Virginia’s waterways are under assault by single-use plastic pollution, but chemical conversion, also known as “advanced” or “chemical” recycling, is a false and flawed solution to the plastic pollution crisis threatening our local waterways, oceans, and aquatic animals. Chemical conversion will not reduce the use of single-use plastics – it will incentivize the continued use of plastics as a feedstock for plastics-to-fuel facilities. The resulting air pollution and hazardous waste generated from chemical conversion would put Virginia’s communities and environmental health at risk. Policy can 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

Chemical conversion is a broad term encompassing a variety of failed and experimental processes where plastic is incinerated in an oxygen-free environment to render a raw material to create fossil fuel (see graphic below). Often, the plastic used in this process is sourced from brokers or single companies, and would not accept residential or local plastic products used by Virginians.

Seven of the eight US chemical conversion facilities are in communities that are predominantly low income, Black, or both.

The increased air pollution and hazardous waste production resulting from chemical conversion put Virginians’ health at risk. Pollution disproportionately burdens communities of color and, as a result of this environmental injustice, Black people are three times more likely to die from exposure to air pollutants than white people.^2,3 In particular, seven of the eight chemical conversion facilities in the United States are in communities that are predominantly low income, Black, or both⁴; this combined with the fact that these facilities frequently violate EPA hazardous waste regulations further demonstrates chemical conversion as a false, inequitable solution.

Plastic pollution and the lack of an effective recycling industry have given the plastics industry an opportunity to market “advanced recycling” technology, like plastics-to-fuel, as a solution, despite the complete lack of operating success⁵ or addressing the root issue of an overabundance of plastic products.

The American Chemistry Council has succeeded in convincing eighteen state legislatures⁶ to pass bills which exempt these facilities from standardized industrial waste regulations – including Virginia.⁷

Moreover, the short history of chemical conversion facilities in Virginia confirms it as a false solution to the plastic pollution crisis and a waste of taxpayer money. Braven Environmental LLC abruptly canceled its plans to build a facility that purported to serve as a “solution” to the state’s plastic waste problem in Cumberland County⁸ after receiving over $200,000 in state grants in 2020.

The EPA recently said that it would strictly regulate plastics-to-fuel operations under the Clean Air Act but we still need a strong defense to ensure that Virginia does not fall victim to investing taxpayer money in false solutions.

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, elevating proven solutions that reduce the amount of virgin plastics manufactured.

Emerging technologies, such as plastics-to-fuel, should be robustly evaluated for safety and proof of scalability before being allowed in Virginia. Technologies should be revenue generating (i.e. not reliant on taxpayer dollars) and proven to achieve goals that advance Virginia’s quality of life, such as litter reduction, plastic waste management, and environmental equity.

We have seen the plastics-to-fuel industry stumble due to issues surrounding technology scalability, high volumes of hazardous waste production, energy consumption, and overall inability to turn over a profit.⁹ To truly tackle the plastic pollution crisis, Virginia needs actual plastic reduction solutions that reduce our reliance on single use plastic to protect human health, water quality, and aquatic life (see REDUCING PLASTICS, LITTER, & MARINE DEBRIS).

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. https://www.no-burn.org/wp-content/uploads/All-Talk-and-No-Recycling_July-28.pdf.

² Robert D. Bullard and Beverly Hendrix Wright, “The Politics of Pollution: Implications for the Black Community.” Phylon 47, no. 1 (1986): 71–78. https://doi.org/10.2307/274696.

³ Di, Q., Wang, Y., Zanobetti, A., Wang, Y., Koutrakis, P., Choirat, C., Dominici, F.,Schwartz, J., “Air Pollution and Mortality in the Medicare Population”. New England Journal of Medicine 372 no. 26 (2017): 2513-2522. https://doi.org/10.1056/NEJMoa1702747.

⁴ “Recycling Lies: “Chemical Recycling” Of Plastic Is Just Greenwashing Incineration,” NRDC, 2022, https://www.nrdc.org/sites/default/files/chemical-recycling-greenwashing-incineration-ib.pdf

⁵ Joe Brock, Valerie Volcovici, and John Geddie, “The Recycling Myth: A Plastic Waste Solution Littered with Failure,” The Recycling Myth: Big Oil’s Solution for Plastic Waste is Littered with Failure, July 29, 2021, https://www.reuters.com/investigates/special-report/environment-plastic-oil-recycling/.

⁶ Cheryl Hogue, “Chemical recycling of plastic gets a boost in 18 US states – but environmentalists question whether it really is recycling,” Chemical and Engineering News, 2022, https://tinyurl.com/35m27tc7.

⁷ Code of Virginia: § 10.1-1400. Definitions. § (2021), https://law.lis.virginia.gov/vacode/title10.1/chapter14/section10.1-1400/.

⁸ Patel,”All Talk and No Recycling.”

⁹ James Bruggers, “‘Advanced’ Recycling of Plastic Using High Heat and Chemicals Is Costly and Environmentally Problematic, a New Government Study Finds,” Science, January 19, 2023, https://insideclimatenews.org/news/19012023/plastic-advanced-recycling-cost-environmental-impact/.

¹⁰ “Draft National Strategy to Prevent Plastic Pollution,” EPA, June 14, 2023, https://www.epa.gov/circulareconomy/draft-national-strategy-prevent-plastic-pollution#summary.