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The reports that sealed the deal The various ecology studies done for the project, and what went wrong and right with them

The reports that sealed the deal The various by admin

When the fishing community of Sakhri Nate joined, concerns about the project expanded from land ecology to include marine as well. The study of marine life, habitat, organisms, and their interaction with the environment was deemed crucial to see what impact the project would have on fishing.

The EIA includes a report on marine ecology, which the National Environmental Engineering Research Institute (NEERI) commissioned the College of Fisheries (CoF), Ratnagiri, to prepare. The report concludes that the nuclear power plant and hot water discharge from it will not adversely affect the native flora and fauna.

The report—which makes sweeping statements like “hence will not adversely affect the native flora and fauna”—seems confused in its basic idea. It is unclear whether it is a baseline survey or an impact assessment, or both.

The title and preface say that it is a “Baseline Marine Ecological Assessment”, which justifies the clear lack of studies conducted to assess impact. However, the EIA uses the terms “biodiversity mapping” and “impact assessment” interchangeably while referring to this report. The EIA also mentions that “Baseline Status of Aquatic Life and Impact Assessment” was done. It clearly mentions that “Specific Biodiversity Mapping of Marine Environment” was conducted by CoF, Ratnagiri. However, it is unclear whether the same institution or NEERI or another agency assessed impact, or whether impact assessment was done at all.

To clarify the purpose of the study, we met the dean of CoF, Dr V. P. Joshi. “We have never conducted any study for NEERI or NPCIL,” he said. When showed the report of 2007-08 study, he said, “What more information do you need when you have the report?”

The conclusions in the report seem definite and strong for a study that was conducted in less than three months between December 2007 and February 2008. It is a 21-page report on an issue that can easily be considered crucial for the 1,000-page EIA.

Terrestrial ecology, the study of plant-soil-atmosphere interactions, was studied over an entire year (January to December 2007). In the preface, the project coordinator and the then dean of CoF, Dr S. R. Kovale, admitted to “…limited observation could only be used by considering the time available and facilities in our institute”.

A change of seasons

The study period did not include summer which, according to the same report, witnesses maximum impact due to discharge of condenser cooling water. The report reads: “The effect of season in the zone under question plays important role too. The cooling requirement of the power plants is maximum in peak summer period. Therefore this is the most critical time at which maximum impact is anticipated.”

The study has only assessed impact and temperature tolerance through work done by past surveys. The conclusions that follow the past studies, which differ greatly in their own conclusions, do not seem to have been derived logically. NEERI has carried out additional literature survey and also refers to a laboratory study done in 1993 and a DAE-BNHS 2004 report.

There are some inconsistencies in the statements that the CoF Report makes on its own.

In one part, the report says: “The tropical organisms are more susceptible than their temperate counterparts, as they already live in the temperature closer to their maximum tolerance limit.” However, the overall conclusion is that there will be no impact on native flora and fauna with an increase of 5°Celsius.

The report admits that “the maximum sea water temperature in a limited area due to discharges of condenser cooling water will be 33°C in winter and 34°C in summer”, and also, “in case of macro algae and sea grasses sustained temperature above 33°C can cause extensive mortalities”. The “no adverse impact” conclusion does not seem in line again.

The report also admits “(t)he magnitude of temperature rise of the receiving water body (sea in this case) depends upon the mixing pattern and season”.

Does this indicate that a site-specific study needs to be done over a long period to conclude any impact with certainty? The answer was “a big yes” when we spoke to Dr Baban Ingole, chief scientist, biological oceanography, at Goa’s National Institute of Oceanography (NIO), a CSIR constituent laboratory.

“Summer is a very important season; this is the time of the year when marine life flourishes. Monsoon is equally important; it is a disturbing season. Many species naturally disappear and many others dwindle hugely in their numbers in monsoon. A comprehensive marine ecological study needs to be conducted before setting up a project, which could affect marine life,” he says.

Ingole swears by bioassay tests, which use biological organisms to test for toxicity, in case of possible change in temperature. “This is the only credible way of finding out possible impact of change in temperature on marine life and ecosystem. It is even more important that impact of rise in temperature is studied at the site or in similar tropical waters. Studies done in cold countries cannot be referred to as the thermal tolerance level in cold conditions could be much higher.”

The EIA has not followed either of these norms.

Fundamental flaws

An EIA for a nuclear power plant in a coastal site, particularly in Konkan, must look into certain key aspects of marine ecology. A marine biologist at one of the CSIR constituent laboratories said: “Three issues are very important: studying the possible impact of dredging; impact of effluents including thermal discharge on marine ecology; and preparing a mitigation plan in case of a radioactive leak.” He says no matter how small the possibility of a leak, a plan is essential.

According to the marine biologist, the construction of a jetty and channels to let out hot water into the sea and cold water into the power plant requires a huge amount of dredging, which has been known to severely impact marine ecology. Dredging happens not just once to construct the pipelines, but regularly as part of maintenance. He says, “With every dredging cycle, a part of biomass might be destroyed. In case they construct a jetty, the impact will be even higher.”

The NPCIL has a plan to construct a roll-on/roll-off (RoRo) jetty but the marine ecology report does not mention it. The EIA declares that construction activity on the site, as well as construction and operation of the jetty, “will not have any adverse impact on the environment”.

The only effluent discharge—intentionally or by accident—into the sea that has been looked into the marine ecology report and in the EIA is hot water. About 5,200 crore litres of seawater every day (600 cubic metre/sec) will be drawn to cool the condenser and then be let out into the sea at JNPP (all six plants). The temperature of water will rise substantially after cooling the condenser. This water will be channeled through long pipes till its temperature comes down before being discharged into the sea at a rate of 100 cubic metre/sec.

The temperature of this water, where it is let out into the sea, will still be higher than the sea temperature and thus be potentially hazardous to marine life. For nuclear plants in India, the limit of this temperature difference has been 7°C. However, for Jaitapur, the Ministry of Environment and Forests (MoEF) set the limit at 5°C.

”Even a 0.5°C of continuous thermal stress will lead to mortality of marine species. And here we are talking about a 5°C shift,” The Times of India quoted Dr Deepak Apte, marine biologist and deputy director of Bombay Natural History Society (BNHS), as saying on November 29, 2010, three days after the MoEF clearance for JNPP. “The true impact of the project of this scale will never be known unless one decides to do a comprehensive biodiversity assessment. The thermal discharge of this scale is bound to cause an ecosystem shift in a large area.”

Apte wrote “A Preliminary Report: Diversity of Coastal Marine Ecosystem of Maharashtra in November 2010”, part one of which had chosen 10 coastal sites—including Madban, the site of JNPP—which were identified as important biodiversity hotspots based on a year’s work in Ratnagiri and Rajapur. The primary objective was to “evaluate coastal habitats of Maharashtra and prioritization of sites for conservation as biodiversity hotspots”.

The area is described as one of Maharashtra's most serene coastal areas.

Sriram Vittalamurthy

The report was in response to certain developments. “The Konkan coast of Maharashtra, India, has been the stage for another conservation battle and this time for opposing a slew of coal-fired power projects, nuclear power plant and mines … These developments will ravage one of Maharashtra’s most serene coastal areas and Western Ghat areas which are home to rich biodiversity including several globally endangered species as well as world famous Alphonso mango,” the abstract of the report reads.

Apte declined to speak to Fountain Ink. He said, “BNHS is doing biodiversity conservation plan (for JNPP) as directed, thus won’t be able to comment on (this) matter.”

The NPCIL entrusted BNHS to prepare a biodiversity conservation plan for JNPP in 2011, based on a 2010 direction (as part of conditional environmental clearance) by the MoEF. An expert appraisal committee of the MoEF recently recommended the plan for approval by the ministry.

Meanwhile, Apte and team published another report in October 2012, titled “Preliminary Report on Diversity of Coastal Ecosystems of Maharashtra”. Part 1 of the report identified ecologically sensitive coastal areas of Ratnagiri, Rajapur and Vijaydurga along with a list of specific threats to each of these sites. This report lists JNPP as a threat to 16 ecologically sensitive coastal sites.

Interestingly, NEERI did not consider its sister concern, NIO in Goa (NEERI and NIO are both CSIR constituent laboratories), to study marine ecology around the Jaitapur site, even though NIO is an institute of national repute, is less than 200 kilometres away from the site, has done several detailed studies in the area and on the entire west coast, and was also a favourite of the NPCIL, at least in the past, to conduct studies at nuclear power plants.

NPCIL has previously entrusted NIO to conduct studies related to Kalpakkam, Tarapur and Kudankulam nuclear power stations. It was NIO that conducted one of the few studies available on marine ecology on the Jaitapur site, way back in 1990. This report, titled “Ecobiological characterisation of the environs of the Nuclear Power Station site at Jaitapur and Bioassay Tests for Tolerance and Lethal Limits of Thermal Effluents on Biota and Environment”, has not made it to the reference list in the Marine Ecology Report prepared by the College of Fisheries, despite the fact that it was the NPCIL that had commissioned the NIO study.

Even Dr Kovale, then dean of CoF, Ratnagiri, who admitted to “limited observation” due to restriction of resources and time, could not make CoF or NEERI refer to the NIO report.

Some of the conclusions of NIO’s 1990 study were: “Small change in water temperature shall affect the primary production and in turn the food chain. Fish catch data shows that the environs of Jaitapur harbour are rich fishing grounds. Bioassay studies clearly indicated that slight change in ambient temperature upsets the behaviour and physiology of the biota and thus the heated effluents from the proposed nuclear power plant can prove lethal to marine living resources.”

The omission of this report is striking, as Apte’s report acknowledges that these “areas are very poorly studied so far in terms of diversity and other ecological aspects” and there is a “strong need of more robust data regarding species diversity and distribution, generated through systematic evaluation of these habitats to underscore the importance of this area”.

That same year, NPCIL sponsored another study: “Biofouling and corrosion studies at Jaitapur site”. The work—which was aimed at collection of baseline data on the extent and nature of fouling and corrosion of different metals and alloys at the proposed site—was “approved initially for three years. However, the data collection had to be stopped after one year at the request of NPCIL. A report was prepared with the available data and submitted to NPC. Recommendations on the antifouling and anticorrosive methods could not be given due to abrupt ending of the project,” reads the NIO director’s report for the year 1990-91.

We were not able to ascertain why the NPCIL discontinued the study or why the completed study with definite conclusions was not referred to in preparing the EIA.

Madhav Gadgil, an ecologist who chaired MoEF’s Western Ghats Expert Ecology Panel, says, “The estuarine region of Jaitapur and Aghanashini estuary in the Uttara Kannada district of Karnataka are biogeographical regions. There is a very high level of similarity between the two. Extensive work in Aghanashini by the Centre for Ecological Sciences, Indian Institute of Science, has established estuarine areas are very rich in biodiversity. These areas are very important not just for scientific or conservation point of view but also form an important basis of livelihood for very large population.”

The area around the JNPP site is rich in mangrove vegetation. The terrestrial study in the EIA highlights: “These ecosystems are rich with 12 mangroves and mangrove associates … The mangrove forests are located along the edges of the creeks in the study area. Their value as habitat of wildlife is immense and they support a variety of wildlife”.

Dr V. Krishnakumar of the NIO is clear in his conclusion in his report, “An overview of thermal pollution with special reference to India coastal waters”. He writes, “Power plants may not be located in estuarine areas as these areas are breeding and nursery grounds for many aquatic species”. The report also emphasises the need for “adequate and proper coastal oceanographic investigations for siting a power plant.”

Konkan Bachao Samiti, fishermen, and locals have registered a strong protest against the EIA’s conclusions on the possible impact of JNPP on marine ecology.

Is that the reason the NPCIL has commissioned Central Institute of Fisheries Education, Mumbai to conduct some fresh studies, for which College of Fisheries, Ratnagiri is only assigned the job of collecting samples?

The problem of Jaitapur’s EIA

In the absence of a detailed project report or techno-economic report, the only detailed document specific to JNPP that is available in the public domain is the EIA. It has been severely criticised by analysts and activists alike on several counts.
The EIA ignores many important issues and is inconsistent on others. But the sweeping statements that it makes in favour of nuclear energy in general and JNPP in particular are not backed up in the details.

    • The report does not mention “sterilised area”: a zone of five-kilometre radius from the plant’s centre where population density should be small.
    • It ignores the topic of reprocessing spent fuel, a very important environmental and safety issue. In a meeting with Madban’s Janhit and Konkan Bachao Samiti (KBS) on July 9, 2010, NPCIL said spent fuel would be re-processed at a different location which would involve transportation, something not brought up in the EIA, says Adwait Pednekar of KBS.
    • The EIA states radioactive solid waste will be stored ”underground”, which the EIA asserts will have no impact on the environment. This is contrary to the information NPCIL shared with KBS on August 4, 2010, when it said storage would be “above the ground”. NPCIL claimed this was a new development while EIA was based on a generic practice. The impact of the new development has not been assessed either.
    • An independent assessment of radiological impact is difficult as this expertise is confined to the Bhabha Atomic Research Centre and the Department of Atomic Energy, both government agencies. DAE is also the parent organisation of NPCIL. Its lack of expertise has not deterred NEERI from mentioning in many places that radiological releases will be well within “stipulated” limits and “not have any adverse impact”.

Janhit and KBS objected to the shortcomings of the draft EIA since the public hearing did not address issues people raised. Jairam Ramesh then chaired a joint meeting of NPCIL, Neeri, KBS, Janhit on July 13, 2010 to address this issue.

The MoEF had earlier promised Janhit and KBS complete transparency in the data, information sharing, and the review process, as well as public representation in the upcoming expert appraisal of the draft EIA. After three meetings with the NPCIL and AEC chairman and two written responses from NPCIL, the answers were still vague and evasive.

In the case of Mithi Virdi, another proposed nuclear power project in Gujarat, an expert appraisal committee of the MoEF returned the NPCIL’s application for environmental clearance in October 2014, asking why AERB site clearance was not obtained before applying for environmental clearance.

Citing this decision of the EAC on Mithi Virdi, KBS has urged the government to revoke environmental clearances for Jaitapur as the MoEF’s conditional clearances came without a siting clearance from the AERB, and was based on an EIA which has insufficient details.

Studying the land

Residents of Madban are offended at the use of term “barren” for their land. “Our village changes its avatar every two weeks. Some flowers and grass that you see now will be gone the next month and some others will be seen. They say our land is barren! How do they fail to see this beauty and its diversity?” says Srikrishna Mayekar, a prominent member of the protest.

The EIA calls the area a barren rocky plateau.

Anand Murali

The EIA, however, calls the site a “barren rocky plateau” with sparse vegetation in the form of grasses. MoEF has clarified whether the proposed site conforms to the approved land use of the area. However, Dr Aparna Watve, a vegetation ecologist with the School of Rural Development, Tata Institute of Social Sciences, Tuljapur, seems to disagree with this idea of classification of land.

“The 2010 Wastelands Atlas of India, by the National Remote Sensing Centre and Ministry of Rural Development, shows extensive ‘Category 22’ (barren rocky /stony waste areas) in Kolhapur, Pune, Satara, Ratnagiri and Sindhudurg districts, which in reality are rocky plateaus with high biodiversity value,” she writes in “Status Review of Rocky Plateaus in the northern Western Ghats and Konkan region of Maharashtra, India”. This study was published under a Western Ghats Special Series in the Journal of Threatened Taxa on March 26, 2013.

“The wasteland status has been easily exploited for acquiring rocky plateaus for mining, wind farms and infrastructure projects throughout the study area (northern Western Ghats and Konkan region of Maharashtra),” she adds.

Dr Madhav Gadgil also points out in his report that the windswept lateritic plateaus of the Western Ghats—commonly dismissed by EIAs as barren lands—are in fact very rich in biodiversity. He emphasises the current environmental clearance processes are seriously defective and EIAs are particularly weak in sections on biodiversity and socio-economic issues.

Watve’s report lists JNPP as a “threat” to the rock outcrop in Jaitapur, which could cause “high level of disturbance … These vast and biologically rich plateaus have been claimed for nuclear power plant, conversion of land into intensive urbanization and industrialisation. The sad neglect of such a specialized habitat and its biodiversity needs to be stopped immediately.”

JNPP and its surrounding areas fall under the low-level ferricretes (LLF) category in Konkan, which Watve says are most at risk of the diverse rocky plateaus studied, as none of them fall under any legally protected area. Land conversion is very easy because the rocky plateaus fall under “wasteland” category. Jaitapur nuclear power plant, Ratnagiri airport, Ratnagiri industrial zone, and Devrukh township are some examples of development on Konkan plateaus.

The ecological importance of this plateau was evident when Gadgil chose to include this area in his official field visit as the chairman of the Western Ghats Ecology Expert Panel though the site and surrounding areas are not strictly part of the Western Ghats but are westward spurs of the Ghats. “The police surrounded me and did not let me speak to the people, who had gathered to meet me, when I visited Sakhri Nate and Madban in 2010. I was making a tour of the Konkan region as part of my official duty as the chairman of the WGEEP,” he told us.

“It was a clear sign that the administration wanted to overlook the concerns of people and suppress their demands,” he added.

The Gadgil panel later recommended an indefinite moratorium on new environmental clearances for power plants, mining, and red and orange category polluting industries.

The panel later met with NPCIL officials to discuss Jaitapur. As part of its study, it commissioned two scientific papers focussing on Konkan, took up a field tour of Konkan, and organised 10 public/civil society group consultations, focussing on issues of cumulative impact assessment, environmental problems, long-term ecology monitoring site in Konkan.

Apart from being an important habitat for several endemic floral and faunal species, the rocky plateau provides crucial ecosystem services of water catchment and helps in pollination for crops and orchards in the area. It’s also home to several rivers and rivulets which help both agricultural and fishery production as the monsoon runoff to the sea carries rich nutrients from the forests.

Watve’s report recommends “conservation and management of these rocky plateaus”.

Need for cumulative assessment

Gadgil, who is strictly against nuclear power plants anywhere, has bigger reservations about such a project in an ecologically important area like Konkan. “Assessing impact in a five or 10 kilometre radius area is not enough. All the proposed merchant power plants, which have been given environmental clearances in the Konkan region, would produce 15,600 MW of power. With all these power plants coming up in the Konkan region, the cumulative impact of all the projects operating and proposed in the Konkan is necessary,” he said.

Dr Madhav Gadgil

Janhit Seva Samiti

Apte fully agrees. “At least 15 proposed coal-fired power projects equalling 25 GW of power are set to be built on a narrow strip of coastal land 50 to 90 kilometres wide and 200 kilometres long. It is evident from the impact maps provided in the report, that if looked in totality, there is not a single square kilometre area free of impact in the stretch … of coastal Konkan from Dabhol to Sindhudurg.”

Gadgil adds, “Another important thing is to improve EIA practices. The EIA consultants should be delinked from the developers and the process of EIA should be made more meaningful by taking people’s opinion seriously,” Gadgil adds.

Social impact assessment

The social impact section in the EIA does not show a single negative impact of the project. All the parameters considered by NEERI either show a positive or an insignificant impact.

The reason for this is probably because a detailed social impact assessment (SIA)—as the National Rehabilitation and Resettlement Policy, 2007 directs—was never done for Jaitapur. The SIA was made a part of EIA, and the methods adopted for the survey are unclear.

In an RTI reply on September 7, 2010, the NPCIL merely said, “Baseline survey of socio-economic environment was carried out by NEERI, Nagpur, as part of EIA study”. However, the NEERI’s EIA says that the Rehabilitation and Resettlement (R&R) plan is “based on the baseline socio-economic survey by an independent agency Yashwantrao Chavan Academy of Development Administration (Yashada) appointed by the State Government”.

In an RTI reply on September 22, 2009, Yashada clarified that the baseline survey was not carried out either due to protest from affected people. A separate RTI reply from NPCIL confirms this.

Residents of project affected villages were never approached by NEERI or any other agency for a primary survey, after Yashada officials were “chased away”.

Yashada’s RTI response also clarified: “Revenue & Forests Department, Government of Maharashtra order on 6 February 2007 gave Yashada the task of conducting a Baseline Survey of people affected by JNPP. In the government order, there was no mention of Social Impact Assessment of the project.”

Therefore, the R&R plan has been prepared without an SIA and with a baseline survey whose authorship is questionable. The draft R&R plan was never discussed in gram sabhas or consulted on with affected families, which is a requirement.

As the government kept the people out of its R&R plan, the project affected people decided to get an SIA done for themselves. Conducted by the Jamsetji Tata Centre for Disaster Management (JTCDM) of Tata Institute of Social Sciences, Mumbai, the SIA is titled “Perceptions Matter”, and prefers to call itself a people’s report.

Mahesh Kamble, officiating chair of JTCDM, is he author of this report. He writes that he “witnessed how the government was trying to suppress the people’s struggle aggressively”. He also mentions many specific instances where the district administration did not help him with information. “It is not only lack of information, but (also) manipulation of information that disturbs people,” he writes.

Kamble also reports allegations of land records being fudged, anger over loss of livelihood and fear of radiation from the project, none of which has made it to the EIA’s social impact section, which is full of benefits.

Kamble’s report says people “believe that the plant would require specialized people and job market will not be available for the villages” and that they feel that if Konkan’s biodiversity must be appreciated by setting up government projects, it should be done via eco- friendly tourism projects and not by setting up power plants.

“The atmosphere is rife with insecurity and a feeling of being cheated,” Kamble notes.

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