AMBR Comments to the EPA on Pyrolysis Reclassification

AMBR provided comments on the proposed EPA rule addressing air curtain incinerators (ACIs) and temporary-use incinerators (Docket ID No. EPA–HQ–OAR–2025–0068). We are deeply concerned that elements of this proposal would weaken Clean Air Act protections, reduce oversight of waste combustion, and create pathways for the expansion of pyrolysis and similar thermal processes without appropriate safeguards. These changes risk undermining both public health and the integrity of recycling systems.

Instead we urge the EPA to:

• Maintain full Clean Air Act Section 129 protections for all waste incineration facilities
• Ensure consistent application of Title V permitting requirements to preserve transparency and accountability
• Clearly regulate pyrolysis and similar thermal processes within the incineration framework of Section 129
• Avoid creating regulatory exclusions that weaken oversight of pyrolysis facilities or other combustion technologies
• Prioritize investments in reduction, reuse, and recycling systems
• Conduct a robust environmental justice analysis of cumulative impacts