7/29/2019 Cancel the Environmental Public Hearing for Mithi Virdi Nuclear Power Plant on 5th March 2013
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BY Email & FAX
Most Urgent Most Urgent Most Urgent
28th
February 2013
ET/eRc/MV-MoSMoEF/01
To
Thirumathi Jayanthi Natarajan
Minister of State for Environment and Forests
Paryavaran Bhavan, CGO Complex, Lodhi Road,
New Delhi 110 003
Subject: Demand for Cancelling the Environmental Public Hearing due to be held by Gujarat PCB on 5th
March
2013 for non-compliance of key aspects of the TOR issued vide EAC meeting held on 14th
February 2011 for the
Mithi Virdi Nuclear Power Plant prepared by Engineers India Limited
Dear Madame,
In direct contrast to the policies of your government and the
TOR specified by your Ministry, the Gujarat State Pollution
Control Board has announced and is preparing for the Public
Hearing to be held on 5th
March 2013.
1. The location of the site with 78% of double cropped landfor the plant not only indicates the lack of sensitivity in the
choice of area for acquisition but also that the State and
the NPCIL are putting more people to risk, as settlements
would be also too close for nuclear plant and the need for
some exclusion zone need not be over-emphasised after
the recent accidents and increased concern on nuclear
disasters.
Madame, your Government has repeatedly emphasised the
need to identify non-agricultural lands for industrial development and this excercise is more like a fait-accompli.
2. The report does not talk about the impacts of taking away such a huge proportion of prime agricultural land,but on the contrary presents a denigrating attitude towards the farming activities and the farming
communities. Here we quote from the EIA Report which talks about impact on Land
The impact on land environment during construction phase shall be due to generation of debris/ construction
material, which shall be properly collected and disposed off. There will be no accumulation of drainage on the
higher elevation side as the site will be graded. A garland drain network is developed to collect and route the drain
water towards sea. No impact is envisaged due to the same.
The total land requirement for the
project is 877 ha, which includes
777 ha for the project and 100 ha
for township. The project land
also includes 21 ha of forestland.
The project area includes the
requisite exclusion zone for the six
nuclear reactors. Out of this land,
603 ha falls under double crop
agriculture category.
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All wastes generated are segregated as solid and hazardous wastes and collected together for disposal. All such
wastes will be transported to authorized disposal agency. Accordingly, there shall be no additional load on land
environment during operation phase of the project.
For establishing soil characteristics within the study area, soil samples from 10 locations were collected and
analysed for relevant parameters. The soil of the proposed site is silty loam type. At present, most of the land is
under cultivated and sparse scrub vegetation also exists in the study area. However, with the introduction of the
project, the land use pattern of the area will improve with neat and clean project buildings, lawns and gardens.
(emphasis added) The area in the exclusion zone around the project will be developed into a green belt as per the
requirements of AERB and Gujarat Pollution Control Board (GPCB). This will further improve the aesthetic and land
use environment at the proposed project site.
3. Madame, we are not going into the gross inadequacies of the entire EIA report and such flimsy statementsthat are being made in the name of scientific and technical studies and defended by none other than NPCIL.
Madame, if there were specific issues we would have offered it as our submission during the Public Hearing,
but to conduct a Public Hearing without even adhering to the minimum TOR fixed by the Government is a
mockery of the process and hence we seek your intervention to cancel this public hearing and issue strictures
to the GSPCB for its lack of oversight. The reality is the EIA has not even identified who will be impacted and
what will be impacted and to what extent and is a generic document will some data which has neither any use
to local understanding or implications.
One of the issues clearly pointed out in the TOR and is fundamental to any dialogue with Public is to know the
Project Affected People and the Resettlement and Rehabilitation Plan. The point number (xiv) in the TOR sates
Application of resettlement and rehabilitation policy may be described. Project affected persons should be
identified and rehabilitation and resettlement plan should be prepared. The section on R&R in the EIA report is
totally hypothetical and does not even say how many households would be affected.
The following reproduction from the EIA will make it very obvious to you why this is a fraud being played on the
public in the name of public hearing.
Preparation of a detailed Rehabilitation and Resettlement (R & R) plan is taken up for compensation to the Project
Affected People (PAP) in line with the National Rehabilitation & Resettlement Policy2007 and in consultation with
Gujarat State Government for the project affected people.
Discussions are being held with District Collector / Commissioner of the concerned area for compensation for land &
landed properties.
The NPCIL policy envisages a special focus on the creation and up-gradation of skill sets of landless persons and
other project affected persons (PAPs), who are dependent upon agricultural operations over the acquired land, and
for the rural artisans e.g. blacksmiths, carpenters, potters, masons etc., who contribute to the society together, to
improve their employability. With the help of District Administration, the essential inputs containing lists of land
losers and project affected persons are being prepared. NPCIL is committed to establish requisite system for
organizing vocational and formal training and education for all such identified persons and extend full assistance to
them to become eligible for seeking employment with the project proponent or any other organized sector. NPCIL is
committed to implement the R & R package as per the mutual agreement with the State Government.
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Given the fact that these have yet to be accomplished why is the NPCIL and GPCB in such a hurry to conduct the
Public Hearing without providing the necessary basic information for a meaningful public hearing.
We sincerely hope that you will be seized of this, as you have done in issues of environmental importance and
natural justice and order the cancellation of this public hearing and instruct the proponent to furnish atleast thebasic information relevant to the people.
Added to this is the fact that your Ministry has not accorded the required accreditation to this agency for conduct
of EIAs for Nuclear Plants as is clear from the following reproduction
4. Finally, Madame it would be pertinent to point out that the Hon High Court of Himachal Pradesh in CWP No.586 of 2010 Along with CWPIL No. 15 of 2009 pronounced certain guidelines which are as follows and are
being continually violated:
109. We also are of the view that certain guidelines need to be issued to ensure that such events do not re-occur in
future and accordingly issue the following guidelines:
a) The H.P. State Pollution Control Board shall ensure that consent to establish is not granted just for the asking.
Even at the time when consent to establish is granted the H.P. State Pollution Control Board, MoEF/EAC shall verify
the facts stated in the project report and they shall also indicate to the project proponent what are the para-meters
and the laws which the project proponent will have to comply with keeping in view the nature of the project.
b) The statement made by the project proponent shall not be accepted without verification. It shall also be madeclear that if any statement made by the project proponent is found to be false the permissions granted shall
automatically stand cancelled.
c) The Pollution Control Board shall ensure that whenever any public hearing is held, the people of the area are well
informed about the public hearing and they are also informed about the benefits and the illeffects of the project.
The Pollution Control Board must have its own machinery and own scientists who should give an independent
opinion on the pros and cons of the project. These shall also be placed on the website of the PCB.
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d) In future whenever any studies are being carried out by any project proponent while preparing the EIA
reports, the study shall be carried out only after notice to the State Pollution Control Board, MoEF/EAC in case
the project requires clearance at the central level and also to the inhabitants of the area where such studies are
to be carried out and project has to be established. Notice to the public shall be given in the same manner notice
of public hearing is given. (emphasis added)
The NPCIL and GPCB must go back to the drawing board and conduct authentic studies through accredited
agencies, inform people and then become eligible to conduct the public hearing, until which time no permission
should be granted to them including the 21 ha of forest land being sought by the agency.
With very warm regards and Expecting Immediate Action,
R.SreedharManaging Trustee
Cc:
The Secretary
Ministry of Environment & Forests, Government of
India
Paryavaran Bhavan, CGO Complex, Lodhi Road,
New Delhi - 110 003.
The Chairman
Central Pollution Control Board
Parivesh Bhawan, CBD-cum-Office Complex, EastArjun Nagar, DELHI - 110 032
The Member Secretary
Central Pollution Control Board
Parivesh Bhawan, CBD-cum-Office Complex, East
Arjun Nagar, DELHI - 110 032
The Zonal Officer
Central Pollution Control Board
Parivesh Bhawan, Opp. VMC Ward Office No. 10,
Subhanpura,
Vadodara - 390 023
The Chairman
Gujarat Pollution Control Board
Paryavaran Bhavan Sector 10-A,
Gandhinagar - 382 010
The Member Secretary
Gujarat Pollution Control Board
Paryavaran Bhavan Sector 10-A,
Gandhinagar - 382 010
The Regional Officer
Gujarat Pollution Control Board
Plot No. 1154/2, B, Ghogha Circle,
Pattani Road, Bhavnagar - 364 002
The Chairman / The Collector
Environment Public Hearing Committee of
Bhavnagar
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