Ensuring Accountability in the Chemical Conversion Industry
Elly Boehmer // Environment Virginia // eboehmer@environmentvirginia.org
Connor Kish // Sierra Club Virginia Chapter // connor.kish@sierraclub.org
Chris Leyen // Virginia League of Conservation Voters // cleyen@valcv.org
Phillip Musegaas // Potomac Riverkeeper Network // phillip@prknetwork.org
Pollution Prevention
Executive Summary
Virginia’s waterways are under assault by single-use plastic trash that is carried by stormwater and thoughtlessly discarded as litter. The volume of plastic trash and the ongoing recycling crisis led the plastics and chemical industries to promote chemical conversion as a solution. Chemical conversion will not reduce the use of single-use plastics, it will incentivize its continued use and create demand for plastic as a feedstock for plastics to fuel facilities. Legislators and regulators must ensure that the industry does not pollute waterways, entrench our dependence on single-use plastics, and inequitably burden communities of color where chemical conversion plants are often sited.1 Industry accountability should include publicly available disclosure of intake, operational, and output data for these facilities to verify that the industry’s performance claims are valid.
Challenge
Plastic pollution and the lack of an effective recycling industry has given the plastics and chemical industries an opportunity to market their “advanced recycling” technology as a solution. However, there is a complete lack of operating history to show that it works, and a complete lack of transparency when it comes to the pollution and environmental justice impacts of chemical conversion plants on the surrounding community.
Chemical conversion is an experimental process where plastic is melted down in an oxygen-free environment to render a raw material for more plastic production, or to mix with traditional petroleum for fuel. The American Chemistry Council has succeeded in convincing thirteen state legislatures to pass bills weakening or streamlining state regulation of chemical conversion facilities. SB1164 passed in Virginia in 2020, effectively exempting these facilities from regulation under the Solid Waste Management Act, where landfills, waste transfer facilities, and recycling facilities are routinely regulated.
Chemical conversion is an experimental process where plastic is melted down for more plastic production or to mix with petroleum for fuel.
There is one chemical conversion facility currently being proposed and permitted for Cumberland County, but the industry is intent on expanding its presence in Virginia. We must have proper regulation, accountability, and public involvement throughout the chemical conversion process and facility operations to ensure that the industry’s stated objectives are true and the state government can verify them as such.
Solution
State solid waste management policy should focus on reducing single-use plastics in the waste stream and as litter, reusing products where possible, and if recycling is required, elevate solutions that “don’t downcycle.”
Nascent technologies like chemical conversion should be robustly evaluated/reported and, if shown to be feasible, thoughtfully incorporated into best practices for litter reduction and plastic waste management.
Success or failure of this industry must be assessed by looking at the following metrics: total waste reduction, percent of plastic waste volume diverted from landfills, energy consumption and climate emissions impact, and reduced environmental harm for communities impacted by manufacture, storage, waste management, and transport of plastics.
Policy Recommendations
Require a sophisticated regular reporting accountability system for chemical conversion facilities that includes data related to the intake, operational, and output aspects of the facility.
Mandate that any submitted permit application for a chemical conversion facility includes a robust public outreach effort that is fully compliant with Virginia’s current Environmental Justice policy.
Ensure that all aspects of the regular reporting system as well as the full submitted permit, community meeting and outreach schedule, and opportunities for virtual and in-person comments from the public are available in a prominent and easily accessible location.
End Notes
1 Patel, D., Moon, D., Tangri, N., Wilson, M., All Talk and No Recycling: An Investigation of the U.S. “Chemical Recycling” Industry. Global Alliance for Incinerator Alternatives (2020). www.doi.org/10.46556/WMSM7198.