ToxicsWatch Alliance (TWA)
Dr Veerappa Moily
Union Minister of Environment & Forests
Member, Cabinet Committee on Economic Affairs (CCEA)
Government of India
January 6, 2014
Subject- Imminent environmental & public health crisis from Delhi’s waste to energy incinerators
This is with reference to the peoples’ march against waste to energy based on hazardous unapproved Chinese technology held in Okhla on January 5, 2014 and the letter of Shri Jairam Ramesh as the Union Minister of Environment & Forests to the Chief Minister of National Capital Region of Delhi underlining the violation of environmental regulations in the matter of unapproved and hazardous Chinese technology based waste to energy plant in Okhla, Delhi. The letter of Shri Ramesh was sent following his site visit on March 30, 2011 and meeting with residents on 31st March, 2011. The photographs of the peoples’ march and the letter is attached.
We submit that hundreds of people marched through Okhla on Sunday, Jan 5th to protest against toxic emissions from a Waste-to-Energy incinerator being operated by Jindal Ecopolis close to
their residences in violation Supreme Court orders and Municipal Waste Handling Rules. They also demanded that ministry of environment & forests should cancel the environmental clearance given to this illegal and illegitimate plant. The plant in question does not have clearance under the Wildlife Act although the plant is situated within 1.7 km of the Okhla Bird Sanctuary, administered by Uttar Pradesh Government. It is not surprising that bird count in the sanctuary is going down at an alarming rate. If immediate steps are not taken the sanctuary might become a ghost sanctuary and Okhla may become a ghost colony.
We demand an inquiry into the circumstances under which this plant was given clearance based on fake public hearing and misleading facts presented in the plant’s Environment Impact Assessment (EIA) report. The clearance was for RDF technology but the plant is operating admittedly based on an experimental technology turning residents and birds of Okhla into guinea pigs. This came to light in a 31 page report submitted by a committee headed by Central Pollution Control Board on orders from Shri Ramesh.
We submit that your ministry's deafening silence on the 31 page report of the Technical Experts Evaluation Committee of Central Pollution Control Board (CPCB) on the Timarpur-Okhla Waste to Energy Incinerator Plant constituted by Union Environment & Forests Minister condemned the Timarpur-Okhla Waste to Energy Incinerator Plant by JITF Urban Infrastructure Limited (Jindal Ecopolis) which has violated every rule in the rule book including environmental clearance conditions is intriguing. It revealed to the Experts Committee in September 2011 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. Its findings merit your attention.
We submit that the power plant in question has been set up by M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited owned by Shri Prithviraj Jindal. This plant is facing bitter opposition from residents, environmental groups and waste pickers. It is facing a case from Sukhdev Vihar Residents Welfare Association in the National Green Tribunal (NGT). The next date of hearing is on January 28, 2014. Earlier, the Delhi High Court listed this very case 28 times till January 2013. Even in NGT one year has passed without any relief to the residents of Okhla. Even Uttar Pradesh Government has joined the case objecting to the controversial plant.
We deeply appreciate that your ministry has assigned the task of “Waste Minimization Strategies Administration” as per the cardinal principles of sustainable waste management.
We submit that contrary to "White Paper on Pollution with an Action Plan" of the Union Ministry of Environment & Forests as per which your ministry’s wisdom is opposed to such municipal waste incinerators, the waste incinerator plant entails waste maximization for energy generation at any human and environmental cost. It is contrary to the cardinal principles of sustainable waste management that a message is being given out that if Delhi residents generate more waste, these waste incinerator based power plants can generate more energy.
The relevant part of White Paper in paragraph 4.1 reads: "The NEERI studies show that the treatment of solid waste not reduces the quantity requiring disposal but also reduces its pollution potential thereby preventing its adverse impact on environment. Some treatment methods also yield a product which can be recycled. Thermal treatment methods such as incineration or conversion of waste to briquettes and its subsequent use as fuel are not feasible due to the low heat value of the municipal solid waste in MCD area. The experience of the incineration plant at Timarpur, Delhi and the briquetting 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." Reference: http://envfor.nic.in/divisions/cpoll/delpolln.html
We submit that Smt. Jayanthi Natarajan, as Union Minister of Environment & Forests informed the Parliament in the matter of “Pollution by Okhla Waste to Energy plant" on March 13, 2012. Her answer was/is incomplete and callous towards the plight of residents, environment and the livelihood of waste pickers.
We submit that the change in government in Delhi happened because of such anti-people, anti-environment and anti-public health initiatives.
As an environmental health research group, ToxicsWatch Alliance (TWA) has been opposing the hazardous incinerator technology since 2000 and the proposal of Okhla municipal waste incinerator plant since March 2005 due to its adverse public health consequences. The plant in question has violated every rule in the rule book. It is a matter of fact that such plants have consistently failed in India.
We submit that at a 2-day conclave in the national capital organised by Centre for Science and Environment (CSE) during 24-24 February 2012, on behalf of TWA gave testimony on the environmental lawlessness with regard to the waste incinerators in Delhi in front of the 150 participants from about 100 organisations. The conclave ended with a charter demanding consent of the people as a ‘must’ before granting clearances and cumulative impact assessment among other things. The people of Okhla never gave their consent for the hazardous project in their proximity. There is documentary evidence that the public hearing that was conducted was only fake, it was conducted at Saket. The environmental clearance given to the project is also flawed as it has been amended repeatedly to increase the amount of waste treated and energy generated in an apparent effort to grab subsidies being offered by MNRE. The cumulative impact assessment of the pre-existing biomedical waste incinerator and the new municipal waste incinerator has never been done. The emissions from both these units are already becoming part of body burden of residents of Okhla.
This is to draw your attention towards the imminent public health crisis due to biomedical waste incinerator plant and the construction of municipal waste to energy incinerator in Delhi's Sukhdev Vihar residential area which is surrounded by university, schools, hospitals, bird sanctuary and several other residential areas of Okhla. Similar hazardous plants are proposed in Delhi's Narela-Bawana and Ghazipur. It is germane to mention that several waste incinerator technology based projects are proposed all over the country.
We submit that this grave situation has emerged due to evidently flawed waste to energy policy of Union Ministry of New & Renewable Energy (MNRE) which is providing fiscal incentives to hazardous incinerator and co-incineration incineration technologies like Refuse Derived Fuel (RDF). The MNRE must be persuaded to give this aspect of the policy to save irreparable damage to sustainable and sane municipal solid waste management practices. It may be noted that besides being an emitter of Persistent Organic Pollutants, as per Annexure A of Kyoto Protocol, waste incineration is a green house gas emitter. The Ministry of Power can vouch for the fact that the energy from municipal is inconsequential compared to the colossal public health concerns.
This is to draw your attention towards the imminent public health crisis due to the municipal waste to energy incinerator in the Sukhdev Vihar residential area which is surrounded by university, schools, hospitals, bird sanctuary and several other residential areas of Okhla. Similar hazardous plants are proposed in Narela-Bawana and Ghazipur. It is relevant to note that 35 waste related carbon credit projects have been given host country approval by the National CDM Authority across the country. The waste to energy incinerators proposed in Delhi is included in it.
We have read the relevant above mentioned minutes of the Environment Pollution (Prevention & Control) Authority for the NCR (EPCA) wherein Municipal Corporation of Delhi (MCD) was asked about the actions taken to improve Municipal Solid Waste (MSW) management in Delhi in your presence. "To this MCD replied that individual waste to energy projects have been already given to Jindal, Ramky and GMR, which will result in minimal inert residue for landfilling along with the generation of electricity," the minute reads. This is factually deceptive and scientifically incorrect.
We submit that as per the Manual on Municipal Solid Waste Management, Union Ministry of Urban Development, physical composition of Indian waste shows that inert material constitutes from 43.59 % to 53.90 % and compostable matter constitutes 44.57 % to 30.84 %. Thus, the total inert residue from waste to energy incinerator projects will be significantly higher after the incineration of waste which will produce toxic ash as well that requires disposal in engineered landfills. The same manual reveals the chemical composition of Indian waste has the calorific value of 1009.89 kcal/kg to 800.70 kcal/kg with moisture content ranging from 25.81 % to 38.72 % and organic matter ranging from 37.09 % to 39.07 %.
It has been established that everything organic has a ratio of carbon to nitrogen (C:N) in its tissues. It is the combination of materials that creates the ideal climate for compost microbes-a C:N ratio of 30:1. In such a context, a Technical Report titled "Environmental Audit of Municipal Solid Waste Management, June 2006" infers, "we can deduce the Indian waste has a high content of organic matter, which makes it suitable for processes like composting and anaerobic digestion. The C/N ratio is between 20-30 and this ratio is very suitable for composting (Eiland, et al, 2001). The waste also has a high moisture content which makes it unsuitable for incineration." The audit was done with financial assistance from the Union Ministry of Science and Technology. Reference: CES TECHNICAL REPORT - 112 Energy and Wetlands Research Group, Centre for Ecological Sciences, Indian Institute of Science, Bangalore.
We submit that the waste to energy incinerator projects mentioned by MCD does not make municipal solid waste disappear or minimize inert residue instead they maximize it. They encourage waste generation and current patterns of production and consumption, which are at the root of solid waste problems. They are the most costly of all solid waste management options; result in air and water pollution, and still need to be supplemented by landfills as they produce an ash that is far more toxic than ordinary domestic trash. This has not been disclosed in a deliberate act by MCD which has chosen not to learn from its failure in Timarpur and Ghazipur.
We submit that even with waste to energy incinerators NCR will still need landfills for ash disposal and construction wastes. Ash can comprise about 25% by weight of an incinerator’s throughput and must be landfilled. Thus, incineration means incineration plus landfill. There are two kinds of by-pass waste: bulky materials that do not fit into the incinerator (such as mattresses), and collected waste that cannot be burned when the incinerator is down for regularly scheduled or unscheduled maintenance. These materials typically require landfilling in communities that have built incinerators.
It is clear from Environmental Ministry's White Paper and the Technical Report prepared with assistance from Ministry of Science and Technology that MCD's “waste load” and its mishandling by the aforementioned contractors will distort the municipal solid waste management beyond repair. From the minutes of the meeting of the EPCA, it is evident that municipal corporation is relying on failed technology in the following projects:
1. 2050 Metric Ton project at Okhla by Jindal company
2. 1000 Metric Ton project at Narela-Bawana by Ramky company
3. 1300 Metric Ton project at Ghazipur by GMR company
We submit that municipal corporation has not disclosed that Ramky Enviro Engineer Ltd proposes to process 4000 MT of waste in two phases using RDF incineration technology in Narela-Bawana adjacent to Sannaut village of Delhi and other residential areas. Having visited the plant site and having interacted with the villagers, one found that they are protesting against the proposed Dioxins emitting plant.
We submit that it is estimated that after all these 3 plants would be functional they will require approximately 7300 MT of waste to produce the projected amount of energy.
We wish to draw your attention towards the analysis published in ECO magazine (March, 2012) which notes that the plant is situated not only in the proximity of New Friends Colony, Maharani Bagh, Sukhdev Vihar and the business district Nehru Place - but also several prominent institutions, including hospitals like Apollo, Escorts and Holy Family. But disregarding these, as also a number of binding guidelines from multiple state agencies and at least one Supreme Court directive, the plant has come up, under the shade of slack regulation, at one-tenth the cost of a world-class waste-to-energy facility, deploying China-made equipment and inadequately provisioning for toxic by-products of incineration. It is strange that the Delhi government is backing the project as a technology solution to the city's two enduring, and worsening, problems - excess of waste and shortage of power. But while contributing to the solution of two problems, the plant kindles a number of new ones, with potentially serious health and environment implications for the residents of Delhi.
Unmindful of such concerns, the owners of this controversial plant are making false claims about the technology being used at Okhla is absolutely safe. The polluting potential of a 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, which are among the most toxic substances known to science.
We submit that the same is true about GMR Energy Ltd's New Delhi Waste Processing Company Private Ltd (now renamed as Indraprastha Energy and Waste Management Company Private Limited), Joint venture of Govt.of Delhi and IL & FS for the “Implementation of Integrated Municipal Solid Waste Processing (MSW) (waste to energy) complex” on BOOT basis at Ghazipur, Delhi. A case has been filed against it by the residents in the Delhi High Court. A statement on GMR website reveals "DIAL-SELCO consortium participated in the BID and emerged as winner in the BID. The proposed project is being setup on 5.73 acres of Land at Ghazipur, East Delhi owned by Delhi Power Company Limited (DPCL), which has been given on lease basis to GMR's East Delhi Waste Processing Co. Pvt. Ltd.
The reference to SELCO on GMR website merits attention. A Fact Finding team comprising of Dr K Babu Rao, former scientist at the Indian Institute of Chemical Technology, Hyderabad, Dr Narasimha Reddy Donthi, Chief Advisor, Chetana Society, Hyderabad and the author visited the plant site of SELCO International Ltd’s Refuse Derived Fuel (RDF) incineration technology based waste to energy project at Elikatta Village, Shadnagar Mandal, Mahboobnagar district and found the plant to be locked on August 1, 2011. This is the plant that was cited a successful example by Shri Najmi Waziri, Delhi Government's counsel on 18th July, 2011 in the Delhi High Court in front of Chief Justice Bench to defend Delhi’s Okhla Waste to Energy plant.
The security guard of the SELCO International Ltd's 6.6 MW Municipal Solid Waste to Energy Project at Elikatta Village, Shadnagar Mandal, Mahboobnagar District, Andhra Pradesh informed the team that the plant is closed for the last three years. This fact has been verified with the local people and a site inspection too revealed the same.
We submit that the municipal waste to energy incinerator in the residential area is based on hazardous incinerator technology that emits persistent organic pollutants like Dioxins and toxic heavy metals like Mercury. Incinerators are tried, tested and failed technology.
We submit that the three waste to energy incinerators in Delhi are in violation of the Supreme Court order in Writ Petition (Civil) 888 of 1996.
We wish to submit research papers and relevant documents to you to help prevent public health disaster due to biomedical waste incinerator plant and the construction of municipal waste to energy incinerator plant in the Okhla area in particular and in Delhi in general. Such unprecedented health crisis has been witnessed in Gandhumguda village, Peeranchery Panchayat, Ranga Reddy district in Andhra Pradesh where SELCO ran its waste to energy incinerator plant. The same was brought to the notice of the Supreme Court's Waste to Energy Committee by the residents and the author of this letter following which the Court only approved biomethanation technology. This order echoes the recommendations in the White Paper and the Technical Report.
It was heartening to find its reference even the National Action Plan on Climate Change released by you but saddening to find promotion of hazardous incinerator technology in the Draft National Mission on Sustainable Habitat. One is still hopeful that your Council on Climate Change will do the needful in order to adhere to the cardinal principles of waste management in this respect.
We also wish to draw your attention towards the ongoing protest rallies and an online campaign on Facebook - Okhla ka Ghosla- against the toxic, waste-to-energy incinerator where students are also participating in large numbers.
In view of the above, a delegation of residents, environmental and waste picker groups would like to meet you to apprise you of the emerging situation due to these hazardous commercial and industrial establishments in residential areas which appears to be an act of environmental lawlessness in the heart of the national capital. Kindly suggest when we can meet you at the earliest.
ToxicsWatch Alliance (TWA)
Shri Arvind Kejrial, Chief Minister, Government of NCT Delhi
Dr. Farooq Abdullah, Union Minister of New & Renewable Energy
Shri Kamal Nath, Union Minister of Urban Development
Shri Jairam Ramesh, Member, Cabinet Committee on Economic Affairs (CCEA)
Shri Susheel Kumar, Additional Secretary, Union Ministry of Environment & Forests