By: Barbara Weber, California Field Organizer
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency
Thank you for the opportunity to testify today. My name is Barbara Weber, and I serve as the California Field Organizer for Moms Clean Air Force.
I am here to strongly oppose EPA’s proposal to remove pyrolysis incineration of plastic waste (often misleadingly labeled as “advanced recycling”) from the Other Solid Waste Incinerators (OSWI) Rule.
This proposal is a dangerous rollback of critical public health protections that would allow plastics-burning facilities to operate without the safeguards required under the Clean Air Act. By removing pyrolysis incinerators from Section 129, EPA would effectively grant these facilities a free pass to emit unlimited amounts of toxic pollution into the air our children breathe.
Pyrolysis of plastic waste is not recycling. Full stop. It is a form of plastic incineration. Burning plastic simply shifts the problem from landfills and puts it straight into our atmosphere for children’s developing lungs to breathe. This process produces hazardous air pollutants, including dioxins, benzene, formaldehyde, particulate matter, and heavy metals, such as mercury and arsenic. These same pollutants are linked to cancer, respiratory illness, neurological damage, and developmental harm in children.
We have already seen what happens when communities are faced with these facilities. In Rohnert Park, California, a company proposed a so-called “chemical recycling” plant using a microwave pyrolysis technology just a short distance from a high school. Residents (many of them parents) raised serious concerns about toxic emissions, including benzene and heavy metals, and the risks to children’s health. After months of public outcry, protests, and thousands of comments, the company ultimately withdrew and left the state altogether.
What this example shows is that when communities are informed about pyrolysis, they overwhelmingly reject it. Families do not want these polluting facilities near their homes, schools, or neighborhoods.
Communities living near incineration facilities are often low-income communities and communities of color, and they already bear a disproportionate burden of pollution. Removing pyrolysis from the OSWI Rule would deepen existing environmental injustices by allowing more of these facilities to be built and operated with little to no oversight, monitoring, or emissions controls.
EPA’s proposal also ignores the broader context of the plastic crisis. The U.S. generates more plastic waste per capita than any other country yet recycles only a small fraction of it. Instead of addressing this systemic issue, the plastics industry is promoting pyrolysis as a false solution that enables continued and expanded plastic production while externalizing the health costs onto communities.
This proposal prioritizes polluters over people. It would allow the plastics and petrochemical industries to turn plastic waste into toxic air pollution, exposing families to harmful chemicals without the basic protections guaranteed under the Clean Air Act. There is no alternative regulatory pathway that would adequately control emissions from these facilities if they are removed from Section 129.
As mothers, aunts, caregivers, and residents of this country, we are deeply concerned about what this means for our children’s health and future. The story in Rohnert Park underscores how the burden of ensuring our air remains clean and free from harmful chemicals is placed on families and communities, versus the regulators and government agencies whose very job it is to do just that.
We urge EPA to reject this proposal and uphold its mission to protect public health. Pyrolysis incineration must remain subject to the OSWI Rule and the full protections of the Clean Air Act, including emissions limits, monitoring, and reporting requirements.
Our children deserve clean air and not yet another regulatory loophole that allows toxic pollution to spread unchecked.