Shri Tejendra Khanna
Lt Governor, Delhi
Subject-Toxic Municipal Waste to Energy (WTE) plants
This is to draw your attention towards the fact that 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 New and Renewable Energy (MNRE) and Delhi Government is promoting it without regard to citizens’ health and environmental concerns and the livelihood of the waste recycling workers. The proposed Waste to Energy project for carbon credit is in violation of Supreme Court's order as well.
The environmental clearance to this project was given when Mr A Raja was the Union Minister for Environment & Forests ignoring the protests of waste pickers whose livelihood depends on it. Residents are already facing the consequences of medical waste incinerator plant.
Most recently, it has reliably been learnt that Asian Development Bank (ADB)'s Asian Pacific Carbon Fund (APCF) has dropped the Timarpur-Okhla incineration based waste to
energy plant out of its portfolio. But the construction of the plant is still underway.
Sadly, now given the fact that Delhi High Court that heard the matter on 12th January, 2011 has posted the matter for hearing in March 2011. This plant is coming up in violation of the Supreme Court’s order.
It is noteworthy that Chairperson, Parliamentary Standing Committee on Energy wrote to the Ministry on 14 June 2005 seeking review of its WTE programme. It supported a ban on economic incentives for such projects, saying: "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."
I wish to draw your attention towards this Timarpur-Okhla Waste to Energy project that has met with protest rally from the residents of Gaffar Manzil, Sukhdev Vihar and Hazi Colony together. Over thousands of people have walked through the colonies in a procession to stage their protest. Similar plant is proposed at Ghazipur and Timarpur in Delhi.
It is noteworth that the proposed plant is located inside dozens of densely populated residential colonies like Harkesh Nagar and Johori Farm, when the policy of the government is to shift or relocate all existing industries whatsoever from the residential areas. Besides this the site is in proximity of hospitals like Holy Family, Fortis-Escorts and Apollo. Inhabitants of colonies like Gaffar Manzil, Sukhdev Vihar and Hazi Colony are rightly alarmed at the prospect of a Dioxins emitting incinerator plant from coming up in their vicinity.
This has reference also to a reply by the Union Minister for New and Renewable Energy dated December 11, 2009 in the Lok Sabha and laying of a foundation stone on June 26, 2010 in Sukhdev Vihar, Delhi by Mrs Sheila Dikshit, Delhi’s Chief Minister for a polluting waste to energy plant in the residential area despite the experience of Bhopal Gas Leak Disaster.
In his reply the Minister for New and Renewable Energy stated, “Our Ministry is implementing a programme for setting up five pilot projects on Energy recovery from municipal solid waste”. Initially, Delhi Government claimed in the Delhi High Court that it was one of the five projects you referred to in your reply, which the court later found to its shock that such a claim was manifestly untrue.
The MNRE and Delhi government have been misled into promoting this dubious technology despite incontrovertible evidence against the technology and in spite of its explicit exclusion by the Prime Minister’s National Action Plan for Climate Change.
Waste incineration systems (including waste pelletisation, pyrolysis and gasification systems) produce pollutants, which are detrimental to health & environment. It is expensive and does not eliminate or adequately control the toxic emissions from today's chemically complex municipal discards. Even new 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.
Incinerator based technological intervention in the waste stream distorts waste management beyond repair. Such systems rely on minimum guaranteed waste flows. It indirectly promotes continued waste generation while hindering waste prevention, reuse, composting, recycling, and recycling-based community economic development. It costs cities and municipalities more and provides fewer jobs than comprehensive recycling and composting. It prohibits the development of local recycling-based businesses.
These waste to energy projects are being promoted in manifest violation of international environmental norms. Incineration of waste violates Kyoto Protocol because as per the Protocol waste incineration is a greenhouse gas emitter. It violates 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 recommendations of United Nations Environment Programme (UNEP)'s Global Assessment on Mercury which includes measures such as reducing or eliminating the mercury emission from waste incineration because unlike other heavy metals, mercury has special properties that make it difficult to capture in many control devices. 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 contrary to national legislations and norms such as Municipal Solid Waste (Management & Handling) Rules, 2000 because according to these Rules it is illegal to incinerate chlorinated plastics (like PVC) and wastes chemically treated with any chlorinated disinfectant and recommendations of the Supreme Court constituted committee on waste management.
While no one will allow an incinerator based plant in one's own backyard or in one's own residential area, the same is being done by the Delhi Government and your Ministry. In an open letter to the Chief Minister the residents said, “This plant will emit large quantities of hazardous and toxic emissions (such as dioxins and furans) due to burning of Municipal Solid Waste, and will profoundly affect the health of the people living in the surrounding areas and environment for all times to come in future.”
Delhi Government must take cognizance of the sad plight at waste to energy site in Gandhamguda village in Ranga Reddy district of Andhra Pradesh (wrongly mentioned as Hyderabad project) which had the same technology. While the RDF incinerator was in operation, the village was covered by a heavy shroud of dark smoke. Originally a pelletisation plant with a furnace, After the plant came up, local doctors started detecting case of problems not found before— skin rashes, asthma, respiratory problems and some cases of stillborns. In a statement, Gandhamguda sarpanch D. Shakuntala had said: ‘‘Everyone in Peerancheru Gram Panchayat and its adjoining regions is now contaminated with harmful pollutants and symptoms are visible in the form of brain fever, vomiting, jaundice, asthma, miscarriages, infertility.’’ Similar fate awaits residents of Delhi.
For misplaced carbon revenue, it would not be appropriate to turn Delhi residents as guinea pigs. MNRE has an incorrect policy of subsidizing hazardous technologies like proposed incinerators.
Environmental groups, recycling workers and neighborhood residents are demanding closure of this combustion based project for a just transition from burning waste to building a better, cleaner future for the residents of Delhi. The transition is necessary in the face of issues such as the high cost of incineration, health effects of pollution in neighborhoods, and adverse climate change. Children suffer asthma rates three times the national average among other devastating health impacts.
This plant is based on a hazardous technology that receives fiscal incentives from Union Ministry of New and Renewable Energy (MNRE). Notably, while 'whether or not energy from mixed municipal waste (with hazardous characteristics) is a driving concern' remains in dispute, the Prime Minister’s National Action Plan on Climate Change (NAPCC) categorically refers to Biomethanation technology, a biological treatment method for waste to energy instead of the Refuse Derived Fuel (RDF) process which is a incineration technology and is a tried, tested, failed and Dioxins emitting technology.
MNRE and Delhi Chief Minister has turned a blind eye to Delhi High Court order which led to an inquiry by the Comptroller and Auditor General of India (CAG) into the failure of the Timarpur plant that was also based on incineration technology (namely Refuse Derived Fuel) and the ‘White Paper on Pollution in Delhi with an Action Plan’ prepared by Union Ministry of Environment and Forests, the Chief Minister has been misled in to promoting it. 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.”
Even Municipal Corporation of Delhi (MCD)’s own Feasibility Study and Master Plan for Optimal Waste Treatment and Disposal for the Entire State of Delhi of March 2004 says, “Incineration of RDF is considered waste incineration.” (Page 25, Appendix D, Technology Catalogue). It also says the costs of RDF are often high for societies with low calorific value because energy is used to dry the waste before it becomes feasible to burn it.
In fact the Master Plan Report (2020) of Municipal Corporation of Delhi (MCD) itself says, “RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions.” One is surprised that despite this observation the report then goes on to suggest RDF. In fact the MCD report itself says that RDF is another form of incineration.
A 10 member Fact Finding Team visited the plant site on 18th June 2010 to take stock of the situation. Its preliminary findings are as follows: 1. RDF or incineration is completely inappropriate for Indian urban waste, which is largely biodegradable in nature. They extract a very high cost for the energy which they claim to generate. 2. The cost largely subsidised by various schemes, does not however include the environmental and health costs caused by their toxic releases, and which are externalized. 3. These technologies also use valuable resources which can be recycled, such as plastics and metals, and which support a massive recycling sector in the country. Indian municipal waste is fit for composting and bio-methanation treatment processes. 4. RDF is a thermal and combustion technology, mainly used to prepare waste for mass incineration. 5. If mixed waste is burnt will create problems of very toxic compounds such as dioxins and furans, heavy metals and other pollutants. 6. The calorific value for the waste comes from materials such as plastics and metals. 7. Plastics, especially chlorinated plastics such as polyvinyl chloride (PVC) when combusted gives rise to these highly toxic pollutants and
8. PVC plastic combustion which is part of the mixed waste is banned in India by regulation both in the municipal and bio-medical waste handling rules.
Earlier residents had not allowed the land handover ceremony for the project that is proposed in the residential area of Okhla but unmindful of the public protest, New Delhi Municipal Corporation (NDMC) had permitted Jindal Urban Infrastructure Ltd to set up this plant. This company has secured a contract from New Delhi Waste Processing Company Limited, a joint venture between the Delhi Government and Infrastructure Leasing and Financial Services Ltd. (IL&FS), to produce 16 MW power from 2, 000 metric tonnes of municipal waste. Jindal company’s misplaced claims to that effect that it will process nearly 2000 tonnes of waste, later it would be in a position to process as much as 4,000 tonnes based on obsolete technology will distort capital city’s waste management beyond repair.
The proposed polluting technology to deal with the waste from South Delhi, North West Delhi and East Delhi is fraught with disastrous public health consequences for which two companies namely, Timarpur-Okhla Waste Management Company (TOWMCL) and the Unique Waste Processing Company (subsidiary of IL&FS Infrastructure Development Corporation Limited have been set up.
As per the agreement, BRPL will procure 50 per cent of the 16 MW electricity to be produced by TOWMCL at its plant in Okhla in the vicinity of numerous residential areas such as Sukhdev Vihar, Hazi Colony, Gaffar Manzil and others. The plant being set up plans to process over 6,43,500 lakh metric tonnes or one third of Delhi's Municipal Solid Waste (MSW) per year generated in Delhi. The plant is scheduled to be commissioned in late 2010-2011. Around 1,300 Tonnes Per Day (TPD) of MSW will be sourced from the Okhla landfill site and 650 TPD from Timarpur. BRPL will procure power at a DERC approved competitive tariff rate, determined by a competitive bidding process. The agreement allows the promoters to sell the remaining 50 per cent electricity through a suitable open access mechanism.
Similar waste to energy project is coming up at Ghazipur, Delhi as well. Earlier, in November, 2009 BRPL had signed a 25-year-agreement to procure 49 per cent of the electricity generated from garbage to energy project at Ghazipur. Chief Minister referred to this project as well while laying the foundation stone.
Unmindful of the environmental and human cost the installation of proposed municipal solid waste (MSW) to energy plants in Ghazipur, Timarpur and Okhla, based on incineration of Refuse Derived Fuel (RDF) is being pursued. This compelled the residents to move to the Delhi High Court. Earlier, the matter came up for hearing on December 11, 2009 wherein the petitioners (Sukhdev Vihar Residents Welfare Association & others) pointed out the polluting nature of the Refuse Derived Fuel (RDF) Incineration technology and how both the central government and the Delhi government has misled the court. The court in its latest order has found that it was misled earlier which had led to it dismissing the petition which has now been restored before the Delhi High Court. In the presence of A.S. Chandihok, Additional Solicitor General, the bench headed by the Chief Justice, Delhi High Court in an order dated 15th January, 2010 observed, “that the project in question” and “the location of the pilot project in Delhi was neither recommended by the Expert Committee nor approved by the Supreme Court.”
Also East Delhi Waste Processing Company Private Limited, a special purpose vehicle of the latter company is working for generating electricity at the Ghazipur site with the support of the Delhi Government. ‘New Delhi Waste Processing Company Private Limited’ a Joint Venture company of Delhi Government, IL&FS and APTTDC is supporting the project as well. The integrated municipal waste-processing complex is proposed to include a MSW processing plant at Ghazipur to produce Refuse Derived Fuel (RDF) along with a power plant of 10 MW capacity where the RDF derived from the waste will be used as fuel to produce electricity. It is supposed to handle an average 1300 tons per day. It claims that 111,949 metric tonnes CO2 equivalent per annum of greenhouse gases would be reduced. The crediting period for the project is from 1st November, 2010 to 31 October, 2020.
The Timarpur-Okhla carbon credit project was registered on 10th November, 2007 with a claim to reduce greenhouse gases to the tune of 262,791 metric tonnes CO2 equivalent per annum. Unique Waste Processing Company, a subsidiary of Infrastructure Leasing and Financial Services (IL&FS) and Andhra Pradesh Technology Development Centre (APTDC) has incorporated Timarpur-Okhla Waste Management Company for developing the project for processing municipal waste and also to produce electricity at two locations namely Timarpur and Okhla, at the site at Okhla that is adjacent to defunct Okhla Sewage Treatment Plant (STP). TOWMCL is working with New Delhi Municipal Council (NDMC) and MCD. The Timarpur and Okhla plant will together be processing 650 tonnes per day of MSW at Timarpur site and 1300 tonnes per day of MSW at Okhla and claims to generate 16 MW of electricity.
The move underway to install RDF plants in Delhi and several other state capitals is an environmentally unsustainable solution, which should be deemed unacceptable. If Delhi allows such toxic plant, it will set a bad precedent for other cities. It raises serious concerns about the health and safety of the citizens, which such a technology, will jeopardize.
Therefore, it is incumbent upon the policy makers to exclude "waste," "waste resources," "waste pelletisation", "waste incineration," "pyrolysis," "gasification" technologies from qualifying as renewable energy or fuel and also exclude renewable energy subsidy/loan programs for burn technology based waste to energy programs and policies. The high cost routes must be avoided and instead only appropriate methods such as small-scale bio-methanation, composting and proper recycling be propagated.
Meanwhile, the Inter-Ministerial Task Force on Integrated Plant Nutrient Management did not encourage WTE policy and has recommended setting up of 1000 compost plants all over the country and has allocated Rs. 800 crore for the same. Even Dr A.P.J. Abdul Kalam, as the President rightly summed up the need for Integrated Zero Waste Management. He has illustrated it by referring to a village of 2,400 families, which generates garbage of over 48 tonnes per year. This garbage is converted into manure and recyclable waste generating over Rs 3 lakh in revenue. This scheme provides employment to people of the Panchayat. Such measures promote sustainable development as against the current trend of introducing failed polluting technologies, which turn citizens into guinea pigs for experiments.
The incentives and subsidies should be offered in areas of `cold' technologies alone, which are suited to our country economically, socially and also to our wastes. The ideal resource management strategy for MSW is to avoid its generation in the first place. This implies changing production and consumption patterns to eliminate the use of disposable, non-reusable, non-returnable products and packaging. The alternative waste disposal methods include waste reduction, waste segregation at source, extended use and refuse, recycling, biomethanation technology and composting.
In view of these grave concerns, we request you to direct the concerned authorities to take preventive steps in order to save Delhi's environment from highly polluting plants in residential areas.
Bhartiya Kachra Intzamia Andolan
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