Trash Incineration More Polluting than Coal

To make the same amount of energy as a coal power plant, trash incinerators in 2018 released 1.7 times as much carbon dioxide (CO2), as much carbon monoxide, three times as much nitrogen oxides (NOx), five times as much mercury, nearly six times as much lead and 27 times more hydrochloric acid (HCl).

Chart: Number of times more polluting trash incineration is compared to coal

Trash incinerators are the dirtiest way to make electricity by most air pollution measures. Even with air pollution control equipment, trash incinerators emit more pollution than (largely uncontrolled) coal power plants per unit of energy produced. Coal power plants are widely understood as the most air-polluting energy source, but few realize how much worse trash incinerators are for air quality.

This is not a radical conclusion. The New York State Department of Environmental Conservation proved, in a 2011 analysis, that the state’s 10 trash incinerators are dirtier than the 8 coal-burning power plants that were still operating at the time (all of the coal power plants have since closed, but the 10 incinerators remain). Besides sulfur dioxide, trash incinerators are dirtier than coal on all other pollutants the state compared.[1] See the chart at the bottom of this page for the summarized New York data.

Dioxins/furans: Trash incinerators are well known to be the largest source of the most toxic man-made chemicals known to science – dioxins. The latest national inventory of dioxin emissions – by the U.S. Environmental Protection Agency in 2006, looking at data from 1987, 1995, and 2000 – shows that trash incineration has gone from the largest source of dioxin emissions in 1987 and 1995 to the 4th largest source in 2000. However, if one accounts for the lack of continuous monitoring and the consequent massive underestimation of dioxin emissions from incineration, trash incineration is still the largest source of dioxins, despite the cleanup or closure of some of the dirtiest incinerators.[2]

Between 2000 and 2005, new dioxin emissions limits were implemented for trash incinerators, requiring the worst dioxin polluting incinerators to clean up or shut down. EPA and the trash incinerator industry tout that dioxin emissions from trash incinerators have been reduced by over 99% between 1990 and 2005. Even with this large reduction, and without even accounting for the aforementioned underestimation from lack of continuous monitoring, trash incinerators release 28 times as much dioxin than coal power plants do to produce the same amount of energy.[2],[3],[4]

Mercury is another notoriously toxic pollutant released from incinerators. It is a potent neurotoxin that accumulates in the fatty tissue of fish once in the environment. Mercury emissions from trash incineration were a close second to coal power plants in the early 1990s, which is rather incredible given the much larger size of coal power plants and the fact that there are about five times as many coal plants as incinerators. Pollution controls required on trash incinerators reduced the industry's mercury emissions 96% by 2005.[5] However, even with this dramatic industry-wide reduction, trash incineration still put out 5.3 times as much mercury as coal plants do to produce the same amount of energy, according to the latest available national data from 2018.[5] A state-wide analysis by the New York State Department of Environmental Conservation found that, in 2009, the state’s 10 trash incinerators released 14 times as much mercury per unit of energy than the state’s 8 coal power plants – high enough that the total amount of mercury coming from the incinerators was higher than the emissions from the coal plants, even without adjusting for size (coal plants are far larger facilities).[1]

Lead is another well-known toxin that diminishes intelligence and – by lowering dopamine levels in the brain – may even be tied to increases in violent behavior and cocaine addiction.[6],[7],[8] Trash incineration releases more than six times as much lead as coal to produce the same amount of energy.[5]

Nitrogen oxide (NOx) pollution primarily contributes to eye, nose, throat, and lung irritation and respiratory problems like shortness of breath that can trigger asthma. Trash incineration releases 3.3 times as much NOx as coal does to produce the same amount of energy.[15]


Carbon monoxide (CO) is also released from trash incinerators at rates comparable coal power plants per 1 MWh of energy produced.[5] Both NOx (directly) and CO (indirectly) contribute to the formation of ground-level ozone pollution, aggravating asthma.[10],[11]

Sulfur dioxide (SO2) – famous as a cause of acid rain – is also bad for lungs, with even short exposures to ambient levels causing “bronchoconstriction and increased asthma symptoms.”[12] SO2 is one of the rare pollutants where coal plants are worse. Coal plants release two times more SO2 as trash incinerationbsp;to produce the same amount of energy.[15],[5]

Hydrochloric Acid (HCl) is linked to acute bronchitis and lung cancer.[16] Trash incineration releases a whopping 27 times more HCl than coal plants to produce the same amount of energy.[5]

Carbon dioxide (CO2) – the prime global warming pollutant – is released at a rate between 1.7 and 2.5 times that of coal power plants.[9],[15] Between 2007 and 2012, EPA reported that incineration released 2.5 times more CO2 than coal plants to create the same amount of energy.[10] Inexplicably, after 2014, EPA reports that trash incinerators released 1.7 times more CO2.[15] There are no carbon dioxide pollution controls for trash incinerators -- only the composition of MSW burned (i.e. the amount of plastic in the waste stream, the wetness of waste) changes the emissions. Roughly the same amount of waste was burned (in tons) to produce 1 MWh of energy in 2012 and 2014.[17] This rules out the explanation that an increase of plastic in the stream of MSW being burned is the culprit (plastics are essentially oil... it burns well and provides a lot of energy value, so the MWh and the efficiency would increase). Through preliminary discussions with EPA, we have learned that most CO2 data in eGRID (which our analysis is based on) is estimated from emissions factors (and is not "real" data). The emissions factors changed between 2012 and 2014, effectively reducing CO2 emissions for trash incinerators but not coal plants. We are in talks with EPA to determine why the emissions factors changed and how we can analyze "real" data. However, even with the reduced emissions factors, trash incineration is still substantially worse than coal.

The industry argues that the "biogenic" portion of CO2 emissions (that from burning paper and other organic material) should not count because trees will regrow and take the CO2 back out of the air.[13] However, studies of the alleged "carbon neutrality" of biomass incineration have shown that biomass is not truly carbon neutral, as it can take many decades for trees to reabsorb the pulse of CO2 emitted by incineration – meanwhile, the climate is heating up at a higher rate.[15] This also presumes that somewhere, trees are being replanted in sufficient numbers to eventually take up this extra carbon pollution (and that those trees aren’t being counted toward offsetting some other climate damage… and that the trees will not be cut back down as soon as it’s profitable to use them). Even if one accepts EPA’s assumption that carbon trapped in a tree is the same as carbon in the air and that the “biogenic” carbon emissions from incinerators should be counted as zero, the fossil portion of the emissions from trash incinerators (such as that from burning plastics) is still comparable to the CO2 emissions from burning coal.


Comparision of pollutants with the strongest data

Using 2018 interim NEI data [5], we conducted a robust analysis of over 73 pollutants tracked by NEI that were emitted and tracked across many different types of power plants (biomass burners, gas plants, oil plants, etc.). From there, we eliminated pollutants that had less than 25 facilities reporting emissions (since an outlier could significantly change data) and pollutants based on modeled data. Using reliability scores (with a reliability score of 1 representing a verified measurement and a score of 5 representing the lowest data quality) from EPA's peer-reviewed StEWI software [18], we further restricted the pollutants to those with reliability scores of 1, 2, 3 ensuring that we were only comparing pollutants with verified measurements and calculations.

Pollutant Coal emissions (lbs/MWh) Coal Data Points Incinerator emissions (lbs/MWh) Incinerator Data Points x times worse than coal
Lead 4.0E-05 186 2.5E-04 42 6.2
Mercury 7.8E-06 188 4.0E-05 41 5.2
Benzene 3.2E-04 159 1.1E-03 30 3.3
Nitrogen oxides 1.5E+00 220 4.9E+00 51 3.3
Toluene 7.1E-05 148 2.0E-04 30 2.8
Cadmium 1.0E-05 189 2.4E-05 40 2.4
Carbon Monoxide 7.0E-01 189 7.1E-01 42 1.0
PM2.5 Primary 3.1E-01 189 1.6E-01 42 0.5
Nickel 6.3E-05 188 2.5E-05 32 0.4
Sulfur dioxide 2.1E+00 220 7.6E-01 51 0.4

Comparison of incinerators versus coal plants

As you can see, trash incineration is worse (or as bad) than coal for 9 out of the 12 pollutants compared.

[The 2018 data above is from US EPA's National Emissions Inventory (NEI) and Emissions & Generation Resource Integrated Database (eGRID). Our spreadsheet, used to produce the charts above, is available here.]

Summary of New York Department of Environmental Conservation analysis

Chart of New York Department of Environmental Conservation comparison data showing trash incineration is far more polluting than coal



  1. New York State Department of Environmental Conservation, “Matter of the Application of Covanta Energy Corporation for Inclusion of Energy from Waste Facilities as an Eligible Technology in the Main Tier of the Renewable Portfolio Standard Program. Case No. 03-E-0188,” Aug. 19, 2011.{DEEA097E-A9A6-4E53-898C-0BC2F4C60CC4}
  2. “An Inventory of Sources and Environmental Releases of Dioxin-Like Compounds in the United States for the Years 1987, 1995, and 2000,” U.S. EPA, November 2006, Table ES-2. The largest sources in 2000 are considered to be backyard burn barrels (498.5 grams), followed by medical waste incineration (378 g), sewage sludge applied to land and emissions from sludge incineration (89.7 g) and trash incineration (83.8 g). The backyard burn barrel estimate is not subject to drastic differences based on test methods. 95% of medical waste incinerators have closed between 2000 and 2009. Most of the sewage sludge dioxin emissions are from land application rather than sludge incineration (since far more is dumped on farm fields than is burned). EPA admits in their inventory report (p 3-23): “Because all tests were conducted under normal operating conditions, some uncertainty exists about the magnitude of emissions that may have occurred during other conditions (e.g., upset conditions, start up, and shut down).” If the medical waste, sludge incineration and trash incineration numbers are adjusted upwards by 30-50 times to account for the fact that a 6-hour stack test each year underestimates dioxin emissions by this amount, compared to using continuous monitoring (and if the aforementioned differences in the medical waste and sludge incineration data are accounted for), trash incineration would still be the largest dioxin pollution source by far. A newer study from the Netherlands (data from 2015 to 2017) found that actual dioxin emissions are 460-1,290 times higher than stack tests indicate. See Arkenbout, A, Olie K, Esbensen, KH. "Emission regimes of POPs of a Dutch incinerator: regulated, measured and hidden issues"
  3. U.S. Environmental Protection Agency, Emissions & Generation Resource Integrated Database, eGRID2002 and eGRID2007 (for 2000 and 2005 electric generation data).
  4. “Emissions from Large and Small MWC Units at MACT Compliance,” U.S. Environmental Protection Agency memorandum, August 10, 2007.
  5. United States Environmental Protection Agency (EPA). 2018. "National Emissions Inventory (NEI)" Interim 2018 data accessed from the Emissions Inventory System (EIS) Gateway via EPA's Standardized Release and Waste Inventories (StEWI) python module. Data parsed and aggregated using EPA's peer-reviewed methodology.
  6. Canfield, et. al., “Intellectual Impairment in Children with Blood Lead Concentrations below 10 micrograms per Deciliter,” N Engl J Med 2003; 348:1517-1526, April 17, 2003.
  7. Lidsky and Schneider, “Lead neurotoxicity in children: basic mechanisms and clinical correlates,” Oxford Journals, Medicine, Brain, Volume 126, Issue 1, Pp. 5-19, 2002. (lead exposure increases aggression)
  8. Nation, Smith & Bratton, “Early developmental lead exposure increases sensitivity to cocaine in a self-administration paradigm,” Pharmacol Biochem Behav. 2004 Jan; 77(1):127-35.
  9. U.S. Environmental Protection Agency, Emissions & Generation Resource Integrated Database, eGRID Version 1.0, 9th Edition, (2010 data), released February 24, 2014.  Data summarized and analyzed by Energy Justice Network here:
  10. U.S. Environmental Protection Agency, (NOx)
  11. Kowalska, Ma?gorzata et al. “Effect of NOx and NO2 Concentration Increase in Ambient Air to Daily Bronchitis and Asthma Exacerbation, Silesian Voivodeship in Poland.” International journal of environmental research and public health vol. 17,3 754. 24 Jan. 2020, doi:10.3390/ijerph17030754
  12. EPA
  13. Lisa Gibson, ‘Good News for Forest Biomass,’ Biomass Magazine, 1/25/2012.
  14. Studies compiled here:
  15. United States Environmental Protection Agency (EPA). 2022. “Emissions & Generation Resource Integrated Database (eGRID), 2020” Washington, DC: Office of Atmospheric Programs, Clean Air Markets Division. Available from EPA’s eGRID web site: Data analyzed using methodology documented here:
  16. The Collaborative on Health and the Environment. "Toxicant and Disease Database - hydrochloric acid" showcategory=&showdisease=&showcontaminant=2651&showcas=&showkeyword=
  17. United States Energy Information Administration (EIA). 2022. "Form EIA-923 detailed data with previous form data (EIA-906/920)" Available from EIA's web site:
  18. Young, Ben, et al. “A System for Standardizing and Combining U.S. Environmental Protection Agency Emissions and Waste Inventory Data.” Applied Sciences, vol. 12, no. 7, Mar. 2022, p. 3447. Crossref,