To
Dr. Sumita Mishra
Chairperson
Haryana State Pollution Control Board (HSPCB)
Panchkula
Date: 31 August, 2021
Subject: Request for Cancellation of Public Hearing on 31 st August 2021 for Waste to Energy Plant Expansion in the NCR Aravallis
Madam,
With due respect this is with reference to the Public Hearing regarding the expansion of the Waste to Energy plant at Bandhwari landfill site in Aravallis from 15 MW to 25 MW on 31 August, 2021.
The public hearing notice issued by the Haryana State Pollution Control board clearly states that the EIA study for the same will be available on the HSPCB website (hspcb.gov.in) and the offices of the Deputy Commissioner of Gurugram, Municipal Corporation Gurugram, Zila Parishad Gurugram and Regional office of the Haryana State Pollution Control Board in Vikash Sadan, Gurugram - along with the Executive Summary.
The public hearing notice issued by the Haryana State Pollution Control board clearly states that the EIA study for the same will be available on the HSPCB website (hspcb.gov.in) and the offices of the Deputy Commissioner of Gurugram, Municipal Corporation Gurugram, Zila Parishad Gurugram and Regional office of the Haryana State Pollution Control Board in Vikash Sadan, Gurugram - along with the Executive Summary.
When I wrote to Regional Officer, HSPCB in this regard, I did not get any reply. When I called him, I got no response. I have also learnt that when Aravalli Bachao team members spoke to the office of the Deputy Commissioner on the 27 th August 2021 to check if these documents are available with them, they said they do not have these documents in their office when according to the Public Notice these documents should be available in the DC Gurugram’s office for the public to view.
According to Appendix 4 of the EIA Notification 2006, a copy of the EIA report needs to be made available to the public 30 days prior to the date of the Public Hearing so that sufficient time is given to citizens to study the document and give their views.
The EIA Notification also states that the Executive Summary of the EIA report needs to be translated in local language and be made available to the public 30 days prior to the date of the Public Hearing. Both these criteria have not been met for the Public Hearing called on 31 st August 2021 for expansion of the waste to energy plant. The required documents were not available on the HSPCB website as late as 26 August, 2021.
In Covid pandemic times when people are avoiding going to public places, accessing and studying documents online is the safest and most convenient way for citizens to give their suggestions / objections to the said project.
In blatant violation of the law, HSPCB has failed to give this option to the public. I have learnt that after my letter to the Regional Officef, HSPCB and the Aravalli Bachao team’s visit to the Regional office of HSPCB at Vikash Sadan in Gurugram on 26 August 2021 and after submitting a letter demanding cancellation of the Public Hearing, the next day i.e 27 August 2021 (4 days prior to the date of the Public Hearing scheduled on 31 August 2021), the required documents were uploaded on the HSPCB website. On 30 August, 2021, I submitted to you my preliminary critique of the EIA/EMP. (http://www.toxicswatch.org/2021/08/critique-of-draft-eiaemp-report-of.html?m=1)
It is crystal clear that instead of the mandatory 30 days period required by law, the HSPCB has given the public only 4 days to go through the hundreds of pages of the EIA report. HSPCB expects citizens to go through the EIA report in just 4 days, analyse its implications and give suggestions / objections on the Public Hearing scheduled on 31st of August 2021. This is quite irrational. It is due to these reasons, that I endorse the citizens' demand for cancellation of this Public Hearing which is in violation of the EIA Notification 2006.
Having worked on the issue of waste management since 2000, I have reached the conclusion that waste incineration technologies like Refuse Derived Fuel technique is anti-environment, anti-science and anti-public health. It is Dioxins emitting technology. Dioxins was used as a chemical weapon in US-Vietnam war under the brand name Agent Orange. I wish to draw your attention towards the following papers for your perusal and consideration:
1. Why urban waste continues follows the path of least resistance
2. In india, critics assail proposal to build 100 waste-fuelled power plants
3. Biomass Burning is not Green-Part I
4. Biomass Burning is not Green-Green-Part II
5. Clean India Mission on wrong track
In view of the above, I seek your considered intervention to stop the project proponent from setting up this tried, tested and failed Refuse Derived Fuel (RDF) technology based thermal plant which is linear, contrary to nature's circular process and is in violation of UN's Stockholm Convention on Persistent Organic Pollutants, UN's Minamata Convention, Paris Agreement and cardinal principles of waste management that paves way for adoption of Zero Waste philosophy.
Thanking you
Warm Regards
Gopal Krishna, LL.M., Ph.D
ToxicWatch Alliance (TWA)
E-mail: krishnaruhani@gmail.com
Mb:9818089660
Web: www.toxicswatch.org
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