Administrator Michael S. Regan
Environmental Protection Agency – 1101A
ATTN: EPA PFAS Action Council
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
(202) 564-4700

September 30, 2021

Dear Administrator Regan,

In order to protect the health of site workers, service members and neighboring communities, we are requesting an immediate halt to the open air burning and detonation of PFAS and hazardous waste currently permitted by the U.S. EPA or allowed to operate under interim status without a permit.

Pyrotechnic compositions of magnesium/Teflon/Viton (MTV) are widely used in military flares and for igniting the solid propellant of a rocket motor, and are comprised of as much as 45% PFAS.

The demilitarization of excess, obsolete, or unserviceable flares and other energetic waste currently relies on open burning and open detonation (OB/OD) – a practice that produces an ongoing uncontrolled release of PFAS and other toxic chemicals to the environment.  

As an imminent and substantial endangerment to public health and the environment, we believe the Administrator has the responsibility to require an immediate national pause to open air burning and detonation of PFAS and other munitions wastes.

Most contaminated military bases and industrial sites are located in rural and often economically-depressed areas where community members have little if any resources to effectively organize and achieve environmental justice.

Moreover, members of the public often hesitate to question the Department of Defense even when their homes and their health may be at great risk. Exempted from many environmental regulations – as in the case of OB/OD – the military continues to be our nation’s largest polluter.  

There are alternatives to open air burning and detonation, as EPA has affirmed and documented, and they can and should be deployed.  

EPA’s current strategy is to issue even more permits which only perpetuates this devastating practice. EPA and Congress must immediately ban routine open air burning and detonation of hazardous waste in the U.S. and its territories in favor of safer advanced technologies.

Sincerely,              

Laura Olah, Citizens for Safe Water Around Badger (CSWAB)
Linda Shosie, Environmental Justice Task Force in Tucson
Brenda Vallee, Central LA Coalition for a Clean & Healthy Environment
Jeffrey Lamont, SOH2O
Kristen Mello, Westfield Residents Advocating For Themselves (WRAFT)
Cheryl Nenn, Milwaukee Riverkeeper
Read Eldred
Dr. Linda Birnbaum, Scientist Emeritus and Former Director, NIEHS and NTP
Pamela Miller, Alaska Community Action on Toxics
Larry Menkes, Veterans Green Jobs Initiative
Craig Williams, Kentucky Environmental Foundation
Tara Thornton, Endangered Species Coalition
Al Gedicks, Wisconsin Resources Protection Council
Laura Olah, Cease Fire Campaign
Brian O'Donnell
Mary Ann Lucking, CORALations Inc.
Elizabeth O'Nan, Protect All Children's Environment
Jane Williams, California Communities Against Toxics
Gretel Munroe
Sonja Stark, Clean Air Coalition of Greater Ravena and Coeymans
David Walker, Lmont-Doherty Earth Observatory
John Blair, Valley Watch
Vicki Berenson, Safe Skies Clean Water Wisconsin
Jane H Kavaloski, Interfaith Peace Working Group
Denise Patel, Global Alliance for Incinerator Alternatives
Gar Smith, Environmentalists Against War
Emily Donovan, Clean Cape Fear
Paul Hancock, Clean Air Action Network
Janet Weil, Veterans For Peace, Climate Crisis and Militarism Project
Linda Engle
Wayne Wenzel, Friends of the Mississippi River
Sue Fenton
Carol Miller, Peaceful Skies Coalition
Ellen Barfield, Phil Berrigan Memorial Chapter Veterans For Peace
Brendan Kelly
...and many more...

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