Embed Size (px)
Citation preview
Complaints of People from neighbouring villages to the NGT and the response from the proponent M/s. Coromandel Sugars Ltd., Makavalli village, Mandya District, Karnataka state
A Because the proposed project consists of a Distillery, cogeneration plant and power plant and Molasses‐based Distillery has been classified as a Category 'A' industry at Entry No. 5(g) of the Schedule to the Environment Impact Assessment Notification, 2006, and a 'red category' industry, and in light of the same it was essential that the environment impact assessment was carried out in a scientific and comprehensive manner so as to ensure that an independent and objective assessment was done in the interests of the environment and the local populations in the vicinity of the proposed project. However, this has not been done
We have obtained the environmental clearance following the due process as mentioned in SO 1533 dt. 14.9.2006 by the Ministry of Environment Forests and Climate Change (MoEFCC).
B Because, the grant of environmental clearance is clearly in violation of the Environment Impact Assessment notification 2006 and various judgments of the Hon'ble Supreme Court and High Courts and therefore needs to be set aside
National Green Tribunal, Chennai advised the EAC and MoEFCC to review the documentation once again in view of the objections raised by the appellants.
C Because the project proponents have a long history of environmental pollution in the operation of their Sugar Industry on which premises the Distillery Cogen and power plant are proposed, and hence it is unjustified‐that they be permitted to start another highly polluting industry in the same region in such a mechanical manner.
The existing unit obtained Consent to Operate vide letter no. PCB/111/HPI/2010/1012 from Karnataka State Pollution Control Board (KSPCB) dt. 06.11.2014. The unit is in operation from 1996. The unit modified the Effluent treatment plant during 2013 and established ventury scrubbers as advised by the KSPCB from time to time. The reports of monitoring conducted both by the KSPCB and third party laboratory is observed to be within the limits. The results are presented in Annexure ‐ I.
D Because the Environmental Appraisal Committee has failed to apply its mind to the facts and circumstances of the Project and the Terms of Reference framed are not comprehensive and fail to take into consideration various social and environmental aspects, or the probable environmental pollution and degradation and social impacts possible from the proposed project.
The TOR's have omitted the existing pollution caused by the sugar industry and the implications that the proposed new plants have in that context
The details of effluent treatment plant are presented in page no. 116 to 129 of EIA report. The TORs do not even make any mention of the Fly‐ash Notification, 1999 as
amended from time to time issued by the Ministry of Environment and Forests, placed as Annexure ‐ A27, which is unjustifiable
The proposal is for a cogeneration plant of 30 MW using a combination of 15:85 of coal and bagasse. The fly ash notification is applicable for TPP's that utilize 100% coal.
E Because, the entire approach of the EAC/MOEF has been to recommend the project for approval without considering the ecological and socio‐cultural impacts of the project and by turning a blind eye to the shoddy EIA report prepared by M/s Enviro Care India Private Limited, the illegal manner in which the public hearing was conducted and the report prepared and the failure to consider the valid objections raised by the villagers including the Appellants
The project authorities obtained terms of reference for preparation of EIA vide letter no. F.No. J‐11011/565/2010‐IA II (I) dated. 23.03.2011
The public hearing for the project was conducted on 09.12.2011 at Factory premises. The final EIA was appraised by the honourable Environment Appraisal Committee (EAC) on 24‐25th September, 2012 The EC was issued vide letter no.F.No. J‐11011/565/2010‐IA II (I) dt. 31.12.2012 from MoEFCC The CTE was obtained vide letter no.PCB/111/HPI/2011/90 dt. 24.04.2013 from KSPCB.
F Because the non‐application of mind by the Project proponent and the lack of scrutiny by the EAC and the MoEF where they have simply accepted the submissions made by the project developer without any independent verification, is contrary to the precautionary principle
The final EIA was appraised by the honourable Environment Appraisal Committee (EAC) on 24‐25th September, 2012
G Because, as per the accreditation granted by the Ministry of Environment and Forests, M/s Enviro Care India Private Limited are competent to take up Category 'B' projects and not Category 'A', whereas the present project is on categorized under Category 'A', and in the light of the same, the entire process of the grant of Environmental Clearance gets vitiated. The relevant extracts of the List of Accredited EIA Consultants Organizations as per the Ministry of Environment and Forests is placed as Annexure A‐28.
The proposal was presented by Team Labs and Consultants in the EAC meeting, which was Accredited EIA Consultant for Category “A” Projects of EIA notification category 5(g)
H Because the project proponents and the EIA Report suppresses the fact that the proposed project is within 1.5 km of the Hemavathi river, which is apparent even from the records of the KSPCB, reference being made to Annexure ‐ A24, wherein the KSPCB has stated that the distance between the factory and the Hemavathi river is between 1.2 to 1.6 kms. The establishment of the proposed industry is contrary to the Siting Guidelines for new industries brought out by the Karnataka State Pollution Control Board/ applicable to distilleries which states that "No new industry specified below shall be permitted to be established within 1.5 k.m.from the embankment of the streams, rivers, dams as indicated below, If any of these water bodies are the source of drinking water, then such distance shall be stipulated which will not affect such waters by discharge of the pollutants." The Siting Guidelines notified by the KSPCB is placed as Annexure ‐ A29.
KSPCB has categorically informed the NGT that the site is 2 km away from Hemavathi river. "The Tribunal is of the considered view that the present project is only an expansion of the existing industry and the KSPCB has filed its reply stating that the Hemavathi river is situate at a distance of 2 km from the project. Much significance cannot be attached to the distance criteria since the location of the expanded facility is in the same premises as that of the existing industry. Hence, this point is decided in favour of the 3rd respondent industry" (Para No. 81, Page No. 67‐68 of the NGT order dated 12.05.2012).
I Because all the land impacted by the Coromandel Distillery project and all components integral to the project have not been included in the environmental and social impact assessment making the decision made on this incomplete information liable to be set aside.
The impact area considered is 10 km radius area surrounding the plant site.
J Because the EIA Report does not meet the ToRs issued, evidenced by the Table placed above) For instance
i In regard to the TOR 'Present land use based on satellite imagery', it is found that the detail of site and information related to environmental setting within 10 km radius of the project site is
not provided. Further, the Draft EIA Report consciously suppresses the true number of villages and towns in the vicinity of the project. Moreover/ the fact that the Hemavathi River is less than1/2 km away from the proposed project is suppressed
The land use land cover map is presented in Annexure ‐ III of the EIA report. An updated land use land cover map is also prepared and the same is enclosed in Annexure ‐ II.
ii In regard to the TOR 'Storage for bagasse', no details of the storage facility are provided
The total bagasse requirement for proposed 140 TPH boiler is 1560 TPD and same was stored in covered shed. Baggase storage area is indicated in Plant Layout (Annexure ‐ III)
iii In regard to the TOR 'Hydro‐geological study of the area for availability of ground water', no reference is made to the Hemavathi River and further extremely sketchy baseless and unreliable information is provided without any sources or supporting documents cited
The hydrogeological study of the area was not conducted as the existing and propsoed plants depend on Hemavathi river for its water requirement. Government of Karnataka permitted withdrawl of surface water Hymavathi river to an extent of 1.293 cusec (3176 KLD). The water requirement after the expansion is 2850 KLD, and no additional water permission is warranted.
iv In regard to the TOR 'List of flora and fauna in the study area', an extremely casual presentation of supposed findings is provided. For instance at page 95 reference is made to 'sussels viper' when in fact it is Russell’s viper. Moreover, the bird species are not even identified. There is no mention of the bird sanctuary at near Hemagiri falls, which though not declared as a sanctuary Houses. There is no assessment on the probable impact on the aquatic life in Hemavathi River. Further the fact there is a massive State Forest, Krishnaraya Forest, within 4 kms of the proposed plant has been suppressed and there has been no assessment of the flora and fauna in the forest which is known to have endemic flora and several species of fauna including wild pigs, peacocks, deer, Kirba (cheetah), rabbits, foxes, etc.
The proposal initially depended on the toposheet (57 D/6) issued by the SOI in 1972‐73, which does not reflect any forest within the imapct area. Recently we have acquired the latest SOI toposheets (copyright 2011) for this area and it was observed to have a reserve forest at a distance of 8.87 km in SW direction. We shall submit a detailed ecology and biodiversity report of this area in view of the RF in the impact area.
v In regard to the TOR 'Details of socio‐economic welfare activities’, no clarity is provided as to whether the survey was for villages within 5km radius (para 3.9.1) or 10 km radius (para 3.9.2), and there is no supporting information or details. Shockingly, table 3.8 is meteorological data! Further, para 3.9.4 is completely misleading inasmuch as that there are more than two crops and no reference is made to canal irrigation
The updated socioeconomic data for the imapct area is presented in Annexure ‐ IV.
K Because the EIA report is of a poor quality and indicates both a lack of authenticity and expertise in the EIA consultants, showing a combination of poor secondary research of scientific papers and poor fieldwork, and indicating a poor study of both ecological and socio‐cultural aspects in the EIA report. The concocted nature of the draft EIA is exposed on pursuing Chapter 3 of the Report titled 'Existing environmental status', A false claim is made that the baseline data was monitored from April to June 2011 and secondary data was collected from various government and NGOs, which is not made out in the Chapter.
No data in regard to the micro‐meteorological conditions including temperature, rainfall, relative humidity, wind direction, wind speed has been collected at all, and instead all the data presented pre‐dates the TORs.
Ambient Air Quality (AAQ) data and micrometeorological data was collected during April 2011 to June 2011 after submission of application for Terms of Reference (TOR).
The baseline data of soil quality presented in the said chapter is undated and bereft of the methodology adopted in regard to the sampling and assessment of soil quality
Soil sampling was done as per the guidelines of ECI‐SOP‐SAM‐35, and the monitoring was conducted during April 2011.
The water quality parameter of ground water and surface resources is unreliable since the same is bereft of any details in‐regard to the methodology of sampling and details of testing. Further, there is no assessment or even reference made to the Hemavathi River, which flows less than11/2 km from the site of the proposed project
Both ground and surface water samples were collected using IS method no.IS: 3025:P1: 1999, and the samples were analysed on the basis of IS: 3025/P14/2002 and its parts.
The ambient air quality referred to at para 3.5 suffers from the same critical drawbacks and shockingly there is no reference even made to the existing sugar industry and its impacts on the ambient air quality. Similar is the case with the parameters of the noise environment.
Ambient air quality was monitored while the sugar plant was operational during April 2011. The noise quality was monitored during April 2011.
A perusal of the so‐called studies on land use (para 3.7), which except for stating the objectives of the land use studies, provides no other details whatsoever. As pointed above, the assessment of the biological environment (para 3.8) has at best, if at all carried out, been cursory and carried out without any sense of responsibility.
Land Use and Land Cover Map is presented in Annexure III of EIA report.
The lackadaisical approach is also brought out in regard to the analysis of the socio‐economic environment (para 3.9), wherein at 3.9.1 it is claimed that the socio‐ economic study was carried out in a 5 km radius, whereas at 3.9.1 it is claimed that it carried out in villages in the 10 km radius.. Further, while it is stated in para 3.9.2, that there are 8 villages in the 10km radius, in reality there are at least 15 Panchayats consisting of scores of villages and several towns within this radius
The updated socioeconomic data for the imapct area is presented in Annexure ‐ IV.
The evaluation of agriculture in para 3.9.4, it is falsely1 stated that there is insufficient irrigation facilities, without even making a reference to the surface irrigation through canals and directly from the river.
Majority of the imapct area has dry land agriculture with crops of Ragi and black eyed peas, while the canal and borewell irrigated area has sugar cane and paddy as main crops. The area also has coconut and eucalyptus plantation in few patches of land.
Though there are existing and proposed industry around this proposed industry (para 4.3.2), no reference is made whatsoever in regard to these industries and the pollution being caused and the impacts suffered.
No major industries or distilleries are located within the impact area. (TOR no.7)
The EIA Report states that there are no forest/wildlife within 25 kms, which is completely contrary to the facts on ground. There is the Krishnaraya State Forest within 4 kms of the proposed project with various species of flora and fauna. It is submitted that this is also reflected in a Report prepared by the Deputy Environmental Officer, KSPCB, Mysore at the time of issuance of consent for establishment of the sugar industry at Makavalli Village dated 26/02/1998, placed herewith as Annexure ‐ A29, wherein it is clearly stated that "There is social forestry, forest on north eastern and south eastern direction at a distance of about 3 KM from the proposed site."
The proposal initially depended on the toposheet ( 57 D/6) issued by the SOI in 1972‐73, which does not reflect any forest within the imapct area. Recently we have acquired the latest SOI top sheets (copyright 2011) for this area and it was observed to have a reserve forest at a distance of 8.87 km in SW direction. We shall submit a detailed ecology and biodiversity report of this area in view of the RF in the impact area.
The claim in the EIA Report that there are no hill/ mountains within 25 kms is false, as there is mountainous region within 4kms of the proposed project on which the forests are
The highest MSL observed in the impact area is 840 m and the plant site MSL is 823 m. The impact area consists of open agricultural lands sloping mainly towards Hemavathi river and draining into the river and or its drains. A minor part of the imapct area in the northern side drains into Kikkeri tank. The North eastern The southwestern region of the impact area has hillocks raising to a height of 840 m with MSL of 823 m. The impact area is also irrigated by Hemagiri and High level Hemavathi left bank canal.
The claim that there are no historical places within 25 kms of the Project is false, which is blatantly false since there are several historical and archeologicai sites within 10 kilometers of the proposed plant including
Lakshminarayana Temple at Hosaholalu is a magnificient example of Hoysala architecture of the
thirteenth century. The intricate carvings in stone depict various images from the Mahabharata and other epics
Panchalingeshwara Temple dating to pre‐Hoysala period, and others within 10 kms. Brahmeshwara Temple, Kikkeri, which is a fine specimen of Hoysala architecture and was
constructed in A.D.1171 ASI site on the island in Hemavathi River near. Akkihebalu which dates to the reign of Tipu Sultan In fact Shravanabelagola is within a 19 kms radius of the proposed plant, is the location of the
57‐feet tall monolithic statue of Gommateshvara, which is considered to be the world's largest monolithic stone statue. The following table presents the notified archaeological monuments by both ASI and state ASI, with reference to their distance and bearing from the plant site.
S.No Name of the Monument Notified
by Distance from the project site (km)
Direction
1 Lakshminarayana temple ASI 9.29 SE 2 Panchalingeshwara ASI 8.83 NW 3 Brahmeshwara State ASI 7.22 N
ASI: Archaeological Survey of India
L Because Chapter 4 titled Impact Analysis1 is an exercise in speculation without any scientific or rational basis. For instance
The impact analysis only puts forth a cursory understanding of the impact during the construction phase, which is unreliable and unscientific. In regard to the operational phase, there are no details forthcoming of the effect of the distillery plant or the power place or the cumulative effect of the same.
The air quality impact predictions considered the anticipated emissions from the proposed 140 TPH coal and bagasse fired (15:85) boiler. The boiler is provided with ESP to control the emissions.
Technical Specifications of Electrostatic Precipitator – 140 TPH Boiler S.NO DESIGN PARAMETER 100% IMPORTED
COAL 100% BAGASSE
1 DESIGN GAS FLOW RATE IN AM3/HR 254628 363663 2 TEMPERATURE DEG.C (OPERATING) 160 160 3 CASING MECHANICAL DESICN TEMPERATURE
DEG.C 250 250
4 DUST TYPE FLY ASH FLY ASH 5 MAXIMUM INLET DUST LOADING (GM/NM3) 25 2.84 6 OUTLET EMISSION FOR ESP(MGM/NM3)ALL
FILED WORKING 50 50
7 OUTLET EMISSION FOR ESP(MGM/NM3)‐FIRST FIELD OUT OF SERVICE
100 100
8 MOISTURE IN GAS (% V/V) 9.9 50 9 UNBURNT CARBON IN FLY ASH (%) 10 10 10 COLLECTION AREA M2 5630.4(N)4222.8
(N‐1) 5630.4(N)4222.8 (N‐1)
11 SPECIFIC COLLECTION AREA M2/M3/SEC. 79.60/59.70 55.74/41.80 12 NO OF GAS PASSAGES 23 23 13 EFFECTIVE C E WIDTH (METER) 3239 3239 14 EFFECTIVE C E HEIGHT (METER) 9.448 9.448 15 VELOCITY THIROUGH ESP M/SEC 0.8 1.14 16 TREATMENT TIME (SEC). 16.2/12.10 11.3/8.50 17 NO OF FIELDS IN SERIES 4MECH /4 ELECT 4MECH /4 ELECT 18 MIGRATION VELOCITY(CM/SEC) 6.90/8.06 7.25/8.00 19 DESIGN PRESSURE (mm WG) ±400 ±400 20 DUST DENSITY FOR POWER (KG/M3) 1100 1100 21 DUST DENSITY FOR DISCHARGE (KG/M3) 800 400 22 FLG TO FLG PRESSURE DROP (mm WC) 25 25 23 EFFICIENCY(%) 99.59 98.24
ASH COLLECTION RATE IN EACH FIELD (KG/HR) SR.NO FUEL 100% IMPORTED COAL 100% BAGASSE
1 FIELD‐1 1475(0) 414(0) 2 FIELD‐2 373(1578) 151(438) 3 FIELD‐3 94(317) 55(143) 4 FIELD‐4 24(64) 20(47) 5 DUST COLLECTED IN SP(KG/HR)S 1967(1959) 640(628)
VALUES IN PARENTHESIS ARE FOR FIRST FILED OUT OF SERVICE
At para 4.3.2. (a), the ash from Bagasse is estimated to be 30 tonnes/ day, while the ash from coal is estimated to be 40 tonnes/ day without any basis whatsoever. This is a recurring theme in the chapter and the Report.
It is proposed to use agrofuels in combination with coal (15%) in 140 TPH boiler. The total ash generation shall be in the order of 15 TPD.
In the para titled 'Air Environment', (para 4.3.5), there is no reference made whatsoever on the ash content and the sulphar content which is to used in the cogent plant which is the primary factor to determine quantum of fly ash, nature of emissions including SOx. As such there is absolutely no scientific analysis of the impacts that the project would have in regard to the air environment.
Fuel analysis Ultimate analysis of Bagasse
S.no Ultimate analysis Input Values Units 1 Carbon 23.5 % 2 Hydrogen 3.25 % 3 Oxygen 21.75 % 4 Ash 1.5 % 5 Moisture 50 % 6 Sulphur 0 % 7 Nitrogen 0 %
Total 100 % GCV 2272 Kcal/kg Ultimate analysis of coal
S.No Ultimate analysis Input Values Units 1 Carbon 55.4 % 2 Hydrogen 4.91 % 3 Oxygen 20.25 % 4 Ash 2.0‐3.0 % 5 Moisture 10 % 6 Sulphur 0.81 % 7 Nitrogen 0.95 % Total 100 %
GCV 5545 Kcal/kg
M Because the chapter on the * Environment Management Plan1 (chapter 5) cannot be relied upon for any purpose whatsoever, in view of the fact that the analysis of the existing environmental parameters is shoddy and furthermore the assessment of the impacts of the proposed project have not even been identified or scientifically evaluated.
N Because, as per the EIA notification 2006 'deliberate concealment, and/or submission of false or
misleading information or data which is material to screening or scoping or appraisal or decision on the application shall‐make the application liable for rejection, and cancellation of prior environmental clearance granted on that basis'. In the instant case the project proponents are guilty of several material suppressions that vitiate the entire process.
No comment O Because the Draft EIA Report falls woefully short of the standards set in the 'Technical EIA 'Guidance
Manual for Distilleries' prepared for the Ministry of Environment and Forests by IL&FS Ecosmart Ltd EIA report was made based on the Terms of Reference (TOR) issued by MOEFCC vide letter no.
F.No.J‐11011/565/2010‐IA II (I) dt. 23.03.2011.
P Because, misleading and wrong Information amounts to fraud and any decision made on the basis of such fraudulent information is liable to be set aside with exemplary cost
No comment.
Q Because although there are more than 15 Gram Panchayat consisting of scores of villages and several urban conurbations within a 10 km radius of the proposed project, information in regard to the public hearing was only provided to the Makavalli Gram Panchayat, hence denying all other affected persons the right to participate in these proceedings. Further even according to the minutes of the public hearing a copy of the draft EIA Report was only displayed at the office of the Makavalli Gram Panchayat. In this regard, reference could be drawn to Annexure ‐ A15, wherein the Chowdenahalli Gram Panchayat passed a resolution dated 10/08/2012 which was submitted to the KSPCB, wherein it was noted that all 13 villages coming under the Gram Panchayat limits, which are adjacent to the proposed plant will be affected by the project
The notification of the public hearing was advertised in English (The Hindu) and Kannada (Prajavani) on 08.11.2011. The public hearing was conducted on 09.12.2011, chaired by the district commissioner (collector), Mandya district. The public hearing was attended by over 100 people of the local villages along with the local public representative MLA of Krishnarajpet Taluk. The minutes of the meeting reflect various concerns expressed during the public hearing. The honourable NGT observed the following; “hence, the contention put forth by the appellant’s side that the public hearing was not conducted as contemplated under the EIA notification, 2006 is without force and has to be rejected".
R Because even the villagers at Makavalli village only became aware of the said public hearing only a few days before the same, in contravention of the EIA Notification, 2006, The persons were also not informed that the same was a public hearing which was an opportunity to raise objections, but merely as a meeting that they were to attend. Further, even during the meeting, the Deputy Commissioner informed them that this was not the final meeting, and a subsequent meeting would be held to take a decision in regard to the proposed project
The notification of the public hearing was advertised in English (The Hindu) and Kannada (Prajavani) on 08.11.2011. The public hearing was conducted on 09.12.2011, chaired by the district commissioner (collector), Mandya district. The public hearing was attended by over 100 people of the local villages along with the local public representative MLA of Krishnarajpet Taluk. The minutes of the meeting reflect various concerns expressed during the public hearing. The honourable NGT observed the following; “hence, the contention put forth by the appellant’s side that the public hearing was not conducted as contemplated under the EIA notification, 2006 is without force and has to be rejected".
S Because the draft EIA report is available only in English, and not in the local language, i.e. Kannada, in contravention of the EIA Notification, rendering the entire process of public consultations a mere formality. Pertinently, the fact that the draft EIA Report was not available in Kannada was specifically raised in the public hearing by one of the speakers, and the same has neither been" denied nor addressed.
The notification of the public hearing was advertised in English (The Hindu) and Kannada (Prajavani) on 08.11.2011. The public hearing was conducted on 09.12.2011, chaired by the district commissioner (collector), Mandya district.
The public hearing was attended by over 100 people of the local villages along with the local public representative MLA of Krishnarajpet Taluk. The minutes of the meeting reflect various concerns expressed during the public hearing. KSPCB informed NGT that the proponents have to submit the summary documents in both English and Kannada while EIA report is submitted in English. The honorable NGT observed the following; " hence, the contention put forth by the appellants side that the public hearing was not conducted as contemplated under the EIA notification, 2006 is without force and has to be rejected".
T Because the entire draft EIA report was not made available to the local populations for reference before the public hearing was held, due to which the public hearing was rendered a mere formality and their participation mere tokenism. The lack of critical and correct information suppressed by the project proponents clearly reveals their deliberate and intentional strategy to scuttle the entire process and efforts of environmental protection.
The honorable NGT observed the following; " hence, the contention put forth by the appellants side that the public hearing was not conducted as contemplated under the EIA notification, 2006 is with out force and has to be rejected".
U Because, the public hearing was not conducted in compliance with the EIA notification 2006 and orders of various Courts. Persons from other affected villages in about 15 Gram Panchayats and numerous towns were not informed about the public hearing and hence were denied their right to participate in the same.
The honorable NGT observed the following; " hence, the contention put forth by the appellants side that the public hearing was not conducted as contemplated under the EIA notification, 2006 is without force and has to be rejected".
V Because the minutes of the public hearing have not been prepared in accordance with law and instead have been drafted in the confines of the Deputy Commissioner, contrary to Section 6.4 of Appendix IV of the EIA notification that states that: "...The summary of the public hearing proceedings accurately reflecting all the viexos and concerns expressed shall be recorded by the representative of the SPCB or UTPCC and read over to the audience at the end of the proceedings explaining the contents in the local/vernacular language and the agreed minutes shall be signed by the District Magistrate/ District Collector/Deputy Commissioner or his or her representative on the same day and forwarded to the SPCB/UTPCC concerned."
The honorable NGT observed the following; " hence, the contention put forth by the appellants side that the public hearing was not conducted as contemplated under the EIA notification, 2006 is with out force and has to be rejected".
W Because, the manner in which the approval has been granted clearly reflects non‐applicajtion of mind to relevant considerations, and a perusal of the records reveals that the whole effort has been to justify the project without these considerations. Few examples as an illustration are provided below:
There was no mention of the outcome of the public hearing in the EAC minutes and therefore
there was no detailed scrutiny. As per the EIA notification 2006, "Appraisal means the detailed scrutiny by the Expert Appraisal Committee or State Level Expert Appraisal Committee of the application and other documents like the Final EIA report, outcome of the public consultations including public hearing proceedings, submitted by the applicant to the regulatory authority concerned for grant of environmental clearance." However, the EAC has not done a detailed scrutiny of the 'outcome of the public consultations including public hearing procedures'
Copy of the presentation made to the EAC is enclosed.
The EAC has not discussed the present pollution being caused by the very same industry Copy of the presentation made to the EAC is enclosed.
X Because, the approval granted and the proceedings of the EAC reveals non‐application of mind and
also is contrary to principles of administrative law which requires that reasons be given for every decision by‐a public authority
No comment.
Y Because, the manner in which the EAC dealt with the issue reveals a casual and lackadaisical No comment.
Z Because the Environmental Clearance granted is based on false and fabricated information, which has
been blindly believed, despite I objections being raised against the same No comment.
AA Because there is no compliance with the Flyash notification, when the draft EIA states that about 40
tones/day would be generated from the Cogen plant during off season (page 128 of Draft EIA). The proposal is for a cogeneration plant of 30 MW using a combination of 15:85 of coal and bagasse.
The fly ash notification is applicable for TPP's that utilize 100% coal.
BB Because the water requirements for the proposed distillery, cogeneration and power plants are sought to be met entirely from the Hemavathi river flowing nearby which is impermissible in view of the fact that the 3rd respondent only has permission to draw water from the Hemavathi river directly for the purposes of running the sugar factory only. Further, it is the major source of drinking water for K.R. Pete taluk. Hence, the allocation for the proposed project is also contrary to the National Water Policy, 2002 as per which the water allocation priorities should be as follows; • Drinking water • Irrigation • Hydro‐power • Ecology • Agro‐industries and non‐agricultural industries • Navigation and other uses
Water requirement after expansion is 2850 m3 per day is well within the permission accorded by Govt. of Karnataka. Copy of permission to withdraw water from Hemavathi river is enclosed at Annexure ‐ V
CC Because the project proponents have already begun construction activities towards establishment of the project without even securing all the necessary clearances, permissions .and NOCs including the Consent for Establishment from the Karnataka State Pollution Control Board.
Consent for Establishment was obtained for expansion from KSPCB vide letter No. PCB/111/HPI/2011/93 dated 24.04.2013 and the erection of co‐generation plant is completed while the construction of distillery is yet to be commenced. We have also obtained the permission from the honorable NGT to conduct test run the co‐generation plant, however we have not completed the test run. (Photographs enclosed)
ANNEXURE – II: Land Use and Land Cover Map
ANNEXURE – II: Land Use and Land Cover Map
ANNEXURE – III: Layout Showing Baggase Storage Shed
ANNEXURE – IV: Updated Socio Economic Data of the Impact Area Population Distribution – Study Area
Category kms Total 1‐3 3‐5 5‐7 7‐10
Total Population 7534 9732 24208 72075 113549Total Population – Male 3819 4915 12128 36111 56973Total Population – Female 3715 4817 12080 35964 56576Population <6 years 790 924 2420 7286 11420Male <6 years 400 469 1223 3719 5811Females < 6years 390 455 1197 3567 5609Scheduled Caste Population ‐ Total 1126 942 3439 9191 14698Male – SC 584 482 1735 4565 7366Female – SC 542 460 1704 4626 7332Scheduled Tribe Population Total 317 83 420 2248 3068Male – ST 158 42 212 1117 1529Female – ST 159 41 208 1131 1539
Literacy Study Area
Category kms Total 1‐3 3‐5 5‐7 7‐10
Total Population 7534 9732 24208 72075 113549Total Population – Male 3819 4915 12128 36111 56973Total Population – Female 3715 4817 12080 35964 56576Population <6 years 790 924 2420 7286 11420Male <6 years 400 469 1223 3719 5811Females < 6years 390 455 1197 3567 5609Total Literates 4636 5829 15258 47162 72885Male –Literates 2714 3413 8639 26211 40977Female – Literates 1922 2416 6619 20951 31908Total Illiterates 2898 3903 8950 24913 40664Male –Illiterate 1105 1502 3489 9900 15996Female – Illiterate 1793 2401 5461 15013 24668
Employment ‐ Study Area
Category kms Total 1‐3 3‐5 5‐7 7‐10
Total Population 7534 9732 24208 72075 113549Total Population – Male 3819 4915 12128 36111 56973Total Population – Female 3715 4817 12080 35964 56576Total Workers 3403 4181 11990 32859 52433Total Workers – Male 2513 3133 7909 22641 36196Total Workers – Female 890 1048 4081 10218 16237Total Main Workers 2822 3568 9642 25618 41650Main workers – Male 2361 2919 7369 19984 32633Main Workers – Female 461 649 2273 5634 9017Total Marginal Workers 581 613 2348 7241 10783Marginal Workers – Male 152 214 540 2657 3563Marginal Workers – Female 429 399 1808 4584 7220Total Non Workers 4131 5551 12218 39216 61116Non Workers – Male 1306 1782 4219 13470 20777Non Workers – Female 2825 3769 7999 25746 40339
Main workers Study Area Category kms Total
1‐3 3‐5 5‐7 7‐10 Total Population 7534 9732 24208 72075 113549Total Population – Male 3819 4915 12128 36111 56973Total Population – Female 3715 4817 12080 35964 56576Total Main Workers 2822 3568 9642 25618 41650Main workers – Male 2361 2919 7369 19984 32633Main Workers – Female 461 649 2273 5634 9017Total Cultivators 1977 2415 6061 12289 22742Cultivators – Male 1805 2101 4978 10313 19197Cultivators‐ Female 172 314 1083 1976 3545Total Agriculture Labor 377 902 1633 4614 7526Agriculture Labor – Male 179 611 873 2663 4326Agriculture Labor – Female 198 291 760 1951 3200Total Household Workers 70 9 164 376 619Household Workers – Male 65 9 136 267 477Household Workers – Female 5 0 28 109 142Total Others 398 242 1784 8339 10763Others – Male 312 198 1382 6741 8633Others – Female 86 44 402 1598 2130
Land Utilization Pattern
Category kms Total Area,
Ha 1‐3 3‐5 5‐7 7‐10 Forest Land 19 145 304 173 641 Area not available for cultivation 276 332 889 2520 4017 Cultural Waste Land 467 969 1028 3080 5544 Total Irrigated Land 874 781 2175 4156 7986 Un Irrigated Land 873 1645 2313 6066 10896 Total 2508 3872 6709 15995 29084
PERMISSION FOR THE WITHDRAWAL OF WATER
PERMISSION FOR THE WITHDRAWAL OF WATER
