On behalf of the National Oil, Gas, Mineral Resource, Power and Port Protection Committee, Bangladesh
Engineer? Sheikh Muhammad Shahidullah
Prof. Anu Muhammad, Member Secretary
October 18, 2016
The Honourable Prime Minister,
We respectfully address you with grave concern and anxiety. The people of Bangladesh today is sternly worried over the future of the Sundarbans, which not only happens to be the only protection barrage of the southern belt of Bangladesh, but also the largest Mangrove Forest of the world, as well as the most valuable ecological habitat of the country and the World Heritage Site. The joint venture of both India and Bangladesh to build a1320 MW capacity coal-fired power plant has caused much worry among the people of Bangladesh.
We have already written to the Honourable Prime Minister of Bangladesh regarding this. As India is the major partner of this project, we believe, as the head of the Indian government, it is fundamentally important for us to address also to you in this regard, mainly for two reasons.The Rampal Power Plant, officially known as the Maitree Super Thermal Power Project, is a joint venture project of BPDB of Bangladesh and NTPC Limited of India. As per the joint venture agreement signed between Bangladesh and India, NTPC is responsible for planning, building and operating the plant. Bharat Heavy Electricals Limited (BHEL) is now officially responsible for engineering, procurement and construction (EPC) of the Rampal Power Plant. Exim Bank, a state bank of India, has been officially selected for financing this project, whereas Coal IndiaLimited, most probably, is going to be appointed for supplying of necessary coal.
Secondly, if the Sundarbans, adjacent to the Bangladesh part is damaged, it would have a massive spillover effect on the Indian portion as well, affecting the lives and livelihood of the people of India living near Sundarban.
Based on studied opinion of asignificantly large number of local and international experts, it is obvious that this particular coal-firedpower plant would bring extensive destruction to the forest. It is also worth noting that, followingthe decision of building a power plant in Rampal, a range ofinfluential business groups and commercial projects havepierced into the same area. It is predicted that the cumulative effect of such commercial aggression would ultimately cause fatal destruction to the Sundarbans.
It is important to note that around 3 to 4 million people including forest and fishing folks are dependent on the Sundarbans and the adjacent water bodies for their natural livelihood. Around 40 million people live in the southerncoastal belt of Bangladesh. The power plant is ringing an alarm to the entire coastal community. Moreover, the damage would not be merely restricted to the Bangladesh portion of the Sundarbans. Around 5 million people living near to the Indian portion of the Sudnarbans would be put intograve danger too. Eventually, future generations from both nations would have to bear the deadly impact of the plant.
Obviously, we do not deny ?development?. Power grids are also vital to modern lives. However, what is not acceptable is the implementation of some environmentally deadly projects which would merely profit the vested interest groups at the cost of the people and environment.
You must be aware of the fact that ?this project has drawn huge criticism from both India and Bangladesh, and around the world. The UNESCO, the Ramsar Authority, the South Asian Human Rights Forum led by IK Gujral of India, along with other 150 various organizations have also opposed to the plant and demanded to scrap the deal.The Norwegian Council of Ethics has already withdrawn their fund from this controversial project.
Even the Minister of Finance of Bangladesh has admitted that inevitable environmental damage will be there, nevertheless the project must go on (15 February, 2016)1. We do not want to believe that it is the Government of India whois insisting on the project. Rather, we believe that the Government of India can play a vital role in saving the world?s largest Mangrove Forest by scrappingthiscontroversial project.
Honourable Prime Minister,
The plant site is located on North of the Sundarbans, only 14 kilometers away from its boundary and within merely 4 kilometers of the Ecologically Critical Area (ECA).This site is only 2 meters above the sea level. It obviously holds a key financial and operating risk given the fact that it falls within a tidal delta region which experienced a tidal surge with the height of 5 meters. EIA study itself further notes that the Rampal plant would be in the ?wind risk zone? of Bangladesh. It is worthy noting that this particular zone witnessed 16 cyclones in the past 25 years. We are deeply worried that the site?s location and elevation will be at extreme risk should sea levels rise or should an extreme weather event occur. In such events, the ash ponds – located near the Possur River – could easily be washed away putting the river at a serious ecological risk. The riveris, in fact, one of the vital water bodies that provides fresh water flow to the world?s largest mangrove forest.
The Indian EIA guideline 2010 itself disallows setting up of similar projects within 25 kilometers of ecologically sensitive areas of India, including forests, rivers, and sanctuaries.2 You must have been aware of the fact that due to such environmental consciousness of the Indian Government, a number of coal-fired plant and coal mining project has been called off by the Green Tribunal and the Ministry of Environment of India3. We would like to call for your attention that while moving forward with this project,the Indian company has violated all environmental rules and regulations of the Indian government itself.
For the production of electricity, the plant will annually consume 4.72 million tons of coal.4 The coal and other toxic and chemical materials required for the construction and operation of the power plant will be transported to the project site through the waterways of the Sundarbans. The transportation of coal (nearly 13 thousand tons per day) through the waterways of the Sundarbans holds dire prospect of coal spillage, ballast water, bilge water, oil spillage, lubricant, and garbage. For the next 30 years, the transportation of cargo and lighter vessels, and the loading and unloading of coal will indeed bring extensive damage to the ecology of the forest and the wildlife habitats.
To run the Power Plant, water of the Possur River will be withdrawn (at the rate of 9,150 m3/hour) and discharged (at the rate of 5,150 m3/hour) into it again after use witha varying temperature5. This will reduce the oxygen of the water and damage the fish stocks of the Possur River. The rising temperature, company admits at least 2C6, will also affect the entire ecosystem and biodiversity of the forest, including the Zooplankton, the Phytoplankton, and the marine ecology. If it continues for the next 25 to 30 years, the marine ecology and the biodiversity of the Possur River would be destroyed, as well as the hydrological characteristics of the river including its salinity front, salinity level, sedimentation pattern, and tidal behavior. Discharged water will also contain huge amount of Mercury if coal-washing is done as confirmed by the Authority.
The zoologists have shown concern that the toxic substances emitted from the coal-fired power plant including arsenic, lead, mercury, nickel, vanadium, beryllium, barium, cadmium, chromium, selenium, and radium are capable of contaminating the air and water to such an extent that it could harm the reproductive health system of the wild life animals and the species of the Sundarbans. The bird scientists are concerned that the coal-fired pollution may hamper the existence of at least 3 rare species of bird, which shelter in the Sundarbans.
The experts and engineers have long suggested that Ultra Super Critical Technology itself is only capable of reducing pollution only at a rate of 8 to 10 percent. Even if other pollutant reducing technology should be used, no record suggests that risk of pollution could be entirely eliminated.? For instance, the installation of FGD may reduce the risk of SO2 pollution, while increasing the chances of water pollution through the release of heavy chemical materials including Arsenic, Mercury, Selenium and Boron7. If low NOX Burner should be used, pollution could be reduced up to 40 to 60 percent, nevertheless, the rest of the toxin chemicals would remain hazardous enough to spoil the environment8. Though the authority has assured the use of FGD and ESP, the combined application of all such technology is capable of dropping thecontamination level merely up to 48 percent9. On the other hand, the risk of release of an extensive amount of Mercury still persists, as there is no mention of applying any technology in tender document that regulates or controls the release of Mercury into the forestry and water10.
In the last few years, a number of accidents in the water routes, including deadly oil spill had left its long term footprints on the sensitive forest lives. The current transportation system on the Sundarbans area itself is creating severe sound and water pollution around the forest ecology. Lately, some sensitive locations around the forest have been announced as ?endangered? for the Irrawaddy Dolphins by the Government of Bangladesh. The Prime Minister of Bangladesh previously suggested bringing a complete halt to the transportation routes in the Shela River. However, the attempt failed. In these circumstances, we simply cannot take further risk by allowing a 1320 MW capacity of coal-fired plant on the backyard of the Sundarbans. Our experience with institutional capability is also frustrating11.
A coastal belt, in general, survives on the resistant capacity of the mangrove swamps. For instance, extensive commercial establishments in the coastal bodies of the New Orleans state of the USA have ultimately damaged the natural flow of Mississippi river. Due to the vulnerability of these coastal belt areas, Hurricane Katrina could make unprecedented damage to the coastal areas of New Orleans. In Bangladesh, during Hurricane Sidr and Aila, the Sundarbans has largely protected the people and resources of the southern coast. If the Sundarbans is damaged, the people and the species of the entire coastal belt will be practically unprotected.
We would like to stress on the point that no deadly experiement should be taken when the Sundarbans is concerned. Rather we demand to cancel the project, along with every other pollution enhancingprojects and commercial activities around the Sundarbans. We also demand to bring a halt to the transportation of hazardous commodities around the Sudarbans. As Rampal power plant is not only a risk by itself, but alsohas consistently attracted a range of commercial ventures into the area; by scrapping the deal, the Indian government could play a crucial role in protecting the Sundarbans from all kind of forest damaging ventures.
The Sundarbans to us is not a subject of negotiation. Meanwhile, alternative locations and technology is available for power generation. Lately, the Srilankan government had cancelled a similar power plant deal with India (May 18, 2016)12. If Srilanka and India could scrap it, why not Bangladesh to prevent much bigger disaster?
Honourable Prime Minister,
We gratefully remember the contribution of India during the time of our liberation war in 1971. The people of Bangladesh have not forgotten the safe shelter that was provided by the people of India in a time of despair and misery. Nevertheless, it is also observed that the people of Bangladesh also hold much resentment towards the state of India due to its consistent measures of oppressive and humiliating policies. The Farakka dam, the upcoming dams along with the Indian river linking projects, border killing, the building of border fence, unfair trade agreements and loan terms, and the one sided transit deal are few Indian policies which have generated discontent in the minds of people of Bangladesh. And now it is the destructive power plant project.
We would like to stress on the point that people still expect solution of all earlier disputes, but if Sundarban is affected, the damage would be irrecoverable and there would be no turning back. The resentment and anger would stay for ever, the ?friendship? company will turn into permanent ?source? of hostility. We certainly do not want to create a condition as such. Rather we expect, for the sake of the friendship, the project should be called off. We believe, peaceful co-existence of the two nations could only be achieved through mutually respectable agreements and arrangements that would reflect the aspiration of both people in a fair and just manner.
Based on such aspirations, we hope that, you, as the Head of Indian government, along with our Prime Minister, would consider the genuine concerns of the people of Bangladesh and immediately scrap the Rampal Power Plant project.
Sincerely,
On behalf of the National Oil, Gas, Mineral Resource, Power and Port Protection Committee, Bangladesh
Engineer? Sheikh Muhammad Shahidullah, ?Convener
Prof. Anu Muhammad, Member?Secretary
References:
1.?Ittefak, 15 February, 2016
Rampal power plant to be commissioned despite risk to ecology
2.?Locations of thermal power stations are avoided within 25 km of the outer periphery of the following:
? metropolitan cities;
? National park and wildlife sanctuaries;
? Ecologically sensitive areas like tropical forest, biosphere reserve, important lake and coastal areas rich in coral formation;?
3. The need to preserve the Khajuraho temple, famous for its erotic sculptures, as well as nearby tiger and crocodile sanctuaries has prompted a government panel to hold off on clearing a?Rs.18,000 crore thermal power plant in Madhya Pradesh.
The National Green Tribunal (NGT) .. .. quashed the environmental clearance for the 3,600-MW thermal power plant proposed by IL&FS Tamil Nadu Power Company Limited in Cuddalore, on the grounds that no proper cumulative impact assessment was done.
Noting that a thermal power plant near human habitat and on agricultural land was not viable, a Central green panel has refused to give approval to the National Thermal Power Corporation (NTPC) to set up a 1320 MW coal-based project in Madhya Pradesh.
4. Rampal EIA, page 378
5. Rampal EIA, page 117.
6. ?Temperature of discharge water shall never be more than two degree Centigrade (2OC) above river water temperature?- Question To Answer From Rampal Authority
7. Cleansing the Air at the Expense of Waterways
8. AN OVERVIEW OF TECHNOLOGIES FOR REDUCTION OF OXIDES OF NITROGEN FROM COMBUSTION FURNACES, page-4
9.?https://netl.doe.gov/File%20Library/Research/Coal/ewr/mercury_-FGD-white-paper-Final.pdf
10. State-of-the-art technology for mercury control is sorbent injection in the boiler or in the flue gases followed by capture of the resultant particulates in a bag house. These technologies are simply missing in the tender document.
11. ?90,000 m3 polluted water flowing into rivers around Dhaka every day?. Banik Barta, 2 April, 2016
12. Sri Lanka scraps NTPC?s plan to build coal plant
