October 2012

Produced for

United States Environmental Protection Agency, Region 6 

&

North American Development Bank

By

Integrated Environmental Management Services, S.A. de C.V.

Matamoros No. 1443 Poniente, Colonia Maria Luisa,

Monterrey, Nuevo Leon, Mexico. 64040

TIRE FLOW STUDY

IN THE 

TEXAS–MEXICO BORDER

REGION

EXECUTIVE SUMMARY
Disclaimer

Integrated Environmental Management Services, S. A. de C.V.

(IEMS) was retained by the North American Development Bank (NADB)

to conduct the project titled “Tire Flow Study in the Texas-Mexico Border

Region” with the financial support of the United States Environmental

Protection Agency, Region 6 (EPA).

Although this document has been reviewed by NADB and EPA,

assertions and conclusions here contained are from IEMS and do not

necessarily represent NADB’s or EPA’s policy; they should not be cited

as official NADB or EPA’s assertions. Trade names, equipment and

products presented herein do not constitute endorsements from IEMS,

NADB or EPA.
Tire Flow Study in the Texas-Mexico Border Region

Index

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Table of Contents

Introduction iii

1. Scope of Work 1

2. Tire Flow Estimation 9

3. Waste Tires Ultimate Disposal Locations 23

4. Environmental and Economic Impacts of the Waste Tire Flow From 

Texas into Mexico 27

5. Comparison between Texan And Mexican Tire Tracking Systems 47

6. Waste Tire Management Regulatory Framework 53

7. Recommendations Regarding Changes to the Current Texas and 

Mexico Waste Tire Policies, Laws, Regulations and Procedures 57

8. Recommendations Regarding Potential Markets for Tire-Derived 

Products in Mexico 67

9. Waste Tires Appropriate Disposal Alternatives 99
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Index

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Attachments Index

Attachment Title

1 Ultimate disposal locations of waste tires that are being transported from 

Texas into Mexico.

2 Operation and management procedures of each waste tires accumulation 

site of the Mexican side of the Texas-Mexico border area.

3 Ultimate disposal locations map of waste tires being transported from Texas 

into Mexico.

4 Waste tire sites display map per Mexican city.

5 Crackdown on Illegal Dumping - Handbook for Local Government.

6 Display map of appropriate tire disposal alternatives identified in the Texas 

side of the Texas-Mexico Border Area.

7 Display map of appropriate tire disposal alternatives identified in the Mexican 

side of the Texas-Mexico Border Area.
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Introduction

Throughout the Texas–Mexico Border Region, a significant number of 

scrap tire piles exist containing millions of scrap tires. Scrap tire piles pose 

significant environmental and health risks. For instance, if tire piles catch fire, they 

can burn for weeks, even months, causing serious air quality problems from dense 

smoke and noxious fumes. Also, when this occurs, large amounts of liquid waste 

are generated, which can contaminate the soil, as well as ground and surface 

waters. Further, these sites are ideal breeding grounds for mosquitoes, rodents, and 

other vectors of disease; and increase risks of malaria, dengue fever, West Nile 

Virus, and encephalitis. The health risks are especially of concern because of the 

proximity of tire piles to communities.

To address this problem, the U.S. and Mexico officials have collaborated 

through programs such as the Border 2012 Environmental Program, adopted in 

2007. This bi-national program aims to protect public health and the environment in 

the U.S.–Mexico border region within 100-kilometer on each side of the international 

border. One of the program’s key goals is for the two countries to reduce land 

contamination along their shared border, including tire piles. The Border 2012 

program has helped communities on both sides of the U.S.-Mexico border analyze 

environmental problems, such as waste tires, and evaluate potential solutions.

The primary purpose of this study was to conduct a used and waste tire 

flow study in the Texas-Mexico Border Region. The study assessed in a 

comprehensive manner the current situation of scrap tires in the Texas-Mexico 

Border Region and suggests actions to address and attenuate the problem. The 

NADB hired Integrated Environmental Management Services S.A. de C.V. (IEMS) 

to perform the tasks outlined below to provide the NADB and the EPA with the 

information necessary to better understand the nature and logistics of how and 

where used and waste tires are being transported and stored along the TexasMexico Border Region. 

IEMS developed a methodology to obtain and report information on the 

number of used and waste tires that have been transported between Texas and 

Mexico from 2005 to date. Data was also collected about locations of existing tire 

piles and estimates of the number of the tires that are being sold, reused, and 

disposed of in the Texas-Mexico Border Region. 

Another component of this study addresses the economic and 

environmental aspects of tire flow into the Texas-Mexico Border Region. The 

economic considerations include the costs to transport the tires, revenue from the 

sale of the tires, costs of disposal of the tires, costs to remediate disposal sites, and 

the costs resulting from possible waste tire pile fires.
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An evaluation of the existing regulatory structure used by Texas and 

Mexico to manage used tires along the Texas-Mexico Border Region was necessary 

to understand the current waste tire management systems.

This included investigating and providing an evaluation of current waste tire 

policies, laws, regulations and procedures along the Texas-Mexico Border Region 

and making suggestions, if appropriate, for considerations by policy makers.

This Executive Summary includes key information of the study. A full 

description of the information here described can be found in the study Full report 

and its attachments, including copies of relevant documents, description of 

estimations made, and reference data, figures, and images.
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Section 1. 

Scope of Work
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1 Scope of Work

The Texas-Mexico border comprises 1,241 miles along the Rio Grande 

River and 31 established crossings; 26 of them for vehicles and 5 rail lines. 

According to the August 1983 La Paz Agreement on Cooperation for the Protection 

and Improvement of the Environment in the Border Area, the “border area” was 

defined as a “the area situated 100 kilometers (62.5 miles) on either side of the 

inland and maritime boundaries between the Parties”.

For this study, IEMS has chosen a different definition of the border area 

based on political/administrative divisions (counties on the US side and 

municipalities on the Mexican one) rather than distance, to facilitate a clear 

boundary and avoid jurisdiction issues between counties or municipalities. Only 

those counties and municipalities that make-up the border were chosen as a study 

area. There are a total of nineteen (19) counties and twenty-two (22) municipalities 

that form the Texas-Mexico border.

This study chose to focus on urban areas because one of the magnets for 

used and waste tire flow are population centers due to their potential large 

consumption markets, and because the impacts of the tires may be more severe 

around larger population centers.

Using the definition of urban area both for the U.S. and Mexico, a total of 

fifty two (52) urban areas were located in the bordering counties/municipalities. Of 

these, thirty (30) are located around the 26 international crossings, and thus, these 

were selected for the study.

In summary a total of thirty (30) urban areas were chosen, 13 on the U.S. 

side and 17 on Mexico. The cities chosen depicted in Figure 1.1.

1.1 Methodology

IEMS’ methods are divided as follows: 1) desktop work and 2) field work. 

Both methods are aimed at acquiring both quantitative and qualitative information; 

however, desktop work also includes the analysis of information as required by 

NADB’s terms of reference (TOR).

Data to be collected includes quantitative and qualitative information; some 

of which was estimated based on observations and interviews. There is a clear 

distinction on the type of data used so any user can support his assumptions and 

projections stated in this project.
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Figure 1.1.

Cities Identified in the Texas-Mexico Tire Flow Study

Texas

Mexican States Bordering Texas:

 Chihuahua Coahuila Nuevo Leon Tamaulipas

1. El Paso

2. Fabens

3. Presidio

4. Del Rio

5. Eagle Pass

6. Laredo

7. Roma

8. Rio Grande City

9. La Joya

10. McAllen

11. Pharr

12. Progreso

13. Brownsville

17. Cd. Acuña

18. Piedras 

Negras

19. Nava

20. Venustiano 

Carranza

21. Anahuac 22. Nuevo Laredo

23. Nueva Cd. 

Guerrero

24. Cd. Miguel 

Aleman

25. Cd. Camargo

26. Cd. Gustavo 

Diaz Ordaz

27. Reynosa

28. Cd. Rio Bravo

29. Nuevo 

Progreso

30. Matamoros

14. Cd. Juarez

15. Guadalupe

16. Ojinaga
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1.2 Desktop Activities

IEMS envisioned that the use of both desktop-based research and field 

data would result in a well-rounded study that offers its users a solid platform that 

reflects the day to day reality of the tire issues along the Texas-Mexico border 

region.

Desktop-based research consists of the review of available literature 

sources, electronic correspondence and/or teleconferencing with key stakeholders 

and design of field-research methodology and procedures.

This was done primarily through telephone calls with Mexican municipal 

authorities, data base preparation and analysis, consulting written material found in 

U.S. and Mexican governmental information sources, recognized industry 

associations, public Geographical Information Systems (GIS), news sources, and 

related studies in similar regions, among others.

1.2.1 General Information Sources

The general information search dealt with the border region and social, 

economical and environmental characteristics including information about new, used 

and waste tires and their uses. This information was obtained from U.S. and 

Mexican governmental sources, industrial associations from both countries and 

complemented by news articles, academic thesis, and information obtained from 

telephonic interviews with tire related stakeholders. 

1.2.1.1 Historical Research

Historical research focused on tracing the flow of waste tires across the 

Texas-Mexico border and with other parts of the world. Sources for this information 

include telephone interviews, documents by industrial associations and previous 

related studies of the Texas-Mexico border and of regions similar to the study area.

The U.S.-Mexico border area has been in the past the focus of several 

environmental studies on the tire movement along and across the border. 

These studies were given a careful consideration to generate a 

standardized and defensible method for estimating the waste and used tire 

generation and demand in order to perform the tasks presented above.

Consulted previous tire flow studies and publications about the TexasMexico border include those of Border 2012, and other conducted researches. 

Consultation of previous tire flow related studies and publications about regions 

similar to the Texas-Mexico border area covered:

 California-Mexico border.

 California.

 New Mexico.

 Mexico Federal District.
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 Puerto Rico.

 Continental United States of America.

 The Americas

1.2.1.2 Survey Design and Analysis

Survey design and analysis were done to gather quantitative and semiquantitative information regarding used and waste tire management and crossborder flow, as well as its trends/behaviors. Surveys were designed for the following:

Key stakeholders in Texas

 Texas Commission on

Environmental Quality

 Texas State Health Department

 Councils of governments.

 City waste management 

authorities

 City vector control authorities

 City code enforcement authorities

 Fire department

 New tire dealers

 Used tire dealers

 Tire haulers

 Collection stations

 Storage facilities

 Landfill managers

 Industry associations

 Processing and recycling facilities.

Key stakeholders in Mexico

 Ministry of Economy (Secretaria 

de Economia or SE)

 Federal Institute of Access to 

Information (Instituto Federal de 

Acceso a la Informacion or IFAI)

 Tax Administration Service 

(Servicio de Administración 

Tributaria or SAT)

 State of Nuevo Leon 

Environmental Ministry

 Customs administrators

 Municipal waste management 

authorities

 Municipal civil guard authorities

 Landfill managers

 Processing and recycling facilities

 Industry associations

 Non-Government Organizations.

These questionnaires were sent via email to all Mexican authorities and 

stakeholders in the contact directory and were applied individually during U.S. 

fieldwork. 

1.2.1.3 Interview Planning

The content and style of the interviews (semi-structured) was developed by 

the team leader with the objective to gather all the information required by the 

designed surveys and record details that arise during a conversation style approach.

This style was useful during face to face interviews, especially with public 

officials. Nevertheless, a structured question-answer approach was implemented 

when time-availability was an issue for the interviewee which was generally the case 

for business owners and managers as well as for officials interviewed via telephone.
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1.3Fieldwork Activities

Field-based research consisted of site visits to the thirteen (13) selected 

Texas cities plus Austin and Houston as well as a visit to Mexico Federal District for 

interviews with industrial association representatives. The information obtained was 

both quantitative and qualitative and even though the location of tire piles was 

requested, the research focused more on obtaining an estimation of the tire flow 

from Texas to Mexico as well as the state of the market in the study area. Also 

during one day face to face quotations were obtained from used tire dealers in the 

cities of Ciudad Juarez, Reynosa and Matamoros.

1.3.1 Road Reconnaissance

Road reconnaissance trips to the thirteen border cities along the 

international crossings with population greater than 2,500 were performed on the 

Texas side of the border.

The visits purpose was to identify the location of waste tire piles, reach 

relevant stakeholders, and assess the relationships and activities these 

stakeholders have with waste tires. The trips were of limited utility in identifying 

larger tire piles as required by the TOR, since most of these are located outside the 

cities in county back-roads and information on known locations was restricted due to 

administrative and legal procedures against dumpsite owners. However the 

remaining goals were fulfilled with these visits. Due to security reasons no fieldwork 

was performed on the Mexican side of the border.

1.3.2 Interviews with Key Stakeholders

On the Texas side of the border 122 (one hundred and twenty two) face to 

face interviews were performed to gather the necessary data required to perform the 

tasks described above as well as to obtain quantitative and semi-quantitative 

information and trends/behaviors regarding used and waste tire management and 

cross-border flow. Emphasis was set for medium and small used tire dealers which 

represent more than 40% of the interviews.

The largest new and used tire dealers in each of the cities were sought to 

obtain estimated numbers from the bigger sellers and decrease the uncertainty gap 

of not interviewing a 100% of the dealers. All the U.S. cities identified in this study 

had at least one used tire dealer and was interviewed.

Face to face interviews in Mexico were conducted to:

 Waste management authorities of Ciudad Juarez and Matamoros

 Landfill representative of Ciudad Juarez

 ANDELLAC and CNIH representatives.
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During one day face to face used tire price requests were performed in the 

Mexican cities of Juarez, Reynosa and Matamoros, yet for security reasons other 

cities and further field data in the Mexican side of the Texas-Mexico border was not 

requested.

1.4 Safety

The safety of all the personnel involved with the project was of outmost 

importance, especially those conducting field work activities. Following 

recommendations by the U.S. Department of State, minimum fieldwork was 

conducted on the Mexican side of the border.

Most interviews were sent via e-mail with a formal letter explaining the 

purpose of the project and the organizations involved. This because releasing any 

type of information represents a potential security threat to the Mexican officials. 

Private landfill managers requested an additional letter from the NADB 

project’s commissioner assuring that IEMS was hired to gather and perform the 

present study. It was provided to IEMS from NADB representatives on September 

15, 2011 in both English and Spanish. 

1.5 Key Stakeholders

In order to assess the actual inflow of used and waste tires into Mexico 

from Texas a variety of stakeholders was interviewed as detailed in Section 1.2.3.

Authorities and industry associations provided general estimations on the 

flow of these tires into Mexico. Tire dealers and haulers provided other details on the 

overall tire flow from Texas to Mexico.

All the stakeholders interviewed were asked to sign a permission letter to 

be quoted on this project; these letters are kept by IEMS as hard-copy and are 

available upon request.

Other stakeholders that have been identified are junkyard owners, 

community environmental leaders, and used tire customers.
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Section 2. 

Tire Flow

Estimation
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2 Tire Flow Estimation

The movement of tires is presented using a simple diagram depicted on 

Figure 2.1., displaying the origin and destiny of tires used in Texas.

Between 2005 and 2011 the tire flow in the U.S.-Mexico border area, or 

part of it, had already been mapped in two previous studies. Both studies display 

very similar flows to that presented by IEMS with the exception of the addition of the 

classification between waste tires and used tires. This classifying process happens 

inside the tire merchant and tire transportation facilities (i.e., waste tire generators 

and transporters).

Figure 2.1.

Tire flow in the State of Texas
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2.1 Methodology to Estimate Tire Flows

There are primarily three distinct tire flows/movements:

1. Texas-Mexico.

2. U.S. -Texas international border.

3. Third country-Texas international border.

The first flow requires different levels of detailing:

a. Legal vs. illegal flow

b. Reuse vs. recycling vs. processing 

c. Proper disposal vs. illegal disposal

2.1.1 Texas-Mexico

2.1.1.1 Legal Used Tire Flow

Formula 1.

Annual legal 

used tire flow =

Used tires to be 

commercialized 

flow +

Used tires in 

annual legal car 

imports flow +

Commercial used tires 

import from Texas for 

re-treading

Used Tires to be Commercialized

The Ministry of Economy (Secretaria de Economia or SE) is in charge of 

issuing importation permits for three regions in the U.S. – Mexico border. These 

permits are granted annually according to a global used tire import quota to people 

or companies dedicated to commercialization of used tires in these areas. The 

regions where used tire importation has been authorized and controlled by the SE 

are:

1. The State of Baja California;

2. The State of Sonora State; and,

3. Ciudad Juarez, Chihuahua. 

Every year the number of authorized used tires for import or used tire 

import quota is established by the SE and divided between each of the three 

regions. For the purpose of this study the number of used tires legally imported was 

based on the quota established at the ports of entry in the region of Ciudad Juarez, 

Chihuahua, Mexico.

This is defined as Ciudad Juarez annual used tire import quota. Note that 

there is no legal import quota assigned to the rest of the Texas-Mexico border.
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Formula 2.

Used tires to be 

commercialized flow =

Ciudad Juarez annual 

used tire import quota.

Used Tire Flow for Legal Annual Car Imports 

Formula 3.

Used tires in annual 

legal car imports flow =

Annual legal car 

imports flow x

Average number 

of tires per car

Commercial Used Tires Import for Retreading

There are a different set of authorizations issued by the SE for the 

importation of commercial tires for the sole purpose of retreading in a Mexican 

facility. Only registered tire renovation facilities are assigned a used tires import 

quota for renovating purposes. Retreading passenger tires although possible is not 

economically viable (ANDELLAC, 2011). Without this tire renovating industry the 

commercial carriers in Mexico would go bankrupt given the cost of new tires. (CNIH, 

Rubber Industry National Chamber , 2011).

Used tires for retreading can be imported into Mexico through any legal port 

of entry following the used tire legal import requirements for retreading purposes.

For this purpose the following formula will be applied:

Formula 4.

Commercial used tires import for 

retreading purposes entering from 

Texas

=

Used tires imported under legal import 

requirements for retreading purposes 

through any legal Texas-Mexico point of 

entry.

According to what was reported previously used tires to be commercialized 

may only be imported from the United States through the Ciudad Juarez, a portion 

of Sonora and Baja California border. 

Because of this, all used tires legally imported through any point of entry in 

the Texas-Mexico border, excepting Ciudad Juarez, will be assumed to be destined 

to retreading purposes. Except for the year 2005 when importing used tires for 

commercialization was not allowed, this year all used tires imported through the 

Texas-Mexico border are assumed to be for retreading purposes.
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2.1.1.2 Illegal Used Tire Flow

The illegal flow of used and waste tires from Texas is a much more 

complex issue to estimate. This flow consists of very different streams and each 

must be estimated separately to determine the overall illegal flow. 

This study is based on information obtained from interviews on both sides 

of the border, data from the Tax Administration System (SAT), National Institute of 

Geography and Statistics (INEGI), Non Government Organizations, environmental 

studies and Mexican states public information, among others.

Information obtained from interviews includes tire-flow estimations from 

Mexican industry representatives and final destinations.

It has been assumed that commercialization for profit is the driving force for 

the flow of tires. Therefore to estimate the tire flow from Texas into the TexasMexico border area it was assumed that:

Formula 5.

Used tire flow = Legal used tire flow + Illegal used tire flow

Formula 6.

Used tire flow is greater than or equal to the theoretical Mexico border 

area used tire demand.

Formula 7.

Theoretical 

Mexico 

border area 

used tire 

demand 

=

(

Theoretical Mexico 

border area tire demand -

Estimate of new tires sold in 

Mexico border area )

Percentage of useful life remaining on a Type 3 used tire

Used tires are classified as follows:

 Special. Semi new;

 Type 1. Not toasted or cracked, evenly worn and have 60% of tread 

remaining;

 Type 2. One side is more worn than the other, have 20 to 40% of 

remaining tread;

 Type 3. May be toasted or cracked, have less than 20% of 

remaining tread;
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Formula 8.

Estimate of new 

tires sold in Mexico 

border area

=

New tires sold 

per vehicle in 

the state x

Vehicles in 

each 

municipality

Formula 9.

New tires sold per 

vehicle in the state =

New tires sold in the 

state

Vehicles in the state

Formula 10 a.

Theoretical 

Mexico border 

area tire 

demand

=

Vehicles in 

each 

municipality x

Tires 

per car x

Average annual 

mileage per tire

Average endurance of a new tire sold in Mexico

or

Formula 10 b.

Theoretical Mexico 

border area tire 

demand

=

Vehicles in each 

municipality x Tires per car

5 years

The reason two different formulas may be applied to estimate the 

theoretical Mexico border area tire demand is that tires may degrade more over time 

from elements exposure than from tread wear due to friction with the road surface.

Basing tire demand only on degradation due to exposure to the ambient elements 

does not consider tires may be discarded earlier than when they are 5 years old, but 

neither after this time, yet it provides an estimated number with which stakeholders 

may work and compare with other estimations.

Formula 11

Illegal used 

tire flow ≥

Theoretical Mexico 

border area used 

tire demand -

Legal used 

tire flow

Formula 12.

Vehicles in each 

municipality =

Registered 

vehicles +

Unregistered 

vehicles
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To estimate the number of illegal and American vehicles in the Mexican 

border area two different formulas were applied.

Formula 13.

Unregistered 

vehicles =

Illegal 

vehicles +

American 

vehicles

Each car imported into Mexico through any point of entry in the TexasMexico border has at least 4 tires that presumably will eventually be disposed on the 

Mexican side of the border. For this reason every imported car through the bridges 

in Chihuahua, Coahuila, Nuevo Leon and Tamaulipas will be considered as four

tires.

Based on information from interviews with Mexican industrial associations 

most tires do not remain within the border area. The largest markets are the bigger 

cities such as Mexico City, Guadalajara, Monterrey, Puebla among others. One of 

the industrial associations interviewed estimated that at least 50% of tires that flow 

from the US into Mexico leave the border region to be sold further inland. 

2.1.1.3 Reuse, Recycling, Raw Material and Energy

After their initial intended use, tires can have a variety of destinations: 

reused in vehicles, recycled into alternative uses, processed for use as raw material 

for other products, burned to extract energy or disposed on the land.

Literature has some estimation on the proportion of tires that follow these 

different paths, and calculations were made using field data.

For the U.S. data are more centrally controlled by the Texas Commission 

on Environmental Quality (TCEQ) and those numbers were taken. For Mexico, 

some municipalities had information on the amount of tires diverted to landfills and 

cement companies supplied data for the energy stream.

The proportion of tires destined for recycling was estimated based on 

interviews and news sources; the reused fraction for Mexico is reported by industrial 

associations to be minimal. Finally the reused fraction in the Texas side of the 

border was requested through interviews with the tire recyclers and processors in 

the state.

2.1.1.4 Proper and Illegal Disposal

Proper disposal in the U.S. side of the border is well documented by the 

TCEQ although in the City of Presidio there is no option for proper disposal of tires. 

Illegal disposal was documented during interviews to local code 

enforcement authorities and through the interviews with used and new tire dealers.
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Data on proper/legal disposal in Mexico were obtained from the local 

environmental authorities of each municipality. Although not all Mexican 

municipalities possess adequate disposal facilities and management procedures, 

their storage sites for waste tires for the purposes of this study will be considered 

the proper disposal option for those specific regions.

Attachments 1 and 2 display the proper disposal facilities, the approximate 

number of waste tires accumulated, location and management procedures in each 

of the Mexican municipalities.

2.1.2 Tires from Other U.S. States 

The origin of used tires in Texas was obtained through interviews with local 

used tire dealers. There are no tire manufacturing facilities within Texas (interview email with RMA) so all new tires sold or entering the study’s scope area is assumed 

to originate from one of the other 49 states, Canada, or another foreign country.

The origin of used tires that are being transported through Texas from other 

states, which are considered to have the greatest environmental or economic effect 

on the Texas-Mexico border based on information obtained through fieldwork on 

the Texan side of the border are:

• Alabama

• California

• Denver, Colorado

• Atlanta, Georgia

• Illinois

• Louisiana

• Michigan

• Minnesota

• Missouri 

• Las Vegas, Nevada

• Las Cruces, New Mexico

• New York

• Cincinnati and Fostoria, Ohio

• Pennsylvania

Figure 2.2 represents the states from which used tire dealers obtain their 

used tires for commercialization on the U.S. side of the Texas-Mexico border area. It 

is assumed that 74% of the used tire dealers on said area acquire their used tires on 

Texan cities. 
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Alabama

1%

California

1%

Colorado

1%

Georgia

1%

Illinois

1%

Louisiana

1%

Michigan

1%

Minnesota

1%

Nevada

1%

New Mexico

1%

Pennsylvania

1%

Missouri 

3%

Ohio

3%

New York

7%

Texas

74%

Figure 2.2.

Used Tires Origin Presented by Used Tire Dealer Interviews

A used tire dealer that obtains used tires from Texas may also acquire used 

tires from other states. The number of used tires brought to Texas from other parts 

of the U.S. is yet to be assessed.

No data regarding the number of used tires arriving to the Texas-Mexico 

border region from other American states was obtained during fieldwork or desktop 

interviews and activities reason for which it was not possible for IEMS to estimate 

the number of tires that are being transported through Texas from other states, 

which may have either an environmental or economic effect on the Texas-Mexico 

Border. 

2.1.3 Third Country-Texas-Texas Border

Information on out-of-U.S. origins of used tires was obtained during the 

Texas interviews. The only third country mentioned, by only 1 of the interviewees, 

was Canada.

No data regarding the number of used tires arriving to the Texas-Mexico 

border region from other countries was obtained during fieldwork or desktop 

interviews and activities. Because of this, it was not possible for IEMS to estimate 

the number of tires that are being transported to the Texas-Mexico Border Region 

from countries outside the United States. 
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2.2 Estimations and Results

The following includes the results of the use of information obtained from 

different stakeholders across Texas and Mexico and the application of the 

previously described formulas and criteria. 

2.2.1 Legal Used Tires Flow

2.2.1.1 Ciudad Juarez Annual Used Tire Import Quota

The following table was created by applying Formula 2, employing data 

obtained from the Economy Ministry through IFAI.

Table 2.1

Ciudad Juarez, Chihuahua

Annual Used Tire Import Quota

Year Used tires legally imported per year

2005 0

2006 340,000

2007 340,000

2008 340,000

2009 340,000

2010 191,100

2011 198,400

Total 1,749,500

2.2.1.2 Used Tires in Annual Legal Car Imports Flow

Table 2.2 presents the results from applying Formula 3 employing data 

obtained from the Tax Administration System (SAT) commercial imports balance 

report.

2.2.1.3 Commercial Used Tire Import for Retreading

Table 2.3 presents the results from applying Formula 4 employing data 

obtained from the Tributary Administration System (SAT) commercial imports 

balance report.
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Table 2.2.

Used Tires Flow for Annual Legal Car Imports 

Imported vehicles each year per scope state (Vehicles) Annual 

legal car 

imports 

flow (cars)

Average 

number of 

tires per car 

(used 

tires/car)

Used tires in 

car imports flow 

(used tires) Year Chihuahua Coahuila Nuevo 

Leon Tamaulipas

2005 58,482 16,074 26,183 144,701 245,440 4 981,760

2006 202,076 46,702 101,275 521,855 871,908 4 3,487,632

2007 132,624 28,375 14,351 628,889 804,239 4 3,216,956

2008 73,993 15,254 532 422,761 512,540 4 2,050,160

2009 42,805 10,338 1,346 163,496 217,985 4 871,940

2010 91,073 10,665 1,976 205,615 309,329 4 1,237,316

2011* 68,543 8,965 9,960 151,056 238,524 4 1,602,692

Total 669,596 136,373 155,623 2,238,373 3,199,965 4 13,448,456

*Information obtained until August 2011. Used tires in car imports flow data for year 2011 was linearly extrapolated 

from imports on years 2009 and 2010.

Table 2.3.

Import for retreading flow entering from Texas

Year Used tires import for retreading

20051168,457

2006 219,399

2007 274,036

2008 276,619

2009 299,073

20102 343,052

20112 374,898

Total21,955,534

1

Estimated by adding all used tire legal imports through the TexasMexico border including the Ciudad Juarez border since no legal import 

quota existed in 2005 for this area.

2

From June 2010 to December 2011 import data was obtained through 

a linear extrapolation with a R2of 0.901
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10%

79%

11%

.

Ciudad Juarez annual used tire import quota 

Used tires in annual legal car imports flow

Commercial used tires import for retreading entering from Texas.

From the information presented on Tables 2.1 thru 2.3, the legal flow of 

used tires from 2005 to 2011 is estimated on:

17,153,490 tires units

Figure 2.3 depicts the distribution of this flow. Used tires mounted on 

imported vehicles represent almost 80% of the legal used tires import flow.

Figure 2.3 

Legal used tire import flows through the Texas-Mexico border

2.2.2 Illegal Used Tire Flow

The results of applying the formulas to estimate the illegal flow of used tires 

resulted on a negative value. This value should not be interpreted as a negative flow 

of used tires back into Texas; it should be interpreted as a sign that the current used 

tire imports could theoretically supply the Mexican scope border region used tire 

demand. 

Actually the legal used tire flow could theoretically supply more than two 

times the estimated used tire demand of the Texas-Mexico border region as the 

table above displays.

Assessing the reason for this surplus in used tire offer crossing the TexasMexico border is not part of this study scope and will not be further addressed. Yet it 

is important to note that the National Rubber Industry Chamber (Camara Nacional 

de la Industria Hulera or CNIH) associates have detected used tire shipments in 

large Mexican cities further south of the border such as Guadalajara and the Federal 

District.
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Based on the fact that both fieldwork and desktop interviews with key 

stakeholders report the existence of an illegal flow of used tires from Texas into 

Mexico it would be safe to imply that a demand larger than the one of the border 

area is being supplied by both legal and illegal used tire flows. 

As a general conclusion the results obtained from estimating the illegal 

used tire flow from Texas into Mexico based only on the Mexican border region 

demand greatly underestimates the actual illegal used tire flow. 

2.2.3 Theoretical Mexico Border Area Used Tire Demand

From the application of Formula 7, the theoretical Mexico Border Area 

used tired demand resulted in the information presented in Table 2.4.

Table 2.4.

Theoretical Mexico border area used tire demand

Year

Theoretical Mexico border area 

used tire demand 

(used tires)

2005 913,904

2006 1,431,049

2007 847,033

2008 997,133

2009 1,227,711

2010 1,396,641

2011 1,576,431

TOTAL 8,389,903

Additional results and estimations made during the study are presented in 

the study Full Report.

2.2.4 Reuse, Recycling & Processing

No relevant information regarding tires sold for reuse, recycling or for other 

tire derived products in the Texas-Mexico border region was reported or provided by 

any interviewed stakeholder. For this reason no estimations regarding this subject 

were made in this report.
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2.2.5 Proper Disposal vs. Illegal Disposal

2.2.5.1 Proper Disposal

Attachments 1 and 2 display the proper disposal facilities, the approximate 

number of waste tires accumulated, location and management procedures in each 

of the Mexican scope municipalities.

2.2.5.2 Illegally Disposed

No conclusive data regarding illegal waste tire disposal was obtained from 

the interviewed Mexican stakeholders. Attachment 3 presents a map with potential 

illegal tire disposal locations on the Mexican side of the Texas-Mexico border region.
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Section 3. 

Waste Tires 

Ultimate Disposal 

Locations
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3 Waste Tires Ultimate Disposal Locations

IEMS created a geo-referenced directory and display map of known 

ultimate disposal locations of waste tires that are being transported from Texas into 

Mexico. Their operation, who is responsible for them, their management procedures, 

number of waste tires accumulated and display maps.

Also IEMS presents the Mexican cities of the Region geo referenced list of 

possible waste tire generators, possible illegal tire piles and a display map for each 

city.

3.1 Disposal Locations

IEMS envisioned that the use of both desktop-based research and field 

data would result in a well-rounded study that offers its users a solid platform that 

reflects the day to day reality of the tire issues along the Texas-Mexico border 

region.

Desktop-based research consisted on the review of available literature 

sources, online regional periodic publications, electronic correspondence and/or 

teleconferencing with key stakeholders.

This was done primarily through telephone calls with Mexican municipal 

authorities and key stakeholders, data base preparation and analysis, consulting 

written material found in U.S. and Mexican governmental information sources, 

recognized industry associations, public Geographical Information Systems, news 

sources, and related studies in the region, among others.

Location of waste tire dumps sites was assessed through directions 

obtained from stakeholders interviewed, the border tire network tire pile database

and online periodic news sources that described the location settings and/or 

surroundings.

The areas geographical coordinates were obtained using public 

Geographical Information Systems (GIS), primarily the GoogleTM Earth software, by 

visually searching the sites following the directions given by the sources mentioned 

on the paragraph above. 

No fieldwork was performed on the Mexican side of the Region due to 

security reasons. No confirmation visits, using Geographical Positioning Systems 

(GPS) devices or what was observed through GIS were performed in order to verify 

the accuracy of the data obtained from the sources. Nevertheless only sites that 

were visually consistent to what was described by the Mexican stakeholders were 

selected as dump sites.
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Instead a visual search of junkyards and used vehicle lots in the Mexican 

cities using public GIS was performed in order to assess the possible location of 

waste tire generators and potential tire pile sites; this methodology is further 

explained in this document.

IEMS employed desktop-based research which consisted on the review of 

available literature sources, online regional periodic publications and electronic 

correspondence and/or teleconferencing with key stakeholders. The location of 

waste tires piles along the Texas-Mexico region had been the focus of the following 

publications:

 Border 2012: U.S.-Mexico Border Scrap Tire Inventory Summary 

Report. (United States Environmental Protection Agency (EPA), 

2007)

 Border Tire Network, Tire Pile Information (Border 2012, 2011)

The tire pile sites reported in above mentioned documents were used as a 

base for which the report objectives were constructed.

IEMS also performed a visual search of junkyards of all sizes and used car 

lots on the Mexican cities of the Region to assess the potential final destination of 

the used and waste tires mounted on imported vehicles from Texas into Mexico. 

From all the information gathered, display maps with the identified locations

of possible junkyards, possible illegal tire piles, and the piles, were prepared and are 

presented for each of the Mexican cities under the scope of the study in 

Attachment 4.
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Section 4. 

Environmental and 

Economic Impacts 

of the Waste Tire 

Flow from Texas 

into Mexico
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4 Environmental and Economic Impacts of the Waste 

Tire Flow from Texas into Mexico

For the estimation of environmental an economic impacts related to the 

scope of work, several considerations and assumption were made. These 

considerations are described in full in Chapter 4 of the study Full report.

4.1 Revenue from the Sale of Used Tires to Mexico

IEMS estimated a revenue range, rather than a single number, of what the 

revenues may have been in any determined period of time between January 2005 

and April 2012. As presented on Figure 4.1.

Figure 4.1

Lowest (blue) and Highest (red) estimated revenue per tire

 

Table 4.1.

Highest revenue per tire per year

(US dollars / used tire)

Rim size R 13 R 14 R 15 R 16

Highest net revenue

Remaining (US dollars / used tire)

tread / year 20%-40% 20%-40% 20%-40% 20%-40%

2005 $2.95 $10.86 $12.15 $3.25 $29.21

2006 $2.95 $10.84 $12.12 $3.24 $29.15

2007 $2.88 $10.60 $11.86 $3.17 $28.52
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Table 4.1.

Highest revenue per tire per year

(US dollars / used tire)

Rim size R 13 R 14 R 15 R 16

Highest net revenue

Remaining (US dollars / used tire)

tread / year 20%-40% 20%-40% 20%-40% 20%-40%

2008 $3.10 $11.40 $12.75 $3.41 $30.66

2009 $2.44 $8.98 $10.04 $2.69 $24.14

2010 $2.53 $9.30 $10.40 $2.78 $25.01

2011 $2.67 $9.83 $10.99 $2.94 $26.44

2012 $2.43 $8.95 $10.01 $2.68 $24.08

Table 4.2.

Lowest revenue per tire per year

(US dollars / used tire)

Rim size R 13 R 14 R 15 R 16

Lowest revenue (US 

Remaining tread / dollars / used tire)

year

0-20% 0-20% 0-20% 0-20%

2005 $0.86 $3.13 $3.58 $0.98 $8.55

2006 $0.86 $3.11 $3.56 $0.97 $8.49

2007 $0.87 $3.17 $3.62 $0.99 $8.66

2008 $0.71 $2.57 $2.93 $0.80 $7.01

2009 $0.64 $2.33 $2.66 $0.72 $6.35

2010 $0.75 $2.71 $3.10 $0.84 $7.40

2011 $0.69 $2.51 $2.87 $0.78 $6.85

2012 $0.71 $2.56 $2.93 $0.80 $7.00

Table 4.3.

Mexican’s specific rim size preference when buying used

tires (percentage)

Rim size / 

municipality Rim 13 Rim 14 Rim 15 Rim 16

Juarez 17% 44% 33% 6%

Reynosa 10% 30% 40% 20%

Matamoros 8% 42% 42% 8%

Geometric 

mean

11% 38% 38% 10%

error 3%
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Table 4.4.

Highest mean revenue per rim size of used tire in the

2005-2012 period in representative Mexican scope cities

(US dollars / used tire)

Rim size R 13 R 14 R 15 R 16

Remaining tread / 

year

20%-40% 20%-40% 20%-40% 20%-40%

2005 $26.45 $28.47 $31.84 $33.34

2006 $26.40 $28.41 $31.77 $33.28

2007 $25.82 $27.79 $31.08 $32.55

2008 $27.76 $29.88 $33.41 $35.00

2009 $21.86 $23.53 $26.31 $27.55

2010 $22.65 $24.38 $27.26 $28.55

2011 $23.94 $25.77 $28.81 $30.18

2012 $21.80 $23.46 $26.24 $27.48

Table 4.5.

Lowest mean revenue per rim size of used tire in the

2005-2012 period in representative Mexican scope cities

(US dollars / used tire)

Rim size R 13 R 14 R 15 R 16

Remaining tread 

/ year 0-20% 0-20% 0-20% 0-20%

2005 $7.74 $8.21 $9.38 $10.01

2006 $ 7.68 $ 8.16 $ 9.32 $ 9.94 

2007 $ 7.83 $ 8.31 $ 9.50 $ 10.13 

2008 $ 6.34 $ 6.73 $ 7.69 $ 8.20 

2009 $ 5.74 $ 6.09 $ 6.96 $ 7.43 

2010 $ 6.69 $ 7.10 $ 8.12 $ 8.66 

2011 $ 6.19 $ 6.57 $ 7.51 $ 8.02 

2012 $ 6.33 $ 6.72 $ 7.68 $ 8.19 

Table 4.6.

Minimum mean revenue per tire in a specific Mexican city

(Mexican pesos / used tire)

Rim size R 13 R 14 R 15 R 16 R 17

Remaining tread /municipality 0-20% 0-20% 0-20% 0-20% 0-20%

Juarez $123 $130 $141 $196 $205

Reynosa $77 $77 $85 $85 $98

Matamoros $72 $82 $102 $89 $92

Lowest mean revenue per tire in Mexican 

scope cities i (Mexican pesos / used tire) $88 $94 $107 $114 $123
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Table 4.7.

Highest mean revenue per tire in Mexican scope cities

(Mexican pesos / used tire)

Rim size Rim 13 Rim 14 Rim 15 Rim 16

No. Remaining tread 

/ Municipality 20%-40% 20%-40% 20%-40% 20%-40%

1 Juarez $355 $346 $382 $452

2 Reynosa $248 $265 $279 $297

3 Matamoros $237 $284 $342 $312

Highest mean revenue per tire in 

Mexican scope cities 

(Mexican pesos /used tire)

$275.33 $296.36 $331.40 $347.10

Table 4.8.

Mean retail price in Mexican representative scope

(Mexican pesos / used tire)

Rim size R 13 R 14 R 15 R 16 R 17

No.

Remaining 

tread 

/Municipality

0-

20%

20%-

40%

0-

20%

20%-

40%

0-

20%

20%-

40%

0-

20%

20%-

40%

0-

20%

20%-

40%

1 Juarez $203 $355 $215 $346 $233 $382 $325 $452 $339 $466

2 Reynosa $111 $248 $111 $265 $122 $279 $122 $297 $141 $339

3 Matamoros $96 $237 $108 $284 $135 $342 $118 $312 $122 $331

Mean retail price in 

Mexican representative 

scope cities i

(Mexican pesos / used 

tire)

$129 $275 $137 $296 $157 $331 $167 $347 $180 $374

4.2 Disposal Cost per Tire in Texas and Mexico

Border Region

Contrary to the Mexican side of the border in Texas private disposal 

companies as well as local authorities are the ones in charge of the collection and 

disposal of waste tires. The price charged to a waste tire generator depends on 

confidential agreements between each waste tire management company and each 

generator. Prices charged by public landfills and collection centers are fixed. Large 

new tire retailers have corporate agreements with a single authorized hauler which 

provides the waste tire collection service in all of their stores and information 

regarding the cost per tire is kept confidential by both parties.
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Although private companies are seldom involved, in the Mexican side of the 

border Municipal authorities are the ones in charge of the waste tire storage and 

disposal sites, specifically the Ecology and/or municipal services departments. Only 

Ciudad Juarez declares a disposal cost for waste tires.

4.3 Potential Cost to Clean up Significant Tire Piles 

in the Texas-Mexico Border Region

Activities such as fire prevention, fumigation and volume diminishing should 

be addressed by each stakeholder depending on his own criteria.

The transportation costs to the closest appropriate disposal sites are 

presented on Table 4.9 based on quotations obtained from trucking companies:

Table 4.9

Estimated transportation costs to closest appropriate disposal sites

Id 

#

Destination1

Accumulated 

waste tires 

(tires) 

Equip. State of 

tire

Estimated 

number 

of travels 

Cost 

per 

travel

Total 

Transportation 

Cost (USD)

Disposal 

Site City

1

CEMEX 

Plant

Monterrey, 

NL. 2,500,000

Truck Whole 1667 $ 829.07 $ 1,382,067.86 

Train Whole 1008 $1,480.00 $ 1,491,840.00 

Truck Cut/Shred 1042 $ 829.07 $ 863,896.05 

Train Shred 323 $1,480.00 $ 478,040.00 

35 GCC Plant Samalayuca 

Chih 2,500,000

Truck Whole --- --- $ 0.00

Train Whole --- --- $ 0.00

Truck Cut/Shred --- --- $ 0.00

Train Shred --- --- $ 0.00

3

CEMEX 

Plant

Monterrey, 

NL. 550,000

Truck Whole 367 $ 350.00 $ 128,450.00 

Train Whole 222 $1,272.92 $ 282,587.50 

Truck Cut/Shred 230 $ 350.00 $ 80,500.00 

Train Shred 71 $1,272.92 $ 90,377.08 

36 CEMEX 

Plant

Monterrey, 

NL. 400,000

Truck Whole 267 $ 829.07 $ 221,363.00 

Train Whole 162 $1,480.00 $ 239,760.00 

Truck Cut/Shred 167 $ 829.07 $ 138,455.51 

Train Shred 52 $1,480.00 $ 76,960.00 

31 Landfill2 Acuña, 

Coah. 200,000

Truck Whole --- --- $ 0.00

Train Whole --- --- $ 0.00

Truck Cut/Shred --- --- $ 0.00

Train Shred --- --- $ 0.00

32 Landfill2

Piedras 

Negras, 

Coah

115,500

Truck Whole --- --- $ 0.00

Train Whole --- --- $ 0.00

Truck Cut/Shred --- --- $ 0.00

Train Shred --- --- $ 0.00

8

CEMEX 

Plant

Monterrey, 

NL. 100,000

Truck Whole 67 $ 350.00 $ 23,450.00 

Train Whole 41 $1,272.92 $ 52,189.58 

Truck Cut/Shred 42 $ 350.00 $ 14,700.00 

Train Shred 13 $1,272.92 $ 16,547.92 
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Table 4.9

Estimated transportation costs to closest appropriate disposal sites

Id 

#

Destination1

Accumulated 

waste tires 

(tires) 

Equip. State of 

tire

Estimated 

number 

of travels 

Cost 

per 

travel

Total 

Transportation 

Cost (USD)

Disposal 

Site City

4

CEMEX 

Plant

Monterrey, 

NL. 50,000

Truck Whole 34 $ 350.00 $ 11,900.00 

Train Whole 21 $1,272.92 $ 26,731.25 

Truck Cut/Shred 21 $ 350.00 $ 7,350.00 

Train Shred 7 $1,272.92 $ 8,910.42 

34 APASCO 

Plant

Ramos 

Arizpe, 

Coah.

50,000

Truck Whole 34 $1,959.63 $ 66,627.47 

Train Whole --- --- ---

Truck Cut/Shred 21 $1,959.63 $ 41,152.26 

Train Shred --- --- ---

2

CEMEX 

Plant

Monterrey, 

NL. 32,000

Truck Whole 22 --- ---

Train Whole 13 $1,329.33 $ 17,281.23 

Truck Cut/Shred --- --- ---

Train Shred 5 $1,329.33 $ 6,646.63 

15 CEMEX 

Plant

Monterrey, 

NL. 13,000

Truck Whole 9 --- ---

Train Whole 6 $1,160.13 $ 6,960.80 

Truck Cut/Shred --- --- ---

Train Shred 2 $1,160.13 $ 2,320.27 

12 CEMEX 

Plant

Monterrey, 

NL. 3,000

Truck Whole 2 --- ---

Train Whole 2 $1,115.02 $ 2,230.03 

Truck Cut/Shred 2 --- ---

Train Shred 1 $1,115.02 $ 1,115.02 

7

CEMEX 

Plant

Monterrey, 

NL. 1,000

Truck Whole 1 $ 350.00 $ 350.00 

Train Whole 1 $1,272.92 $ 1,272.92 

Truck Cut/Shred 1 $ 350.00 $ 350.00 

Train Shred 1 $1,272.92 $ 1,272.92 

33 APASCO 

Plant

Ramos 

Arizpe, 

Coah.

1,000

Truck Whole 1 $ 565.28 $ 565.28 

Train Whole 1 $6,757.26 $ 6,757.26 

Truck Cut/Shred 1 $ 565.28 $ 565.28 

Train Shred 1 $6,757.26 $ 6,757.26 

11 CEMEX 

Plant

Monterrey, 

NL. 800

Truck Whole 1 --- ---

Train Whole 1 $1,115.02 $ 1,115.02 

Truck Cut/Shred 1 --- ---

Train Shred 1 $1,115.02 $ 1,115.02 

* Means data was not confirmed with a key stakeholder, it is presented as it was obtained from previous tire pile inventories.

Tire sites 16 to 30 are not located within the study's selected search area but are located within 100km from the Texas-Mexico border.

The information presented on this Table was obtained through remote interviews with the key stakeholders.

Nuevo Laredo tire pile was cleaned up during the writeup of this Report according to the remote interview applied to the municipal 

Environment and Climate Change Coordinator on April 20, 2012. 

Prices in red are subject to KCSM FSC 

Prices in blue are subject to negotiations with Ferromex

Prices don't include VAT.

1 Disposal sites selected according to cheaper transportation cost.

2

Transportation costs for Acuña, Juarez and Piedras Negras are not considered due to landfill being in the same city.
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4.4 Current Potential Cost to Extinguish Fires and 

Remediate Environmental, Public Health, and Economic 

Impacts Should Any of the Major Tire Piles in the Region 

Set Ablaze

4.4.1 Cost to Extinguish Fires in the Texas-Mexico Border Area

The Table 4.10. represents an abstract of the responses given for Mexican 

civil guard; the personnel cost was obtained considering Mexican minimum wage as 

$4.77 (US dollars) for 8 hours, the salary per hour is about $0.59 USD.

Table 4.10.

Summary of Resources to extinguish fires given by Mexican civil guard

City State

Number of 

tire fires 

attended 

since 2005

Resources to extinguish fires

Time Personnel

Personnel 

Cost 

(USD)+

Extinguishing 

agents

Ojinaga Chihuahua ---- 1.5 to 2 h ---- ---- Water / Foam

Nava Coahuila 90 1 to 3 h 5 $ 3 - 9 Water / Foam

Acuña Coahuila 210 20 min to 

1 h ---- ---- Water / Foam

Piedras 

Negras Coahuila ---- 1 to 2 h 3 $ 1.8 - 3.6 Water / Foam

Anahuac Nuevo 

Leon Rarely 0.5 to 1 h 3 $ 1 - 1.8 Water / Foam

Nuevo Laredo Tamaulipas Rarely ---- ---- ---- Water / Foam

Guerrero Tamaulipas 72 12 to 24 

h

6 $ 43 - 85.8 Water / Foam

Gustavo Diaz 

Ordaz Tamaulipas 300 ---- 6 ---- Water / Foam

Río Bravo Tamaulipas Frequently 20 to 30 

min 3 $1 Water / Foam

+ Personnel cost was estimated as follow: 

According to interviewees, the estimate personnel cost is considered $35

USD per hour per person and $75 USD per hour to estimate de extinguishing 

agents cost; although a global cost was given.
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Table 4.11.

Summary of Resources to extinguish fires given by Texas firefighting agency

City

Number 

of tire 

fires 

attende

d since 

2005

Resources to extinguish fires

Time

Number 

of 

Personn

el

Personn

el Cost 

(USD)

Extinguishing 

agents

Extinguishin

g agents 

cost (USD)

Brownsville 6 6 to 8 h 18 $4000 to 

$5000

4 Engines and 3000 

gall of water $450 to 600

Laredo 30 45 min 

to 1 h 4 $90 to 140 + Water / Foam $50 to 75 *

Mc Allen 18 ---- --- ---- Water / Foam $2,500 to 6,000

Rio Grande 72 ---- 15 ----

90 gall of foam and 700 

gall of water

$10,000 to 

12,000

Del Rio

One in the 

landfill ---- ---- ---- Water / Foam $6,000 to 7,000

Eagle Pass 120 20 min 

to 2 h 6 $70 to 420 + 15 gall of foam and 2 engines $25 to 150 *

+ Personnel cost was estimated as follow: 

* Extinguishing agents cost was estimated as follow: 

4.4.2 Public Health Impacts Remediation Costs

4.4.2.1 Pyrolytic Oil and Ash

In order to identify the best remediation techniques and their estimated 

costs IEMS consulted the US Federal Remediation Technologies Roundtable 

(FRTR) Table 3-2 Remediation Technologies Screening Matrix and Reference 

Guideand selected the following remediation options:

In Situ Biological Treatment: Phytoremediation

“Phytoremediation is a process that uses plants to remove, transfer, 

stabilize, and destroy contaminants in soil and sediment. Contaminants may be 

either organic or inorganic.” (FRTR)

Table 4.12.

FRTR reported remediation costs estimates for Phytoremediation

(US dollars)

RACER PARAMETERS Small site Large site

Easy Difficult Easy Difficult

Cost per cubic foot $18 $66 $4 $14

Cost per cubic meter $626 $2,322 $147 $483

RACER means Remedial Action Cost Engineering Requirements
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Ex situ Physical/Chemical Treatment (assuming excavation): 

Chemical Oxidation

“Reduction/oxidation chemically converts hazardous contaminants to nonhazardous or less toxic compounds that are more stable, less mobile, and/or inert. 

The oxidizing agents most commonly used are ozone, hydrogen peroxide, 

hypochlorites, chlorine, and chlorine dioxide.” (FRTR)

“Estimated costs range from $190 to $660 per cubic meter ($150 to $500 

per cubic yard).” (FRTR)

Excavation, Retrieval & Offsite disposal

“Contaminated material is removed and transported to permitted off-site 

treatment and disposal facilities. Pretreatment may be required.” (FRTR)

Cost estimates for excavation and disposal range from $300 to $510 per 

metric ton ($270 to $460 per ton) depending on the nature of hazardous materials 

and methods of excavation. These estimates include excavation/removal, 

transportation, and disposal at a permitted facility. Additional cost of treatment at 

disposal facility may also be required. (FRTR)

4.5 History of Known Environmental Health Hazards

Associated with past or Current Waste Tire Piles Located in 

Regions with Ecosystems Similar to the Texas-Mexico 

Border Region

Over the past decade American used vehicles imports, explosive 

population growth and a steady demand for used American tires in Mexico have 

contributed to the proliferation of scrap tires on the Texas–Mexico border.

Most of the major border cities host piles containing from tens of thousands 

to millions of tires, and a few of the largest cities are home to piles ten times as 

large. Tire piles, legal or illegal, pose at least two health threats: pests and fire. 

Tire piles easily accumulate rain and organic matter transported by wind 

and, therefore, become ideal incubators for mosquito larvae. As leaf litter decays, 

the microorganisms that grow on it serve as food for the mosquito larvae. 

Furthermore, tires absorb heat, which helps accelerate the larval growth. 

Tire piles have also been identified as breeding ground for vermin (rodents 

and other pests) due to the combined presence of water, heat, and shade. 

(Secretaría de Medio Ambiente, 2002).
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Mosquito-borne diseases include Dengue, encephalitis, malaria, and yellow 

fever. (Moore & Mitchell, 1997). Globally, Dengue is currently the most important of 

all vector-borne viral diseases in terms of human morbidity and mortality, with Aedes 

aegypti and Aedes albopictus, the mosquito vector for the Dengue viruses, found in 

more than 100 tropical countries (Cortez Florez, 2001). In areas where Ae. aegypti

is abundant, this species might be expected to play a far more important role in 

Dengue transmission than Ae. albopictus (Moore & Mitchell, 1997).

Dengue can produce a spectrum of clinical illness, ranging from a 

nonspecific viral syndrome to severe and fatal hemorrhagic disease. Although 

Dengue fever is not usually fatal, Dengue hemorrhagic fever (DHF) and Dengue 

shock syndrome can be. On average, 5% of hospitalized cases result in death. The 

majority of fatalities occur among children younger than 15 years (Lloyd, 2003). 

In 2002, the Department of Health Services’ Vector-Borne Disease Section 

identified five discarded truck tires, one of which yielded seven Aedes albopictus

larvae after being tested. The Aedes albopictus, was initially detected in 2001 in 

Los Angeles and Long Beach, according to a 2003 Department of Health Services 

report. The most immediate concern in California, however, is the potential role of 

waste tires in the spread of the West Nile Virus. According to the Department of 

Health Services, this mosquito-borne disease reached the United States in 1999 

and has since spread to 48 states. 

In 2004, it had been detected in 56 of California’s 58 counties with nearly 

600 identified cases of persons afflicted by the disease. In 2008, 35 cases of West 

Nile Virus were reported for San Diego County alone. Fortunately, the arid 

conditions of California lower the risk of adequate mosquito habitat in tire piles in the 

region. 

However, a year with more precipitation or development of tire piles in 

locations where they would trap water from stormwater runoff would be a matter of 

concern (Reyes Tomassini, 2009).

Tire piles are typically high-priority targets of efforts to prevent or slow 

outbreaks of mosquito-borne diseases. Unfortunately, treating them with insecticides 

is problematic. It is difficult to penetrate tire piles to the depths where mosquitoes 

breed.

Also, mosquitoes are developing resistance to many widely used 

insecticides. Finally, insecticides used to suppress adult mosquitoes are 

environmentally hazardous, and those used to suppress larvae are costly. Thus, 

mitigating mosquito-borne diseases may require completely removing tire piles 

(Blackman & Palma, 2002).

Tire piles also pose a major environmental threat given their risk of burning. 

Tire piles burn intensely due to their high per-pound heat output. 
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For example, the energy content of tires is 14,000–15,000 British thermal 

units (BTUs) per pound, as compared to 8,000–12,000 per pound of coal (California 

Integrated Waste Managment Board, 2009).

The environmental impact of tire fires ranges from moderate to severe 

effects on air, water, and soil pollution. Tires do not combust completely and, as a 

result, produce both conventional air pollutants and hazardous air pollutants; along 

with solid and liquid waste. 

Tire fire smoke contains irritating chemicals, particulate matter, and 

carcinogens. A 1997 USEPA report indicated that tire fire emissions are significantly 

more toxic than emissions from coal-fired utilities with pollution controls.

Identified health effects from exposure to such compounds include irritation 

of mucous membranes (eye, nose, and throat), exacerbation of asthma symptoms 

and respiratory conditions, and potential exacerbation of preexisting heart disease

(California Integrated Waste Managment Board, 2009).

Tire fires also cause water and land contamination. A standard automobile 

tire generates about two gallons of oil when burning and liquefying. 

The burning of large tire piles, then, could potentially result in the leaching 

of large amounts of toxic oil into the soil and possibly into the aquifers. 

If soil becomes contaminated with oil, its microbiological quality is reduced 

and plant growth is depressed, diminishing the health and productive capacity of the 

land. 

Remediation is generally difficult, and the sites of many tire fires have been 

designated as hazardous waste cleanup sites (Blackman & Palma, 2002).

An example of the potential extent of a tire fire is the one which engulfed 

the S.F. Royster Tire Disposal Facility in Tracy, California, in San Joaquin County. 

The facility stored an estimated 7 million tires that burned for more than two years. 

Local, state, and federal authorities worked together to conduct emergency 

response activities. They determined that the best course of action was to let the fire 

burn itself out.

The decision was based primarily on concerns that water hosing the fire 

might produce excessive amounts of hazardous wastewater. In December 2001, 

state and local agencies completely extinguished the fire and remediation efforts 

followed.

The Board estimated that the fire contaminated an area of some 564,000 

ft2, or 13 acres (California Integrated Waste Managment Board, 2009).
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To address the long-term economic impacts of a tire fire, the highly toxic 

emissions of the smoke plume must be considered significant ozone pollution 

contributors in the wider air basin. 

Ground-level ozone, or “bad” ozone, is formed when volatile organic 

compounds—such as benzene and butadiene, which are components of tire fire 

smoke—react with sunlight and nitrogen oxide in the earth’s lower atmosphere. High 

ozone concentrations reduce crop yield and result in losses to consumer and 

producer welfare (California Integrated Waste Managment Board, 2009).

In summary, known environmental health hazards associated with past or 

current waste tire piles located in regions with ecosystems similar to the TexasMexico Border Region are the following:

 Mosquito transmitted diseases such as Dengue fever and West Nile 

Virus.

 Carcinogenic compound emissions when tires are burned.

 Increase in ground level ozone when tires are burned.

 Soil and water contamination with toxic oil which leaches when tires 

are burned.

Identified health effects from exposure to emissions from tire fires include 

irritation of mucous membranes (eye, nose, and throat), exacerbation of asthma 

symptoms and respiratory conditions, and potential exacerbation of preexisting heart 

disease.

4.6 Potential Cost to Remediate the Environmental 

Health Threats Associated with Disease Carrying Vectors 

Located in Tire Piles Along the Texas-Mexico Border 

Region

To obtain information related to health threats remediation costs associated 

with Dengue and West Nile Virus, the following key stakeholders in the Mexico were 

consulted:

 Tamaulipas Health Secretariat

 Nuevo Leon Health Secretariat

 Coahuila Health Secretariat

 Chihuahua Health Secretariat

These key departments were asked to deliver information regarding 

Dengue and West Nile Virus recorded cases from 2005 to this day within the study’s 

scope regions, and the treatment costs for said diseases.
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4.6.1 Dengue

State of Tamaulipas

Mr. Juan Francisco Castañon Barron, Chief of the Vector State Department 

of Tamaulipas Health Secretariat delivered data from all municipalities in the State 

of Tamaulipas regarding Dengue Fever and Dengue Hemorrhagic Fever from 2005

to half 2011, which was the most recent available data. No West Nile Virus data was 

provided. The following tables contain detected dengue fever and dengue 

hemorrhagic fever cases in study’s scope regions in the State of Tamaulipas.

Table 4.13.

Detected dengue fever and dengue hemorrhagic fever cases in study’s scope regions in 

the State of Tamaulipas. (2005-2007)

Municipality 2005 2006 2007

DF DHF TOTAL DF DHF TOTAL DF DHF TOTAL

Camargo 0 1 1 0 0 0 9 3 12

Diaz Ordaz 0 0 0 0 0 0 1 4 5

Matamoros 1160 438 1598 14 10 24 46 21 67

Miguel Aleman 0 1 1 0 0 0 8 2 10

Nuevo Laredo 1 2 3 1 0 1 360 142 502

Reynosa 143 62 205 27 9 36 448 198 646

Rio Bravo 2 3 5 1 3 4 9 2 11

Guerrero 0 0 0 0 0 0 0 0 0

Total 5069 1832 6901 151 46 197 1406 516 1922

Table 4.14.

Detected dengue fever and dengue hemorrhagic fever cases in study’s scope regions in the 

State of Tamaulipas. (2008-2011)

Municipality

2008 2009 2010 2011

DF DHF TOTAL DF DHF TOTAL DF DHF TOTAL DF DHF TOTAL

Camargo 0 0 0 0 0 0 0 0 0 0 0 0

Diaz Ordaz 0 0 0 0 0 0 0 1 1 0 0 0

Matamoros 257 231 488 46 29 75 23 3 26 2 0 2

Miguel Aleman 0 0 0 0 0 0 0 0 0 0 0 0

Nuevo Laredo 4 3 7 9 0 9 2 1 3 0 0 0

Reynosa 284 105 389 81 35 116 29 14 43 15 0 15

Rio Bravo 4 2 6 5 1 6 107 99 206 0 1 1

Guerrero 0 0 0 0 0 0 0 0 0 0 0 0

Total 1014 522 1536 696 215 911 409 168 577 78 15 93

DF = Dengue Fever Cases

DHF = Hemorrhagic Fever Cases

Mr. Juan Francisco Castañon Barron also provided information on length of 

hospitalization times and its corresponding costs. On average it is known that 

Dengue Hemorrhagic Fever patients need between 4-7 days to recover from illness 

which translates into $5,000 - $8,000 pesos for hospitalization costs. 
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There are no specific antiviral medicines for dengue, doctors prescribe 

medicine to counteract disease symptoms such as painkillers and antipyretics, 

Parecetamol is highly recommended as it fulfills both functions, as well as electrolyte 

drinks.

For cost estimation, treatment cost (TrC) of $130 pesos and hospitalization 

cost (HC) of $5,000 pesos will be used per patient. Costs can be higher according to 

patient critical condition.

The following tables contain detected dengue fever and dengue 

hemorrhagic fever costs in study’s scope regions in the State of Tamaulipas.

Table 4.15.

Dengue fever and dengue hemorrhagic fever costs in study’s scope 

regions in the State of Tamaulipas (2005-2006)

Municipality 2005 2006

TrC HC TC TrC HC TC

Camargo $130 $5,000 $5,130 $0 $0 $0

Diaz Ordaz $0 $0 $0 $0 $0 $0

Matamoros $207,740 $2,190,000 $2,397,740 $3,120 $50,000 $53,120

Miguel Aleman $130 $5,000 $5,130 $0 $0 $0

Nuevo Laredo $390 $10,000 $10,390 $130 $0 $130

Reynosa $26,650 $310,000 $336,650 $4,680 $45,000 $49,680

Río Bravo $650 $15,000 $15,650 $520 $15,000 $15,520

Guerrero $0 $0 $0 $0 $0 $0

Total $235,690 $2,535,000 $2,770,690 $8,450 $110,000 $118,450

Table 4.16.

Dengue fever and dengue hemorrhagic fever costs in study’s scope regions in 

the State of Tamaulipas (2007-2008)

Municipality

2007 2008

TrC HC TC TrC HC TC

Camargo $1,560 $15,000 $16,560 $0 $0 $0

Diaz Ordaz $650 $20,000 $20,650 $0 $0 $0

Matamoros $8,710 $105,000 $113,710 $63,440 $1,155,000 $1,218,440

Miguel Aleman $1,300 $10,000 $11,300 $0 $0 $0

Nuevo Laredo $65,260 $710,000 $775,260 $910 $15,000 $15,910

Reynosa $83,980 $990,000 $1,073,980 $50,570 $525,000 $575,570

Río Bravo $1,430 $10,000 $11,430 $780 $10,000 $10,780

Guerrero $0 $0 $0 $0 $0 $0

Total $162,890 $1,860,000 $2,022,890 $115,700 $1,705,000 $1,820,700
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Table 4.17.

Dengue fever and dengue hemorrhagic fever costs in study’s scope regions in the State of 

Tamaulipas (2009-2011)

Municipality 2009 2010 2011

TrC HC TC TrC HC TC TrC HC TC

Carmargo $0 $0 $0 $0 $0 $0 $0 $0 $0

Diaz Ordaz $0 $0 $0 $130 $5,000 $5,130 $0 $0 $0

Matamoros $9,750 $145,000 $154,750 $3,380 $15,000 $18,380 $260 $0 $260

Miguel Aleman $0 $0 $0 $0 $0 $0 $0 $0 $0

Nuevo Laredo $1,170 $0 $1,170 $390 $5,000 $5,390 $0 $0 $0

Reynosa $15,080 $175,000 $190,080 $5,590 $70,000 $75,590 $1,950 $0 $1,950

Río Bravo $780 $5,000 $5,780 $26,780 $495,000 $521,780 $130 $5,000 $5,130

Guerrero $0 $0 $0 $0 $0 $0 $0 $0 $0

Total $26,780 $325,000 $351,780 $36,270 $590,000 $626,270 $2,340 $5,000 $7,340

Notes:

TrC = Treatment Cost ($130 pesos per patient)

HC = Hospitalization Cost ($5,000 per patient)

TC = Total Cost

Costs can be higher according to patient critical condition.

No written or specific data was provided during the preparation of this 

report for the States of Nuevo Leon, Coahuila or Chihuahua.

4.6.2 West Nile Virus 

The results of the estimations of the number of WNV cases in Mexican 

border municipalities are presented only for border counties which presented at 

least one WNV case from 2005 to 2011.

Table 4.18. 

Estimated West Nile Virus cases in Matamoros

Year

Mexican Border US Border

Municipality of Matamoros Cameron County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 462157 0 370735 0 0

2006 467564 4 376882 3 7.96E-06

2007 472971 5 382703 4 1.05E-05

2008 478379 0 389164 0 0

2010 489193 0 406220 0 0

Total WNV Ocurrence 9 7
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Table 4.19. 

Estimated West Nile Virus cases in Rio Bravo

Year

Mexican Border US Border

Municipality of Rio Bravo Hidalgo County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 106842 0 665475 0 0

2006 109125 1 683719 2 2.93E-06

2007 111409 1 701862 3 4.27E-06

2008 113692 0 721275 0 0

2010 118259 0 774769 0 0

Total WNV Ocurrence 2 5

Table 4.20. 

Estimated West Nile Virus cases in Reynosa

Year

Mexican Border US Border

Municipality of Reynosa Hidalgo County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 526888 0 665475 0 0

2006 543289 2 683719 2 2.93E-06

2007 559689 3 701862 3 4.27E-06

2008 576090 0 721275 0 0

2010 608891 0 774769 0 0

Total WNV Ocurrence 5 5

Table 4.21. 

Estimated West Nile Virus cases in Gustavo Diaz Ordaz

Year

Mexican Border US Border

Municipality of Gustavo Diaz 

Ordaz Hidalgo County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 15028 0 665475 0 0

2006 15177 1 683719 2 2.93E-06

2007 15327 1 701862 3 4.27E-06

2008 15476 0 721275 0 0

2010 15775 0 774769 0 0

Total WNV Ocurrence 2 5
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Table 4.22. 

Estimated West Nile Virus cases in Miguel Aleman

Year

Mexican Border US Border

Municipality of Miguel Aleman Webb County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 24020 0 220968 0 0

2006 24619 0 225985 0 0.00E+00

2007 25218 1 230848 1 4.33E-06

2008 25817 1 235937 1 4.23842E-06

2010 27015 1 250304 1 3.99514E-06

Total WNV Ocurrence 3 3

Table 4.23. 

Estimated West Nile Virus cases in Nuevo Laredo

Year

Mexican Border US Border

Municipality of Nuevo Laredo Webb County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 355827 0 220968 0 0

2006 361468 0 225985 0 0.00E+00

2007 367109 2 230848 1 4.33E-06

2008 372751 2 235937 1 4.23842E-06

2010 384033 2 250304 1 3.99514E-06

Total WNV Ocurrence 6 3

Table 4.24. 

Estimated West Nile Virus cases in Juarez

Year

Mexican Border US Border

Municipality of Juarez El Paso County

Population 

(Inhabitants)

Estimated WNV 

Ocurrence

Population 

(Inhabitants)

WNV 

Cases

WNV / 

Inhabitant

2005 1313338 21 708683 11 1.55217E-05

2006 1317097 28 720756 15 2.08E-05

2007 1320855 68 727828 37 5.08E-05

2008 1324614 0 738416 0 0

2010 1332131 0 800647 0 0

Total WNV Ocurrence 117 63
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Although symptoms and general treatments for WNV are publicly available 

all cases require different levels of medical care and costs can be very high 

depending on complications. Also WNV time of recovery varies greatly on a case by 

case basis. 

For the reasons above stated; standard treatment costs and time for 

recovery of WNV cases are not available on public literature and are were not 

provided by health stakeholders on neither side of the border. 
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Section 5. 

Comparison 

between Texan and 

Mexican Tire 

Tracking Systems 
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5 Comparison Between Texan And Mexican Tire

Tracking Systems

To obtain the information required, IEMS performed the following activities:

 Face to face interviews with industry key stakeholders.

 Face to face interviews with Texas local environmental authorities in 

the scope’s selected fieldwork cities 

 Remote interviews with the Mexican municipal ́s environmental

authorities.

 Consulted previous studies focused on tracing the flow of waste tires 

across the Texas‐Mexico Border and similar regions in both countries 

and the regulatory framework described by them. 

 Reviewed the existing regulatory structure used by Texas and Mexico 

to manage used tires along the Texas-Mexico Border Region. 

The last one includes an investigation of current waste tire policies, laws, 

regulations and procedures along the Texas-Mexico Border Region in international, 

federal, state and local levels applying to it described in detail on the Chapter 6 of 

the Full Report.

5.1 Tracking Systems

In this section the tracking systems employed in Texas and Mexico are 

examined and later on compared.

In the study area, tires sold, imported and exported can be classified as:

 New

 Used 

Although waste tires are likely to be sold, imported or exported if mixed with 

used tires, special handling waste tracking systems for them are later on presented 

in detail on the Chapter 6 of the Full Report.

5.1.1 Texas Tracking Systems

5.1.1.1 New Tires Sales Tracking Systems

Tire sale tracking systems are regulated at federal level by the National 

Traffic and Motor Vehicle Safety Act section 30117

5.1.1.2 Used Tires Sales Tracking Systems

No used tire tacking systems were reported to be used by the used tire 

dealers interviewed during fieldwork activities in the Texas scope cities.
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5.1.1.3 New and Used Tires Import and Export Tracking Systems

“The Harmonized Commodity Description and Coding System”, generally 

referred to as "Harmonized System" or simply "HS", is a multipurpose international 

product nomenclature developed by the World Customs Organization (WCO). It 

comprises about 5,000 commodity groups; each identified by a six digit code, 

arranged in a legal and logical structure and is supported by well-defined rules to 

achieve uniform classification. The system is used by more than 200 countries and 

economies as a basis for their Customs tariffs and for the collection of international 

trade statistics. Over 98 % of the merchandise in international trade is classified in 

terms of the HS.

The HS contributes to the harmonization of Customs and trade procedures, 

and the non-documentary trade data interchange in connection with such 

procedures, thus reducing the costs related to international trade. It is also 

extensively used by governments, international organizations and the private sector 

for many other purposes such as internal taxes, trade policies, monitoring of 

controlled goods, rules of origin, freight tariffs, transport statistics, price monitoring, 

quota controls, compilation of national accounts, and economic research and 

analysis. The HS is thus a universal economic language and code for goods, and an 

indispensable tool for international trade.” (World Customs Organization (WCO))

New and used tires are classified in chapter 40, “Rubber and articles 

thereof”, and their tariff schedules or codes start with the four numbers, or heading:

New tires  4011 (United States International Trade Commission, 2012)

Used tires 4012 (United States International Trade Commission, 2012)

5.1.2 Mexico’s Tire Tracking Systems

5.1.2.1 Sales Tracking Systems

No new or used tires tracking systems are applied neither by the industry 

nor any level of government. 

5.1.2.2 New and Used Tires Import and Export Tracking Systems

The same Harmonized system described developed by the World Customs 

Organization is applied by Mexico’s federal government Tributary Administration 

System (Sistema de Administracion Tributaria, SAT) to track the import and export 

of used and new tires.

An additional used tire tracking system is employed by the Secretary of 

Economy to ensure the proper disposal of used tires legally imported through the El 

Paso-Ciudad Juarez border.

The Secretary of Economy (Secretaria de Economia or SE) is in charge of 

issuing importation permits for three regions in the U.S. – Mexico border.
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These permits are granted annually according to a global used tire import 

quota to people or companies dedicated to commercialization of used tires in these 

areas. The used tire import quota also determined by the SE is based on:

a) The volume of used tires imported the previous year and 

b) Compliance with final disposal legislation. 

The regions were used tire importation has been authorized and controlled 

by the SE are:

1. The state of Baja California.

2. Sonora State.

3. Ciudad Juarez, Chihuahua. 

Every year the number of authorized used tires for import or used tire 

import quota is established by the SE and divided between each of the three 

regions. For the purpose of this study the number of used tires legally imported was 

based on the quota established at the ports of entry in the region of Ciudad Juarez, 

Chihuahua, Mexico. This is defined as Ciudad Juarez annual used tire import 

quota.

5.1.2.3 Used Tire Legal Import Requirements for Commercialization 

Purposes

According to the Colombia international bridge customs administrator A. 

Diaz (personal communication, June, 28, 2011) there are several conditions that 

must be met to legally introduce used tires into Mexico. The legal import 

requirements are:

I. The used tire importer must be registered, as such, in the used tires 

importers record kept by the Central Administration of Accounting and 

Explanation (Administracion Central de Contabilidad y Glosa or ACCG) 

of the SAT.

II. Retain a share of the authorized used tire import quota set by the 

Mexican Secretary of Economy (Secretaria de Economia or SE) for the 

year during which the import is performed. The used tire import quota is 

the maximum number of used tires that can enter through a portion of 

the U.S.-Mexico border in a particular year. It is specific for the type or 

origin of the used tires and is valid only for a particular year.

III. Legal submission of an import petition to the customs authority of the 

point of entry through which the tires will enter Mexico. This has to be 

made by a customs agent and comply with the requirements set in the 

Annex 22 of the General Character Rules Regarding Exterior Commerce 

(Anexo 22 de las reglas de caracter general en materia de comercio 

exterior). 
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Note: in order for the customs agent to submit an import petition other 

legal requirements must be met.

IV. Pay the import tariff (schedule) for each used tire entering Mexico. This 

varies depending on the year and it is defined in the Import and Export 

General Tax Law (Ley de los impuestos generales de importación y de 

exportacion) valid during importation.

Each item legally crossing the Mexican border has a numeric code or tariff 

item(schedule) assigned to it depending on how it is classified by the Import and 

Export General Tax Law (Ley de los Impuestos Generales de Importacion y 

Exportacion or LIGIE). 

5.1.2.4 Commercial Used Tires Import for Retreading

There are a different set of authorizations issued by the SE for the 

importation of commercial tires for the sole purpose of retreading in a Mexican 

facility. Only registered tire renovation facilities are assigned a used tires import 

quota for renovating purposes. Retreading passenger tires although possible is not 

economically viable. Without this tire renovating industry the commercial carriers in 

Mexico would go bankrupt given the cost of new tires. 

Used tires for retreading can be imported into Mexico through any legal port 

of entry following the used tire legal import requirements for retreading purposes.

5.1.2.5 Used Tire Legal Import Requirements for Retreading 

In addition to the four legal import requirements described, the import of 

used commercial tires for retreading is exclusive for natural and legal 

persons/entities dedicated to tire retreading.

The authorizations are annual, unchangeable, and defined according to 

formulas.
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Section 6. 

Waste Tire 

Management 

Regulatory 

Framework
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6 Waste Tire Management Regulatory Framework

IEMS conducted a thorough review of U.S. and Mexican legislations, 

regulations and standards, at all Federal, State, and Local levels, in order to identify 

all applicable to waste tire management. The review included International treaties. 

In addition, the enforcement agencies related to the identified applicable 

requirements were also identified and listed.

The following list summarizes the laws and regulations related to the 

management and disposal of tires in both countries. A full list of applicable articles is 

included in Chapter 6 of the study Full report.

6.1 International Treaties

 NAFTA

 North American Agreement on Environmental Cooperation

 Agreement on Cooperation for the Protection and Improvement of the 

Environment in the Border Area

 Basel Convention about Control of Transboundary Movements of 

Hazardous Wastes and their Disposal

 Customs Convention for the Temporary Importation of Private Road 

Vehicles.

 Convention on Combating Bribery of Foreign Public Officials in 

International Business Transactions

 World Health Regulations

 Guidance Manual for the Control of Transboundary Movements of 

Recoverable Wastes

 United Nations Convention on the Law of the Sea

6.2 American Regulatory Framework

 Federal Law

o US Disposal of Solid Waste Code – Section 6002 - 101 

 State of Texas

o Texas Health and Safety Code 361.112 - Storage, Transportation, 

and Disposal of Used or Scrap Tires

 Local Law

o City of El Paso 

 Chapter 9.04 - Solid Waste Management 

o City of Del Rio

 CHAPTER 24 - Solid Waste

o City of Eagle Pass

 CHAPTER 14 - Municipal Solid Waste [26] 

o City of Laredo

 ARTICLE IV. - Tire Business Registration Program

 ARTICLE V. - Dengue Fever Prevention [45] 
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o City of McAllen

 CHAPTER 90 - Solid Waste

o City of Pharr

 ORDINANCE NO. O-2010-33

o City of Brownsville

 CHAPTER 82 - Solid Waste

6.3 Mexican Regulatory Framework

 Federal laws

o General Law for the Prevention and Integrated Management of 

Wastes

 State and local laws

o Chihuahua

 Law of Ecological Equilibrium and Environmental Protection of the 

State of Chihuahua

 Municipal Regulation of Ecology and Environmental Protection of 

the Municipality of Juarez, Chih.

 Regulation of the public cleaning service for the municipality of 

Ojinaga

o Coahuila

 Law of Ecological Equilibrium and Environmental Protection of the 

State of Coahuila

 Law for the Prevention and Integrated Management of Wastes of 

the State of Coahuila

 Regulation of the Ecological Balance and Environmental 

Protection Law of the State of Coahuila de Zaragoza on matter of 

Environmental Impact

 Regulation of the Ecological Balance and Environmental 

Protection Law of the State of Coahuila de Zaragoza on matter of 

Contaminants Emissions and Transfer Registry

 Regulation of Ecology of the Municipality of City of Acuña, 

Coahuila.

 Regulation of Ecology and Environmental Protection of the 

Municipality of Piedras Negras, Coahuila.

o Nuevo Leon

 Environmental Law of the State of Nuevo Leon

 Law of the Environment and Natural Resources Protection Agency

 Regulation of the Environmental Law of the State of Nuevo Leon

 Civil Guard Rulebook of Anahuac, Nuevo Leon

o Tamaulipas

 Environmental Protection Law for the sustainable development of 

the State of Tamaulipas.

 Law of Ecological Equilibrium and Environmental Protection of the 

State of Tamaulipas

 Code for Sustainable Development of the State of Tamaulipas
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 Regulations for the Ecological Equilibrium and Environmental 

Protection in the Municipality of Nuevo Laredo, Tamaulipas

 Regulation for the Ecological Equilibrium and Environmental 

Protection in the Municipality of Reynosa, Tamaulipas

 Regulation for the Ecological Equilibrium and Environmental 

Protection in the Municipality of Rio Bravo, Tamaulipas

 Regulation for the Equilibrium and Environmental Protection in the 

Municipality of Matamoros, Tamaulipas

6.4 Enforcement Agencies

Two different levels of authority are involved in the main enforcement of 

applicable requirements for the management of scrap tires in the U.S. territory:

 The Federal authority is the Environmental Protection Agency.

 Environmental Authority at State level in Texas is the Texas Commission 

on Environmental Quality.

Three different levels of authority are involved in the main enforcement of 

applicable requirements for the management of scrap tires in the Mexican territory:

 The Federal authority is the Mexican Secretary for the Environmental 

and Natural Resources (Secretaria del Medio Ambiente y Recursos 

Naturales, SEMARNAT). The prosecutor agency at the service of 

SEMARNAT for the supervision of the applicably of federal regulations is 

the PROFEPA (Procuraduria Federal de Proteccion al Ambiente).

 Four Mexican States are involved in the Texas-Mexico border area as 

previously identified. Each State with an environmental office, identified 

as follows:

o State of Coahuila Environmental Office (Secretaria del Medio 

Ambiente de Coahuila, SEMAC).

o State of Chihuahua Urban Development and Ecology Office 

(Secretaria de Desarrollo Urbano y Ecologia, SEDUE).

o State of Nuevo Leon Environment Protection and Natural Resources 

Agency (Subsecretaria de Proteccion al Medio Ambiente y Recursos 

Naturales, SPMARN).

o State of Tamaulipas Urban Development and Environment Office 

(Secretaria de Desarrollo Urbano y Medio Ambiente, SEDUMA).

 Municipal Ecology and public Works departments are in charge of tire 

management enforcement in a municipal level when waste tires are 

generated as municipal solid waste.
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Section 7. 

Recommendations 

regarding changes 

to the current 

Texas and Mexico 

Waste Tire Policies, 

Laws, Regulations 

and Procedures
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7 Recommendations Regarding Changes to the 

Current Texas and Mexico Waste Tire Policies, Laws, 

Regulations and Procedures

7.1 Recommendations

Table 7.1 shows the Recommendations regarding changes to the current 

Texas and Mexico waste tire policies, laws, regulations and procedures in order to 

improve waste tire management in the Texas-Mexico Border Region.

Table 7.1.

Recommended changes to the current Texas and Mexico waste tire policies, 

laws, regulations and procedures 

No. Impact Cause(s) Recommendations for each impact

1 Tire fires

 Trash fires  CPR dead tires campaign

 Tire burning for 

metal extraction  Tire fire prevention measures 

 Grass fires  Tire ordinance-passing-trainingenforcement

2 Mosquitoes

 Water 

accumulation 

inside whole 

tires

 CPR dead tires campaign

 Tire ordinance-passing-trainingenforcement

3

Blocked water 

ways

 Illegal dumping 

of whole tires

 CPR dead tires campaign

 Tire ordinance-passing-trainingenforcement

 Make access difficult to sensitive 

spots

4

Bad image, 

Hives, Vermin 

and poisonous 

animals

 Whole tire 

dumping or 

improper storage

 CPR dead tires campaign

 Tire ordinance-passing-trainingenforcement

5

Used tires lack 

of tracking

 No manifest 

given when 

reinserted into 

the market

 Include the number of resold used 

tires in their annual report to the 

TCEQ scrap tire program.

7 Tire piles

 High disposal 

costs.

 No available 

recycling 

markets.

 CPR dead tires campaign

 Market recommendations of Section

8.
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$1.25

$0.91

$1.50 $1.50 $1.50 $1.50

$3.00

$0.25 $0.33 $0.35 $0.50

$1.25

$0.75 $0.75

Figure 1.- Comparison of the disposal fees for 

whole and cut tires in several Texas border cities

(US dollars / tire)

Whole tires Cut tires 

7.2 CPR Dead Tires Campaign

CPR stands for Cut-Pack-Recycle which are basic steps IEMS identified in 

order to facilitate waste tire handling.

Dead tires is the name given by Texas used tire dealers to tires that are no 

longer reusable.

7.2.1 Cut

Cutting refers to the act of removing the sidewalls of a waste tire.

It can be accomplished manually using a linoleum knife or cutter or by 

means of a machine, necessary especially for cutting commercial truck tires.

Cutting a tire provides the following benefits:

 Retained water inside waste tires is easier to remove.

 Disposal fee reduction (In Texas up to 80% and average savings of 

55%, refer to Figure 7.1).

 Volume reduction ranging from 70% to 79% depending on the tire size 

demanding less storage area and diminishing transportation costs (see

Figure 7.2).

 Increase recycling and marketing options (refer to Section 8).

Figure 7.1.

Comparison of the disposal fees for whole and cut tires 

in several Texas border cities (US dollars / tire)
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65%

70%

75%

80%

12 13 14 15 16 17 18 19 20 21

Tire and rim diameter (in)

Figure 2.-Approximated waste tires volume reduction when 

sidewalls are removed and the resulting pieces packed

Figure 7.2.

Approximated waste tires volume reduction when sidewalls are 

removed and the resulting pieces packed

7.2.2 Pack

Packing refers to the act of storing in an ordered fashion the cutting 

resulting pieces to take advantage of their reduced volume.

It is easy to notice the volume reduction advantages obtained when tire 

sidewalls are removed as well as several packing alternatives.

Packing the resulting cut tire pieces provides the following benefits:

 Diminish the storage area required.

 Increase storage order.

 Diminish transporting cost per tire.

 Facilitate the loading and unloading into transport vehicles. (Either by 

hand or stacking on standard pallets).

7.2.3 Recycle

Waste tires tread and sidewalls can have different alternative uses than 

whole tires depending on whether they belonged to passenger of commercial truck 

tires. Recycling involves classifying activities based on whether they came from 

commercial or passenger tires, tread quality and dimensions. The following tread 

quality classification is suggested:

Type A

No visible wiring is observed, when sliding a plastic bag across the surface

(in any direction) it isn’t cut or damaged meaning a person can handle the tread 

without using gloves without hurting his skin.
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Image 7.1.

Example of a Type A waste tire tread.

Type B

Tread presents visible wiring and/or when sliding a plastic bag across the 

surface (in any direction) it is cut or damaged meaning a person cannot handle the 

tread without using gloves.

Image 7.2.

Examples of type B tire treads.

Dimensions and tire of origin classification is only relevant on specific 

recycling options. Tire part properties as well as market and recycling options are 

enumerated and detailed on the market recommendations of Section 8.
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7.3 Tire Fire Prevention Measures

The following fire prevention measures should be implemented in every tire 

storage site, plus the local, state and federal fire prevention requirements.

 Waste tires should be separated from vegetation or any other flammable 

material by at least 40 feet. (12.2 meters).

 Every tire storage site should be fenced or surrounded by walls at least 

2m tall, barb wired on the top, and have access doors with control such 

as locks. This with the objective to prevent the entrance of arsonists.

7.4 Tire Ordinance

The tire ordinance recommended is based on the regulations already in 

place in the cities of Laredo and Pharr, Texas. These ordinances both share the 

sections marked on blue on the following table:

Table 7.2.

Comparison of tire ordinances sections

Laredo Pharr

Purpose and intent

Definitions Definitions

Residential property

Tire business registration program

Tire business and mobile repair road Tire business permits

service units application

Terms of registration

Denial of permit or renewal; suspension 

or revocation of permit

Denial of permit or renewal; suspension 

or revocation of permit

Fees

Tire hauler permit

Destruction of tires

Storage of tires

Disposal of tires Disposal of tires

Disposal records/Transmittal Manifest

Administration/Enforcement

Penalty for violations Violations and penalties

Injunctive relief Injunctive relief

Severability
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Tire ordinances common sections are:

1. Definitions.

2. Denial of permit or renewal; suspension or revocation of permit.

3. Disposal of tires.

4. Penalties.

5. Injunctive relief.

In summary the Pharr ordinance presents a more specific approach, 

especially on violations and penalties, and covers more tire related issues than the 

Laredo ordinance. 

Both cities report significant waste tire management improvement when 

applying their own tire ordinances. IEMS recommends that each city, county or 

municipality in the Texas-Mexico border facing tire related issues to pass an 

ordinance which as a minimum contains the enumerated sections.

This suggestion should be considered, taking into account that always the 

opinion of a professional legal ordinance advisor should be obtained when an 

ordinance is to be written and passed. This recommendation doesn’t replace the 

need of legal professional counseling when writing an ordinance or any other legal 

document.

Naturally it would also be desirable to consider including all of the 

recommendations presented in this report in the tire ordinances. These 

recommendations should be carefully reviewed by a professional experienced in law 

making of each country and consulted with all involved entities, public or private, 

before passed.

7.4.1 Passing

The city of Laredo set the example on the Texas-Mexico border area by 

passing a tire ordinance; afterwards it was followed by the city of Pharr. Other cities

such as El Paso are in process of passing one. The stakeholders interviewed in said 

cities highlighted the benefits of possessing a specific legal framework for waste tire 

management in their areas because it facilitates antidumping enforcement and 

prevention.

7.4.2 Training

The person in charge of setting up, direction and enforcement of the tire 

ordinance should perform the following activities:

1. The regulated entities have to be notified and trained on the purposes, 

scope and application of the tire ordinance. To effectively perform this, 

the following activities are suggested:
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 Summon a meeting with the waste tire generators, haulers and 

processors of the area. Present the tire ordinance and provide a 

copy of it. Finally request them to sign a confirmation of notification 

and training by means of a list of assistance. (The presence and 

coverage of the event by the local media is desirable).

 Perform a visit to each tire generator, signal it location by means of 

a GPS, provide a copy of the ordinance and have them sign of 

reception and give them a period of time to comply. (six months).

2. Enforcement agents training. Passing an ordinance is not effective if the 

following agencies do not know its purpose and scope. The following 

agencies and agents should be educated on the tire ordinance purpose, 

scope and application:

 Enforcing agency personnel.

 Special commission personnel.

 Code enforcement agents.

 Fire department.

 Police department.

 Vector control and health departments.

3. Also after the enforcing personnel has been trained in the purposes, 

scope and application of the tire ordinance, the training on these 

subjects of the Municipal judges is key

The success or failure of a tire ordinance relies on the consequences faced 

by violators. The municipal court will have the final word on whether a civil penalty 

should be applied or not as well as its severity. 

An untrained or unwilling to punish judge may let go violators without any 

punishment discouraging and disempowering enforcement agencies and officers 

and sending the wrong message to the regulated entities which may think complying 

is not necessary.

7.4.3 Enforcement

Immediately after the time given to the regulated entities to comply with the 

new legislation has passed, tire ordinance enforcement agents should visit all 

notified regulated entities and inspect their compliance if any violation is identified 

the corresponding fine or consequence should be applied with zero tolerance. 

Periodic visits should be performed, at least annually to ensure a continued 

compliance and application of the tire ordinance.

New regulated entities identified should be trained and afterwards also be 

visited.
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7.5 Make Access Difficult to Sensitive Dumping 

Spots

Although tire dumping always generates negative impacts, these are 

exacerbated when it occurs on waterways causing their course reduction or 

blocking. 

In most cases illegal dumping takes very little effort. It can take more effort 

to dispose of waste legally tan to dump it illegally. areas continue to experience 

illegal dumping problems after being cleaned up. 

Effective structural solutions will increase the effort and risk of being caught 

thereby deterring offenders. Structural solutions can reduce accessibility to popular 

sites for illegal dumping. A clean up plus:

 Introducing signs;

 Lighting;

 Barriers;

 Landscaping; and,

 Increasing the visibility;

Image 7.3.

Diagram of a tire tread fence 

Further information is available on Section 8 Markets Report.

Attachment 5 of this report presents an extract of Chapter 4 (Illegal 

dumping prevention techniques) of the following document:

 Crackdown on Illegal Dumping - Handbook for Local Government 

(Department of Environment and Climate Change (DECC) New South 

Wales Government, 2008)

This document presents experience and suggestions on access control 

techniques and their efficiency in preventing dumping.
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7.6 TCEQ Scrap Tire Program Modification

Transporters, scrap tire facilities, and storage sites must file annual reports 

to the Texas Commission on Environmental Quality (TCEQ). Current Scrap tire 

annual reports do not include reselling used tires as an option, meaning that waste 

tires which are reported to be disposed of could actually be reinserted into the 

market. 

By counting the number of waste tires reused a more realistic number of 

properly processed tires will be at hand. As well as facilitating the tracking of used 

tires and their actual generation within Texas. No modification to the report format is 

required.
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Section 8. 

Recommendations 

Regarding 

Potential Markets 

for Tire-Derived 

Products in 

Mexico
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8 Recommendations Regarding Potential Markets for 

Tire Derived Products in Mexico

Each stakeholder should decide what market is more attractive to him 

based on his own considerations. Nevertheless IEMS recommendations are based 

on the following criteria:

 Markets which require the minor equipment investment and provide the 

higher income per tire (high market price) were selected as the most 

recommendable markets.

 Estimated incomes per tire which are minor than the income theoretically 

obtained from the burning of tires for metal extraction were not 

considered recommendable.

 By doing this discrimination the market thrives to burn waste tires for 

metal extraction would theoretically be discouraged because a higher 

income could be obtained through alternative recommended markets.

 Alternatives which imply higher green house gas emissions per tire 

processed are considered less recommendable.

8.1 Social Considerations

Only Mexican legal framework was considered. To identify legal restrictions 

and regulations, concerning the markets identified a search was performed on 

Mexican Official Standards (Normas Oficiales Mexicanas, NOMs), International 

treaties signed by Mexico, federal, state and local Mexican laws. 

All recycling markets identified as long as they promote energy and raw 

materials savings without affecting health, ecosystems or their elements, are 

allowed. It would be recommendable for each project to perform a SIA prior to make 

any decision regarding a processing project.

By identifying impacts in advance: 

 Better decisions can be made about which interventions should proceed 

and how they should proceed; and 

 Mitigation measures can be implemented to minimize the harm and 

maximize the benefits from a specific planned intervention or related 

activity.

 In order to aid stakeholders to assess social impacts the SIA is 

described according to the international principles of the social impact 

assessment emitted by the International Association for Impact 

Assessment.
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IEMS will present the bases of a social impact assessment and useful data 

in order for each stakeholder to perform its own local social impact assessment on 

the area to be impacted by their planned projects.

8.2 Economic Impact Considerations

To make evident the difference in amount of economic investment required 

by each raw material state, the necessary investments on equipment to process 

waste tires was obtained from previous studies and quotations from manufacturers.

The equipment necessary was determined according to market tire derived 

raw materials specifications such as:

 Tire part

 Type of tire where the raw material originated

 Particle size

 Metal content

 Fiber content.

This estimation considers the required machinery to modify waste tires in 

order to obtain the raw materials as the market demands them. It does not include 

secondary equipment, land, vehicles or facilities.

8.3 Environmental Impact Considerations

Since all alternatives identified are actually recycling activities, all 

alternatives provide the positive environmental impacts and benefits of:

 Waste reduction.

 Tire pile mitigation which means a reduction in soil pollution. 

 Prevent atmospheric and potentially water contamination by eliminating 

tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

Yet health and environment issues have been presented though time 

regarding tire derived products.

IEMS performed a search of serious publications and studies and selected 

the one that was considered to be performed in the most scientific rigor in order to 

assess if health and environmental risks may present in any of the identified 

markets.
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Based on electrical energy consumption and processing speed a 

comparison of estimated green house gas emissions per passenger tire equivalent 

processed was performed to identify the less pollutant alternatives.

Emission per kilowatt-hour were the ones reported for the Mexican Federal 

Commission of Electricity (Comision Federal de Electricidad, CFE) estimated by the 

Technicians and Professionals in Energetic Application Association (Asociacion de 

Tecnicos y Profesionistas de Aplicacion Energetica, ATPAE), which is of 0.6539 

Kilograms of equivalent CO2 per kilowatt-hour.

8.4 Markets Identified

Markets are any tire derived application where waste tires can be put to a 

new use, different than their original and the end user or processor economically 

compensates their tire derived raw materials supplier. The identified markets on the 

Texas-Mexico border area are the following:

1. Passenger tire sidewalls (bulk).

2. De-beaded passenger sidewalls (bulk).

3. Passenger tire sidewalls' bead wire (bulk).

4. Tire treads (bulk).

5. Tire derived geo cells (TDGC).

6. Steel belted rubber for rammed-earth encased walls.

7. Landscaping edging.

8. Tire fences.

9. Tire derived aggregates (TDA) (bulk).

10. Ground rubber for rubberized asphalt (RA) (bulk). 

11. Ground rubber for athletic and recreational surfaces (bulk).

12. Rubber mulch (bulk).

13. Ground rubber for molded and extruded products (bulk).

During this search a pattern was identified and products could be 

catalogued by the state of the raw material needed by them, it could be:

 Shredded or ground rubber. 

 A specific part of a whole tire (i.e. tread, sidewalls, tread with one 

sidewall, etc).
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8.4.1 Passenger Tire Sidewalls

Bulk passenger tire sidewalls can be considered a source for rubber, metal, 

synthetic fibers and thermal energy.

Passenger tire sidewalls are also employed in the creation of diverse 

handcrafts and pet biting toys.

Sidewalls from passenger tires can be easily obtained by cutting through 

the tires shoulder using a knife. Also sidewall removing machines of different models 

and brands are available in the market.

Truck tire sidewalls can only be removed employing a truck tire sidewalls 

remover.

Benefits from recycling tire sidewalls:

 Sidewalls are easily removed.

 Sidewalls can be available with no investment costs through a dead tire 

Cut-Pack-Recycle (CPR) campaign

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent tire piles burns.

 Savings in disposal fees.

 Savings in landfill space.

Image 8.1.

Passenger tire sidewalls, slit at the shoulder of the tire, ready to be transported 

at a processors site in El Paso, Texas, USA
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Issues related to recycling tire sidewalls:

 Need of a shredding machine capable of shredding rubber with metal 

content.

 Rubber obtained contains metal traces even if magnetic separation is 

applied.

 Demand may not be locally available.

Note: Open air burning of tires or of any of their pieces is illegal in all states 

of the Mexican side of the border. 

Image 8.2.

Rubber garden jars made out of tire treads and sidewalls

8.4.2 De-beaded Passenger Tire Sidewalls 

Bulk de-beaded passenger tire sidewalls can be considered a source of 

rubber, metal, synthetic fibers and thermal energy. Passenger tire sidewalls are also 

employed in the creation of diverse handcrafts and pet biting toys.

Sidewalls from passenger tires can be easily obtained by cutting through 

the tires shoulder using a knife. Also sidewall removing machines of different brands 

and models are available in the market. Truck tire sidewalls can only be removed 

from a tire employing a truck tire sidewall removing machine.

The benefits identified are:

 Sidewalls are easily removed from a tires body using a linoleum knife 

or a sidewall removing machine.

 De-beaded passenger tire sidewalls are a source or non metallic 

content rubber which has a higher market value.
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 Bead wire removed can be sold as scrap steel.

 Less powerful shredding equipment is necessary since rubber and 

fiber are the only constituents of passenger tire sidewalls. 

 Tire sidewalls can be available with no investment costs through a 

dead tire Cut-Pack-Recycle (CPR) campaign implemented in 

coordination with waste tires generators.

 Waste reduction. Reuse of a raw material that was considered a 

waste.

 Tire pile mitigation which means a reduction in soil and water

pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

Issues related to recycling tire sidewalls are:

 Demand may not be locally available

8.4.3 Passenger Tire Sidewalls' Bead Wire 

The bead is a rubber-coated steel cable whose function is to ensure that 

the tire remains attached to the wheel rim. Bead wire removed from passenger, light 

truck and heavy truck tires is a source of metal.

De-beading machines are commonly employed for this purpose. No manual 

techniques were identified in this study’s desktop and fieldwork activities.

Benefits from recycling tire sidewalls:

 Attractive purchase prices from diverse buyers are available in most

large cities Mexico.

 Waste reduction.

 Tire pile mitigation.

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

The following related to recycling tire sidewalls’ bead wire issues were 

detected:

 Specialized equipment is required to remove the sidewall’s bead wire. 
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 If the rubber was set on fire to obtain the steel bead wire a large amount 

of carcinogenic and toxic gases and liquids are released, additionally it is 

one of the main causes of tire pile fires in the Mexican side of the scope 

border area.

8.4.4 Tire Treads 

Bulk tire treads can be considered a source of tire derived geo cells, molds 

for rammed earth tire walls, landscape edging, fencing components, rubber, metal, 

synthetic fibers, thermal energy,

Benefits from recycling tire sidewalls:

 High value products such as TDGC, landscape edging, and fence 

railings can be locally obtained at very low costs.

 The use of treads as rammed earth walls molds presents an opportunity 

for low income families without access to commercial building materials 

or for enthusiasts of eco-friendly buildings.

 Passenger tire treads may be easily obtained using a knife to slit through 

a passenger tire shoulders.

 Transportation of tire treads is cheaper than transportation of whole tires 

due to extreme volume reductions.

 Tire cylinders, with sidewalls removed, can be available with no 

investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign 

implemented in coordination with waste tires generators.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

Issues related to recycling tire treads:

 If the rubber was set on fire to obtain the steel belts a large amount of 

carcinogenic and toxic gases and liquids are released, additionally 

burning of tires to extract the metal in the is one of the main causes of 

tire pile fires in the Mexican side of the border area. 

 Rubber obtained would present metal traces lowering its market value 

and increasing rubber production costs if metal is removed.

 Some markets may not be locally available.
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8.4.5 Tire Derived Geo Cells (TDGC)

Geo cells are widely recognized in the construction industry as a 

permanent soil stabilization best management practice (BMP) used for a variety of 

applications including: Roadway load support and stabilization, erosion control, soil 

stabilization on steep slopes, revetments and flexible channel lining systems, earth 

retention structures.

By removing one or both sidewalls of a tire, slit at the shoulder, the 

remaining tread cylinder can be used as a geo cell, herein the name tire derived geo

cell or tire derived geo cylinder (TDGC).

Benefits from recycling TDGC applications:

 Use of TDGC as road base strengthening in Mexican scope 

municipalities could completely remediate all identified tire piles.

 Local materials and soils may be used as TDGC fill material eliminating 

the need of transport and mining of aggregates from distant locations 

thus eliminating the transport and mining environmental and economic 

impacts.

 Reduced cost of materials and construction since both scrap tires and 

backfill soils can be recycled local materials.

 The construction of the system is relatively simple. It doesn’t require 

skilled workers or heavy machinery.

 A problem causing waste is converted into a high value engineering 

input which improves the quality of life and safety of its users.

 Large number of applications in civil engineering projects.

 Green Building certification.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

 Tire cylinders, with sidewalls removed, can be available with no 

investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign 

implemented in coordination with waste tires generators.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Savings in landfill space.

The following related to TDGC issues were detected:

 Some tire derived geo cell technology applications are patented in the 

United States, such as the Mechanical concrete® application.

 Zinc Leaching. 
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8.4.5.1 TDGC Mechanical Concrete® 

Mechanical Concrete® is built with cylindrical tension bands created from 

used auto tires from which both sidewalls have been removed. When appropriately 

sized stone aggregate is poured into the cylinders, the stones tightly lock together 

and behave as a solid, immovable mass: Mechanical Concrete®. This construction 

method uses less stone, requires no compaction or curing, and is instantly ready to 

support construction loads.

It is a way of binding crushed stone aggregates together into a load bearing 

cellular building unit. The Mechanical Concrete®unit can support compressive 

loads and resist lateral soil pressure. It is basically a compressive material. The 

TDGC performs functions similar to the cement / water mixture, the rebar and the 

formwork in hydraulic cement concrete. It actually improves the load bearing 

capacity of the aggregate material be it sand, stone or sandy clay.

Image 8.3.

Mechanical cement® and mechanical concrete® images

Mechanical Concrete® geo-cylinder confinement system has many 

economical and beneficial uses reported by its patent holder. Rural and heavy duty 

road base, gas well pad, mechanically stabilized earth retaining wall systems (MSE) 

and bearing wall applications have been currently implemented. 

Image 8.4.

TRIAD Consulting Engineers Parking Lot, Morgantown, WV USA

(REAGCO, 2011)

Tire derived geo cylinder 

(TDGC) also named Mechanical Cement®

Tire derived geo cylinder (TDGC) 

filled with aggregates also named Mechanical Concrete®
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Potential applications of mechanical concrete TDGC are:

Load Support for

 Paved and Unpaved road sub-base, base, and shoulders

 Unpaved and Paved Low Volume Road intersection interfaces

 Industrial and mining roadways

 Rail road ballast bed stabilization, repair and reconstruction

 Conveyor foundations

 Bridge piers

 Underwater foundations

Earth Retaining Walls and Free Standing Load Bearing Walls

 MSE & Gravity Retaining Walls

 Industrial and commercial building and other load bearing walls and 

foundations

 Mining protective walls and sound wall structures

 Dams, ponds, levees, embankment construction

 Industrial Security walls and sound walls

Channel and Slope Protection

 Drainage control structures

 Bridge pier scour protection

 Erosion control structures to reduce and absorb water runoff velocity 

energy

 Storm water retention

 Channel, Slope and Embankment stabilization and Restoration

Other Uses

 Helipads

 Oil and Natural Gas Drill Pads

 Airfield Construction

 Overflow parking site stabilization

 Emergency Vehicle Road Entrances

 Energy Absorbing Highway and Transportation Crash Barriers

 Natural stone golf cart paths, cycle and walking paths and trails that 

support natural drainage patterns

 Permeable structures for highway, railway and trail slippage repair and 

reconstruction

 Military force protection.
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Benefits on the implementation of MC technology on road bases:

 Road bases load tested to greater than HS 20 wheel loads.

 Using a tire tread cylinder, i.e. any standard automotive tire with both 

sidewalls removed, in a construction application; i.e. where the 

supported vertical loads are in the range of 100psi, 7 TSF; provides a 

rugged, very conservative materials engineering approach.

 Tire-derived-geo-cylinders economically create a virtually indestructible 

base so it basically eliminates most road maintenance problems.

 It can be used effectively and economically in nearly all construction, onroad or off-road applications for a maximum wheel loading of 50,000lbs.

 It more than triples the usual maximum load carrying capacity of sandy, 

granular, and graded stone materials.

 Less general labor and less skilled labor is required.

 It consumes less energy in its construction process since it can use 

smaller equipment.

 It requires no compaction, vibration, forms or rebar.

 It reuses a ready-made cylinder that is a low cost, combination stay-inplace form and reinforcing element.

 It uses the compressive load bearing capacity of low-cost stone 

aggregates or other recycled or earthen aggregate materials.

 It is simple to understand and use so it improves construction worker 

productivity. 

 Speeds-up and facilitates the construction process.

 Common infrastructure problems such as potholes and ruts are virtually 

eliminated.

 When compared to the cost of retaining walls, bearing walls and 

foundations, roads and site stabilization made of conventional concrete 

or compacted stone; Mechanical Concrete® can deliver a minimum 25% 

savings. In many cases this savings can be as high as 50%. In road 

construction the savings can be 25 to 30% or more depending on the 

aggregate used.

The following related to Mechanical concrete® issues were detected:

 Tire derived geo cylinder technology is patented in the United States 

(U.S. Patent 7,470,092 B2).

 It should be implemented using accepted civil engineering design 

techniques, processes and traditional construction techniques.
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8.4.6 Steel Belted Rubber for Rammed Earth Tire Walls

In order to build a rammed earth structure, temporary forms are needed in 

which the soil may be compressed. Generally, rammed earth walls are simple to 

construct, requiring only a form to mold the dirt in and the soil itself. Tires perform 

the function of a mold that can withstand the pressure generated by fill dirt being hit 

by a sledgehammer in order to compress it.

The most common method of building rammed earth tire walls is to place a 

used tire on the ground, fill the tire with dirt and compress the dirt with a hammer. 

Cardboard is often placed in the bottom of a tire before the dirt is placed in it to 

prevent the soil from falling out as it is compacted. This process is repeated until the 

tire is completely filled with compacted soil. 

An individual tire is placed on the running axis of the wall; it is filled and 

compacted in that position. Other tires are then placed and filled next to the first tire. 

Once one row of tires is complete, another row is placed on top of the first row, but 

staggered in alternate lay from the first row, like bricks. In order for this to happen, 

half tires must be used. 

Benefits of structures built using rammed earth tire walls:

 Incombustible, thermally massive and nearly soundproof

 Strong and durable.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

 Tire cylinders, with sidewalls removed, can be available with no 

investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign 

implemented in coordination with waste tires generators.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

Issues of structures built using rammed earth tire walls:

 Ramming earth is labor intensive.

 As with any construction a proper technique is imperative for security’s 

sake.

 Thick walls diminish internal living spaces on buildings with small lots.
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8.4.7 Tree and Landscaping Tire Tread Edging 

Landscaping using tire derived products is a proven and current use of 

waste tires, mostly in the form of tire derived rubber mulch. Garden edging is a new 

application developed by IEMS’ team. No knowledge of its application in the TexasMexico border or elsewhere was found. Nevertheless it is presented as a potentially 

large market once its viability is confirmed through testing and pilot applications, 

which are strongly suggested but not part of this study’s scope.

Landscape edging provides the following benefits:

 Edging permanently defines the landscape bed, so that continual 

reshaping of the bed is virtually eliminated.

 Significant savings in maintenance expenses will be achieved as 

landscape edging eliminates the continual spading of the bed edge by 

hand or using power edgers.

 Edging assures crisp, clean lines will be maintained throughout the 

landscape bed, ensuring the original design intent is maintained.

 Edging blends architectural details with the landscape beds, building a 

properly designed and balanced landscape.

 Landscape is truly defined by proper separation of lawn, flowerbeds and 

aggregates and edging will achieve those goals.

 When various aggregates are used in a contained area, edging is the 

only way to assure a permanent separation.

 Properly installed, quality landscape bed edging gives clarity and 

significantly increases the level of visual aesthetics and adds value to 

the business or residence.

Landscaping edging using cut tire treads provides the following additional 

benefits:

 Long lasting product materials, virtually indestructible.

 Use of low carbon footprint product since required energy input to 

produce it is minimum compared to extruded and molded ground rubber 

products.

 With a relatively low investment an almost ubiquitous residue becomes a 

highly valued product. 

 Because of its relatively low required investment it can represent a 

viable market solution to the waste tire problems occurring on the TexasMexico border, especially on the Mexican side where municipal solid 

waste management budgets are significantly lower.

 Municipalities, cities and counties can improve the public landscaping on 

parks and public areas with a minimum investment, avoiding tire 

disposal costs which burden them nowadays.

 Tire tread cylinders, with sidewalls removed, can be available with no 

investment costs through a Cut-Pack-Recycle (CPR) campaign 

implemented in coordination with waste tires generators.
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 Using 100 percent acrylic exterior house paint the edging can be colored 

as desired.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

Issues from tree and landscape edging using cut tires:

 Accidentally exposed wires could harm people or animals.

 Possible human health hazards.

No adverse human health or ecological health effects are likely to result 

from these beneficial reuses of tire materials.

Since recycled tire rubber has been deemed non dangerous for human 

health or the environment in playgrounds, which are located in parks and gardens, it 

is IEMS’s opinion that cut tire treads (with a protection installed on each extreme to 

prevent wires to be exposed) will be as safe for humans and the environment as 

both applications evaluated by ChemRisk.

8.4.8 Tire Tread Fences

The creation of fences using cut tire treads is an innovative solution 

developed by IEMS’ team. No knowledge of its application in the Texas-Mexico 

border or elsewhere was found. Nevertheless it is presented as a potentially large 

market once its viability is confirmed through testing and pilot applications, which are 

strongly suggested but not part of this study’s scope.

Image 8.5.

Diagram of tread hog fence
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Benefits expected from cut tire tread fencing:

 Cut tire tread fences may lower labor and inputs costs making them 

more affordable than treated wood applications with similar performance 

except on strength. 

 For intruder control, cut tread fences would have the added value of 

being more resilient to vandalism or entrance attempts by cutting them 

than other kinds of fences, such as chain link which can be easily cut 

with manual tools. 

 Tread fences wouldn’t be see through, providing more privacy to the 

protected area.

 Long lasting product materials.

 Use of a recycled product which avoids the use of virgin materials such 

as wood.

 Municipalities, cities and counties can fence municipal properties using 

waste tires with a minimum investment.

 The tire dump sites may be fenced using this technology to avoid arson.

 Tire cylinders, with sidewalls removed, can be available with no 

investment costs through a dead tire Cut-Pack-Recycle (CPR) campaign 

implemented in coordination with waste tires generators.

 Using 100 percent acrylic exterior house paint the fence can be colored 

as desired.

 They require low energy input.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

8.4.9 Tire Derived Aggregate (TDA)

Tire derived aggregate (TDA) is an engineered product made by cutting 

scrap tires into 25- to 300-millimeter (mm) pieces. Depending on particle sizes TDA 

is classified on types A and B (Gray, 2010).

8.4.9.1 Type A TDA

Type A TDA is appropriate for a range of drainage applications in layers up 

to 1 m (3.3 feet) thick. 
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Potential drainage applications include (Gray, 2010):

 Drainage layers within landfill leachate collection and removal systems.

 Permeable aggregate for landfill gas collection layers and trenches.

 Free draining aggregate for edge drains for roadways.

 Permeable backfill for exterior walls below the ground surface.

 Septic system drains fields.

 Landfill gas collection systems.

8.4.9.2 Type B TDA

Type B TDA is used for lightweight fill applications in layers up to 3 m (10 

feet) thick.

Fill applications include:

 Lightweight fill for highway embankments.

 TDA and TDA soil mixtures have been used as a replacement for 

conventional soil in embankment construction.

 Compressible layers behind integral abutment and rigid frame bridges.

 Backfill for retaining walls, bridge abutments, and sheet-pile walls. 

 Limit the depth of frost penetration and to provide drainage during the 

spring thaw.

 Use as drainage layers in landfills, septic system drain fields, and 

highway edge drains.

 A TDA layer beneath the stone ballast of rail lines reduces off-site 

vibrations.

Benefits from using TDA in specific engineering applications:

 TDA provides many solutions to geotechnical challenges since it is 

lightweight: 50 pounds per cubic foot.

 Produces low lateral pressures on walls (as little as one-half that of soil).

 Is a good thermal insulator (eight times better than soil).

 Has high permeability (more than 1 centimeters per second [cm/s] 

dependent on TDA size).

 Has good shear strength 

 Absorbs vibrations.

 Moreover, each cubic meter of TDA fill contains the equivalent of 100 

passenger car tires.

 Is used to improve the stability of embankments constructed on weak 

marine clay.

 Cost reduction

 Small scale applications can be implemented by municipal officials such 

as public works directors.

 Waste reduction.
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 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

 Green Building certification. Facilities earn more points for the US Green 

Building Council’s LEED® certification program or for any other green 

building certification standard.

Issues arising from using TDA in specific engineering applications:

 The economics of using TDA for civil engineering applications depend 

on the local costs to produce TDA and the local costs for competing 

alternative construction materials. TDA is not a generally cost-effective 

substitute for conventional earth fill.

 Zinc leaching

 Sophistication

8.4.10 Ground Rubber for Rubberized Asphalt (RA)

Rubber modified asphalt is the product of mixing crumb rubber from scrap 

tires or other sources with asphalt. It is used as Asphalt pavement for roads.

Benefits obtained from paving using rubberized asphalt (RA)

 Performance. Roads last longer than traditional asphalt, sometimes 

dramatically longer, but this performance has not been universal.

 Cost. Use of thinner rubber modified asphalt lifts (layers) can turn cost 

into an advantage where applicable and accepted.

 Noise reduction and increased safety are accomplished through use of 

open-graded friction course (OGFC) pavement using large, uniformly 

graded aggregate. Improves the flexibility and tensile strength of the 

asphalt mix reducing the appearance of cracks due to fatigue or 

temperature changes.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.
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Issues arising from paving using rubberized asphalt (RA):

 Poor performance has been attributed to improper installation, weather 

conditions, bed preparation, and aggregate grading.

 Florida found that rubber modified asphalt performed well, but that 

polymers out-performed terminal-blended rubber modified asphalt for 

some high-traffic applications.

 The installed cost of an equivalent thickness of rubber modified asphalt 

is generally 10 to 100 percent higher than unmodified asphalt, as 

previously discussed.

8.4.11 Ground Rubber for Athletic and Recreational Surfaces 

The current generation of artificial sports turf uses 7.6-cm (3-inch)-long 

strands of green polyethylene embedded in a porous backing to form a carpet like 

structural framework for the turf system. 

The polyethylene grass-like blades add containment to the ground rubber, 

and the rubber provides cushioning while the combined synthetic turf system bears 

the physical forces of athletic activity (Gray, 2010). 

Synthetic sports turf is mostly used in football stadiums but now this can be 

used on a wide range of sports fields at all levels of play, like American football, field 

hockey, baseball, etc.

Benefits obtained from using ground rubber for athletic and recreational 

surfaces:

 Health. Studies indicate that the severity of injuries is worse on natural 

grass turf. There are more head, neural, and ligament injuries on natural 

grass, while there are more epidural, muscle trauma, and temperature 

related injuries on synthetic turf.

 Economics. Synthetic turf’s higher initial cost is offset by reduced 

maintenance associated with water, fertilizer, pesticides, cutting, turf 

replacement, and manpower.

 Synthetic turf drains rapidly, allowing use quickly after heavy downpours. 

In addition, synthetic grass turf can reportedly tolerate up to 3,000 hours 

of use per year, about four times more use than natural grass turf.

 Tire pile abatement

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.
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 Savings in landfill space.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

Issues from using ground rubber for athletic and recreational surfaces:

 Elevated Turf Temperature

 The pieces of black rubber and colored synthetic turf blades absorb light 

energy and become warmer than ambient temperatures.

 Zinc Leaching

8.4.11.1 Playground Safety Surfaces

In order to avoid injuries derived from falls from playground equipment the 

areas under and surrounding them are covered with surfaces with high shock 

absorbing properties.

Benefits obtained from applying rubber for playground safety surfaces:

 Higher fall protection.

 Durability. Rubber is flexible, resilient, and durable, properties that make 

it a good outdoor cushioning material. 

 Accessibility of equipment by children in wheelchairs or on crutches can 

be an important consideration.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

Issues from applying rubber for playground safety surfaces:

 Flammability.

 Latex Sensitivity.

 Toxicity and environmental questions associated with ground rubber 

have been raised for playground applications as well as for synthetic 

turf.

 Zinc Leaching.
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8.4.12 Rubber Mulch

Mulch is any material applied to the garden in order to retain soil humidity 

and suppress weeds. It also has esthetical purposes. It can be made of leaves, 

gravel, wood chips and rubber, among other many materials, which normally are 

locally available.

Benefits of rubber mulch:

 Control weeds

 Resist mold.

 Retain moisture.

 Requires infrequent addition. 

 Does not harbor insects or attract neighborhood animals.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

Issues that arise from using rubber mulch: 

 Flammability

 Temperature. Black ground rubber pieces absorb light and can heat up. 

 Zinc Leaching

8.4.13 Ground Rubber for Molded and Extruded Products 

Molded products are created when heated rubber is pressed into a mold or 

through a die cast to shape it into a new product. Extrusion normally involves using 

a screw system to mix, heat, and force a raw material through a die to produce a 

continuous shape.

This market is very versatile and can create a wide variety of products.

Molded crumb rubber for example can be transformed into items such as 

pavers, tiles, splash guards, tree rings, curbing, mats, wheels for trash cans, traffic 

cones, vehicle bumpers, wheels, mud flaps, etc.
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Long items such as: hoses, weather stripping, tubes, molding, belting, pet 

toys, car bumpers, gaskets, garden hoses, complex components for medical and 

electrical equipment, synthetic woods, shingles and other structural materials are 

made by extrusion processes.

Benefits from creating molded and extruded products from ground rubber

 Low-Cost Raw Material.

 Ground rubber can be a low-cost raw material with many of the intrinsic 

performance properties of rubber.

 This market is very versatile and can create a wide variety of products.

 Waste reduction.

 Tire pile mitigation which means a reduction in soil and water pollution. 

 Prevent atmospheric, soil and potentially water contamination by 

eliminating tire piles which could burn.

 Savings in disposal fees.

 Diminish the environmental impacts of virgin materials extraction and 

transportation.

 Savings in landfill space.

 Facilities earn more points for the US Green Building Council’s LEED® 

certification program or for any other green building certification 

standard.

Issues involved in creating molded and extruded products from ground 

rubber:

 Displacement Challenges. Making any new product can involve 

substantial investment in processing technology, equipment, 

optimization, product testing, distribution, and marketing. 

 Any residual wire or fiber can accelerate wear, or damage extrusion 

heads and equipment. 

 This technology can be labor intensive in its basic form.

 Mixtures. Rubber generally functions as filler in mixtures with plastics. 

Thermoset rubber and thermoplastics do not naturally bond, resulting in 

significant changes in the performance characteristics of plastics when 

rubber is added. 

New tires can contain from 5% to 10% of recycled rubber, if more than that 

is added the tire will fail (Information provided by Francisco Martha Hernandez, 

general director of the Mexican rubber industry national chamber. Tire rubber dust 

can be de-vulcanized at very high costs; it would be over than 3 times more 

expensive than virgin materials.

Ground rubber for extruded products could also be presented as a separate 

market since additional equipment is necessary in order to achieve the fine mesh 

size required by these applications (30 to 200 mesh).
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8.5 Market Recommendations of Tire Derived

Products in Mexico

Each stakeholder should select the market that better suits him/her needs, 

the purpose of this section is to present the evaluation results in order to aid in the 

market selection process.

8.5.1 Tire Derived Products Market Prices 

The following references to Attachments included in the study Full report, 

present information on market prices for the identified tire derived products:

 Attachment 27. Estimated and consulted market prices of tire derived 

products currently supplying the identified markets.

 Attachment 28. Daily prices of tire derived products and parts during 

May 2012.

 Attachment 29. Potential revenue per passenger tire equivalent (PTE) 

for each market and formulas applied to obtain each.

 Attachment 32. Scrap tire wire purchase prices in the Mexican side of 

the Texas-Mexico border region.

8.5.2 Required Investments on Equipment

The following references to Attachments included in the study Full report, 

present information on equipment necessary to produce each of the identified tire 

derived products. It is relevant to note that the amounts presented are for equipment 

only, not including required land, facilities, secondary equipment, production costs, 

etc:

 Attachment 30. Matrix of required equipment per type of product.

 Attachment 31. Equipment quotations and pricing sources.

Of the identified existing and potential markets the most expensive to 

access, based only on required investment on equipment, are the following:

 Type B tire derived aggregate (TDA) (bulk).

 Type A tire derived aggregate (TDA) (bulk).

 Ground rubber for Rubberized Asphalt (RA) (bulk).

 Ground rubber for Athletic and recreational surfaces (bulk).

 Rubber mulch (bulk).

 Ground rubber for molded and extruded products (bulk).

 Ground rubber for extruded products (bulk). 
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Of the identified existing and potential markets the most accessible ones, 

based only on required investment on equipment, are the following:

 Passenger tire sidewalls (bulk).

 Tire-derived-geo-cylinders, (TDGC).

 Steel belted rubber for rammed-earth encased walls.

 Tire treads (bulk).

 Passenger tire de-beaded passenger sidewalls (bulk).

 Passenger tire sidewalls' bead wire (bulk).

 Cut tire tread tree and landscape edging 

 Cut tire tread fencing.

8.5.3 Recommendations 

A) The income per tire of any promoted market should be higher 

than the amount paid for the steel present in the tire to discourage tire open 

burning for metal extraction. One of the main causes of tire fires is tire burning for 

metal extraction. This is caused by the need to obtain resources through the sale of 

the steel wire embedded inside tires.

For example: scrap tire wire is bought in Reynosa, Tamaulipas, Mexico at 

an estimated mean of $2.92 Mexican pesos per kg ($0.096 USD per pound). So the 

potential income per passenger tire by burning it for metal extraction is $4.38 

Mexican pesos per passenger tire ($0.316 USD per passenger tire) in Reynosa. 

B) Zinc leaching should be considered an Environmental Issue of 

Concern (EIC) on some tire derived products. Since the following tire derived 

applications will be in direct contact with rain water and soil, it was considered 

relevant to consider this EIC also for them: TDGC, Landscape edging, TDA, RA, 

Ground rubber for athletic and recreational surfaces and Rubber mulch

C) To implement CPR dead tires campaigns, or similar, in the TexasMexico scope areas

Image 8.6.

English version example of a CPR dead tires campaign

 
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Image 8.7.

Spanish version of example of a CPR dead tires campaign

A CPR dead tires campaign promotes waste tire generators to: 

i. Slit passenger waste tires on the shoulder to remove both sidewalls 

“Cut”.

ii. Order and pack the resulting tread cylinders and sidewalls in a way the 

volume they occupy is minimum “Pack”.

iii. Recycle them or send the packed tire pieces to a recycling facility 

“Recycle”. 

By implementing a CPR dead tires campaign the following benefits could 

be obtained:

 Eliminate mosquito breeding areas.

 Health benefits. By eliminating mosquitoes breeding sites, their related 

diseases such as Dengue Fever and West Nile Virus are also fought.

 Storage space required by waste tires is greatly reduced.

 Transportation costs are reduced.

 Disposal fees are reduced.

 Promoting a Cut-Pack-recycle (CPR) campaign among waste tire 

generators would make tire derived cylinders (treads) and slit sidewalls 

available to recyclers, authorities and processors without the need of 

investing resources such as time, labor and money in sidewall removing 

activities.

Also by implementing a CPR dead tires campaign recyclers, authorities and 

processors would have direct and cheap access to:

 Tire derived geo cells for civil engineering projects.

 Steel belted rubber for rammed earth tire walls.

 Slit sidewalls ready for de-beading.

 Packaged tire treads ready for transportation to processing or disposal 

sites at lower costs than when transporting whole waste tires.
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Image 8.8.

Used tire dealership worker manually cutting passenger tires’ sidewalls using a 

cutter knife in Brownsville, Texas

8.6 Markets Evaluation

8.6.1 Legal Evaluation

While none of the proposed market alternatives is illegal in Mexico, some 

alternatives are more heavily regulated and or restricted than others.

A general prohibition throughout the Mexican side of the border is the 

burning of tires in open air.

Only the rubberized asphalt application is specifically regulated in Mexican 

legal framework. These regulations are focused on ensuring the quality control of 

the modified asphalt created in part of tire ground rubber.

It should be noted that even if no specific regulations were found, it doesn’t 

mean general regulations and laws don’t apply. The purpose of this search was to 

identify regulations that applied specifically to tire derived products, apart from the 

general regulations which apply to a traditional application.

8.6.2 Economic Evaluation

8.6.2.1 Market Prices per Tire

Prices currently paid for each tire derived product identified are described in 

study Full report. Since some of these products are not yet available on the market, 

the prices presented for these are the ones paid for similar products with which they 

would compete.
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Figure 8.1 displays the potential income per Passenger Tire Equivalent 

(PTE) received when supplying each of the identified markets. 

It is relevant to note that the following are considered to use de-beaded tire 

sidewalls as rubber source: 

 Ground rubber for athletic and recreational surfaces.

 Molded and extruded products.

Meaning that an alternative income for the tire treads sale can be obtained 

depending on the market supplied with them. Violet bars represent consulted current 

prices of the tire derived products on existing markets. Gray bars represent 

estimated prices based on what similar products are currently worth in the market.

8.6.2.2 Required Equipment Investment per Market

In order to supply any of the identified markets, waste tires require 

modifications in order to comply with the demand specific needs. The equipment 

necessary to perform said modifications greatly varies in size, complexity, required 

energy input, required investment, labor needs, etc. 

The estimated economic investment on equipment to modify waste tires 

according to current and potential markets demands is presented on Figure 8.2.

This figure displays the required investment on equipment, not including the 

required facilities, labor, energy inputs, secondary equipment, etc. 

Rubber for extruded products is presented on a separate column in Figure 

8.2. because mesh size required can be as low as 200 mesh, to obtain this mesh 

size it is required additional equipment which would further elevate the investment 

required. Since no quotations were obtained for this specific equipment it is only 

noted that the market which requires the largest investment on equipment is the 

ground rubber for extruded products.

The section below evaluates in more depth which markets require large 

investments on equipment to process tires.

8.6.2.3 Most Expensive Markets to Enter Based on Equipment Required 

Investment

Based on the information presented on Figure 8.2. it is visible that some

markets require larger initial investments on processing equipment than others.

Of the identified existing and potential markets the most expensive to 

access, based only on required investment on equipment, are the following:
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 Type B tire derived aggregate (TDA) (bulk)

 Type A tire derived aggregate (TDA) (bulk)

 Ground rubber for Rubberized Asphalt (RA) (bulk) 

 Ground rubber for Athletic and recreational surfaces (bulk).

 Rubber mulch (bulk).

 Ground rubber for molded and extruded products (bulk).

8.6.2.4 Most Accessible Markets Based on Equipment Required 

Investment

Of the identified existing and potential markets, the most accessible ones

based only on required investment on equipment are the following:

 Passenger tire sidewalls (bulk).

 Tire-derived-geo-cylinders, (TDGC).

 Steel belted rubber for rammed-earth encased walls.

 Tire treads (bulk).

 De-beaded passenger sidewalls (bulk).

 Passenger tire sidewalls' bead wire (bulk).

 Tire tread tree and landscape edging 

 Tire tread fencing.

It is evident that some markets require the same equipment to produce tire 

derived products. For example to sell passenger tire sidewalls, treads, TDGC and 

steel belted rubber for rammed earth tire walls the investment is the same. The 

same happens with the equipment required to produce de-beaded sidewalls and 

bead wire, and yet again on the fencing and edging markets. 

More accessible equipment investment range from $3,900 USD ($54,011 

Mexican pesos) in order to manufacture:

 Passenger tire sidewalls in bulk.

 Tire-derived-geo-cylinders, (TDGC).

 Steel belted rubber for rammed-earth encased walls.

 Tire treads (bulk).

These markets require only removing the sidewalls of waste tires. 

Equipment investment to remove passenger tire sidewalls can be lowered to $15.2 

USD ($210.5 Mexican pesos) for the purchase of a professional linoleum knife or 

even lower. Making the markets that only require removing one or both passenger 

tire sidewalls the most accessible based on required investment on equipment.

To a required equipment investment of $10,950 USD ($151,646.55 

Mexican pesos) in order to manufacture cut tire tread for fencing.
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8.6.3 Environmental Evaluation

Performing environmental impact assessments on each application for 

each location in the Mexican scope area is not possible since many variables would 

be unknown. Such as: water bodies, biodiversity in the area, type of soil and its 

characteristics, climate, processes, etc.

Yet during fieldwork and deskwork activities IEMS identified environmental 

issues of concern which are presented as follows: 

8.6.3.1 Environmental Issues of Concern (EIC)

Zinc Leaching

Tire rubber contains about 1.5 percent zinc as a vulcanization accelerator 

within the rubber polymer matrix. Water can gradually leach small amounts of zinc 

from the chip into the underlying soil. Traces of zinc serve as a micronutrient for 

many species, but excessive quantities can have a negative impact on some plants 

and grasses. 

Leaching is slow and controlled with water flowing through chips on the 

surface of beds, but it could be accelerated by continuous submersion in water or 

soil (Gray, 2010). 

The following information was obtained from the document “Kanematsua, 

Masakazu et al. (2010) Characterization and potential environmental risks of 

leachate from shredded rubber mulches”. Davis: National Institutes of Health, and is 

presented textually to illustrate why Zinc leaching is an environmental issue of 

concern on some of the identified markets.

“In order to determine whether shredded rubber mulches (RM) 

posed water quality risks when used in stormwater best management 

practices (BMPs) such as bioretention basins, batch leaching tests were 

conducted to identify and quantify constituents in leachates from RM such 

as metal ions

“The results indicate that aqueous extracts of RM contain high 

concentrations of zinc (Zn) compared with wood mulches (WM), and its 

concentration increased at lower pH and higher temperature.

Leaching of Zn from RM appears to be a potentially larger water 

quality issue for RM” (Kanematsua, 2010)”.
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Analysis of EIC

Some zinc concentrations on rubber mulch leachate are higher than 20 

mg/L, which is the maximum permissible monthly average limit established by 

Mexican Official Standard NOM-001-SEMARNAT-1996 for zinc concentrations in 

water discharges on national water bodies or soil. Although this regulation does not 

directly apply to mulch leachate it provides a reference value of how relevant these 

concentrations are.

In mediums with pH of 5 all rubber mulch leachates at any temperature, 

ranging from 10°C to 40°C, surpassed zinc concentrations of 10mg/L, which is the 

maximum daily authorized average concentration of zinc in waste water discharges 

according to the mentioned standard. 

Although the study of the NHS encompasses rubber mulch on a very 

conservative approach, since the following tire derived applications will be in direct 

contact with rain water and soil, it was considered relevant to consider this EIC also 

for them.

Tire applications where relevant Zinc leaching may occur:

 Tire derived geo cells (TDGC).

 Landscaping edging.

 Tire derived aggregates (TDA) (bulk).

 Ground rubber for rubberized asphalt (RA) (bulk). 

 Ground rubber for athletic and recreational surfaces (bulk).

 Rubber mulch (bulk).

IEMS strongly suggests that the Environmental Impact Assessment (EIA) 

performed for the application of any of the markets mentioned above should

consider the impact caused by zinc leaching from tire rubber when in contact with 

water. And propose mitigation alternatives to prevent contamination of soil and 

ground or surface water bodies.
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Figure 8.1. 

Potential income per passenger tire equivalent on each market
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Figure 8.2. 

Required Investment on processing equipment to produce each tire derived product (US dollars)
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Section 9. 

Waste Tires 

Appropriate 

Disposal 

Alternatives
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9 Waste Tires Appropriate Disposal Alternatives

9.1 Methodology

The following methodology was followed for the determination of 

appropriate disposal alternatives.

9.1.1 Identification

Appropriate disposal alternatives in this study are the ones which, as a 

base, comply with the legal regulations that apply where the disposal site is located.

Waste tire disposal stakeholders in both sides of the border were interviewed to 

gather the required information for this section.

A brief description based on previous publications, studies, regulations, 

laws and government agencies data bases, publications, fieldwork and deskwork 

data, associations, etc., are presented to educate the reader.

9.1.2 Recommendation

Based on the evaluation results specific recommendations regarding 

appropriate tire disposal management are presented.

9.1.3 Evaluation

Texas’ border region tire disposal alternatives evaluated:

 Land reclamation projects using tires (LRPUT).

 Landfills.

Mexico’s border area evaluated alternatives:

 Landfills

 Tire derived fuel in cement kilns (TDF)

Each local stakeholder should base local disposal guidelines on:

 Social evaluation:

 people’s way of life;

 their culture;

 their community;

 their political systems;

 their environment;

 their health and wellbeing;

 their personal and property rights;

 their fears and aspirations;
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 Environmental impacts on:

 Inert physical media;

 Living physical media;

 Economic evaluation: 

 Transportation costs;

 Disposal fees.

9.2 Identified Disposal Alternatives

Appropriate tire disposal alternatives identified in the Texas-Mexico border 

region and the ones developed by IEMS are the following:

1. Landfill, shred or cut waste tires;

2. Burial of whole, shred or cut waste tires in land reclamation projects 

using tires (LRPUT);

3. Burning, shred, cut or whole, waste tires as tire derived fuel in cement 

kilns (TDF);

4. Reclamation of depleted open pit coal mines.

Options 1 and 2 are applied in the U.S. side of the border while only 1 and 

3 are applied in the Mexican side of the border. Option 4 was developed by IEMS’ 

team of engineers and is not yet applied in any side of the border.

9.3 Landfill Shred or Cut Waste Tires

Landfills are engineered areas where waste is placed into the land. 

Landfills usually have liner systems and other safeguards to prevent polluting the 

groundwater.

Modern landfills are well-engineered facilities that are located, designed, 

operated, and monitored to ensure compliance with federal regulations. Solid waste 

landfills must be designed to protect the environment from contaminants which may 

be present in the solid waste stream. 

Only split, quartered, or shredded tires may be disposed of in a landfill. 

Storage or processing activities must be specified in a landfill’s permit and scrap 

management registration is required.

According to Mexican remote interviews private landfills in Mexico also 

receive waste tires. These are previously shredded in order to prevent them from 

floating into the surface.

Landfills in the Texas side of the border area are classified, according to 

the type of waste they may receive, as following:

 Type I landfills are authorized to accept municipal solid wastes.
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 Type IV landfills are normally more limited in that they may only accept 

brush, construction and demolition debris, and other waste that will not 

putrefy.

An additional designation “AE” in the landfill type indicates an “arid exempt” 

facility. AE landfills normally are limited in the amount of waste they are authorized 

to accept. 

Image 9.1.

Hogzilla® shredder

Waste tires are considered by Mexican legislation as a special handling 

waste. The federal standard NOM-083-SEMARNAT-2003 dictates the 

environmental protection specifications for the selection, design, construction, 

operation, monitoring, closure and complementary works of an urban solid waste 

and special handling waste disposal sites. 

This standard classifies final disposal sites (landfills) based on the amount 

of daily waste entering to them, in metric tons, as the following table displays.

Table 9.1.

Final disposal sites categories

Type Tons received Per Day 

(Tons / Day)

A More than 100

B From 50 to100

C From 10 to less than 50

D Less than10
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9.3.1 Disposal of Cut or Shred Tires in Landfills

Tires present unique and challenging disposal problems because of their 

size, shape, and physical and chemical properties. Landfill of whole tires consumes 

a large volume of landfill space because the tires are relatively incompressible and 

75 percent of the space a tire occupies is empty. In addition, they tend to trap gases 

and rise to the top of landfills after being buried. As a result, laws in both Mexico and 

the United States prohibit landfill tires along with other types of waste.

In the US, the tire management laws in most states do not ban disposal 

outright. In all, 38 states have bans, however, of those states with tire bans, some 

states allow disposal if the tires have been shredded, chipped, or halved. To keep 

track of who is collecting and transporting tires some states also have put permitting 

or registration requirements into legislation. Along the Mexican boundary, solid 

waste disposal sites began accepting waste tires that had the sidewalls removed. 

There, the tires are buried in the landfill. Waste tires that have been shredded or cut 

into three pieces also are allowed to dispose in the landfills.

Private landfills in the Mexican side of the border, such as the Piedras 

Negras PASA facility, posses an exclusive cell for shredded of cut waste tire final 

disposal. In theory all sanitary landfills which comply with federal legislation in 

Mexico are able to receive cut or shred waste tires.

Cutting Process Description

Cutting the sidewalls out of waste passenger tires, and also making at least 

one cut across the tread for larger tires are the ways in which a tire must be 

processed prior to disposal at a landfill since these methods of processing reduce 

the volume of the tire by at least 50% and prevent the tire from retaining water.

9.4 Land Reclamation Projects Using Tires (LRPUT)

LRPUTs are projects to fill, rehabilitate, improve, or restore already 

excavated, deteriorated, or disturbed land, using no more than 50 percent by 

volume of tire pieces along with inert fill materials, to restore the land to its 

approximate natural grade and to prepare or reclaim the land for reuse. In Texas all 

tires used to fill land must be split, quartered, or shredded. Whole tires cannot be 

placed belowground. Completed projects must be covered with 18 inches (0.46 

meters) of clean soil. 

In the state of New Mexico, USA, land reclamation projects are not required 

to cut or shred waste tires in order to bury them as it is stated in the New Mexico 

Administrative Code (NMAC) 20.9.20 and specifically in 20.9.20.43.

Mexican legislation does not contemplate the use of special handling 

wastes such as tires as filling material in abandoned open pit mines. The only 

allowed disposal alternative are sites which comply with standard NOM-083-

SEMARNAT-2003. 
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Image 9.2.

LRPUT in El Paso, Texas

9.5 Tire Derived Fuel (TDF) in Cement Kilns

Calcinations of raw materials to manufacture clinker (a fundamental 

element in the production of cement) which takes place inside of kilns, is the core of 

the process within the cement plants; which requires a large amount of energy, 

supplied by fuel, which is injected into the kilns, and represents the bigger cost in 

the manufacture of cement. High temperatures in kilns and long residence times 

inherent to the cement manufacturing process, represent an high potential for the 

destruction of organic compounds, which enables the use of a wide variety of fuels, 

by-products of other industrial processes or derived from wastes, both solid (waste 

tires, wood, paper, cardboard, plastic, urban and industrial sludge, etc.) and liquids 

(solvents, used oils, distillation waste, etc.). For this, cement plants meet the 

necessary conditions to carry out a clean burning of tires and taking advantage of its 

high caloric content instead of petroleum or coal. 

No cement kilns are installed in the Texas side of the scope border area, 

only one kiln is located in the Mexican side of said border in the city of Ciudad 

Juarez, Chihuahua, which has no facilities for the use of tires as TDF.

The General Law for the Prevention and Integral Management of Waste 

(Ley General para la Prevencion y Gestion Integral de Residuos, LGPGIR) 

promotes waste valorization, which encompasses the principle and group of 

associated actions whose objective is the recovery of the remaining value or caloric 

power of the materials which make up wastes, through their incorporation in 

productive processes, under shared responsibility criteria, integral management and 

environmental, technologic and economic efficiency. 
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9.6 Reclamation of Depleted Open Pit Coal Mines

Open pit mining is an industrial activity of high environmental, social and 

cultural impact. It is an inherently unsustainable industrial activity.

Technical innovations that have experienced mining from the second half of 

this century have radically changed the activity, so that it has gone from the 

exploitation of underground mines of high quality to exploitation in open pit mines of 

lower quality minerals in larger deposit areas.

Open pit mining removes the surface layer or overload the soil to make 

accessible the extensive deposits and low quality ores. It is profitable because it is 

less expensive than an underground mine (AECO-AT, 2001).

Coal, like all other sources of energy, has a number of environmental 

impacts, from both coal mining and coal use. According to World Coal Association, 

coal mining raises a number of environmental challenges, including soil erosion, 

dust, noise and water pollution, and impacts on local biodiversity.

Image 9.3.

Active open pit coal mine in Coahuila, Mexico

Image 9.4.

Unrehabilitated inactive coal mine in Coahuila, Mexico.
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9.6.1 IEMS’s Land Reclamation Proposal in Open Pit Mines

In Land Reclamation Projects Using Tires (LRPUT), tires are used as a fill 

material on land that has been mined or subjected to significant erosion and is in the 

process of being restored (reclaimed). Tires are used to level out the contour of the 

land before the land is covered with soil and reseeded. In 2007, about 70.8 

thousand tons of scrap tires were used in reclamation projects in the United States. 

Reclamation projects were reported in four states: Arkansas, Nebraska, New Mexico 

and Texas, being the later one that has the more relative usage of scrap tires in land 

reclamation projects (87.8 %).

Land reclamation is commonly used in the United States; the second 

largest use category for scrap tires in Texas is Land Reclamation Projects Using 

Tires (LRPUT). Shredded scrap tires have routinely been used as fill material in civil 

engineering and reclamation projects for a number of years.

Figure 9.1.

Diagram of surface coal mining operations (top) & mine rehabilitation 

activities (bottom)

 
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As a reference: in areas that have been strip mined or mined for sand and 

gravel, a 50:50 mixture of tire pieces and soil is usually used as fill material to 

reclaim the mined area. 

The mine reclamation process proposed by IEMS consist in the use of a cut 

tires layer less than 1 meter thick followed by a soil layer with 1 meter thick and then 

repeated. Since the mineral coal extracted in Coahuila has 69-86% of carbon, it is 

feasible to refill open pit mines with waste tires, whose composition has 85% of total 

carbon approximately, practically replacing the coal extracted with a similar carbon 

source.

Since carbon mines are to be reclaimed at the end of their life, the 

reclamation equipment and machinery could very well be used for the burial of 

already cut or shredded tires. This assuming tires disposed by generators are cut or 

shredded before being sent for disposal. Figure 9.2. displays a diagram of the 

proposed reclamation technique using tires.

Figure 9.2.

Coal mine rehabilitation diagram including intermediate cut-tires layers

To determinate layers thickness, IEMS proposes to apply the Design 

Guidelines to Minimize Internal Heating of Tire Shred Fills published by the EPA on 

the Scrap Tires: Handbook on Recycling Applications and Management for U.S. and 

Mexico (EPA, 2010). According to this report, although there have been no projects 

with tire layers less than 4 meters (13.1 feet) that have experienced a catastrophic 

heating reaction, to be conservative, tire layers greater than 3 meters (9.8 feet) thick 

are not recommended. Additionally no design features are required to minimize 

heating of tires layer less than 1 meter thick.

It also recommends that tires are contaminant-free such as oil, grease, 

gasoline, diesel fuel, etc., that could create a fire hazard or leachate. In any case the 

cut tires shall not contain the remains of tires that have been subjected to a fire 

because the heat of a fire may liberate liquid petroleum products from the tire that 

could create a fire hazard or leachate when the tires are placed in a fill.

For every cubic meter of volume to be reclaimed 28 passenger tires could 

be disposed. Considering millions of cubic meters of coal are extracted from the 

mines, a large disposal volume potential is available.
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9.6.1.1 Coal Mining in the Texas Border with Mexico

Currently four coal mines are located in the Texas side of the scope area. 

Three of them, located in Webb County, were still in reclamation process on August 

2011 which presents a waste tire disposal opportunity for Texas border cities 

nearby. Figure 9.3. displays the coal mining locations in Texas. 

Figure 9.3.

Permitted coal mines in Texas

The currently active Eagle Pass mine could be an appropriate tire disposal 

site once it begins reclamation works for Del Rio and Eagle Pass cities which 

currently only posses a type 1 landfill for local waste tire disposal.

9.6.1.2 Coal Mining in the State of Coahuila, Mexico

The coal mining industry and the variability of its activity have played a 

decisive role in the structuring and regional evolution of the central-eastern and 

northeastern areas of Coahuila state. The dependence of this region on mining 

exploitation in the absence of other economic activities that constitute real 

development alternatives, have made this region become vulnerable because of its 

geographical impact due to overexploitation of coal in open pit mines.

5.- (Rachal Mine) Farco Mining, Inc. [R]

13.- (Palafox Mine) Farco Mining, Inc. [R]

14.- (Eagle Pass Mine) Dos Repúblicas Coal Partnership

15.- (Treviño Mine) Farco Mining, Inc. [R]
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In 2010 State of Coahuila participated with 5.86% mining national 

production, occupying the first place in coal, iron and magnesium sulfate production. 

Coahuila is the Mexican state with more production of coal.

Mining in Coahuila started in 1828 by extracting coal in mines. The 

overexploitation of coal deposits in Coahuila began in the Sabinas basin to serve the 

steel industry of Piedras Negras, Monclova and Monterrey. Coal exploitation was 

subsequently extended to Fuentes-Río Escondido Basin as a result of the need to 

supply fuel to Río Escondido and Carbon II power plants.

Figure 9.4.

State of Coahuila, Mexico coal basins

The coal extracted from Coahuila open pit mines is Bituminous and has a 

total carbon concentration range of 69-86% as well as high sulfur and ashes 

content, so according to international standards, it is considered of poor quality, due 

to having a high polluting potential, before and after being extracted, as well as 

during its use.

As it was previously mentioned on the LRPUT description current Mexican 

legislation doesn’t allow the final disposal of special handling wastes on sites unless 

they comply with the standard NOM-083-SEMARNAT-2003. 

Kilometers

I.-FUENTES- RIO ESCONDIDO BASIN

II.-SABINAS-MONCLOVA BASIN

SUB BASINS 

CRETACIC BASINS TERTIARY BASIN

III.- COLOMBIA-SAN IGNACIO BASIN

STATE LIMIT

CAPITAL CITY

MUNICIPAL HEAD

Graphical scale
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9.7 Recommendations

The Texas-Mexico border region being of great extent does not present a 

unique disposal alternative for all of its population. Each city should evaluate 

independently which alternative fits its economic and social needs based on the 

presented cost estimations and environmental impacts. Nevertheless all alternatives 

recommended theoretically comply with their local, state and federal regulations and 

are authorized by their corresponding environmental authorities.

By identifying social, environmental and economic impacts in advanced a 

stakeholder:

1. Can make better decisions about which appropriate tire disposal 

alternatives to select, how to proceed; and,

2. Select what mitigation measures can be implemented to minimize the 

harm and maximize the social, environmental and economic benefits.

In IEMS’ opinion each individual community should perform the following 

based on what it’s presented in this document and other sources they consider 

appropriate:

 Decisions need to be deduced from principles, and principles need to be 

derived from core values. Only by first establishing the core values of the 

community of practice, then deriving the principles, and only then 

developing guidelines, can truly appropriate guidelines emerge.

 Guidelines and principles must be developed in participatory processes, 

include the people to whom the guidelines are directed. These are the 

people who ultimately need to develop ‘ownership’ of the guidelines if 

they are to be adopted and be utilized. (Vanclay, SIA principles, 2003)

9.7.1 Appropriate Tire Disposal Alternatives 

Texas international border area appropriate tire disposal alternatives 

currently available:

A. Land Reclamation Projects Using Tires (LRPUT);

B. Type 1 Sanitary Landfills.

LRPUT being an option which does not occupy landfill space and its used 

in a re-habilitation process its more socially and environmentally desirable tire 

disposal alternative than landfills. Although both are considered appropriate by this 

study.
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TCEQ authorized tire transporters and processors which finally dispose of 

waste tires in these alternatives or other TCEQ authorized alternatives located 

further north should also be considered appropriate. This study focus was 

specifically on final disposal alternatives, not including intermediaries.

Mexican side of the Texas-Mexico border:

A. Tire Derived Fuel in Cement Kilns;

B. Sanitary Landfills complying with standard NOM-089-SEMARNAT2003.

The following attachments present information regarding LRPUTs and Type 

1 landfills:

 Attachment 6. Display map of appropriate tire disposal alternatives 

identified in the Texas side of the Texas-Mexico border area.

 Attachment 7. Display map of appropriate tire disposal alternatives 

identified in the Mexican side of the Texas-Mexico border area.

Additional information including:

 List of appropriate tire disposal alternatives identified in the Texas side 

of the Texas-Mexico border area and disposal fees charged at the time 

this study was written.

 Environmental evaluation regarding the disposal of tires in land 

reclamation projects.

 Environmental evaluation regarding tire disposal in a sanitary landfill.

 Approximate driving distances from Texas scope cities to appropriate 

tire disposal sites in the Texas side of the Texas-Mexico border area.

 List of appropriate sites in the Texas side of the Texas-Mexico border 

area and disposal fees charged at the time this study was written. 

 Environmental performance report of using tires as fuel in cement kilns 

both in Mexico and the U.S.A.

 Approximate driving distances from Mexican scope cities to appropriate 

tire disposal sites in the Mexican side of the Texas-Mexico border area.

 Transportations costs to cement kilns available to the Mexican side of 

the Texas-Mexico border area (per city per whole, cut or shredded tire).

Is presented within study Full report attachments for further reference.

9.7.2 Tire Management Recommendations

Waste tires should be cut or shred by generators prior to their 

transportation. From these actions, transportation and disposal benefits can be 

obtained. 
Tire Flow Study in the Texas-Mexico Border Region

Executive Summary

Printed on 100% recycled fiber paper using solid ink 

112

Table 9.2. presents estimated savings obtained when transporting cut tires 

instead of whole tires.

Table 9.2.

Estimated savings when transporting cut tires 

instead of whole

Vehicle Cost/tire/mile Savings*

whole cut

Pickup truck $0.017 $0.010 41%

Pickup with trailer $0.004 $0.003 29%

Box truck $0.003 $0.002 27%

Tractor with 48 foot trailer $0.002 $0.001 38%

*Increasing the gross weight at which a vehicle operates will increase its 

fuel consumption (Coyle, 2007) this increase is not considered when 

estimating the savings.

As Table 9.2. displays important savings may be obtained when 

transporting cut tires instead of whole tires. These savings will be more relevant as 

the hauling distance increases. This savings are obtained because of the increase in 

the number of tires that can be transported. As an example a 48 foot trailer may 

transport approximately 60% more tires if the tires are cut.

Additionally, tire disposal fees are 75% minor when disposing of cut or 

shred waste tires in appropriate disposal sites compared to whole tire disposal fees 

on the same sites. This occurs because sites no longer need to further process 

waste tires in order to landfill or bury them.

9.8 Alternatives Economic Evaluation

As previously mentioned, two main variables affect the disposal cost:

1. Transportation costs

2. Disposal fees

9.8.1 Common Transportation Options 

The purpose of evaluating the different transporting options in this section 

is to aid the reader in choosing the one which better suits his/her needs. Figure 9.5.

presents the cost per tire (whole and cut) per mile employing each type of 

equipment considered for Texas. 
Tire Flow Study in the Texas-Mexico Border Region

Executive Summary

Printed on 100% recycled fiber paper using solid ink 

113

Figure 9.5.

Estimated transportation cost per tire per mile

Based on the results presented on Figure 9.5. it is visible that tractors with 

trailers are the most cost efficient way to transport cut and whole tires, especially on 

large distances. Pickup trucks are the most inefficient in the same way. 

As previously mentioned in Table 9.2., important savings may be obtained 

when transporting cut tires instead of whole tires. These savings will be more 

relevant as the hauling distance increases. This savings are obtained because of 

the increase in the number of tires that can be transported. This increase in the 

number of tires that can be transported per trip is summarized in Table 9.3.

Table 9.3. 

Estimated increase in tires per load capacity when 

transporting cut tires instead of whole.

Vehicle PTE / load Load capacity 

whole cut estimated increase

Pickup truck 50 85 70%

Pickup with trailer 250 350 40%

Box truck 400 550 38%

Tractor with 48 foot trailer 1400 2250 61%
Tire Flow Study in the Texas-Mexico Border Region

Executive Summary

Printed on 100% recycled fiber paper using solid ink 

114

It is worth mentioning that cost efficiency when transporting shredded tires 

on the mentioned vehicles and equipment would not further increase since their 

maximum payload capacity is already reached when transporting cut tires.

9.9 Disposal Fees per Tire

Disposal costs per tire are presented separately for the Texas and Mexican 

sides of the border.

9.9.1 Texas Side of the Border

A full list of costs for appropriate tire disposal alternatives identified in the 

Texas side of the Texas-Mexico border area and disposal fees charged at the time 

this study was written is presented on Attachment 44 of the study Full report.

Since the tire disposal in reclamation of depleted open pit coal mines sites 

alternative is not currently being applied there is no available data regarding 

disposal fees that could be charged by the site owner. It could be presumed that 

fees would be similar to the ones charged on LRPUT currently working on the 

border area.

9.9.2 Mexico’s Side of the Border

A full list of costs for appropriate tire disposal alternatives identified in the 

Mexican side of the Texas-Mexico border area and disposal fees charged at the 

time this study was written is presented on Attachment 49 of the study Full report.
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 1

Ultimate disposal locations of 

waste tires that are being 

transported from Texas into 

Mexico
Tire Flow Study in the Texas-Mexico Border Region

Attachment 1

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border 

area

General Data

Accumulated 

waste tires 

(tires) 

Directions to the site

site's coordinates 

(UTM, Datum WGS84) Elevation

Id 

# Municipality State Zone X Y (FASL) (MASL)

1 Matamoros Tamaulipas 2,250,000

"Ejido of Guadalupe". 

Road to Reynosa Km 11.5 (7.15 

miles)

14 642436 2866898 33 10

2 Rio Bravo Tamaulipas 32,000

Taking federal highway 2 (ReynosaMatamoros) turn right 4.17 km (2.59 

miles) after "Camioneta Tahoe" road. 

Cross a ditch and continue 3.45km 

(2.14 miles), turn right and continue 

400m (0.25 miles)

14 598665 2868165 89 27

3 Reynosa Tamaulipas 200,000

Open air dump "Las Anacuas". 

Taking the Reynosa-San Fernando 

road, turn right on "Beatriz Velazco" 

(or "Puerto Escondido"), then turn left 

on "Prolongacion Boulevard Loma 

Bonita", continue 1.42Km (0.89 

miles), the road will turn right, 

continue 1.17Km (0.72 miles) and the 

disposal site is located on the right 

side of the road.

14 568689 2876212 194 59

4 Reynosa* Tamaulipas* 50,000* Open air dump "Las Calabazas"* 14* Unknown* Unknown* Unknown* Unknown*

5 Reynosa* Tamaulipas* 50,000*

Open air dump "Corrales"* UTM 

coordinates point an approximate 

location.

14* 575974.53* 2882372.51* 0* 0*
Tire Flow Study in the Texas-Mexico Border Region

Attachment 1

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border 

area

General Data

Accumulated 

waste tires 

(tires) 

Directions to the site

site's coordinates 

(UTM, Datum WGS84) Elevation

Id 

# Municipality State Zone X Y (FASL) (MASL)

6 Reynosa* Tamaulipas* 50,000* Open air dump "Cumbres"* 14* Unknown* Unknown* Unknown* Unknown*

7 Reynosa* Tamaulipas* 50,000* "Las Colmenas" Landfill* 14* Unknown* Unknown* Unknown* Unknown*

8 Reynosa* Tamaulipas* 50,000* "Alto Bonito" Landfill* 14* Unknown* Unknown* Unknown* Unknown*

9 Reynosa Tamaulipas 200

Km 187.5 (116.5 miles) MonterreyReynosa road. UTM coordinates 

point an approximate location.

14 558979 2880564 263 80

10 Gustavo Dias 

Ordaz Tamaulipas Unknown 

4Km (2.48 miles) taking the road to 

Monterrey from Gustavo Diaz Ordaz 

city.

14 541240 2897625 125 38

11 Camargo Tamaulipas 800

"Las Flores" colony municipal yards. 

Entering Camargo city from Reynosa 

turn right on "Acceso No. 4” Drive 

750 meters (0.465 miles) then turn 

left. Continue one block to arrive to 

the municipal grounds. UTM 

coordinates point an approximate 

location.

14 518635 2910553 164 50

12 Miguel Aleman Tamaulipas 3,000

Located on the "5 de Junio" overpass 

in "Rodriguez" colony. UTM 

coordinates point an approximate 

location.

14 496410 2920211 0 0
Tire Flow Study in the Texas-Mexico Border Region

Attachment 1

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border 

area

General Data

Accumulated 

waste tires 

(tires) 

Directions to the site

site's coordinates 

(UTM, Datum WGS84) Elevation

Id 

# Municipality State Zone X Y (FASL) (MASL)

13 Guerrero Tamaulipas 200

"General Lazaro Cardenaz" street 

corner with "Adrian Gonzalez 

Gonzalez". Take "Avenida Hermanos 

Gutierrez de Lara" towards the city 

center, turn left on "sexta", and 

continue 3 blocks west. Behind the 

city's cemetery.

14 475931 2938002 325 99

14 Nuevo Laredo Tamaulipas

Unknown, site 

was remediated 

on year 2012 

Integral center for the handling of 

waste tires. Located on Km 18 (11.2 

miles) of national highway Mexico 85. 

Take Nuevo Laredo-Sabinas Hidalgo 

road (Mexico 85) continue 11.88km 

(7.38 miles) starting from the corner 

with "Luis Donaldo Colosio" 

boulevard, then turn left and continue 

1.5 km (0.96 miles) towards east.

14 443827 3022773 446 136

15 Anahuac Nuevo Leon 13,000

6.5 Km (4 miles) from the city center 

on the Anahuac-Nuevo Laredo road, 

on the left side.

14 392412.45 3016770 686 209

16 Cerralvo* Nuevo 

Leon* 200* Not available* 14* 445886* 2888049* Unknown* Unknown*

17 Cerralvo* Nuevo 

Leon* Unknown* Not available* 14* 442743* 2888198* Unknown* Unknown*
Tire Flow Study in the Texas-Mexico Border Region

Attachment 1

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border 

area

General Data

Accumulated 

waste tires 

(tires) 

Directions to the site

site's coordinates 

(UTM, Datum WGS84) Elevation

Id 

# Municipality State Zone X Y (FASL) (MASL)

18 Cerralvo* Nuevo 

Leon* Unknown* Not available* 14* 442709* 2888207* Unknown* Unknown*

19 Cerralvo* Nuevo 

Leon* 1,500* Not available* 14* 442706* 2888060* Unknown* Unknown*

20 Sabinas 

Hidalgo*

Nuevo 

Leon* 8,000* Not available* 14* 384468* 2926343* Unknown* Unknown*

21 Los Aldamas* Nuevo 

Leon* 230* Not available* 14* 480135* 2881301* Unknown* Unknown*

22 Los Aldamas* Nuevo 

Leon* Unknown* Not available* 14* 480115* 2881384* Unknown* Unknown*

23 Los Aldamas* Nuevo 

Leon* Unknown* Not available* 14* 480099* 2881301* Unknown* Unknown*

24 General Bravo* Nuevo 

Leon* 450* Not available* 14* 481032* 2846332* Unknown* Unknown*

25 General Bravo* Nuevo 

Leon* Unknown* Not available* 14* 480653* 2846462* Unknown* Unknown*

26 General Bravo* Nuevo 

Leon* Unknown* Not available* 14* 481099* 2846526* Unknown* Unknown*

27 General Bravo* Nuevo 

Leon* Unknown* Not available* 14* 480626* 2846671* Unknown* Unknown*

28 Vallecillo* Nuevo 

Leon* 65* Not available* 14* 402210* 2948724* Unknown* Unknown*

29 Vallecillo* Nuevo 

Leon* Unknown* Not available* 14* 402182* 2948764* Unknown* Unknown*
Tire Flow Study in the Texas-Mexico Border Region

Attachment 1

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border 

area

General Data

Accumulated 

waste tires 

(tires) 

Directions to the site

site's coordinates 

(UTM, Datum WGS84) Elevation

Id 

# Municipality State Zone X Y (FASL) (MASL)

30 Vallecillo* Nuevo 

Leon* Unknown* Not available* 14* 402393* 2948827* Unknown* Unknown*

31 Acuña Coahuila 200,000

Acuña-Santa Eulalia road 7.18km 

(4.46miles) from the "Emilio 

Mendoza Cisneros" overpass.

14 299864 3245347 1085 330

32 Piedras Negras Coahuila 115,500

Taking the Piedras Negras-Acuña 

road (Federal 2), turn right 7.5km 

(4.64miles) after the "Manuel Perez 

Trevino" overpass and drive north 

800m (0.5miles).

14 345497 3182226 833 254

33 Nava Coahuila 1,000 Progreso street, 2km (1.24 miles) 

west of downtown Nava. 14 328493 3143850 1049 321

34 Ojinaga Chihuahua 50,000

Taking the Chihuahua freeway turn 

right 8.4km (5.23 miles) after 

crossing the overpass with the road 

to Camargo (Avenida de la 

Juventud). The site is located 

100meters (328 feet) from the 

freeway.

13 548717 3269389 2684 818
Tire Flow Study in the Texas-Mexico Border Region

Attachment 1

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Ultimate disposal locations of waste tires that are being transported from Texas into Mexico on the Texas-Mexico border 

area

General Data

Accumulated 

waste tires 

(tires) 

Directions to the site

site's coordinates 

(UTM, Datum WGS84) Elevation

Id 

# Municipality State Zone X Y (FASL) (MASL)

35 Juarez Chihuahua 2,500,000

Located at km 27.5 (17 miles) of the 

Panamerican freeway (Mexico 45). 

Taking Mexico 45 towards the south 

turn right 6Km (3.72 miles) after 

crossing Federal 2 freeway, finally 

continue 1.5 km (0.93 miles) towards 

the west.

13 358959 3492229 4065 1239

36 Matamoros Tamaulipas 400,000

Federal Freeway number 101, Km. 

21 (75.2 miles) without number, turn 

right and follow the road 1.54Km 

(0.96 miles)

14 641485 2843741 23 7

* Means data was not confirmed with a key stakeholder, it is presented as it was obtained from previous tire pile inventories mentioned on Chapter 3 and public 

Geographical Information Systems.

Tire sites 16 to 30 are not located within the study's selected search area but are located within 100km from the Texas-Mexico border.

MASL = meters above sea level. FASL = feet above sea level
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 2

Operation and management 

procedures of each waste tires 

accumulation site of the Mexican 

side of the Texas-Mexico border 

area
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

1 Matamoros Tamaulipas 2,250,000 Municipal 

government

Municipal 

Waste Tires 

Collection 

Center

All waste tires collected in 

the cleaning of drainage 

ditches, junk collection 

programs, incidentally 

collected by garbage 

trucks, disposed by 

factories, among other 

sources used to be taken 

to this collection and 

storage center by the 

municipal authorities. Site 

is currently not receiving 

waste tires, they are being 

sent to the landfill waste 

tire storage center.

Tires are sent to a cement 

kiln to be used as Tire 

Derived Fuel (TDF) in the 

city of Monterrey, state of 

Nuevo Leon, Mexico. 32,000 

waste tires were sent on the 

year 2011. 

Active

2 Rio Bravo Tamaulipas 32,000 Municipal 

government

Municipal 

Landfill and 

waste tires 

storage center

Waste tires are collected 

by the municipal 

government employees 

from people's homes and 

taken to the storage 

center. 

Non Active

3 Reynosa Tamaulipas 200,000 Municipal 

government

City open-air 

dump.

Municipal employees 

collect the waste tires 

throughout the city and 

leave them in the open air 

dump. 

On 2010 nearly 800,000 

waste tires were burned in a 

fire. 

Active
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

4 Reynosa * Tamaulipas* 50,000* Unknown*

Open air dump 

"Las 

Calabazas"*

Unknown* Unknown* Active*

5 Reynosa * Tamaulipas* 50,000* Unknown* Open air dump 

"Corrales"* Unknown* Unknown* Active*

6 Reynosa * Tamaulipas* 50,000* Unknown* Open air dump 

"Cumbres"* Unknown* Unknown* Active*

7 Reynosa * Tamaulipas* 50,000* Unknown* "Las Colmenas" 

Landfill* Unknown* Unknown* Active*

8 Reynosa * Tamaulipas* 50,000* Unknown* "Alto Bonito" 

Landfill* Unknown* Unknown* Active*

9 Reynosa Tamaulipas 200

Private 

company: 

RECO de 

Reynosa S.A. 

de C.V.

Private landfill.

Waste tires generated by 

their own vehicles or 

accidentally introduced 

into garbage collecting 

trucks.

Waste tires are used within 

the landfill to delineate 

roads, to create planters and 

when 100 waste tires are 

accumulated they are used 

as daily cell base. 

Inactive

10 Gustavo Dias 

Ordaz Tamaulipas Unknown Municipal government Open air dump.

Waste tires are taken and 

dumped into the municipal 

open air dump. 

Waste tires are burned as 

they arrive to the municipal 

open air dump. 

Active
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

11 Camargo Tamaulipas 800 Municipal 

government

Municipal 

Waste Tires 

Collection 

Center

Tires are collected and 

stored were the municipal 

junk yard was located 

waiting to be processed. 

Non Active

12 Miguel Aleman Tamaulipas 3,000 Municipal 

government

Provisional 

Municipal 

Waste Tires 

Collection 

Center

Tires are collected and 

stored on the municipal 

fair grounds. 

During a period of time 

waste tires were sent to 

Nuevo Laredo for their 

handling. Actually they are 

stored waiting for disposal 

due to a lack of budget. 

Active

13 Guerrero Tamaulipas 200 Municipal 

government

Municipal openair dump

Tires are collected and 

sent to the open air 

municipal dump. 

The Mexican armed forces 

use them as barricades. Also 

400 waste tires were lost 

during a fire. 

Active

14 Nuevo Laredo Tamaulipas

Unknown, during 

year 2012 site was 

remediated

Municipal 

government Storage center

Waste tires are collected 

on 5 mobile collection 

centers by the 

environmental municipal 

authority, taken to the 

storage center where they 

are counted.

Waste tires are shredded 

and sent to the city of Ramos 

Arizpe in the state of 

Coahuila, Mexico to be used 

as Tire Derived Fuel (TDF) in 

a cement kiln. 300,000 waste 

tires were burned during a 

fire in August 2011. 

Active
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

15 Anahuac Nuevo Leon 13,000 Municipal 

government

Municipal 

Landfill

Tires are collected by the 

municipal authorities from 

tire repair shop and stored 

in a storage center 

adjacent to the city landfill. 

Also the inhabitants 

dispose of their waste tires 

on said location.

Waste tires are sent to the 

city of Monterrey in the state 

of Nuevo Leon, Mexico were 

they are shredded and used 

as Tire Derived Fuel (TDF) in 

cement Kilns or sent to a 

state managed landfill.

Active

16 Cerralvo* Nuevo 

Leon* 200* Not available* Unknown* Unknown* Unknown* Inactive*

17 Cerralvo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

18 Cerralvo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

19 Cerralvo* Nuevo 

Leon* 1,500* Not available* Unknown* Unknown* Unknown* Inactive*

20 Sabinas Hidalgo* Nuevo 

Leon* 8,000* Not available* Unknown* Unknown* Unknown* Active*

21 Los Aldamas* Nuevo 

Leon* 230* Not available* Unknown* Unknown* Unknown* Inactive*

22 Los Aldamas* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

23 Los Aldamas* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

24 Gral. Bravo* Nuevo 

Leon* 450* Not available* Unknown* Unknown* Unknown* Active*

25 Gral. Bravo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

26 Gral. Bravo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

27 Gral. Bravo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

28 Vallecillo* Nuevo 

Leon* 65* Not available* Unknown* Unknown* Unknown* Inactive*

29 Vallecillo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

30 Vallecillo* Nuevo 

Leon* Unknown* Not available* Unknown* Unknown* Unknown* Unknown*

31 Acuña Coahuila 200,000 Municipal 

government

Municipal 

Landfill

Waste tires are taken to 

collection centers by tire 

repair shops personnel 

and by regular people 

motivated by different 

education campaigns. 

Then taken to a storage 

center by the Ecology 

municipal authorities. 

Non Active
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

32 Piedras Negras Coahuila 115,500

Promotora 

Ambiental S.A. 

De C.V.

Private landfill.

The municipal Ecology 

and Urban Image 

department picks up the 

tires throughout the city 

and takes them to the 

private company landfill.

Tires are shredded and 

buried in an exclusive cell. 

Also waste tires were 

transported, by train, to the 

city of Torreon, state of 

Coahuila, Mexico for their 

handling.

Active

33 Nava Coahuila 1,000 Municipal 

government Storage center

Tires are collected from 

tire repair shops by 

municipal workers and 

accumulated in a storage 

center adjacent to the 

municipal landfill waiting 

for an adequate disposal. 

Inhabitants also take there 

their waste tires. 

Non Active

34 Ojinaga Chihuahua 50,000 Municipal 

government Storage center

Tires are collected from 

tire repair shops by 

municipal public services 

workers and accumulated 

in a storage center 

adjacent to the municipal 

landfill waiting for an 

adequate disposal. 

Non Active
Tire Flow Study in the Texas-Mexico Border Region

Attachment 2

Printed on 100% recycled fiber paper using solid ink 

Table 1.

Operation and management procedures of each waste tires accumulation site of the Mexican side of the Texas-Mexico border 

area

General Data

Number of waste 

tires accumulated

Operation and management procedures 

Id 

# Municipality State

Responsible 

of the site's 

management

Type of site Waste tires inflow 

source 

Waste tires outflow 

destiny Status

35 Juarez Chihuahua 2,500,000 Municipal 

government Storage center

Tires are accumulated in 

a storage center adjacent 

to the municipal landfill. 

Tires are sent to a cement 

kiln to be used as Tire 

Derived Fuel (TDF). 

Active

36 Matamoros Tamaulipas 400,000 Municipal 

government

Municipal 

landfill waste 

tire storage 

center

Waste tires collected in 

the cleaning of drainage 

ditches, junk collection 

programs, incidentally 

collected by garbage 

trucks, disposed by 

factories, among other 

sources are taken to the 

collection and storage 

center by the municipal 

authorities. 

Tires are cut in four pieces 

by a machine. Then the 

pieces are accumulated.

Active

* Means data was not confirmed with a key stakeholder, it is presented as it was obtained from previous tire pile inventories mentioned on section 2.0.1 of the Chapter 3.

Tire sites 16 to 30 are not located within the study's selected search area but are located within 100km from the Texas-Mexico border.

The information presented on this attachment was obtained through remote interviews with the key stakeholders mentioned on Attachment 1.
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 3

Ultimate disposal locations map 

of waste tires being transported 

from Texas into Mexico
N

CLIENT.

TITLE. PROJECT.

LOCATION.

DATE.

DRAWN BY.

SCALE.

CHECK.

34

15

4

2

5 6

7

8

31

32

14

3

11 12

19

20

33

26

25

27

23 22

17

18

29

30 10

9

24

21

16

13 28

 Ultimate 

 disposal locations 

N A D B Texas-Mexico 

Border Region

432.01 1 / 02 / 2012

E s te b a n Ib a rra

1:5'900,000

MK

RV

>1’000,000

100,000 - 1 ́000,000 500 - 9,999 <500 Non 

significant

Quantity 

unknown

Approximate amount of waste tires per pile:

1,14,34,33, 29,24.

Site ́s Identification 

Numbers

The color of the Id. number depends on 

the approximate amount of waste tires in 

the pile.

10,000 - 99,999

36

35

1

AUTH.
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 4

Waste tire sites display map per 

Mexican city
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Ciudad Juarez

sites display map.

Ciudad Juarez

Chihuahua, Mexico.

0 5 km

Graphic

35
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Ojinaga

sites display map.

Ojinaga

Chihuahua, Mexico.

0 2 km

Graphic

34
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B Marcel Lopez

EI

RV

Acuña

sites display map.

Acuña

Coahuila, Mexico.

0 2 km

Graphic

31
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Piedras Negras

sites display map.

Piedras Negras

Coahuila, Mexico.

0 6 km

Graphic

32
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Nava

sites display map.

Nava

Coahuila, Mexico.

0 1 km

Graphic

33
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Anahuac

sites display map.

Anahuac

Nuevo Leon, 

Mexico.

Marcel Lopez

0 1.5 km

Graphic

15
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Nuevo Laredo

sites display map.

Nuevo Laredo

Tamaulipas, Mexico.

0 4 km

Graphic

14
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Nueva Cd. 

Guerrero

sites display map.

Nueva Cd. Guerrero

Tamaulipas, Mexico.

0 1.5 km

Graphic

13
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

 

Miguel Aleman

sites display map.

Miguel Aleman

Tamaulipas, Mexico. Marcel Lopez

0 1.5 km

Graphic

12
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Camargo

sites display map.

Camargo

Tamaulipas, Mexico.

0 2 km

Graphic

11
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Gustavo Diaz Ordaz

sites display map.

Gustavo Diaz Ordaz

Tamaulipas, Mexico.

0 1 km

Graphic

10
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Reynosa

sites display map.

Reynosa

Tamaulipas, Mexico.

0 6 km

Graphic

3

5

9
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

Rio Bravo

sites display map. 432.01 23/08/2012

N A D B

Rio Bravo

Tamaulipas, Mexico.

Marcel Lopez

EI

RV

0 2 km

Graphic

2
TITLE PROJECT DATE

CUENT. LOCATION. DRAWN BY.

SCALE.

CHECK.

APRP

N

432.01 23/08/2012

N A D B

EI

RV

Marcel Lopez

 

Matamoros

sites display map.

Matamoros

Tamaulipas, Mexico.

0 6 km

Graphic

1

36
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 5 

Crackdown on Illegal Dumping - 

Handbook for Local Government
45

Crackdown on Illegal Dumping - Handbook for Local Government 37

4.0 ILLEGAL DUMPING PREVENTION TECHNIQUES

When researchers at University College London studied 

the opportunities that give rise to illegal dumping 

they found that conventional enforcement tactics can 

sometimes reduce the activity quickly but the effects 

soon fade without additional preventive measures. 

Whereas well-designed and well-focused illegal 

dumping prevention programs can have a substantial 

and long-term impact on illegal dumping.12

Which techniques councils choose to adopt will depend 

on the analysis of existing data and information. 

Importantly, the decision must focus on the mechanism 

most suited to the problem, for example, increase 

the effort or reduce the rewards, before going on to 

select the particular technique that’s most likely to 

trigger it. Too often practitioners jump to the technique 

before thinking through how it is supposed to work 

and whether this is likely in the circumstances of the 

particular problem.

You will then need to monitor how it is done and the 

outcome to identify the need for any further intervention. 

This may involve refining the initial response, or if 

necessary trying something completely different. 

It may also be necessary to keep an eye on newly 

emerging problems so that they can be dealt with as 

quickly as possible. Where appropriate, a combination 

of mechanisms, if used strategically, can often be more 

effective.12

Figure 17 summarises the techniques you can use to 

tackle illegal dumping.

4.1 Increase the effort: make 

access difficult

In most cases illegal dumping takes very little effort. 

It can take more effort to dispose of waste legally than 

to dump it illegally. Councils can change the balance to 

make it easier to comply with the law and make it harder 

to not do so. Many areas continue to experience illegal 

dumping problems after being cleaned up. Effective 

structural solutions will increase the effort and risk of 

being caught thereby deterring offenders. Structural 

solutions can reduce accessibility to popular sites for 

illegal dumping.12 A clean up plus introducing signs, 

lighting, barriers, landscaping or increasing the visibility 

of a site can contribute to reducing or eliminating 

continued dumping.

Structural approaches

Councils across NSW have used the following structural 

approaches, usually combined with a mix of education 

and regulation.

Lighting

When lighting is used in other crime prevention 

strategies it can be an effective deterrent in poorly lit 

or remote areas. This may be useful where dumping 

occurs under the cover of darkness. Additional lighting 

increases the visibility of the offender and increases the 

risk of being caught. The impact of sensor lights has yet 

to be evaluated. 

Solar lights in 

hotspots

City of Canada Bay Council installed solar 

lights and signs in a dumping hot spot. 

Outcome

The enhanced lighting has deterred 

dumping in the area and resulted in fewer 

complaints to the council. Anecdotal 

opinion is that other known dumping areas 

near this hot spot are also experiencing less 

illegal dumping.
45

38 Crackdown on Illegal Dumping - Handbook for Local Government

Figure 17: The five main illegal dumping prevention mechanisms

1. Increase the effort: make access difficult (see Section 4.1)

Make access difficult to hot spots using structural approaches, such as:

• lighting

• landscaping, revegetation or beautification

• barriers, such as fences and locked gates, concrete blocks, logs and boulders and earth mounds.

2. Increase the risk of getting caught (see Section 4.2)

Strengthen surveillance:

• use surveillance cameras and signs to indicate the area is being watched

• increase patrols in hot spots

• assist community surveillance and reporting of suspect activities

• use aerial surveillance in rural and remote areas.

Carry out periodic, high-profile compliance campaigns.

Use partnerships with other councils, agencies and stakeholders.

Publicise successes as widely as possible.

3. Reduce the rewards: deny financial benefits (see Section 4.3)

Provide and/or promote free or subsidised waste services.

Issue fines to offenders.

Require offenders to clean up.

4. Reduce provocations: don’t give them a reason to dump (see Section 4.4)

Provide efficient and well communicated waste services.

Ensure reasonable waste service costs where possible.

Foster community pride by enhancing the area’s aesthetic appeal.

Keep areas free of illegally dumped material.

5. Remove excuses: educate and inform the community (see Section 4.5)

Publicise waste services.

Carry out education programs outlining responsibilities.

Keep areas free of illegally dumped material.

Install signs at hot spots with illegal dumping prevention messages. 

It is crucial to alter the perceived as well as the actual degree of effort, risk and reward involved.12
































45

Crackdown on Illegal Dumping - Handbook for Local Government 39

Landscaping, revegetation and 

beautification

Landscaping and revegetating a site can indicate it is 

valued, monitored and used. Simple landscape activities, 

such as grass cutting and weed removal, can be enough 

in some areas to suggest that a site is cared for and 

maintained, which will deter some of the nuisance 

dumping offenders.

Beautification, such as benches, pathways, picnic tables, 

murals or flowerbeds, can change a community’s 

perception of a site. Many communities will get involved 

in and take part in projects that build community pride 

and can lead to changed perceptions and increased 

community surveillance, which all contribute to 

increasing the risk for people illegally dumping. 

Barriers

Physical barricades that restrict access are very effective 

for reducing dumping in areas with a single point of 

entry, such as lanes, fire trails and private roads. Fences, 

posts, earth mounds, bollards and rocks have all been 

used to prevent vehicle access. Each site is unique and 

therefore deterrents need to be carefully managed and 

planned. On some sites a single barrier blocking access is 

all that is required. In some cases offenders may be able to 

continue to dump over a barrier, but this increases the risk 

of being caught and may deter the majority of offenders. 

Councils used funding from the 2002-2004 Illegal 

Dumping Clean-up and Deterrence Grants to build a 

range of physical barriers with varying success. They 

reported that some sites were difficult to enclose. 

Beautification: Woollahra Municipal Council’s ‘Liveable Lanes’ project

Woollahra Municipal Council’s ‘Liveable Lanes’ project was designed to change its community’s perception 

of back lanes as a dumping ground. The council was committed to beautify and improve the look and feel 

of the area to increase community pride and, therefore, reduce the incidence of illegal dumping. It used 

a 2002-2004 Illegal Dumping Clean-up and Deterrence grant to clean up dumping hot spots, landscape 

them and carry out an education campaign to deter future dumping. Minor capital works in the area 

complemented the educational component.

The council developed its project in an attempt to keep sites clean long after the campaign had finished. 

A second part of the project focused on a reserve that experienced persistent dumping. It used landscaping 

works, including new plants for garden beds, to improve the aesthetics of the area and detract dumpers. 

The new plants were selected to make it difficult to hide bags and other dumped rubbish, as was previously

the case. Plants were widely dispersed so that the garden is more open to deter other anti-social behaviours. 

The council also built a retaining wall to stop bins being dragged through, presented and stored in the 

garden area. 

Woollahra Municipal Council attributes the success of its project to a multidisciplinary team of council 

staff, including team members from communications, waste section, compliance, outdoor works and 

management, who collaborated and brought together areas of the project according to their expertise. 

A broader, more strategic prevention program can bring in representation from much wider sections of 

council asking for comments on program design, use and evaluation. The project is also a good example 

of community participation where the council values the community as a partner.

Outcome

The enhancement of the Oswald Street Reserve has provided the most positive results in improved 

environment. Dumps in this area have decreased and been maintained over a five-month period. 
45

40 Crackdown on Illegal Dumping - Handbook for Local Government

Fences and locked gates 

Many councils used illegal dumping clean up and 

deterrence grants of 2002-2004 to install fences

and locked gates. 

Some councils indicated that new gates and locks were 

vandalised almost immediately after installation. Locks 

were tampered with or gates and fences broken down. 

For some dumpers, locked gates “just seem to be an 

invitation to become a vandal as well”. Often there was no 

real alternative to fences and gates and so many councils 

need to consider vandalism in project planning as either 

programmed maintenance scheduled for a period of time 

or as the additional cost of vandal-resistant materials.

At a number of sites vandal-resistant locks, locking 

bollards and almost indestructible fence materials have 

been carefully selected. 

Concrete blocks 

A number of councils reported using concrete blocks 

to barricade entry to a site. This was described as a 

‘relatively cheap, inexpensive and effective option’. 

For many residents though the blocks are unsightly, 

do not fit in with the natural environment and may 

incur complaints to council. Some sites had experienced 

graffiti soon after installing the blocks. 

Fences to protect 

rural hotspots

Maitland City Council selected a rural 

style fence to restrict vehicle access at 

some rural sites. 

Outcome

It helped reduce illegal dumping on the sites 

and restricted access to a small stockpile area 

for local road reconstruction works. Four of 

the five fenced sites continued to show little 

signs of illegal dumping activity 12 months 

after the project.

Indestructable 

fencing materials

Tharawal Local Aboriginal Land Council (LALC) 

and DECC Parks and Wildlife Division used 

almost indestructible fence materials at a 

remote site in Wedderburn to prevent 4WD and 

commercial vehicles dumping materials. The 

adjoining landholder (industry) donated railway 

track and steel rope, which was used to erect a 

500-metre fence line. 

Outcome

The fence has remained intact and unauthorised 

vehicles have been kept out.
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 6

Display map of appropriate tire 

disposal alternatives identified in 

Texas
300000 500000 700000 310000 510000 710000

300000 500000 700000 310000 510000 710000

3500000 3300000 3100000

3500000 3300000 3100000 2900000

2900000

Land Reclamation Project Using Tires 

(LRPUT)

Land Reclamation Project Using Tires 

(LRPUT) with whole tire burial 

authorized.

Type 1 Sanitary Landfill. 

Symbology

Note: Sites colored according to social and/or environmental performance, being green the most recommended, and red the least recommended 

alternative .Although all are considered appropriate tire disposal alternatives by this study.

Appropriate tire disposal alternatives 

in Texas’ international border area

UTM Coordinates 
Tire Flow Study in the Texas-Mexico Border Region

Attachments

Printed on 100% recycled fiber paper using solid ink 

ATTACHMENT 7

Display map of appropriate tire 

disposal alternatives identified in 

the Mexican side of the TexasMexico Border Area