By: Rachel Meyer, Ohio River Valley Field Organizer
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency
My name is Rachel Meyer, and I am the Ohio River Valley Field Organizer for Moms Clean Air Force. Thank you for the opportunity to testify.
Moms Clean Air Force strongly opposes EPA’s misleading proposal to remove pyrolysis incineration from the Other Solid Waste Incinerators (OWSI) Rule. Removing the reference to “pyrolysis/combustion units” from the definition of “municipal waste combustion unit” in the OSWI rules is not appropriate. Removing pyrolysis from this rule would allow the dangerous combustion of plastics with no pollution controls and would have a devastating effect on nearby communities. The pollution from these combustors increases the risk of cancers, birth defects, reproductive system damage, developmental issues, cardiovascular problems, respiratory impairment, and neurological problems. Among the most impacted are children.
Because I live near an ethane cracker that produces plastic, I have become acutely aware of the air pollution from the facility and the toxicity of plastic. I worry how both could be impacting my six-year-old daughter’s health. There are more than 16,000 chemicals found in plastics. Over a quarter of these chemicals are known to be toxic while most of the rest, more than 10,000 chemicals, have not even been tested for toxicity and may also be causing harm. As a mother, I’m also concerned about my daughter’s exposure to these chemicals from microplastics which we all breathe and ingest every day. And because plastic waste is piling up all around us, industry has come up with a scheme to visibly make plastic disappear from sight by pyrolysis incineration deceptively branded as “advanced recycling.”
Plastic pyrolysis incineration facilities do not lessen the plastic pollution problem. They take plastic waste and burn it polluting the air with PFAS, dioxins, and other chemicals and creating hazardous waste, and Pyrolysis plastic waste incinerators are hardly turning old plastic into new plastic. According to a study on recycling techniques for common plastics by U.S. Department of Energy scientists, only between 0.1% and 6% of the plastic waste that goes into a pyrolysis facility ends up in new chemicals or plastic.
Pyrolysis units have historically and correctly been regulated by the Clean Air Act's Other Solid Waste Incineration Standards (OSWI). Removing them from Section 129 would allow these incinerators to burn plastic trash without any pollution controls, monitoring, or reporting requirements exposing communities to lead, cadmium, mercury, dioxins, benzene, toluene, formaldehyde, vinyl chloride, hydrogen cyanide, particulate matter, and many other toxic chemicals that can impact public health.
Communities impacted by solid waste incinerators using pyrolysis to combust plastics need the protection of the Clean Air Act to help safeguard the health of children and families. Because they are solid waste incinerators, the OSWI rule does regulate pyrolysis incineration facilities and must continue to do so.