Dr Sudhir Krishna Secretary Union Ministry of Urban Development Government of India New Delhi
Date: September 22, 2012
Subject- ‘Unproven technologies’ for electricity generation from waste based power plants major public health concern in Delhi’s Okhla, Narela-Bawana, Gazipur and elsewhere
This is with reference to your submission in the matter of waste to energy projects at the International Conference organized by Confederation of Indian Industry (CII), Union Ministry of Urban Development, British High Commission and Athena Infonomics, a consultancy firm on September 20, 2012 at India Habitat Centre, New Delhi.
I wish to inform you that at the conference Mr Andrew Jackson, Counsellor, Knowledge Economy, British High Commission released a 136 page book ‘Public Private Partnerships in Urban Water Supplu and Municipal Solid Waste Management’ edited by Deepa Kerthykeyan, Arslan Aziz, Ankit Kumar Chatri and Saloni Shah of Athena Infonomics. A copy of this book was given to you as well prior to your valedictory address.
I want to draw your attention towards what is underlined at page 82-83. Under the title ‘Unproven technologies’, it reads: “Controversies in the scientific and environmental arena for some waste management technologies e.g., incineration, plasma gasification, have made ULBs (Urban Local Bodies) apprehensive about going ahead with such technologies.” It refers to an article The Economist which has underlined that “…few people were aware that such chemicals (that waste incinerators emit) presented a serious health hazard, capable of upsetting the immune system, damaging the liver and causing cancer.”
At page 83 of the book there is a box titled ‘Waste to Energy Plant- Municipal Corporation of Delhi’, it reads: “The Municipal Corporation of Delhi (MCD) established a 3.75 MW waste to energy (wte) plant with assistance from government of Denmark in 1987 to address the twin problems of waste disposal and electricity shortage faced by the city. The capacity of the plant was 300 TPD of solid waste and was set up at the cost of Rs 25 crore by Volund Milijotechnik A/S Denmark that also supplied the incineration technology. The plant started operations but was shut down…”
I submit that the Comptroller and Auditor General of India (CAG) had also conducted an inquiry after the Delhi High Court ruled in April 2001 on the Timarpur waste to energy plant's failure. The court had taken issue with the procurement of the incineration plant and said that "No order should have been placed for procurement of the plant unless its utilities were completely known."
I submit that criticism did not come just from the Delhi High Court. Referring among other things to the originally 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." The White Paper on Pollution in Delhi with an Action Plan is available on Environment Ministry’s website.
I submit that 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, the Chairman of the Parliamentary Standing Committee on Energy wrote to the Union Ministry of New and Renewable Energy (called Ministry of Non conventional Energy Sources) on 14 June 2005 seeking review of its WTE programme. The Chairman 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."
I submit that amidst bitter opposition from residents, waste pickers and environmental groups a Writ Petition (Civil) NO. 9901/2009 in the Hon’ble Delhi High Court against the power plant by 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 October 19. In the Hon’ble Supreme Court a related matter [Writ Petition (Civil) 888/1996] in which there was an order passed putting a stay on power plants based on waste incineration, is listed for hearing on October 1, 2012.
I submit that Parliamentary Standing Committee on Energy has once again been apprised of the waste to energy projects based on polluting incinerator technologies.
I wish to draw your attention towards the 31 page report of the Union Environment & Forests Ministry constituted Technical Experts Evaluation Committee of Central Pollution Control Board (CPCB) on the Timarpur-Okhla Waste to Energy Incinerator Plant has condemned the Timarpur-Okhla Waste to Energy Incinerator Plant by JITF Urban Infrastructure Limited (Jindal Ecopolis) has violated every rule in the rule book including environmental clearance conditions. It revealed to the Experts Committee that it is using untested and unapproved Chinese incinerator technology in complete violation all laws and environmental clearance of 2007 including its own project design document and environment impact assessment report. Chinese technology provider is from Hangzhou New Century Company Ltd of Hangzhou Boiler Group. The critique of the report is attached.
I submit that at the conference I had asked Prof. Mukul Asher of Lee Kuan Yew School of Public Policy, National University, Singapore, the Moderator of the Technical Session II about the appropriateness of waste-to-energy incinerators of Singapore which is cited as solution for the national capital in India unmindful of the study of application of life cycle assessment (LCA) for evaluating various waste management options in Singapore which recommends, “Out of all the waste strategies, the recycling of wastes offers the best solution for environmental protection and improved human health for the nation. Significant emission savings can be realized through recycling.”
The study was done by Department of Chemical and Biomolecular Engineering, National University of Singapore. According to this study titled ‘Impact assessment of waste management options in Singapore’ observed, “The impact assessment results for climate change, acidification, and ecotoxicity show that the incineration of materials imposes considerable harm to both human health and the environment, especially for the burning of plastics, paper/cardboard, and ferrous metals. The results also show that, although some amount of energy can be derived from the incineration of wastes, these benefits are outweighed by the air pollution (heavy metals and dioxins/furans) that incinerators produce.” Prof. Asher observed that one country solution cannot be considered appropriate for another country. It is also a fact that the composition of Singapore’s municipal waste and that of Indian waste is quite different.
I submit that Union Minister for Environment & Forests has acknowledged in the Parliament that “complaints were received against the incineration of municipal waste and its likely harmful effects on the air quality and health of people in the Sukhdev Vihar/Okhla area due to the emissions from Waste-to–Energy plant at Okhla… on four occasions out of ten, levels of Particulate matter (PM) exceeded the standard of 150 mg/Nm3” however “the Minister said that as per the Central pollution Control Board, the technology being used by the Waste-to-Energy plant at Okhla is as specified in the Municipal Solid Waste (Management and Handling) Rules, 2000.” This is far from truth as is evident from the CPCB’s report which is now in public domain.
I submit that in the report, Dr A B Akolkar, Director, CPCB emphasized that as per Municipal Solid Waste (Management & Handling) Rules ‘biodegrdable waste’ is to be treated using biological method rather than deriving RDF or by incineration as is being done by Jindal Ecopolis. This clearly demonstrates that the Timarpur-Okhla Waste to Energy Incinerator Plant violates the Municipal Solid Waste (Management & Handling) Rules framed under Environment Protection Act, 1986.
I submit that in the Writ Petition (Civil) No. 9901 of 2009 in Delhi High Court, legal officials like Mr A S Chandiok Additional Solicitor General and Standing Counsel for the Delhi Government and for the Delhi Pollution Control Committee, Najmi Waziri has been misleading and misrepresenting facts about waste to energy plants in Andhra Pradesh by saying that “the Refuse Derived Fuel incineration technology was already in use at Hyderabad and Vijayawada”. The fact is that there is no plant in Hyderabad. The plant that became functional as per legal officials now stands defunct in Shadnagar, Mahboobnagar district of Andhra Pradesh. On 18th July, 2011, Delhi High Court asked CPCB and the Delhi Pollution Control Committee (DPCC) to conduct a joint inquiry about India's first waste-to-energy plant and file a report on the allegations that it posed health risks to citizens. "A joint report be submitted by the DPCC and the CPCB after an inquiry of the site of the energy plant about the alleged risks posed to citizens," ordered a bench of Chief Justice, Delhi High Court. This has not been done so far. A bizarre situation has emerged because the arguments for ‘Refuse Derived Fuel incineration technology’ that was advanced by the law officers is no more relevant because the plant is using an experimental Chinese technology which was never ever mentioned at the time of submitting the project proposal.
I submit that there have been incessant demonstrations and protest rallies against this project. There is an ongoing campaign against it. The plant that has been built despite protest is 150 m from the residential areas. The area has a bird sanctuary, a university and three hospitals within a radius of 10 kilometres. All will be adversely affected by toxic fumes of the plant. The idea of waste to energy plants which is based on a tried, tested and failed incineration technology in Okhla.
I submit that MCD, Delhi government and central government has shown inexcusable callousness towards hazardous emissions from municipal incinerators that cause serious environmental and health problems both to people living near them and thousands of kilometres from the source. These projects are destroying the livelihood of about 3.5 lakh waste recycling workers and valuable resource material for compost that is required to be treated by composting/anaerobic digestion/vermin composting/other biological processing for stabilization as per Municipal Solid Waste (Management & Handling) Rules.
I submit that representatives of GTZ (German Technical Cooperation) led by Dr. Juergen Porst, Senior Advisor have stressed the need for a Disaster Management Plan in the very first meeting of the CPCB’s Technical Expert Committee, which is annexed to the CPCB’s report. But this does not find mention in the recommendations of the report. This finds reference in the minutes of the meeting annexed with the report. It underlines the possibility of disaster from the Timarpur-Okhla Waste to Energy Incinerator Plant, which is situated in a residential area. It is noteworthy that a hazardous plant in Bhopal’s residential area that led to world worst industrial disaster in 1984 also did not have any disaster management plan.
I submit that the Review of Technical Evaluation by Anant Trivedi, Member, Technical Evaluation Committee, CPCB reads: "The Okhla plant has a capacity of 2050 tpd of domestic waste input. However the plant design allows upto 10,000 tpd of input for incineration. Toxic bottom ash quantity produced will be 20-30% of input. This amounts to at least 410 tpd rising to a maximum of 3,000 tpd. Additionally there will be toxic flyash of about 10% of the bottom ash.None of the landfill sites have the capacity to take in so much toxic waste and mulba has been dumped everywhere including all public spaces." He asks, "so what is proposed to safeguard public health from this toxic substance?
I submit that the report apprehended that the information that is submitted to the experts committee of CPCB might be used in the on-going case in the Delhi High Court. It makes a shocking revelation that although High Court has been hearing the case since 2009, the project proponent did not inform the court about gross deviations from the project design plan envisaged in the EIA report. As per the minutes of the second meeting of the technical experts committee, non-cooperative approach of the senior officials of Timarpur-Okhla Waste to Energy Incinerator Plant was condemned on August 11, 2011. Representatives of GTZ underlined that there was lack of transparency with regard to environmental and health impact on the neighborhood residents. It was also noted that the fugitive emissions and the expected emission of Dioxins and Furans has not been quantified. The characteristic of ash and required standards was not mentioned. Prof. T R Sreekrishnan, Department of Biochemical Engineering and Biotechnology stated that disposal option for incineration instead of bio-methanation proposed for green waste is in violation of what was mentioned in the EIA report.
I submit that CPCB report steers clear of the fact that fiscal incentives for projects of power generation from MSW through new technologies violates Supreme Court’s Order: The court has put a stay on subsidy for waste to energy projects except 5 pilot projects based on Biomethanation technology. It has come to light that none of Delhi’s three projects are based on biomethanation technology and are not the pilot projects approved by the court. The Timarpir-Okhla project is getting incentives from the government although the apex court has put a stay on subsidy. Although the court’s order applies to Delhi’s other waste to energy incinerator projects it is functioning with impunity.
I wish to inform you that I mentioned at the conference about a Fact Finding team’s visit to the plant site in Andhra Pradesh of SELCO International Ltd’s Refuse Derived Fuel (RDF) incineration technology based waste to energy project at Elikatta village, Shadnagar Mandal, Mahboobnagar District, Andhra Pradesh and found it to be lying in defunct, rusting and abandoned condition where cows were seen grazing in the dilapidated factory premises. It is the same plant which was cited as a successful plant in the High Court to advocate Okhla’s power plant.
It may be noted that earlier, Asian Development Bank (ADB) withdrew from this Rs 200-crore power project at Okhla in south Delhi. The bank had promised about Rs 10 crore to the plant under the Asia Pacific Carbon Fund. ToxicsWatch Alliance (TWA), a research and advocacy group had written to the ADB. In a reply, ADB informed: “Asia Pacific Carbon Fund is no longer associated with TOWMCL integrated waste-to-energy project in Delhi and no funds were released to this project” besides that it has also decided to stop providing technical assistance to the project.
I submit that as per the principles of waste management what is required is a resource management strategy for municipal solid waste 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 the above, it is clear that ‘Unproven technologies’ for electricity generation from waste based power plants major public health concern in Delhi’s Okhla, Narela-Bawana, Gazipur and elsewhere is technologically incompatible with reducing dioxins and heavy metals emissions. It is noteworthy that these projects rely on minimum guaranteed waste flows. It indirectly promotes continued waste generation while hindering waste prevention, reuse, composting, recycling, and recycling-based community economic activities. It costs cities and municipalities more and provides fewer jobs than comprehensive recycling and composting. It prohibits the development of local recycling-based businesses. At the conference, I mentioned the conclusively established inappropriateness of the incineration based waste to energy initiatives in Delhi by Ramky, GMR and Jindal companies.
I wish to request you to revisit the Waste to Energy policy being pushed by the Union Ministry of New and Renewable Energy to ascertain whether or not it is distorting waste management beyond repair after paying a site visit and interaction with the residents at the Timarpur-Okhla power plant in Sukhdev Vihar, Hazi Colony, Gaffar Manzil and others.
Let me take the opportunity to request you invite CAG to audit the waste to energy projects and the subsidies being cornered.
I will be happy to meet you with a delegation and share relevant documents mentioned above.
Yours faithfully Gopal Krishna Convener, ToxicsWatch Alliance (TWA) Mb: 9818089660, Email: firstname.lastname@example.org Web: toxicswatch.blogspot.com Okhla Anti-incinerator Committee, http://www.facebook.com/home.php#!/ghoslaokhla Cc Shri Kamal Nath, Union Minister of Urban Development Lt Governor, Government of National Capital Territory of Delhi Chief Secretary, Government of Andhra Pradesh Chief Secretary, Government of Bihar Chief Secretary, Government of Chattisgarh Chief Secretary, Government of Goa Chief Secretary, Government of Gujarat Chief Secretary, Government of Haryana, Chief Secretary, Government of Himachal Pradesh Chief Secretary, Government of Jammu and Kashmir Chief Secretary, Government of Jharkhand Chief Secretary, Government of Karnataka Chief Secretary, Government of Kerala Chief Secretary, Government of Madhya Pradesh Chief Secretary, Government of Maharashtra Chief Secretary, Government of Orissa Chief Secretary, Government of Punjab Chief Secretary, Government of Rajasthan Chief Secretary, Government of Tamil Nadu Chief Secretary, Government of Uttar Pradesh Chief Secretary, Government of Uttarakhand Chief Secretary, Government of West Bengal Chief Secretary, Government of Puducherry Chief Secretary, Government of Arunachal Pradesh Chief Secretary, Government of Assam Chief Secretary, Government of Manipur Chief Secretary, Government of Meghalaya Chief Secretary, Government of Mizoram Chief Secretary, Government of Nagaland Chief Secretary, Government of Sikkim Chief Secretary, Government of Tripura Chief Secretary, Government of Andaman and Nicobar (UT) Administrator, Government of Dadra and Nagar Haveli (UT) Administrator, Government of Daman and Diu (UT) Administrator, Government of Lakshadweep (UT)