Fracking in Kaza Block By Vedanta: HRF Urges Collector To Reject Issuance Of NOC

To,
J. Nivas,
District Collector and Magistrate,
Krishna District,
Andhra Pradesh

Sub: Issue of NOC for Oil and Gas fracking by Vedanta Ltd. beside Machilipatnam canal in Krishna District.

Sir,

The Human Rights Forum is a citizens’ forum established with the objective of working for the protection of the constitutionally guaranteed/internationally recognized rights of the people.

M/s Vedanta Ltd (Cairn Oil and Gas) proposed to produce shale oil and gas through fracking in the Kaza block, spreading over villages in Gudur and Machilipatnam mandals of Krishna district. Public hearing was held on 12 April 2021 at the start of the second wave of COVID 19.  In fact, the list of corona affected persons announced by the district administration on April 8, 2021 contained a person from Kaza village. However, the PH was held with very thin attendance ignoring appeals to hold it after COVID threat subsides.

The project had gone before the Expert Appraisal Committee of the Ministry of Environment, Forests and Climate Change, and the Ministry has raised a query for clarification.

“In view of the fact that Machilipatnam canal passes through the centre of the Block, please obtain NOC from State Water Resource Deptt. Further, you are requested to submit detailed measures proposed for protecting the canal from project activities.”

Hydraulic fracturing is a relatively recent method and the said project is a first of its kind in the area. As such, we have strong misgivings about the capacity of the Water Resource Department in the matter of evaluating the effects on surface water bodies due to shale oil and gas production using hydraulic fracturing technology. As you are aware, all canals originating at Prakasam barrage are being thoroughly contaminated with sewage from Vijayawada.

A Report of the US Environmental Protection Agency and published research indicate the contamination of ground and surface waters due to hydraulic fracturing. Hundreds of highly toxic chemicals are employed in the fracking process and they invariably enter the surface water and groundwater during the operations. Machilipatnam town depending on the Bandar canal for drinking water needs faces high risk to public health from contamination of canal water. Apart from that, thousands of hectares of land are cultivated under this canal. No measures by the proponent company can completely eliminate pollution as our regulatory system is not based on prevention of pollution but permitting an extent of pollution perceived as safe.

Water use for hydraulic fracturing reported in the December 2016 report of the Environmental Protection Agency, USA is: “Water is the major component of nearly all hydraulic fracturing fluids, typically making up 90–97% of the total fluid volume injected into a well. The median volume of water used, per well, for hydraulic fracturing was approximately 1.5 million gallons (5.7 million liters) between January 2011 and February 2013”.

A study by the Duke University published in Science Advances in 2018 gives much higher values for water use for fracking. “The Marcellus region (Pennsylvania and West Virginia) had the lowest increase in water use (20%), from a median value of 23,400 m³ per well in 2011 to 27,950 m³ per well in 2016, while the Permian Basin (Texas and New Mexico) had the largest increase in water use (770%), from 4900 m³ per well in 2011 up to 42,500 m³ per well in 2016.”

But Vedanta made a false claim that they will use only 1000 KL of water for fracking operation. Even if we accept that they will drill and frack only 45 wells, the water required is enormous and even the Prakasam barrage cannot meet the need without sacrificing the existing commitments. It also requires reiteration that the drinking water needs of Machilipatnam and the irrigation needs of thousands of hectares of land are dependent on this canal. Pollution and withdrawal of water from this canal will deplete the available water for these sections. As we know, the first and second priorities of water usage are reserved precisely for these purposes. It also needs to be pointed out that the area where the fracking is proposed is the tail end area of Machilipatnam Canal and that already the water availability here is quite meagre.

As head of the District administration, we urge you to act to protect the basic needs of the people, in this case, the water. Permitting large quantities of water to be diverted for fracking operations will invariably lead to severe water stress in this area. An EPA study presents large number of chemicals used in fracking: “By evaluating available data sources, we compiled a list of 1,606 chemicals that are associated with the hydraulic fracturing water cycle, including 1,084 chemicals reported to have been used in hydraulic fracturing fluids and 599 chemicals detected in produced water.”

Spills are very common in oil and gas operations. The above table of data on spills in different states in USA is indicative that even the advanced technology and regulation do not prevent spills. Inevitable water pollution with highly toxic chemicals that APPCB is not equipped to detect in water will endanger the lives of the people.

That study by EPA on request of the US Congress concluded thus: “Through this national-level assessment, we have identified potential mechanisms by which hydraulic fracturing could affect drinking water resources. Above ground mechanisms can affect surface and ground water resources and include water withdrawals at times or in locations of low water availability, spills of hydraulic fracturing fluid and chemicals or produced water, and inadequate treatment and discharge of hydraulic fracturing wastewater. Below ground mechanisms include movement of liquids and gases via the production well into underground drinking water resources and movement of liquids and gases from the fracture zone to these resources via pathways in subsurface rock formations.” [USEPA 2015]

Human Rights Forum therefore appeals to you to uphold the cardinal principle of Right to Life of the people of this region by rejecting issuing of No Objection Certificate (NOC) to Vedanta.

Sincerely,