Van Hollen, Booker, Huffman, Lowenthal Raise Concerns Over Climate & Environmental Justice Risks of Chemical Recycling of Plastics
Today, U.S. Senator Chris Van Hollen (D-Md.) joined Senator Cory Booker (D-NJ) and U.S. Representatives Jared Huffman and Alan Lowenthal (both D-Calif.) in sending a letter raising concerns over chemical recycling technologies that contribute to the climate crisis and perpetuate environmental injustice in vulnerable communities. The letter comes as the Environmental Protection Agency (EPA) considers whether to remove existing Clean Air Act protections from chemical recycling processes.
“Chemical recycling technologies, specifically pyrolysis and gasification, are forms of incineration and do not help us achieve new source reduction,” wrote the members of Congress in a letter to EPA Administrator Michael Regan. “These two processes are primarily used to “produce fuels like crude oils or synthetic natural gas,” and often do not result in the production of new plastic, meaning these technologies may not support the transition to a “circular economy.”
The members of Congress continued by highlighting that “estimates suggest that the pyrolysis of plastics emits nearly twice as much CO2 as mechanical recycling—and unlike mechanical recycling, is not guaranteed to recover plastics into the supply chain or reduce the need for new virgin plastic.” Mechanical recycling processes include washing, grinding, and re-granulating to recover plastic resins.
In addition to detailing the harms associated with chemical recycling processes, the members of Congress also raised concerns over the hazardous waste released by chemical recycling facilities, which have been found to “emit highly toxic chemicals, including benzene, toluene, ethyl benzene, xylenes, and dioxins, many of which are linked to cancer, nervous system damage, and negative effects on reproduction and development.” As the EPA currently reviews whether pyrolysis and gasification should continue to be regulated as “municipal waste combustion units” under Section 129 of the Clean Air Act, the members of Congress wrote that “changes in how these facilities are regulated could have significant impacts on local air emissions in the communities where these facilities are located, disproportionately impacting minority and low-income communities.”
“We ask that EPA continue to regulate pyrolysis and gasification units as waste combustion units so that the most vulnerable communities do not bear even more of a burden from existing facilities,” concluded the members of Congress. “We also urge the EPA to prioritize solutions that reduce our reliance on single-use plastic and move us towards a circular economy through source reduction interventions and improved mechanical recycling as it implements the National Recycling Strategy….Technologies that worsen the climate crisis, perpetuate a reliance on single-use plastics, and adversely impact vulnerable communities cannot be viewed as viable solutions moving forward.”
The letter was cosigned by Senators Van Hollen, Booker, Murray, Merkley, Markey, Feinstein, Sanders, and Warren, and Representatives Jared Huffman, Lowenthal, Norton, Takano, Matsui, Scanlon, Alma Adams, Castor, McEachin, Lofgren, Bush, Tlaib, Jackson-Lee, Barragán, "Chuy" García, Levin, DeSaulnier, Stansbury, Jacobs, Espaillat, Pocan, Welch, Ocasio-Cortez, Blumenauer, Maloney, Raskin, and McNerney. The letter was also endorsed by over 45 environmental and environmental justice organizations.
Full text of the letter can be found here and below.
Dear Administrator Regan:
We are writing to express our concern over recent investments in chemical recycling as a means to manage our growing plastic pollution crisis. In addition to the harmful downstream impacts of inadequately managed plastic waste that finds its way into the environment, plastic production is a substantial source of greenhouse gas emissions and a driver of environmental injustice in vulnerable communities located near polluting petrochemical facilities. Plastic production and consumption are on track to double in the next decade, exacerbating these harmful impacts. Addressing this growing crisis requires a focus on reducing the production of new plastic. Chemical recycling technologies, specifically pyrolysis and gasification, are forms of incineration and do not help us achieve new source reduction. For these reasons, we urge caution in how the Environmental Protection Agency (EPA) treats these technologies moving forward.
A recent National Academies of Science report called for a comprehensive approach to address this crisis and transition to a circular economy. While we cannot recycle our way out of the plastic pollution crisis, the science is clear that we need recycling to work if we want to move towards a circular economy independent of fossil fuels. According to EPA’s latest estimates (2018 data), the plastics recycling rate in the country was 8.7%. However, it appears plastics recycling rates are even lower as the Department of Energy analyzed data from 2019, finding that only 5% of plastics are being recycled. We support EPA’s continued work towards helping our country reach our national recycling goal of increasing the recycling rate to 50% by 2030.
However, we were disappointed to see EPA include chemical recycling in Part One of the National Recycling Strategy. Whereas current plastics recycling technology employs mechanical processes like washing, grinding, and re-granulating to recover plastic resins, chemical recycling, sometimes called “advanced recycling” or “molecular recycling,” includes a suite of technologies that use non-mechanical processes to break down plastics. Of particular concern are pyrolysis and gasification, which produce fuels like crude oil or synthetic natural gas in part through combustion and other plastic burning technologies. There is no way to guarantee that the feedstocks created through these processes are used to produce new plastics, meaning that they may not advance a circular economy.
Instead of leading to the recovery of plastic and supporting the transition to a circular economy, pyrolysis and gasification lead to the release of more harmful pollutants and greenhouse gases. Estimates suggest that pyrolysis of plastic waste emits nearly twice as much CO2 as mechanical recycling1 – and unlike mechanical recycling, is not guaranteed to recover plastics into the supply chain or reduce the need for new virgin plastic.2 Additionally, chemical recycling facilities are sending significant amounts of hazardous waste nationwide.3 Chemical recycling contributes to our growing climate crisis and leads to toxic air emissions that disproportionately impact vulnerable communities. We ask that EPA take action to advance solutions that reduce our use of single-use plastic and enhance the circular economy and forgo false solutions like chemical recycling that perpetuate the climate crisis and environmental injustice.
In addition, we are aware that EPA is currently reviewing whether pyrolysis and gasification units should continue being regulated as “municipal waste combustion units” under Section 129 of the Clean Air Act. Changes in how these facilities are regulated could have significant impacts on local air emissions in the communities where these facilities are located, disproportionately impacting minority and low-income communities. Chemical recycling facilities emit highly toxic chemicals, including benzene, toluene, ethyl benzene, xylenes, and dioxins, many of which are linked to cancer, nervous system damage, and negative effects on reproduction and development. The plastic and petrochemical industry has lobbied at the state level to eliminate emission control requirements for incinerators using these technologies, exposing vulnerable fenceline communities to toxic emissions from these processes.
We urge EPA to maintain its longstanding position that pypyrolysis and gasification units are subject to regulation under Section 129 of the Clean Air Act and must meet EPA’s existing incinerator standards. We also urge EPA to use existing authorities under Section 114 of the Clean Air Act to obtain information on emissions from chemical recycling facilities, including criteria and hazardous air pollutants, CO2, and other greenhouse gases. Communities located near these facilities need to know what chemicals they are being exposed to, and they need the full protection that Congress intended the Clean Air Act’s incinerator standards to provide.
We share the concern of over 100 environmental and environmental justice organizations urging EPA to continue to regulate these chemical recycling technologies under the Clean Air Act for the health and safety of vulnerable communities.
We ask that EPA continue to regulate pyrolysis and gasification units as waste combustion units so that the most vulnerable communities do not bear even more of a burden from existing facilities. We also urge EPA to prioritize solutions that reduce our reliance on single-use plastic and move us towards a circular economy through source reduction interventions and improved mechanical recycling as it implements the National Recycling Strategy. Chemical recycling will not solve our plastics crisis and it removes incentives for industry to design their products to transition to a circular economy. Technologies that worsen the climate crisis, perpetuate a reliance on single-use plastics, and adversely impact vulnerable communities cannot be viewed as viable solutions moving forward.
Sincerely,