NACEJ Statement: Revoke Dangerous Deregulation of Toxic Waste-to-Energy Incinerators: No to Blue Category, No to EC Exemption !
napm india
Revoke Deregulation of Toxic Waste-to-Energy Incinerators
No to Blue Category, No to EC Exemption!
9th Nov, 2025: The National Alliance for Climate and Ecological Justice (NACEJ), a pan-Indian forum of the National Alliance of People’s Movements (NAPM), comprising grassroots community activists, ecologists, climate scientists, environmental researchers and lawyers are deeply concerned at the MoEF & CC’s recent decision to exempt Waste-to-Energy (WTE) incinerators from prior Environmental Clearance (EC) under the EIA Notification, 2006.
We also strongly object to the CPCB’s re-classification of WTE plants from the ‘Red’ to ‘Blue’ category! While endangering public health, these decisions would exacerbate environmental pollution, climate impacts and adversely affect the livelihoods of millions of waste workers across the country. These decisions of the Central Govt are patently anti-people and anti-ecology.
We call upon the MoEF & CC, CPCB and other relevant authorities to immediately revoke the EC Exemption of October 2025, re-classify WTE into the Red category; recognizing their hazardous waste output, end subsidies and ‘renewable energy’ status to WTEs, initiate independent, transparent public studies on WTE's effects and embrace circular solutions such as shifting to source segregation, decentralized composting, recycling, single-use plastic bans, and reduced consumption.
We express profound alarm and outrage over the Central Government's recent draft notification (S.O. 4531(E), dated October 3, 2025) proposing to exempt Common Municipal Solid Waste Management Facilities (CMSWMFs) – explicitly including Waste-to-Energy (WTE) incinerators – from prior Environmental Clearance (EC) under the Environment Impact Assessment (EIA) Notification, 2006. This move, comes on top of the Central Pollution Control Board's (CPCB) recent re-classification of WTE plants into the lax "Blue" category under the guise of providing ‘essential environmental services’, from the earlier “red” category.
We join all other civil society organizations, waste workers' collectives and communities, environmental justice groups, public health advocates and concerned citizens in demanding an immediate revocation of these disastrous decisions.
A Pattern of Reckless Deregulation:
The CPCB's "Blue" reclassification falsely portrays WTE incinerators as benign "Essential Environmental Services" despite their generation of vast quantities of hazardous bottom and fly ash requiring secured landfilling. Inspections by CPCB itself have documented high levels of heavy metals and toxic chemicals in ash and leachate from Delhi's WTE plants, contradicting the claim that these facilities produce no hazardous waste. Furthermore, CPCB reports submitted to the National Green Tribunal have shown how none of the 21 existing WTE plants are compliant with the Solid Waste Management Rules, 2016.
Now, the Ministry of Environment, Forest and Climate Change (MoEFCC) seeks to strip away even the minimal oversight of prior Environmental Clearance. This exemption ignores the Expert Advisory Committee's own 2017 clarification that landfills in CMSWMFs require EC, and it undermines the stringent monitoring under the Water and Air Acts, 1974 and 1981, as touted in the notification. These steps defeat the spirit of the Solid Waste Management Rules, 2016, which mandate source segregation and circular economy principles. Instead, they greenwash incineration as "waste-to-wealth," while enabling the diversion of recyclable materials and against the principles of circular economy.
Grave Concerns Amplified by Deregulation:
1. Health and Environmental Risks: WTE incinerators spew dioxins, furans, SOx, NOx, HCl, and heavy metals, contributing to respiratory diseases, asthma, cancers, and vulnerabilities for children and pregnant women – impacts well-documented in Delhi. Exempting EC will accelerate unchecked emissions, leachate contamination, and soil pollution, turning neighborhoods into toxic zones.
2. Livelihood Threats: Diverting recyclables such as paper, cardboard, plastics and textiles etc. to WTE incinerators will devastate this informal sector, pushing workers into poverty impacting more than 4 million waste workers in India[1].
3. Financial Burden: WTE electricity costs over ₹7/unit – far costlier than solar or wind at under ₹3.3/unit – saddling taxpayers with subsidies for inefficient, polluting technology.
4. Climate Catastrophe: Burning every ton of waste in an incinerator releases about 1.7 tons of CO2 and Delhi's four WTEs emit CO2 equivalent to 30 lakh passenger cars. These plants emit more climate emissions per unit of electricity produced than coal and the Climate Action Plans of cities like Chennai and Mumbai have clearly rejected WTE as a waste management solution.
5. Technical Infeasibility: India's Municipal Solid Waste (MSW) is 60% biodegradable with low calorific value and high moisture – unsuitable for incineration, as confirmed by CSIR-NEERI's NGT submission.
The flawed ‘public consultation’ for the Blue category also highlights the power of industry lobbying as there was less than 1% representation from environmental groups, waste workers’ collectives and civil society organizations in the consultation and over 75% representation from the industry!
Our Demands: We demand immediate action to protect people and planet:
1. Revoke the EC Exemption: Withdraw the October 2025 draft notification and restore prior, mandatory Environmental Clearance (EC) for all CMSWMFs, including WTEs with landfills.
2. Reclassify WTE as Red: Immediately revert WTE incinerators to the "Red" category, recognizing their hazardous waste output.
3. End Subsidies and Renewable energy Status: Remove WTE from ‘renewable energy’ lists, as it burns fossil-fuel-derived plastics, and halt all financial incentives.
4. Transparent Impact Studies: Commission independent, public studies on WTE's effects on air quality, health, environment, and climate; establish real-time monitoring for existing plants.
5. Embrace Circular Solutions: Shift to source segregation, decentralized composting, recycling, single-use plastic bans, and reduced consumption – cheaper, effective, and job-creating alternatives.
We call on the MoEFCC, CPCB, and the Parliament of India to heed science, concerns of communities, and the precautionary principle. Waste management must serve people and the planet, not polluters and profiteers.
Join us in this movement – sign petitions, amplify on social media (#NoBlueWTE #RevokeECExemption), and demand accountability. Together, we can and must build a toxic-free, just future for all.
Signatories to the Statement: NACEJ Members:
1. Alok Shukla, Chhattisgarh Bachao Andolan, Raipur
2. Amitraj Deshmukh, NACEJ, Pune, Maharashtra
3. Anasuya Kale Chhabrani, Swacch Association, Nagpur, Maharashtra
4. Apoorv Grover, People for Aravalis, New Delhi
5. Dr. Babu Rao, Scientists for People, Telangana
6. Bhanumathi Kalluri, Dhaatri Trust, Telangana
7. Chythenyen Devika Kulasekaran, Centre for Financial Accountability, Selam, Tamil Nadu
8. Dr. Gabriele Dietrich, Penn Urimay Iyakkam &NAPM, Madurai, Tamil Nadu
9. John Michael, NAPM Telangana
10. Krithika Dinesh, Legal researcher, Delhi
11. Medha Patkar, Narmada Bachao Andolan and NAPM, Madhya Pradesh
12. Meenakshi Kapoor, Researcher, Himachal Pradesh
13. Meera Sanghamitra, NACEJ Telangana
14. Moncy M Thomas, Librarian and Environmentalist, Trivandrum, Kerala
15. Neelam Ahluwalia, Founder Member, People for Aravallis, Haryana
16. Nirmala Gowda, Mapping Malnad, Bengaluru
17. Prasad Chacko, Social Worker, Ahmedabad, Gujarat
18. Rajesh Ramakrishnan, Chennai Climate Action Group, Chennai
19. Ramnarayan K, Natural History Educator, Uttarakhand
20. Ravi S P, Chalakudy puzha Samrakshana Samithi, Kerala
21. Shreekumar, Activist, Sangatya, Udupi, Karnataka
22. Simran Grover, Environmental and Energy Researcher, Rajasthan
23. Soumya Dutta, Movement for Advancing Understanding of Sustainability and Mutuality (MAUSAM), NACEJ, New Delhi
24. Stella James, Researcher, Bengaluru
25. Dr. Suhas Kolhekar, NAPM & NACEJ (Pune, Maharashtra)
26. Sunil M. Caleb, Environmental Activist, Kolkata.
27. Tarini, Independent Filmmaker, Delhi
Issued by: National Alliance for Climate and Ecological Justice (NACEJ - NAPM)
Contact for details: E-mail: nacej...@gmail.com
NACEJ members across India are grassroots movement activists, ecologists, climate scientists, environmental researchers and lawyers, working to address Climate Crisis, through an Ecological and Social Justice Approach, upholding human rights and co-existence of all species.