By: Melody Reis, Federal Policy Director
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency
Hi, my name is Melody Reis. I’m the Federal Policy Director at Moms Clean Air Force. I appreciate the opportunity to speak with you this morning to express my strong opposition to the proposal to exempt pyrolysis from Section 129 rules.
Section 129 exists specifically to regulate facilities that burn or process waste because of the unique and serious risks posed by these activities. Among the harmful pollutants these facilities emit are dioxins, benzene, formaldehyde, particulate matter, and heavy metals, including mercury and arsenic. Exposure to this pollution has been linked to serious adverse health effects, including cancer, birth defects, and cardiovascular and neurological disorders. Removing pyrolysis from Clean Air Act rules won’t change this reality - it simply removes the guardrails designed to protect the public.
Supporters of this exemption argue that pyrolysis is different from incineration. But that is false, because these facilities are combusting solid waste. And from a community health perspective, semantics aren’t the point. What matters is what is being released into the air. Burning plastic, whether you call it pyrolysis, incineration, or advanced recycling, results in the release of hazardous air pollutants that are dangerous even in small quantities. Congress determined that extra safeguards are needed to protect the public from these activities. And thus, for the past 30 years, EPA has regulated pyrolysis units as solid waste combustors.
Imagine telling a family living next to one of these facilities that strict air pollution controls are no longer necessary because industry lawyers successfully argued that pyrolysis is “not technically incineration.” Could you do that with a straight face?
And speaking of delivering falsehoods with a straight face, I want to briefly address the larger issue of pyrolysis. We all know there’s a plastics crisis. We all see the plastics piling up in our trash cans and recycling bins; we see litter in our communities, our parks, and in our waterways. We need to address the crisis, but not by turning it into air pollution. We need meaningful solutions that actually reduce plastic production, not greenwashing that allows companies to continue business as usual at the expense of our planet and our health.
I urge the EPA to keep pyrolysis facilities subject to Section 129 and, further, to prioritize long-term systemic change and source reduction over false solutions like so-called “advanced recycling.” The health of our communities depends on it. Thank you.