Dear Waste Management Board,

We are writing in strong support of keeping the false solution of advanced recycling out of Virginia on behalf of Waterkeepers Chesapeake, a coalition of seventeen Waterkeepers, including three in Virginia, working to make the waters of the Chesapeake and Coastal Bays swimmable and fishable. Currently, recycling regulations in the Commonwealth fail to specifically exclude practices that convert plastic waste to fossil fuels from their recycling definitions. This allows advanced recycling facilities to contribute harmful pollutants to the environment, burden already vulnerable communities, and waste economic development funds under the guise of a false solution to solving the plastic pollution problem. Advanced recycling is inherently a polluting activity as studies conducted by plastic manufacturers revealed that advanced recycling generates more harmful emissions than either landfilling plastic or burning it and “generates far more pollution than eliminating single-use plastics altogether.”

At the federal level, the EPA’s recent Draft National Strategy to Prevent Plastic Pollution states that the federal agency does not consider “activities that convert non-hazardous solid waste to fuels or fuel substitutes (‘plastics-to-fuel’) or for energy production to be ‘recycling’ activities.” Virginia should not fall behind the slow-moving EPA as not only would Virginians’ health suffer but doing so prevents a true circular economy, which would turn plastic waste to new plastic products–not fuel, fuel ingredients, energy or other feedstock.These regulations should be reviewed with an eye towards improving Virginia’s environment and the health of its citizens, not guided by Executive Order 19 and its harmful stated goal of removing 25% of all regulatory requirements in the Commonwealth.

For these reasons stated above, we urge the Board to revise the recycling definitions in a way to best protect the health of Virginians and the Commonwealth’s unique and beautiful environment, and not guided by the harmful principles of Executive Order 19.

Sincerely,

Waterkeepers Chesapeake

Alex Villazon

Climate & Justice Legal Fellow

alex@waterkeeperschesapeake.org