To
The Chairman and Members
SEAC, Andhra Pradesh
C/o Andhra Pradesh Pollution Control Board, Vijayawada
Subject: Objections to the application of M/s. Vizag Hyperscale Data Center Park Limited (Sy.No.275 ofAdavivaramvillage and Sy.No.26 of Mudasarlova village, Visakhapatnam Rural mandal) – project attracts the General Condition and is Category A; SEAC lacks jurisdiction to appraise project as B2
Sir,
The Human Rights Forum (HRF) is a citizens’ forum established with the objective of working for the protection of the Constitutionally guaranteed/internationally recognised rights of the people. The right to a wholesome and dignified life is the touchstone for the rights that may be aspired for. In particular, HRF works for the protection of the right to a clean and safe environment. HRF is a self-financed organisation whose members for the most part are from the professions of teaching, journalism and the law.
HRF objects to the above proposal and its Environmental Management Plan (EMP), and submits that it cannot be entertained by this Authority, the StateLevel Expert Appraisal Committee (SEAC) as a Category B2 project.
- The project attracts the General Condition and is Category A and therefore the SEAC has no jurisdiction. Under the General Condition appended to the Schedule of the EIA Notification 2006, a Category B project located within 10 km of the boundary of a Protected Area notified under the Wildlife (Protection) Act, 1972 must be treated as Category A and appraised by the Expert appraisal Committee (EAC) of the Ministry of Environment, Forest and Climate Change (MoEF&CC) at the Centre. The proponent’s own EMP (page 9) records that the site is 0.86 km from the Kambalakonda Wildlife Sanctuary boundary and 0.45 km from its notified Eco-Sensitive Zone (Sanctuary and ESZ notified vide S.O. 1366(E) dated 28.04.2017).
The site is therefore well within the 10 km radius, and the General Condition is mandatory. Despite this, Form-I Item 7 (“attracts the General Condition?”) and Item 21 (b) (“Wildlife (Protection) Act, 1972?”) are both answered “No”. This is a material misstatement in a statutory declaration, contradicted by the proponent’s own document. The EMP’s reasoning that the site is “outside the eco-sensitive zone” is irrelevant: The General Condition is triggered by proximity to the Sanctuary boundary, not by whether the site lies inside the ESZ. Consequently, the project is Category A by operation of law. Therefore, the SEAC lacks competence to appraise it as B2. It is mandatorily required to undergo a full Environment Impact Assessment (EIA) and public hearing. - The cooling system, the defining environmental aspect of a data center, is entirely absent in the Environmental Management Plan (EMP). This is a hyperscale data center drawing 512 MW. Its heat-rejection/cooling system governs its true water and energy footprint, yet the EMP describes no cooling system at all. Item 6.6 refers only to LED lighting. The entire water requirement is stated as just 307 KLD (246 fresh + 61 recycled) for domestic use, flushing and gardening, implausible by orders of magnitude for a 512 MW facility. Either the cooling load and its water, power and heat impacts have been wholly omitted, or the project description is internally inconsistent. The EMP is therefore incomplete and incapable of appraisal.
- The 8(a) classification is mis-applied. Filing a 512 MW industrial-scale facility under item 8(a) “Building and Construction” reduces eligibility to a built-up-area test (1,22,858.74 sq.m) and excludes from appraisal the project’s dominant impacts, power, cooling water, diesel emissions and waste heat. The development footprint is itself stated inconsistently (119.4 acres /~48.3 ha, against a separate “~160-acre APIIC allotment”).
- A captive diesel power station has not been considered. The “backup” is ≈279 MW of DG sets (100 × 2.75 MW + 4 × 1 MW) with HSD consumption of 110 KL per hour of operation, a major combustion and fuel-storage installation dismissed in a single line, while Form-I declares HSD non-hazardous and “in small quantities.”
- Water equity: Even the understated 246 KLD fresh water is to be drawn from the Rural Water Supply & Sanitation Scheme. This will in competition with the already stressed rural drinking-water needs near Visakhapatnam. The far greater, undisclosed cooling demand is not assessed.
We, accordingly request to:
(a) hold that the project attracts the General Condition and is Category A, and that SEAC has no jurisdiction to appraise it as B2.
(b) return/reject the application and direct the proponent to seek clearance from the MoEFCC as a Category A project, with a full EIA report and public consultation.
(c) record that the Form-I declaration on the General Condition and the Wildlife (Protection) Act is contradicted by the proponent’s own EMP.
HRF requests an opportunity to be heard in person before any decision is taken.
Yours truly
VS Krishna – HRF AP&TG Coordination Committee member
Y Rajesh – HRF AP State general secretary
19-05-2026
Visakhapatnam
Address for communication:
VS Krishna
54-11-59/2, Gazetted Officers Colony
Visakhapatnam-530022
Ph: 9440411899
Email: vskvizag@gmail.com
Copy to:
Chairman, State Environment Impact Assessment Authority (SEIAA)
Member Secretary, APPCB