I am writing to express deep concern about the growing number of proposed pyrolysis and gasification facilities, or “chemical recycling” plants, in my region and across the country. These facilities are often touted as a solution to plastic pollution and a clean energy alternative, but the reality is far different.

These chemical recycling plants release a mix of highly toxic chemicals –including benzene, toluene, and dioxins – linked to cancer, nervous system damage, and impacts on reproduction and development. Without proper enforcement of regulations and oversight, these plants can be incredibly dangerous for the environment and frontline communities – particularly for low-income communities and communities of color where most pyrolysis and gasification facilities exist, and where they are likely to be sited in the future.

The Clean Air Act (CAA) already has provisions in place to regulate these facilities under Section 129. The section clearly defines solid waste incineration units, including those burning plastic, and mandates strict emission controls to protect public health. The EPA must enforce these existing regulations rigorously to ensure these facilities operate safely.

In addition, current New Source Performance Standards (NSPS) do not clearly specify how several types of pyrolysis facilities are regulated, such as those under the Commercial and Industrial Solid Waste Incineration Units category. This ambiguity creates loopholes that could allow these facilities to operate without adequate emissions controls. With the rapid increase in proposed pyrolysis plants, the EPA must act swiftly to establish clear and comprehensive NSPS, specifically for all pyrolysis and gasification facilities, under Section 111(b) of the CAA.

Furthermore, it is imperative that the EPA frequently and transparently engage with frontline community members early in the process where chemical recycling facilities are proposed, under construction, and exist currently. Concerns and feedback from residents must be incorporated throughout the process.

In short, for the sake of public health, the climate crisis, and environmental justice, I urge the EPA to take immediate action to:

- Implement Section 129 of the Clean Air Act by ensuring strict enforcement on pyrolysis and gasification facilities. The Municipal Waste Combustion Rule, the Good Neighbor Rule, and the Boilers Rule, also, must be imposed and enforced by USEPA at the existing plastic incineration facilities and the ones proposed in the future.
- Actively engage and meet with residents in communities where these facilities are proposed or already exist, transparently, frequently, and early in the process.

Sincerely,