Re: Stand Strong for Community Health Protections by Implementing Plastic Pollution Prevention and Packaging Producer Responsibility Act Without Delay
Dear Governor Newsom,
We urge you to stand firm in implementing SB 54 without delay or industry interference. Individuals nationally and globally overwhelmingly support strong environmental protections, with two-thirds of Californians identifying plastic packaging waste as a major problem. The world is watching as the Global Plastics Treaty advances, and California has the opportunity—and responsibility—to lead with integrity.
You are in a unique position to be a national leader, and to ensure an effective and health-centered solution to the well-known global plastic packaging crisis by moving SB 54 implementation forward before the March 8, 2025, deadline.
California cannot allow industry to degrade the intent of this landmark law. Your administration has already demonstrated leadership in protecting public health and the environment—most notably with the 2024 closure of the state’s last two municipal waste incinerators. That progress must continue. SB 54 explicitly excludes plastic recycling technologies that produce hazardous waste, including chemical recycling methods like pyrolysis and gasification, which have been exposed as false solutions.
California policy provides a critical firewall between incineration technologies and recycling. The following policies consistently classify incineration (including gasification, pyrolysis, and similar approaches) as waste disposal–in line with US Environmental Protection Agency regulations on incineration–while these recycling goals and requirements prevent incineration and similar approaches from masquerading as recycling:
- Goal of 75% of solid waste generated annually statewide be source reduced, recycled, or composted (AB 341, Public Resources Code 41780.01)
- Waste Management Hierarchy (Public Resources Code 40051)
- Greenhouse Gas Reduction Fund (GGRF) amendment of Section 126, Item 3970-101-0001 of Section 2.00 of the Budget Act of 2022
- Battery Recycling (AB 2440, 2022) amendment of Public Resources Code 42420.1
- Tire Recycling (Public Resources Code 42873)
- Carpet Recycling (Public Resources Code 42968)
- Renewable Portfolio Standard (RPS) Eligibility (Public Resources Code 25741)
- Elimination of Diversion Credit for Transformation (AB 1857 C. Garcia, 2022)
Please uphold the state and your powerful legacy by standing strong against industry pressure to slow down or halt implementation of SB 54 and to weaken its protections against so-called “chemical recycling,” as described in recent news articles. SB 54 drew a clear line to “exclude plastic recycling technologies that produce significant amounts of hazardous waste,” specifically including the so-called “chemical recycling” technologies identified in Senator Allen’s SB 54 Letter to the Journal and respective committee analyses: solvolysis, solvent-based technologies, pyrolysis, incineration, and gasification.
The success of SB 54 depends on strong state oversight, not industry self-regulation. California has a chance to set the national standard for producer responsibility in plastics. We urge you to uphold your commitment to environmental justice and stand strong against corporate influence.
Sincerely,
Denaya Shorter
Senior Director, GAIA US & Canada
ATTACHMENT: Nov 2024 NGO letter on chemical recycling in SB 54