Dr. Marco J. Castaldi, Principal Investigator of the Combustion and Catalysis Laboratory and Professor at The City College of New York, recently submitted a public comment to the U.S. Environmental Protection Agency (EPA) regarding a proposed rule addressing air curtain incinerators and related solid waste combustion units.
The comment was co-authored with Dr. Rachel A. Meidl, Deputy Director and Fellow at the Baker Institute for Public Policy at Rice University. Together, Dr. Castaldi and Dr. Meidl provide technical context on the distinction between combustion-based processes and non-combustion thermal conversion technologies such as pyrolysis.
The proposed rule, titled Standards for Air Curtain Incinerators that Only Burn Wood Wastes, Yard Wastes and Clean Lumber; Provision for Commercial and Industrial Solid Waste Incineration Units: Temporary Use Incinerators and Air Curtain Incinerators Used in Disaster Recovery, is associated with EPA Docket ID EPA-HQ-OAR-2025-0068-0001.
In the comment, Dr. Castaldi and Dr. Meidl emphasize that incineration and air curtain incineration rely on combustion, while pyrolysis occurs under oxygen-limited or oxygen-free conditions and produces hydrocarbon products that may retain value as chemical feedstocks or manufacturing inputs.
This distinction is important where regulatory classifications depend on whether a process is defined as combustion under Section 129 of the Clean Air Act. The comment encourages EPA to evaluate technologies based on operating conditions, outputs, and system-level performance rather than categorical assumptions, and to use terminology that reflects meaningful technical differences among thermal processes.
By contributing technical expertise to the rulemaking process, CCL continues to support science- and engineering-based approaches to waste management, resource recovery, and environmental regulation.
Read the full comment here:
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