Trash Incineration and Climate Change: Debunking EPA Misinformation

Trash incin­er­a­tion is incred­i­bly bad for the cli­mate, releas­ing 2.5 times as much car­bon diox­ide CO2 to make the same amount of elec­tric­i­ty as a coal pow­er plant. This is evi­denced by nation­al data com­piled by the U.S. Envi­ron­men­tal Pro­tec­tion Agency (EPA) in their eGRID database.

How­ev­er, the indus­try, with the sup­port of the EPA, uses cre­ative account­ing to make it seem as if the trash incin­er­a­tion indus­try is actu­al­ly a cli­mate solu­tion. It’s impor­tant to under­stand their account­ing tricks. First, if you look at the actu­al amount of CO2 com­ing out of smoke­stacks from trash incin­er­a­tors vs. oth­er sources, it’s obvi­ous that they’re the worst of the lot. This is based on our analy­sis of EPA’s eGRID data:

 Note that the nat­ur­al gas emis­sions are far low­er than they would be if you fac­tor in methane leaks through­out the sys­tem, which make their glob­al warm­ing impacts far worse than coal.  More on that on our nat­ur­al gas page.

This gets at the issue of a life-cycle assess­ment approach.  The EPA has con­ve­nient­ly cho­sen not to look at the life cycle of nat­ur­al gas in set­ting poli­cies like the Clean Pow­er Plan, which inap­pro­pri­ate­ly encour­ages a switch from coal to gas as a cli­mate solu­tion.  Con­verse­ly, they opt to use a life-cycle assess­ment approach to make trash and bio­mass incin­er­a­tion emis­sions look low­er than coal, propos­ing them as solu­tions in the Clean Pow­er Plan and oth­er poli­cies.  In doing this, EPA is encour­ag­ing a switch from coal to fuels worse for the cli­mate than coal, in the name of reduc­ing green­house gas emissions.

Here are the ways that EPA down­plays the green­house gas emis­sions from incineration:

  • Ignor­ing “bio­genic” car­bon emissions
  • Sub­tract­ing avoid­ed methane emis­sions from land­fills, as if con­ven­tion­al land­fills are the only alternative
  • Sub­tract­ing emis­sions from off­set­ting fos­sil fuels for ener­gy generation
  • Sub­tract­ing emis­sions due to recy­cling of met­als that remain in the ash after combustion
  • Sub­tract­ing emis­sions from avoid­ing long-dis­tance trans­porta­tion to landfills

In bend­ing over back­wards to make trash incin­er­a­tion look envi­ron­men­tal­ly prefer­able, EPA also mis­leads the pub­lic about the indus­try’s emis­sions of mer­cury, nitro­gen oxides (NOx), volatile organ­ic com­pounds (VOCs), par­tic­u­late mat­ter (PM), car­bon monox­ide, and haz­ardous air pol­lu­tants (HAPs).  EPA shows com­par­isons of the total amount of these pol­lu­tants released in the U.S., rather than adjust­ing for the mas­sive dif­fer­ence in the size and num­ber of facil­i­ties.  The aver­age coal pow­er plant in the U.S. is 873 megawatts (MW), and the aver­age trash incin­er­a­tor only 39 MW.  As of late 2016, there are about 370 coal pow­er plants remain­ing and just 77 trash incin­er­a­tors.  To do a fair com­par­i­son of how pol­lut­ing a fuel type is, one must look at the amount of pol­lu­tion per unit of ener­gy pro­duced.  We did hon­est com­par­isons of trash incin­er­a­tors to coal pow­er plants, and found that incin­er­a­tors are dirt­i­er than coal on every mea­sure for which data is avail­able.  To make the same amount of ener­gy as a coal pow­er plant, trash incin­er­a­tors release 28 times as much diox­in than coal, 2.5 times as much car­bon diox­ide (CO2), twice as much car­bon monox­ide, three times as much nitro­gen oxides (NOx), 6–14 times as much mer­cury, near­ly six times as much lead and 70% more sul­fur dioxides.

To their cred­it, EPA does eval­u­ate CO2 emis­sions from trash incin­er­a­tors on a “per unit of ener­gy” basis, but not for the oth­er pol­lu­tants.  With CO2 emis­sions, EPA uses oth­er meth­ods (out­lined above) to down­play the indus­try’s impacts.  Here’s why it’s inap­pro­pri­ate to make the assump­tions that EPA (and the indus­try) makes:

Ignor­ing “bio­genic” car­bon emissions

Almost half of the munic­i­pal sol­id waste (trash) stream is con­sid­ered to be “bio­genic” — mean­ing that it’s ulti­mate­ly made from plants, such as food scraps, paper, wood, or even from ani­mals, like leather.  Slight­ly more than half is the fos­sil frac­tion (the burn­ing of plas­tics, syn­thet­ic rub­ber, etc.).  For many years, EPA and oth­ers have assumed that CO2 released from burn­ing the bio­genic frac­tion should not be count­ed because it’s “car­bon neu­tral” since plants and trees regrow.  This has been thor­ough­ly debunked in recent years.  It depends on many flawed assump­tions, such as the idea that new plants and trees are plant­ed that would­n’t oth­er­wise be grow­ing, and that this addi­tion­al growth off­sets incin­er­a­tor CO2 emis­sions instant­ly.  The first major study to debunk this (com­mis­sioned by the Com­mon­wealth of Mass­a­chu­setts in 2010) showed that the 50% high­er emis­sions from burn­ing trees com­pared to coal takes an aver­age of 45 years to be sucked back up from new­ly-grow­ing trees.  After those 45 years, the emis­sions aren’t zero or neu­tral, but are equal to coal.  It would take hun­dreds of years of new­ly-grow­ing trees that would­n’t oth­er­wise be grow­ing, and being left alone all that time, to approach car­bon neu­tral­i­ty.  We don’t have that sort of time to avert the worst impacts of cli­mate change.  See our write­up debunk­ing bio­mass car­bon neu­tral­i­ty for an overview of the sci­ence on this.

Sub­tract­ing avoid­ed methane emis­sions from land­fills, as if con­ven­tion­al land­fills are the only alternative

Con­ven­tion­al land­fills are not the only alter­na­tive.  A prop­er zero waste sys­tem can divert over 90% of dis­card­ed mate­ri­als from incin­er­a­tors and land­fills, and would involve bio­log­i­cal­ly sta­bi­liz­ing the remain­ing waste before land­fill­ing avoid­ing the cli­mate emis­sions asso­ci­at­ed with con­ven­tion­al land­fills.  Doing this prop­er­ly ensures that the methane gen­er­at­ing poten­tial from organ­ic mate­ri­als in trash is removed in an enclosed envi­ron­ment where the methane can be cap­tured much more effec­tive­ly than in an open-air land­fill.  See this report on the best dis­pos­al option for the “left­overs” on the way to zero waste.

Sub­tract­ing emis­sions from off­set­ting fos­sil fuels for ener­gy generation

It’s inap­pro­pri­ate to sub­tract emis­sions from fos­sil fuels that might oth­er­wise be burned for elec­tric­i­ty.  Doing so is like allow­ing a wind farm with zero CO2 emis­sions claim that their actu­al emis­sions are neg­a­tive because a coal or gas pow­er plant is not run­ning as hard.  The zero emis­sions from wind are a ben­e­fit enough, with­out hav­ing to use accou­t­ing tricks to make them seem bet­ter than they already are.

Also, it’s arbi­trary to assume that fos­sil fuels, or even the aver­age elec­tric grid CO2 mix is being dis­placed.  It’s a cur­rent real­i­ty that trash incin­er­a­tion com­petes with oth­er renew­able ener­gy sources with­in state and fed­er­al renew­able ener­gy man­dates and incen­tives.  Espe­cial­ly in a state like Mary­land, where trash incin­er­a­tion is put on the same tier as wind pow­er in the state renew­able ener­gy man­date, trash incin­er­a­tion com­petes most direct­ly with wind and oth­er renew­ables, than with fos­sil fuels.

Sub­tract­ing emis­sions due to recy­cling of met­als that remain in the ash after combustion

Met­als can more prop­er­ly be recy­cled if divert­ed before hit­ting a dis­pos­al facil­i­ty like an incin­er­a­tor or land­fill.  Count­ing the ener­gy sav­ings from met­al recy­cling as a means to down­play actu­al CO2 emis­sions from incin­er­a­tors is a stretch.

Sub­tract­ing emis­sions from avoid­ing long-dis­tance trans­porta­tion to landfills

There are near­ly 1,200 oper­at­ing land­fills in the U.S. and only 76 trash incin­er­a­tors.  While cer­tain cities are clos­er to incin­er­a­tors than near­by land­fills, this is very site-spe­cif­ic, and is gen­er­al­ly mis­lead­ing to assume that trans­porta­tion to land­fills is very long-dis­tance.  Also, long-dis­tance truck­ing of waste to incin­er­a­tors is not unusual.


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