Tuesday, June 28, 2011

Mega Realty Project abutting KBR National Park, Jubilee Hills, Hyderabad

 Back ground of the Project


The Jubilee Hills Landmark Projects Ltd,, an ICICI Venture led consortium , the project proponent of Mega Realty Project abutting KBR National Park, had undertaken the work at the site as far back as 2006 much before the application for EC was submitted to MOEF on 30-05-2007, in clear violation of the provisions of Para 6 of EIA Notification of 2006   The proponent also deliberately concealed and/or submitted false or misleading information to APPCB,   


MOEF Environmental Clearance


  But in spite of the facts mentioned above, MoEF, GOI, vide Letter of 26-01-08, granted Environmental Clearance to the project, involving the construction of a structure with 3 Basements + Ground floor + 15 Floors,  to accommodate 324  Room Five Star Hotel with 4 Restaurants and 4 Show Rooms and 315 Residential Apartments, on a plot area of 2 hectares, with total built-up area of 2,05,891.81 Sq Mtrs.


Eco-Sensitive Area around KBR National Park


The proposed project abutting KBR Park falls well within Eco-Sensitive Zone of the National Park, which acts as "Shock Absorber" and "Transition Zone "for the protected area of the National Park..  It is not known whether AP State Administration has declared the Eco-Sensitive Zone around KBR National Park, in accordance with   MOEF "Guidelines for Declaration of Eco-Sensitive Zones around National Parks and Wildlife Sanctuaries " issued on  09-02-2011.?




 As it is now reported that ICICI Venture led Consortium is likely to revive the project implementation after a lapse of nearly 5 years, it is requested that Environmental Clearance granted earlier be reviewed and cancelled in the light of the following reasons:


a)    The Project falls within Eco-Sensitive Zone of KBR National Park,


b)    The Project Proponent Undertook the project work much before applying to MOEF for Environmental Clearance, apart from giving misleading information to APPCB.


c)    The project is likely to have serious adverse impact on Flora and Fauna of KBR Park, which plays a very critical role for maintenance of ecological balance of Hyderabad  urban area


d)    The Heritage Precinct No.13 notified by HUDA in 2000. - KBR Pak and the Valley, extending up to Banjara Lake, starts from the junction of Road No.2 of Banjara Hills with the Road No.1 of Jubilee hills at the North-West corner. Therefore the proposed project site forming part of the notified Heritage Precinct No.13, is in violation of the heritage regulations  


e)     According to HUDA regulations on the subject, the Skyline in the precinct shall be maintained as may be existing in the surrounding area, so as not to diminish or destroy the value and beauty of the said precinct.


f)     The AP Government, vide G.O.Ms.No 86 dated 3-3-2006- Hyderabad Revised Building Rules-, which itself does not conform to National Building Codes of India 2005 in respect of Height and FS I of buildings, prohibits High-Rise buildings ie 18 meters and above- in Banjara Hills and Jubilee Hills.


  In the light of the position explained above, it is requested that the construction of the proposed project at the site should not be permitted.




Saturday, June 18, 2011

Nuclear Power - Points to be addressed by DAE / NPCIL ?

 Point No.1. Does Nuclear Power (NP) provide Energy Security for India?

The energy security is better defined as the Nation's ability to sustain adequate, reliable energy services in ways that maximize economic competitiveness and minimize environmental degradation  

The Nuclear power is not a 'home grown' source of energy and does not provide security in energy supplies, as most of the Uranium supplies required for nuclear power, are being imported, from politically-unstable countries like Kazakhstan.  

As per one estimate, without adding any new nuclear reactors at the current consumption rate of uranium, we have uranium to last for about 50 to 60 years. Therefore it is not sustainable source of energy.

 As exploitable sources of Uranium ore containing reasonable concentrations of Uranium 235 become exhausted, the costs will go up. And as higher-grade ores are exhausted, more energy will be consumed and more CO2 will be released in mining and enriching the remaining poor grade uranium ores.

The idea of obtaining large quantities of uranium, by reprocessing radioactive spent fuel & other waste from nuclear reactors/ nuclear weapons, is widely regarded as an expensive failure, apart from being medically dangerous to nuclear workers and releasing large amounts of radioactive material into the Air and Water contaminating the Food-Chain.

 Most of the non-nuclear decarburization scenarios provide far greater security of energy supplies than nuclear power, without its associated worries about radiation contamination, the security of uranium supplies, and terrorist attacks on nuclear plants & nuclear materials in transit and proliferation of nuclear weapons.

Point No.2. Is Nuclear Power CO2- Free?

 The fact is, "It takes energy to make energy"- even Nuclear Energy. Although a Nuclear power plant itself releases no carbon dioxide, the production of nuclear electricity, depends upon a vast complex and hidden industrial infrastructure (Nuclear Fuel Cycle- very Expensive, Sophisticated and Dangerous Way to Boil Water) is the intensive user of Fossil Fuel -the kind of energy the Nuclear power is touted as replacing -with the concurrent production of Carbon Dioxide.         

Far from being an answer to the problem of CO2 Emissions and Climate Change, Nuclear Power would be a miss-allocation of resources, making things worse by diverting funds away from better and cheaper alternatives. We get six times the reductions in   CO2, by investing in Energy-Efficiency, rather than Nuclear Power and much faster too.

Point No.3. Is Nuclear Power Safe, Clean & Green?

The head of the International Renewable Energy Agency –- an intergovernmental group known as IRENA that advises about 140 member countries on making the transition to Clean Energy –- dismissed the notion of including Nuclear Power among its favored technologies. The IRENA will not support nuclear energy programs because it is a complicated process; it produces radioactive waste and is relatively risky.

Contrary to the Nuclear industry claims, smoothly running nuclear power plants are also not radioactive emission free. They are permitted routinely to emit hundreds of thousands of Curies of radioactive gases and other radioactive elements into the environment every year, with significant exposure to radiation. A German study has shown that within a 10-mile radius of their reactors, childhood leukemia has increased to a frightening level.

 In addition, thousands of tons of solid radioactive waste is getting accumulated. This waste contains extremely toxic elements, which will inevitably pollute the environment and human food-chains, a legacy  that will lead to epidemics of Cancer, Leukemia, Genetic disease in populations living near Nuclear power plants and Radioactive waste facilities for many generations to come for thousands of years.

 If the Nuclear Power is so safe and entails as little risk as the Nuclear Industry claims, the insurance premium will not need to be particularly high. Why should the proposed "Civil Liability for Nuclear Damage Bill 2009" of Govt. of India should impose any liability caps on nuclear accident insurance? Why are the American Nuclear Power Plant Vendors demanding Nuclear-Accident Immunity, a pre-condition for their entry in the Indian Civil Nuclear Sector?

Point No.4. Is Nuclear Power Cheap? 

When Nuclear Reactors were first commercialized half a century ago, they were encouraged by governments that saw Nuclear Energy as a peaceful, redemptive byproduct of the deadly power unleashed at Hiroshima. The US federal official, Lewis L. Strauss said Nuclear Energy would produce electricity "Too Cheap to Meter." It has never given consumers anything like that. 

Nuclear Power is not only a high-risk technology in terms of safety, but also with respect to financial investment. It does not stand a chance in a market economy without state subsidies. The costs for decommissioning of nuclear power plant are very high & the cost of isolating radioactive byproducts/wastes from the biosphere & safeguarding them for hundreds of thousands of years, which defy human imagination, cannot even be estimated.

 When the environmental costs and all the overt and hidden subsidies/costs are factored in, Nuclear Power is one of the most expensive ways of generating electricity.  

Point No.5   Do We Accept the Socialization of Nuclear Power?

Various studies found that there is no financial return on investment in Nuclear Power without substantial government subsidies. The open market system of capitalism won't support Nuclear Power without government subsidies, as it is found to be a very risky business to invest in Nuclear Power.

 Standard economic theory states that subsidies can be justified when they lead to an overall increase in social welfare. But the environmental and health risks associated with radioactive waste, accidents, and risk of meltdown, nuclear proliferation, and the threat of terrorism, decrease the overall contribution to social welfare provided by Nuclear Power plants.

The United Nations Environment Protection (UNEP) Organization, specifically dictates that that the removal of subsidies that are economically costly and harmful to the Environment and to People, represents a Win-Win Policy. It is hard to imagine a more poignant case in point than Nuclear Power Industry, for removal of subsidies.. 

Point No.6   What Right do we have to commit Future Generations?  

 When we consider the entire lifecycle of a Nuclear Power Plant, from construction to decommissioning, combined with sourcing uranium and disposal of the radioactive wastes, the present generation would be making decisions that impact people far into the future. We are supposed to tell future generations, for at least 10,000 years, to keep their feet off nuclear waste dumps.  Mankind has no experience of communicating so many years ahead in time, making Nuclear Waste a serious language problem..



Thursday, June 16, 2011

Review of Bhavanapadu 2640 MW TPP of ECEPL - A Ritual & Eyewash ?

The Expert Appraisal Committee (EAC) on Thermal Power Projects in its 24 th meeting held on 2-3 May 2011 recommended that that the Ministry may rescind the stop work order issued on March 01, 2011, at the proposed power plant site of Bhavanapadu 2640 MW TPP of ECEPL at Kakarapalli, since at this stage, a zero base level assessment of the project is not a feasibility.


Reject Recommendation of EAC and Cancel EC


In accordance with Sub- Para 8 (vi) of EIA Notification, the deliberate concealment and/or submission of false or misleading information or data which is material to screening or scoping or appraisal or decision on the application shall make the application liable for rejection, and cancellation of prior environmental clearance granted on that basis.

It is therefore requested that the recommendation of EAC be rejected outright and the E.C granted to Bhavanapadu 2640 MW TPP of ECEPL at Kakarapalli, be cancelled by MOEF, after giving a personal hearing to the project proponent and following the principles of natural justice, based on the following facts & ground realities::

a) The NEAA in its Order dated 30-8-2010 observed that various reports including that of sub-committee of EAC were found to be incorrect
     and EAC & in turn the MOEF has relied on these reports for granting Environmental Clearance(EC) for the project.


b) The NEAA also observed that as stated by the expert of BHNS and agreed by  Dr.Kaul, a renowned expert on Wetlands, elevation of

     the project site by the project  proponent, after the grant of EC nearly a year ago, has caused irreversible changes  in the character

    of the ecologically important wetland.


c) In the 17 th Meeting of the Standing Committee of National Board for Wild Life held on 22-12-2009, under the Chairmanship of the

    Minister for E&F, the site inspection  report of Dr.Asad Rahmani and Dr, Asha Rajvanshi had clearly stated that Naupada  Swamps

    area was an excellent habitat for Migratory Birds and was classified as IBAS.  It also stated that the entire area of the project,

    starting from approach road to the project site is marshy land and the EIA Report of the applicant ignored Bio diversity of the area.


d) AP High Court, while dismissing WP NO..9360/2009 observed that " A plain reading  of the reproduction from the counter of the

    Respondent - State makes it clear that clearance was granted by the State after due deliberation and application of mind" ---
   "It is amply clear that the Power Project area is not part of Naupada Swamp and as  such bereft of any ecological importance"

    This is far from the facts and the ground realities


Penal Action


Instead of filing false criminal cases against innocent villagers peacefully agitating against Kakarapalli Power Project, necessary penal action be initiated, in accordance with Sections 15,17 and 19 of The Environment (Protection) Act, 1986, against Project Proponent and the Officials responsible for suppressing the info and/or submitting incorrect/misleading info/data about the project site.



Tuesday, June 14, 2011

Misuse of Diesel by Telecom Mobile Network Towers

The Diesel is heavily subsidized mainly for the benefit of Agricultural activities, Transportation of Goods and Passengers (Trucks/Railways/Busses). But the Telecom Sector is misusing the subsidized Diesel to power their mobile network towers, causing an estimated burden to the extent of Rs 2500 Crores to the Government.


National Action Plan On Climate Change


 The National Action Plan on Climate Change is initiated by Prime Minister of India for protecting the poor and vulnerable sections of the Society, through an inclusive and sustainable development strategy sensitive to Climate Change. The focus is on promoting understanding of Climate Change, adaptation and mitigation, energy efficiency and natural resource conservation by active participation of Public Private Partnership and the Civil Society.  


Natural Resource Conservation


 The Oil, like Coal is fast depleting non-renewable natural resource contributing to Climate Change. Therefore the consumption of Diesel needs to be curtailed in all sectors by judicious adaptation of Demand Side Management Measures, Energy Efficient Devices, and Renewable Sources of Energy..


Misuse of Diesel by Telecom Mobile Network Towers


 The Telecommunication Sector providing mobile telephone services, seems to depend on Diesel Generators, misusing heavily subsidized Diesel, for powering their mobile network towers to a large extent, mainly because of a) interruptions of grid power supply, b) location of Towers in remote places, and c) comparatively higher tariff of grid power.




 The following measures are suggested for consideration and implementation, in the spirit of National Action Plan On Climate Change, after discussion with the Telecom Sector and other concerned agencies:


a) The bulk supply of Diesel from the retail outlets should be  stopped, by March 2012,  so as to ensure that subsidized Diesel is not misused by the bulk consumers such as Captive/Emergency Diesel Generation sets used by Industry, Mobile Network Towers, Commercial establishments , Domestic Sector etc


b)   The bulk supplies of Diesel to the above users are to be made from the Refinery Outlets only,  at the price to be revised upwards to bring at level with the market price and avoid the burden of  subsidy from April 2012.


c)   The new Mobile Network Towers,  are not to be permitted to use Diesel Generators with effect from April 2012 onwards


d)   All existing Mobile Network Towers should completely phase out their Diesel Generators by March 2013 by opting to Solar Power with adequate Battery back up.


e)   All Mobile Network Towers should change over to the use of at least 50% of Green Power (Solar PV) by March 2014





Monday, June 13, 2011

Environmental Clearance Process nothing to do with Land & Livelihoods


 The Hon'ble Minister for Environment & Forests , GOI , in an obvious attempt to distance himself from likely violence during evictions at the POSCO site in Orissa, is reported to have stated that "Environment and Forest Clearance Process should not be used to fight other battles that have to do with important issues like, Land Acquisition, Compensation and Livelihoods."


EIA Process


 The Public Consultation of EIA refers to the process by which the concerns of local affected persons/communities and others who have plausible stake in the environmental impacts of the project or activity are ascertained with a view to taking into account all the material concerns in the project.


Human Environment


 The Environment (Protection) Act, 1986, the implementation of which is mandated with MOEF, drew its inspiration from the proclamation adopted by the United Nations Conference on the Human Environment, which includes Water, Air & Land and the interrelationship, which exists among and between water, air, land and human beings, other living concerns ,plants, micro-organism and property.


The protection and improvement of the Human Environment is a major issue, which affects the well being of people and economic development throughout the world; it is the urgent desire of the people of whole world and the duty of all governments "Vide  Article 48-A of The Constitution of India.




 The EIA process is required to take into consideration the adverse impacts of the Land-Use change due to the proposed project and its likely Socio-Economic effects on local communities, and other cultural values, before according Environmental Clearance to the project.  


 The Environment, Land and Livelihoods are inseparable and form integral part of the Project Appraisal and Public Consultation




 The present process of Public Consultation and Environmental Appraisal of the projects for granting Environmental Clearance has become a ritual and farcical, ignoring the main issue of protection and improvement of Human Environment and the consent from the affected village level Grama Sabha.


 Otherwise, we would not have had the Land and Livelihood problems of Sompeta, and Kakarapalli in AP State, Jaitapur in Maharashtra and now POSCO episode. In Orissa.


 Hope the Government of India and MOEF will stop using different yard sticks for granting Environmental Clearances for the projects, in different States, with a view to gain Political Mileage.?


Monday, June 6, 2011

Hyderabad International Airport , Shamshabad - Monitoring

The monitoring and review of the status of compliance of specific conditions stipulated by MoEF GOI, in its letter of 6-3-2003, granting Environmental Clearance for Hyderabad International Airport ( HIA) Shamshabad, is very unsatisfactory, .not transparent & accountable to the public at large, for ensuring their effective compliance.

Supreme Court Order   


The Hon'ble Supreme Court in its Order dated 1-12-2000, ruled that the government could not grant exemptions to the provisions of G.O.111, prohibiting polluting activities, in the catchment up to 10 Kms from Full Tank Level ( FTL) of the Lakes, unmindful of the fate of Lakhs of citizens of Twin Cities, to whom drinking water is supplied from these lakes. Such exemptions carelessly passed ignoring the "Precautionary Principle" could be catastrophic


Monitoring of Acidification of Himayat Sagar


By the very fact that an area of 314.0 acres, out of about 2200.0 acres of prohibited catchment area of Himayat Sagar, is being utilized for the airport activities, the monitoring & review of compliance needs special attention.  The acidification of lake waters due to toxic emissions from the aircraft, during landing and taking-off operations, needs to be regularly monitored by a suitable agency, in the light of the provisions of Sub Para 3(e) of GO. 111 dated 8-3-1996


Monitoring of Specific Conditions


In the light of Supreme Court directive and the fact that prohibited catchment area of Himayat Sagar is being utilized by HIA., the specific conditions in particular, stipulated while granting E.C  for HIA, are required to be monitored and reviewed for their effective compliance/implementation

Flight Scheduling and Noise Levels

The specific condition of special importance is that "Flight Scheduling and airport zoning should be properly done to reduce noise levels and their impact during night time. The noise levels should be as per the prescribed norms/standards." It may be of relevance to note, that REIA Report, predicted post project decrease in noise pollution in some areas abutting the proposed airport and the incremental noise level due to airport are pegged at 60 dBA. This aspect needs to be verified for its effective compliance & confirmed

Bird Hits & Smog

The other aspects are the possible "Bird Hits" endangering the safety of aircraft and the lives of the air- passengers & the proposed remedial measures, and the likely adverse impact of Smog in the area on the flight schedules, particularly in winter months, because of the presence of a number of air-polluting industries around the area and the proposed remedial measures etc     

Need for Epidemiological Study

The evaluation of Cancer Risks attributed to Air Pollution in Southwest Chicago published in April 1993 by EPA USA, attributed 10.5% of the total cancer cases within 16 square-mile area surrounding Midway Airport, Chicago, to emissions from aircraft. 


Seattle- King County Department of Public Health studied the health effects of citizens in Georgetown, an area surrounding the King County International Airport and released a report on June 20, 1997.The statistical comparison of the hospitalization rates for Georgetown with those for King and North King Counties in Seattle, show :


     * a 57% higher asthma rate

     * a 28% higher pneumonia/influenza rate

     * a 26% higher respiratory disease rate

     * a 83% higher pregnancy complication rate

     * a 50% higher infant mortality rate

     * Genetic diseases are statistically higher

     *a 36% higher cancer death rate with pneumonia and influenza among
        the top five leading causes


 Therefore, there is an immediate need to undertake Epidemiological Study of the surrounding area of Hyderabad International Airport, Shamshabad, to assess and evaluate the long term health impacts on the citizens and for initiating the required mitigation measures.

Lack of Confidence in Monitoring / Regulatory System

 The following facts, showing the speed with which the HIA Project, of considerable adverse environmental impacts on the drinking water source, in violation of the provisions of G.O.111 and Supreme Court Order, had been granted NOC by APPCB, within about 20 days from the Date of Environmental Public Hearing, speak volumes about bureaucratic / political highhandedness.

       * 28-12-2002    Public Hearing

       * 28-12-2002-   Minutes of PH issued

       * 30-12-2002    Technical Committee first meeting held

       * 08-01-2003    Technical Committee second meeting held

       * 17-01-2003    CFE Committee meeting held

       * 18-01-2003    NOC granted by APPCB

       * 07-02-2003    Application Received by MOEF

       * 06-03-2003    Environmental Clearance of MOEF granted 

Authority taking precedence over Prudence could be dangerous.