Burning biomass is not green

As of February, 2008, when the Municipal Corporation of Delhi (MCD) and the Ministries who were testing the waters all along realized that now the opposition by the Delhi based NGOs has been exhausted, they are now promoting the proposed a 16 MW waste to energy plant. The MCD proposes to deliver waste for free and even the New Delhi Municipal Council is joining the bandwagon as well. This mixed waste will undergo a host of mechanical and thermal processes to flush out the combustible elements. The power plant proposes to use about a third of the daily waste of the city. The project cost is estimated at Rs 175 crore. The capital investment per MW of power is almost Rs 11 crore. The coal-powered plant can be set up at about Rs 4 crore per MW. The project is located within the city across 18 acres of land in Okhla and Timarpur. The construction is expected to start by April 2008.

The Municipal Corporation of Delhi and the Timarpur Waste Management Company Pvt. Ltd., have proposed a waste incineration plant to treat the city's solid waste and generate 6 MW of electricity. TWMPCL has applied to a United Nations body for tradable carbon credits.

The Municipal Corporation of Delhi (MCD) has proposed to initiate a waste to energy (WTE) project at Timarpur that uses incineration. The Timarpur Waste Management Company Pvt. Ltd. (TWMCPL), a subsidiary of Infrastructure Leasing & Financial Services Ltd. (IL&FS) plans to generate 6 MW of electricity from the project at Timarpur, Delhi. It plans to process and treat 214,500 MT of Municipal Solid Waste (MSW) and produce 69,000 MT of Refuse Derived Fuel (RDF) in a year as per company's project design document. The project requires an investment of Rs.580 million. The promoters claim that the Department of Economic Affairs, Ministry of Finance has agreed to provide 20% of the project's cost as a capital grant.

TWMCPL is a subsidiary of IL&FS and has been created only for Timarpur project. A Memorandum of Understanding between MCD and IL&FS was signed in March 2005 by D K Mittal, the CEO of TWMCPL and Rakesh Mehta, IAS the then Commissioner of MCD. Mehta is Principal Secretary and Chairman-cum-Managing Director of Delhi Tansco Limited in Delhi Government. Mittal is also a serving IAS officer, besides being the CEO, Special Infrastructure Projects, Infrastructure Leasing and Financial Services (IL&FS) and a member, Supreme Court Committee on Waste to Energy despite being an interested party. Mittal was earlier with Union Ministry of Commerce and Industry.

On 14 March 2005, MCD said that it plans to earn carbon credits from the project. TWMPCL has since applied for approval from the United Nations Framework Convention on Climate Change's (UNFCCC) Clean Development Mechanism (CDM) Executive Board to earn carbon credit. The project got listed before the board on 23 May 2006, and the board sought comments until 21 June. TWMCPL had submitted its project design document.

The CDM Executive Board of the UNFCCC supervises the Clean Development Mechanism part of the Kyoto Protocol, and is accountable to the Conference of Parties (COP), the decision making body for the protocol.

The Kyoto Protocol entered into force on 16 February 2005, after which the CDM Executive Board started registering projects. The board is based in Bonn, Germany, at the UNFCCC Secretariat.

The Chair of the CDM Executive Board is Jos� Domingos Miguez. There are two Indian members as well in the Board, out of its 10 members from the parties to the Protocol. The Indian members are Sushma Gera and Rajesh Kumar Sethi. In addition, there are 10 alternate members in the Board.

The Clean Development Mechanism (CDM) allows industrialised countries to meet their emission reduction targets by paying for green house gas emission reduction in developing countries. Say that a company in India switches from coal power to biomass and that the CDM board certifies that by doing this, the company has reduced carbon dioxide emissions by 100,000 tonnes per year. The company will be issued 100,000 Certified Emissions Reductions (CERs). One CER corresponds to reduced green house gas emissions by one tonne of carbon dioxide per year. For example, if a project generates energy using wind power instead of burning coal, and saves 50 tonnes of carbon dioxide per year, it can claim 50 CERs.

Under the Kyoto Protocol, the United Kingdom (a developed country) has to reduce its green house gas emissions by 1 million tonnes of carbon dioxide each year. Continuing with the example above, if the UK purchases the 100,000 CERs from the Indian company, its target goes down from 1 million tonnes/year to 900,000 tonnes per year, making the goal that much easier to achieve. Developed countries are expected to buy CERs from developing countries under the CDM process to help them achieve their Kyoto targets. CERs are therefore a "certificate", like a stock and help achieve trading of emissions credits.

A significant point to note is that in India, income from CERs are not taxed. MCD and TWMCPL are arguing that since they propose to generate electricity using a non-conventional energy source instead of fossil fuel, the Timarpur project must be deemed a renewable energy project and for which carbon credits be given to them. TWMCPL wants to receive CERs for this project to earn revenue by selling those CERs.

Problems galore

The central problem with the Timarpur proposal is that waste burning technology cannot automatically be deemed a renewable energy project. If anything, MCD and TWMCPL's attempt to classify the WTE plant as a CDM project is far fetched and misleading. Waste incineration is itself a greenhouse gas emitter and cannot qualify as CDM project. Incineration of waste violates Kyoto Protocol because as per the Protocol waste incineration is a green house gas emitter.

For a project to qualify as climate change 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.

Two, the design document deliberately chooses not to mention emission of dioxins and heavy metals and thus does not mention the method to deal with such emissions. Dioxins are the most lethal Persistent Organic Pollutants (POPs) which are associated with irreparable environmental health consequences.

Three, less known is the fact that a similar incinerator-cum-power generation plant at this very site had failed several years ago and the reasons are worth going into. The Comptroller and Auditor General of India (CAG) had also conducted an enquiry after the Delhi High Court ruled in April 2001 on the plant's failure. The court had taken issue with the procurement of the incineration plant at a cost of Rs.20 crores from a Danish firm Volund Milijotecknik in the mid-1980s and said that "No order should have been placed for procurement of the plant unless its utilities were completely known."

A Ministry of Environment and Forests 1997 white paper had gone into the orginally failed waste incineration plant at Timarpur, a project initiated in the mid-80s.

The MoEF paper said that the failure supported the fact that thermal treatment of municipal solid waste is not feasible in situations where the waste has a low calorific value.

It added: "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."

In June 2005, Gurudas Kamat (MP, Congress, Mumbai North-east), Chairman of the Parliamentary Standing Committee on Energy wrote to the MNES seeking review of its WTE programme, citing similar reasons.

Criticism did not come just from the Delhi High Court. Referring among other things to the orginally failed Timarpur incineration plant, a 'White Paper on Pollution in Delhi with an Action Plan' prepared by the Union Ministry of Environment and Forests prepared in 1997, said this: "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."

Four, besides the Kyoto Protocol, the project violates other agreed upon multilateral conventions. It breaks with the Stockholm Convention on POPs because it calls for improvements in waste management with the aim of the cessation of open and other uncontrolled burning of wastes. It violates Dhaka Declaration on Waste Management adopted by South Asian Association for Regional Cooperation (SAARC) in October 2004. As per this declaration, SAARC countries cannot opt for incineration and other unproven technologies.

It is inspite of all this that in March 2005, the MCD signed an agreement with IL&FS to setup a waste incineration plant afresh at Timarpur. This time around, civil society groups protested at the India International Centre, the Delhi Secretariat, and MCD offices. Protest letters were submitted to ministers and officials both at the central and state levels. Around 60 individuals participated.

Caught in a time warp

Unmindful of the fact that waste incinerator technologies are net energy losers when the embodied energy of the materials burned is accounted for, the Union Ministry of Non-Conventional Energy Sources (MNES) continues to promote it without any success. It is providing subsidy to such projects through its policy. It has written to all state governments to follow this policy as part of an excecutive order. MNES has now been renamed as Ministry of New and Renewable Energy.

However, not only the judiciary, but a Parliamentary committee has also expressed its opinion against incineration projects. Referring to two burn projects in Andhra Pradesh as well to problems of incineration in general, Gurudas Kamat (Congress, Mumbai North-east), the Chairman of the Parliamentary Standing Committee on Energy wrote to the MNES on 14 June 2005 seeking review of its WTE programme. Kamat supported a ban on economic incentives for such projects, writing this: "We therefore direct that land filling of unsegregated wastes, incineration and recovery of energy from municipal waste shall henceforth not receive any Govt. sponsorship, encouragement or aid in any manner, except for completion of any projects that have already invested 30% of their capital cost on site."

It is not that better methods of handling municipal waste in Indian cities are unknown. Researchers of waste suggest that composting and recycling materials is a better alternative because it saves the amount of energy that incinerating these same materials would generate. When properly applied, compost prepared from segregated waste is an excellent organic fertilizer. Burning organic waste litter eliminates this valuable resource. Where volumes are too high for local land application, composting is a more sustainable alternative. Organic fertilizer can be analysed and managed before application; but smokestack emissions are dispersed by the wind.

On one occasion, the President rightly summed up the need for integrated zero waste management. He illustrated this by referring to Gandhi Nagar, a town panchayat of around 2,400 families in Vellore district, Tamil Nadu. Gandhi Nagar generates garbage of over 48 tonnes per year. This garbage is converted into manure and recyclable waste generating over Rs.3 lakh in revenue, and the scheme provides employment to local people. Such measures promote sustainable development as against the current trend of introducing failed polluting technologies, which turn citizens into guinea pigs for experiments.

In a related development in favour of this approach, the Inter-Ministerial Task Force on Integrated Plant Nutrient Management has recommended setting up of 1000 compost plants all over the country and has allocated Rs.800 crore for the same in the year 2005. This report has been submitted in the Supreme Court in the writ (civil) no. 888/1996) case. Notably, this report recommends composting as a measure for waste management instead of energy recovery because Indian soil is carbon deficit. But the Ministry of New and Renewable Energy and Urban Development has ignored it.

One the question of CERs, while it remains to be seen what the CDM Executive Board will do, it is very likely it will not accept the TWMCPL proposal, as it is against the letter and spirit of the Kyoto Protocol.