Submission before the Panel holding Environmental Public Hearing on 4-12-2009 into the proposed 2,640 MW coal-based power plant by M/s Alfa Infraprop (P) Limited (AIPL), New Delhi, at Kotipam village of Komarada mandal, Vizianagaram district, Andhra Pradesh.
Human Rights Forum (HRF) is a citizens’ forum established with the objective of working for the protection of 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 a cornerstone of our efforts. In particular the Human Rights Forum works for the protection of the right to a clean and safe environment.
HRF believes that the public hearing being held today is not valid because the comprehensive EIA report has not been made available in Telugu to the affected people. A mere summary cannot do full justice and will not be sufficient for the people to understand the environmental impact and take an intelligent stand in the matter. It is necessary that a Telugu translation of the full EIA report is made available to each village, and officials of the Revenue Department as well as the AP Pollution Control Board make themselves available to the people to explain matters to them and clear their doubts. Only then can a meaningful public hearing be held. In the absence of such a process, the said public hearing is rendered meaningless.
It is stated in the EIA report that the total land required for the proposed power plant is 1675 acres comprising of 38.3% Government land and 61.7% private land. It is by now common knowledge that a large portion of this site falls in the ayacut of the Vankabadi Gadda reservoir. In fact, the proposed project clearly overlaps with the ayacut of the Vanakabaadi Gadda reservoir which was inaugurated with much fanfare by the Congress government in April 2006 and is presently under construction. It falls in the tribal sub-plan area and one adivasi village, Battumogavalasa, which is facing submergence by the reservoir, is being resettled and rehabilitated by the government Once completed, this irrigation project will provide water for nearly 1,100 acres, a large extent of this for a second crop. It is shocking that a private power project is allowed to come up in an ayacut of a State government irrigation project. Most of the beneficiaries of this ayacut are SC and ST small and marginal farmers. Their livelihood will be severely undermined if the ayacut land is handed over to the project proponent.
Moreover, it is stated in the EIA report that the project proponent has only acquired 551 acres of land from private land-holders, out of a total requirement of 1675 acres. This shows that the AIPL is still not in possession of the remaining land which is to the extent of 1,124 aces of which 642 acres is government land. This is a significant point. Why are the revenue and irrigation departments silent about this? Why are concerned authorities not stating clearly that this is Vanakabaadi Gadda ayacut land and straightaway refusing requisite permission? Also, is the AP Pollution Control Board not aware of these facts? Why is this farce of a public hearing taking place at all?
The AIPL has even been assured by the Irrigation Department of 2.5 TMC of water from the Nagavali river! How could this allocation be done when available yield at Thotapalli barrage is 32 TMC and Andhra Pradesh’s share of this is 16 TMC and our State has been showing utilization of 15.8 TMC? Farmers in the area, who are eagerly awaiting completion of the ongoing Thotapalli barrage works that is expected to raise the ayacut from the present 64,000 acres to about 1.25 lakh acres, are already agitated. It is clear that water meant for agriculture and domestic needs to nearly 20 mandals in Vizianagaram and Srikakulam districts is being sought to be diverted to a private industrial house.
Also, there are 19 water bodies located in the proposed project site which will go under thereby hitting at the livelihood of farmers in the Chinakarjheli, Gumada and Kotipam panchayats. These water bodies help irrigate hundreds of acres in the area and their disappearance will undermine water security of the local farmers. .
The EIA report as it stands does not reflect the full reality of the environmental impact. Huge amounts of waste water, running into over 2 lakh litres per hour will be discharged into the surface water body. Notwithstanding all the claims made by the proponent about discharge standards, this is great cause for worry. Moreover, the Jhanjavathi river is perilously close to the proposed project site, in particular the ash pond.
Though there is reference to the emission of sulphur dioxide, there is no reference to the possibility that it may result in acid rain over the years. Though some reference is made to the effluent ash containing mercury and other heavy metals, there is no discussion of their poisonous impact on the surroundings. Acid rain destroys ecosystems, including streams and lakes, by changing their delicate pH balance making them unable to support life. Acid rain can destroy forests and devastate plant and animal life. These toxic metals once released into the environment continue to circulate for ages and do not get eliminated. Damage to all life from these emissions will be enormous.
It is claimed in the EIA report that a major portion of the entire 5.44 MTPA of ash generated will be utilized. It does not appear to be a realistic projection considering the breakup figures given in the relevant table and also the absence of cement plants in the area that can make use of the fly ash to such an extent. Also several coal based power plants are proposed in Srikakulam and Visakhapatnam districts and are in various stages of implementation. The NTPC power plant near Visakhapatnam that has been in operation for the last several years is unable to totally utilize the ash even now.
There are over 25 forest blocks in a reserved forest area within a vicinity of 1.5 km–5 km from the proposed project site. To allow a thermal power industry in such close proximity is a violation of both MOEF guidelines as well as environment protection norms as it would adversely impact the ecology of these forests.
We are of the firm opinion that if this coal-based thermal plant comes up at all, it will cause immense and irreversible harm to the environment grossly damaging the health of the local people. Apart from destroying local livelihood of adivasis and SCs and other communities and wiping out precious local water bodies, it will pollute the area as well as the Jhanjavathi and Nagavali rivers that are located very close by.
There is increasing scientific evidence against use of coal for generation of power. Leading scientists are not only issuing statements against setting up any new coal fired power plants without carbon capture and storage facility, but also participating in civil disobedience actions of people. Carbon dioxide released into the atmosphere continues to remain airborne for more than 1000 years. So what is released today keeps warming the earth for more than 1000 years. There is no way to remove it from the atmosphere once it is released. The only option is to reduce/eliminate release of CO2.
In the present case the people, especially in the 0-50 km in the neighbourhood of the project site will be disproportionately exposed to toxic air pollution especially of toxic heavy metals such as mercury, lead and arsenic, with hardly any benefit accruing from the project. The power produced in the project is not likely to be made available to the villagers in the neighbourhood. If the company obtains Merchant power plant status, even the people of AP may not get to use power produced in the plant!
The HRF finds the EIA report as an Engineered Impact Assessment and not an objective Environmental Impact Assessment. Consultants have clearly chosen to give up professional ethics for consideration of profit.
In addition to major loopholes in environmental regulation in favour of polluting industries and utter lack of enforcement, even the TOR prescribed by the Expert Appraisal Committee are not comprehensive and do not reflect the world wide 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. Coal fired power plants are being now called ‘Death Factories’. Several epidemiological studies have been conducted and published on the damage to health of people living near these power plants. These power plants are the single largest source of mercury air pollution. Mercury is a highly toxic metal that, once released into the atmosphere, settles in lakes and rivers, where it moves up the food chain to humans.
In view of the above lapses in the EIA for the project, and the immense potential for pollution and damage to human health, irrigation sources and crops, loss of livelihood to ayacutdars, mostly small and marginal farmers of the SC, ST communities and diversion of precious irrigation and drinking water source from Nagavali river for a private industry, we firmly oppose giving environmental clearance for the proposed plant.
We strongly urge authorities concerned to cancel the public hearing. It is clear that a number of illegal and fraudulent methods have been employed by the project proponent so far in connivance with government functionaries of various departments. The entire thermal project proposal must be dropped and a thorough enquiry must be held to get to the truth.
Environmental clearance for all future coal fired power plants should impose SO2, NOx and Mercury and heavy element removal systems. It is environmental injustice to permit companies to make profits at the cost of public health in the name of energy security.
VS Krishna – HRF State General Secretary
04.12.2009
Komarada, Vizianagaram district