Date: February 27, 2023
To: Michal Freedhoff, Asst. Administrator for the Office of Chemical Safety and Pollution Prevention
Joseph Goffman, Acting Assistant Administrator for the Office of Air and Radiation
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20004
Dear Ms. Freedhoff and Mr. Goffman:
Last week’s exposé in ProPublica raised concerns for Moms Clean Air Force regarding the EPA’s renewable fuels initiative.
We were disturbed to learn that EPA has quietly inserted plastics pyrolysis incineration into a program designed to fast-track the production of renewable fuels from plants, algae, and other biological sources. As described on the EPA website, “Congress created the renewable fuel standard program to reduce greenhouse gas emissions and expand the nation’s renewable fuels sector while reducing reliance on imported oil.”
While plastic trash is surely ubiquitous, it is disingenuous to call it a renewable resource. Nearly all plastic is made from fossil fuels, and pyrolyzing it produces dioxins, heavy metals, and other hazardous air pollutants as well as greenhouse gas emissions. The resulting plastic-waste oils are heavily contaminated. We ask that the EPA cease including waste plastic as a renewable feedstock in this biofuels program.
Second, Moms Clean Air Force was shocked to learn that EPA would condone exposing the community surrounding the Chevron refinery in Pascagoula to a cancer risk level of 1 in 4. Such exposure presents a grave and unprecedented danger to those living near the facility, which makes jet fuel from the heavily contaminated oil from plastics pyrolysis incineration. We are disappointed by the Biden EPA’s cold-hearted calculation. Pascagoula is a community in which nearly one quarter of the population lives in poverty, and more than half are Black or Brown people. This decision is environmental injustice at its worst. We ask that EPA immediately rescind its approval of the use of plastics-based fuel at the Chevron refinery.
Third, we are surprised by the surreptitious manner in which EPA has buried the plastics-pyrolysis initiative in a program to fast-track renewable energy and biofuels, and disappointed that EPA has redacted the entire basis of its decision on the Chevron facility, calling it “confidential business information.” In the future, we would hope to see greater transparency about how EPA is using taxpayer dollars and about the resulting toxic chemical emissions. It is perplexing that on the same day that the EPA announced $550 million to advance environmental justice, we also learn that—behind the scenes—EPA approved subjecting the Pascagoula community to a 1-in-4 cancer risk from plastics-waste emissions. We understand that 15 other waste projects have been fast-tracked under the biofuels initiative, and we would be interested to learn more about these projects.
We would be grateful for your prompt attention to this matter.
Director, Moms Clean Air Force
Vice President, Environmental Defense Fund
Sen. Thomas R. Carper, Chair, Senate Environment and Public Works Committee
Rep. Frank Pallone, Ranking Member, House Energy and Commerce Committee