Date: January 17, 2023
To: Governor Michelle Lujan Grisham, 490 Old Santa Fe Trail, Room 400, Santa Fe, NM 87501
Dear Governor Lujan Grisham,
We, the undersigned 78 organizations, urge that you not support the dangerous rebranding of plastic incineration as “advanced recycling.” This greenwashing ploy is part of a chemical industry effort to incinerate plastics without meeting the environmental and health protections of the Clean Air Act. We hope you will oppose any effort in the state legislature to move New Mexico in the wrong direction on this issue.
Under the Clean Air Act, the Environmental Protection Agency (EPA) is responsible for pollution standards for solid waste incineration. Pretending that burning plastic waste in pyrolysis and gasification incinerators is not solid waste incineration but, instead, “advanced recycling,” offers the industry a way to avoid Clean Air Act requirements and to do incineration on-the-cheap without having to invest in pollution controls or bother with air quality monitoring and reporting. Community members would be unable to stop it or even to find out what toxic pollutants they are being exposed to.
Plastic incineration releases toxic air emissions and results in hazardous waste. This is not recycling. Far more sensible would be to address the underlying issue of plastic overproduction. Rather than supporting “chemical recycling,” we hope you will embrace policies to reduce plastic production and use in New Mexico.
Burning plastic is not safe for the environment nor for human health. Plastics contain thousands of chemicals added during the production process, including per- and polyfluoroalkyl substances (PFAS). Plastic manufacturers use PFAS in the molding and extrusion process so the plastic does not stick to machinery. PFAS chemicals are widespread in our food containers and other plastic waste. Other chemicals added to plastic include bisphenols, ortho-phthalates, halogenated flame retardants, perchlorates, formaldehyde, toluene, and heavy metals. Many of these chemicals are associated with serious public health harms including birth defects and cancers. When plastic is burned or turned into fuel to be burned, these toxic compounds must go somewhere, whether they are released in emissions during the “chemical recycling” process, in the resulting fuels which are then burned, or in toxic ash.
However it is pitched, “chemical recycling” is plastic incineration, and it is taking place without pollution controls. In recent years petrochemical interests have been wildly successful at convincing state legislatures to redefine “chemical recycling” as “manufacturing” rather than “incineration.” Yet research from the Global Alliance for Incinerator Alternatives (GAIA) shows that “chemical recycling” emissions are as dangerous as traditional waste incineration, if not more so, and that the climate emissions are worse than those from coal-fired power plants. A March 2022 report from the Natural Resources Defense Council found that these highly-polluting "chemical recycling" facilities are emitting dioxins, benzene, cadmium, arsenic, lead, polycyclic aromatic hydrocarbons (PAHs), mercury, and other toxic chemicals.
Nearly all of these facilities are located in low-income communities and communities of color. Redesignating the incinerators as “recycling” or “manufacturing” in order to evade Clean Air Act pollution controls would be environmental injustice at its worst. Recently, long-term safety concerns of the “chemical recycling” process convinced Mayor Lester Miller in Macon, Georgia to withdraw support for a proposed $680 million “chemical recycling” operation.
Traditional plastics recycling is not working; the current U.S. recycling rate is less than 6%. Meanwhile, the U.S. is generating more than 40 million tons of plastic waste annually, and the production of new plastics from fossil fuels is predicted to double by 2030 and to triple by 2060. More than 40% of new plastic goes toward single-use disposables, used for mere minutes but persisting in the environment for generations. Plastic can be incredibly useful, as it has properties unlike any other material. However, the issues of toxic emissions and of overproduction of single-use plastics require urgent action.
Governor Lujan Grisham, New Mexico needs policies to reduce plastic production and use – not polluting and untenable “chemical recycling” schemes. No waste-management technology will be able to stem the growing tsunami of plastic. We urge you to champion policies that will reduce plastic waste at the source and protect our families from reckless and unchecked sources of pollution.
Sincerely,
350 New Mexico
Altura Honey LLC
Americans for Indian Opportunity
Bachi Media, LLC
Beyond Plastics
Beyond Plastics Santa Fe
Birdsong Distributing
Buckeye Environmental Network
California State University
Californians Against Waste
Center for Biological Diversity
Climate Reality Chapter of Northern New Mexico
Common Ground Rising
Conservation Carnivale
Do Good LLC
Earth Ethics, Inc.
Earth Future
East Mountain Editing Services
Ecology Center
Eldorado/285 Recycles
First Congregational United Church of Christ Green Justice team
Frack Free New Mexico
FreshWater Accountability Project
Friends of the Earth
Global Alliance for Incinerator Alternatives (GAIA)
Greenpeace USA
Group Against Smog & Pollution
Heart of the Gila
Indivisible Albuquerque
Indivisible Santa Fe
Inland Ocean Coalition
Jemez Sustainable Solutions
Little Green Bucket
McKinley Citizens' Recycling Council
Micah Six Eight Mission
Moms Clean Air Force
Native Plant Society of New Mexico
Natural Resources Defense Council
New Mexico Climate Justice
New Mexico Environmental Law Center
New Mexico Interfaith Power and Light
New Mexico Recycling Coalition
New Mexico Wilderness Alliance
Niko Dellios Legacy Fund
NM Healthy Soil Working Group
NM No False Solutions
NMVC Action Fund
Paradox Farm
PASUP (Pittsburgher's Against Single Use Plastic)
People & Planet Refill, PBC
Plastic Action Team of New Mexico
Plastic Pollution Coalition
Positive Energy Solar
Prairie Dog Advocacy Watch Group (PDAWG)
Progressive Democrats of America - Central New Mexico
Prosperity Works
Putting Down Roots
R. Mole Sculpture
ReferenceSystemK
Rio Grande Chapter of the Sierra Club
Rio Grande Valley Broadband
Sandoval Moots Architect, LLC
Sobadores del Llano and Remedios Naturales NM LLC
Taos Environmental Film Festival
The Global Warming Express
The Last Beach Cleanup
The Last Plastic Straw
The Story of Stuff Project
The University Lobo Community
The University of New Mexico Lobo Community Garden
ThinkLikeABee.org
UNM Leaders for Environmental Action and Foresight (LEAF)
Upper Gila Watershed Alliance
Upstream
Valencia Water Watchers
WastelessLife NM
Westminster Presbyterian Church
WildEarth Guardians