Date: 20 December, 2013
Shri A.S. Lamba – Chairman
Expert Appraisal Committee
Dr. Saroj, – Member
Ministry of Environment and Forests
Subject: Need for a Comprehensive and Broader Cumulative Impact Assessment prior to giving a go ahead for expansion of Sasan Ultra Mega Power Project in Singrauli
Srijan Lokhit Samiti is a people’s movement, working on social and environmental issues in Singrauli area of Madhya Pradesh and Uttar Pradesh. In the past three decades Singrauli has seen an influx of industrial projects which have resulted in multiple displacements of people, severe health issues and a highly toxic environment in the area. Srijan Lokhit Samiti has been fighting for people’s rights, displacement, land rights, human rights and environmental issues since thirty years as in this growth the people of Singrauli have been pushed to the periphery.
Srijan Lokhit Samiti appreciate the fact that Sasan UMPP expansion application has been rejected by the Ministry of Environment and Forests. But unfortunately, the conditionalities that have been put for the go ahead of the expansion of the Project are inadequate and show complete disregard for the enormity of the environmental and social concerns in the region.
There are significant parameters that have been ignored by the Expert Appraisal Committee (Committee) in the hearing at Ministry of Forest and Environment, dated 2nd September 2012 for expansion of Sasan UMPP that, we want to bring to your notice in this letter. We also want to bring to your attention the concerns of the affected people that were raised at the public hearing for the expansion of the project, which the Committee has pointed out in the minutes of the meeting as having been addressed. We continue to suffer the disastrous environmental and social consequences of this project even as the ministry feels satisfied with the answers provided by Reliance Power Limited and is making way for the project expansion.
The least we can expect of the Ministry is to understand the urgent need to review the carrying capacity of environment and ecology of Singrauli considering the fact that when the Central Pollution Control Board conducted its study ‘Comprehensive environmental assessment of industrial Clusters’ in 2009[i], Environment Ministry decided to impose a moratorium on clearances for all projects in Singrauli coalfields, as environmental pollution in these areas exceeded norms. Subsequently, the moratorium on environmental clearance in 43 critically polluted areas or industrial clusters including Singrauli was lifted after the State Pollution Control Board submitted a plan for mitigation of adverse effects of pollution. But, this did not change the situation on ground.
A recent study(October 2012) done by the Centre for Science and Environment’s Pollution Monitoring Laboratory[ii] conducted an extensive analysis of water and soil samples from the region, as well as biological samples such as blood, nails and hair of local people. The aim was to find out precisely what industrial pollution was doing to the district’s environment, ecology and people. The results of the tests exposed a tale of terrible contamination and ill-health stalking the region. High level of mercury and fluoride contamination was found in drinking water and soil. Rihand Reservoir water was found contaminated with mercury. Arsenic was also found in Renuka River. One of the findings of the study is that residents of this region exhibited adverse health conditions and could be suffering from the effects of mercury poisoning, other than normal diseases. The report further states that, the likely cause of mercury pollution in the area is burning of huge amount of coal for power generation.
The report also goes to make recommendation that monitoring of methyl mercury in fish should be done regularly and advisory on eating fish must be issued by the government. This clearly shows that impact on aquatic life.
In an assessment of environment-mediated production functions of reservoirs done in 1995 and published as a technical paper by FAO[iii], it had been noted that, “Rihand is a large man-made lake of 46 000 ha, into which converge cooling waters from four super thermal power plants under the public sector viz., Singrauli (2 000 MW), Vindhyachal (2 260 MW), Anpara (3 130 MW) and Rihand (3 000 MW), besides the private sectors Renusagar thermal power plant with a capacity of 210 MW. All these power generating plants are located within a small area of 30 km2. Adverse effects of heated discharge on resident aquatic organisms were reported. Mortality of fish and decrease of aquatic life within 50 km of the discharge point, owing to high temperature (46 to 52°C) of the effluent was recorded.”
It further says, “Deposition of fly ash has been reported up to 500 m downstream of the outfall point. Cooling waters of Renusagar power plant discharged into Rihand reservoir are acidic and high in chlorides. Although an increase in water temperature is known to cause deoxygenation, a rise within reasonable limit enhances photosynthetic activities resulting in supersaturation of water with oxygen. All the power plants around Rihand Reservoir are located near the intermediate and lotic sectors, where the fishes are known to congregate. The most deleterious among the impacts of thermal pollution is the blanketing effect on the reservoir bed. Thick mat of fly ash deposit at the bottom bed over the years may seal the nutrients away from the water phase and thereby affect productivity.”
Since 1995, there has been a huge rise in the number of power projects in the region and the water source has been the same, thus just escalating the problems caused from coal and flyash. These are serious concerns and need to be dealt with urgency.
Also, the mining activities and coal mining overdumps pose serious health related concerns and over the years there has been a very high increase in the bronchial diseases apart from various kinds of cancers (liver and kidney being the most common). The area has noted a huge increase in skin disorders and water infections also.
Considering all these factors, we request the Committee to not only look at cumulative impact in terms of water but also, cumulative impact of all the projects in the singrauli industrial belt on air quality and soil quality. We fear that the industrial and mining activities in the region are way beyond the carrying capacity of the area and Singrauli is becoming uninhabitable for the local population.
Apart from serious environmental concerns; there are serious social concerns that have marred Sasan UMPP. Though the committee seems to be satisfied with the replies of Reliance Power Limited, we would like to bring to your notice the ground situation of people affected the construction and working of Sasan UMPP. One of the most serious concerns in the project is that most of the property of the local people was destroyed much prior to the process of acquiring their land. The way the entire land acquisition process went on was coercive in nature and people were intimidated, false promises for employment were made to acquire land.
Planning for rehabilitation of project affected people was done without any consultation with them, which resulted in construction of rehabilitation colonies which are not at all suitable for the locals and lack basic facilities like water sources, health facilities, and connectivity to the main market and town areas etc. Result is that most of these rehabilitation colonies are still empty.
There has been no consideration shown for the rights of indigenous people who have been affected by the project. The Baiga tribe which is identified as a scheduled tribe in India has been worst hit by this project as this area has been home to them. Since, most of them lived in the forest that has been allocated to the company for coal mining dumping purposes; they have just had to leave the area as those forests were identified as government land. With no work and being away from forest most have been reduced to beggary and mere survival has become a struggle.
Apart from this, the modus operandi of the company much resembles that of mafia which resolves any incident of dissent, non agreement with abductions, coercion, pressure from local government, and police. The condition of the labour working at the Sasan UMPP is of grave concern. A number of laborers have died while working at the plant and the information does not go out. Since most of the labourers working there are migrant workers, there is no one out there to even try to find their whereabouts.
It is extremely unfortunate that the committee feels that issues of safe drinking water, electricity and health facilities have been addressed adequately when in reality; the social concerns which arose during the construction and operation of the Sasan UMPP have still not been looked into or resolved as mentioned earlier in the letter.
Another important issue is that requires attention is the fact that for the expansion by addition of 3×660 MW to the project, no additional land has been demanded. This clearly reflects the serious issue of excessive land being acquired at the first phase of the project itself. Sasan UMPP awarded to Reliance Power has also run into land and environmental problems including ‘failure to get forest clearances’ in the past and has also been in trouble over excessive mining in the coal mines allotted for the project.
At this juncture, it is essential that expansion of the Sasan UMPP should not be given a go ahead, before some critical and comprehensive steps are taken to assess the damage on ecology, environment and people of Singrauli.
- There is an urgent need to conduct a study on the carrying capacity of the environment and ecology of Singrauli before giving a go ahead for any other industrial project in the region.
- There is an urgent need to do a comprehensive and broader cumulative impact assessment of the impacts of the expansion of the Sasan UMPP covering not only impact on water quality but also on air quality and soil quality and its impact on the local population.
- There is a need to do a comprehensive study on the health of the people in Singrauli and the damage caused by the decades of industrial influx and pollution.
- The study that has been recommended by the committee to the project proponent for long term study of radioactivity and heavy metals contents on coal needs to be provided with a time frame.
- Time frame also needs to be provide for setting up a mechanism for an inbuilt continous monitoring for radioactivity and heavy metals in coal and flyash shall be put in place and in and around the existing ash pond.
We request the Committee withhold the expansion hearing for the Sasan UMPP expansion until all the above stated demands are looked into. We also want to make the point that it is essential that Singrauli should not be evaluated on the parameters of an industrial zone rather; emphasis should be laid to that fact that Singrauli district is home to a population of more than 11 lakhs(approximately) and their survival with dignity should be of paramount importance to the Government.
Srijan Lokhit Samiti
Dhuti, Navjivan vihar
Vindhya Nagar, District Singrauli
Email id: firstname.lastname@example.org, email@example.com
- Dr. C.R. Babu – Member, Professor Emeritus, Centre for Environmental Management of Degraded Ecosystems, School of Environmental Studies, University of Delhi, Delhi, 110007
- Shri Jawahar Lal Mehta – Member, Former Director (Planning & Projects), Neyveli Lignite Corporation Limited, Shanti Vihar, 514-A, Aryapuri, Ratu Road, Ranchi-834001, Jharkhand
- Shri T.K.Dhar – Member, 31-B, Mansarovar Apartments,Sector -61, Noida – 201 301,Uttar Pradesh.
- . Shri N.K. Verma – Member, 602, Skytech Magadh, Sector-3, Vaishalia, Ghaziabad (U.P)
- . Shri A.K. Bansal – Member, 804, Swarn Jayanti Apartment, Plot No. 97, Sector- 54, Gurgaon
- . Dr. Ratnavel, MD – Member, 21/7, Thandavarayan Mudali Street, Old Washermpet, Chennai
- Shri G.S. Dang – Member, (Former Deputy Director, Indian Institute of Petroleum) SF-4, Anand Villa Apartments 117/1, New Road, Dehradun- 248 001
- . Representative – Member, Central Pollution Control Board, Officer dealing in Thermal Power, Parivesh Bhawan, East Arjun Nagar, Delhi- 110 032
- . Shri P.D. Siwal, Director – Member, Central Electricity Authority (CEA), Ministry of Power, Sewa Bhawan, R.K. Puram, New Delhi – 110 066
- . Dr. S.D Atri – Member, Deputy Director General of Metrology,Indian Meteorological Department, Mausam Bhawan, Lodhi Road, New Delhi-110 003.
- . Dr. Asha Rajvanshi/Dr. V.B. Mathur – Member, Wildlife Institute of India, Post Box# 18, Chandrabani, Dehradun- 248 001.
- . Dr. CBS Dutt – Member, Deputy Director (ECSA)/Scientist-H, National Remote Sensing Centre, Indian Space Research Organisation, Balanagar, Hyderabad- 500 037