By: Celerah Hewes, Senior Manager, State Field Campaigns
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency
My name is Celerah Hewes, and I am a mother, as well as a field manager for Moms Clean Air Force, where I work with petrochemical communities across the country. Thank you for the opportunity to give testimony today.
One thing that rings true in the communities Moms Clean Air Force works with is the concern of health impacts for those living near pollution, industrial pollution especially. From Chemical Valley in West Virginia to Cancer Alley in Louisiana, people need protection from harmful air pollution. The Trump-Zeldin EPA proposal would put the health of children and families across the county at risk by removing pyrolysis incineration from the Other Solid Waste Incinerators (OSWI) Rule, resulting in no regulation of this process at all under the Clean Air Act.
Moms Clean Air Force strongly opposes EPA’s misleading proposal to remove pyrolysis incineration from the safeguards of the Clean Air Act. Removing plastics-burning facilities from OSWI would allow these combustors to smother communities with unlimited amounts of harmful pollution. EPA must not allow plastics-burning incinerators to operate without the pollution controls that help safeguard the health of children and communities.
The growing concern of parents and caregivers who are entrusted with protecting the little lungs of children, which are especially vulnerable to pollution, should be the priority of EPA. Living near plastic incinerator facilities can increase the risk of cancer, birth defects, reproductive system damage, developmental issues, cardiovascular problems, respiratory problems, neurological problems, and more. Burning plastics moves the plastics chemicals from the landfill to the air—and directly into children’s lungs.
Wherever pyrolysis plastic waste incinerators are located, the surrounding communities can be exposed to lead, cadmium, mercury, dioxins, benzene, toluene, formaldehyde, vinyl chloride, hydrogen cyanide, particulate matter, among many other toxic chemicals that can impact public health.
As the plastics industry seeks to build dozens or even hundreds of these plastics incinerators in communities throughout the nation—allowing these incinerators to burn plastic trash without any pollution controls, monitoring, or reporting requirements is both reckless and shortsighted.
And the plastic industry’s attempt to rebrand the pyrolysis incineration of plastic waste as “advanced recycling” is misleading and dangerous. This is not recycling—it is a form of plastic burning that produces harmful air pollution, hazardous waste, and toxic pyrolysis oil.
EPA cannot simply remove this class of plastic incinerators from Section 129 of the Clean Air Act. Doing so would eliminate the only pathway to regulate pyrolysis incinerators, leaving families without protection from harmful pollution.
Once again, I urge you not to remove pyrolysis incineration from the Other Solid Waste Incinerators Rule. EPA must not allow plastics-burning incinerators to operate without the pollution controls that help safeguard the health of children and communities.
Thank you.