On the 15th December 2018, the State Pollution Control Board in Karnataka will organise a public hearing on the EIA report for the proposed expansion of the Kaiga Atomic Power Station by adding 2 more units of 700 megawatt each. Kaiga is situated in ecologically fragile region of southern India, and the nuclear power plant has impacted people’s safety, environment and livelihoods negatively since its operation.  

We are reproducing a letter sent to the Ministry of Environment, Forest and Climate Change, Govt of India, as well as the Prime Minister’s Office (PMO) by independent power policy analyst Mr. Shankar Sharma which raises crucial questions that must be answered before such a nuclear expansion can be allowed in a democracy . 

Environmental public hearings, particularly for nuclear power projects, have been invariably turned into cruel jokes if we go by experiences in the recent years in Gorakhpur, Chutka, Jaitapur, Mithi Virdi and other projects – consent for shoddily prepared EIA reports is obtained under police duress.

[Kumar Sundaram, Editor, DiaNuke.org]

To

The Secretary,
Ministry of Environment, Forest and Climate Change,
Indira Paryavaran Bhawan, Jor bagh Road, Ali Ganj,
New Delhi-110003

Cc to:
(1) Dr. Harshavardhan
Minister for Environment, Forest and Climate Change
Govt. of India, New Delhi

(2) Dr. Jitendra Singh
Minister of State for PMO
Govt. of India, New Delhi

Dear Mr. Secretary,

Greetings from Sagar, Western Ghats, Karnataka.

The Website of the Karnataka State Pollution Control Board (KSPCB) has listed a public hearing for 15.12.2018 for NPCIL as: M/s.Nuclear Power Corporation of India Limited(NPCIL), Kaiga, karwar Taluk, Uttar Kannada District, Karnataka.

Whereas it is deplorable that KSPCB, as the agency entrusted with the task of conducting the public hearing as per EIA rule 2006, has not displayed the the required level of responsibility in this website by not even identifying the project proposal, and it has also not provided any further details of the proposed project, its is learnt from other sources that the same public hearing is for the capacity expansion (adding Units 5 and 6) at Kaiga nuclear power project, Karnataka.

KSPCB and other pollution control Boards may please be asked to post all the relevant information such as the relevant date & time, venue, EIA report and the DPR on their website with adequate advance notice.

I have gone through the summary of EIA for the proposal by NPCIL for the capacity expansion (adding Units 5 and 6) at Kaiga nuclear power project, Karnataka. Whereas multiple deficiencies in the EIA report are glaring from different perspectives, few things stand out, and can be treated as adequate grounds not to conduct the proposed public hearing at all.

1. The communication dated 6th Sept. 2016 by MoEF & CC, informing NPCIL on Terms of Reference for the project proposal, has clearly stated that the area within 10 kM is predominantly forest land with dense growth of tall and stout trees, and that the forest is categorised as reserve forest. Additionally, the section 3.6 of the executive summary of EIA states :”The project site is located in the interior part of Western Ghat of peninsular India. Kali (Dandeli-Anshi) Tiger Reserve (KTR/DATR) extends from NE to NW. The minimum distance observed varies between 718 m to 1,734 m from Kaiga site Exclusion zone boundary.” Since a Tiger Reserve area must have 15 kM of buffer zone, the proposed project area is clearly within the buffer zone of Kali (Dandeli-Anshi) Tiger Reserve. In this context, it is shocking that about 54 Hectares of thick forest lands of very high ecological value from the Climate Change perspective and in the buffer zone of a Tiger reserve is being proposed to be diverted to the project; against all known wisdom of environmental upkeep and clearly against the critical need of the hour to preserve and enhance the tropical forests, as per IPCC (even though this much of forest land is said to be already under the possession of NPCIL). Since the ownership of the forest land is not of any relevance as long as it is allowed to continue to provide the associated ecological services, the diversion of this forest land and also few sq. kM of the adjoining thick forest lands required to construct the additional transmission lines will be completely against the interest of not only our communities, but also against India’s global obligations w.r.t Climate Change. Hence, the environmental clearance for this project cannot even be considered.
2. The Gazette notification no. 3956 of 3rd October, 2018 ( as applicable to MoEF&CC) proposing to implement the recommendations of the High Level Working Group (also generally referred to as Kasturi Rangan Committee) has notified the identified area of 56,825 square kilometre which is spread across six states, namely, Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamil Nadu, as the Western Ghats Ecologically Sensitive Area. As per Annexure C, (Page 161) of this Gazette notification, the villages of Kaiga, Mallapur and Virje, which are identified as the proposed project areas in the EIA, are declared as ecologically sensitive areas to be completely protected. Hence, the question of environmental clearance for this project cannot be entertained at all.
3. At a time when the forest & tree cover in the country and in Karnataka is only about 20% as against the national forest policy target of 33% of the total land area, and against the target of 66% of the land area in hilly districts, the proposal to divert more than 54 Hectares of thick forest land in the hilly district of Uttara Kannada (Karwar) district may be termed as against the letter and spirit of our Constitution and of the relevant Acts of Parliament on environment and forests. It will also be in negation of India’s commitment to the global community to being a leader in addressing the Climate Change, wherein the conservation and enhancement of tropical forests is clearly acknowledged as one of the most effective solutions by IPCC.
4. The National Forest Policy of 1988 and the draft National Forest Policy of 2018 have unequivocally advocated the relevant need as: “In the hills and mountainous regions, the aim will be to maintain two-third of the area under forest & tree cover in order to prevent soil erosion and land degradation and also to ensure the stability of the fragile eco-systems.”. The district of Uttara Kannada in Karnataka, where the project site is located, is a hilly district withing the core area of the Western Ghats, which the MoEF&CC proposes to protect and conserve. The forest and tree cover area is already less than 50% in this district. Hence diversion of more than 54 Hectares of thick forest lands in this district for the proposed project will negate the very objective of MoEF&CC.
5. Additional Transmission line works and the associated environmental impacts have not been mentioned in the EIA; probably because the project proponent seem to believe that MoEF&CC can be subsequently lobbied to view it as ‘inevitable’ after the works for the power plant begin and lot of money is spent. Such a scenario has occurred few times in the past. This is a major concern as a large number of tall & stout trees are likely to be cut for the transmission lines. How many additional transmission lines, at what voltage, and for what lengths will be needed/planned? How much of the forest area to build such lines will have to be diverted? How many tress need to be cut? It is deplorable that without planning the evacuation paths for the generated power the environmental clearance for the project is being sought. Knowing well that the increase in the overall generating capacity will be about 250%, there will be clear need for additional transmission lines. Without considering all such aspects of the environment the entire project EIA is incomplete and hence the application for EC should be summarily rejected.
6. The MoEF&CC, in its previous avatar, had dealt a policy blow to the people of this region and of the country by allowing such a high impact project in the thick forests of Western Ghats. It must not aggravate the same blunder by allowing an expansion which will be more than the double the size of the original capacity at enormous costs to the region and to the global ecology.

These issues alone must be sufficient reasons to summarily reject the the project proposal in its entirety and the particular. Hence I strongly urge MoEF&CC to cancel the proposed public hearing.

However, there are more concerns on economic, technical and logistical front.

1. The addition of two nuclear reactors of 700 MWe capacity each to the existing capacity of 4×235 MWe, shall mean that the total reactor power capacity at the site will go up by about 250% with the corresponding increase in normal radiation levels, The catastrophic failure risk also will go up by similar margin, if not more. Our communities deserve much better considerations on their welfare aspects than being subjected to such avoidable risks for the sake almost negligible benefits.
2. The estimated cost (as per EIA) of Rs. 21,000 crores (excluding the transmission line (TL) costs) for the 1,400 MW of additionally proposed capacity shall mean the capital cost of Rs. 15 Crores per MW (excluding the TL costs and unimaginably high ecological costs), which is also the highest per MW cost among all the known technologies ( as compared to about Rs. 8 Crore per MW of fossil fuels and about Rs. 10 per Crore MW of dam based hydel plants). Having conveniently and intentionally ignored to compare this risky nuclear technology with other known, established and low cost technologies (as a study of alternatives required under EIA rules), the EIA has not bothered to establish as to why our society should be even be considered to be burdened with this risky project.
3. Without an effective risk analysis and disaster management plan (as should be applicable to the scenario such as the disasters at Chernobyl and Fukushima) the project proponent, through this EIA, has failed to assure the local communities of the safety of their lives.
4. “54.09 hectare forest land along with the land in possession of NPCIL will be utilized for setting Kaiga 5&6.” (section 2.1). Can we afford to lose this much of tropical rain forest of very high ecological value to the nation’s and planet’s environment for inconsequential additional power?
5. In view of the insignificant/irrelevant contribution of nuclear power to Indian scenario (the installed nuclear capacity is less than 2% of the total power capacity in the country as on today, and the same will be most likely to be less than 0.5% by 2026, which is completion target for this project as per EIA), the local community, the state of Karnataka and the entire country should not be burdened with the unacceptable costs and risks associated with the financial, social and environmental/ecological aspects of building, operating, decommissioning and safe disposal of nuclear wastes.
6. There are many benign and more attractive options available to our country to meet the legitimate demand for electricity of our communities. The project proponent, through this EIA, has not even bothered to consider various other options to meet the growing energy demand.
7. There have been a plethora of technical and economic reports from around the world indicating how the nuclear power technology is the economically the costliest and ecologically the worst technology, as highlighted by the disasters at Chernobyl and Fukushima.

In view of these and many other concerns, I am of the considered opinion that the proposed public hearing should be cancelled altogether. Also, since the project is prima- facie non-viable, DAE should not go ahead with the expansion of the Kaiga NPP.

Regards

Shankar Sharma
Power Policy Analyst, based in Sagara, Karnataka