A bombshell study by the Centre for Financial Accountability (CFA) has revealed that Delhi's four Waste-to-Energy (WTE) incineration plants score a staggering 100 out of 100 on the Central Pollution Control Board's (CPCB) own Pollution Index — making them more toxic than coal-fired power plants, open-cast coal mining, and copper smelters — yet the regulator quietly moved them into a newly created "Blue" category last year that strips away critical environmental safeguards.
The report, titled "100/100 Pollution Score: Why Waste-to-Energy Incineration Plants Don't Belong in the 'Blue' Category" and authored by researcher Surbhi Shukla, uses exclusively CPCB's own data, joint inspection reports with the Delhi Pollution Control Committee (DPCC), and regulatory submissions before the National Green Tribunal (NGT) and Supreme Court to demolish the scientific basis for the reclassification.
The "Blue" Category: A Regulatory Shield for the Most Polluting Industry
In January 2025, the CPCB introduced an unprecedented fifth tier in its industry classification framework — the "Blue" category — reserved for facilities designated as "Essential Environmental Services" (EES) managing domestic waste. Unlike the Red, Orange, Green, and White categories, which are pegged to specific Pollution Index score ranges, the Blue category operates entirely outside the 0–100 scoring system.
The practical consequences are severe. As the report documents, Blue category facilities receive:
- Consent to Operate (CTO) renewals of up to 7 years (versus 5 years for other categories)
- Self-assessment of their own Pollution Index scores — a structural conflict of interest
- A proposed removal of prior Environmental Clearance (EC) requirements, eliminating mandatory Environmental Impact Assessments (EIA) and public hearings
"The Blue category does not assign a PI range. Facilities in Blue are not bound by the 0–100 scoring system that governs every other category," the report states. "This creates a regulatory blind spot for facilities with documented PI scores of 97.6 (according to the CPCB) or 100 (according to our analysis)."
100/100: The "Perfect Storm" of Pollution
Using the CPCB's own Excel-based Pollution Index methodology, the study evaluated Delhi's four operational WTE plants — Okhla, Ghazipur, Bawana (Narela-Bawana), and Tehkhand — which collectively burn approximately 7,250 tonnes per day of unsegregated municipal solid waste.
The Pollution Index formula averages three components: Water Pollution (PIW), Air Pollution (PIA), and Hazardous Waste (PIH). The study's findings:
- Water Pollution (PIW): 95/100 — Driven by BOD and COD exceedances, heavy metals including hexavalent chromium and copper, and massive effluent generation exceeding 500 cubic metres per day.
- Air Pollution (PIA): 100/100 — Maxed out due to emissions of dioxins, furans, and mercury in the "Deadly" group, plus nitrogen oxides, sulphur dioxide, and massive fuel consumption.
- Hazardous Waste (PIH): 95/100 — Near-maximum score from generating over 5,000 tonnes per year of hazardous ash; fly ash remains highly toxic even after stabilization.
- Cumulative PI: 100/100 — Firmly within the Red category, which has a threshold of 80 or above.
The report highlights a critical discrepancy: "CPCB has given a cumulative PI score of 97.6 out of 100 but our analysis, using their data, shows that the cumulative PI for WTEs is 100 out of 100." The study argues that by documenting the score as 97.6 instead of 100, the CPCB avoids admitting that WTE plants have reached the absolute maximum "ceiling" of pollution potential.
A comparative chart in the report places WTE plants at the top of India's most polluting industries:
- WTE Plants (CFA Analysis): 100
- Open-cast Coal Mining (CPCB): 97.5
- Underground Coal Mining (CPCB): 93
- Copper Smelter (CPCB): 90
- Thermal Power Plants (CPCB): 85
The CPCB's own directions state that the Blue category is for "Essential Environmental Services which do not generate Hazardous Waste." Yet the study documents that WTE plants are massive producers of hazardous waste.
The four Delhi plants generate an estimated 1,450–2,100 tonnes per day of fly ash and bottom ash — material laced with heavy metals including cadmium, lead, mercury, manganese, arsenic, and copper. A five-year New York Times investigation cited in the report found incinerator ash with:
- Cadmium: 19 times higher than safe thresholds
- Manganese: 11 times higher
- Arsenic: 10 times higher
- Lead: 4 times higher
"Even after stabilization, the leftover ash is considered highly toxic," the report notes. The Okhla plant alone generates approximately 390–400 tonnes per day of ash, while the Bawana plant — the largest at 2,400 TPD capacity — produces 480–720 tonnes per day.
The study also flags that CPCB's 2025 monitoring report to the NGT confirmed that none of the 21 WTE facilities operating across India are compliant with all monitored emission parameters, most notably dioxins, furans, and heavy metals.
Plant-by-Plant: Documented Violations
The report provides granular evidence for each facility, drawn from joint CPCB-DPCC monitoring reports and NGT submissions:
Okhla WTE Plant (South-East Delhi)
- Operator: Timarpur-Okhla Waste Management Company Limited (Jindal Group)
- Capacity: 1,950–2,000 TPD
- Dioxin levels recorded at 900% above prescribed limits during CPCB inspection
- Located as close as 35–40 metres from residential housing
- The New York Times found the plant impacted the health of more than 1 million people
Ghazipur WTE Plant (East Delhi)
- Operator: Ever Enviro Resource Management Pvt. Ltd.
- Capacity: 1,300 TPD
- Dioxin and furan levels exceeding limits by 270%
- OCEMS (Online Continuous Emissions Monitoring System) data did not match CPCB's independent readings
- Operated for extended periods without valid Consent to Operate
Bawana (Narela-Bawana) WTE Plant (North Delhi)
- Operator: Delhi MSW Solutions Ltd.
- Capacity: 2,400 TPD (largest in Delhi)
- Dioxin, furan, and cadmium+thallium levels exceeded stack emission norms
- Fly ash confirmed to exceed regulatory limits for cadmium, manganese, lead, and copper
- Groundwater exceedances for TDS, hardness, sulphates, nitrates, and phenolic compounds
Tehkhand WTE Plant (South Delhi)
- Operator: South Delhi Municipal Corporation
- Capacity: 2,000 TPD
- Treated effluent exceeded norms for chloride and phenolic compounds
- Fugitive emissions from waste handling and ash storage documented
The "Bluewashing" Process: Industry Capture of Regulation
The report delivers a scathing indictment of the regulatory process behind the Blue category's creation. The 2023 draft classification report did not include the Blue category at all. It was introduced via an addendum on July 11, 2024, with only a 30-day comment window.
Of the 161 representations received during the 2023 consultation, 76% came from industry associations, only 1% from civil society organizations, and none from impacted communities. For the July 2024 addendum, only 9 comments were received, and the representations were never made public.
"The transition to the Blue category reflects significant 'regulatory capture' by the industry lobby, which dominated over 75% of the CPCB's consultation process while environmental groups were largely excluded," the report states. "By rebranding high-pollution incineration as an 'Essential Environmental Service,' the industry lobby successfully secured a regulatory shield that protects the most polluting industry in India from strict oversight, high compliance costs, and public scrutiny."
Expansion Plans Amidst Toxic RealityThe study warns that Delhi is not merely maintaining these facilities but aggressively expanding them. By 2027, the city plans to burn 14,250 tonnes of garbage per day — nearly double current capacity — through:
- Expanding Okhla and Tehkhand to 3,000 TPD each
- New Ghazipur plant at 2,000 TPD
- New Narela-Bawana plant at 3,000 TPD
Additional incinerators are planned in Bhandwari, Ghaziabad, Sonepat, and Ambala in the National Capital Region.
"These facilities are also climate regressive, emitting 68% more greenhouse gases per unit of energy than coal plants," the report notes. "The diversion of public money towards WTEs effectively starves genuine, cost-effective circular economy initiatives and sustainable renewables such as biogas plants."
A Call to Reverse the "Blue" Classification
The report's conclusion is unequivocal: "The classification of WTE plants as 'Blue' is scientifically indefensible and inconsistent with the precautionary principle."
It demands that WTE incineration be returned to the Red category — where it belongs based on its 100/100 Pollution Index score — ensuring stringent monitoring, frequent inspections, and full regulatory oversight.
"The 'Blue' classification of WTE plants is not merely a technical error but a fundamental policy failure that prioritizes administrative convenience over human life," the report warns. "By 'bluewashing' these facilities, the state effectively sanctions the most 'toxic industry' to continue its operation by dismantling existing environmental and health safeguards."
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