The current solid waste planning and recycling regulations do not go far enough to adequately manage the plastic waste stream and protect Virginia's residents and environment. The regulations, emboldened by recent Executive Orders, enable and encourage the development and operations of advanced recycling facilities in Virginia. Advanced recycling and pyrolysis are false and flawed solutions to the plastic pollution crisis which threaten local environmental and community health. The goal of waste management and recycling should be to achieve a truly circular economy; not just burn or combust waste into fuel or fuel substitutes. Contrary to its greenwashed advertising, advanced recycling technology will not reduce the use of single-use plastics, but instead will incentivize their continued use as a feedstock for plastics-to-fuel facilities (VCN, 2022). 

Additional comments:

• True “circular economy” practices convert plastic waste into new plastic products–not fuel, fuel ingredients, energy or other feedstock. The EPA’s Draft National Strategy outlines the Agency’s efforts to promote a circular approach for plastics management in the U.S.; Virginia’s state regulations should support this national goal.
• Advanced recycling is not recycling by any means. In their Draft National Strategy, the EPA reaffirms 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." If the federal government does not consider plastic to fossil fuel production to be recycling; neither should Virginia.
• Plastic to fossil fuel production facilities are energy intensive and are still classified as incineration under the Clean Air Act. These facilities require a NPDES (National Pollutant Discharge Elimination System) Permit. Virginia’s taxpayers should not be footing the bill for these polluting, energy intensive facilities. Furthermore, rural communities should not be burdened by these dangerous, polluting facilities (as E.O. 17 emphasizes).

Eleanor Kluegel

Clean Fairfax Council / Litter Free Virginia