By: Lani Wean, West Virginia Field Organizer, Moms Clean Air Force
Date: November 25, 2025
About: EPA’s Proposed Rule for Hazardous Air Pollution from Hazardous Waste Combustors, Docket ID No.: EPA-HQ-OAR-2004-0022
To: U.S. Environmental Protection Agency
Hi, my name is Lani Wean, and I’m the West Virginia Field Organizer at Moms Clean Air Force. I appreciate the opportunity to speak to you all today about the need to strengthen the EPA’s proposed standards for Hazardous Air Pollutants (or HAPs) from Hazardous Waste Combustors. As proposed, these standards fail to protect our nation’s most vulnerable and impacted communities. The proposal puts the health and well-being of millions of people at risk, including those of us who live in West Virginia’s Chemical Valley. I urge the EPA to propose stronger standards for Hazardous Air Pollutants from Hazardous Waste Combustors to ensure the safety and survival of communities across the country.
The hazardous air pollutants released by hazardous waste combustors are known to cause serious health issues such as cancer, neurological, birth and developmental issues, all of which disproportionately harm children, communities of color and families experiencing poverty who have historically lived closer to industrial pollution.
West Virginia is particularly vulnerable to the health risks and climate disasters resulting from the HAPs released by hazardous waste combustors, and additional waste-burning facilities are eyeing our state hungrily for future development. My home county, Kanawha County, is called the ‘Chemical Valley’ due to its dangerous levels of toxic air and water pollution from the concentration of chemical facilities here. We have dozens of schools, playgrounds, healthcare facilities, and neighborhoods all within a few miles from high-risk chemical facilities – many of which have been at the center of major chemical disasters. EPA’s extremely weak proposed standards will put communities like mine in harm’s way. I’ve stood by neighbors who have lost their homes to flooding, or their family members to cancer, or lost their health, or financial stability due to chemical disasters. How can you draft rules that ignore the harm to the residents you claim to represent?
Something I simply cannot fathom from this proposed rule is the complete disregard of the human health consequences of hazardous air pollution. It appears that all EPA cares about is lessening the financial costs for chemical companies. As proposed, the EPA would not require pollution monitoring in communities immediately adjacent to high-polluting facilities, known as fenceline communities; nor would it enforce emissions standards during startup, shutdown, or malfunction at a facility; and absurdly it would restructure the compliance deadlines to 3 years, which it calls ‘as expeditious as practicable.’ Each of these revised standards alone has the potential to dramatically increase exposure to these pollutants for communities like mine. And the compounded effects of these revisions will only exacerbate the harms fenceline communities experience. There is no world in which these revisions could protect human health and well-being.
This review and revision of the standards for hazardous waste combustors is decades overdue. It’s your responsibility to do it right, just like it is mine to speak up for my state and our neighbors who are living on the frontline of this pollution. Moms Clean Air Force strongly opposes EPA’s proposed weak and unprotective Hazardous Air Pollutant emissions rules for Hazardous Waste Combustors. Every child has the right to breathe clean air.