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Resource Library / Plastics and Petrochemicals / Advanced Recycling

Testimony: Kiya Stanford, Removing “Advanced Recycling” From EPA’s Other Solid Waste Incinerators Rule, April 6, 2026

Testimony

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By: Kiya Stanford, Georgia Field Organizer
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency

My name is Kiya Stanford, and I am the Georgia Field Organizer at Moms Clean Air Force. I am from Atlanta, Georgia, and on behalf of Moms Clean Air Force, I strongly oppose EPA’s misleading proposal to remove pyrolysis incineration from the Other Solid Waste Incinerators Rule. Removing these facilities from the rule would allow them to release unlimited amounts of dioxins, lead, and mercury. We know that the plastic burned during this process releases heavy metals and particulate matter that cause cancer and birth defects, and toxins that are especially dangerous to the developing lungs of our children.

Honestly, seeing where these plants are commonly located is deeply personal and incredibly disappointing. As a Black woman who has lived in communities disproportionately exposed to air pollutants, I recognize this pattern all too well. Nexus Circular already operates a plant in Atlanta in a community that is 94% people of color and 44% low income. Their proposed McDonough facility sits in an area that is 75% people of color and 37% low income. When we talk about these facilities exacerbating health outcomes, we are talking about real people in my community who are already at a disadvantage simply because of their zip code. This isn't just a policy shift; it's an environmental justice crisis.

This proposal feels like a move to prioritize polluters over people. It offers the plastics industry a cheap way to make waste "disappear" from sight by spewing it into the air as toxic pollution. Industry lobbyists are counting on this decades-old technology to justify tripling plastics production by midcentury, essentially using our neighborhoods as sacrifice zones to fuel their growth.

EPA must not allow these incinerators to operate without the pollution controls that safeguard our health. I urge you to keep our communities and our children at the center of this decision.

Thank you.

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