Mr Martin Hession
Clean Development Mechanism (CDM) Executive Board
United Nations Framework Convention on Climate Change's (UNFCCC) Secretariat
Subject- Objection against CDM Projects like Delhi’s Timarpur-Okhla Waste to Energy project
I wish to draw your attention towards the Writ Peition (Civil) NO. 9901/2009 in the Delhi High Court against a large Clean Development Management (CDM) project for waste incineration based power plant proposed by Mr Prithviraj Jindal of Delhi’s Timarpur-Okhla Waste Management Co Pvt Ltd (TOWMCL) of M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited is scheduled for hearing on November 1, 2011.
The TOWMPCL had submitted its CDM Project Activity Registration through Siddarth Yadav of Société Générale de Surveillance (currently known as SGS), a Switzerland and United Kingdom based Designated Operational Entity (DOE) on March 3, 2007. The project Registration Date is mentioned as November 10, 2007 and its Reference No. 1254. It is crediting period is mentioned as 01 April 2009 - 31 March 2019. At the time of the approval of the registration, CDM Executive Board had Mr Rajesh Kumar Sethi as its member. Mr Sethi was elected for two years in 2006 as a member. He became the Chair of the Executive Board that regulates the CDM projects in January 2008. Prior to that Mr Sethi was the Vice-Chair of the Board and had served as Chairman Methodologies Panel of the Board as well from January 2006 – January 2007.
It may be noted that on May 15, 2007, Mr Sethi in his role as Director, Climate Change Division, Indian Ministry of Environment & Forests and Designated National Authority had given Host Country Approval to the project in question to an Indian Administrative Service Officer who was officiating as Chairman, Timarpur-Okhla Waste Management Co Pvt Ltd (TOWMCL). The letter of Host Country Approval is attached.
In the light of the widely reported revelations by Wikileaks which quotes Mr R. K. Sethi, the then chairman of the CDM’s Executive Board and member-secretary of the Indian CDM Authority, admitting that the authority only “takes the project developer at his word for clearing the additionality barrier”, I seek your intervention to review the registration granted to the Timarpur-Okhla Waste to Energy project. WikiLeaks website has revealed that most of the CDM projects in India should not have been certified because they did not reduce emissions beyond those that would have been achieved without foreign investment.
Having studied these projects and their impacts, I submit that Executive Board ought to devise ways to stop such hazardous projects from being designated as CDM projects. I submit that the project in question is one of the 35 Municipal Solid Waste (MSW) projects approved by India’s Designated National Authority (DNA), National CDM Authority. (List attached) I am familiar with 11 of these projects. All the waste incineration based projects mentioned in the list are based on the claimed success of a failed Dioxins emitting waste to energy incinerator plant for 6.6 MW that lies defunct at Elikatta Village, Shadnagar Mandal, Mahboobnagar District, Andhra Pradesh by SELCO International Ltd, which is also mentioned in the list of 35 projects.
I recollect the original plan of Timarpur Waste Management Company Pvt. Ltd. (TWMCPL), a subsidiary of Infrastructure Leasing & Financial Services Ltd. (IL&FS) was to generate 6 MW of electricity to earn carbon credits based on Certified Emissions Reductions (CERs). The project got listed before the Executive Board on 23 May 2006, and the Board had sought comments until 21 June, 2006 after TWMCPL had submitted its project design document. I had submitted adverse comments on it but to no avail.
I submit that 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.
I submit that the Project Design Document deliberately chose 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. It did not reveal that the project is situated in an ecologically fragile residential area.
I submit that promoting waste to energy projects based on burn technologies is that it violates Kyoto Protocol. Waste combustion is a toxic activity and a contributor to global warming but CDM may end up becoming a vehicle to promote it in developing countries as a sustainable activity. Promoting waste incineration under various names such gasification and pyrolysis as renewable energy is an unpardonable environmental sin. Energy drawn from projects that use resource incineration processes is a non-renewable energy and it cannot be used for certified emissions reductions. The fact that waste incineration leads to global warming is acknowledged in the Kyoto Protocol itself where it is listed as one of the sources of green house gases. It is true that the Kyoto Protocol mentions waste management, but what is really happening is that investors and promoters of incineration technologies into India are taking advantage of Article 10(c) of Kyoto, which seeks to facilitate transfer of or access to environmentally sound technologies pertinent to climate change.
I submit that the CDM Executive Board, while deliberating over the criteria for small-scale project activities with a maximum output capacity equivalent of up to 15 megawatts has defined renewable energy as "a project activity that uses partly or in its entirety sources of energy that do not use up the earth's finite mineral resources and that is replaced rapidly by the natural processes". Waste incineration does not meet the criteria of renewable energy but what is emerging is that organic waste as a fuel for electricity generation through combustion processes is being termed a renewable process. This is a gross attempt to twist scientific facts to suit vested interests. It makes a farce of CDM, which encourages renewable energy technologies (RETs) to reduce carbon emissions and not otherwise.
I submit that failure of a similar plant Andhra Pradesh has established that RDF incinerator is a failed technology. It is linked to rising cases of skin rashes, asthma, respiratory problems and some cases of stillborns in the region to the presence of plant. Incinerator based interventions in the waste stream distort waste management beyond repair. Waste to power plants cost cities and municipalities more and provide fewer jobs than comprehensive recycling and composting. It prohibits the development of local recycling-based businesses.
I submit that the Executive Board should promote biological methods instead of hazardous technologies to deal with waste management through material recovery and by recycling. India’s Inter-Ministerial Task Force on Integrated Plant Nutrient Management did not encourage WTE policy and instead recommended setting up of 1000 compost plants all over the country. There is need to provide incentives and subsidies to cold’ technologies alone, which is suited our country economically, socially and also our wastes.
I submit that a Fact Finding team visited the plant site in Andhra Pradesh on August 1, 2011 of SELCO International Ltd’s Refuse Derived Fuel (RDF) incineration technology based waste to energy project at Elikatta village. The Preliminary Fact Finding Survey Report is attached. The Report's preliminary inference states, "On 10th August, Citizens of Vietnam remember the anniversary of the first use of nearly 80 million liters of Dioxins laced Agent Orange as chemical weapon against Vietnam from 1961 to 1971 that has wrecked havoc crippling people and causing hitherto unknown diseases for last 50 years. The Dioxins emitting waste to energy incinerators in residential and ecologically fragile areas or elsewhere tantamount to peace time use of chemical weapon against one’s own citizens and their ecosystem." The Fact Finding Survey team comprised of K Babu Rao, former scientist at the Indian Institute of Chemical Technology, Hyderabad, Narasimha Reddy Donthi, Chief Advisor, Chetana Society, Hyderabad and Gopal Krishna, Convener, ToxicsWatch Alliance (TWA), New Delhi.
The report takes note of the statement of Waste to Energy is non-Renewable Energy- '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,' said Mark Radka, Chief of the Energy Branch, Division Technology, Industry and Economics for the United Nations Environment Programme (UNEP).
I wish to draw your attention towards the White Paper on Pollution in Delhi with an Action Plan' prepared by Union Ministry of Environment and Forests. It 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."
I reiterate that incineration of Refuse Derived Fuel (RDF) violates Kyoto Protocol. As per Annexure A of the Protocol waste incineration is a green house gas emitter.
I submit that the issue was examined by the India’s Supreme Court’s Committee on Waste to Energy: Based on Committee’s recommendations, the Court rejected this technology and approved Biomethanation technology that too only for five pilot projects.
I submit that fiscal incentives for projects of power generation from MSW through new technologies violates Supreme Court’s Order: Supreme Court has put a stay on subsidy for waste to energy projects except 5 pilot projects based on Biomethanation technology. These projects already had incentives from the government which the court stayed.
I wish to draw your attention towards the website of New and Renewable Energy Development Corporation of Andhra Pradesh Ltd, a state government company, it is mentioned under the Success Story section that SELCO INTERNATIONAL LTD is “segregating and processing the heterogeneous garbage and generating Electricity from RDF through municipal solid waste process under waste to energy sector. This Project have produced 6.6 MW Electricity from RDF for the first time in the Country and synchronized with Grid on 8th November-2003 and generating Electricity since then.” It was sanctioned on June 5, 2000. New and Renewable Energy Development Corporation of Andhra Pradesh Ltd was earlier named the Non-Conventional Energy Development Corporation of Andhra Pradesh Ltd (NEDCAP). It is clear that the subsidy regime underlines that the project in question is a business as usual project and does not meet the additionality criteria as well.
I implore the intervention of the Executive Board to ensure that this project and similar projects mentioned in list of 35 projects should be disapproved. More such projects are in offing in Delhi’s Narela-Bawana and Gazipur and in other cities like Patna, Bangalore, Chennai, Pune etc and they are likely to meet the same fate as the Andhra Pradesh plant.
I submit that RDF incineration technology which is being used for waste to energy projects is a thermal and combustion technology, mainly used to prepare waste for mass incineration. Also if mixed waste is burnt, it creates problems of very toxic compounds such as dioxins and furans, heavy metals and other pollutants. The calorific value for the waste comes from materials such as plastics and metals. Plastics, especially chlorinated plastics such as polyvinyl chloride (PVC) when combusted gives rise to these highly toxic pollutants. In fact PVC plastic combustion is banned in India by regulation both in the municipal and bio-medical waste handling rules.
In the light of the above facts, there is need for the Executive Board to send an Inquiry Team to visit the site of the Timarpur-Okhla Waste based Power Plant near Sukhdev Vihar in New Delhi and Municipal Solid Waste to Energy Project at Elikatta Village, Shadnagar Mandal, Mahboobnagar district in Andhra Pradesh to ascertain facts for themselves along with representatives from media and environmental groups.
I will be happy to share more information.
ToxicsWatch Alliance (TWA)
Tel:91-11-65663958, Fax: 91-11-26517814, Mb: 9818089660
Email: firstname.lastname@example.org, Web: toxicswatch.blogspot.com
Mr. Rajiv Kumar, Member Secretary & Designated National Authority (DNA), National CDM Authority
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