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Union Power Minister requested to save Koelwar-Bihta residents from chemical weapon like threat of 98 hazardous waste generating industrial units

Written By mediavigil on Monday, September 06, 2021 | 6:20 PM


Shri Raj Kumar Singh 

Hon'ble Cabinet Minister 

Union Ministry of Power, New & Renewable Energy

Government of India

New Delhi

Subject-Urgent Request: Koelwar-Bihta residents face chemical weapon like threat from 98 hazardous waste generating industrial units   


With due respect this is with reference to the above mentioned subject, I wish to draw your urgent attention towards illegitimate construction activity for a hazardous waste and medical waste incineration plant by Hyderabad-based Ramky Enviro Engineers Limited in the river bed of Sone in proximity to residential areas of villages in Koelwar, Bhojpur and Bihita, Patna. It is noteworthy that in a communication sent to Union Environment, Forests and Climate Change (MoEFCC) by Bihar State Pollution Control Board (BSPCB).  BSPCB had informed MoEFCC that most Koilwar, Bhojpur villagers are opposed to the Hyderabad based Ramky company’s proposal for a hazardous waste plant in the river bed of Sone river. The proposal for setting up an Integrated Common Hazardous Waste Treatment, Storage, Disposal and Recycling Facilities by Bihar Waste Management Limited (a Division of M/ s Ramky Enviro Engineers Ltd) at Survey Numbers Plot no: 401, Khata No: 69-68/2, 67/3, Thana no: 107, Mahui Mauza, Koelwar-Jamalpur-Babura-Chhapra road, Bhojpur, near Bihta, Patna is unscientific, anti-public health and anti-environment.  (Photo: A K Jain, ex-Chief Engineer, DVC and Dharmatma Sharma, Paryawaran Swasthya Suraksha Samiti)

In its letter, BSPCB annexed the minutes of the public hearing organised by BSPCB on October 16, 2014. The letter is signed by Shri Rakesh Kumar, Member Secretary, BSPCB and addressed to Dr. Lalit Kapoor, Member Secretary, Experts Appraisal Committee (EAC), MoEFCC. The minutes were signed by Shri Suresh Kumar Sinha, Additional District Magistrate (Upar Samaharta), Bhojpur and the BSPCB Officials, Shri Nand Kumar and Shri S N Jaiswal. It may be noted that Shri Suresh Kumar Sinha, ADM, Bhojpur had addressed the villagers at the public hearing in Jamalpur, Koelwar, Bhojpur on October 16, 2014. The official proceeding of the public hearing is attached

I wish to request you to deny any subsidy to this polluting unit and recommend cancellation of the NOC and Environmental Clearance given to this unit of Ramky company because EAC has been indifferent towards the communication of BSPCB in granting Environmental Clearance (EC) dated December 2, 2015. I submit that this project in question was rejected by EAC in its meeting dated 8-9 November, 2012. The minutes of EAC are available on EAC’s website. The Minutes of the 118th Meeting of the EAC held on 8th-9th November, 2012 reveals that the EAC concluded that M/s Ramky Enviro Engineers Ltd the project “Proponent has not justified selection of the site and also there is a habitation at about 200 m from the site which is not advisable for this type of Hazardous waste handling and incineration activity.” Disregarding its own finding under some misleading influence,  the EAC in its 149th meeting held on 24th- 26th June, 2015, wrongly recommended the project for grant of Environmental Clearance. BSPCB ought to contest the grant of EC by denying/cancelling the NOC to this unit. There is a precedent in this regard in the matter of asbestos based plant in Vaishali wherein BSPCB stood its ground disregarding the report of the Central Pollution Control Board, MoEFCC. The EC records the "Major issues raised during Public Hearing". It reads: "The major issues raised during public hearing are about the air pollution due to the recycling process, burning of waste, groundwater depletion and the presence of water body within 50m from the site boundary and burning of plastic wastes leading to the formation of Dioxins and Furans." The BSPCB official admitted at the public hearing that Bihar does not have any Dioxins testing laboratory. Dioxins were used as chemical weapons in the US-Vietnam war under the brand name Agent orange.  

I submit that BSPCB ought to dispute the contention of the project proponent "the land is not prone to flood and is around 1.25km away from Sone River on the western side"  which is a manifest case of fraudulent misrepresentation of facts after a site visit to verify the veracity of such submission by the company. It is apparent that EAC too has been misled by the company.   

At the public hearing former chief engineer, DVC and noted whistle blower Shri A K Jain questioned the inconsistent claims of the Ramky company about land, water and power by comparing its project with other projects. Shri Jain said that the company has not disclosed that this site is flood proneThis can cause a Bhopal Gas leak like disaster. 

I submit that villagers had expressed their opposition to Ramky's project at the public hearing. Paryawaran Bachao Jeewan Bachao Sangharsh Morcha had written to BSCPCB pointing out the threats posed to residents of villages in Koilwar, Bhojpur and Bihta, Patna from the Dioxins emitting plant. Villagers have been campaigning against the hazards of hazardous waste dumping and burning. The site in question is in the river bed of Sone river in the vicinity of residential areas of the village in the proximity of the main road in an area of 57.24 acres. 

I submit that residents will not allow the setting up of a hazardous waste incineration plant proposed in the area next to a village along the Sone river to incinerate 50,000 tonnes waste/month. The hazardous waste generated from 98 industrial units in various parts of Bihar would be transported to the proposed unit for burning, according to the proposal for the “integrated common hazardous waste treatment” plant. The villagers have learnt that the officials of Ramky Enviro Limited blatantly lied about the use of the site to purchase land. The company officials had informed the villagers that iron rods would be manufactured in the plant. Villagers have formed an association, Paryavarn Bachao Jeevan Bachao Sangharsh Morcha (PBJBSM), to oppose the construction of the plant. The association in its petition has demanded that the venue of the proposed unit be shifted from their locality to an industrial area. 

I submit that burning of hazardous wastes would have long-term health impacts on people and can lead to lung and stomach cancers. In the aftermath of the industrial disaster of Bhopal, the Government of India banned establishment of such plants and instructed state governments and pollution control boards to ensure that hazardous plants should not be set up in the vicinity of residential areas. Such industrial waste and medical waste burning units too are quite hazardous.

I submit that a review of epidemiological studies on adverse health effects associated with incineration, says that medical waste incinerators are a leading source of dioxins and mercury in the environment and there is a link between incinerator emissions and adverse health impacts on humans. 

In the public hearing it was submitted by the villagers that Hon'ble Delhi High Court's order in a similar case observed that “Residents living within 10 km of an incinerator, refinery, and waste disposal site” showed “Significant increase in laryngeal cancer in men living with closer proximity to the incinerator and other pollution sources”. It observed that the “Residents living around an incinerator and other pollution sources” showed “Significant increase in lung cancer related specifically to theincinerator”. The “People living within 7.5 km of 72 incinerators” displayed “Risks of all cancers and specifically of stomach, colorectal, liver and lung cancer increased with closer proximity to incinerators”. Hon'ble Delhi High Court, in a judgment delivered in 2013  based on the findings of the study had instructed the government to establish such units away from the human settlements.

Hon'ble Court’s judgment reads: “Both older and more modern incinerators can contribute to the contamination of local soil and vegetation with dioxins and heavy metals. In several European countries, cow's milk from farms located in the vicinity of incinerators has been found to contain elevated levels of dioxin, in some cases above regulatory limits. Increased levels of dioxins have been found in the tissues of residents near to incinerators in the UK, Spain and Japan. At an incinerator in Finland, mercury was increased in the hair of residents living in the vicinity. Children living near a modern incinerator in Spain were found to have elevated levels of urinary thioethers, a biomarker of toxic exposure. It notes that “After 2 years of operation of the incinerator, dioxins levels were found to have increased by about 25% in both groups living between 0.5 to 1.5 and 3.5 to 4.0 km away (201 people) of people. In the repeat analysis, the increase was in the range of 10-15%”.

The judgment records that “Mothers living close to incinerators and crematoria from 1956 to 1993” showed “increased risk of lethal congenital abnormalities, in particular, spinal bifida and heart defects, near incinerators: increased risk of stillbirths and anacephalus near crematoria”.

I submit that Ramky's EIA report is quite misleading. It ignores the nearest schools, hospitals, CRPF camp and the Koilwar railway station. It refers to Ara railway station as the nearest railway station. BSPCB does not have the capacity to test and monitor dioxins emissions. It came to light that BSPCB is not enforcing environmental laws in the 99-125 factories from which hazardous industrial waste is generated which requires disposal and treatment at the palace of their generation.    

Citing these facts at the public hearing held on 16.10.2014 at Ambika Sharan Singh High School, Jamalpur, Post- Naya Mohammadpur, District- Bhojpur, the villagers said that they will pay any price to stop waste from hundreds of factories and thousands of hospitals from coming to Koilwar due to imminent public health crisis the present and future generations of residents of villages on the Babura-Koilwar road in Bhojpur, Bihar. There was unanimous political opposition to Ramky's irresponsible, insensitive, anti-people, ant-environment and anti-health proposal.  I can share the documents and the video of the proceedings of the public hearing given to me by BSPCB under Right to Information Act.  

In view of the above, I earnestly request you to kindly ensure that the construction activity of Ramky company is stopped at the earliest to save residents of Koelwar-Bihta from chemical weapon like threat from 98 hazardous waste generating industrial units and medical waste units.

Thanking you 

Warm Regards

Gopal Krishna, LL.M., Ph.D

Web: www.toxicswatch.org


Security Council resolution on Afghanistan sans China and Russia

Written By mediavigil on Tuesday, August 31, 2021 | 2:00 AM

UN Security Council resolution sans resolution China and Russia

Resolution seeks safe passage for people wanting to get out of Afghanistan

The UN Security Council passed a resolution on 30 August, 2021 that calls for the Taliban to facilitate safe passage for people wanting to leave Afghanistan, allow humanitarians to access the country, and uphold human rights, including for women and children.

Thirteen of the 15 ambassadors voted in favour of the resolution, which further demands that Afghanistan not be used as a shelter for terrorism.

Permanent members China and Russia abstained from voting. 

Countries condemned in the strongest terms the deadly blasts at Kabul airport on 26 August, which killed more than 150 people and injured upwards of 200 more.  The terrorist group Islamic State in Khorosan Province (ISKP) claimed responsibility, according to UN news release.

The attack targeted people fleeing Afghanistan in the wake of the Taliban’s takeover two weeks ago, and international forces assisting the evacuations.

Thousands of Afghans have been trying to escape from the country ahead of the full withdrawal of the USA by its self-imposed 31 August, 2021 deadline.

The resolution was tabled by USA, alongside fellow permanent Council members France and the UK.

“The Security Council expects the Taliban to live up to its commitment to facilitate safe passage for Afghans and foreign nationals who want to leave Afghanistan, whether it’s today, tomorrow, or after August 31,” said US Ambassador Linda Thomas-Greenfield.

“Consistent with the right to leave any country, including one’s own, everybody must be allowed to safely leave Afghanistan, for whatever reason, whenever they want, by air or by land. This is of the utmost importance to us.”

Since July 2021, the USA has evacuated more than 122,000 Americans, foreign nationals and at-risk Afghan citizens, she reported.  Thomas-Greenfield added that the resolution also reflects the Council’s "crystal clear" commitment to assisting those who remain in Afghanistan.

“It underscores that all parties need to facilitate humanitarian assistance, and that humanitarian actors be given full safe and unhindered access to continue service delivery to those in need,” she said.

The resolution takes note of a Taliban statement this week which allows Afghans to leave the country at any time. Nathalie Estival-Broadhurst, Deputy Permanent Representative of France, called for that commitment to be upheld.

“This resolution calls on everyone to make all efforts to secure the airport and the surrounding area.,” she said.

“And to create this safe passage and protection is a sine qua non condition to ensure that threatened Afghans who wish to leave can do so safely, but also to ensure that humanitarian assistance can reach all of those who need it through the airport, of course, but also over land borders.”

On the issue of human rights, UK Ambassador Barbara Woodward emphasized the need to protect gains made over the past two decades, stressing that the rights of women, children and minorities must be safeguarded.

She described the resolution as an important step towards a unified international response to the situation in Afghanistan.  

“We will continue to build on this to ensure the Council holds the Taliban accountable on its commitments. The Taliban will be judged by the international community on the basis of their actions on the ground, not their words,” she stated.

In explaining his vote, Ambassador Vassily Nebenzia said Russia was forced to abstain because certain “principled concerns” were not reflected in the draft text, which was circulated on 27 August, 2021.

“Firstly, despite the fact that the resolution was proposed against the backdrop of a terrible terrorist attack, the authors categorically refused to refer to a passage on the fight against terrorism containing internationally recognized terrorist organizations ISIL and the East Turkistan Islamic Movement,” he said.

“We see this as a reluctance to acknowledge the obvious, and a desire to divide terrorists into ‘ours’ and ‘theirs’; and that is to say, to downplay the terrorist threat coming from these groups."

Ambassador Geng Shuang of China stated that given the fragile situation on the ground, and the uncertainties, any Council action should help ease tensions, and not intensify them.

“The recent chaos in Afghanistan is directly related to the hasty and disorderly withdrawal of foreign troops,” he said.  “We hope that relevant countries will realize the fact that withdrawal is not the end of responsibility, but the beginning of reflection and correction.” 

Meanwhile, on August 31, 2021, Ambassador of India to Qatar, Deepak Mittal, met Sher Mohammad Abbas Stanekzai, the Head of Taliban's Political Office m Doha. The meeting took place at the Embassy of India, Doha to discuss safety, security, and early return of Indian nationals stranded in Afghanistan besides the issue of travel of Afghan nationals, especially minorities,who wish to visit to India, India's concern about the possibility of Afghanistan's soil being used for anti-Indian activities and terrorism. Stanekzai assured India. 


Demand for Cancellation of Public Hearing of waste fuelled thermal power plant in NCR Aravallis

Written By mediavigil on Monday, August 30, 2021 | 8:31 PM


Dr. Sumita Mishra
Haryana State Pollution Control Board (HSPCB) 

Date: 31 August, 2021

Subject: Request for Cancellation of Public Hearing on 31 st August 2021 for Waste to Energy Plant Expansion in the NCR Aravallis 


With due respect this is with reference to the Public Hearing regarding the expansion of the Waste to Energy plant at Bandhwari landfill site in Aravallis from 15 MW to 25 MW on 31 August, 2021.

The public hearing notice issued by the Haryana State Pollution Control board clearly states that the EIA study for the same will be available on the HSPCB website (hspcb.gov.in) and the offices of the Deputy Commissioner of Gurugram, Municipal Corporation Gurugram, Zila Parishad Gurugram and Regional office of the Haryana State Pollution Control Board in Vikash Sadan, Gurugram - along with the Executive Summary. 

When I wrote to Regional Officer, HSPCB in this regard, I did not get any reply. When I called him, I got no response. I have also learnt that when Aravalli Bachao team members spoke to the office of the Deputy Commissioner on the 27 th August 2021 to check if these documents are available with them, they said they do not have these documents in their office when according to the Public Notice these documents should be available in the DC Gurugram’s office for the public to view. 

According to Appendix 4 of the EIA Notification 2006, a copy of the EIA report needs to be made available to the public 30 days prior to the date of the Public Hearing so that sufficient time is given to citizens to study the document and give their views. 

The EIA Notification also states that the Executive Summary of the EIA report needs to be translated in local language and be made available to the public 30 days prior to the date of the Public Hearing. Both these criteria have not been met for the Public Hearing called on 31 st August 2021 for expansion of the waste to energy plant. The required documents were not available on the HSPCB website as late as 26 August, 2021. 

In Covid pandemic times when people are avoiding going to public places, accessing and studying documents online is the safest and most convenient way for citizens to give their suggestions / objections to the said project. 

In blatant violation of the law, HSPCB has failed to give this option to the public. I have learnt that after my letter to the Regional Officef, HSPCB and the Aravalli Bachao team’s visit to the Regional office of HSPCB at Vikash Sadan in Gurugram on 26 August 2021 and after submitting a letter demanding cancellation of the Public Hearing, the next day i.e 27 August 2021 (4 days prior to the date of the Public Hearing scheduled on 31 August 2021), the required documents were uploaded on the HSPCB website. On 30 August, 2021, I submitted to you my preliminary critique of the EIA/EMP. (http://www.toxicswatch.org/2021/08/critique-of-draft-eiaemp-report-of.html?m=1) 

It is crystal clear that instead of the mandatory 30 days period required by law, the HSPCB has given the public only 4 days to go through the hundreds of pages of the EIA report. HSPCB expects citizens to go through the EIA report in just 4 days, analyse its implications and give suggestions / objections on the Public Hearing scheduled on 31st of August 2021. This is quite irrational. It is due to these reasons, that I endorse the citizens' demand for cancellation of this Public Hearing which is in violation of the EIA Notification 2006. 

Having worked on the issue of waste management since 2000, I have reached the conclusion that waste incineration technologies like Refuse Derived Fuel technique is anti-environment, anti-science and anti-public health. It is Dioxins emitting technology. Dioxins was used as a chemical weapon in US-Vietnam war under the brand name Agent Orange. I wish to draw your attention towards the following papers for your perusal and consideration:

1. Why urban waste continues follows the path of least resistance 

2. In india, critics assail proposal to build 100 waste-fuelled power plants

3. Biomass Burning is not Green-Part I

4. Biomass Burning is not Green-Green-Part II

5. Clean India Mission on wrong track 

In view of the above, I seek your considered intervention to stop the project proponent from setting up this tried, tested and failed Refuse Derived Fuel (RDF) technology based thermal plant which is linear, contrary to nature's circular process and is in violation of UN's Stockholm Convention on Persistent Organic Pollutants, UN's Minamata Convention, Paris Agreement and cardinal principles of waste management that paves way for adoption of Zero Waste philosophy.  

Thanking you

Warm Regards
Gopal Krishna, LL.M., Ph.D
ToxicWatch Alliance (TWA) 

Critique of Draft EIA/EMP Report on Expansion of Waste Incineration based Power Plant at Bandhwari, Gurugram

The Public Hearing of Expansion of Waste based Power Plant from 15 MW to 25 MW at Bandhwari, Gurugram is scheduled to be held at the site of the proposed plant on 31st August, 2021. The notice of the Public Hearing reveals that there is a manifest procedural violation of the Environment Impact Assessment (EIA) Notification 2006 under the Environment (Protection) Act, 1986. The Clause No. 1 of the EIA Notification, 2006 clearly states that the Hearing should give opportunity to "widest possible public participation". Disregarding this provision, the notice of the Environmental Public Hearing invites “suggestions and objections, if any, of the nearby public on the proposed project”. The notice makes a mockery of the EIA notification and the procedure of public hearing. Given the fact that air pollutants and water pollutants are long distance travellers and do require permission to go to farther places, confining the public hearing to “nearby public” transforms the EIA process into an empty ritual and a non-serious formality.  It is a mockery also because there is no existing plant to expand. Initially, the project proponent submitted a proposal for 15 MW and now its is trying to expand it.

Residents of Gurugram in particular and environmental groups in general are seriously perturbed with this initiative of the Municipal Corporation of Gurugram in the name of ‘Integrated Municipal Solid Waste Processing Facility’ in their region. The proposed setting up of this monstrous municipal solid waste based “waste-to-energy” incineration project in question is highly polluting and hazardous. As per the United States Environmental Protection Agency (USEPA), all municipal waste combustors (i.e. incinerators), regardless of technologies, release a number of pollutants, including cadmium, lead, mercury, dioxin, sulfur dioxide, hydrogen chloride, nitrogen dioxide, and particulate matter. Dioxin and mercury are of particular concern because they are toxic, persist in the environment, and bioaccumulate. The decision of Municipal Corporation of Gurugram to set up and expand the said project is ill conceived, and blatantly ignores the present demography of the surrounding areas of the proposed site. How can it propose such a hazardous project in the vicinity of residential areas while ignoring the current geography of the area? This plant emits large quantities of hazardous and toxic emissions (such as dioxins and furans) due to burning of mixed Municipal Solid Waste, and profoundly affects the health of the people living in the surrounding areas and environment for all times to come in future. This is in violation of the fundamental right under Article 21 of the Constitution of India and Articles 47, 48A and 51-A (g) of the Constitution. It disregards the provisions under Municipal Solid Waste Management Rules 2016, Rule 4(6), 4(7) and 4(8) which creates a compelling need for segregation of organic waste and composting or bio methanation. The proposed project is going to spoil the quality of life and living, the quality of the air for breathing, the quality of under-ground water and bring disaster to lives of all the residents.  The burning of 1500 to 2000 Tonnes of municipal solid waste per day near Gurugram and in the middle of Bandhwari village exposes them to toxic fly ash and bottom ash.

It is noteworthy that no EIA report has been uploaded on the website of Haryana State Pollution Control Board’s Website or on the website of Municipal Corporation of Gurugram till recently. The notification on public hearing dated 28 July, 2021 made an incorrect claim that it is available in HSPSCB website. The Reginal Officer of the Board was asked to provide the EIA report but he never responded to email and telephonic communications.

The proposed plant is located amidst an ecologically sensitive zone-Aravalli forest- between Bandhwari and Damdama which is very rich in wildlife acts as a corridor between Asola Bhatti wildlife sanctuary. The proposed thermal power plant is less than 10 kms away from it. The Wildlife Institute of India has confirmed the presence of leopards, hyenas, jackals, nilgais, porcupines, palm civets and many birds around the landfill. It is threat to the fragile forest ecosystem, flora, fauna and habitats.

It is noteworthy that the transportation of 2000 tonnes of waste to the proposed site will require a some 300-400 trucks on Delhi-Haryana corridor, will add to the carbon emission, smoke and dust in the city. The proposed project will have adverse impact on the public health and environmental health.

The proposed project can only make the problem invisible and complex. It can not make the mixed municipal solid waste with hazardous waste characteristics disappear. It requires a hazardous waste landfill to hold toxic ash and residuals from such plants. Minimum of 25 % of the waste burnt in the facility will reach landfill. It will cause food chain poisoning through air pollution and water pollution.

The city have to arrange for segregated collection of organic waste. When it is collected segregated the city should be able to set up decentralized composting facilities to recover it. That reduces cost and volume of waste to the common facility.

The residents are clearly the “victims” of improper, unjustified planning reflecting no concern towards the health of the residents. This kind of “planning” disregards all the scientific evidence. The residents have been demanding stoppage of this project to avoid Bhopal Gas disaster like situation in this residential area.

The following details are relevant in this regard:

1.      At page 27, 29, 34 and 39, of the 487 page long Draft EIA report pays lip service to health and prevention of health hazards. This is factually not correct as has been borne out by the order of Hon’ble Delhi High Court pertaining to a plant using similar incinerator technology at the same location. The landmark judgment in Writ Petition (C) No. 6976 of 2008 refers to 'The summary of "Epidemiological Studies on Adverse Health Effects Associated with Incineration" would show that medical waste incinerators are a leading source of dioxins and mercury in the environment and there is link between incinerator emissions and adverse health impacts on incinerator workers and residents living around the incinerators.'

2.     The observations made in the judgment will have far reaching implications. It reads: "Both older and more modern incinerators can contribute to the contamination of local soil and vegetation with dioxins and heavy metals. In several European countries, cow's milk from farms located in the vicinity of incinerators has been found to contain elevated levels of dioxin, in some cases above regulatory limits. Increased levels of dioxins have been found in the tissues of residents near to incinerators in the UK, Spain and Japan. At an incinerator in Finland, mercury was increased in hair of residents living in the vicinity. Children living near a modern incinerator in Spain were found to have elevated levels of urinary thioethers, a biomarker of toxic exposure. "It notes that "After 2 years of operation of incinerator, dioxins levels were found increased by about 25% in both groups living between 0.5 to 1.5 and 3.5 to 4.0 km away (201 people) of people. In the repeat analysis, the increase was in the range of 10-15%". It records that "Mothers living close to incinerators and crematoria from 1956 to 1993" showed "increased risk of lethal congenital abnormalities, in particular, spinal bifida and heart defects, near incinerators: increased risk of stillbirths and anacephalus near  crematoria". With regard to "Residents from 7 to 64 years old living within 5 km of an incinerator and the incinerator workers" the judgment observes, "Levels of mercury in hair increased with closer proximity to the incinerator during a 10 year period".

3.     This judgment found that "Residents living within 10 km of an incinerator, refinery, and waste disposal site" showed "Significant increase in laryngeal cancer in men living with closer proximity to the incinerator and other pollution sources". The "Residents living around an incinerator and other pollution sources" showed "Significant increase in lung cancer related specifically to the incinerator". The "People living within 7.5 km of 72 incinerators" displayed "Risks of all cancers and specifically of stomach, colorectal, liver and lung cancer increased with closer proximity to incinerators". The order observes, "10. In Master Plan for Delhi, 2021, notified on 07.02.2007, hazardous waste processing viz. hospital/medical/industrial waste is amongst the industries, manufacturing of which shall be prohibited within National Capital Territory of Delhi." It is not in dispute that Delhi's municipal waste has hazardous waste characteristics. The Hon'ble Court observed that "This is a mandatory requirement of the guidelines issued by CPCB that such facility should be far away from residential and sensitive areas". The same holds true for the location of the proposed municipal waste based RDF plant.

4. The reference to “renewable power generation” at page no. 35 of the 487 page long Draft EIA/EMP Report of Expansion of Power Plant from 15 MW To 25 MW (Waste To Energy) are scientifically and factually incorrect and misleading. The contention that generating electricity using a non-conventional energy source instead of fossil fuel must be deemed a renewable energy project is scientifically questionable. waste burning technology cannot automatically be deemed a renewable energy project. If anything, such attempts to classify the WTE plant as renewable project is farfetched.  Waste incinerator technologies are net energy losers when the embodied energy of the materials burned is accounted for. The move by the incineration industry to persuade public institutions to term waste incinerators as 'renewable energy' projects is not only fraudulent but also dangerous. Municipal solid waste is not considered to be a renewable energy source since it tends to be a mixture of fuels that can be traced back to renewable and non-renewable sources. The perpetuation of the myth claiming waste incineration as a source of ‘renewable energy’ has deeply harmful ramifications. European Commission’s definition of Renewable Energy Directive states that ‘energy from renewable sources’ is derived only from non-fossil sources. As per this definition energy from waste is not a renewable energy because waste is not a non-fossil source. It is “energy from a source that is not depleted when used, such as wind or solar power”.

5. Waste is not like wind or solar. It consists of paper, plastic food etc – all having been made from other sources of energy and resources. For instance, if waste consists entirely of plastic (for example) and generates 100MW of energy per tonne, it’s only renewable if it took less than 100MW of energy to produce. If this is how energy is being defined as ‘renewable’ then Waste to Energy is not renewable energy. A road that harnesses the movement and sound of cars to create electricity is not typically considered ‘renewable’ because it relies on a car’s use of fossil fuels to move. It is this very principle which is being applied to waste. The advocates of waste incineration based power plants prefer to pre-empt segregation and recycling efforts being made by municipalities and communities around the world.

6. Given the fact that at present the national electric grid in India has an installed capacity of 383.37 GW as of 31 May 2021, there is no compelling logic for the extraction of power from WTE plants.

7. The residents of the region are in a state of profound fear because of the expanison of the plant’s capacity from 15 MW to 25 MW. This amounts to transforming the residents and wild life in the area into guinea pigs for testing war chemicals in peace time. The emission of Persistent Organic Pollutants (POPs) like Dioxins from the plant in this residential and ecologically fragile area is akin to use of Agent Orange, a war Dioxins based war chemical used by US Army against Vietnam.  Agent Orange is an herbicide and defoliant chemical, one of the "tactical use" Rainbow Herbicides. It is widely known for its use by the U.S. military as part of its herbicidal warfare program, Operation Ranch Hand, during the Vietnam War from 1961 to 1971. 

8. The fact is that contrary to the Environment Impact Assessment (EIA) report, Refuse Derived Fuel (RDF) units do not exist.

9.  No residential locality in its sanity can give consent to allow expansion of un-segregated municipal waste incineration based thermal power plant in their locality. They cannot be expected to be superior bearers of risk. The Experts Appraisal Committee cannot turn a blind eye to serious health hazard to tens of thousands of people living and working in this ecologically-sensitive area.  

10. The residents and their neighbourhood will get submerged in the ashes which emerge from the such power plants plant which is going to burn mixed municipal waste which has hazardous waste characteristics.

11.  It is quite appropriate that Hazardous Substances Management Division (HSMD), MoEFCC has framed the Municipal Solid Waste (Management and Handling) Rules given the fact that Indian municipal waste does have hazardous waste characteristics.

12. The polluting potential of the proposed plant using municipal solid waste as fuel is serious. Emissions include suspended particulate matter (SPM), sulphur oxides (SOx), nitrogen oxides (NOx), hydrogen chloride (HCl), and dioxins and furans, the most toxic substances known to mankind.

13. It is noteworthy that the 'White Paper on Pollution in Delhi with an Action Plan' prepared by Union Ministry of Environment and Forests. The White Paper says, "The experience of the incineration plant at Timarpur, Delhi and the briquette plant at Bombay support the fact that thermal treatment of municipal solid waste is not feasible, in situations where the waste has a low calorific value. A critical analysis of biological treatment as an option was undertaken for processing of municipal solid waste in Delhi and it has been recommended that composting will be a viable option. Considering the large quantities of waste requiring to be processed, a mechanical composting plant will be needed." The paper is available on Ministry's website. This paper is relevant for the proposed thermal treatment based RDF plant in Bandhwari, Gurugram, Haryana.

14. The failure of Delhi's Timarpur waste to energy plant, Hon'ble Delhi High Court had ordered an enquiry by the Comptroller Auditor General (CAG). In its annual report dated March 1990, the Comptroller Auditor General of India (CAG) observed, "The Refuse Incinerator-cum-Power Generation Plant installed by Ministry of Non-Conventional Energy Sources in March 1985 remained inoperative since its installation. The Ministry failed to utilise or dispose off the inoperative plant and incurred an expenditure of Rs 1.25 crore on maintenance and insurance of the plant." The project was scrapped in July 1990. It is germane to note that Union Ministry of New and Renewable Energy which is now part of Ministry of Power provides a subsidy of Rs 1.5 crore/MW is distorting waste management in the country including Delhi.

15. As per Hon'ble Supreme Court's order in the Writ Petition (Civil) No.888 of 1996 such subsidies are not meant for incinerator plants like the one in Okhla. Hon'ble Court's order dated 6th May, 2005 said, "...we hope that till the position is clear, the Government would not sanction any further subsidies." It is noteworthy that on 15th May, 2007, the Court's order "permit (s) Ministry of Non-conventional Energy Sources (MNES) to go ahead for the time being with 5 pilot projects chosen by them" but it is noteworthy that this refers specifically to bio-methanation technology. MNES is renamed as Ministry of New & Renewable Energy (MNRE). It has been revealed through RTI that neither the proposed Delhi's waste to energy incinerator projects one of those 5 pilot projects nor is it based on the recommended technology.

16. As per the March 2018 report of the Parliamentary Standing Committee on Energy, on a query regarding provisions of financial incentives provided by the Government for Renewable Energy for Urban, Industrial and Commercial Applications, the Ministry furnished the information that Power generation from Municipal Solid Waste gets Rs. 2.00 crore/MW (Max. Rs.10 crore/project) from the MNRE. Other incentives and support measures provided by the Ministry under the programme incentives are given to State Nodal Agencies: service charge @ Rs. 1% of the subsidy restricted to Rs. 5.00 lakh per project and financial assistance for promotional activities: for organizing training courses, business meets, seminars/workshops and publicity/awareness, subject to a maximum of Rs. 3.0 lakh per activity. In addition, the Ministry of Urban Development is also implementing “Swachh Bharat Mission” (SBM) since 2 October, 2014, which also includes setting up of waste to energy plants with Central support up to 35% of the project cost in the form of Viability Gap Funding (VGF) / grant, subject to the overall State-wise funds envelop for SBM." Incentives include "Accelerated Depreciation: Tax depreciation rate of 80% under AD benefits besides concessional Custom Duty Exemption and GST. Waste to Energy projects draws 5% GST besides availing concessional custom duty which would help the promoters / developers to avail these concessions to improve economic viability of the projects.

According to the amended Tariff Policy, Distribution Licensee(s) are required compulsorily procure 100% power produced from all the Waste-to-Energy plants in the State, in the ratio of their procurement of power from all sources including their own, at the tariff determined by the Appropriate Commission under Section 62 of the Act. The Central Electricity Regulatory Commission (CERC) vide notification dated 07th October 2015 and 31st March 2015 have notified norms for determination of Generic Tariff for MSW, RDF and Biogas based WTE projects along with Generic Tariff for FY 2016-17. The Levelised Tariff which is in the range of Rs.6.50 to Rs.7.60 per unit."

 When asked about the modes of financing, existing financial support available and possible options for funding capital and operation & maintenance costs with respect to W to E Plants, the Ministry stated: "The Government of India, through various schemes extends financial support for introducing appropriate solid waste management systems and for setting up processing and disposal facilities. These include Viability Gap Funding Swacch Bharat Mission of MoUD,  Loan from IREDA, Grants from MNRE for Supporting W to E Projects and Preferential Tariff by Regulators besides support for Purchase of Compost from Ministry of Agriculture.

 When the Committee desired to know about the current status and performance of Waste to Energy Plants in the country, the Ministry informed that "At present, six waste-to-energy plants using Municipal Solid Waste (MSW) with cumulative installed capacity of 65.75 MW are in operation in the country. The State-wise details of Municipal Solid Waste (MSW) based power projects set up. It is apparent that the ministry is blind to environmental health concerns in its drive for energy from waste at any human and environmental cost. Such an unscientific approach is distorting waste management and poisoning the food chain. It high time MNRE withdrew or modified its letters that encourage and promote polluting technologies like the one proposed at Bandhwari, Gurugram, Haryana,  situated in residential and admittedly ecologically sensitive areas.

17. Every claim made about RDF is misplaced and an exercise in glaring misrepresentation of facts.

18.   It is noteworthy that for a project to qualify as climate crisis mitigating project it is necessary that it excludes waste incineration

-- including waste pelletisation or RDF, pyrolysis, gasification systems -- technologies. Incineration produces pollutants which are detrimental to health and the environment. Incineration is expensive and does not eliminate or adequately control the toxic emissions from today's chemically complex municipal discards. Even the latest incinerators release toxic metals, dioxins, and acid gases. Far from eliminating the need for a landfill, waste incinerator systems produce toxic ash and other residues. Such projects disperse incinerator ash throughout the environment and subsequently enter our food chain.

19. The emission of dioxins and heavy metals from such waste based thermal power plants is a cause of grave concern. Dioxins are the most lethal Persistent Organic Pollutants (POPs) which are associated with irreparable environmental health consequences.

20. It may be noted the Master Plan Report (2020) of Municipal Corporation of Delhi (MCD) said, “RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions.” The EAC ought to pay heed to it as well.

21. Union Minister of Environment, Forests, and Climate Change, in a written reply to a question in Lok Sabha has informed, “Government  is  aware  of  the  reports  published  by  the  World  Health  Organization (WHO)  and  the  Health  Effects  Institute  (HEI)  regarding the  impact  of  air  pollution  on  human health in  terms  of  higher  casualty  rate  due  to  air  pollution.  The reports are based on models, simulations and extrapolations. The Central Pollution Control Board (CPCB) has carried out epidemiological studies to assess the impact of pollution on human health. Air Pollution could be one of the triggering factors for respiratory ailments and associated diseases. However, there are no  conclusive  data  available  in  the  country  to  establish  direct  correlation  between diseases and air  pollution. Health  effects  of  air  pollution  are  generally  synergistic  manifestation  of  the  individual’s food habits, occupational habits, socio-economic status, medical history, immunity, heredity, etc.” WHO’s Ambient Air Pollution database has been marked National Capital Region as the most polluted city in the world with an annual particulate matter (PM) 2.5 level of 153 μg/Nm3. The pollution had spiked beyond acceptable limits with dangerous PM 2.5 and PM 10 levels hitting 999 μg/Nm3, while the safe limits for those pollutants are 60 and 100 respectively. A 2010 study conducted by the Boston-based Health Effects Institute (2010) has estimated that about 3000 premature deaths occur in Delhi due to air pollution related diseases. This works out to about 8 deaths per day in National Capital Region alone relating to air pollution related diseases. This year again, levels of PM 2.5 in Delhi reached 710 μg/Nm3, more than 11 times the safe limit prescribed by the WHO. Biomass burning in the proposed  waste based thermal plant is a significant contributor to the air pollution load.

In such a backdrop, it is not surprising that municipal waste to energy plant based on incinerator technology in question faces bitter opposition from residents, environmental groups and waste pickers. 


Given the fact that at present India has surplus power, there is no compelling logic for the extraction of power from WTE plants. There is a logical compulsion to desist from proposing such toxic plants in order to save present and future generation of residents from being enveloped in a toxic gas chamber as a consequence of use of such hazardous incinerator technology adopted for generating energy from waste which admittedly has hazardous waste characteristics.

Contact Details: Gopal Krishna, LL.M., Ph.D, ToxicsWatch Alliance (TWA), Mb: 9818089660, E-mail: krishnagreen@gmail.com, Web: www.toxicswatch.org 

Note: TWA has been working on the issue of waste since 2000 and has managed to stop seven waste incineration based projects in Delhi, Mumbai, Chennai, Kanpur, Bhopal, Jaipur, Agra and Bhojpur, Bihar. It has been part of research and advocacy regarding Okhla based waste to energy plant since March 2005.


Photo: Notice for Environmental Public Hearing of Expansion of Power Plant from 15 MW t25 MW (Waste To Energy) Capacity at BandhwariGurugram, Haryana

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