding during storage and use of the waste tires.
  3. Waste tires stored at the farm, when not in use on the bunker silos, must be stored away from combustible materials and from potential ignition sources. Procedures and means to extinguish fires must be in place at all times.
  4. The burial of waste tires is prohibited.
  5. The burning of waste tires is prohibited.
  6. No routine reporting to the Department is required. Any correspondence related to this BUD, should be sent to:
    Sally Rowland, Ph.D., P.E.
    Division of Materials Management
    Bureau of Waste Reduction & Recycling
    Albany, NY 12233-7253
  7. The Department reserves the right to rescind or modify this BUD at any time, if it finds pursuant to 6 NYCRR 360-1.15(d)(4), that any matter serving as the basis for this BUD is incorrect or no longer valid, or the Department finds there has been a violation of the conditions of this BUD. All administrative protocols in 6 NYCRR Parts 622 and 624 will be followed.
  8. This determination does not exempt the farm from other local, state or federal requirements.

NYFB continues work with DEC to address farmers’ concerns with implementation of Part 360 as it relates to waste tires on bunk silos.

March 15, 2018

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