An Open Letter to AEC

To
The Chairman and Members
Atomic Energy Commission [AEC]
Anushakti Bhavan, CSM Marg,
Mumbai- 400 001

Copy to:
(1)  Dr Harshvardhan
        MoEF&CC, Government of India, New Delhi
(2)  Dr Jitendra Singh,
        Union Minister of State, Prime Minister' Office, Government of India, New Delhi
(2)  Prime Minister, Government of India, New Delhi

Dated, 23rd Dec. 2018

Dear Sirs,
Greetings from Sagar, Western Ghats, Karnataka.

This has reference to the public hearing under the EIA Rule 2006 of MoEF&CC, which was held on 15.12.2018 at Mallapur-Virje, Karvar Taluk, Uttara Kannada district, Karnataka.

The region around the Kaiga NPP, which also has an important river Kali flowing through it, is ecologically very sensitive, and is considered to be of very high ecological value from the global warming perspective. This area, around Kaiga NPP including the three villages of Kaiga, Mallapur and Virje, which are identified as project area in the EIA, is anyway declared as Ecologically Sensitive Area by a draft notification (3rd Oct. 2018) of the MoEF&CC. The decision to set up the Kaiga NPP in such an ecologically sensitive region in 1990s itself was an enormous policy blunder, which has resulted in incalculable ecological damage to the rich biodiversity here. Three reports from the scientists of IISc, Bengaluru under the title, (i) "Ecological Sustainability of Riverine Ecosystems in Central Western Ghats", 2018; (ii) "Stimulus of developmental projects to landscape dynamics in Uttara Kannada, Central Western Ghats", ELSEVIER, 2016, and (iii) "Salient Ecological Sensitive regions of Central Western Ghats, India", Springer Nature 2018, have all copiously highlighted the ecologically critical importance of the area around Kaiga NPP. Society should not be seen as continuing with such policy disasters by permitting further destruction of more than 54 hectares of thick forests at a time when these tropical forest are considered by IPCC as the most effective and cost effective option to address the threats of Climate Change.

These issues clearly emphasise the need for MoEF&CC to view all the related issues with the highest level of responsibility as the custodian of the environment, and not to dilute its own Acts, rules and policies. Obviously the MOEF&CC needs a very strong mandate from PMO to carefully review the existing forest and environment related policies to ensure the sustenance of ecological services through the sustainable forest management strategies. I may please be excused to state that the ongoing policy of MoEF&CC to accord EC to almost all such project proposals to divert thick original forest lands, especially for those of the Union and state governments, can be seen as a serious dereliction of it Constitutional responsibilities, when people also consider the fact that all the credible concerns by the civil society groups are being completely ignored, as in the case of my own submission at the associated Public Hearing on 15.12.2018.

Detailed submission at the official public hearing on 15.12.2018 had highlighted a large number of issues/concerns in the Environmental Impact Assessment (EIA) of the project proposal (only on which the decision to issue EC seem to have been arrived at), totaling more than 80 issues over a length of 22 pages. These concerns from the perspective of technical, economic, environmental, social, logistics, disaster management, intergenera-tional, and long term waste disposal have all enormous costs/implications to the local communities and the country as a whole, when compared to a meager benefit of only about 800 MW power (i.e. net power when we consider various constraints of the power system) from the project. A diligent application of 'Options Analysis' and 'Costs and Benefits Analysis' from a country level perspective (which EIA has failed to consider), will reveal that there are very many benign options available in the country to obtain the equivalent of 800 MW of net benefit from this project at much less overall cost to the society without having to cause any serious damage to the ecology of a bio-diversity hotspot.

A close perusal of the EIA has demonstrated that there is no single parameter discussed in it which can remotely establish that this project proposal is essential, and of least overall cost to our society. When one also objectively considers the unmitigated disasters associated with a credible scenario of uncontrolled nuclear radiation emission, however remote it may be, as witnessed in Chernobyl and Fukushima, it should become amply evident that the project proposal is not only unacceptable but also it is totally avoidable.

This EIA is found to be seriously deficient in not considering: (i) the details and costs associated with the additional transmission lines required for the project; (ii) adequate details of disaster management plan to safely evacuate more than 32,000 people of the immediate surroundings (within the emergency-planning zone up to 16 km radius) and rehabilitate them satisfactorily in the case of any unfortunate nuclear accident of the type noticed at Chernobyl and Fukushima; (iii) policy and details associated with the safe disposal and long term storage of spent nuclear fuel; (iv) "options analysis" and " costs and benefits analysis" of various techno-economically feasible options of much less overall cost available to our country to get the same amount of electricity in particular and in meeting the electricity demand in particular; (v) to establish beyond reasonable doubt the project is the best option in the larger context of the region, country and the planet.

This project proposal, if allowed to be executed, will cause enormous damage to the ecologically sensitive region by destroying more than 54 hectares of dense forest land of very high ecological value. In addition to about 8,700 mature trees which will have to be cut in this 54 hectares of thick forest, there will be a need to cut many thousands more of mature trees in order to construct new transmission lines to transport the additionally generated power. The project proposal has conveniently chosen not to mention this additional need for forest land diversion, and the MoEF&CC has failed to take note of the same. Whereas, the EC states that the approval by National Wild Life Board is required, it is a moot point as to why the EC was given hurriedly before the approval by National Wild Life Board is available. Is it intentionally done to put pressure on the National Wild Life Board to accord the approval?

Under the prevailing scenario in the country and the planet, as detailed herein, it will be a travesty of social and environmental justice, and the violation of the provision of the country's Constitution and provisions of many relevant Acts of the Parliament to allow the diversion of more than 54 hectares of dense forest land of very high ecological value, and 6,346 cubic meter per hour of fresh water from river Kali, which can meet the daily needs of about 15-lakh-people to this enormously risky project, because the main objective of this project can be realised at much less overall cost and vastly reduced burden on the environment and population through many benign options. A high level examination of "options analysis" and "costs and benefits analysis" is also enclosed for kind information.

In the context of such misrepresentation of the overall message of Public Hearing, what might have transpired in the Environmental Clearance process indicates that the associated Public Hearing was a farce, and has amounted to a cruel joke on the participating public, because the overarching mood of the participating public was not only falsified in the EC letter, but the EC appraisal proceedings by Environment Appraisal Committee (EAC) in relation to nuclear projects is also intentionally hidden from the public. Whereas the EAC seem to have blindly accepted the views of the project proponent, even though there is a very high probability of falsehoods and hidden truths in the submissions of the project proponents, it is deplorable that the civil society groups/ project affected people are not allowed to appear before the EAC. In the present case, it is clear that the project proponent has got away with incomplete/incorrect information, and by intentionally ignoring much benign options available to our country to get the same amount of electricity.

A diligent application of the "Options Analysis" and "Costs and Benefits Analysis" would have established that all other options available to meet the growing demand for electricity in the country would be much less costly and much benign than the nuclear power option. By not allowing the civil society groups/project affected people to respond to the tall claims made by the project proponent, EAC and MoEF&CC may be just permitting themselves to be misguided by flasehood of the project preponent at enormous cost to the country. These must be mandate for adequate transparency in every step of such approval processes of MoEF&CC. The concerned civil society groups/project affected people/domain expert should be encouraged to participate in the deliberations of EAC at the time when the project proponent makes submissions.

With the proposed increase of about 250% in the overall reactor capacity at the project site, the Kaiga NPP site will face exponential increase in radiation emission risks with the presence of six nuclear reactors in close proximity with each other and sharing many technical services. Nuclear safety experts identify such a scenario as "enhanced risk for NPPs with multiple reactors and shared technical facilities". A serious issue noticed in the EIA was the unanswered questions over the inadequate preparedness on part of the concerned authorities during any unfortunate accident of the type which occurred in Chernobyl (USSR) and Fukushima (Japan).

An insightful article, 'The missing safety audits" by Dr A Gopalakrishnan poses many serious concerns on the safety aspects in the nuclear establishment of the country. What Dr A Gopalakrishnan has recommended as safe operating practices for Indian nuclear industry may be seen as real concerns to the existing nuclear reactor sites, on the apprehension that these recommendations might not have been implemented. He has recommended that the nuclear power policy of the government should be thoroughly debated in parliament and openly discussed with energy specialists in the country. "It should be preceded by a re-look of the overall energy policy of our country to assess whether all viable non-nuclear electricity generation schemes have been given their due priority, before we jump-start an extensive nuclear power programme."

One of the recent arguments by the proponents of nuclear power is that it is clean and green, and hence should be a suitable option to address to reduce the GHG emissions at the global level. Whereas the nuclear power plants are generally not associated with any GHG emissions during their operation, the life cycle CO2 emissions (which are linked to various stages from nuclear ore mining till the spent nuclear fuels/wastes are safely disposed of after thousands of years) are generally recognised as considerable. The energy related cost of keeping the spent nuclear fuel safe for hundreds of years, if not for thousands of years, cannot be inconsiderable and can be seen as unjust burden on the future generations, because all the associated benefits of nuclear power, however meager they may be, would have come to the present generation alone. Taking all these direct and indirect costs and CO2 emissions into objective account the nuclear power technology has been ranked by credible analysis as one of the least beneficial to human kind among various sources of electricity. There have been a large number of credible studies from different parts of the world to analyse whether nuclear power can be a suitable technology in order to minimise CO2 emission

Nuclear power is considered as one of the most expensive ways to reduce the CO2 emissions. Also, in terms of cost-effectiveness in reducing CO2 emissions, nuclear power fairs very poorly. It is reported that in 1995, after a year-long, exhaustive review of the case for nuclear power, the UK Government concluded that nuclear power is one of the least cost-effective ways in which to cut CO2 emissions. In the US improving electricity efficiency is considered to be nearly seven times more cost effective than nuclear power for obtaining emissions reductions.

Back to Home Page

Frontier
Vol. 52, No. 24, Dec 15 - 21, 2019