By: Sam Schmitz, Project Manager
Date: April 6, 2026
About: Docket #EPA-HQ-OAR-2025-0068-0001
To: Environmental Protection Agency
Thank you for the opportunity to testify. My name is Samantha Schmitz and I live in Washington, DC. I am here on behalf of Moms Clean Air Force to oppose this EPA’s misleading proposal to remove pyrolysis incineration from the Other Solid Waste Incinerators Rule. Removing plastics-burning facilities from this rule would allow these combustors to smother communities with unlimited amounts of dioxins, lead, mercury, and other carcinogens. Pollution controls are crucial to the safeguarding of our health, our communities, and our future.
Let’s be clear. Advanced recycling is neither advanced nor recycling. It is simply a greenwashed term for burning plastic in an effort to evade crucial environmental and public health regulations that keep people safe. The plastic burning that is disguised as these “advanced recycling” facilities can emit particulate matter (soot), volatile organic compounds (VOCs), per/polyfluoroalkyl substances (PFAS), and dioxins. These toxic chemicals can cause cancer, worsened asthma, respiratory issues, neurological challenges, developmental delays, preterm birth, low birth weight, miscarriages, stillbirth, and birth defects. How could parents possibly accept those exposures for their children?
Most of these so-called “chemical recycling” facilities use what are called “pyrolysis and gasification,” processes that burn plastic trash and turn it into harmful air pollution and chemical wastes. Some of the outputs created by “chemical recycling” facilities are burned again later as hazardous waste or as heavily contaminated industrial fuels, releasing additional toxic air pollution. What part of that sounds like recycling?
A 2023 investigation showed just how dangerous the resulting fuels really are: A Chevron refinery in Pascagoula, Mississippi, received EPA approval to use the pyrolysis oils derived from incinerating plastic as ingredients to make jet and boat fuel. This research from ProPublica showed that air pollution produced from burning the jet fuel is expected to cause cancer in one in every four people exposed over a lifetime. The boat fuel ingredient is even more toxic: every person exposed over a lifetime would be expected to get cancer. This risk level is one million times higher than what EPA usually considers acceptable for new chemicals and six times higher than the chances of lung cancer from a lifetime of smoking. Let that sink in.
It’s also crucial that we acknowledge the unfortunate fact that children are uniquely vulnerable to air pollution since their bodies are still developing and because children breathe in more air for their size than adults. Breathing in more air means breathing in more air pollution. And what’s worse is that children will have to live with these dangerous chemical harms for decades into the future as the chemical industry seeks to triple plastics production by 2060.
These deceptive, cancer-causing facilities can pop up anywhere and turn families’ lives upside down. I’ve watched this happen to the Cedar Creek community in Columbia, Maryland where serial environmental criminal and superpolluter WR Grace built a proposed facility just 70 meters from local homes. . I’m here today to fight for them as I’ve watched first-hand the grave financial, emotional, and health impacts of having chemical recycling in your backyard. No kid should grow up with a plastics pyrolysis incinerator in their backyard.
Communities like Cedar Creek that are directly impacted by solid waste incinerators need and deserve the protection of the Clean Air Act. Put people over polluters – the future is watching and history will not be kind to those that knowingly fall for this scam. Do not remove pyrolysis incineration from the Other Solid Waste Incinerators Rule. Please step up to ensure a safe, healthy, livable neighborhood and future for the communities you are supposed to serve. Thank you for your time.