Submission before the Panel holding Environmental Public Hearing on 24-8-2009 into the proposed 450 MW coal fired Power Plant by Meghavaram Power Private Ltd (MPPL) at Kakarapalli village in Santhabommali mandal of Srikakulam district, Andhra Pradesh.
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, and for the right of the people to propose and strive for new rights not yet recognised in national or international law. The right to a wholesome and dignified life is the touchstone for the rights that may be aspired for. In particular the Human Rights Forum 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.
The EIA report as it stands does not reflect the full reality of the environmental impact. We recall that the East Coast Energy Pvt. Ltd. (EEPL) is also setting up a 2640 MW thermal power project near Kakarapalli village in a marshy wetland swamp in which it is not desirable to set up such projects. There is a fundamental flaw in the EIA report which is that a cumulative environmental impact study of both the projects, which is necessary, has not been presented. We say this because the proposed thermal plant by MPPL is adjacent to the proposed EEPL plant.
The area is the only remaining remnant of the marsh area on the east coast. The proposed site is an ecological entity with incomparable value requiring conservation and protection.
To quote from the sub-group of the Environmental Appraisal Committee that visited the site on July 21-23, 2008 the project area: “is a swamp area, which has become mud flat over the geological past, which is a unique habitat. The site is an integral component of unique eco system of marine, terrestrial, brackish and fresh water ecological site with there own specific floral and faunal characteristics. The component of these unique eco systems are the Naupada swamps (marine), Telineelapuram area (terrestrial) and Tekkali creek (brackish and marine). This swamp/ mud flat together serve as biologically rich wetland. It is ecologically rich and diverse and a home for some of the highly endangered species of Evi fauna.
Further, the region also includes an identified important bird site at Telineelapuram. The area commands high ecological importance as wetland habitat, priority area for conservation as important bird area, feeding areas for winter migrants, breeding area for spot billed pelicans and representative area of remnant salt water marsh lands. The locations of the project is therefore likely to directly conflict with conservation objectives.”
It is clear that the Naupada Swamps and Tekkali Creek are perhaps the last surviving marshy stretches in Andhra coast and they are an integral part of the surface-cum-marine ecosystem that supports a variety of flora and fauna, including the Telineelapuram bird nesting and feeding habitat. The MPPL project violates wetland conservation norms and moreover interferes with the water flow pattern at the site causing irreversible disastrous changes in the water-based ecosystem in the area. There is a crying need to protect and nourish such wetland systems and not destroy them as the MPPL plant will surely do. The EIA report is silent on these crucial points.
`The project will generate harmful levels of pollutants like sulphur dioxide and mercury. Once released into the environment they continue to circulate for ages and do not get eliminated. Damage to all life from these emissions will be enormous.
Drawal of sea water and the outflow will seriously undermine marine breeding and resources rendering much harm to livelihood of fisher-folk. The construction will certainly result in flooding and inundation of the land in the area causing damage to farmers. It is deplorable that the EIA report is totally silent on the matter given the grave implications it holds for agriculture in the area.
We once again emphasise that the EIA study is incomplete as it has not gone into a cumulative impact of the two projects, the MPPL and the EEPL. This one reason is enough for the project proposal to be rejected outright.
Also, in addition to major loopholes in environmental regulation in favour of polluting industries and utter lack of enforcement, even the TOR prescribed are not comprehensive and do not reflect the worldwide concern towards Global Warming. With large number of coal-based power plants on the anvil and several of them based on imported coal with higher sulphur content, it is high time the MOEF begins to enforce implementation of DeSOx and DeNox systems to reduce emissions from the power plants. While the world over use of Mercury is being strictly regulated and is taken out of use even for clinical thermometers, no limits are being set for power plants that are the largest emitters.
VS Krishna
HRF State general secretary
24.08.2009
Kakarapalli, Srikakulam district