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Resource Library / Plastics and Petrochemicals

Letter to Congress About Federal Plastic Incineration Bill, September 19, 2022

Letter

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Date: September 19, 2022

To: Members of the House and Senate

Dear Senator,

The undersigned 201 environmental, health, science, consumer protection and environmental justice organizations urge you not to sponsor or co-sponsor legislation that supports so-called “advanced recycling” promoted by the American Chemistry Council (ACC) and other plastics industry lobbyists. The ACC seeks to change existing law so that plastics incinerators can operate without meeting the environmental and health protections of the Clean Air Act.

Under the guise of offering a solution to the global plastic waste crisis, the American Chemistry Council has invented an Orwellian new name for decades-old incineration technologies. It seeks to rebrand pyrolysis and gasification incinerators as “advanced recycling,” even though there is nothing advanced about them and nothing gets recycled. In reality, the plastic trash that enters pyrolysis and gasification incinerators gets burned, creating dioxins and other harmful air pollution. What’s left is toxic chemical waste that gets burned again later at hazardous waste disposal facilities or as a dirty fuel. Far from “recycling” the plastic waste they get paid to accept, gasification and pyrolysis incinerators are turning plastic into highly toxic air pollutants and generating hundreds of thousands of pounds of hazardous waste.

For chemical industry lobbyists, the concept of “advanced recycling” is a dream come true. Having an eco-sounding way to make plastic waste vanish from sight helps the industry justify exponential growth in plastics production, which is expected to triple over the next 40 years. Pretending that burning plastic waste in pyrolysis and gasification incinerators is “advanced recycling” offers a way to avoid Clean Air Act requirements and do incineration on-the-cheap without having to invest in pollution controls or bother with air quality monitoring and reporting. Some companies would even become eligible for manufacturing subsidies and tax breaks.

While the plastics industry claims that the process of burning plastic via pyrolysis and gasification meets state and federal environmental standards, the whole point of the “advanced recycling” legislation they are promoting is to allow pyrolysis and gasification incinerators to evade these very protections. If plastic incinerators can avoid being regulated as incinerators, they can escape Clean Air Act requirements altogether and emit as much toxic pollution as they like. Community members will be unable to stop it or even to find out what toxic pollutants they are being exposed to.

Because pyrolysis and gasification incinerators combust solid waste, they are incinerators under the Clean Air Act. The statute requires the same strong protection for pyrolysis and gasification incinerators as it does for all other incinerators – a point EPA recognized almost 30 years ago when it first set emission standards for incinerators under the Clean Air Act. The American Chemistry Council now seeks to exempt pyrolysis and gasification incinerators from air pollution laws by having Congress or EPA declare that these incinerators are not incinerators. To that same end, they may seek to have the EPA declare that plastic waste is not “waste” under the Resource Conservation and Recovery Act. Either of these actions, if taken by Congress or EPA, will remove existing Clean Air Act protections, leaving the incineration of plastic via pyrolysis and gasification entirely unregulated under federal law, at the same time the chemical industry has pushed through legislation in 20 states to relax state-level requirements.

Plastic contains hundreds of toxic chemicals, including heavy metals, phthalates, flame retardants, bisphenol A and PFAS. The process of burning plastic via pyrolysis and gasification generates even more toxic pollution, including chemicals known to cause cancer, birth defects and other serious health harms. Emissions include dioxins, benzene, cadmium, arsenic, lead, polycyclic aromatic hydrocarbons (PAHs) and mercury. Removing existing Clean Air Act limitations on burning plastic will allow chemical manufacturers to produce and release these toxic chemicals into our communities without limitation.

Eliminating these long-standing federal protections will sanction and promote uncontrolled burning of plastic waste – or any other waste – in pyrolysis and gasification incinerators across the country. Most of that uncontrolled incineration will take place in communities of color and in low-income neighborhoods already overburdened by toxic pollution. Changing the legal definition of incineration or waste so that chemical companies can burn plastic in poor and minority communities without controlling the toxic pollution they emit is environmental injustice at its worst.

If chemical manufacturers can operate pyrolysis and gasification facilities in compliance with Clean Air Act protections, as they claim, then why are they fighting to remove these federal health protections? If they cannot meet these basic protections, the last thing Congress should do is exempt them from pollution control laws. It would be unconscionable for any member of Congress to endorse and enable the chemical manufacturers’ plans to evade federal health protections for incinerating plastic, particularly in the face of a global plastic pollution crisis and the projected tripling of plastic waste.

Calling pyrolysis and gasification “advanced recycling” does not change what they are: heavily polluting, inefficient, and energy-intensive means of burning fossil fuel plastics. To the extent they create anything other than air pollution, their product is a form of chemical waste that is burned again later as hazardous waste or dirty industrial fuel – causing yet more air pollution.

This is incompatible with a climate-safe future, and arguably even more deleterious for the planet than burning fossil fuels directly. So-called “advanced recycling” moves the plastics from the landfills to the atmosphere, and into our lungs.

Congress is currently spending significant time and resources grappling with the ongoing PFAS crisis, created and perpetuated by the same industry that now wants Congress and EPA to approve the unlimited burning of PFAS and other plastic waste. We urge you to reject the advances by chemical manufacturers and say “No” when asked to sponsor or co-sponsor legislation to remove existing federal health protections from incineration of plastic.

For more information please contact Daniel Rosenberg, NRDC, at drosenberg@nrdc.org; Jim Pew, Earthjustice, at jpew@earthjustice.org; or Cynthia Palmer, Moms Clean Air Force, at CynthiaPalmerMail@gmail.com.

Sincerely,

Jim Pew
Senior Attorney, Earthjustice

Judith Enck
President, Beyond Plastics

Jane Williams
Executive Director, California Communities Against Toxics

Lisa Ramsden
Senior Oceans Campaigner, Greenpeace USA

Sonya Lunder
Senior Toxics Policy Advisor, Sierra Club

Sarah Packer
Director, Petrochemicals, Plastics & Climate, Center for Environmental Health

Matthew Davis
Senior Director, Government Affairs, League of Conservation Voters

Nick Lapis
Policy Director, Californians Against Waste

Frankie Orona
Executive Director, Society of Native Nations

Bianca Lopez
Co-Founder, Director, Valley Improvement Projects

Daniel Rosenberg
Director of Federal Toxics Policy, Natural Resources Defense Council

Martin Bourque
Executive Director, Ecology Center

Jessica Roff
US / Canada Regional Policy Advocate, Global Alliance for Incinerator Alternatives

Renee Sharp
Strategic Advisor, Safer States

Shannon Smith
Executive Director, FracTracker Alliance

Lori Caughman
Law & Policy Program Manager, New Jersey Environmental Justice Alliance

Caitlin Hart
Senior Manager, Gov’t Relations, Ocean Conservancy

KT Andresky
Campaign Organizer, Breathe Free Detroit

Alison Waliszewski
Policy & Outreach Manager, 5 Gyres Institute

Pamela Miller
Executive Director, Alaska Community Action on Toxics

Sarah Martik
Campaign Director, Center for Coalfield Justice

Mike Belliveau
Founder, Executive Director, Defend Our Health

Logan Welde
Senior Attorney, Clean Air Coalition

Bobbi Wilding
Executive Director, Clean & Healthy New York

Dave Arndt
Director, Locust Point Community Garden

Sam Pearse
Lead Campaigner, Story of Stuff Project

Jennifer Savage
Senior Manager, Plastic Pollution Initiative, Surfrider Foundation

Christy Leavitt
Plastics Campaign Director, Oceana

Dianna Cohen
Co-Founder, CEO, Plastic Pollution Coalition

Alejandra Warren
Executive Director, Plastic Free Future

Teresa Mills
Executive Director, Buckeye Environmental Network

Dominique Browning
Senior Vice President, Moms Clean Air Force

Kathleen Curtis
Founding Director, Moms for a Nontoxic New York

Jan Dell
Founder, Independent Engineer, The Last Beach Cleanup

Jackie Nunez
Founder, The Last Plastic Straw

Morgan Huette
Gulf Program Coordinator, Turtle Island Restoration Network

Ruth Abbe
President, Zero Waste USA

Lynn Hoffman
National Coordinator, Alliance of Mission-Based Recyclers (AMBR)

Laura Simpson
Steering Committee, 350 Humboldt

Elisabeth Bialosky
Youth Campaigns Organizer, 350 New Hampshire

Jane Selden
Co-Chair, WasteNøt/350NYC 350NYC

Janet Nudelman
Senior Director of Program and Policy, Breast Cancer Prevention Partners

Matthew Mehalik
Executive Director, Breathe Project

Lee McNair
Co-Leader, Cedar Lane Environmental Justice Ministry

Blake Kopcho
Senior Oceans Campaigner, Center for Biological Diversity

Dick Green
Principal, DW-GREEN Associates

Lauren Pagel
Policy Director, Earthworks

Michael Garfield
Executive Director, Ecology Center

Stephanie Compton
Organizer, Energy Justice Network

Stephanie Erwin
Director of Circular Economy Policy, American Sustainable Business Network

Marcia Lehman
Board Member, Treasurer, Beaver County Marcellus Awareness Community (BCMAC)

Tom Taylor
Co-Chair, Beaverdam Creek Watershed Watch Group

Jose Luis Aguayo Pozo
Senior Science Associate, Center for Health, Environment & Justice

Trevor Jones
Campaign Manager, Only One

Jane Patton
Campaign Manager for Plastics & Petrochemicals, Center for International Environmental Law

Staci Rubin
Vice President, Environmental Justice Conservation Law Foundation

Alison L Steele
Executive Director, Environmental Health Project

Kathleen Holmay
Team Member, Environmental Ministry Team, Cedar Lane UU Church

Karen Cannon
Executive Director, Envision Frederick County

David Steigerwald
Maryland Legislative Representative, Chesapeake Earth Holders

Sue Y. Lee Mossman
Chair,C limate Action Campaign of the Humboldt Unitarian Universalist Fellowship

Leah Redwood
National Mobilization Hub Volunteer, Extinction Rebellion US

Lisa Frank
Executive Director, Washington Legislative Office, Environment America

Marcie Keever
Oceans & Vessels Program Director, Friends of the Earth

Simrata Keshav
Founder, Go Green Vernon Hills & Lincolnshire

Nicole Cantello
President, AFGE Local 704

Jodie Bechard-Maro
Coordinator, Bristol Residents for Clean Air

Robina Suwol
Executive Director, California Safe Schools

Kathy Bartolomeo
Volunteer, Greenbelt Climate Action Network

Alison Burchell
Board Member, Outreach Co-Director, Colorado Democratic Party - Energy & Environmental Initiative

Tracy Carluccio
Deputy Director, Delaware Riverkeeper Network

Stephen Brittle
President, Don't Waste Arizona

Pat Kelly-Fischer
Board Member, Environmental Action

Yvette Arellano
Executive Director, Fenceline Watch

Jim Walsh
Policy Director, Food & Water Watch

Leatra J Harper
Managing Director, FreshWater Accountability Project

Susan Penner
Co-Chair, Legislative Working Group, 1000 Grandmothers for Future Generations

Nora Privitera
Co-Chair, Federal Climate Team, 350 Bay Area Action

Steph Compton
Organizer, Energy Justice Network

David Nickell
Council Chair, Heartwood

Caleb Merendino
Co-Executive Director, Waterway Advocates

Jamie McConnell
Deputy Director, Women's Voices for the Earth

Brenda Platt
Director, Composting for Community Institute for Local Self-Reliance

Basav Sen
Climate Policy Director, Institute for Policy Studies Climate Policy Program

Mark J. Palmer
Associate Director, International Marine Mammal Project of Earth Island Institute

Dr. Tadesse Amera
Co-Chair, International Pollutants Elimination Network (IPEN)

Kirstie Pecci
Executive Director, Just Zero

Lori Mendez, Esq., MAS-MBC (SIO-2018)
Attorney, Law Offices of Lori R. Mendez

Anne Hedges
Co-Director, Director of Policy, Montana Environmental Information Center

Heather Cantino
Steering Committee Chair, Athens County's Future Action Network

Doris Yen H. Nguyen
Founder, Glen Echo Heights Mobilization

Arlene Blum, Ph.D.
Executive Director, Green Science Policy Institute

Khrystle Bullock
Climate Justice Campaigner, Hip Hop Caucus

Mouli Venkatesan
Independent Analyst

Richard Deutschmann
Facilitator, Climate Action Team Indivisible Howard County MD

Bonnie Brydges
Board Member, Sustainable Practices, LTD

Melissa Jung
Program and Outreach Manager, Inland Ocean Coalition

Lisa Tyson
Director, Long Island Progressive Coalition

Marylee M. Orr
Executive Director, Louisiana Environmental Action Network

Cecilia Plante
Co-Chair, Maryland Legislative Coalition

Jennifer Swearingen
Assistant Director, Montanans Against Toxic Burning

Ashley Funk
Executive Director, Mountain Watershed Association

Elizabeth R. Ndoye
Facilitator, MoveOn.org Hoboken

Sharon Davlin
Board Member, Zero Waste Baltimore

Jennifer Driban
Senior Vice President, Chief Mission Officer, National Aquarium

Erica Donnelly-Greenan
Executive Director, Save Our Shores

Laura Anthony
Program Coordinator, Save the Albatross Coalition

Ted Schettler M.D., M.P.H.
Science Director, Science and Environmental Health Network

Martin Wolf
Director, Sustainability & Authenticity, Seventh Generation

Robert K. Musil, Ph.D., M.P.H.
President & CEO, Rachel Carson Council

Tracy W. Rosenberg
Executive Director, Media Alliance

Cheryl Nenn
Riverkeeper, Milwaukee Riverkeeper

Dana Ripper
Executive Director, Missouri River Bird Observatory

Diana Younts
Co-Chair, MLC Climate Justice Wing

Cari Gardner
Vice Chair, New York Progressive Action Network

Lisa Adamson
Partner, North Country Earth Action

Laura Haight
US Policy Director, Partnership for Policy Integrity

Stiv Wilson
Co-Director, Peak Plastic Foundation

Abigail M. Jones
Vice President of Legal & Policy, PennFuture

Rev. Sandra L. Strauss
Director of Advocacy & Ecumenical Outreach, Pennsylvania Council of Churches

Edward Ketyer, M.D.
President, Physicians for Social Responsibility, Pennsylvania

Carol De Angelo
Director of Office of Peace, Justice and Integrity of Creation, Sisters of Charity of New York

Jack Eidt
Co-Founder, SoCal 350 Climate Action

Martha Camacho Rodriguez
Director, Social Ecological Education-La (SEE)

Robin Schneider
Executive Director, Texas Campaign for the Environment

Christopher Chin
Executive Director, The Center for Oceanic Awareness, Research, and Education (COARE)

Heather Hulton VanTassel
Executive Director, Three Rivers Waterkeeper

Paddy McClelland
Co-Founder, Wall of Women

Chris Wilke
Global Advocacy Manager, Waterkeeper Alliance

Susanne P Kernan
Steering Committee Chair, Rockland Citizens Action Network

Ting Barrow
Steering Committee, Uptown Progressive Action

Iyanu Corniel
Partnerships Director, PLAN: The Post Landfill Action Network

John Beard, Jr.
CEO, Port Arthur Community Action Network

Sarah K. Pierpont
Executive Director, Recycle Santa Fe

James O. Michel
Co-Founder, Resist the Pipeline

Jean Tepperman
Co-Coordinator, Sunflower Alliance

Timothy Edward Duda
Director, Terra Advocati

Josephine Gingerich
Regional Organizer - Appalachia, The Climate Reality Project

Don Ogden
Co-Producer/Co-Host, The Enviro Show

Ruth Kastner
Director, The Quantum Institute

Matt Casale
Environment Campaigns Director, U.S. PIRG

Jin Tanaka
Branch Manager, UNISC International

Selden Prentice
Federal Policy Lead, 350 Seattle

George Povall
Executive Director, All Our Energy

Cheryl Auger
President, Ban SUP (Single Use Plastic)

Katherine Black
Steering Committee Chair, Benicians for a Safe & Healthy Community

Andrew Hinz
Board Member, Beyond Extreme Energy (BXE)

Edna Litten
President, Beyond Plastics, Altamont NY

Jeanine Behr Getz
Founder, Bring Your Own Connecticut

Debby Lee Cohen
Executive Director, Cafeteria Culture

Jenn Engstrom
State Director, CALPIRG

Wes Gillingham
Associate Director, Catskill Mountainkeeper

Crystal Dreisbach
CEO, Don’t Waste Durham

Lee McNair
Board Member, Unitarian Universalist Environmental Justice Ministry

Terry Lowman
Co-Chair, Unitarian Universalists for a Just Economic Community

Fran P. Aguirre
President, Unite North Metro Denver

Jean Ross
Board President, Vote Climate

Laura Olah
National Coordinator, Cease Fire Campaign

Gwen DuBois, MD, MPH
President, Physicians for Social Responsibility, Chesapeake

Rebecca Overmyer-Velazquez
Coordinator, Clean Air Coalition of North Whittier

Beto Lugo Martinez
Kansas Organizer, Clean Air Now

Jesse Marquez
Executive Director, Coalition for a Safe Environment

Joseph Wilson
Coordinator, Coalition for Outreach, Policy & Education

Kate Bailey
Policy Director, Eco-Cycle

Janet Byron
Co-Founder, El Cerrito Strollers & Rollers

Patrick Campbell
Executive Director, Group Against Smog & Pollution

Naomi Yoder
Staff Scientist, Healthy Gulf

Liz Feighner
Steering Committee, HoCo Climate Action

Doug Bender
Steering Committee, Indivisible, South Bay LA

Karen Goodheart
Board Member, It’s Easy Being Green

Liz Feighner
Co-Chair, Less Plastic Please

Jane Dow
Co-Chair, Mankato Zero Waste

Emily Scarr
Director, MDPIRG (Maryland)

Caroline Taylor
Executive Director, Montgomery Countryside Alliance

Barbara W Brandom, MD.
Steering Committee, Concerned Health Professionals of Pennsylvania

Abraham Scarr
Senior Advisor, Environment Illinois

Luke Metzger
Executive Director, Environment Texas

Molly Hauck
Board Member, Environmental Justice Ministry Cedar Lane Unitarian Universalist

Liat Meitzenheimer
President, Fresh Air Vallejo

Katie Craig
State Director, NCPIRG (North Carolina)

Nancy Stoner
President, Potomac Riverkeeper

Allie Rosenbluth
Campaigns Director, Rogue Climate

Diana Conway
President, Safe Healthy Playing Fields

Stephanie A. Blumenthal
President, Sheffield Saves

Diana Zuckerman
President, National Center for Health Research

Lynn Anderson
Treasurer, Youngstown Drinking Water Protection Community Bill of Rights

Sean Mohen
Executive Director, Tri-County Sustainability

Tracy Frisch
Chair, Clean Air Action Network of Glen Falls

Abraham Scarr
Director, ILPIRG (Illinois)

Patricia Albers
Plastics Division, Climate Action California

Martha Camacho-Rodriguez
Director, Social Ecological Education-LA

Marianne Comfort
Justice Coordinator, Sisters of Mercy of the Americas Justice Team

Graham Hamilton
US Policy Officer, Break Free From Plastic

Sister Joan Agro
Congressional Secretary, Sisters of St. Dominic of Blauvelt, NY

Celeste Delgado-Librero
Founder & Chair of the Board Sustainable Roanoke

Rebekah Thomson
Secretary, The Field Fund, Inc.

Gabrielle Rigutto
Environmental Health Researcher, US Berkeley

Alison Burchell
Senior Enviro. & Reclam. Geologist Climate & Energy Policy Advisor, Empower Our Future

Betsy Nicholas
Executive Director, Chesapeake Waterkeepers

Laura Olah
Executive Director, Citizens for Safe Water Around Badger

Timothy Watkins
CEO, Watts Labor Community Action Committee

Amanda Kiger
Executive Director, River Valley Organizing

Brya Ukena
CEO, Recycle Ann Arbor

 

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