sample letter to CM-1

To

Mr. Jairam Ramesh,
Union Minister
Ministry of Environment & Forests
Government of India
Lodhi Road, New Delhi-110003

Subject-Seeking Appointment to Discuss Waste to Energy Plants in Residential Areas of Delhi

Sir,

Thank you for your letter dated 19th July along with a copy of NEERI report titled "Assessment and Remediation of Hazardous Waste Contaminated Areas in and around M/s Union Carbide India Ltd., Bhopal", I am going through it and share my comments shortly.

This letter is to seek an appointment to meet you with a small delegation from some Delhi based Residential Welfare Associations, environmental groups and waste recyclers in the matter of proposed waste to energy plants based on incineration technology in general and Timarpur-Okhla Waste to Energy project in particular.

I had discussed this issue with you in person during my first meeting with you. You had expressed your awareness about the failed Timarpur waste to energy project. The same technology is once again being bulldozed in a residential area despite consistent resistance of residents, waste recyclers and environmental groups.

Unmindful of the environmental and human cost the installation of proposed municipal solid waste (MSW) to energy plants in Ghazipur, Timarpur and Okhla, based on incineration of Refuse Derived Fuel (RDF) is being pursued. This compelled the residents to move to the Delhi High Court. Earlier, the matter came up for hearing on December 11, 2009 wherein the petitioners (Sukhdev Vihar Residents Welfare Association & others) pointed out the polluting nature of the Refuse Derived Fuel (RDF) Incineration technology and how both the central government and the Delhi government has misled the court. The court in its order has found that it was misled earlier which had led to it dismissing the petition which has now been restored and was heard most recently on 22nd July before the Delhi High Court. The court has summoned Delhi Pollution Control Committee (DPCC) for explanation. In the presence of A.S. Chandihok, Additional Solicitor General, the bench headed by the Chief Justice, Delhi High Court in an order dated 15th January observed, “that the project in question” and “the location of the pilot project in Delhi was neither recommended by the Expert Committee nor approved by the Supreme Court.” So far the court has passed six orders. (attached)

I wish to draw your urgent attention towards how Chief Minister of Delhi has turned a blind eye to Delhi High Court order which led to an inquiry by the Comptroller and Auditor General of India (CAG) into the failure of the Timarpur plant that was also based on incineration technology (namely Refuse Derived Fuel) and the ‘White Paper on Pollution in Delhi with an Action Plan’ prepared by Union Ministry of Environment and Forests, the Chief Minister has been misled in to promoting it. The White Paper says, “The experience of the incineration plant at Timarpur, Delhi and the briquette plant at Bombay support the fact that thermal treatment of municipal solid waste is not feasible, in situations where the waste has a low calorific value. A critical analysis of biological treatment as an option was undertaken for processing of municipal solid waste in Delhi and it has been recommended that composting will be a viable option. Considering the large quantities of waste requiring to be processed, a mechanical composting plant will be needed.”

I wish to inform you that the Timarpur-Okhla Waste to Energy project that has met with protest rally from the residents of Gaffar Manzil, Sukhdev Vihar and Hazi Colony and several others. Local politicians have also pledged their support for the protesters but to no avail. Over 600 people walked through the colonies in a procession to stage their protest. The proposed plant is located inside dozens of densely populated residential colonies like Harkesh Nagar and Johori Farm, when the policy of the government is to shift or relocate all existing industries whatsoever from the residential areas. Besides this the site is in proximity of hospitals like Holy Family, Fortis-Escorts and Apollo. Inhabitants of colonies like Gaffar Manzil, Sukhdev Vihar and Hazi Colony are rightly alarmed at the prospect of a Dioxins emitting incinerator plant from coming up in their vicinity.

This has reference to the laying of foundation stone on June 26, 2010 by Mrs Sheila Dikshit, Delhi’s Chief Minister for a polluting waste to energy plant in the residential area despite the experience of Bhopal Gas Leak Disaster in a residential area.

Delhi government and have been misled into promoting this dubious technology despite incontrovertible evidence against the technology and in spite of its explicit exclusion by the Prime Minister’s National Action Plan for Climate Change.

While no one will allow an incinerator based plant in one's own backyard or in one's own residential area, the same is being done by the Delhi Government. In an open letter to the Chief Minister which is attached for your perusal, the residents said, “This plant will emit large quantities of hazardous and toxic emissions (such as dioxins and furans) due to burning of Municipal Solid Waste, and will profoundly affect the health of the people living in the surrounding areas and environment for all times to come in future.”

I also wish draw your attention towards the sad plight at waste to energy site in Gandhamguda village in Ranga Reddy district of Andhra Pradesh (wrongly mentioned as Hyderabad project) which had the same technology. While the RDF incinerator was in operation, the village was covered by a heavy shroud of dark smoke. Originally a pelletisation plant with a furnace, After the plant came up, local doctors started detecting case of problems not found before — skin rashes, asthma, respiratory problems and some cases of stillborns. In a statement, Gandhamguda sarpanch D. Shakuntala had said: ‘‘Everyone in Peerancheru Gram Panchayat and its adjoining regions is now contaminated with harmful pollutants and symptoms are visible in the form of brain fever, vomiting, jaundice, asthma, miscariages, infertility.’’ Similar fate awaits residents of Delhi.

For misplaced carbon revenue, it would not be appropriate to turn Delhi residents as guinea pigs. Ministry of New and Renewable Energy (MNRE) has an incorrect policy of subsidizing hazardous technologies like proposed incinerators.

Environmental groups, recycling workers and neighborhood residents are demanding closure of this combustion based project for a just transition from burning waste to building a better, cleaner future for the residents of Delhi. The transition is necessary in the face of issues such as the high cost of incineration, health effects of pollution in neighborhoods, and adverse climate change. Children suffer asthma rates three times the national average among other devastating health impacts.

This plant is based on a hazardous technology that receives fiscal incentives from MNRE. Notably, while 'whether or not energy from mixed municipal waste (with hazardous characteristics) is a driving concern' remains in dispute, the Prime Minister’s National Action Plan on Climate Change (NAPCC) categorically refers to Biomethanation technology, a biological treatment method for waste to energy instead of the Refuse Derived Fuel (RDF) process which is a incineration technology and is a tried,tested, failed and Dioxins emitting technology.

Even Municipal Corporation of Delhi’s own Feasibility Study and Master Plan for Optimal Waste Treatment and Disposal for the Entire State of Delhi of March 2004 says, “Incineration of RDF is considered waste incineration.” (Page 25, Appendix D, Technology Catalogue). It also says the costs of RDF are often high for societies with low calorific value because energy is used to dry the waste before it becomes feasible to burn it.

In fact the Master Plan Report (2020) of Municipal Corporation of Delhi (MCD) itself says,... “RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions.” One is surprised that despite this observation the report then goes on to suggest RDF. In fact the MCD report itself says that RDF is another form of incineration.

A 10 member Fact Finding Team visited the plant site on 18th June 2010 to take stock of the situation. Its preliminary findings are as follows: 1. RDF or incineration is completely inappropriate for Indian urban waste, which is largely biodegradable in nature. They extract a very high cost for the energy which they claim to generate. 2. The cost largely subsidised by various schemes, does not however include the environmental and health costs caused by their toxic releases, and which are externalized. 3. These technologies also use valuable resources which can be recycled, such as plastics and metals, and which support a massive recycling sector in the country. Indian municipal waste is fit for composting and bio-methanation treatment processes. 4. RDF is a thermal and combustion technology, mainly used to prepare waste for mass incineration. 5. If mixed waste is burnt will create problems of very toxic compounds such as dioxins and furans, heavy metals and other pollutants. 6. The calorific value for the waste comes from materials such as plastics and metals. 7. Plastics, especially chlorinated plastics such as polyvinyl chloride (PVC) when combusted gives rise to these highly toxic pollutants and 8. PVC plastic combustion which is part of the mixed waste is banned in India by regulation both in the municipal and bio-medical waste handling rules.

Earlier residents had not allowed the land hand over ceremony for the project that is proposed in the residential area of Okhla but unmindful of the public protest, New Delhi Municipal Corporation (NDMC) had permitted Jindal Urban Infrastructure Ltd to set up this plant. This company has secured a contract from New Delhi Waste Processing Company Limited, a joint venture between the Delhi Government and Infrastructure Leasing and Financial Services Ltd. (IL&FS), to produce 16 MW power from 2, 000 metric tonnes of municipal waste. Jindal company’s misplaced claims to that effect that it will process nearly 2000 tonnes of waste, later it would be in a position to process as much as 4,000 tonnes based on obsolete technology will distort capital city’s waste management beyond repair.

The proposed polluting technology to deal with the waste from South Delhi, North West Delhi and East Delhi is fraught with disastrous public health consequences for which two companies namely, Timarpur-Okhla Waste Management Company (TOWMCL) and the Unique Waste Processing Company (subsidiary of IL&FS Infrastructure Development Corporation Limited have been set up.

As per the agreement, BRPL will procure 50 per cent of the 16 MW electricity to be produced by TOWMCL at its plant in Okhla in the vicinity of numerous residential areas such as Sukhdev Vihar, Hazi Colony, Gaffar Manzil and others. The plant being set up plans to process over 6,43,500 lakh metric tonnes or one third of Delhi's Municipal Solid Waste (MSW) per year generated in Delhi. The plant is scheduled to be commissioned in late 2010-2011. Around 1,300 Tonnes Per Day (TPD) of MSW will be sourced from the Okhla landfill site and 650 TPD from Timarpur. BRPL will procure power at a DERC approved competitive tariff rate, determined by a competitive bidding process. The agreement allows the promoters to sell the remaining 50 per cent electricity through a suitable open access mechanism.

Similar waste to energy project is coming up at Ghazipur as well. Earlier, in November, 2009 BRPL had signed a 25-year-agreement to procure 49 per cent of the electricity generated from garbage to energy project at Ghazipur. Chief Minister referred to this project as well while laying the foundation stone.

East Delhi Waste Processing Company Private Limited, a special purpose vehicle of the latter company is working for generating electricity at the Ghazipur site with the support of the Delhi Government. ‘New Delhi Waste Processing Company Private Limited’ a Joint Venture company of Delhi Government, IL&FS and APTTDC is supporting the project as well. The integrated municipal waste-processing complex is proposed to include a MSW processing plant at Ghazipur to produce Refuse Derived Fuel (RDF) along with a power plant of 10 MW capacity where the RDF derived from the waste will be used as fuel to produce electricity. It is supposed to handle an average 1300 tons per day. It claims that 111,949 metric tonnes CO2 equivalent per annum of green house gases would be reduced. The crediting period for the project is from 1st November, 2010 to 31 October, 2020.

The Timarpur-Okhla carbon credit project which was registered on 10th November, 2007 with a claim to reduce green house gases to the tune of 262,791 metric tonnes CO2 equivalent per annum. Unique Waste Processing Company, a subsidiary of Infrastructure Leasing and Financial Services (IL&FS) and Andhra Pradesh Technology Development Centre (APTDC) has incorporated Timarpur-Okhla Waste Management Company for developing the project for processing municipal waste and also to produce electricity at two locations namely Timarpur and Okhla, at the site at Okhla that is adjacent to defunct Okhla Sewage Treatment Plant (STP). TOWMCL is working with New Delhi Municipal Council (NDMC) and MCD. The Timarpur and Okhla plant will together be processing 650 tonnes per day of MSW at Timarpur site and 1300 tonnes per day of MSW at Okhla and claims to generate 16 MW of electricity.

The move underway to install RDF plants in Delhi and several other state capitals is an environmentally unsustainable solution, which should be deemed unacceptable. If Delhi allows such toxic plant, it will set a bad precedent for other cities. It raises serious concerns about the health and safety of the citizens, which such a technology, will jeopardize.

In view of these grave concerns which Delhi residents, environmental groups and waste recyclers face, please grant us an appointment to meet you as a delegation and apprise of the situation at the earliest.

warm regards

Sri K Rosaiah

 Chief Minister of Andhra Pradesh

AP Secretariat Hyderabad

We are all aware of the ways and means crisis enveloping the state on account of reckless populism and cumulative impact of unsustainable policies on the sate exchequer.

As a result of the state’s ways and means problems, we are often acting in a penny-wise and pound-foolish manner, hunting the interests of the state severely. I would like to point out the problems encountered in the critical education sector on account of imagination and the persistent ad hoc approach adopted by the state.

Andhra Pradesh is spending the largest amount among all states in India towards fee reimbursement and scholarships in higher education. Though an amount of Rs 2300 crore has been allocated in 2010-11 budget, there is still unmet demand to a tune of Rs 1190 crores. If the total demand is to be met, it will need about Rs 3500 crores in 2010-11. With the increase in tuition fee for engineering education, the burden may go up to Rs 4000 crores. At the same time, the state is not able to release the state’s share of expenditure in critical centrally-sponsored schemes like Sarva Siksha Abhiyan (SSA) and Rajiv Gandhi Madhyamika Siksh Mission (RMSA). For instance, as against Rs 1100 crore projected programme under SSA meant for primary schools (from class 1 to class 8), the state could utilize only Rs 425 crore. This is because we could not get central funds as the state failed to release state’s share of 40%.

At the same time the state is borrowing money from various sources like RIDF to provide educational facilities in tribal and interior areas. In the present year 2010-11, SSA budget for the state (including central and state share and spill over) is project to be of the order of Rs 1700 crore. But by current indications, we may not achieve even Rs 800 crore to improve the school education of the poorest children in the state. There cannot be a greater abdication of responsibility, and a graver injustice to the poor. While the government is spending large sums for short-term consumption purposes, it has no will or capacity to utilize money available to improve education and eliminate poverty by helping people to stand on their own feet.

Similarly, this year the budget allocation under RMSA meant for high schools and junior colleges is about Rs 700 crore. But by current indications, the state will not be able to utilize more than Rs 150 – 200 cores. Thus under these two schemes of SSA and RMSA alone, the state is losing about Rs 800 – 1000 crore central funds on account of the state’s failure to release its share of the schemes.

The net result is, we are spending the highest amount in India on an ad hoc basis for fee reimbursement in higher education, and yet are unable to meet the demand; at the same time school education is starved of much-needed funds because we are not able to find the money to meet state’s 40% share of centrally sponsored SSA and RMSA. There cannot be a more shocking example of bad management of resources. Similar failure to avail central funds can be seen in the crucial health sector also. On behalf of Lok Satta Party, I urge you to take immediate corrective action to set things right in these vital sectors of education and healthcare. In respect of education, I urge you to take the following measures immediately:

1. The fee reimbursement scheme should be redesigned to meet the full, genuine demand from all eligible, poor families seeking higher education; at the same time the burden on the state exchequer should be reduced. Right now many families which can afford college fees are availing this facility, and many other deserving families are left out. The government should facilitate all poor students getting full education loan toward tuition fee, and a scheme of subsidizing interest must be designed to help the students during the period of study. The interest subsidy can be so adjusted as to make the loans interest-free or a bear a nominal interest of, say 3% during the period of college education. Then only those students who need support will seek loans. Interest subsidy can be credited to the banks directly. The burden on the state will be only of the order of Rs 300 – 500 crore and yet all the deserving students can be covered.

2. The money so saved can be utilized as state’s share of SSA and RMSA. The state will thus get an additional Rs 1000 crore from Government of India for education for the poor. Both SSA and RMSA can then be implemented in full measure. Andhra Pradesh has the worst record in literacy and school education among all the four Southern States and Maharashtra and Gujarat. We have to act with great commitment and dedication to improve the situation, without burdening the state exchequer. Now that the Right to Education Act is being implemented, and the Union Government is providing significant resources for school education, we should utilize the opportunity and improve our levels of literacy and education, and our human development indicators.

I am writing this letter with great sense of responsibility and in a non-partisan spirit, and I urge you to act immediately to retrieve the situation and protect the state’s interests.

With warm regards,

Jayaprakash Narayan