Wednesday, July 27, 2011

Change of Land Use -Conservation to Residential Use in HMDA


This has reference to AP Govt G.O.MS.No.288 of 23-07-2011 changing the land-use of the Site in Sy.No. 615(P) & 616(P) in Pattighanpur Village of Pattancheru Mandal in Medak District, to an extent of Ac.19.15 Gts, which is presently earmarked for Conservation use zone in the notified Master Plan as Residential use zone


Reduction of Conservation Use Zone & Adverse Impacts


 In the Master Plan, the land use under Residential, Commercial etc zones was increased considerably, taking away the area from, Conservation– Agricultural, Hills, Recreation Open spaces etc - and even land under water bodies &forests. As a result the area under Conservation use zone had come down drastically to about 50% of the area in 2000. In addition there are unauthorized changes of land use of conservation areas


 The reduction of the area in Conservation, Forest etc zones, is already adversely affecting the quality of life, with deteriorating Air Quality, increasing Temperatures of Heat-Islands, increasing Storm Water Runoff & consequent flooding etc in HMA. With the reduction of agriculture land, there is already scarcity of locally grown seasonal vegetables, fruits, flowers etc, as result of which their prices are going up, increasing the cost of living and making the life of common city dweller more and more difficult.


Change of Land Use Illegal


The practice of changing the land-use notified in the Master Plan by a Gazette Notification by the Govt in essence, means the letter of the law is observed but the spirit is ignored. The regulation of land-use continues to be handled by the State Govt, in violation of Item 2 of Twelfth Schedule of the Constitution.   


The  Hon'ble A.P. High Court in its landmark judgment on  W..P. Nos.23835/96 and 35/97, against the use of Indira Park and "Buddhapurnima Park"  for cremation of mortal remains of the two former Chief Ministers of the State, observed 


 "Whatever little scope was available to argue that the government of the State represents the sovereign and retained thus its eminent domain in deciding in respect of the use of a public place one way or the other is taken away by the Constitution Amendment Act, 1992 and Article 243W (a) therein read with the list in the Twelfth Schedule" (Page 49).

 The Courts can only high light the ill effects of "Bad Governance" but they cannot bring in "Good Governance" under the present system

 Objection to the Land-Use Change

 In the light of the position explained above, the change of land-use being authorized by the State Govt, vide G.O. Ms.No 288 of 23-07-2011, may please be reviewed and cancelled.

 Another aspect which needs urgent reform is for discontinuing the practice of changing the notified land use in the Master Plan  by inviting  objections with short notice  through  a Gazette Notification which is not easily accessible by the public .The  wide publicity needs to be given for the change of land use asking public objections instead of confining to Gazette publication with short notice


Tuesday, July 26, 2011

Appointment of Whole Time Chairman of APPCB

The proposal for appointment of whole-time Chairman of AP State Pollution Control Board,(APPCB) is reported to be under active consideration of the State Govt. It is a welcome change as the Chief Secretary had been officiating as part-time Chairman of APPCB all these years, and was not able to address effectively, the serious environmental problems/ issues being faced by the State.


APPCB Performance


 Some of the serious environmental problems/issues being faced by the State are – the pollution of water bodies, the unabated urban air pollution, the discharge of untreated / undertreated industrial effluents, the destruction of sensitive wetlands in coastal areas by Thermal Power Plants, the poor performance of CETPs & STPs, the non-implementation of MSW Rules 1999, the failure to stop manufacture of sub-standard Plastic Carry Bags etc


 Due to lack of proper direction and guidance from the Chairman & the Board and in the absence of regular Review & Monitoring of the performance by the Board, the APPCB failed to act and perform effectively in many of the issues, in spite of strictures /directives of AP High Court and the Supreme Court of India, from time to time


Need for Whole Time Chairman  


The need of the day is reconstitution of the Board and the appointment of a person having special knowledge and administrative experience in respect of environmental issues, as the Whole-Time Chairman of APPCB. But the post should not be used for rehabilitation of the Retiring IAS Officer. To be fair to IAS Officers, hasten to add, that a couple of IAS Officers appointed as Member Secretary of APPCB had performed extremely well leaving their mark.


SCMC Observations on APPCB


The Supreme Court Monitoring Committee(SCMC) on Hazardous Wastes, in its Report of visit to Hyderabad 19-20 October 2004, made the following observations on functioning of APPCB:


  a)As the Board stands constituted today, neither the Chief Secretary  (Chairman) nor the Member Secretary is a subject professional with   
     the  necessary technical  qualifications & relevant experience, to  ensure that the Board discharges its functions as required by

      the Environment Laws.


 b)There also appears to be clear conflict of interest between the  decisions required by  the Board and the the decisions of the A.P. Govt..

    As the Board has been   reduced to an appendage of the Government, it does appear to be taking decisions  that will always support

     the Government. This is clearly  demonstrated in the case of  two large projects. ( The PVC Plant at   Krishnapatnam and Pharma City

     at Parwada)


c)Given the rapid advances in environmental sciences & technologies & allied  disciplines , the SCMC is not convinced that the 

    present leadership structure of the Board is either consistent with the provisions of The Water Act, The Air Act, The  Recommendations

    of the MGK Menon Committee and the report of the Planning Commission on the matter. 


d)We are therefore of the strong opinion that the AP Government ought to reconstitute the APPCB, in the light of the recommendations

   given in the Menon Committee. The Member Secretary must be a technically qualified person, as he is the Chief Executive Officer

   of  the Board.


e)The SCMC recommends that the State Government sets up a Selection Committee of  three eminent Scientists/Administrators ,

     who can preside over the selection process  that will send a list of three qualified candidates for each post to the Government for
     eventual selection.


f)The A.P State needs a Board that is dynamic & is technically well equipped to take stock of the serious environmental problems

  facing the State


 But unfortunately, the report of SCMC does not seem to have received the attention and consideration it deserved by the State Administration during the last seven years. As the industrial and development activities in the State had increased many folds during the last decade, the recommendations of SCMC are much more relevant to day, for initiating necessary action by the State Govt.


Parliamentary Standing Committee Recommendations


The Parliamentary Standing Committee on Science & Technology, Environment & Forests, which presented its report on functioning of Central Pollution Control Board (CPCB) to both Houses of Parliament, is reported to have observed that the trend of IAS Officers and Bureaucrats holding key posts in Central and State Pollution Control Boards is very disturbing and that practice needs to be stopped forthwith.


 The Parliamentary Standing Committee also reported to have expressed its displeasure over not fixing qualifications or criteria for members of CPCB and State PCBs and observed that with composition dominated by government representatives, the CPCB and State PCBs cannot be expected to act as watchdog of environmental protection.


Prime Minister's Announcement


The Hon'ble Prime Minister is reported to have announced on 24 th July regarding the establishment of an independent Regulator "National Environment Appraisal and Monitoring Authority" (NEAMA).soon. This organization staffed by dedicated professionals, will work on a full-time basis, to evolve better and more objective standards of scrutiny  




 In the light of the position explained above, the Hon'ble Chief Minister is requested to consider setting up the Selection Committee of three eminent Scientists/Administrators as recommended by SCMC, for appointment of Whole-Time Chairman and the reconstitution of APPCB Board at the earliest in accordance with Section 4 of The Water (Prevention and Control of Pollution) Act, 1974.


Look forward for early response from the Hon'ble Chief Minister , who "Can Make A Difference" by his  Swift & Decisive Action




Wednesday, July 20, 2011

KBR National Park, Banjara Hills, Hyderabad

Background of KBR Park


Before 1990, the place was well known as "Chiraan Palace" gardens owned by the Nizam of Hyderabad. Because of its wilderness and being left unused, except in one corner, it acted as the catchment for Banjara Lake & Hussainsagar, apart from helping recharge of the ground water regime of Banjara & Jubilee Hills & adjacent colonies.


The total vegetative cover of the area helped percolation of storm water & recharge of ground water and graduating the flows into the water bodies down stream, apart from harboring biodiversity of both flora and fauna. This prompted the State Govt to take over the area and notify it as Reserve Forest and subsequently as "National Park" under the provisions of Wildlife Protection Act and named it after a well known former Chief Minister, Kasu Brahmananda Reddy.(KBR).


Walkers Association - High Court Orders


While all the statuary requirements are completed for notifying the "National Park" and the final notification was awaited, a group of influential citizens of the neighboring areas, banding themselves as "Walkers Association" got AP High Court Orders permitting them to use the area for recreational walking, pending final notification.


After the final notification was issued notifying the place as National Park, it was closed for recreational walking .But the Walkers Association approached AP High Court again and got orders to permit recreational walking in the National Park. Against these orders, the Division Bench of AP High Court was moved by Nallamalla Foundation, in which the AP Forest Department filed an affidavit clearly stating the Recreational Walking was not a permitted usage, in terms of Section 28 of the Wildlife Protection Act.


The Division Bench of AP High Court set aside the orders of the single judge allowing recreational walking in KBR National Park. The Hyderabad Urban Development Authority (HUDA) developed very good walking path all around KBR National Park for the use of recreational walkers and, to conserve the National Park, with all the disciplines that go with it, like closed seasons, limited entry etc.


Inaction & U-turn of Forest Department


But the recreational walking continued unabated with paved pathways though not black topped, treating National Park like a Municipal Park, even having a Laughing Club, Yoga Classes etc inside the park, As the Forest Department did not stop the walking, the earlier petitioner moved the High Court for implementation of the Division Bench Orders. Based on the changed stand of the Forest Department, putting forward the concept of a "Visitor's Zone"(i.e. walkers as visitors) to allow the walking to continue, and not bringing forth before the court the adverse impacts on the water regime and biodiversity over the years, the second Division Bench of AP High Court permitted recreational walking in KBR National Park,.


Walkers Paradise


Once the court permitted recreational walking, the KBR National Park is thronged and crowded  by the residents of Banjar & Jubilee Hills and the near by areas in their cars, in the mornings and evenings through out the year, making it look like a Mela. Because of cluttering of a large number of vehicles, the chaotic traffic  is a regular feature  at the entrance of the Park on Road No. 2 of Banjara Hills and the nearby areas, in addition to heavy Air Pollution due to vehicular toxic emissions..


The irony is that even when there is an alternative of a very good walking path all-round KBR National Park, the Walkers choose to walk inside the National Park only, violating the provisions the Wildlife Protection Act, and oblivious of their Fundamental Duty- vide Article 51-A (g) and the long term consequences of their actions.  .




If recreational walking is allowed to continue inside the KBR National Park unchecked, the last wilderness in congested Hyderabad City will slowly disappear and become yet another ordinary park, suffering the same fate as once famous Hyderabad Public Gardens, having serious adverse impact on quality of life of large mass of citizens. 


Thursday, July 7, 2011

Biofuels and Food Crisis - National Policy?

 National Bio-Fuel Policy


The National Biofuel Policy was announced, with the object of raising the proportion of the use of Biofuels from 5 to 20 % in petrol and diesel fuels over the coming decade, using non-edible plant sources. According to the policy the transport fuels in India need to contain 20 per cent Biofuel by 2017. The main Biofuels envisaged are alcohol from plant wastes, chiefly sugarcane molasses, and biodiesel - oil produced from non-edible oilseed crops such as Jatropha which can be blended with diesel.

The policy supports increasing biodiesel plantations on community, government-owned and forest wastelands, but not on fertile, irrigated lands The policy also details incentives for growers of Biofuel crops, removing taxes and duties on biodiesel, setting a minimum support' price for buying biodiesel oilseeds from growers and a minimum purchase price of bio-ethanol, to ensure adequate returns to crop growers &oil makers.


A 2006 analysis by the UN Conference on Trade and Development (UNCTAD) concluded that India cannot rely on sugarcane molasses as a reliable feedstock for alcohol, given the crop's dependence on monsoon and vagaries of the domestic sugar industry. Similarly, difficulties in procuring oilseeds and lack of infrastructure could obstruct substantial biodiesel production by 2011-12 UNCTAD suggested that India might have to import both bio-ethanol and biodiesel to meet its targets


Diversion of Grains from Food to Fuel


As per the information available about 50% Diesel and Petrol is being used as transport fuels working out to be about 35 million tones per annum. But Biofuels will only substitute a little for fossil fuel use, yet lock-up huge land areas for crop cultivation, says Anumita Roychowdhury, associate director for research and advocacy at the Centre for Science and Environment, Delhi


Dr.R.K.Pachauri, Chairperson of IPCC, said subsidies on Grain and Oil Seed, Biofuels, making farmers shift from growing food grains to Biofuel plantations, resulting in food shortages, driving food prices up high and leaving millions hungry. According to Dr.Pachauri, subsidies on grain based ethanol & palmoil based bio-diesel, had brought in distortions by converting food into fuel and by resorting to change of land use of forests for growing crops for Biofuels.  


It was reported that in Chhattisgarh state, 400 million Jatropha saplings were planted on more than 155,000 hectares of fallow land during the last 5 years or so and, until now, there does not seem to be any reported data on survival of saplings or seed production. while farmers in many areas are in a fix as the plants have not yet borne fruits


.Grain based Ethanol Projects


To add fuel to the fire in AP State, the grain based mega ethanol project of M/s Sentini Bioproducts (P) ltd, in Krishna District of AP, will add to the shortages and high prices of food grains, by diversion of agricultural land and their produce.

 The Bio-Energy plant of M/S Natural Bio Energy Limited ( NBEL), near Kakinada port, for producing nearly 300 tones of Biodiesel per day, from imported crude palmoil from Malaysia and Indonesia. The company is reported to be planning to export 100,000 metric tones per annum, to European countries by sending a vessel every six weeks. This explains for shortage and high prices of edible oils in the country.


Unpublished World Bank Report


According to a confidential World Bank report obtained by the Guardian, UK some time back, it was reported that the Biofuels have forced global food prices up by 75%, far more than previously estimated. The findings of the report seem to contradict the US government's claims that plant-derived fuels contribute less than 3% to food-price rises, justifying the shift to plant-derived fuels 


Rethink on National Bio-Fuel Policy


The National Bio-fuel Policy of giving subsidies for Biofuel production, which is a Supply Side Management (SSM) Policy, increasing the demand for use of fuels for transportation, needs to be reviewed. The Govt of India should opt for Demand Side Management (DSM) Policies that reduce overall demand for fuels. The options for DSM measures are:


  a) Energy efficient Rail Transport Systems for Public Transport and Goods over long distances instead of massive development of National


 b) Intra-city Public Transport Systems for restraining the use of personal vehicles,  particularly SUVs/Cars run on subsidized Diesel, which

      is nothing but looting the Tax-Payers money and is as criminal as Avoiding Taxes. and


 c) Energy Efficiency measures in transport sector having saving potential up to 20%   as per PCRA  



In the light of the position explained above, the "National Biofuel Policy" needs to be reviewed for ensuring "Energy Security" without compromising "Food Security" . Some of the points to be considered are  


   a) The diversion of food-grains for production of Ethanol and the feed stock  (imported or otherwise) of Edible Oils, for production of

         Bio-Diesel, be  prohibited.

  b) The conversion of forest lands, fertile lands etc for development of any type of Biofuel plantations should not be permitted..

  c) The export of Ethanol, Bio Diesel etc should not be permitted


Monday, July 4, 2011

Nuclear Power Park at Kowada, Srikakulam Dt. AP State --Sweeping and Evasive Comments of NPCIL

 The Nuclear Power Corporation of India Ltd (NPCIL), while responding to various Points raised with regard to the proposed Nuclear Power Park (6X1000 MWe, LWR) at Kowada village, Srikakulam, Dt. A.P. State, made some sweeping and evasive comments, which are discussed in the subsequent paragraphs


1) Point: Nuclear Power is Not CO2 Free, Not Cheap, Not safe, Not Clean & Green and Does not Provide Energy Security.


NPCIL Response: "The role of Nuclear Power is clearly defined in The Integrated Energy Policy of India 2005" -----"This is a well known fact in public domain in the world that Nuclear Power (NP) is proven to be Environmental Friendly, CO2 Free, and is able to meet the huge demand of power by ever increasing development activities and population and this demand cannot be satisfied by other non-conventional sources of energy due to their low production potential per unit area and their dependence on vagaries of nature. This is being proved by the increasing number of NPPs all over the world and many nations opting for nuclear energy in future. Therefore the available option is to develop NPPs for the progress of the Nation"


Observation: NPCIL seems to be taking shelter under "The Integrated Energy Policy of India 2005"   without addressing specific points raised & by making sweeping &evasive comments as explained below:


a) CO2 Free- The fact is, "It takes energy to make energy"- even Nuclear Energy.   Although Nuclear Power Plant itself releases no CO2, the entire Nuclear fuel Cycle ,- from Uranium mining  to decommissioning & dismantling of the Reactor and the safe storage of radioactive nuclear waste generated in the process - is the most complex and the intensive user of Fossil Fuel. In the huge campaign now being run all over the world, to present Nuclear Power as CO 2 Free, the Nuclear Industry is suppressing the fact that it is a guzzler of fossil-fuel, the kind of energy the

Nuclear power is touted as replacing -with the concurrent production of CO2. . We get six times the reductions in CO 2 by investing in Energy-Efficiency, rather than Nuclear Power and much faster too.

b) Environment Friendly-As per the Environment (Protection) Act 1986, the "Environment" includes Water, Air & Land and the inter-relationship which exists among & between them and human beings & other living creatures, plants, micro-organism & property. The Nuclear Power, producing nuclear waste with high levels of radiation and not to talk of accidents, having serious adverse impact on living organisms, cannot be termed Environment Friendly by any stretch of imagination. The Electricity is but the fleeting byproduct and the actual product is forever deadly radioactive waste, which needs to be isolated from the biosphere for thousands of years that defy human imagination. Even 21 st Century science has no answer for safe disposal of Nuclear Waste.

c) Clean and  Green Energy-Nuclear Power cannot be termed as renewable source of energy because its fuel materials are as limited as fossil fuels such as Coal, Oil, etc 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.


d) Increasing Number of NPPs & many Nations opting for Nuclear Energy-Why hasn't USA commissioned even a single Nuclear Power Plant (NPP), after 1974? Why has Austria opted out of Nuclear Power as a solution for problems of Climate Change or Peak Oil Crisis? .Why has Germany opted to phase out Nuclear Power Plants by 2022? Why has Italy voted against Nuclear Power in the Referendum?  Why has Switzerland dropped the proposal for new NPPs? Even China and Japan are reported to be revising their Nuclear Power Policy after the recent melt down of Fukushima Dai-ichi NPP in Japan. In March 2007, on the 50 th Birthday of the Euratom Treaty, why have more than 600,000 Europeans and 800 European Organizations demanded that European leaders phase out Nuclear Power and massive investments in Energy Saving,/ Efficiency and Renewable Energy ? Why is Indian Government (DAE) being blind to the realities and obstinate about NPPs?


e)To Meet Huge Demand of Power for Increasing Developmental Activities-Based on an unrealistic assumption that economic vitality requires steadily increasing energy consumption, the total capacity of 8, 00,000 MW is projected by 2031-32, which is about 5 times the present capacity.   The breeding ground for Nuclear Power is the inflated power demand projections. As a result, total Nuclear Power capacity projected is 60,000 MW by 2031-32, which works out to be hardly 10 % of the total projected capacity. The Nation's Energy Security depends on efficient use of Energy Services that maximize economic competitiveness and minimize environmental degradation / impact.

2) Point: Safe Disposal of  Radio-Active Waste

NPCIL Response: At present the low & intermediate radio-active solid/solidified wastes are stored in Near Surface Disposal Facility (NSDF). They are stored under ground at a depth of maximum up to 4m either in trenches / RCC vaults / Tile holes depending upon the surface dose rate of the waste. The solid waste disposal site is fenced and designed to store waste for an active control (monitoring, surveillance, remedial work) period of 100 years followed by passive control (land use control) period of 200 years. After 300 years of storage (with 10 or more half lives) the total radio activity of the material will be almost negligible.----- The stored solid waste will never come in contact with ground water during its operational life.

Observation: NPCIL talks of storage of low and intermediate level radioactive solid /solidified wastes generated by the reactor, without addressing the main concern of storage/disposal of high level and extremely potent radioactive wastes generated during the operation of the Reactors and after their decommissioning & dismantling. This is clear indication of misleading the public, on the part of NPCIL.

Each 1000 MW NPP generates 1500 tons of extremely potent radio-active waste in its operational cycle of 50 years. Even though NPPs have been operational for nearly 50 years, the Nuclear Industry has yet to determine how safely transport, this deadly material, prepare adequate storage facility, and to supervise and guard the site for  periods of time, almost beyond our comprehension – 240,000 years. In addition huge quantities of intensely radio-active wastes from decommissioning and dismantling NPPs are to be catered for after the operational cycle of 50 to 60 years The Depleted Uranium (DE) 238, the discarded material after enrichment of Uranium 235, which continues to be radio-active with half-life of 4.5 billion years, remains another problem

The key issues raised about the quantum and duration of radioactivity and solutions for safe disposal of high level and extremely potent radioactive nuclear waste remain unanswered. The questions about Costs, information, transparency, independent regulation, the involvement of the public at large and risk management arise.

3) Point:. Release of Substances Harmful to Human Health 

NPCIL Response: Tritium release in Light Water Reactors is insignificant .Provision for monitoring tritium will be provided    

Observation::Even accepting that Tritium release from Light Water Reactor (LWR) is insignificant, how effective the proposed monitoring and control measures would be, is not known. The information is required regarding the type LWRs being provided for Kowada Nuclear Power Park- Generation II or III?

The response conveniently ignores the possible risk for exposure to unhealthy amounts of radiation from other radioactive gases routinely released from the reactor and the consequences of possible accidents / meltdowns during operation, due to human / mechanical errors and likely terrorist attacks and impacts from climate change and natural disasters.  

4) Point: Hazardous Radio-active Releases- Risk to Health & Environment

NPCILResponse: "The NPP unit is so designed that activity releases to the environment through pre-designated release points. These radioactive effluent releases to the environment are continuously monitored and controlled.------The average dose to the members of the public from all exposure pathways will not exceed 1 mSv in a year by virtue of disposal of liquid, solid and gaseous waste to the environment as stipulated in AERB safety Manual. In the design stage various anticipated accidents and their combinations are assumed and suitable design is worked out on the basis of analysis of the accident scenario. Even very unlikely events are analyzed and mitigating measures are included in the design.-------"

Observation: As an exposure of 100 millisieverts (mSv) per year is considered the lowest level, at which an increase in cancer risk is evident, the claim of NPCIL of 1 mSv needs to be subjected to close and strict scrutiny. 

Contrary to NPCIL claims, NPPs 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, which may be beyond 100 mSv per year. A German study has shown that within a 10-mile radius of their Reactors, childhood leukemia has increased to a frightening level.

U.N. Secretary-General Ban Ki-Moon speaking at Kiev conference commemorating the explosion of a reactor at Ukraine's Chernobyl nuclear reactor is reported to have said."To many, Nuclear Energy looks to be a relatively clean and logical choice in an era of increasing resource scarcity. Yet the record requires us to ask painful questions-: Have we correctly calculated its Risks and Costs? Are we doing all we can to keep the world's people safe?" "The unfortunate truth is that we are likely to see more such disasters."

Japan is perhaps the most technologically advanced nation on earth and yet, the review report by IAEA, of the Fukushima Nuclear Disaster, time after time finds missing measures It highlights the fundamental inability for anyone to anticipate all future events and so deeply undermines the claims of the nuclear industry and its supporters that this time, with the new generation of reactors, things will be different.

Japan has a well organized emergency preparedness and response system and dedicated and devoted officials and workers. But complicated structures and organizations can result in delays in urgent decision making. Even in one of the best nuclear safety regimes, the complexity of accidents can overwhelm the emergency response.

To sum up, NPPs are designed and built mainly for controlling the nuclear fury of the known and anticipated events  at its heart for half a century or more, and controlling the waste produced lasting for many thousands of years,  remains unresolved and beyond the mankind comprehension. On those timescales, unforeseen events are a certainty, with disastrous and very expensive consequences..  

5) Point-.Public Consultation

NPCIL Response: As part of Public Consultation process NPCIL has facilitated the visit teams of persons from the proposed project area, journalists etc to other NPPs like Tarapur, Kalpakkam, Kudankulam etc .Interaction with the project affected people of the areas have also taken place as part of the consultation process..

 Observation: The claim of NPCIL facilitating the visit of teams to other NPPs seems to be window dressing and brain washing exercise. .One side claims are made that radiation from NPP is very low and no adverse impact on the environment, while the actual facts and ground realities are not being shared with the public. The land acquisition for the project should not be started, unless the apprehensions about the possible release of radiation during normal operation of NPP and in the event of likely accidents and their adverse impacts on humans, biodiversity and environment, are cleared, particularly in the light  of recent Fukushima NPP disaster in Japan . 

6) Point:. Public Apprehensions on EIA Process

NPCIL Response: EIA Report is prepared based on precise & accurate information / data collected.----  The project will have an effective environmental management plan which ensures no adverse impact on agriculture, cattle and environment around the project.---"

Observation: We have the bitter experience of EIA Reports and EPHs in respect of Uranium Mining Projects of UCIL in Nallagonda and Kadapa districts in AP State. Even Mr. Jairam Ramesh , Hon'ble Minister for E&F is reported to have stated recently that "EIA Reports are a Joke" Any talk of "Corporate Social Responsibility" of NPCIL makes no sense unless it is demonstrated in EIA Reports by addressing various points raised about NPPs and by well  informed public participation in  Environmental Public Hearing  for the proposed NPP  

7).Point: Nuclear Establishment & AERB

NPCIL Response: NPCIL, and HPD, BARC are totally independent establishments under Department of Atomic Energy (DAE)------ AERB functions effectively and exercises its authority in an independent manner.

Observation: The hollowness of NPCIL response can be seen form the following::

". I can personally vouch from my earlier experience as chairman, AERB that the DAE and the AERB often work in collusion, misusing the Official Secrets Act much more to cover up the serious lapses and inactions in their operations than to protect the safety or security of the public. As per AERB's constitution, the AERB chairman is answerable to the AEC and he cannot therefore disobey the orders of the chairman, AEC (who is also concurrently the Secretary, DAE). Thus, there is no independent nuclear safety regulation in the country and the AERB merely serves as a lapdog of the AEC, DAE and the Prime Minister's Office (PMO)"----Dr. A Gopalakrishnan, 03 May 2010/ New Indian Express

"While India has a good regulatory body, there is need for more transparency," advised director-general of the International Atomic Energy Agency (IAEA) Yukiya Amano when asked about his reaction to massive protests against the development of the world's largest nuclear power hub at Jaitapur, Maharashtra

8) Point:. Exclusive, Sterilized &Emergency Zones of NPP 

NPCIL Response: Very general and evasive

Observation: As per information available, about 17,800 households with habitants of about 75, 000,in about 110 villages/habitats, covering an area  of about 26,700 acres  of private lands with agricultural activities, are reported to be in  these three zones . 

The adverse impacts of exposure to radiation from radioactive gases routinely released from the NPP and the consequences of possible accidents/meltdowns during operation and due to human / mechanical errors and likely terrorist attacks and impacts from climate change and natural disasters on this area have to be clearly spelt out and informed to the public, before the EPH is held

 9) Point: Alternative Choices

The NPCIL had conveniently chosen to be silent with regard to considering alternatives to the proposed Nuclear Power Park. During the EIA Process of the project the fundamental questions to be asked are:


a)    Is the proposed NP Project required for providing energy security?


b)    Are there viable alternatives which could provide the same benefits?


c)    What are the Life Cycle Costs  when compared to likely alternatives ?


d)    What is the level of public safety in relation to hazardous technologies?



Viable Alternative


  it is worth considering for adequate investments in Supply Side Management (SSM) & Demand Side Management (DSM) measures, as "Energy Conservation" is the fastest & the cheapest way of making available Clean Energy. As the energy conservation potential, in our energy intensive economy, is estimated to be more than 25%, we can easily do away with the projected 60,000 MW Nuclear Power. by 2031-32, which works out to be less than 10%

Precautionary principle

The "Precautionary Principle" states that if an action or policy has a suspected risk of causing harm to the public / environment, in the absence of scientific consensus that the action or policy is harmful, the burden of proof that it is not harmful falls on those taking the action.- "Proof of Burden on Polluter". The principle implies that there is a social responsibility to protect the public from exposure to harm, when scientific investigation has found a plausible risk.

 The U.N.Secretary -General Ban Ki-Moon, speaking at Kiev, commemorating the explosion of a Reactor at Ukraine's Chernobyl NPP 25 years ago. said "The more complex technologies become, the more complex societies become, the more important it is to involve civil societies, to have democratic institutions, a free press,"  

Let there be a free and frank public debate about the need for Nuclear Power in India ?