Critique of Draft EIA/EMP Report of Expansion Of Power Plant from 16 MW To 40 MM (Waste To Energy) of Near Okhla STP, Okhla, New Delhi
Photo: Waste based thermal power plant of The Timarpur Okhla Waste Management Company Ltd. (TOWMCL), M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited in Sukhdev Vihar, Hazi Colony, Okhla residential area. Photo Credit: Gilbert Kolonko
Photo: Notice for Environmental Public Hearing at Lajpat Nagar on the Expansion of Waste to Energy Plant of Timarpur Okhla Waste Management Company Ltd at Okhla STP, Near Sukhdev Vihar, New Delhi
The notice of the Environmental Public Hearing reveals that there is a manifest procedural violation of the EIA Notification 2006 under the Environment (Protection) Act, 1986. Public Hearing was scheduled to be held at Lajpat Nagar on 16th January, 2019 for the Expansion of Waste To Energy Plant of Timarpur Okhla Waste Management Company Ltd at Okhla STP, Near Sukhdev Vihar, New Delhi.
The venue of the EIA Public Hearing was far from the site of the waste based thermal power plant. The plant is in Sukhdev Vihar, Okhla but at the venue of the Public Hearing was at the Office of District Magistrate, Southeast Delhi, Lajpat Nagar, New Delhi, which is some 5-10 km far from the plant site. It is a clear violation of September, 2006 EIA Notification, Clause No. 1 of the Procedure for Conduct of Public Hearing as mentioned in the Para 7 of the Annexure-IV, which clearly mentions that the project site should be the venue of Hearing.
The time duration fixed for the EIA Public Hearing was very short, i.e. of two hours only from 11 AM to 1 PM. The Clause No. 1 of the EIA Notification, 2006 clearly states that the Hearing should give opportunity to "widest possible public participation." The notice makes a mockery of the EIA notification and the procedure of public hearing. It takes the consent of residents of Okhla for granted by transforming the EIA process into an empty ritual and a non-serious formality.
DPCC has failed to change the venue of the Environmental Public Hearing. It has failed to extend its time and it also failed to re-notify a new date and venue as requested by the residents. In such a backdrop, the residents did not allow the illegal and fake public hearing to take place.
Residents are seriously perturbed with the initiatives of the Government of NCT of Delhi and its agencies in the name of ‘development’ in our area, and for the sake of rest of Delhi. This area, which has a dense population, has been treated and identified has a dumping ground for the hazardous projects such as common biomedical plant (already functioning), and now the government is hell-bent on setting up monstrous municipal solid waste based “waste-to-energy” incineration project, which is being marketed as the "eco-friendly and renewable" project. As per the United States Environmental Protection Agency (USEPA), all municipal waste combustors (i.e. incinerators), regardless of technologies, release a number of pollutants, including cadmium, lead, mercury, dioxin, sulfur dioxide, hydrogen chloride, nitrogen dioxide, and particulate matter. Dioxin and mercury are of particular concern because they are toxic, persist in the environment, and bioaccumulate. The Delhi Government’s decision of setting up the said project is ill conceived, and blatantly ignores the present demography of the surrounding areas of the proposed site. How can the government allow such a hazardous project amidst residential colonies while ignoring the current geography of the area? This plant emits large quantities of hazardous and toxic emissions (such as dioxins and furans) due to burning of mixed Municipal Solid Waste, and profoundly affects the health of the people living in the surrounding areas and environment for all times to come in future. This is in violation of the fundamental right under Article 21 of the Constitution of India and Articles 47, 48A and 51-A (g) of the Constitution.
The proposed project is located amidst dozens of densely pullulated residential colonies like Sukhdev Vihar, Noor Nagar, Masih Garh, Haji Colony, Gaffar Manzil, Johri Farm and parts of Jamia University etc. The nearest human settlement is just 100 meters from the proposed site. Besides this, the site is in proximity of hospitals like Holy Family, Fortis-Escorts and Apollo. While the government is strictly pushing all the industries outside the city limits, this WTE Project is being allowed in the residential area, and projected as an environmentally sustainable option which is nothing but fraud on the residents of these colonies. This is going to spoil the quality of life and living, the quality of the air for breathing, the quality of under-ground water and bring disaster to lives of all the residents of the affected colonies.
The plant is in the vicinity of ecologically sensitive zone having Okhla Bird Sanctuary, Asola Wildlife Sanctuary, Jahanpanah City PF, Tilpat forest and Central Ridge Reserve Forest.
The residents are clearly the “victims” of improper, unjustified planning reflecting no concern towards the health of the residents. This kind of “planning” disregards all the scientific evidence. The residents have been demanding stoppage of this project to avoid Bhopal Gas disaster like situation in this residential area.
At page no. 1 of the Executive Summary of the Draft EIA/EMP Report of Expansion of Power Plant from 16 MW To 40 MM (Waste To Energy) of Near Okhla Stp, Okhla, New Delhi prepared by M/s Yes Enviro Solutions Ltd the Consultant of The Timarpur Okhla Waste Management Company Ltd. (TOWMCL), M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited, it has been stated that “Waste collected in city contains a large amount of biological and recoverable materials. It is therefore a source of renewable energy.” These submissions made in the Draft EIA/EMP Report are scientifically and factually incorrect and misleading.
It is noteworthy that the Terms of Reference for the EIA for the proposed expansion of the existing project has been given by the Experts Appraisal Committee (EAC) on Thermal Power Projects Union Ministry of Environment, Forest and Climate Change. Earlier, the ToR of the EIA and the environmental clearance for the existing project was given by the Experts Appraisal Committee (EAC) on Infrastructure and Miscellaneous Projects + CRZ, Union Ministry of Environment, Forest and Climate Change. There seems to a procedural mistake and inconsistency with regard to the jurisdiction of the EAC which has awarded ToR for the proposed expansion.
Given the fact that at present India has surplus power to the tune of 3,000-4,000 MW as India's total power capacity increased from 243 GW in March 2014 to 320 GW in March 2017 and as of 31 December 2018 India has an installed capacity of 347.22 GW, there is no compelling logic for the extraction of power from WTE plants.
At page no. 22, it is claimed by the consultant of the Jindal’s company that “This project is green initiative for electricity production.” It is a boastful claim divorced from reality on the ground. Several reports of Delhi Pollution Control Committee (DPCC) and Central Pollution Control Board (CPCB) have found this project highly polluting. The verdict of National Green Tribunal (NGT) found these findings to be true.
The perpetuation of the myth claiming waste incineration as a source of ‘renewable energy’ has deeply harmful ramifications. European Commission’s definition of Renewable Energy Directive states that ‘energy from renewable sources’ is derived only from non-fossil sources. As per this definition energy from waste is not a renewable energy because waste is not a non-fossil source. It is “energy from a source that is not depleted when used, such as wind or solar power”.
Waste is not like wind or solar. It consists of paper, plastic food etc – all having been made from other sources of energy and resources. For instance, if waste consists entirely of plastic (for example) and generates 100MW of energy per tonne, it’s only renewable if it took less than 100MW of energy to produce. If this is how energy is being defined as ‘renewable’ then Waste to Energy is not renewable energy.
A road that harnesses the movement and sound of cars to create electricity is not typically considered ‘renewable’ because it relies on a car’s use of fossil fuels to move. It is this very principle which is being applied to waste.
Jindal company’s submission that generating electricity using a non-conventional energy source instead of fossil fuel must be deemed a renewable energy project is scientifically questionable. waste burning technology cannot automatically be deemed a renewable energy project. If anything, such attempts to classify the WTE plant as renewable project is farfetched. Waste incinerator technologies are net energy losers when the embodied energy of the materials burned is accounted for.
The move by the incineration industry to persuade public institutions to term waste incinerators as 'renewable energy' projects is not only fraudulent but also dangerous. 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. The advocates of waste incinerators prefer to pre-empt segregation and recycling efforts being made by municipalities and communities around the world.
The massive pollution caused by the incineration technology based Waste-to-Energy plant of Jindal company at Sukhdev Vihar, Okhla in the vicinity of Hazi colony, Gaffar Manzil and several residential and sensitive institutional entities besides Okhla Bird Sanctuary. The residents of Okhla region are quite perturbed and alarmed about it. The residents of Okhla region are in a state of profound fear because of the expanison of the plant’s capacity from 16 MW to 40 MW. This amounts to transforming the residents and wild life in the area into guinea pigs for testing war chemicals in peace time. The emission of Persistent Organic Pollutants (POPs) like Dioxins from the plant in this residential and ecologically fragile area is akin to use of Agent Orange, a war Dioxins based war chemical used by US Army against Vietnam. Agent Orange is an herbicide and defoliant chemical, one of the "tactical use" Rainbow Herbicides. It is widely known for its use by the U.S. military as part of its herbicidal warfare program, Operation Ranch Hand, during the Vietnam War from 1961 to 1971.
The expansion which is underway without any Public Hearing is illegitimate and illegal. This activity is in addition to deviation in technology for which environmental clearance was obtained. It has resulted in severe pollution to the environment. The fact is that contrary to the Environment Impact Assessment (EIA) report, bio-methanation plant and Refuse Derived Fuel (RDF) units do not exist. This plant violates siting norms for polluting industries, being barely 150 meters from long-established residential areas, posing a threat to life of residents.
No residential locality in its sanity can give consent to allow expansion of un-segregated municipal waste incineration based thermal power plant in their locality. They cannot be expected to be superior bearers of risk. The EAC cannot turn a blind eye to serious health hazard to tens of thousands of people living and working in this ecologically-sensitive area. It is noteworthy that two major hospitals in the area have complained to the Prime Minister's office about the hazards to patients as well.
The claims made by the project proponent with regard to compliance at Okhla by M/s Timarpur-Okhla Waste Management Co. Pvt. Ltd to the Specific Conditions and General Conditions laid down in the Environment Clearance are factually incorrect and misleading. Specific Condition reads: No Objection Certificate from the Delhi pollution Control committee should be obtained before initiating the project.
Status of Compliance: Delhi Pollution Control Committee (DPCC) has been issuing show cause notice to the project proponent for violation of Specific Conditions which reads: “To minimize odour and aesthetics, it should be ensured that waste will be directly unloaded into specifically designed pits. The air contained in the complex should be suitable treated with wet scrubbing method before lettering out in the atmosphere.”
Status of Compliance: The entire Okhla region surrounding the waste to energy plant is contaminated with toxic ash emanating from the plant. The air pollutants from this plant contribute to the overall air pollution in Delhi that is having adverse health impact and reducing life span of the individuals.
General Condition reads: In case of diversion or alteration in the project including the implementing agency, fresh references should be made to Ministry for modification in the clearances conditions or imposition of new one for ensuring environmental protection. The project proponents should be responsible for implementing the suggested safeguard measures.
Status of Compliance: Although there has been admitted “diversion or alteration in the project including the implementing agency” especially with regard to technology, no fresh references has been made to Ministry for modification in the clearances conditions or imposition of new one for ensuring environmental protection.
This violation of Environment Impact Assessment Notification, 2006 is part of ongoing violations by this project proponent from the very outset. This fact has been admitted by the Union Minister of Environment & Forests in his letter to the Chief Minister of Delhi.
The following details are relevant in this regard:
1. It all started with the plan of The Timarpur Waste Management Company Pvt. Ltd. (TWMCPL), a subsidiary of Infrastructure Leasing & Financial Services Ltd. (IL&FS) to generate electricity from the project at Timarpur, Delhi. The plant got subsequently owned by M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited. At the outset it planned to process and to 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 (PDD) submitted to United Nations Convention on Climate Change (UNFCCC)’s CDM Executive Board.
2. Environmental Impact Assessment (EIA) of Municipal Solid Waste facility at Okhla was submitted by New Delhi Waste Processing Company Private Limited, Okhla, New Delhi (NDWPCL), Infrastructure Leasing & Financial Services (IL&FS). Thus, one arm of the company ILFS proposed the project and another arm of the same company prepared the EIA report. A case of conflict of interest is quite manifest. The report prepared in December 2006 was full of flaws. This document was ridden with flaws.
3. The header on all the pages of EIA report reads “Rapid EIA – Okhla Integrated Municipal Solid Waste Processing Facility”, so it won’t be incorrect to say that this is not a comprehensive assessment of project activity and its likely impacts on health and environment.
4. Page 30 of EIA reads: “Since this being a rapid EIA, only one season data was collected”. This makes the report flawed.
5. If you read page 63/64, where the ecological environment has been described, it says “The proposed project is at the landfill site, near STP located in Okhla industrial area in the southern part of Delhi.” This description is factually and technically incorrect because the piece of land where the waste to energy project has been constructed is not a ‘landfill” site and has historically never been a landfill site. Moreover, because of the geography of this area, a landfill site can never be created here. This is not part of Okhla Industrial Area. All this misrepresentation has been done intentionally to give the impression that this is being located in the industrial area.
6. At page 102, EIA report concludes that “….no likely adverse impact on people’s health is predicted” (i.e. during the operation phase). This is factually not correct as has been borne out by the order of Hon’ble Delhi High Court pertaining to a plant using similar incinerator technology at the same location. The landmark judgment in Writ Petition (C) No. 6976 of 2008 refers to 'The summary of "Epidemiological Studies on Adverse Health Effects Associated with Incineration" would show that medical waste incinerators are a leading source of dioxins and mercury in the environment and there is link between incinerator emissions and adverse health impacts on incinerator workers and residents living around the incinerators.'
7. The observations made in the judgment will have far reaching implications. It reads: "Both older and more modern incinerators can contribute to the contamination of local soil and vegetation with dioxins and heavy metals. In several European countries, cow's milk from farms located in the vicinity of incinerators has been found to contain elevated levels of dioxin, in some cases above regulatory limits. Increased levels of dioxins have been found in the tissues of residents near to incinerators in the UK, Spain and Japan. At an incinerator in Finland, mercury was increased in hair of residents living in the vicinity. Children living near a modern incinerator in Spain were found to have elevated levels of urinary thioethers, a biomarker of toxic exposure. "It notes that "After 2 years of operation of incinerator, dioxins levels were found increased by about 25% in both groups living between 0.5 to 1.5 and 3.5 to 4.0 km away (201 people) of people. In the repeat analysis, the increase was in the range of 10-15%". It records that "Mothers living close to incinerators and crematoria from 1956 to 1993" showed "increased risk of lethal congenital abnormalities, in particular, spinal bifida and heart defects, near incinerators: increased risk of stillbirths and anacephalus near crematoria". With regard to "Residents from 7 to 64 years old living within 5 km of an incinerator and the incinerator workers" the judgment observes, "Levels of mercury in hair increased with closer proximity to the incinerator during a 10 year period".
8. This judgment found that "Residents living within 10 km of an incinerator, refinery, and waste disposal site" showed "Significant increase in laryngeal cancer in men living with closer proximity to the incinerator and other pollution sources". The "Residents living around an incinerator and other pollution sources" showed "Significant increase in lung cancer related specifically to the incinerator". The "People living within 7.5 km of 72 incinerators" displayed "Risks of all cancers and specifically of stomach, colorectal, liver and lung cancer increased with closer proximity to incinerators". The order observes, "10. In Master Plan for Delhi, 2021, notified on 07.02.2007, hazardous waste processing viz. hospital/medical/industrial waste is amongst the industries, manufacturing of which shall be prohibited within National Capital Territory of Delhi." It is not in dispute that Delhi's municipal waste has hazardous waste characteristics. It is noteworthy that the biomedical waste incinerator which now been removed was located exactly in the vicinity of the residential colonies and Jindal's controversial municipal waste incinerator. The Hon'ble Court observed that "This is a mandatory requirement of the guidelines issued by CPCB that such facility should be far away from residential and sensitive areas". The same holds true for the location of the Jindal's municipal waste based incinerator plant.
9. In such a backdrop, it is not surprising that Jindal’s municipal waste to energy plant based on incinerator technology in question faces bitter opposition from residents, environmental groups and waste pickers of Delhi. The plant is just 30 meters away from the Okhla Bird Sanctuary. The sanctuary is situated at the entrance of Noida in Gautam Budh Nagar district of Uttar Pradesh. An area of 3.5 square kilometres on the river Yamuna was notified as a bird sanctuary by the Government of Uttar Pradesh under the Wildlife Protection Act, 1972 in 1990. The Jindal's power plant is sandwiched between an eco sensitive zone and the residential colonies. The plant is situated at a distance of less than 50-100 meters from the residential colonies. This hazardous plant has an adverse impact on a large number of transcontinental migratory birds that visit the Okhla sanctuary. Their numbers have decreased over the years.
10. Not only that there is a large lake which lies sandwiched between Okhla village towards the west and Gautam Budh Nagar towards the east, the impact of the plant on this water source was not been disclosed in the Environment Impact Assessment report of the plant. This plant does not have the required mandatory clearances from the National Board for Wildlife. The sanctuary is approachable from Mathura Road (NH-2), via Sarita Vihar going towards NOIDA. The nearest stations of Delhi Metro are Sarita Vihar and Jasola Apollo metro station. This also reveals that the plant located in the vicinity of the sanctuary is amidst densely populated residential area. It is
quite disturbing that Okhla's vegetable market (subzi mandi) is getting submerged in the ashes which emerge from the plant which is burning some 2050 Metric Tons of mixed municipal waste which has hazardous waste characteristics.
11. It is quite appropriate that Hazardous Substances Management Division (HSMD), MoEFCC has framed the Draft Municipal Solid Waste (Management and Handling) Rules to replace the pre-existing Municipal Solid Waste (Management and Handling) Rules, 2000 given the fact that
Indian municipal waste does have hazardous waste characteristics.
12. This Jindal's waste based power 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 habitations of birds and humans and a number of binding guidelines from multiple state agencies and Supreme Court directive, the plant has deployed unapproved and untested Chinese technology for power generation from burning the garbage unmindful of its human and environmental cost due to emissions of pollutants like persistent organic pollutants and heavy metals. This has serious health and environment implications for the residents of National Capital Region (NCR) in general and Okhla and NOIDA residents in particular.
13. It is noteworthy that transboundary air pollution from plant is adversely affecting Delhi's Okhla vegetable market and UP's NOIDA areas. South Delhi's residents in Okhla face toxic dust as Jindal's waste based power plant in Sukhdev Vihar, Okhla spews out large clouds of thick emissions. Residents are left choking and spluttering and suffered severe eye irritation in Sukhdev Vihar which is barely 30 metres from the plant. Much of Sukhdev Vihar, Hazi colony, Gaffar Manzil and adjoining colonies including Jamia Milia Islamia and hospitals remains blanketed by soapy brown ash which had to be cleaned off floors, cars and even trees and shrubbery. The plant is amidst institutions of national importance like Central Road Research Institute, Institute of Genomics and Integrative Biology and the Indian Institute of Information Technology. EIA for expansion points out the hazards from the boiler explosions but the sole ‘mitigation measure’ its location at a distance of 260 meters making it falling within the explosion impact zone which is in the proximity of women’s hostels of the Jamia Millia Islamia University, residences for staff and students of CRRI and the IGIB and their laboratories. Such toxic emissions from the Jindal's power plant in an ecologically sensitive area and thickly populated area has become a routine affair with all the concerned authorities turning a blind eye towards this illegitimate and illegal act.
14. This plant has violated all the rules in the rule book. 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, the most toxic substances known to mankind.
15. Besides violating all the relevant laws and rules, this plant is violation of Wildlife Protection Act 1972 creating a compelling reason for the closure of this plant. The plant became operational in 2012 but it is using untested and unapproved Chinese incinerator technology, a fact noted in the report of the Central Pollution Control Board committee constituted after a delegation had met the Union Minister of Environment & Forests pursuant to his site visit of the plant. It is noteworthy that the Hon'ble Minister had written to the then Chief Minister, NCT of Delhi underling that the plant is functioning in violation of environmental regulations.
16. It is noteworthy that the 'White Paper on Pollution in Delhi with an Action Plan' prepared by Union Ministry of Environment and Forests. 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." The paper is available on Ministry's website.
17. The failure of Delhi's Timarpur waste to energy plant, Hon'ble Delhi High Court had ordered an enquiry by the Comptroller Auditor General (CAG). In its annual report dated March 1990, the Comptroller Auditor General of India (CAG) observed, "The Refuse Incinerator-cum-Power Generation Plant installed by Ministry of Non-Conventional Energy Sources in March 1985 remained inoperative since its installation. The Ministry failed to utilise or dispose off the inoperative plant and incurred an expenditure of Rs 1.25 crore on maintenance and insurance of the plant." The project was scrapped in July 1990. It is germane to note that Union Ministry of New and Renewable Energy which is now part of Ministry of Power provides a subsidy of Rs 1.5 crore/MW is distorting waste management in the country including Delhi.
18. As per Hon'ble Supreme Court's order in the Writ Petition (Civil) No.888 of 1996 such subsidies are not meant for incinerator plants like the one in Okhla. Hon'ble Court's order dated 6th May, 2005 said, "...we hope that till the position is clear, the Government would not sanction any further subsidies." It is noteworthy that on 15th May, 2007, the Court's order "permit (s) Ministry of Non-conventional Energy Sources (MNES) to go ahead for the time being with 5 pilot projects chosen by them" but it is noteworthy that this refers specifically to bio-methanation technology. MNES is renamed as Ministry of New & Renewable Energy (MNRE). It has been revealed through RTI that neither the proposed Delhi's waste to energy incinerator projects one of those 5 pilot projects nor is it based on the recommended technology.
19. As per the March 2018 report of the Parliamentary Standing Committee on Energy, on a query regarding provisions of financial incentives provided by the Government for Renewable Energy for Urban, Industrial and Commercial Applications, the Ministry furnished the information that Power generation from Municipal Solid Waste gets Rs. 2.00 crore/MW (Max. Rs.10 crore/project) from the MNRE. Other incentives and support measures provided by the Ministry under the programme incentives are given to State Nodal Agencies: service charge @ Rs. 1% of the subsidy restricted to Rs. 5.00 lakh per project and financial assistance for promotional activities: for organizing training courses, business meets, seminars/workshops and publicity/awareness, subject to a maximum of Rs. 3.0 lakh per activity. In addition, the Ministry of Urban Development is also implementing “Swachh Bharat Mission” (SBM) since 2 October, 2014, which also includes setting up of waste to energy plants with Central support up to 35% of the project cost in the form of Viability Gap Funding (VGF) / grant, subject to the overall State-wise funds envelop for SBM."
Incentives include "Accelerated Depreciation: Tax depreciation rate of 80% under AD benefits besides concessional Custom Duty Exemption and GST. Waste to Energy projects draws 5% GST besides availing concessional custom duty which would help the promoters / developers to avail these concessions to improve economic viability of the projects.
According to the amended Tariff Policy, Distribution Licensee(s) are required compulsorily procure 100% power produced from all the Waste-to-Energy plants in the State, in the ratio of their procurement of power from all sources including their own, at the tariff determined by the Appropriate Commission under Section 62 of the Act. The Central Electricity Regulatory Commission (CERC) vide notification dated 07th October 2015 and 31st March 2015 have notified norms for determination of Generic Tariff for MSW, RDF and Biogas based WTE projects along with Generic Tariff for FY 2016-17. The Levelised Tariff which is in the range of Rs.6.50 to Rs.7.60 per unit."
When asked about the modes of financing, existing financial support available and possible options for funding capital and operation & maintenance costs with respect to W to E Plants, the Ministry stated: "The Government of India, through various schemes extends financial support for introducing appropriate solid waste management systems and for setting up processing and disposal facilities. These include Viability Gap Funding Swacch Bharat Mission of MoUD, Loan from IREDA, Grants from MNRE for Supporting W to E Projects and Preferential Tariff by Regulators besides support for Purchase of Compost from Ministry of Agriculture.
When the Committee desired to know about the current status and performance of Waste to Energy Plants in the country, the Ministry informed that "At present, six waste-to-energy plants using Municipal Solid Waste (MSW) with cumulative installed capacity of 65.75 MW are in operation in the country. The State-wise details of Municipal Solid Waste (MSW) based power projects set up, as on 31.01.2018 which included M/s Jindal Urban Infrastructure Pvt Ltd. at Okhla, New Delhi. The Parliamentary Committee was informed about the verdict of NGT penalizing Jindal company’s plant for air pollution amidst alarming air pollution situation in the National Capital Region of Delhi by the ministry in question. It is apparent that the ministry is blind to environmental health concerns in its drive for energy from waste at any human and environmental cost. Such an unscientific approach is distorting waste management and poisoning the food chain. It high time MNRE withdrew or modified its letters that encourage and promote polluting technologies like the one situated in Okhla’s residential and admittedly ecologically sensitive areas.
20. It must be recalled that Delhi Government had falsely claimed in the Hon'ble High Court that it was one of the five projects cleared by Hon'ble Supreme Court leading to dismissal of petition filed by residents but when the Hon'ble High Court later found to its shock that such a claim was manifestly untrue, the petition was restored. It was in March 2009 that Writ Petition (Civil) No. 9901 of 2009 which was initially dismissed on 12th August, 2009 because of misrepresentation of facts by Shri A S Chandiok the then Additional Solicitor General. Hon'ble High Court later found that it was misled earlier which had led to it dismissing the petition. The Petition was restored by an order dated 15th January, 2010. In the presence of Shri A.S. Chandihok, the bench headed by the Chief Justice, Hon'ble Delhi High Court in the order 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."
21. The certificate of Host Country Approval dated 15th May, 2007 given by National CDM Authority to the project of The Timarpur Waste Management Company Pvt. Ltd. (TWMCPL), a subsidiary of Infrastructure Leasing & Financial Services Ltd. (IL&FS) is quite relevant and merits your attention. This approval was given after is consideration by the NCDMA on 30th March, 2007. It was confirmed based on submissions by the company prior to approval and prior to registration with UNFCCC’s CDM Executive Board that “The project contributes to Sustainable Development in India”. Post registration changes establish beyond any reasonable doubt that the project does not contribute to Sustainable Development and sets a very bad precedent for the country in particular. It puts the communities and the ecosystem of Okhla, Delhi to enormous risk which cannot be deemed acceptable.
22. The country approval laid down certain specific conditions which are required to be complied with “during the lifetime of the project”. The approval conditions stated categorically that “This approval is not transferrable. The authority reserves the right to revoke this Host Country Approval if the conditions stipulated in this approval are not complied with to the satisfaction of the National CDM Authority.”
23. The conditions stipulated in the approval certificate have not been complied with the project in this question. It must be noted that the approval was given to The Timarpur Waste Management Company Pvt. Ltd. (TWMCPL), a subsidiary of Infrastructure Leasing & Financial
Services Ltd. (IL&FS) but the approval was transferred to 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. This clearly implies that the conditions have been violated.
24. Besides this the approval certificate states “The TOWMCL shall obtain all statutory clearances and other approvals as required from the competent authorities for setting up of the project.” It is evident from the Validation opinion for post registration changes provided by Det Norske Veritas (DNV) that the “statutory clearances” which were obtained pre registration were not and has not been obtained post registration. This also clearly shows that Host Country Approval “conditions stipulated” in the approval have not been complied with. This creates a full proof compelling logic for the National CDM Authority which admittedly has the “right to revoke this Host Country Approval” to revoke the approval granted to this project.
25. There is an inexcusable admitted deviation from approved and validated technology in the matter of Clean Development Management (CDM) project 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.
26. The company submitted the 52 -page long PDD (Version 2) to the Board as CDM project activity to earn carbon credit. The project got listed before the board on 23rd May, 2006, and the CDM Executive Board invited public comments until 21st June, 2006. Subsequently, there was 90- page long Version 04 of PDD of The Timarpur –Okhla Waste Management Company Pvt Ltd’s (TOWMCL) dated 6th September, 2007. Prior to that there Version 03 of PDD dated 28th July, 2006. Then there was PDD Version 03.1. The initial request for registration was submitted on 3rd March, 2007 by Designated Operational Entity (DOE) through Mr Siddarth Yadav of Société Générale de Surveillance (currently known as SGS), a Switzerland and United Kingdom based DOE. The project got registered on 10th November, 2007. Prior to the registration I had submitted elaborate comments in this regard.
Subsequently, the 55 -page long PDD Version Number 9 titled Version 04. 1 dated 30th January, 2014 was published on the Board’s website following request for post-registration changes.
27. As per Validation opinion for post registration changes provided by Det Norske Veritas (DNV), an Oslo based international certification body and classification society dated 27th May, 2014, new “parameters are now proposed to be additionally monitored consequent upon the technology adopted” by TOWMCL. These include monitoring of average additional distance travelled by vehicle for ash and inert disposal compared to the baseline in year y is now proposed to be monitored to account for the project emission. It also includes monitoring of “Amount of RDF used outside the project boundary is proposed to be monitored based on the sale invoice. There will normally be no sale and the parameter is used for project emission calculations.” It adds, “Weight of RDF sold offsite for which no sale invoices can be provided is also monitored .The quantity will be monitored based on weigh bridge report and is being monitored to account for project emission.” It states “Monitored content of methane in the stack gas from RDF combustion in year y. This will be monitored by third party on quarterly basis. This parameter is being monitored to account for project emission.” It submits “Monitored content of nitrous oxide in the stack gas from RDF combustion in year y. This will be monitored by third party on quarterly basis. This parameter is being monitored to account for project emission.”
28. Every claim made about RDF is misplaced and an exercise in glaring misrepresentation of facts. It is not surprising that residents have noticed how efforts are on within the premises of the
plant to set up a structure in one corner to justify claims regarding RDF.
29. The Validation Opinion informs that as per the registered PDD Version 1 , the project activity was envisaged to be developed at two different location, i.e. Timarpur and Okhla with 650 Tonne Per Day (TPD) of Municipal Solid Waste (MSW) to be processed at the Timarpur site while 1300 TPD of MSW was envisaged to be processed at Okhla site for the preparation of Refuse Derived Fuel (RDF). Additionally, 100 TPD of green waste (waste collected from garden like dry leaves, cut grass, etc) was to be utilized at Okhla site biomethanation plant for generation of biogas. It was also envisaged to generate electricity to the tune of 16 MW by utilizing the RDF produced from the project activity. However, while implementing the project, Timapur site was not considered and the total quantity of waste of 2050 tonnes per day is now processed at Okhla site. The green waste is not being provided as envisaged earlier but additional 100 TPD of Municipal Solid Waste (MSW) is being provided that is total of 2050 TPD of waste is provided for processing. Due to the technology adopted it is estimated that from the RDF produced 20.9 MW of power can be generated instead of 16 MW envisaged due to better efficiency consequent to preheating of the input waste. The biomethanation and composting plants were also not required due to change in design as green waste not being made available for processing. The reference to “the technology” is to city refuse incinerator of China’s Hangzhou Boiler Group Co., Ltd that engages in the installation of boiler.
30. As per DNV’s opinion the start date of the project activity was revised to 27th November, 2009 which was the date of issue of purchase order for the boiler which is the first order issued. DNV from the documents verified /3//5//7/ and from the site visit interviews / 24 / can confirm that the changes in the project activity occurred after the registration of the project activity
on 10th November, 2007. The verified documents refer to Dalkta Energy Services Ltd : Detailed project report dated 4 May 2009, Timarpur-Okhla Waste Management Company Private Ltd.: Board resolution on adopting new technology dated 24th June, 2009 and Timarpur – Okhla Waste Management Company Private Ltd.: Contract for supply Plant and Machinery with Hanzhou Boiler Group dated 27th November, 2009 respectively.
31. It is recorded that “DNV from the interviews and perusal of documents find that, the project participant was not allocated the green waste that was assured earlier and the waste supplied to the project activity was to be processed at two locations Okhla and Timarpur. Subsequently the waste is being processed only at Okhla only /3//6//9/. This resulted in changes in the project design.”
32. It is also recorded that “from the verification of documents /3//5//7//11//, DNV can conclude that the changes were not known to the project participant prior to the registration of the project
activity.” The verified documents refer to Dalkta Energy Services Ltd: Detailed project report dated 4 May 2009, ICICI Bank : Enhanced loan sanction letter dated 24 December 2009 and Delhi Pollution Control Committee : Consent letter T - 12/458TO465 dated 20/11/12 respectively.
33. Responding to the comments received from stakeholders, the CDM Executive Board’s Form asked the project proponent the question:”What are the measures taken by the Company regarding the environmental aspects?” mentioned in the PDD. The project proponent replied, “The Project Proponents has taken adequate measures regarding the environmental aspects and the SPM, SO2 & NOX levels will comply with all the regulatory requirements. Further Environmental Impact Assessment (EIA) study for the project has also been carried
out. The Environment Management Plan (EMP), Risk assessment and Disaster Management Plan (DMP) in the EIA report takes care of all the environmental issues.”
34. The 31- page long report of CPCB communicated on 22nd March, 2012 on the Timarpur - Okhla Waste to Energy Incinerator Plant of Shri Prithivraj Jindal‟s JITF Urban
Infrastructure Limited (Jindal Ecopolis) is based on three meetings of the Technical Experts Evaluation Committee held on 26th April, 2011, 11th August, 2011 and 22ndSeptember, 2011. This report underlined that that the operation of Jindal's waste burning based power plant is an act of environmental lawlessness in the heart of the national capital.
35. The Terms of Reference (ToR) given by Union Ministry of Environment & Forests (MoEF)'s Experts Appraisal Committee (EAC) to the project in question specifically demanded "Disaster Management Plan" (DMP) but the CPCB’s Technical Evaluation Committee constituted by the then Union Minister of Environment & Forests headed by Chairman, Central Pollution Control Board (CPCB) observed in its report that the DMP plan has not been prepared.
36. The Jindal’s power plant in Okhla is amidst residential colonials and institutions of national importance like Central Road Research Institute, Institute of Genomics and Integrative Biology and the Indian Institute of Information Technology. Such toxic emissions from the Jindal's power plant in an ecologically sensitive area and thickly populated area has become a routine affair with all the concerned authorities turning a blind eye towards this illegitimate and illegal act. This plant has violated all the rules in the rule book.
37. The plant is using untested and unapproved Chinese incinerator technology, a fact noted in the report of the Central Pollution Control Board (CPCB) committee constituted after a delegation had met Shri Jairam Ramesh, the then Union Minister of Environment & Forests pursuant to his site visit of the plant. It is noteworthy that the Union Environment Minister had written to the then Chief Minister, Delhi underling that the plant is functioning in violation of environmental regulations.
38. The plant in question is situated in a green belt. It is in contravention of section 3(2) (v) of the Environment (Protection) Act, 1986, Rule 5 (ix) of Environment (protection) Rules, 1986 and
Guidelines for Establishment of Industries issued by Ministry of Environment & Forests. Besides violating all the relevant laws and rules, this plant is violation of Wildlife Protection Act 1972 creating a compelling reason for the closure of this plant. That now a bizarre situation has emerged because the arguments for Refuse Derived Fuel (RDF) incineration technology that was advanced by the company before the MoEF and the UNFCC’s CDM Executive Board are 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 or in its EIA report based on which a so-called Public Hearing was conducted in Saket in the presence of two officials only as per records. It was CPCB’s report that disclosed that Jindal’s power plant was using an unapproved technology.
39. Having studied the details of the project and its impacts, there emerges a compelling is logic to devise ways to stop such hazardous projects from being designated as sustainable development and CDM projects. It is also submitted 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.
40. The Project Design Document (PDD) 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 and a densely residential area adjoining a bird sanctuary and a wetland.
41. The TOWMCL’s agreement with Siemens Ltd: Agreement NG2010 dated 7th May, 2010 for design, engineering, supply and erection of turbine generator merits scrutiny besides agreement with Waxi Guolian Huaguang Power Engineering Co Ltd: Agreement for supply of machinery, equipment for flue gas system and Hangzhou Boiler Group Co: Contract NG2009 - 311 dated 24 Dec ember 2009 for supply of boiler to ascertain whether pre-existing general and specific conditions as envisaged in the Environmental Clearance certificate for the project based RDF technology has been complied with. All these official documents besides the CPCB report clearly indicate that Chinese boiler technology based waste to energy plant has violated every rule in the rule book.
42. The first Environmental Clearance to this plant was granted 21st March, 2007 for 15 MW under the signature of Dr A Senthil Vel, Additional Director, MoEF pursuant to directions from Shri R Chandramohan, Joint Secretary, MoEF. The minutes of the 46th meeting of Expert Appraisal Committee on Infrastructure Development and Miscellaneous Projects held on 16thNovember, 2006 reveals that TOWMCL, the project proponent when it was part of IL&FS Limited (when Shri D K Mittal, IAS was its Managing Director) had submitted that it will set up a Refuse Derived Fuel technology facility based on Department of Science and Technology-TIFAC technology with a capacity to process 1300 tons per day of MSW to produce 15 MW of power. Subsequently, TOWMCL requested Dr A Senthil Vel “to issue make suitable amendments in the EC to reflect the capacity of the proposed plant as 16 MW instead of 15 MW. The EC was amended for processing 1950 tons MSW by an order dated 9th May, 2007. In March 2011, TOWMCL again sought an amendment to the EC after making submission for an additional 4.9 MW before the Expert Appraisal Committee (EAC) for processing of 2050 tons of MSW. The EC was amended again for 20.9 MW. Although these amendments happened no new studies have been carried out to assess the impacts of the alteration in the technology and the changes the installed capacity. Source: http://environmentclearance.nic.in/writereaddata/Form-1A/EC/0_0_15_Jul_2013_151116420123-1-2006.pdf
43. In a glaring omission TOWMCL did not disclose its Contract for supply Plant and Machinery with Hanzhou Boiler Group dated 27th November, 2009 to the EAC.
44. It is noteworthy that even the initial EC was granted based on a fake public hearing as per records. The public hearing was conducted in Saket on January 20, 2007 instead of it being conducted in Okhla area where the project was proposed. The advertisement for the Public Hearing was made through two newspapers on 17th December, 2006. The advertisement was titled “Public Hearing for environmental clearance to the construction of proposed integrated municipal solid waste processing complex at Okhla —adjacent to existing Sewage Treatment Plant (STP) Delhi.” It did not disclose that it was a waste based power plant.
45. The public hearing Shri Mittal wrote at least twice to Shri Chandramohan on 5th October, 2006 and 13th October, 2006. It was “B category project promoted to A category because of proximity to inter-state border & sanctuary (within 10 km). Hence Public Hearing report sought.” The Public Notice for public hearing did not disclose that the proposed plant in the residential area was a waste based thermal power plant, it was advertized as “Integrated Municipal Waste Processing Complex”. The attendance register revealed that there was virtually no attendance for the public hearing. The fact is that the Public Hearing did not take place as per the letter and spirit of Environment Impact Assessment Notification, 2006, something which was
admitted by the then Union Minister of Environment & Forests in writing. Besides the project was subsequently sold to JITF Urban Infrastructure Limited (Jindal Ecopolis), which took no fresh environment clearance.
46. This plant is owned by Shri Prithviraj Jindal who won an open tender in 2008 to build and operate the plant for 25 years at a project cost of Rs 240 crore. It is apparent that the owner has ignored the disastrous environmental health consequences of plant’s operations.
47. The representatives of GTZ (German Technical Cooperation) led by Dr. Juergen Porst, Senior Advisor stressed the need for a Disaster Management Plan in the very first meeting of this CPCB Committee, which is annexed to the CPCB's 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. This report made a shocking revelation that although Hon’ble 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 this committee, non-cooperative approach of the senior officials of Timarpur-Okhla Waste to Energy Incinerator Plant was “condemned” on 11th August, 2011.
Representatives of GTZ had 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 and a member of the Committee 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 of the company in question.
48. All subsequent reports by subordinate officers of Chairman, CPCB are subservient to this report of the High Powered Technical Experts Evaluation Committee headed by Chairman, CPCB. This report revealed how illegal Chinese boilers are being used without any approval in Delhi’s Okhla Waste to Energy project. The technical review by CPCB committee admitted that efficacy of reciprocal stoker type boilers (in place of RDF) "is not known for Indian conditions and requires to be verified." There is a compelling reason to take cognizance of this report as the main report of CPCB. This committee noted that this plant is operating in violation of Municipal Solid Waste (Management & Handling) [MSW] Rules, 2000. It came to light from the observation of Shri A B Akolkar from CPCB who is currently the Member Secretary, CPCB.
48. A study of the first monitoring report of the TOWMCL’s integrated waste to energy project in Delhi dated 17th October, 2012 shows that facts were not verified on the ground and those who were adversely affected by the project were not consulted. As a consequence this questionable project managed to get Certified Emissions Reductions (CERs) issued. The initial crediting period of the project was mentioned as 1st April 2009 – 31st March 2019. Now it has been changed to 30th March 2011 – 29th March 2021 and declared as fixed.
49. All these developments vindicate the validity of comments on the PDD which are available at this URL of CDM Executive Board
50. It may be noted the Master Plan Report (2020) of Municipal Corporation of Delhi (MCD) said, “RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions.” The EAC ought to pay heed to it as well.
51. Having studied the second monitoring report of the project dated 15th October, 2015 and the relevant pages on the website of the Board, it is learnt that as of 30th May, 2016, “CDM Issuance request” for CERs is awaited. As you are aware Issuance is the instruction by the CDM Executive Board to the CDM Registry Administrator to issue a specified quantity of CERs, lCERs, or tCERs for a project activity or PoA into the pending account of the Board in the CDM registry, for subsequent distribution to accounts of project participants in accordance with the CDM rules and requirements. These reports for UNFCCC reference number of the project activity 1254 are available on UNFCCC’s CDM Executive Board’s website. EAC is ought to communicate its considered opinion based on the above submissions to the National CDM Authority and recommend withdrawal of host country approval given to the project in question.
As per the admitted legal requirement, the project proponent’s thermal power plant in question is supposed to comply with standards laid down under Air (Prevention & Control of Pollution) Act 1981 besides requirements under Hazardous and Other Wastes (Management and Trans boundary Movement) Rules, 2016 Solid Waste Management Rules, 2016 and Public Liability Insurance Act, 1991. In the light of the replies given in the Parliament by Union Environment Minister and the verdict of the National Green Tribunal, the claim about there being “marginal impacts on Air, water, land and noise….” Made in the report of Jindal Company’s Draft EIA report dated September 2018 is factually wrong.
Union Minister of Environment, Forests, and Climate Change, in a written reply to a question in Lok Sabha has informed, “Government is aware of the reports published by the World Health Organization (WHO) and the Health Effects Institute (HEI) regarding the impact of air pollution on human health in terms of higher casualty rate due to air pollution. The reports are based on models, simulations and extrapolations. The Central Pollution Control Board (CPCB) has carried out epidemiological studies to assess the impact of pollution on human health. Air Pollution could be one of the triggering factors for respiratory ailments and associated diseases. However, there are no conclusive data available in the country to establish direct correlation between diseases and air pollution. Health effects of air pollution are generally synergistic manifestation of the individual’s food habits, occupational habits, socio-economic status, medical history, immunity, heredity, etc.” WHO’s Ambient Air Pollution database has been marked National Capital Region of Delhi as the most polluted city in the world with an annual particulate matter (PM) 2.5 level of 153 μg/Nm3. The pollution had spiked beyond acceptable limits with dangerous PM 2.5 and PM 10 levels hitting 999 μg/Nm3, while the safe limits for those pollutants are 60 and 100 respectively. A 2010 study conducted by the Boston-based Health Effects Institute (2010) has estimated that about 3000 premature deaths occur in Delhi due to air pollution related diseases. This works out to about 8 deaths per day in Delhi alone relating to air pollution related diseases. This year again, levels of PM 2.5 in Delhi reached 710 μg/Nm3, more than 11 times the safe limit prescribed by the WHO. Biomass burning in Jindal’s waste based thermal plant is a significant contributor to the air pollution load.
Referring to the Waste to Energy project for the expansion of this plant of the Jindal’s company, the report of Jindal Company’s Draft EIA report dated September 2018 makes the claim that “energy-from-waste contributes to energy security”. Given the fact that at present India has surplus power to the tune of 3,000-4,000 MW as India's total power capacity increased from 243 GW in March 2014 to 320 GW in March 2017, there is no compelling logic for the extraction of power from WTE plants.
“This “WtE” project will reduce the problem associated with the disposal of unprocessed waste as landfill and meet the objective and goal set for the country under the Swachh Bharat Mission (SBM).”
The project in question violates even the conservative Manual on MSW handling, released under Clean India Mission (Swacch Bharat) by the Ministry of Housing and Urban Development because it stands on a Green Belt under Delhi Master Plan 2021 and it is also in violation of ‘change in land use’ requirements under the DDA Act.
Amidst protests from residents and waste recycling workers, the WTE plant in Okhla, New Delhi, run by Jindal Urban Infrastructure Limited was penalised by the National Green Tribunal on February 2, 2017, saying, "For the pollution resulting from deficient functioning/operation of 'Waste to Energy Plant'". But it allowed it to operate with a caveat, saying, "In the event, the plant is found to be deficient in its operations or violates the prescribed standards of emissions, it would be liable to pay Environmental Compensation of Rs 5 Lakhs per incident, in addition to such other order or directions that may be passed by the regulatory authorities and/or this Tribunal, including closure of the plant." The fact is that the residents are exposed to ongoing emissions from this plant but this power plant continue st o function with impunity.
It is germane to recollect that Gazette notification dated 1 December, 2009 requires public hearings to be “arranged in a systematic, time-bound and transparent manner ensuring the widest possible public participation at the project site or in its close proximity, district-wise” but residents’ demand that the hearing of the proposed expansion of the Jindal’s plant be held at project site to ensure ‘widest participation’ has unfairly and irrationally been ignored.
The proposed expansion requires installation of two boilers in addition to the three already existing as part of Jindal’s waste based thermal power plant.
The hazards posed by the plant from proximity to the residential areas gets multiplied manifold because of unprecedented deviation in the form of its use of untested and unapproved Chinese boiler technology “without amendment of Environment Clearance or taking consent”. This has been noted in the verdict of National Green Tribunal dated January 16, 2017. The enormous risk also emanates from movement of hazardous ash and residues along an eight-km stretch of New Delhi’s Mathura Road (NH2) because the plant is far any landfill in violation of the environmental rules. Besides the expansion project in question, the project’s proponent has proposed new 2,500 TPD WtE project at Tehkhand within South Delhi Municipal Corporation (SDMC). Unmindful of the cumulative environmental impact of the waste incinerators across the national capital region of Delhi in the form of aggregate pollution load, separate EIAs are being prepared for different waste based projects, such motivated projects disaggregate collective awareness of the residents of the national capital region and undermines collective efforts to safeguard environmental health. Ideally, there should be a combined EIA report of all the waste based projects in the region because residents suffer from grave public health crisis due to combined air pollution load of capital region’s atmosphere. The current approach is insensitive to public health and consequences of environmental pollution because its continues to adopt fragmented and unscientific approach to outwit collective opposition of aggrieved residents of Delhi.
There is a logical compulsion to withdraw the environmental clearance given to this plant in order to save present and future generation of residents from being enveloped in a toxic gas chamber as a consequence of use of such hazardous incinerator technology adopted for generating energy from waste which admittedly has hazardous waste characteristics.
Contact Details: Gopal Krishna, ToxicsWatch Alliance (TWA), Mb: 9818089660, E-mail: firstname.lastname@example.org, Web: www.toxicswatch.org
Note: TWA has been working on the issue of waste since 2000. It has been part of research and advocacy regarding Okhla based waste to energy plant since March 2005. It was an applicant in the National Human Righs Commission as well.
 On 13 October 2017, Yes Enviro Solutions Ltd , the Consultant of The Timarpur Okhla Waste Management Company Ltd. (TOWMCL), M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited it replaced M/s Perfact Enviro Solutions Pvt. Ltd by which submitted the EIA studies online to MoEF&CC on 19 June, 2018
 (2011), Selected chemicals used during the Vietnam war, Blue Water Navy Vietnam Veterans and Agent Orange Exposure, The National Academies of Sciences, Engineering, and Medicine 500 Fifth Street, NW, Washington, DC, https://www.nap.edu/read/13026/chapter/5, accessed on 15 January, 2019
 UNFCCC’s CDM Executive Board’s website, thttp://cdm.unfccc.int/Projects/Validation/DB/9JGKQMHTCBE61J51WVVT1AIH7DUW0H/view.html, accessed on 15 January, 2019
 Statement on Impact of Air Pollution on Health referred to in reply to Lok Sabha Starred Question No. 166 due for reply on14.03.2017 regarding ‘Impact of Air Pollution on Health' by Shri C.R. Patil et al, Ministry Of Environment, Forest and Climate Change, Government Of India, Lok Sabha, Starred Question No. 166