Chemical recycling
FOR IMMEDIATE RELEASE: December 15, 2025
Berkeley, CA — The Global Alliance for Incinerator Alternatives (GAIA) is proud to announce the 2025 recipients of its U.S. Environmental Justice Action Microfunds. Sixteen grassroots partners across the country were selected for their leadership in advancing transformative zero waste solutions, strengthening community power, and confronting pollution threats in frontline communities.
Made possible through an investment from the Cloud Mountain Foundation, the microfunds provide $2,500 in flexible support for frontline and community-based organizations advancing environmental and waste justice in regions overburdened by polluting waste infrastructure. Awardees are addressing impacts related to incineration, so-called chemical recycling, plastics and petrochemicals, landfills and methane, battery-related issues, and more. This year’s awardees are launching projects ranging from youth-led environmental leadership and community education to site fights, expansion of reuse systems, and local zero waste infrastructure. This year’s initiatives reflect the importance of zero waste solutions as cities grapple with the shortcomings of recycling and mounting plastic pollution.
“Frontline communities have the solutions to our waste crisis, and they are leading some of the most effective strategies that make a real impact. GAIA is honored to help resource these efforts and uplift the solutions that are already working,” said Denaya Shorter, Senior Director of the US & Canada Region at GAIA.
The 2025 U.S. Environmental Justice Action Microfunds recipients include:
- ZW Ithaca will expand Ithaca and Tompkins County’s Bring Your Own (BYO) foodware reuse network by hiring a coordinator to strengthen and grow the BYO sticker program.
- Sustainable Community Farms will establish the Food-Energy-Water (FEW) Ambassador program in Detroit to train middle and high school students in environmental leadership, connect school and community-based learning through outdoor projects at Sustainable Community Farms, and empower youth to advocate for more sustainable efforts in their communities.
- Center for Environmental Transformation will educate Camden residents on the health detriments of living near waste incineration facilities like Reworld (formerly Covanta). Through a six-part workshop, CET will provide workbooks and include an “environmental tour” highlighting the local incinerator.
- Heirs to Our Ocean (H2OO) will use microfunds to support the youth members of the U.S. Youth Action Council for the UN Ocean Decade (U.S. YAC UNOD) and their efforts to tackle plastic pollution through brand audits, policy, and movement building.
- Post-Landfill Action Network (PLAN) will use microfunds to support four cohorts of the Reusable To-Go ROI Calculation Course, which will train student leaders at 16–24 campuses to conduct ROI analyses and logistics plans for college campus reusable dining systems that replace single-use plastics.
- Cherokee Concerned Citizens will use microfunds to support the “Relocation to Restoration” initiative by helping residents of Pascagoula, Mississippi, relocate from high-risk areas adjacent to major facilities, including the Chevron Refinery, the Enterprise gas processing plant, Gulf LNG, Bollinger, and the Mississippi Phosphates Superfund site, and restore these areas into native Gulf Coast habitats.
- Buckeye Environmental Network (BEN) will hold a one-day statewide convening in Ohio to train and connect community members fighting chemical recycling plants and petrochemical expansion, providing workshops on site-fighting strategies, permit review, public comment, and communication skills to strengthen local campaigns and statewide collaboration.
- People of Red Mountain will use microfunds to support travel, lodging, and food expenses for members of People of Red Mountain, a grassroots group committed to protecting sacred lands from lithium mining in the McDermitt Caldera, for the 12th Annual Oak Flat March/Run.
- ZW Detroit will engage Detroit-area residents, youth, elders, and local partners through education and workshops on methane reduction, food waste prevention, and air quality, providing practical tools to reduce climate impact and improve public health.
- Breathe Free Detroit will use microfunds to support capacity and participation in quarterly county meetings that oversee the waste management plan and the implementation of the first U.S. model of city-run decentralized composting.
- Physicians for Social Responsibility PA will strengthen grassroots power in Pennsylvania by educating and organizing communities impacted by incinerators and landfills, providing workshops, canvassing materials, and policy support to help residents build leadership and advance local ordinances.
- New Jersey Environmental Justice Alliance (NJEJA) will support community farms in South New Jersey in engaging and educating local communities on zero waste principles, deepening partnerships, co-launching sustainable reuse and circular economy initiatives, and sharing a replicable, community-led model for building zero waste solutions.
- Damascus Citizens for Sustainability will work to prevent a proposed county “waste-to-energy” incinerator by educating and organizing residents, working with local groups, and promoting alternatives such as recycling, composting, and waste reduction.
- Rise for Environmental Justice (RiSE4EJ) will use microfunds to support a site fight and build capacity to defend a recent win against a proposed chemical recycling facility by Reworld (formerly Covanta) in the EJ community of Armourdale, KS.
- Baltimore Compost Collective will transform a new property into a zero waste hub offering local composting, youth green jobs training, and community workshops to reduce waste, build leadership, and promote a healthier Baltimore.
- Our ZW Future will support Zero Waste Rio Grande Valley, the South Texas branch of OZWF, in training five colonia residents in zero waste practices and cooperative business development, advancing economic mobility, and launching a pilot zero waste cooperative that benefits families across the Valley.
The 2025 Environmental Justice Action Microfunds represent GAIA’s continued commitment to resourcing community-led strategies that address pollution at its source while strengthening local leadership and long-term capacity. GAIA looks forward to supporting these partners as they advance effective, community-centered zero waste solutions.
Additional Quotes:
“It is our goal to equip and fortify residents so that they can hold these industries accountable for their crimes against health and the environment. Without the strength and determination of committed individuals, we get nowhere. When communities win, we all win.” — Tonyehn Verkitus, Executive Director, Physicians for Social Responsibility Pennsylvania
“We are grateful for GAIA’s investment in the youth leaders of the U.S. Youth Action Council for the UN Ocean Decade, who are organizing to confront plastic pollution at the source through science, policy, and community leadership. This support will help ensure youth are leading action to shape the solutions our climate, shared ocean, and communities urgently need.”
— Emily Berglund, Executive Director, Heirs To Our Ocean
“We’re deeply grateful for GAIA’s EJ Microfunds and proud to be among this cohort of frontline zero waste and environmental justice projects. With this support, Zero Waste Ithaca will strengthen and grow our Bring Your Own foodware reuse network and expand our BYO sticker program.” — Yayoi Koizumi, Founder, Zero Waste Ithaca
“Stay positive, stay centered, and we can overcome.”
— Barbara Weckesser, Cherokee Concerned Citizens
Press contact:
María Guillén, Communications & Network Development Manager, U.S. & Canada
mariaguillen@no-burn.org
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GAIA is a worldwide alliance of more than 1,000 grassroots groups, non-governmental organizations, and individuals in over 90 countries. With our work, we aim to catalyze a global shift towards environmental justice by strengthening grassroots social movements that advance solutions to waste and pollution. We envision a just, zero waste world built on respect for ecological limits and community rights, where people are free from the burden of toxic pollution, and resources are sustainably conserved, not burned or dumped.
Governor Newsom’s new packaging regulations are a cop out, advocates say
FOR IMMEDIATE RELEASE: September 9, 2025
Sacramento, CA — When California passed Senate Bill 54 in 2022, the world’s fifth-largest economy had enacted a bold law to hold plastic polluters accountable, cut waste at the source, and relieve taxpayers of skyrocketing costs for managing single-use packaging. SB 54 promised nothing short of a transformation: shifting responsibility away from the public and onto the corporations that profit from disposable plastics, reducing the $420 million spent by local ratepayers on litter prevention and removal. And given the worsening plastic pollution crisis, with microplastics found everywhere from the deepest ocean trenches to our brains, we can’t afford for SB 54 to fail.
But three years later, the Newsom Administration’s draft regulations threaten to unravel that promise. Governor Gavin Newsom ordered a rewrite of the first draft in March 2025, citing concerns about costs for businesses and consumers. Instead of upholding the law, the second set of rules issued by CalRecycle are riddled with loopholes that invite greenwashing, funnel money into unproven and harmful technological “solutions,” and shield industry from any meaningful shift from the status quo. Cost efficiency also means not wasting public money on costly “chemical recycling” schemes.
The result: a hollowed-out program that fails California communities, the environment, and ratepayers. That is why legislators, environmental and environmental justice organizations remain staunchly opposed to the proposed regulations as drafted, and are instead calling for the implementation of the law as intended – without creating industry loopholes or further imperiling the communities already hardest hit by pollution.
Notable Loopholes
“Chemical recycling”: SB 54 was explicitly written to ensure that harmful “chemical recycling” technologies are not considered recycling for purposes of the law. However, the law’s requirement that recycling technologies not produce “significant amounts of hazardous waste” has been rendered nearly meaningless in the updated regulations, which replace a detailed scientific process with a statement that a facility meets these criteria if the hazardous waste “is handled and disposed of in compliance with an applicable permit”.
So-called “chemical recycling” technologies are a cluster of costly, toxic, and climate-harming technologies – mainly pyrolysis, which is incineration under the federal Clean Air Act – pushed by the petrochemicals industry to rescue the tarnished image of plastic recycling and perpetuate single-use plastics. The changes to the regulations are in stark contrast to the California Attorney General’s suit against ExxonMobil filed last September, asserting that it “deceptively promotes “advanced recycling” as the solution to the plastic waste and pollution crisis”.
Food packaging: The draft regulations also permanently “categorically exclude” packaging for food or agricultural commodities based on “regulations, rules, or guidelines” issued by the USDA or FDA, whether or not these regulations legally preempt California. In effect, California would allow the Trump administration to issue a “guideline” permanently excluding food and agricultural packaging.
Advocates have issued the following statements in response to the draft regulations issued by Newsom administration:
“California’s SB 54 promised to shift responsibility for plastic pollution away from overburdened communities and onto the producers of the toxic plastic packaging themselves. Instead, the new regulations carve out loopholes that let polluters off the hook, once again sacrificing the health of environmental justice communities in order to grow industry profits. Californians need real solutions that put communities and health ahead of industry interests.” – Melissa Aguayo, Global Co-Coordinator, Break Free From Plastic (BFFP)
“This regulation reads like a cop-out to the petrochemicals industry. It ignores warnings from the environmental community and will see dirty, toxic incineration facilities mushrooming across California, at a great cost to the wallets and health of taxpayers. This isn’t what California needs – what we need is regulations that are faithful to SB 54 and a ban on the whole cluster of dirty technologies that is “chemical recycling”.” – Sirine Rached, Senior Policy Advisor, Global Alliance for Incinerator Alternatives (GAIA)
“California is on the verge of blowing its opportunity for transformational change by adopting regulations that effectively perpetuate the status quo. We are incredibly disappointed to see CalRecycle’s deliberative process be overridden by industry lobbying and political ambition.” – Nick Lapis, Director of Advocacy, Californians Against Waste
Press contacts:
Brett Nadrich, US Communications Officer, Break Free From Plastic
brett@breakfreefromplastic.org
María Guillén, Communications & Network Development Manager, Global Alliance for Incinerator Alternatives (GAIA)
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About BFFP — #BreakFreeFromPlastic is a global movement envisioning a future free from plastic pollution. Since its launch in 2016, more than 2,700 organizations and 11,000 individual supporters from across the world have joined the movement to demand massive reductions in single-use plastics and push for lasting solutions to the plastic pollution crisis. BFFP member organizations and individuals share the values of environmental protection and social justice and work together through a holistic approach to bring about systemic change. This means tackling plastic pollution across the whole plastics value chain – from extraction to disposal – focusing on prevention rather than cure and providing effective solutions. www.breakfreefromplastic.org.
About GAIA — The Global Alliance for Incinerator Alternatives (GAIA) is a member-based, environmental justice network working at the intersection of waste, climate, and justice. In the United States and Canada, GAIA supports grassroots organizations that advance zero waste solutions, challenge the plastics and petrochemical industries, reduce methane emissions, and promote safe, sustainable practices for electric vehicle battery production and recycling.
Plastic is a growing crisis with devastating impacts on the environment, human health, human rights, environmental justice, the rights of Indigenous Peoples, biodiversity, and climate. Global actions to address this crisis are urgently needed. As numerous studies have demonstrated, plastic has been found everywhere, not only in ecosystems and the atmosphere but also in the food we eat, the water we drink, and even inside our bodies. For the Global Plastics Treaty to be effective in reversing the tide of plastic pollution, mechanisms and solutions to address it need to exist within climate and planetary boundaries. This treaty is an opportunity to get it right and open a path for comprehensive national policies to regulate plastic production and consumption. It can potentially be one of the most significant environmental agreements in history.
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Views on the development of UNFCCC roadmaps for a Transition Away from Fossil Fuels in a Just, Orderly and Equitable Manner, and for Halting and Reversing Deforestation and Forest Degradation by 2030
GAIA proposes the following material economy shifts as solutions for the roadmaps to deliver a Transition Away from Fossil…
Issues in Focus
Plastics Crisis: Challenges, Advances and Relationship with Waste Pickers
Negotiations must include the recognition of the historical work of those who have recovered more materials and in the most efficient way: the waste pickers.
Overview of the Plastics Treaty/Tratado sobre plásticos
Plastic pollution does not respect borders. It is in the air we breathe, the food we eat, the water we drink, and even in our bodies. A new binding legal instrument, covering the entire lifecycle of plastic, is required to tackle this planetary crisis.
The Plastic Waste Trade
Top exporters such as the United States, Germany, the UK, Japan and Australia are placing a disproportionate toxic burden on the environment and communities in importing countries. A Global Plastics Treaty can enact stricter measures on the waste trade to prevent environmental injustices.
Plastic and Waste Pickers/Recicladores
Plastic takes up a large percentage of the waste handled by waste pickers. Consequently, they are one of the most vulnerable occupation groups that stand to be impacted by the global plastics treaty. The treaty must establish the legal frameworks required to improve working conditions for waste pickers.
Toxics and Health
Plastic contains toxic chemicals that leach into our food, water, and soil. Out of about 10,000 chemicals used as plastic additives, few have been widely studied, let alone regulated. A treaty must address plastic’s toxic burden.
Plastic and Climate Change/Los plásticos y el cambio climático
Plastic is a significant contributor to climate change throughout its lifecycle. By 2050, emissions from plastic alone will take up over a third of the remaining carbon budget for a 1.5 °C target. A plastics treaty must impose legally-binding plastic reduction targets.
Chemical “Recycling” and Plastic-to-Fuel
Faced with increasing pressure from lawmakers and civil society to reduce plastic production and greater awareness of the limits of mechanical recycling, the petrochemical industry has been peddling chemical “recycling” and “plastic-to-fuel” as a primary solution to plastic pollution. However, after billions of dollars and decades of development, these approaches do not work as advertised. A plastics treaty stands to be undermined if it embraces these industry-backed false solutions.
Waste Incineration and Burning Waste in Cement Kilns
Burning waste emits climate pollution and other toxic chemicals, and is the least energy-efficient and most costly method of energy production. A plastics treaty must adopt a moratorium on new incinerators and encourage a roadmap to phase out all existing incinerators by 2030.
Burning Waste in Cement Kilns
Burning plastic in cement kilns results in toxic emissions, threatening the health of workers, communities and the environment, especially in low-income countries in the Global South. Widespread burning of waste in cement kilns would also worsen the already devastating carbon footprint of the cement industry. A plastics treaty must phase out burning plastic waste in cement kilns.
Plastic Neutrality and Credit
The global plastics treaty provides an important opportunity to officially discourage or ban the use of plastic credits before they become widespread. Doing so would avoid the incredible amount of regulatory oversight needs —both in the private and public sectors— to organize and
manage international plastic credit markets. The collective efforts could be better spent on reducing plastic production rapidly.
Zero Waste Finance
A transition from a plastic-reliant economy toward a circular zero waste economy requires effective mobilization and allocation of financial resources. Public and private finance have distinct and intersecting roles to play in supporting and scaling up innovations for waste prevention, redesign, alternative delivery and reuse systems as well as improving existing waste collection and recycling systems.
Extended Producer Responsibility
Extended producer responsibility (EPR) policies seek to improve the environmental and social performance of products by holding producers and brand owners accountable for the entire lifecycle of their products. The global plastics treaty must embed well-designed EPR policies in it, guiding producers to prioritize upstream solutions.
Bioplastics
The global Plastics Treaty must focus on plastic reduction and reuse, instead of substituting a plastic single-use item for a bio-based, biodegradable, or compostable one.
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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
The Inflation Reduction Act (IRA) channels $270 billion in tax credits for climate investments but raises concerns about incineration—a false solution to waste disposal that could generate 637.7 million tonnes of CO2e emissions over two decades, further harming the environment and disadvantaged communities.
By: Marcel Howard (Zero Waste Program Manager, US/Canada) and Jessica Roff (Plastics & Petrochemicals Program Manager, US/Canada)
Key Highlights
- The Inflation Reduction Act (IRA) is primarily a tax bill. Of the promised $369 billion in climate investments, $270 billion will come in the form of tax credits1
- Incineration is one of the most polluting and expensive waste disposal systems. Industry2 often greenwashes incineration as “waste-to-energy”3 despite producing minimal amounts of usable energy and massive energy input
- By measuring the lifecycle climate impacts of incineration accurately, the Department of the Treasury can deny polluting facilities billions in tax credits intended for actual sustainable energy solutions and ultimately delay or block their construction or expansion
- If industry succeeds in propping up incinerators for 20 years, they will produce 637.7 million tonnes of climate-change-inducing CO2e emissions and further exacerbate toxic pollution and environmental racism4
- Pairing new subsidies for incinerators with incentives for EVs is perverse
- Turning waste, including fossil fuel-derived plastics, into jet fuel is dangerous and does not decarbonize air travel
- Two-thirds of US incinerators are located in states that include incineration in their renewable energy portfolio
- The IRA allocated billions of dollars in lending subsidies specifically meant to drive reinvestment in low-wealth and environmental justice communities. Environmental justice, frontline, and fenceline groups should consider applying for these IRA lending programs
Background
The United States (US) has a waste problem compounded by a plastic problem. For decades, we have been handling our waste in ways that harm communities, our climate, and the natural world. Federal, state, and municipal governments continue to site waste incinerators of all forms in Black, brown, indigenous, and lower-wealth communities — plaguing them with decades of harmful air emissions, high levels of greenhouse gasses, toxic waste, accidents, and other health and safety-related concerns. From fossil fuel extraction to final waste product disposal, the entire production process damages these communities and numerous others. Across the board, incineration is one of the most polluting and expensive waste disposal systems.
Industry often greenwashes incineration as “waste-to-energy” despite producing minimal amounts of usable energy and leverages this greenwashing to access billions of dollars in federal, state, and local green, renewable, and sustainable energy subsidies and tax breaks. Against this backdrop, the Biden Administration signed the Inflation Reduction Act (IRA) into law on August 16, 2022. Many agencies are already approving and funding false solutions under the IRA. The Department of Energy (DOE) is funding new carbon capture programs at nearly $3.5 billion and allocating $1.2 billion of Justice40 money to develop direct air capture facilities. We are in a pivotal moment where the US must decide if it will take critical steps to lower greenhouse gas and toxic emissions and move toward a truly sustainable future or will continue to subsidize the dirtiest industries to annually emit millions of tonnes of new CO2 and other dangerous air pollutants.
IRA Overview
The Biden Administration claims its 755-page IRA is the most comprehensive climate bill in US history that is supposed to “make a historic commitment to build a new clean energy economy.” Its provisions on climate change mitigation, clean energy, and energy innovation dominate headlines, as it raises nearly $800 billion from multiple sources. President Biden said, “With this law, the American people won and the special interests lost.” To ensure this is true and stop the incinerator lobby and other special interests from cashing in on a new pool of taxpayer money, the federal government must implement critical changes to its business-as-usual model.
The IRA is primarily a tax bill. Of the promised $369 billion in climate investments, $270 billion will come in the form of tax credits. Before the IRA, Congress awarded tax credits to specific technologies (including incinerators) regardless of greenhouse gas emissions or community harm. Beginning in 2025, however, their eligibility will depend entirely on the Department of Treasury (Treasury) determining that they are zero-emission technologies. By measuring the lifecycle climate impacts of incineration accurately, Treasury can deny polluting facilities billions in tax credits intended for actual sustainable energy solutions and ultimately delay or block their construction or expansion.
Threats & False Solutions
Lifelines to Old, Failing Incinerators
Corporate polluters are corrupting the IRA, lobbying to weaken its rules and definitions to qualify for billions in new subsidies to expand and retrofit existing incinerators, most of which have been operating for an average of 32 years. It is nearly impossible to construct new conventional incinerators due to cost and community opposition, so industry is focused on expansion and modification. If industry succeeds in propping up incinerators for 20 years, they will produce 637.7 million tonnes of climate-change-inducing CO2e emissions and further exacerbate toxic pollution and environmental racism.
Codifying False and Greenwashed Definitions
The incinerator lobby’s goal is to maximize subsidies, profits, and expansion and to use the IRA and other climate bills as a subsidized path to an undeserved sustainable image upgrade. In the context of the IRA, federal agencies such as the Treasury, the Department of Energy (DOE), and the Environmental Protection Agency (EPA) can either categorize incineration as the dirty, expensive, polluting process it is or bolster industry’s claims that incineration produces sustainable energy. If the federal government supports industry’s definitions in the earliest stages of IRA implementation, they will frame agency action and provide billions in tax credits, likely being codified for many climate laws, including the IRA.
IRA Breakdown & Opportunities for the Incinerator Lobby
The incinerator lobby is working to undermine all aspects of the IRA, specifically focusing on (1) the Renewable Fuel Standard (RFS), (2) Sustainable Aviation Fuel (SAF), and (3) IRA lending programs.
Renewable Fuel Standard (RFS)
In consultation with the Department of Agriculture and DOE, EPA implements the Renewable Fuel Standard (RFS) program. The RFS program is a “national policy that requires a certain volume of renewable fuel to replace or reduce the quantity of petroleum-based transportation fuel, heating oil, or jet fuel.” The four renewable fuel categories under the RFS are biomass-based diesel, cellulosic biofuel, advanced biofuel, and total renewable fuel. Although long limited to liquid fuels like ethanol, Biden’s EPA is in the process of allowing electricity from certain types of bioenergy to generate eligible credits. Under the current proposal, electric vehicle manufacturers would contract with power producers to generate highly profitable RFS credits.
Pairing new subsidies for incinerators with incentives for EVs is perverse. While support for electric vehicles is vital, it must not be fueled by dirty energy nor sacrifice frontline and fenceline communities. Incinerator interests recently launched a lobbying campaign to secure these incentives. Fortunately, EPA is not required to allow incinerator electricity into the program and has recently tabled an industry-backed eligibility proposal. But, only public pressure on Biden’s EPA and key Administration climate deciders will ensure they don’t approve such proposals.
Sustainable Aviation Fuel (SAF)
As one of the most generous IRA incentives, the Sustainable Aviation Fuel Tax Credit (SAF) poses an urgent environmental justice concern. The credit increases in value for lower lifecycle emissions fuels. Treasury’s implementation will determine if this approach succeeds or fails. Industry interests are pushing to make the credit friendlier– and more lucrative–to a new generation of incinerators masquerading behind greenwashing like “pyrolysis,” “chemical or advanced recycling,” and “plastic-to-fuel.” Turning waste, including fossil fuel-derived plastics, into jet fuel is dangerous and does not decarbonize air travel.
Although the new aviation production tax credit theoretically excludes petroleum-based feedstocks like plastic, industry is pressuring the Administration to interpret the law to maximize benefits for incineration-based aviation fuels. President Biden and Treasury must decisively determine that plastic-derived fuel — including that derived from pyrolysis oil or any other product of chemical recycling/pyrolysis/gasification — is ineligible for these tax credits.
Lending Programs
The IRA allocated billions of new dollars to EPA and DOE, in particular, to expand existing lending programs and launch entirely new ones. Like the rest of the IRA, these programs’ climate and justice benefits depend on implementation. EPA is in charge of the new Greenhouse Gas Reduction Fund (GGRF), arguably the most important non-tax provision of the IRA. Worth $37 billion, it will be divided into three separate programs. EPA released broad, unenforceable guidelines in April 2023, suggesting they will focus lending on distributed generation, building decarbonization, and transport. These guidelines will not ensure the money is appropriately allocated, so EPA must prioritize applicants working on proven zero waste approaches.
DOE is in charge of The Energy Infrastructure Reinvestment (EIR) Program, a new loan guarantee program with $250 billion that must be spent before 2026. It can fund energy infrastructure upgrades and the reopening of defunct energy infrastructure, both of which industry could coopt to support their ongoing incineration and chemical recycling plans. DOE must refuse to consider any incinerator applications to guarantee industry does not use loopholes to access clean energy tax credits.
In July, the Republican-led House Appropriations Committee passed the Interior, Environment, and Related Agencies budget for Fiscal Year 2024. Their budget supports chemical recycling while cutting massive amounts from EPA’s budget and the IRA’s environmental justice efforts, including a nearly $4 billion EPA budget cut (a 39% reduction over 2023), reneging on the IRA’s $1.35 billion promised in environmental and climate justice grants.
Call to Action
The incinerator lobby is so desperate for money and a government-greenwashed reputation that they launched a new, big-money–astroturf5 network, including DC power brokers and local government enablers. The combined movements6 for climate justice don’t have industry money, but we have people power, the truth, and a prime opportunity to fight against this industry push. There are three key areas in which to counter industry’s agenda: (1) Treasury engagement, (2) state-level renewable portfolio standards, and (3) IRA lending subsidies.
Treasury Engagement
As the Washington Post exposed in May 2023, the incinerator industry is among polluting industries racing to position themselves as green to access billions in subsidies and tax credits. In the last year alone, industry launched two trade groups to push their message: the Waste-to-Energy Association and the Circular Economy Coalition. Both have made comments to access benefits for incinerators under the Inflation Reduction Act, or considered prioritizing it. Industry is dedicated to getting Treasury to qualify incinerators as renewable, despite overwhelming evidence that incinerators are extremely polluting.
It is critical to engage with Treasury as it develops policies, rules, regulations, and procedures to implement the IRA. If Treasury determines this most costly and polluting form of energy is zero emission, it will set an appallingly low bar within the IRA that will exacerbate rather than address the climate crisis, perpetuating and compounding the issues we currently face, and permanently scarring the Biden Administration legacy.
State-level Renewable Portfolio Standards
The IRA has broad implications, reaching far beyond the federal level of government. Defeating federal government incinerator giveaways in the IRA and other federal climate initiatives will strengthen communities fighting state and local government incinerator giveaways. Currently, different states provide a patchwork of policies and incentives related to incineration. Perhaps most notable are state Renewable Portfolio Standards (RPS). Twenty-nine states, the District of Columbia, and four US territories have an RPS. Each RPS has its own renewable electricity targets, defines what technologies qualify as renewable, designates particular technologies as higher or lower tier within the mix, and enables the trading or sale of renewable energy credits. Two-thirds of US incinerators are located in the 26 US states and territories that include incineration in their renewable energy portfolio. Showing industry’s power, scope, and connections at both the federal and state levels of government. It also shows an entrenched mentality that incineration is a clean energy solution. It is imperative that the IRA does not follow suit.
IRA Lending Subsidies
Along with Treasury engagement, environmental justice, frontline, and fenceline groups should consider applying to IRA lending programs. The Greenhouse Gas Reduction Fund (GGRF) and DOE’s Energy Infrastructure Reinvestment (EIR) Program offers billions of dollars for projects specifically meant to drive reinvestment in low-wealth and environmental justice communities. Both programs provide an opportunity to fund proven zero waste solutions that push back against false solutions, like incineration.
The Greenhouse Gas Reduction Fund (GGRF): The GGRFis a $27 billion investment program designed to achieve the following: “ (1) Reduce greenhouse gas emissions and other air pollutants; (2) deliver benefits of greenhouse gas, and air pollution-reducing projects specifically to low-wealth and disadvantaged communities; and (3) mobilize financing and private capital to stimulate additional deployment of greenhouse gas and air pollution reducing projects.” The GGRF is being implemented via three grant competitions, which include: (1) the National Clean Investment Fund, (2) the Clean Communities Investment Accelerator, and (3) the Solar for All Fund.”7
The National Clean Investment Fund: “The National Clean Investment Fund competition will provide grants to 2-3 national nonprofit clean financing institutions7 capable of partnering with the private sector to provide accessible, affordable financing for tens of thousands of clean technology projects across the country.” To learn more about the program and how to apply, visit Grants.gov. Application packages must be submitted on or before October 12, 2023, at 11:59 PM (Eastern Time) through Grants.gov.
The Clean Communities Investment Accelerator: “The Clean Communities Investment Accelerator competition will provide grants to 2-7 hub nonprofits that will, in turn, deliver funding and technical assistance to build the clean financing capacity of local community lenders working in low-wealth and disadvantaged communities so that underinvested communities have the capital they need to deploy clean technology projects.” To learn more about the program and how to apply, visit Grants.gov. Application packages must be submitted on or before October 12, 2023, at 11:59 PM (Eastern Time) through Grants.gov.
DOE Energy Infrastructure Reinvestment (EIR) Program: “The EIR Program provides $250 billion for projects that retool, repower, repurpose, or replace energy infrastructure that has ceased operations or enable operating energy infrastructure to avoid, reduce, utilize, or sequester air pollutants or greenhouse gas emissions.” To learn more about the program and how to apply, visit Energy.gov. Individuals interested in applying should request a no-cost pre-application consultation with a member from DOE’s Loan Programs Office.
USDA Empowering Rural America (New ERA) Program: “The ERA program provides $9.7 billion for projects that help rural Americans transition to clean, affordable, and reliable energy intending to improve health outcomes and lower energy costs for people in rural communities.” To learn more about the program and how to apply, visit USDA.gov. Individuals interested in applying should submit a Letter of Interest (LOI) by September 15, 2023.
Conclusion
On paper, the Biden Administration’s IRA may be the most comprehensive climate legislation in history, but it also has the immense potential to be a climate destroyer. We are at a crossroads where the Administration and all other levels of government have the power to use the IRA for its stated purpose to “confront the existential threat of the climate crisis and set forth a new era of American innovation and ingenuity to lower consumer costs and drive the global clean energy economy forward.” To make the promise a reality, the Administration — including all the executive agencies, particularly Treasury, Energy, and EPA — cannot succumb to industry greenwashing lobbying.
The Biden Administration must accurately measure the lifecycle climate and health impacts of all forms of incineration and its products (including pyrolysis and gasification) and unequivocally determine that it is not a source of clean energy or a safe way to make jet fuel. It will be up to our ever-expanding movement to hold the Administration accountable to the ideal of the IRA and ensure it is not another greenwashed handout to industry — and that its tax credits and funding go to sustainable solutions that benefit the Black, brown, indigenous, and low wealth communities as it initially intended.
For more information on the Inflation Reduction Act and its lending programs, visit our fact sheet here.
Resources
- The Inflation Reduction Act Fact Sheet, GAIA
- Burning trash for the planet? Climate cash sets off branding frenzy, The Washington Post
- Waste Incinerators Undermine Clean Energy Goals Fact Sheet, GAIA
- Zero Waste to Zero Emissions Report, GAIA
- Incinerators: Myths vs. Facts about “Waste to Energy”
- White House press release: Building a Clean Energy Economy: A Guidebook to the Inflation Reduction Act’s Investments in Clean Energy and Climate Action
- EPA rule boosts biofuel, drops electric vehicle proposal, Politico Pro
- As a tax bill, the categories and definitions of processes are critical because they will determine if a process is covered under it. Historically, there have been some good and some bad determinative definitions (including currently for chemical recycling). ↩︎
- Industry refers to the plastics, incinerator, fossil fuel, and chemical industries who are all perpetuating the plastic waste problem ↩︎
- Industry labels waste-to-energy (WTE) a number of different ways including: plastic-to-fuel (PTF), plastic-to-energy (PTE), refuse-derived-fuel, etc. ↩︎
- This is entirely dependent on if the federal government places incinerators into favorable categories for purposes of massive amounts of tax credits and de facto subsidies. ↩︎
- Astroturfing is the practice of hiding the sponsors of a message or organization (e.g., political, advertising, religious, or public relations) to make it appear as though it originates from, and is supported by, grassroots participants. ↩︎
- The movement includes, but is not limited to – and is always open to expand – the environmental justice movement, climate movement, conservation movement, public health movement, plastics movement, etc. ↩︎
- The deadline for the Solar for All Competition has recently been extended to October 12, 2023. Please review this link for additional information: https://www.epa.gov/newsreleases/biden-harris-administration-launches-7-billion-solar-all-grant-competition-fund#:~:text=The%20Solar%20for%20All%20competition,%2C%20Tribal%20governments%2C%20municipalities%2C%20and ↩︎