To: The Public Hearing Committee

c/o District Environmental Engineer

Tamilnadu Pollution Control Board
Maraimalai Nagar, Kanchipuram District

Sir:

Subject: Rejection of proposal of Corporation of Chennai to process MSW in Pallikaranai

marshlands in violation of MSW Rules, 2000

I register my opposition to the proposal of the Corporation of Chennai to process 1400 tpd of MSW at a
site within the Pallikaranai Marshlands in Perungudi area. My opposition stems from the following
concerns:

1. The Pallikaranai marshlands have shrunk from the 6000 hectare spread 30 years ago to less than
a tenth of the size. Encroachments, including residential areas, IT companies (including of
major software houses), Corporation of Chennai and MetroWater's sewage station have
contributed to this. The Pallikaranai marshlands serve at least three critical functions:
a) as habitat for 126 bird species, 141 plant species, 46 freshwater fish species, 15 species of marine
fish, 20 butterfly species and 8 mammals.
b) as flood mitigator
c) as the largest freshwater reservoir and natural rainwater harvesting and groundwater recharging
system.

The proposal is to use this site for the above stated purpose for the next 25 years at least will ensure
that the already compromised ability of the marshlands to fulfil these functions is further threatened.

2. The proposal is discriminatory and unfair to the people living in the vicinity of the facility. It is
not acceptable to burden people with garbage brought in from other areas. Indeed, this principle
is enshrined in the Municipal Solid Waste Rules, 2000, which encourages source segregation by
generator of the garbage, and decentralised treatment.

3. The proposal is illegal and runs counter to the Municipal Solid Waste Rules, 2000. I do realise
that illegality is merely a minor issue, especially considering that the Corporation of Chennai
has been dumping mixed waste illegally in the wetland for decades now, and very important,
and powerful people are party to the violations.

The proposal is illegal on at least three counts:

a) It encourages generators of garbage to deliver mixed waste. Rather than promote source segregation
(as per Para 1(2) and 1(3) of Schedule II) and decentralised treatment closer to source, the project
promotes mixed waste processing. The Rules enjoin the local body to collect only source-segregated
waste and avoid the processing of mixed waste at waste facilities. Here, the Corporation of Chennai
proposes to process mixed waste for the next 25 years in Pallikaranai.
b) The project is proposed to be located near a residential area and inside the Pallikaranai marshlands
which is a water body. According to Schedule III (Siting Guidelines) of the MSW Rules, 2000, “the
landfill site shall be away from habitation clusters, forest areas, water bodies monuments, National
Parks, Wetlands and places of important cultural, historical or religious interest.”
c) The Committee of Experts appointed by the Madras High Court in the case Sri Sai Nagar Residents
Welfare Association v. State of Tamilnadu has recommended against the project stating: “. . .the present
site is not suitable for dumping of municipal solid waste, as also not suitable for any other activity, and
that it needs remediation and that the siting of the dumpyard and the handling of waste is in violation of
the Municipal Solid Waste (Management and Handling) Rules 2000 framed under the Environment
Protection Act and the Ramsar Convention on Wetlands (1971)." The same committee headed by Ms.
Sheela Rani Chunkath concluded that the current proposal of the Corporation of Chennai is
"environmentally unsound, is a cause for great concern to public health and cannot be legally sited
within the Pallikaranai marsh."

4. The proposal will discourage citizen initiatives to reduce waste and opt for decentralised
treatment of locally generated MSW. The Corporation is signing a contract with the
Concessionaire M/s Hydroair Tectonics guaranteeing them 1400 tpd of MSW at the facility
gate. Indian wastes have about 60 percent by weight of organic, biodegradable material. Any
attempts by residents to compost their own biodegradable wastes at apartment or
neighbourhood level will then result in a reduction of upto 60 percent by weight of wastes
leaving the neighbourhood. This will mean the Corporation will not have sufficient wastes to
meet its contractual obligations. Under such a situation, the Corporation is unlikely to extend
any cooperation to citizen initiatives to reduce wastes or deal with it.

5. The Public Hearing is Illegal because the statutorily required documents that need to be made
available to the public are not available. Appendix IIIA of the EIA Notification, 2006, lays out
the format and contents of a Summary of the EIA document as recognised by the Notification.
Only summaries that meet the requirements laid out in this Appendix are permissible for
submission to regulatory authorities and as summaries for the reference of members of the
public while seeking their comments. The document provided as the Executive Summary is a
reproduction of the company's marketing brochure for the project. Sections such as
“Environmental issues covered, Technology Relevance, Benefits to Corporation of Chennai and
RDF-Green Coal” are directly lifted from the Company's website
(www.hydroair.com/solid.html). The following mandatorily required information as prescribed
in Appendix IIIA are missing: a) description of the environment; b) anticipated environmental
impacts and mitigation measures; c) environmental monitoring program; d) additional studies;
e) project benefits; f) environment management plan. The absence of a proper summary renders
the Public Hearing illegal and meaningless, as the Public is being asked to comment on a
proposal whose details are not known.

6. The alleged “Summary” document does not provide any details about what waste specifically
will go into formation of Refuse Derived Fuels. Also, considering that mixed wastes contain
significant quantities of chlorinated plastics such as PVC, the project does not contemplate how
PVC will be prevented from entering the stream destined for preparation of RDF. Under Indian
incineration guidelines, it is illegal to burn PVC containing wastes.

7. The RDF plant, during processing, and the RDF during combustion of the fuel will emit high
levels of toxic chemicals including dioxins, furans, PCBs and heavy metals such as mercury.
There is no assessment or mention of an assessment of these emissions. There is no mandatory
Environmental Management Plan for dealing with process emissions and emissions during
burning. It is not sufficient to point out that the RDF will be burnt elsewhere. Rather, an
assessment would have to be provided of the impacts at the point of burning, and its
 management.

8. The project contemplates receiving mixed wastes at the facility. By the time wastes are
collected from all over the city and delivered at the factory, and by the time such wastes are
segregated, there would already be a lapse of more than two days. During this time, anerobic
digestion would be well under way, and leachate generation is inevitable. Further, such
degradation would also leach out toxic contaminants from the non-biodegradable material –
such as mercury from fluorescent lights, other heavy metals from paints and batteries, solvents
and pesticides from household pest-killers. These contaminants will now reside in the organic
matter destined for composting. It is criminal to contemplate selling this compost as soil
conditioner or manure to unsuspecting farmers who may end up poisoning their consumers.

9. The project concessionaire lacks experience and has a bad track record. Hydroair Tectonics has
no track record in executing waste projects of this scale. Indeed, in 2008, the Goa Government
has issued a show-cause notice in regard to the now-defunct Rs. 65 lakh anerobic digester
installed by the company.

10. RDF and mixed waste composting are proven failures. In Vilappilshala, the Trivandrum
Municipality initiated mixed waste composting at a much smaller level than what is
contemplated here. This scheme is now an albatross around the neck of the Municipality, which
is left with tons of unusable compost, and a heavily contaminated site oozing leachates into a
river that supplies drinking water. The first WTE facility set up in Timarpur, New Delhi, in
1987 operated for less than 3 months in all, and was shut down because Indian wastes were too
rich in organic content and moisture. A more fine-tuned RDF plant in Vizag now operates with
RDF but has to burn auxiliary fuel. In other words, the RDF itself is not of sufficient calorific
value to burn on its own. Rather it requires additional fuel to help it burn.

I urge the Public Hearing Committee to recommend against this project, and encourage the Corporation
of Chennai to take people into confidence to initiate segregation and decentralised waste treatment
schemes. The Corporation will find that Chennai's residents will support these schemes enthusiastically.

Sincerely,

Nityanand Jayaraman
Resident of Besant Nagar
S45, 35th Cross, Besant Nagar, Chennai 600 090

Dharmesh Shah
Resident of Kalakshetra Colony
M106/4, 29th Cross, Besant Nagar, Chennai 600 090