To: Eduardo Calvo Buendia, CDM Executive Board, UNFCCC, Frank Wolke, CDM Executive Board, UNFCCC, A. Duraisamy, Director (CC) and Member Secretary (DNA), MoEFCC, India

We bring to your urgent attention the alarming project being accredited by the UNFCCC through a Clean Development Mechanism (CDM) for a waste to energy incineration technology at theTimarpur-Okhla Waste Management Company Pty. Ltd in Delhi.

 

This project is being undertaken by M/s Jindal Urban Infrastructure Limited (JUIL), a company of M/s Jindal Saw Group Limited at Sukhdev Vihar, Okhla, Delhi located in the vicinity of several residential and sensitive institutions like leading hospitals and beside the Okhla Bird Sanctuary.

 

The Clean Development Mechanism’s flagship waste management project in India, the Timarpur-Okhla Waste Management Co Pvt. Ltd, has turned into a multi-faceted disaster. Flaws in both the carbon credit mechanism as well as the corporate driven, technology-focused approach to climate change mitigation, has failed the people of India and trashed the reputation of the UNFCCC and its CDM.

 

This project was established not only to reduce carbon emissions as cost-effectively as possible, but also to promote sustainable development and technology transfer to developing countries. Sadly this promise has not been realized.

 

“It is unfortunate that there is such blatant fraud on the UNFCCC’s carbon credit mechanism as well as on the conditions on which the environment clearance was granted by Ministry of Environment, Forests and Climate Change, India” said Umesh C. Bahri, a resident of Sukhdev Vihar and a scientist familiar with accreditation processes. “While both entities have been notified of the fraud, no action has been taken by either bodies or by the NGT.”


The public-private partnership based Jindal conglomerate owned Timarpur-Okhla Waste Management Co Pty Ltd, claims it to be “one of the first and largest integrated waste management projects ever set up in the country, aiming for a sustainable waste management solution by taking MSW through an environmentally friendly process to generate clean and renewable energy. The project boasts a so called “state-of-the-art facility which offers a safe, technologically advanced means of waste disposal while also generating clean, renewable energy, reducing greenhouse gases and in particular methane gas emissions and supporting recycling through the recovery of metals and other recyclable materials.”[2]We point to the lived experience
of the vulnerable host communities affected by this disastrous project.  For several years now, the residents of SukhdevVihar, Delhi, living in the shadow of this waste to energy incinerator plant have been engaged in litigation over the feasibility, use of technology and pollution being caused by the plant. As far back as 2009, residents took the matter to the Delhi High Court[1]claiming that the plant was emitting dioxins and heavy metals; the matter was heard 27 times in the High Court. In February 2013, the case was shifted to the National Green Tribunal (NGT- India’s fast track court for environmental related cases) where there have been more than 50 hearings since and still counting.

 

In addition, the project claims to process 2050 TPD of Delhi’s unsegregated municipal solid waste to produce 20MW of electricity while anticipating an offset of nearly 262,791 tons of CO2 per annum. This would earn the project participants 2.6 million certified emission reductions (CERs) or approximately 23 million Euros.

 

What was touted to be a clean and renewable energy project to manage increasing volumes of the city’s waste, has become a disturbing legacy of toxic pollution, impacted communities and dishonest governance.

 

The Ministry of Environment, Forest and Climate Change (MoEFCC) granted technology approval for the establishment of an integrated Municipal Solid Waste Plant (MSWP) with two Refuse Derived Fuel (RDF) plants, a bio-methanation plant and a power plant. However, the project was set up with no facilities for the generation of RDF (ie pellets or brickettes) or Bio-methanation. Instead the proponent has used reciprocating stoker type boilers of Chinese origin, the use of which is being phased out in even in China following widespread public protest. The Guangzhou Boiler Group which manufactures the stoker-type boilers has installed the equipment at Okhla plant.[3]

 

Regulatory agencies of the state have also issued the project proponent a show cause notice[4]and denied it authorisation or consent to operate during the last monitoring period (2012 – 2015).  Regulators (Central Pollution Control Board of India) have informed the relevant court via affidavit that there have been complete alterations with respect to the description of the project as approved in the said Environmental Clearance.

“Climate change is about justice and sustainability, not about poisoning people and snatching away livelihoods. But this is what the Okhla waste-to-energy plant has done-displace nearly 300 waste pickers, and consequently, 63% of their children out of school. For this, it has received carbon credits. Is this how the world will fight climate change? By funding poverty creation? The new climate finance regime must put decent, sustainable livelihoods and the poor at its centre rather than expect technologies alone to make the world cooler.” ~ Bharati Chaturvedi, Director, Chintan, Delhi


Despite such a long tainted record for this incinerator plant, the UNFCCC has issued a total ofEven as recent as the 6th July 2016 meeting[5] called under the Chairmanship of Chief Secretary, Government of National Capital Territory (NCT) of Delhi to implement the orders of the National Green Tribunal in the matter of Sukhdev Vihar Residents Welfare Association and Ors Versus State of NCT of Delhi & Ors, notifies that the plant may operate on provisional basis and was ordered to improve its emission standards as per the direction of Delhi Pollution Control Committee and National Green Tribunal.

438,793 CERs between the period 30/03/2011 to 09/03/2016 and will even continue to provide CERs under the CDM until 2021. The plant also blatantly violates other state regulations for polluting industries, being barely 150 meters from long-established residential areas, posing unacceptable health risks[6] to neighbouring residents. In sum 2,000 tonnes of unsegregated municipal waste is being incinerated in this plant daily, causing a serious health hazard to tens of thousands of people living and working in this ecologically-sensitive area. Two major hospitals in the area have also complained to the prime minister’s office about the hazards to patients[7].

Despite the projects proven negative social and environmental impacts, the Timapur-Okhla Waste Management Pvt. Ltd. waste to energy project in Delhi continues to be registered under the CDM for reducing emissions of greenhouse gases.

 

The city of Delhi, which hosts this facility, has effectively become a dangerous, high risk, air pollution zone. The levels of PM2.5 pollutants, which are the most harmful because they can deposit deep into the lungs and cross the blood-brain barrier, have reached at least 999 ppm in the city this week, more than 16 times the safe limit of 60ppm.[8]

 

At a time when India is already struggling with its burgeoning pollution problems, it cannot afford to host green-washed, false
climate solutions that rely on burning organics and recyclable materials for comparatively low energy value. Waste to energy incinerators displace more effective Zero Waste practices that create jobs and preserve the materials in our waste stream for future use and are comparatively more cost effective. They also displace cleaner renewable energy technologies such as solar, wind and wave power, anaerobic digesters and biogas plants, while entrenching a globally destructive and
unsustainable linear economic model.

“Incinerating waste, which are actually recyclables, deprives us of our already meagre
livelihoods,” say Zainab Bibi one of an army of waste pickers engaged in collecting and recycling plastic waste in the Okhla area. “There is no alternate employment available to us.”


While incinerators have aroused serious concerns worldwide and their impacts on human health have been extensively documented, the CDM continues to support their expansion, with little regard for their impact on recycling rates and the GHG reduction benefits associated, and without requiring any other pollution controls. It is time for the UNFCCC to recognize that it cannot ensure the environmental integrity of incinerators and their associated toxic ash residue stockpiles, nor eliminate the social harm that they cause. Rather than continuing to support projects with negative social and environmental outcomes, the CDM should cease issuing CERs to solid waste disposal projects, including all forms of waste to energy incinerators and landfills.Furthermore, the assumptions underlying greenhouse gas reduction estimations made under the CDM, do not take into account the considerable GHG reductions achieved by the current informal recycling sector.  For instance, Delhi’s waste-pickers are responsible for annual emissions reductions of approximately 962,133 tCO2e[9]through recycling. If the waste to energy project burns even one-quarter of Delhi’s recyclables, it will effectively wipe out its own emissions savings, resulting in no net emissions reductions. But because the CDM has not calculated the project’s impact on recycling, it will continue to award the company hundreds of thousands of spurious carbon credits – credits which do not represent real emissions reductions.

 

With this compelling evidence before you, we urge you to categorically exclude waste to energy incinerators and landfill projects from eligibility for carbon credits. These waste disposal methods, which destroy finite resources and generate significant toxic and greenhouse gas emissions, have no place in the CDM. They compete with waste reduction, reuse, recycling, and composting — all of which are, according to the waste hierarchy, superior over land filling and incineration.

 

We urge you to reverse your decision to support the establishment of such thermal waste to energy technologies and lead us towards a sustainable Zero Waste future, in the direction that supports the health, vitality and security of India.

We demand that:

 

1. The CDM Board undertakes an immediate independent investigation of the Timarpur-Okhla Waste to Energy plant
to ensure compliance with the current CDM modalities and procedures. Such investigation must include a full human health and environmental impact assessment, in cooperation with state and local authorities and with the full inclusion of all stakeholders to ascertain the harm this project has caused to the community and their environment. Should the CDM Board find that the plant is not compliant and is in fact causing adverse health impacts on the community then it should immediately withdraw the project from the CDM list.

 

2. The UNFCCC/ CDM recompenses the host community for the harm the project has caused them.

 

3. The UNFCCC/ CDM ensure that climate finance is devoted to truly sustainable, low-carbon and toxic free projects in India.

 

Sincerely,

 

The undersigned

1. Vimal Monga, President of Sukhdev Vihar Resident Welfare Association (SVRWA), Delhi, India

2. Pratibha Sharma, Global Alliance for Incinerator Alternatives (GAIA), India

3. Chitra Mukherjee, Chintan Environmental Research and Action Group, Delhi, India

4. Gopal Krishna, Toxics Watch Alliance, Delhi, India

5. Anitha Thampi, HLL Management Academy, Thiruvananthapuram, Kerala, India

6. Shashi Pandit, AIKMM, Delhi, India

7. Om Prakash Singh, Citizen Consumer and Civic Action Group, Chennai, India

8. Maj. Gen. S. C. N. Jatar (Retd.), Pune, India

9. Sandya Narayanan, Solid Waste Management Round Table, Bengaluru, India

10. Shibu Nair, Thanal, Kerala, India

11. Froilan Gate, GAIA Asia Pacific

12. Monica Wilson and Christie Keith, GAIA US

13. Joan Marc Simon and Mariel Viella, Zero Waste Europe

14. Magdalena Donoso H, GAIA Latin America

15. Jane Bremmer, National Toxics Network, Australia

16. Lee Bell, IPEN

17. Eileen Lucero, Ecowaste Coalition, Philippines

18. Mageswari Sangaralingam, Consumers’ Association of Penang, Malaysia

19. Shahriar Hossain, Environment and Social Development Organization (ESDO), Bangladesh

20. Xavier Sun, Taiwan Watch Institute, Taiwan

21. S.M.Mohamed Idris, Sahabat Alam (Friends’ of the Earth), Malaysia

22. Nnimmo Bassey, Health of Mother Earth Foundation (HOMEF), Nigeria

23. Dwi Sawung Rukmono, Friends of Earth, Indonesia

24. Maud Biggs, Fundación El Árbol, Chile

25. Merci Ferrer, Mother Earth Foundation, Philippines

26. David Sutasurya, YPBB, Indonesia

27. Mwadhini Myanza, Morogoro, Tanzania

28. Anabela Lemos, Justica Ambiental, FOE Mozambique

29. Angus Ho, Greeners Action of Hong Kong

30. Shlomo Dowen, United Kingdom Without Incineration Network (UKWIN)

31. Pranay Shrestha, Pragya Seeds Nepal, Kathmandu, Nepal

32. Binay Shrestha, Swarnim Samaj, Birgunj, Nepal

33. Ranjit Devraj, Sukhdev Vihar Resident Welfare Association (SVRWA), Delhi, India

34. Dr. U C Bahri, 86-D, SVRWA

35. Krishan Gopal Kakkar, 44-A,

36. Dr. Danish A Hashim 24-D

37. J.B. Sharma, A-205

38. Pawan K Bahl, 114-A

39. Kaun Raut, 99-A

40. B K Raut, 98-A

41. Dr. M.L. Goglani, 52-A

42. Anju, 44-A

43. Rajendra K Agrawal, 46-B

44. Bina, 46-C

45. Madhuri, 45-A

46. Khalil UR Rehman, 43-A

47. Johnson O, 33-D

48. Prem Paruash, 33-C

49. Dr. Rubal Gupta, 35-A

50. Prof. T. Ramamurthy, 42-A

51. Gulshan K. Khurana, 34 A

52. S. Khan, 44-C

53. R S P Singh, 45-D

54. Vipin Kapoor, 41-B

55. Harsh Nayyar, 153-B

56. Prashant V. R., 61-D

57. R.K. Sardana, 34-C

58. Y.K. Khanna, 122-D

59. Juli Sardana, 34-C

60. Karnal Chand, 39-A

61. A.K. Roy, 119-C,

62. Iti Aggrawal, 85-D

63. Sriraman R, 85-D

64. Sarita Aggrawal, 64-A

65. Navin Arora, 83-B

66. Rajesh Malhotra, 79-A

67. Rajkumar Goyal, 78-C

68. Rajiv Malhotra, 110-B

69. R.K. Godhuvaro, 132-C

70. S.K. Maheshwari, 68-A

71. R.K. Deewan, 75-C

72. L.D. Madan, 67-A

73. H.P. Godhwari, 132-A

74. Kailash Sood, 233

75. Manju, B-7

76. Swantanter Malhotra, 97-B

77. Usha Bhagat, 107-B

78. Balesh Verma, 34-B

79. Meenu Sharma, 32-C

80. Madhu Chowdhary, 78-B

81. Bimla Gupta, 131

82. Kusum Y, 92-A

83. Nandini Rege, 147

84. Pravin Rastogi, 73-C

85. Ajit Bala Sood, 139

86. Seema Rani, 81-B

87. Shashi Prabha, 47-C

88. Bimla Wadhawa, 60

89. Vinod Bala Bhardwaj, 164-B

90. N. T. Thadani, 65-A

91. Anand Malik, 83-A

92. Randhir K Sharma, 94-B

93. V. N. Mathew 75-B

94. Deepti Kar 111-B

95. Usha 97-A

96. Madhu Mehrotra, 125-B

97. Rekha Jain, 186

98. Pushpa Diwan, 75-C

99. Moti Bhatia, 52-B

100. H. P. Singh, 232

101. Sushil Chaudhrey, 73-C

102. Vishnu Dutt Sharma, 53

103. Nirmal Gupta, 41

104. S.S. Sood, 113-C

105. Shubhi Gupta, 48-D

106. Devashish Shukla, 3-D

107. Kapil Dodhi, 120-A

108. Sandeep Biswas, 4-C

109. V.K. Bakshi, 6-A

110. M.I. Khan, 11-A

111. Manoj Mathur, 9-B

112. Mohd. Salimmuddin, 103-B

113. Preeti Narang, 104-B

114. Sajimon PM, 103 C

115. M. Alexx, 104-D

116. H.K. Chadha, 73-B

117. Naushad Zafar, 104-C

118. Oindrila Ghosh, 133-B

119. Deepak, 119-A

120. Kamal K Sehgal, 124-B

121. Nelai Chand Addy, 124-C

122. Manju Maity, 124-D

123. Kunal Tandon, 123-D

124. Shivi Mehrotra, 125-B

125. Ashok Dutta, 126-C

126. B.P. Mathur, 125-C

127. Abhi Rani, 126-D

128. Dr. Pramod, 125-D

129. Rajkumar Goyal, 78-C

130. Rajiv Malhotra, 110-B

131. R.K. Godhuvaro

132. Dr. Abhishek, 24-C

133. P.P. Sharma, Shop. No.5, DDA

134. Ruhulla Hussain, 120

135. Deis, Shop-1, DDA

136. Anant Trivedi, Ishwar Nagar East

 

 


[3]Central Pollution Control Board Report , 2012–
“Technical Evaluation of MSW Based Waste to Energy Plant at Okhla STP Site,
Delhi”  B29016/ (SC)/1/11/HWMD/3762

[4]Central Pollution Control Board Report , 2012–
“Technical Evaluation of MSW Based Waste to Energy Plant at Okhla STP Site,
Delhi”  B29016/ (SC)/1/11/HWMD/3762

[5]Delhi Pollution Control Committee Letter Dated:
10/01/2014, (F.No. DPCC/WMC-II/2013/W1/1598 To 1605), Subj: Show cause notice
for refusal of consent under Air (Prevention and Control of Pollution) Act,
1981 and under Water (Prevention and Control of Pollution) Act, 1974 as amended
to date

[6]Central Pollution Control Board Report , 2012–
“Technical Evaluation of MSW Based Waste to Energy Plant at Okhla STP Site,
Delhi”  B29016/ (SC)/1/11/HWMD/3762

[9]Cooling Agents: An Examination Of The Role Of The
Informal Recycling Sector In Mitigating Climate Change,” Chintan 2009