Friday, November 23, 2012

Lifting of Ban on Bulk Drug Units

The AP Government is understood to be considering, to lift the ban imposed on Bulk Drug Units by G.O.62 dated 28-04-1999, in compliance with the Supreme Court Directive in interim orders dated.12.05.1998 in W.P.N0.1056/90.


The justification being put forward for lifting the ban appears to be that the ban order of a decade old, was based on the then prevailing obsolete technologies / processes being adopted / used by the Bulk Drug Industry. The industry can achieve zero discharges by adopting the State of Art Technologies / Processes now available.


Ground Realities


The Supreme Court in W.P.N0.1056 of 1990, as far back as 1998, directed the industries for segregation of waste streams containing non-degradable pollutants from the degradable ones, for treatment / disposal at the very source of their generation ie at the industry itself, instead of sending it to CETPs. But unfortunately, neither the industry implemented nor the regulating agencies enforced its implementation and the untreated / under-treated effluents, continue to be discharged into 18 KM Pipeline / Sewers / Drains /STPs / Musi River unchecked.


The enforcement of measures for the discharges from CETPs to comply with the Surface Water Standards, as stipulated in the Joint Action Plan of CPCB & APPCB of 2-7-2007 submitted to Supreme Court in W.P.No 476 / 2005, & W.P.No 441 / 2005, does not seem to be effective. If they conform to surface water standards, what is the need to transfer the so called treated effluents of PETL, at considerable cost and effort into Sewers by 18 KM Pipeline, ultimately finding their way, through STPs, into Musi River?


It is abundantly clear that pollution levels are on the increase, as Pattancheru- Bollaram was identified by CPCB in 2010, as one of the critically polluted industrial clusters in the country. It can also be judged by the fact that as late as  2012, the APPCB served closure notice  to 12 Bulk Drug Companies, whose manufacturing units located  around Hyderabad were indulging in manufacture of 'Unconsented' Products' and stepping up of quantity of production without mandatory prior Environmental Clearance and leading to increased pollution load. 




In accordance with sub-section 15 (1) of The Environment (Protection) Act, 1986 , whoever fails to comply with or contravenes any of the provisions of this Act, or the Rules made or Orders or Directions issued there under shall, in respect of each such failure or contravention , be punishable with imprisonment for a term which may extend to five years or with fine which may extend for one Lakh Rupees, or with both?


But, there does not seem to be a single instance, in which penal action was initiated against repeatedly defaulting units with impunity during the last two decades or so. Unless non-compliance of rules / regulations is made a High-Risk Business by strict implementation of the provisions of the Act by stringent Penal Action, the situation may not be very different even after switching over to so called State of Art Technology /  Process.




Why should the Bulk Drug Industry spend money on State of Art Technology / Process to minimize / avoid  pollution load, when it can be passed on To Others, To Elsewhere and To Future, with out of much of a Risk ?  


The Answer is  a) Non -Compliance is to be made A High Risk Business instead of being A High Profit Business as at present .

                             b) Proof of Burden should be on the Polluter  and

                             c) Polluter Pays Principal should be made applicable


Wednesday, November 14, 2012

Kolleru Area Downsizing - Not only Pelicans, Even Eluru & Vijayawada may be at Risk

 The recent floods caused by "Cyclone Nilam" in the various drains– Budameru, Tammileru etc.- that empty into Kolleru Lake, have caused the water to rise up and cross the +8 feet contour. This has resulted in flooding of several colonies along the banks of Budameru in Vijayawada City, for several days.


Dr.Azeez Committee Report


 Dr. Aziz Committee clearly stated that every few years, the lake spreads over +7 feet contour and on an average once in eight years the lake fills to above +9 feet contour, holding up to 1222 million cubic meters of water in contrast to the storage of about mere 150 and 300 million cubic meters at +3 and +5 contours respectively.


 It is also stated that if Kolleru Lake is resized by reducing its effective functional area, inflow during rains would spread far wider and away into upstream areas, submerging bed and belt villages and at times the towns of Eluru, Gudivada and Vijayawada. The elevated water will remain for a longer period, as it is to be drained by only one outlet, the Upputeru, that is now ill equipped to carry all the waters.




 In the light of the position explained above and the urgency & importance of the matter, MOEF, GOI and AP State Govt are  requested for early implementation of the recommendations of Dr. Azeez Committee, which were accepted in Toto by the Standing Committee of NBWL, without any further delay.


Friday, November 9, 2012

Can Avoid Power Cuts by Cutting Down Losses!

 Historical data of AP Power System

As per the "White Paper" dated 31.3.1999, prepared by A.P. TRANSCO, the total of 36380 MU units were available for sale in the system during 1997-98. The Energy Audit of AP Power System conducted month-wise, showed only 34799.50 MU as the total energy input from April 1997 to March 1998. Presumably the unaccounted difference of 1580.50 MU, which works out to be 4.34% of total units available for sale, is accounted as Transmission Losses ( 33KV & above) of the system.

The findings of the Energy Audit also showed 23254.82 MU, as the total actual sales during the year under the following categories.

     *HT Consumers    7703.79 MU (22.14%)       Metered

     *LT Consumers     7260.91 MU (20.86%)       Metered

     *Agl.  Consumers   8290.12 MU (23.82%)       Unmetered and estimated

The balance of 11544.68 MU, which works out to be 33.17% of energy input, was shown as energy lost in the system, over and above 4.34% transmission losses accounted for earlier. These losses in Distribution Network, may be classified into technical losses & commercial losses because of theft. The technical losses were estimated to be of the order of 6960 MU, working out to be 20% and the balance 4584.68 MU i.e. 13.17% is being treated as commercial losses. The total energy lost in the T&D system-13125.18 MU- is equivalent to the installed capacity of 1875 MW, assuming 7MU per MW at 80% Plant Utilization.

No Change even after more than a Decade

 As per the data available in APERC Tariff Order of July 2010, a total of 77, 828.26 MU is approved for purchase by 4 DISCOMS, permitting Transmission Losses of 4.86 % and Distribution Losses of 13.84%, accounting for total loss of 12,790.76 MU,equivalent to installed capacity of  about 1825 MW .

As the LT Sales constitute substantial part of the total sales of the DISCOMS, the verifiable data regarding LT Consumption is of very serious concern. The total metered and billed LT sales, is hovering around 40% of the total LT input since mid 90 s and according to APERC the total LT metered sales of CPDCL, even during 2009-10, are less than 50% of the total LT input.

 The unmetered LT consumption is being appropriated under agricultural consumption and the losses by a process of estimation, with the possible intention of keeping the losses low, at the risk of jacking up agricultural consumption.

Way Out

Even after a decade, there does not seem to be much of improvement in the performance of some of the DISCOMS in implementing SSM measures to bring down the losses, wastages, pilferage etc. in the power system. Some of the issues, which need to be given special attention to achieve definite time bound targets, are;

*Reduction of Transmission Losses, which are around more than 4%  since 1990 s   need to be brought down below 3% at the earliest.

*The 100% Metered LT Sales in sectors other than Agricultural Services, is to be  targeted with out any further delay, to practically eliminate commercial losses (10-15%) and for working out the exact technical losses with a view to  improve the LT network  and above all to create accountability on  the part of the field staff of the utilities, 

* Reduction of Distribution Losses, which hover around 15% need to be brought down  to below 10% in a given time frame.

* Agricultural Consumption figures continue to be controversial and arbitrary for over the  last 10 years which are being projected between 25% to 40%, with out any verifiable  data which can stand any scrutiny.

* Agriculture Consumption, even if it is to be given free, should be metered and accounted for, so as to bring in clarity regarding the amount to be subsidized by Govt. and accountability for Losses on the part of DICOMS   












Sunday, November 4, 2012

Kovvada NPP of NPCIL - Land Acquisition?

Trauma of Land Acquisition 

 The land acquisition process for public use/other purposes invariably causes distress in affected families, because of displacement &the loss of the primary sources of livelihood of fishermen & tribal communities in particular, having traditional rights on Natural Resources of Sea & Forests.

No amount of compensation can offer solace and relief from distress caused by the loss of their age old habitations and livelihoods. In the case of land acquisition for Nuclear Power Plants, the threat from likely nuclear radiation, which became the public knowledge after Fukushima Dai-ichi NPP disaster, persists among the people in the surrounding areas.

Land Acquisition Bill No.77 of 2011


  With a view to minimize the  disturbance & trauma  to the owners of the land and other affected families, the  Govt of India introduced the Land Acquisition, Rehabilitation and Resettlement Bill No.77 of 2011,  for ensuring  a Humane, Participatory, Informed Consultative & Transparent process for land acquisition for public purposes.

 As per the Bill, the Social Impact Assessment (SIA) Study of the families likely to be affected by the land acquisition is to be undertaken in consultation with Grama Sabhas at habitation level. The SIA Study report is to be published after having a Public Hearing in the affected areas. It stipulates the consent of at least 80% of affected families, before land acquisition is initiated. 

G.O.Ms.No 42 of 1 st November 2012 

But unfortunately AP Govt. ignored the basic principles of Land Acquisition, R&R Bill No.77 of 2011- Humane, Participatory, Informed Consultative & Transparent Process- and unilaterally declared and notified the "project-affected" villages based on R&R Policy of 2005 Accordingly G.O.Ms.No 42 dated 01-11-2012 was issued, authorizing District Collector, for acquisition of the land required for Kovvada NPP of NPCIL, in Ranasthalam Mandal of Srikakulam district.

Land Acquisition before Environmental Clearance (EC)?


 The Punjab and Haryana High Court, on Wednesday, 31 st October 2012, is reported to have not allowed the Punjab Government, the auction of a mining site without proper Environmental Clearance.


Therefore G.O.Ms.No 42 dated 01-11-2012 authorizing the District Collector to acquire the land required for Kovvada NPP of NPCIL, before the project is accorded Environmental Clearance by MOEF, is not only  irregular and objectionable and also amounts to be immoral and inhumane, making the entire process of Environmental Clearance, a ritual and a mockery.


People of Kovvada do not Count?


The five "project affected" villages & hamlets (Exclusive Zone) notified in the G.O, have 1983 house holds with population of 7,960 as per 2011 census. These people mostly depending on fishing for their livelihood will be uprooted and rehabilitated elsewhere.


Around 40 villages/hamlets are covered by the Sterilized Zone (1..5 Km to 5.0 Km) having about 6,000 households with population of 30,000. The private land in the zone is to the extent of 11,600 acres, predominantly with intensive agricultural activities.


These 6,000 households with the population of about 30,000, in the close vicinity of the proposed Nuclear Power Park, will be worse affected, as they are likely to be exposed to radioactive gases  routinely released by 6 Reactors, with a capacity 1000 MWe each, for the next 30 to 40 years of their operation. Their agricultural produce is likely to be contaminated by radiation and no new activity is permitted in this zone. 




In the light of the position explained above and taking into account the serious public opposition to the proposed NPP of NPCIL at Jaitapur in Maharashtra even after MOEF accorded Environmental Clearance,  the prolonged and stiff public opposition being faced by NPCIL NPP at Koodankulam in Tamilnadu, which is yet to be commissioned even after 20 years and having compassion for the fellow human beings of Kovvada, the proposed land acquisition should be kept in abeyance.


 The following need to be complied with, before Land Acquisition for Kovvada NPP can be initiated:


a)    Social Impact Assessment (SIA) Study of the families likely to be affected by the land acquisition, be undertaken in consultation with Grama Sabhas at habitation level and the consent of at least 80% of affected families be obtained, before land acquisition is initiated as stipulated in the Bill No.77 of 2011.

b)    NPCIL be asked to comply with preparation of Site Evaluation Report (SER), Safety Analysis Report (SER) and Emergency Preparedness Plan ( EPP), Environmental Impact Assessment (EIA) Report Environmental Public Hearing (EPH) etc. for the project site.

c)    Environmental Clearance by MOEF based on the findings of EPH and other environmental considerations such as Sustainability, Precautionary Principle etc.