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Letter from Shankar Sharma to the Prime Minister

Societal concerns over the Environmental Clearance (EC) accorded for the expansion of Kaiga Nuclear Power Project, Karnataka

To
Sri. Narendra Modi
Honourable Prime Minister
Govt. of India, New Delhi

Dated, 12th September 2019

Dear Sir,

Subject: Societal concerns over the Environmental Clearance (EC) accorded for the expansion of Kaiga Nuclear Power Project, Karnataka

Greetings from Sagar, Western Ghats, Karnataka.

It is with deep distress that I am writing to appeal to you to ask for a diligent reconsideration of the Environmental Clearance (EC) accorded by MoEF&CC (IA Division) vide a communication dated 5th August 2019 to NPCIL, Mumbai for the expansion of the capacity of the Kaiga Nuclear Power Project in Uttara Kannada district, Karnataka.  This EC refers to the proposal by NPCIL/DAE to add two nuclear reactors of capacity 700 MWe each to the existing capacity of 4 reactors of capacity 235 MWe each within the core area of Western Ghats which is designated by MoEF&CC as an ecologically sensitive area (ESA), within the ESZ of The Anshi National Park, with the additional status as Dandeli-Anshi Tiger Reserve, and on the bank of the river Kali surrounded by some of the richest biodiversity of tropical forest in a biodiversity hotspot of a global perspective.

Despite massive protests by the locals; despite a detailed submission on the serious associated concerns during the official public hearing as per EIA rules of 2006 on 15.12.2018; despite a detailed representation in this regard to MoEF&CC on 18.12.2018; and despite another representation to Atomic Energy Commission on 23.12.2018, I notice that MoEF&CC has conveyed the EC, which obviously has ignored everyone of the credible concerns, and without even trying to ascertain the associated concerns, or without giving me an opportunity to substantiate my concerns.  

The communication dated 6th Sept. 2016 by MoEF & CC, informing NPCIL on Terms of Reference for the project proposal, had clearly stated that the area within 10 kM is predominantly forest land with dense growth of tall and stout trees, and that the forest is categorised as reserve forest.  The Anshi National Park, with the additional status as Dandeli-Anshi Tiger Reserve, is at a distance between 718 m to 1,734 m from Kaiga project site as per the EC.  MoEF&CC vide its Circular dated 27.02.2007 and Office Memorandum dated 02.12.2009 has delineated a procedure for consideration of developmental projects located within 10 km of National Park/ Wildlife Sanctuary for grant of environmental clearance under EIA Notification, 2006.  Hence, it is a clear violation of its own policy that this project proposal, as a part of the nuclear power project being a red category industry as per the Pollution Control Board norms, should get environmental clearance. 

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.   Our 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 emphasize 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 we 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 (a copy enclosed for your kind attention as in Annex 1).  My appeal to you is not to allow the trust of the people in MOEF&CC, which is already at a low, to completely disappear.

My 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, inter-generational, 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 to our 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 we also objectively consider 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 tress 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?

I may please be excused to state that 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 realized 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 your kind information (Annexe 2).

As a person who attended the Public Hearing on 15.12.2018, I am sad to notice that the letter conveying the EC states, wrongly though, that “people’s perception regarding the project in general is favorable specifically due to local infrastructure development, employment opportunities, area and business development etc.”  I would like to highlight that the true scenario of that Public Hearing was that out of about 18 people who made the submission, about 16 people clearly stated that they were vehemently against the project proposal.  MoEF&CC has allowed the overwhelming opposition to the project to be falsely stated as one of favoring the project.  Such intentional falsehood on the part of the concerned authorities amounts to the misuse of the trust of the people in the sanctity of MoEF&CC’s decision making processes.

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 our 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 falsehood of the project proponent at enormous cost to the country. Hence, I appeal to you mandate 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). 

The EIA is without any action plan in this regard, and seems to be keen to pass on all the associated responsibilities to the local district administration, which shall not be acceptable to the people of the state. It is a general public opinion that the concerned authorities in the country are ill-equipped and ill-prepared to face such industrial level disasters as experienced in the case of Bhopal gas tragedy in 1984.  A detailed representation highlighting the serious concerns to the public in this regard addressed to the Atomic Energy Commission as in the Annexe has not resulted in any response (Annexe 3).

Few critical considerations for our country in this context should be: (i) at a time when the country is seeking to be a global leader in combating the threats of Climate Change, it can be said to be a criminal act to destroy 54 hectares of dense tropical forest of very high ecological value; (ii) at a time when the country is finding it hard to fight the water crises impacting many millions of people, and at a time when it is hosting 14th Conference of Parties (COP 14) of the United Nations Convention to Combat Desertification (UNCCD), the MoEF&CC seems to be oblivious of the fact that loosing the natural forest cover is the first step in desertification; (iii) whereas, against the national forest policy target of 33% of the land area to be covered by forests and trees, and the present status is only about 21%, the ministry instead of focusing on increasing this percentage cover, seems to have no qualms in permitting the diversion of large chunks of forest lands, as is evident from the reports of thousands of hectares of forest lands being diverted every year in the name of development projects.

A clear conviction of IPCC w.r.t the forests is represented by two associated statements: “Emissions from deforestation are very significant – they are estimated to represent more than 18% of global emissions”; “Curbing deforestation is a highly cost-effective way of reducing greenhouse gas emissions.”  In this context it may even be termed as a crime against humanity to even consider diverting more than 54 hectares of thick tropical forest lands to the proposed project, whose net benefit to the larger society can also be argued as negative, when we take into account the life –cycle cost of the nuclear power beginning from the nuclear ore mining till the nuclear wastes are safely.  

The major concerns mentioned above, in addition to many other concerns raised in the Public Hearing (as in the copy attached), have serious implications to not only the people in the district and adjacent areas, but also to the entire region, if not addressed adequately. I may please be permitted to state that in view of the fact that the concerned authorities, whether it was AEC or MoEF&CC, have ignored to clarify any of these issues, and seem to have ignored every critical issue while according the EC, the entire approval process followed under EIA Rule 2006 can be said to be faulty, and hence should not be relied upon as a diligent economic/ environmental decision making tool.

Whereas, the country recognizes your commitment for the overall welfare of our people through lofty ideals, tough performance targets and untiring efforts to realize them, it appears that the ministers and bureaucrats do not seem to support you adequately in that regard. The escalating number of incidences of forest loss / degradation, pollution / contamination of air, water and soil with disastrous consequences on our community’s overall health and welfare can all be said to indicate that they are failing in their Constitutional responsibilities.  A frequently highlighted slogan of your govt. “sub ka saath, sub ka vikaas, sub ka vishwaas” seem to be completely absent in the omissions and commissions of the ministers and bureaucrats.  They may kindly be asked to strictly demonstrate the adherence to the letter and spirit of the Constitution, associated Acts of Parliament, and their own policies, rules and norms. They may also be asked to adhere to the minimum courtesy of responding to the serious concerns expressed by the people of this country, and certainly not to ignore the genuine concerns of societal importance.

If desired so by PMO, a group of the concerned civil society volunteers will be happy to make an effective presentation to you on the criticality of the diligent adoption of “Options Analysis” and “Costs and Benefits Analysis” in all the relevant economic decision making processes so as to ensure the sustainable development of our communities, and also on various other related issues.

May I appeal to you to put a moratorium on any kind of diversion of original and thick forest lands to non-forestry purposes until the forest & tree cover in the country reaches the target of 33% of the land area as per the national forest policy? 

In the present context, may I appeal to you that the environmental clearance (EC) accorded for the expansion of Kaiga Nuclear Power Project, Karnataka be summarily cancelled, and the project proponent be asked not to consider any such proposal in the Western Ghats?

​Regards

Shankar Sharma
Power Policy Analyst
Anugraha, 5th Cross, 80 ft Road
Vijayanagar 1st stage, Sagara, Karnataka - 577 401
Phone: ++ 91 94482 72503
[email protected]
[email protected]
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Headings of the Enclosures List :
Annex 1 - my submission at the associated Public Hearing on 15.12.2018
Annex 2 – a high level analysis of costs and benefits of nuclear power plants in India
Annex 3 -  a representation to Atomic Energy Commission (AEC) on the issue of absence of  disaster management plan for Kaiga NPP
(List not included here)

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