Please join California Communities Against Toxics and Citizens for Safe Water Around Badger (CSWAB) in calling for a national BAN on open burning PFAS and hazardous munitions wastes.

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President Joe Biden
The White House
1600 Pennsylvania Avenue
Washington DC 20460

Michael Regan, Administrator
United States Environmental Protection Agency
1200 Pennsylvania Ave
Washington DC 20460

June XX, 2024

RE: Banning the Open Air Burning of PFAS and Hazardous Munitions Wastes

Dear President Biden and Administrator Regan,

The open burning of hazardous waste must end.  Americans, especially our nation’s veterans, are keenly aware of the dangers of this practice, yet the Environmental Protection Agency (EPA) and the Department of Defense (DOD) are still allowing it to occur at over 60 sites across our nation. This Administration has the opportunity to end this terribly destructive and damaging practice, and we are urging you to act now.

When EPA adopted the regulations implementing the Resource Conservation and Recovery Act (RCRA), which was designed to protect public health and the environment from the nation’s waste, EPA recognized the obvious need to ban the open burning of hazardous wastes. However, at the request of the Department of Defense, EPA allowed a narrow exception for the open burning/open detonation of explosive hazardous wastes only until safe alternatives could be found…that was nearly a half century ago

Today, advanced treatment technologies to replace OB/OD are available and in use, and have been, for many years.  A coalition of communities living near these sites asked EPA to issue a new rule banning this archaic practice. Instead, EPA has now proposed a rule that, while including certain minimum necessary requirements, does not ban the open burning of hazardous waste or adequately protect human health and the environment.

Disappointingly, the agency’s proposal even envisions new loopholes that will only serve to perpetuate the serious pollution problems communities face. For example, EPA threatens to exempt certain types of hazardous waste incinerators­ from longstanding necessary pollution protections promised by RCRA and the Clean Air Act. It is crucial to transition from open burning to safe and controlled treatment technologies, but communities cannot be forced to accept deregulated and dangerous hazardous waste incinerators as the solution.

Insensitive munitions contain large amounts of PFAS chemicals.  Increasingly, the munitions manufactured by the U.S. are insensitive munitions.  These munitions should not be open burned or incinerated since these types of thermal treatments are not a proven method of destruction for these highly toxic compounds.  There are advanced treatment methods available to destroy these compounds and both EPA and the DOD should be looking to implement these for PFAS destruction.

Open burning of hazardous waste spews toxic fumes into the open air, putting workers, communities, and the environment at serious risk. The remediation costs from contaminated soils and groundwater at open burn sites now runs into the billions of dollars. Many sites have extensive contamination that is very costly to remediate and presents threats of serious public health and environmental harm.

We urge you to simply ban the open burning of hazardous waste and reject the creation of any new regulatory loopholes. It is within your authority to do so and incentivize use of better, modern technologies, and it will save our nation the heartbreak of further damaging the environment and health of communities, including our nation’s service members, from exposure to toxic pollution.

Sincerely,
As noted above, to add your group please fill out this FORM.

Co-signers so far include…
California Communities Against Toxics Rosemond CA
Citizens for Safe Water Around Badger (CSWAB) Merrimac WI
350 Bay Area Action Oakland California
350 Seattle Seattle WA
7th Generation Advisors Los Angeles California
Air Alliance Houston Houston TX
Alaska Community Action on Toxics Anchorage Alaska
Animals Are Sentient Beings, Inc Watertown Massachusetts
Beaverdam Creek Watershed Watch Group Greenbelt MD
Benicians for a Safe and Healthy Community Benicia CA
Beyond Plastics Bennington Vermont
Breathe Project Pittsburgh PA
Buckeye Environmental Network Columbus OH
Californians Against Waste Sacramento CA
Carrizo/Comecrudo Tribal Nation of Texas Floresville TX
Cease Fire Campaign Merrimac WI
Center for Public Environmental Oversight Mountain View California
Central Louisiana Coalition for a Clean& Healthy Environment Colfax Louisiana
Cherokee Concerned Citizens Pascagoula Mississippi
Citizens for Alternatives to Radioactive Dumping Dixon NM
Clean Air Action Network of Glens Falls Glens Falls NY
Clean Water Action Council of NE WI Green Bay WI
Climate Action Campaign at the Humboldt UU Fellowship Bayside CA
Climate Reality Massachusetts Southcoast Fairhaven MA
CODEPINK Bay Area Berkeley California
Common Ground Rising Albuquerque New Mexico
Concerned Citizens for Nuclear Safety Santa Fe NM
Cosmic Poetry Sanctuary Vancleave MS
Dallas Peace and Justice Center Dallas TX
Demand Nuclear Abolition Albuquerque New Mexico
Don’t Waste Arizona Phoenix Arizona
Earth Action, Inc. Fort Walton Beach Florida
Earthjustice Washington D.C.
EcoMadres Washington, DC National
EIP Austin Texas
Endangered Species Coalition Litchfield ME
Environmental Justice Ministry Cedar Lane Unitarian Universalist Congregation Bethesda Maryland
EverythingShaquana | Web-Based Nonprofit Brooklyn NY
FreshWater Accountability Project Grand Rapids OH
GAIA (Global Alliance for Incinerator Alternatives) Berkeley CA
George AFB – HTRW Jamestown CA
Good Neighbor Steering Committee of Benicia Benicia California
Grassroots Environmental Education Port Washington New York
Green Delaware Port Penn DE
Green Science Policy Institute Berkeley California
Greenaction for Health and Environmental Justice San Francisco California
Greenpeace USA Washington DC
GreenRoots Chelsea MA
Honor Our Pueblo Existence (HOPE) Santa Clara Pueblo, Espanola New Mexico
Human Nature Petrolia california
IIS Interdisciplinary Institute for Sciences Amherst MA
International Dialogue on Underwater Munitions Glace Bay Nova Scotia, Canada
Institute for Local Self-Reliance Washington DC
International Dialogues on Underwater Munitions (IDUM) Glace Bay Nova Scotia
Kentucky Environmental Foundation Berea KY
Merrimack Citizens for Clean Water Merrimack NH
Micah Six Eight Mission Sulphur Louisiana
Milwaukee Riverkeeper Milwaukee WI
Moms Clean Air Force Washington, DC and National DC
Mossville Environmental Action Now MEAN Lake Charles Louisiana
MoveOn.org HobokenRESIST Hoboken New Jersey
Nicaragua Center for Community Action Berkeley CA
Non Commissioned Officers Association (NCOA) Selma Texas
NY/NJ Environmental Watch New York New York
Occidental Arts and Ecology Center Occidental CA
Parents Against SSFL Los Angeles CA
Pennsylvania Interfaith Power & Light Lancaster PA
Physicians for Social Responsibility/Florida Tampa Florida
Plastic Free Future Pacifica California
Plastic Pollution Coalition Washingtion DC
Project Outreach: The Frac Sand Sentinel Chippewa Falls Wisconsin
Protect All Children’s Environment Chapel Hill North Carolina
Protect Biodiversity in Public Forests Cincinnati Ohio
Protect Our Water, Heritage, Rights Pembroke Virginia
Prutehi Litekyan Save Ritidian Hagatna Guam
Putnam Progressives Putnam N.Y.
Rachel Carson Council Bethesda Maryland
RootsAction.org Sacramento California
SEE (Social Eco Education) Los Ángeles County Ca
Snake River Alliance Boise Idaho
South Baltimore Community Land Trust Baltimore Maryland
Stand Up/Save Lives Campaign Burr Ridge IL
Sustainable Tucson Tucson AZ
Terra Advocati San Antonio Texas
Texas Campaign for the Environment Austin TX
The Last Plastic Straw Aguadilla PR
The Quantum Institute Glovesville New York
The Revolving Door Project New York New York
The Story of Stuff Project Berkeley California
Therapists for Peace & Justice Oakland CA
Tribal Enviromental Watch Alliance Santa Fe NM
Tri-Valley Communities Against a Radioactive Environment (CAREs) Livermore CA
Turtle Island Restoration Network Galveston Texas
unaffiliated Petoskey MI
Unitarian Universalist Environmental Justice Ministry Chevy Chase Maryland
Valley Watch, Inc. Evansville IN
Vermont PFAS/Military Poisons Coalition Winooski Vermont
Vessel Project of Louisiana Sulphur Louisiana
Veterans for Peace Madison Madison WISCONSIN
Vidas Viequenses Valen Vieques Puerto Rico, 00765
Vote Climate Minneapolis MN
WaSaTi Blockclub Detroit Mi
Waste Action Project Kent WA
West Plains Water Coalition Spokane Washington
Westfield Residents Advocating For Themselves Inc (WRAFT) Westfield MA
Wisconsin Resources Protection Council La Crosse Wisconsin
Zero Waste Ithaca | BYO – US Reduces Ithaca New York
Zero Waste Washington Seattle WA

As noted above, to add your group please fill out this FORM