ACTION ITEM: Chula Vista Sustainability Commission supporting plastics to diesel

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Mar 13, 2022, 4:02:31 PMMar 13
Hello Zero Waste Advocates,

Our friends from the City of Chula Vista are looking for us to help stop this Waste Plastic Reprocessing plant from coming to our community.

Please send comments on this proposal to:  before Monday, March 14th at 4:00pm.


Laura Anthony
Zero Waste San Diego

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---------- Forwarded message ---------
Hi Zero Waste friends,


I’m going to need your help with this one!


The City of Chula Vista’s Sustainability Commission accepted a presentation last month from Enerra, a company that is proposing to “convert” plastics into diesel and other chemical elements. Despite mine and other staff’s attempt to convey that this proposal does not fit with in our circular model of managing materials and certainly not in our zero waste plan. They accepted the company’s concept and will be voting this Monday, March 14 to send a recommendation to City Council in support, (letter and agenda attached).


Enerra is making the rounds, expect them to come to cities near you with similar proposals, the Cities of Palmdale, Bloomington and Salinas are already in agreements for bond financing through the California Pollution Control Financing Authority which is different from their claims assuring that they were fully funded and do not require partnering jurisdiction financial support.  


Feel free to send comments on this proposal to: in time for the meeting.  


Thank you.

Cooperative Agreement for Plastic Waste Reprocessing.pdf
2022-03-14 SSC Agenda DRAFT.docx

Mar 14, 2022, 3:21:53 PMMar 14
to Laura,,,

Dear Laura and all,


Thank you for raising this request for support to stop a plastic to fuel project in Southern California. This reminds me of dozens of similar projects that have been stopped in California and many other states over the past two decades! Here’s a lot of detail that will be helpful to anyone having to deal with hype from Big Oil or companies like this, organized into the following sections:


  1. plastic to fuel is incineration – key consequences, drawbacks, data on similar U.S. facilities, links to resources opposing this from NRDC, GAIA, WWF
  2. Reuters Special Report calls this approach “littered with failure”
  3. Questions to ask any facility
  4. Quick observations based on the extremely limited information on the company’s website


Burning plastic as fuel is incineration & widely opposed by NRDC, WWF, GAIA, Break Free From Plastic movement, and many others

Overwhelmingly, the movement to break free from plastic opposes plastic to fuel. This is another way to burn / incinerate plastic. In many cases, industry is using terms like “chemical recycling,” “advanced recycling,” “plastic to fuel” interchangeably, and in most cases are using gasification incineration or pyrolysis incineration. Despite the industry hype, there are extensive environmental and health drawbacks as described in this new GAIA factsheet “Plastic to Fuel: A Losing Proposition”

  • Plastic-to-fuel produces poor-quality fuels
  • Plastic-to-fuel exacerbates climate change
  • Plastic-to-fuel produces toxic air emissions and byproducts
  • Plastic-to-fuel has wasted billions of dollars
  • Plastic-to-fuel perpetuates overproduction of plastic


Just last week a new NRDC report found of similar operating or proposed U.S. facilities:  (also see article here)

  • The majority of facilities are not recycling any plastic
  • The facilities generate large quantities of hazardous waste;
  • They release hazardous air pollutants
  • They are often in communities that are disproportionately low income, people of color, or both


The NRDC report concluded:

"Using pyrolysis and gasification to convert plastic into fuel should not be considered recycling, and recycling standards must continue to exclude such processes. Plastic-to-fuel is not considered recycling by ISO standards, the EU Environmental Commission, the Ellen MacArthur Foundation, and many other groups. Despite the fact that plastic-to-fuel does not recycle plastic, the industry continues to strongly support it. This is likely because plastic-to-fuel creates a mirage of “recycling” to assuage public concerns about increased plastic use and waste but does not disrupt new plastic production. This paves the way for continued profits and the expansion of plastic production facilities. Ensuring that plastic-to-fuel remains excluded from official definitions of recycling will make it difficult for plastic manufacturers to succeed in this greenwashing."


WWF’s January 2022 position paper states

  • “Plastic-to-fuel activities should not be considered recycling, nor a part of the circular economy.”
  • “Based on currently available evidence, there are significant concerns that these technologies are energy-intensive, pose risks to human health, and/or will not be able to practically recycle plastic beyond what mechanical recycling already achieves.”


Additional resources: GAIA has several technical analyses, reports about facilities in U.S., funds wasted on failed gasification & pyrolysis over the years, and more here:



Reuters Special Report calls this approach “littered with failure”

A Reuters Special Report called “Big Oil’s Solution for Plastic Waste is Littered with Failure” documented several failed similar projects in the United States, including Renewlogy, the company associated with Dow Chemical’s “Energy Bag” program (which appears to have changed course away from plastic to fuel).



Questions we should ask when confronted with plastic to fuel / incinerator projects (on page 9 of this factsheet).

  1. What is the type of technology used in the facility? Has it been proven to work under real-world operating conditions, or just in a laboratory? Has this process been employed at this scale elsewhere?
  2. What is the energy balance of the process and how will it be measured and tracked? What is the carbon balance and how will it be monitored?
  3. What are expected emissions and how will they be monitored and reported?
  4. Which types of feedstock has it been tested on? How much feedstock will be sourced, from which communities?
  5. What are the outputs of the process, including main products and byproducts? How will the ash, wastewater, spent solvent, and residual waste be managed? Will any residual waste be sent to incinerators or cement kilns?
  6. Are the products to be burned on-site or transported to a different location? How will the emissions be monitored off-site?
  7. How will the project be funded? If through public funds, are there other projects that could have been funded for the community to move toward zero waste?
  8. How close is the facility location to marginalized communities or populated neighborhoods? Are there any concerns about causing disproportionate harm to environmental justice communities?



Observations based on the extremely limited information on the company’s website


  1. The “technical information” section of the website contains zero technical information. What type of high heat process is this company proposing? Is it gasification or pyrolysis? Or something else? Since nearly every recent proposal is gasification or pyrolysis, and since the company provided no information about the actual process, this is highly likely to be gasification incineration or pyrolysis incineration, holding the resulting waste streams, and burning those waste streams in other locations.
  2. The website says “All Types of Plastic Waste: Designed to process all 7 types of plastic and to handle multiple combined types of plastics at once.” PVC is plastic #3. Dioxins and other hazardous pollutants are formed as chlorine in PVC (polyvinyl chloride) is in the range of 450-850 Celsius, and if higher heat is used, the PVC and other chemicals will have to pass through that temperature range while heating up and cooling down. What will happen to the chlorine, bromine, other hazardous chemicals that form toxic products of incomplete combustion during the first stage of the process, and during the second stage of the process (direct combustion of waste fuel).
  3. The website claims “Closed-Loop System: No harmful emissions produced.” As anyone who has tracked gasification and pyrolysis and related high heat incinerator approaches over the years has observed, this is a classic distraction from the ultimate burning of the resulting waste fuels. Where will the resulting waste fuels be burned? Who will be affected? Who will be monitoring those emissions?
  4. The website claims this is “renewable energy.” Even if this is not a high heat technology, plastic-to-fuel perpetuates overproduction of plastic, and potential impacts on surrounding communities during operations and burning of fuel must be prevented.


We are happy to be available as resources on this issue, and hope Chula Vista will focus on waste prevention strategies like reuse systems, refill programs, and other waste reduction approaches.




Monica Wilson (she/her), Associate Director/Global Programs Coordinator

GAIA U.S. Office | Berkeley, CA USA | | NEW work phone: +1-510-735-8938

Connect with us! Facebook | @GAIAnoburn | @monicazerowaste | Check out GAIA’s new website!

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Neil Seldman

Mar 14, 2022, 3:25:50 PMMar 14
to, Laura,,,

Thanks for this particular response and for the extraordinary work on this issue by GAIA. The work on Zero Waste alternatives around the world is another remarkable contribution.

Be well and safe.  Neil

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Neil Seldman
Waste to Wealth Initiative
Institute for Local Self-Reliance
1200 18th Street, NW
Washington, DC 20036

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