By Fax -044 22353155 and email tnpcb@md3.vsnl.net.in; tnpcb@dataone.in

March 30, 2007

To

The Member Secretary

Tamilnadu State Pollution Control Board

Chennai

Dear Sir/ Madam,

Re: Our submission for the Public Hearing to be held on March 31st regarding the Koodankulam Nuclear Power Project –KKNPP (establishment of units 3, 4, 5 and 6), Tirunelveli Kattaboman district, Tamilnadu 

We have received information that the environmental public hearing under the EIA notification 1994 is to be held for the Koodankulam nuclear power project (units 3, 4, 5 and 6) on March 31st 2007. Kindly consider this letter as our submission to you regarding this project and forward this to the Union Ministry of Environment and Forests for consideration during the appraisal of the project for grant or rejection of clearance to the project.

At the outset, we would like to place on record our opposition to the project on grounds of the risks associated with this technology. This move of the Government of India to locate a plant that relies on such A dangerous technology on the coast of Tamilnadu, places at risk the lives of tens of thousands of fisherfolk and coastal communities, adversely affects their economic survival and livelihoods and the marine and coastal resources and ecosystem. 

The myth of nuclear energy being ‘clean’ 

Unlike what is being touted, this source of energy cannot be considered ‘clean’ by any stretch of imagination. Nuclear energy is fraught with environmental dangers or costs, at every stage -- be it the mining of ore, fabrication of uranium fuel, its use in reactors to generate the production of energy, or and storage, disposal or reprocessing of spent fuel. The entire “nuclear fuel cycle” involves exposure to ionising radiation, which produces extremely harmful health effects, including cancer and genetic damage. We therefore oppose the manner in which citizens are being misled to believe that this project and nuclear energy are a clean source of energy.  

Clearance under EIA and CRZ notifications

The project requires environment clearance as per the EIA notification 1994. According to procedures laid down by the notification, “the reports submitted with the application shall be evaluated and assessed by the Impact Assessment Agency and if deemed necessary it may consult a committee of Experts having a composition as specified in Schedule II of this notification.” The practice of having sectoral Expert Appraisal Committees to evaluate projects and recommend grant or rejection of clearance to these has been institutionalised by the MOEF since 1994. It is indeed a necessary step in the clearance procedures as it is meant to make available expert opinion on technology and impacts to the MoEF.  

However, we would like to bring to your attention that as of today, there is no Expert Appraisal Committee under the MoEF constituted to evaluate nuclear power projects that seek environment clearance.  The absence of such an expert committee to look into the details of the proposed nuclear power project and to recommend an appropriate decision on the matter of its clearance is of grave concern to us.

The above-mentioned lack of a team of experts to assess the proposed project documents will also undermine the process of grant of clearance under the CRZ notification 1991.

It has been brought to our notice that although the EIA report and its summary have been made available to local people in English, these documents do not exist in the local language. This is a violation of Clause (1) i of Schedule IV of the EIA notification which makes it mandatory for the Executive summary to be made available both in English and the local language.

This has also been reiterated by the Gujarat High Court order in the Special Civil Application No.8529 of 1999: “As far as the Environment Impact Assessment report submitted by the unit to the GPCB along with the application for clearance certificates is concerned, the summary of such Environment Impact Assessment report in the local language shall also be made available to the concerned persons on demand and if further demanded, a copy of the Environment Impact Assessment report also shall be made available..”.

Faulty information in the Executive Summary 

The Executive Summary of the EIA report of the project reads more like a propaganda statement for nuclear power rather than an objective assessment of the proposed project. It is not only misleading but also conceals pertinent information.

For example, it states that the project would not require additional land (page 2). However, this by no means indicates the absence of environmental or social impacts that the project is bound to have. The presence of additional units only enhances the risks that would be already present because of Units 1 and 2 (which are currently under construction).

The summary also states (on page 2) that nuclear power is economical compared to thermal projects and hydro power is not feasible at this site. This is an absurd statement to make. It is a poor substitute for a robust options assessment which should have been made by taking into account the range of choices available in the renewable energy sector. This statement is a clear indication of the fact that the consultant’s terms of reference may not have even theoretically allowed an objective options assessment to be done as the study was commissioned by the project proponent itself. 

The claimed environment-friendliness of NPCIL’s projects, in particular the potential of nuclear power to contribute substantially to reducing global greenhouse gas emissions, is yet another statement intended to mislead citizens. As noted environmentalist and National Coordination Committee member of the Coalition for Nuclear Disarmament and Peace (CNDP), Praful Bidwai points out, “Electricity generation accounts for only nine per cent of global carbon-dioxide (CO2) emissions. And nuclear energy accounts for just 16 per cent of global electricity - in India, for a paltry 3 per cent. So the scope for cutting greenhouse gas (GHG) emissions through the nuclear route is meagre. Each step in the nuclear fuel cycle, from mining to reprocessing, emits GHGs.” (http://www.hinduonnet.com/fline/fl2216/stories/20050812003410500.htm)

On the above grounds, we urge the Tamilnadu State Pollution Control Board, the State Department of Environment as well as the Ministry of Environment and Forests to reject the grant of clearance to this project. 

While we are aware that the Indian government has openly announced its plan to focus on nuclear energy in a big way in the next five year plan (as stated in the 11th Plan Approach Paper) we reiterate our opposition to the use of such technology for the production of power. We urge the government to focus instead on a mix of demand-side electricity and energy options and ensure optimal consumption as well as emphasise renewable and clean sources of power. There are cheaper and environmentally safer and occupationally benign, more manageable and decentralised alternatives to nuclear power, which are not fraught with operational risks and which do not leave wastes that will be active for tens of thousands of years and which cannot be safely disposed of.  

Sincerely, 
 

Manju Menon

For :

Manju Menon/ Kanchi Kohli

Kalpavriksh Environment Action Group 

Sudarshan Rodriguez

Marine Conservation Analyst 

Aarthi Sridhar

Environmentalist, Bangalore