letter representation public hearing 23 march, 2010

8/9/2019 Letter Representation Public Hearing 23 March, 2010

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To: The Public Hearing Committee

c/o District Environmental EngineerTamilnadu Pollution Control Board

Maraimalai Nagar, Kanchipuram District

Sir:

Subject: Rejection of proposal of Corporation of Chennai to process MSW in Pallikaranai

marshlands in violation of MSW Rules, 2000

I register my opposition to the proposal of the Corporation of Chennai to process 1400 tpd of MSW at asite within the Pallikaranai Marshlands in Perungudi area. My opposition stems from the following

concerns:

1. The Pallikaranai marshlands have shrunk from the 6000 hectare spread 30 years ago to less than

a tenth of the size. Encroachments, including residential areas, IT companies (including of

major software houses), Corporation of Chennai and MetroWater's sewage station havecontributed to this. The Pallikaranai marshlands serve at least three critical functions:

a) as habitat for 126 bird species, 141 plant species, 46 freshwater fish species, 15 species of marine

fish, 20 butterfly species and 8 mammals.b) as flood mitigator

c) as the largest freshwater reservoir and natural rainwater harvesting and groundwater recharging

system.

The proposal is to use this site for the above stated purpose for the next 25 years at least will ensure

that the already compromised ability of the marshlands to fulfil these functions is further threatened.

2. The proposal is discriminatory and unfair to the people living in the vicinity of the facility. It is

not acceptable to burden people with garbage brought in from other areas. Indeed, this principle

is enshrined in the Municipal Solid Waste Rules, 2000, which encourages source segregation bygenerator of the garbage, and decentralised treatment.

3. The proposal is illegal and runs counter to the Municipal Solid Waste Rules, 2000. I do realise

that illegality is merely a minor issue, especially considering that the Corporation of Chennaihas been dumping mixed waste illegally in the wetland for decades now, and very important,

and powerful people are party to the violations.

The proposal is illegal on at least three counts:

a) It encourages generators of garbage to deliver mixed waste. Rather than promote source segregation

(as per Para 1(2) and 1(3) of Schedule II) and decentralised treatment closer to source, the projectpromotes mixed waste processing. The Rules enjoin the local body to collect only source-segregated

waste and avoid the processing of mixed waste at waste facilities. Here, the Corporation of Chennai

proposes to process mixed waste for the next 25 years in Pallikaranai.b) The project is proposed to be located near a residential area and inside the Pallikaranai marshlands

which is a water body. According to Schedule III (Siting Guidelines)of the MSW Rules, 2000, the

landfill site shall be away from habitation clusters, forest areas, water bodies monuments, National


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Parks, Wetlands and places of important cultural, historical or religious interest.

c) The Committee of Experts appointed by the Madras High Court in the case Sri Sai Nagar Residents

Welfare Association v. State of Tamilnadu has recommended against the project stating: . . .the present

site is not suitable for dumping of municipal solid waste, as also not suitable for any other activity, andthat it needs remediation and that the siting of the dumpyard and the handling of waste is in violation of

the Municipal Solid Waste (Management and Handling) Rules 2000 framed under the Environment

Protection Act and the Ramsar Convention on Wetlands (1971)." The same committee headed by Ms.Sheela Rani Chunkath concluded that the current proposal of the Corporation of Chennai is

"environmentally unsound, is a cause for great concern to public health and cannot be legally sited

within the Pallikaranai marsh."

4. The proposal will discourage citizen initiatives to reduce waste and opt for decentralised

treatment of locally generated MSW. The Corporation is signing a contract with the

Concessionaire M/s Hydroair Tectonics guaranteeing them 1400 tpd of MSW at the facilitygate. Indian wastes have about 60 percent by weight of organic, biodegradable material. Any

attempts by residents to compost their own biodegradable wastes at apartment or

neighbourhood level will then result in a reduction of upto 60 percent by weight of wastesleaving the neighbourhood. This will mean the Corporation will not have sufficient wastes to

meet its contractual obligations. Under such a situation, the Corporation is unlikely to extend

any cooperation to citizen initiatives to reduce wastes or deal with it.

5. The Public Hearing is Illegal because the statutorily required documents that need to be made

available to the public are not available. Appendix IIIA of the EIA Notification, 2006, lays outthe format and contents of a Summary of the EIA document as recognised by the Notification.

Only summaries that meet the requirements laid out in this Appendix are permissible for

submission to regulatory authorities and as summaries for the reference of members of the

public while seeking their comments. The document provided as the Executive Summary is areproduction of the company's marketing brochure for the project. Sections such as

Environmental issues covered, Technology Relevance, Benefits to Corporation of Chennai and

RDF-Green Coal are directly lifted from the Company's website(www.hydroair.com/solid.html ). The following mandatorily required information as prescribed

in Appendix IIIA are missing: a) description of the environment; b) anticipated environmental

impacts and mitigation measures; c) environmental monitoring program; d) additional studies;e) project benefits; f) environment management plan. The absence of a proper summary renders

the Public Hearing illegal and meaningless, as the Public is being asked to comment on a

proposal whose details are not known.

6. The alleged Summary document does not provide any details about what waste specifically

will go into formation of Refuse Derived Fuels. Also, considering that mixed wastes contain

significant quantities of chlorinated plastics such as PVC, the project does not contemplate howPVC will be prevented from entering the stream destined for preparation of RDF. Under Indian

incineration guidelines, it is illegal to burn PVC containing wastes.

7. The RDF plant, during processing, and the RDF during combustion of the fuel will emit high

levels of toxic chemicals including dioxins, furans, PCBs and heavy metals such as mercury.

There is no assessment or mention of an assessment of these emissions. There is no mandatoryEnvironmental Management Plan for dealing with process emissions and emissions during

burning. It is not sufficient to point out that the RDF will be burnt elsewhere. Rather, an

assessment would have to be provided of the impacts at the point of burning, and its
http://www.hydroair.com/solid.htmlhttp://www.hydroair.com/solid.html


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management.

8. The project contemplates receiving mixed wastes at the facility. By the time wastes are

collected from all over the city and delivered at the factory, and by the time such wastes aresegregated, there would already be a lapse of more than two days. During this time, anerobic

digestion would be well under way, and leachate generation is inevitable. Further, such

degradation would also leach out toxic contaminants from the non-biodegradable material such as mercury from fluorescent lights, other heavy metals from paints and batteries, solvents

and pesticides from household pest-killers. These contaminants will now reside in the organic

matter destined for composting. It is criminal to contemplate selling this compost as soilconditioner or manure to unsuspecting farmers who may end up poisoning their consumers.

9. The project concessionaire lacks experience and has a bad track record. Hydroair Tectonics has

no track record in executing waste projects of this scale. Indeed, in 2008, the Goa Governmenthas issued a show-cause notice in regard to the now-defunct Rs. 65 lakh anerobic digester

installed by the company.

10. RDF and mixed waste composting are proven failures. In Vilappilshala, the Trivandrum

Municipality initiated mixed waste composting at a much smaller level than what is

contemplated here. This scheme is now an albatross around the neck of the Municipality, whichis left with tons of unusable compost, and a heavily contaminated site oozing leachates into a

river that supplies drinking water. The first WTE facility set up in Timarpur, New Delhi, in

1987 operated for less than 3 months in all, and was shut down because Indian wastes were toorich in organic content and moisture. A more fine-tuned RDF plant in Vizag now operates with

RDF but has to burn auxiliary fuel. In other words, the RDF itself is not of sufficient calorific

value to burn on its own. Rather it requires additional fuel to help it burn.

I urge the Public Hearing Committee to recommend against this project, and encourage the Corporation

of Chennai to take people into confidence to initiate segregation and decentralised waste treatment

schemes. The Corporation will find that Chennai's residents will support these schemes enthusiastically.

Sincerely,

Nityanand Jayaraman

Resident of Besant NagarS45, 35th Cross, Besant Nagar, Chennai 600 090

Dharmesh Shah

Resident of Kalakshetra ColonyM106/4, 29th Cross, Besant Nagar, Chennai 600 090

letter representation public hearing 23 march, 2010

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