Sarma raises objections to Masulipatnam hearing on 12th

Visakhapatnam: EAS Sarma, former secretary to government of India, has raised objections to project proposed about which a hearing is scheduled at Machilipatnam on 12 Aprile 2021. He has written a letter to R.P. Gupta, secretary, Ministry of Environmnt, Forsts & Climate Change (MEFCC) with a copy marked to AP government chief secretary Adityanath Das and chairman, APPCB, AK Parida. His first objection was holding a hearing at time when the Covid-19 second wave brought in more dangerous conditions. His main objection to holding hearing based on Environment Impact Report which is inadequate and misleading. The proposed onshore oil and gas development and production from KG/ONDSF/KAZA/2018 Block by Vendanta limited is fraught with problems, Sarma warned.  He expressed concern about the radioactive exposure doing the operations. Here is the full text of the letter:

To
Shri R P Gupta
Secretary
Ministry of Environment, Forests & Climate Change (MEFCC)
Govt of India
Shri Adityanath Das
Chief Secretary
Govt of AP
Shri A K Parida
Chairman
APPCB

Dear S/Shri Gupta/ Das/ Parida,

I understand that APPCB and the Krishna district administration have scheduled a public hearing at Masulipatnam on 12-4-2021 in connection with the proposed Onshore Oil and Gas Development & Production from KG/ONDSF/KAZA/2018 Block, Krishna District, Andhra Pradesh By Vedanta Limited. (Division: Cairn Oil & Gas). 

I have the following objections which may be taken on record.

1. The second wave of COVID 19 has broken out in a highly virulent manner across the country and across AP State with a much higher virus load per case and a much higher rate of transmission from person to person. The new mutants, some of which may not get contained by the available vaccines, are understood to lead to a much higher rate of hospitalisation and perhaps mortality. In view of this, it is imprudent to conduct a public hearing now, which in my view, will open up an avoidable opportunity for the virus to spread far and wide in Krishna district. 
2. Though the Union Home Ministry and the MEFCC have issued clear advisories on the norms to be complied with in regard to social distancing, an upper limit to public gatherings, mask wearing and sanitation, the district administration will not be able to comply with the same as the very nature of a democratic public hearing process requires an unlimited opportunity for each and every one to take part in the consultation process. There are persons with co-morbidity and also senior citizens who are not advised to attend the hearing in person and each one of them should be provided an opportunity to participate at the hearing through the internet. Depending on the number of persons desirous of taking part in the consultation process, subject to the limit of 100 persons per assembly, the public hearing should be conducted for as many days as needed. Also, since there are severe travel restrictions, the consultation process will have to be held at each village to make it meaningful. It is doubtful whether APPCB and the local administration will be able to comply with these norms. If they fail in any respect, they will attract the liability for making the public hearing a “super spreader” endangering the lives of the people, an offence punishable under the relevant provisions of the national disaster management law and Sections 269 & 270 of the Indian Penal Code (endangering the lives of the people through the spread of dangerous infection). I earnestly suggest that APPCB should call off the public hearing rather than taking such an undue risk.
3. The EIA study report on the project, as prepared by the Consultant, is inadequate and misleading. 
4. It fails to comply with the requirements laid down by the Director General of Hydrocarbons (DGH), Ministry of Petroleum & Natural Gas (MPNG). For example, the enclosed guidelines (http://dghindia.gov.in/index.php/policy_doc) clearly indicate that naturally occurring hydrocarbons including shale layers contain the radioactive isotopes of Uranium, Lead and Potassium. The relevant portion of the guidelines state “Naturally Occurring Radioactive Material (NORM) describes radioactive elements that are found in low concentrations in the earth’s crust. Shale rocks typically contain many different kinds of radioactive isotopes, such as uranium, lead, or potassium. NORM also exists in air, water, soil and rock. Generally, NORM found in shale operations are below the common safety limits of radioactive exposure. The waste produced in shale gas operations will usually contain low levels of NORM and operators can protect nature and people against unwanted exposure by following regulatory guidelines and best practices established by international organizations. Flow-back water from hydraulic fracturing may contain significantly high levels of NORM, so Shale Gas developers have to ensure that NORM is managed appropriately, especially within their water management plan“. 
5. Exposure to low-intensity radiation can cause carcinogenic diseases. It is surprising that there is no mention of either the DGH or the above cited DGH guidelines anywhere in the EIA report. The only mention of the possibility of radioactive materials being present in the drilling waste finds place at Page xxi of the EIA report, where a reference to it has been made as “Details on solid waste management for drill cuttings, drilling mud and oil sludge, produced sand, radioactive materials, other hazardous materials, etc. including its disposal options during all project phases” The EIA report treats this risk in a summary manner and seeks to address it by saying, “Generation of drill cutting and drilling mud which will be unusable will be disposed of in 1 mm HDPE liner. Contaminated soil and drill cutting will be disposed of within the site through capping the waste pits by HDPE liner and soil cover” In other words, the EIA report is blissfully unaware of the guidelines issued by DGH and is equally unaware of the corrective steps to be taken.
6. Another serious omission in the EIA report is its total silence on the possibility and extent of land subsidence resulting from hydrocarbons extraction and the consequent pressure loss in the subterranean layers. A technical group headed by Dr Gopalakrishnan, appointed by DGH specifically for the KG Basin and later, the Delta Laboratory of Andhra University sponsored by ONGC, have both come to the conclusion that there will be land subsidence in the KG Basin resulting from the extraction of gaseous hydrocarbons. Land subsidence adversely impacts agriculture and inhibits drainage of irrigation water into the sea from agricultural fields. It can also result in salinity ingress from the sea waters into the ground water aquifers. There are huge economic losses that are associated with this. Also, land subsidence in the KG Basin has been a matter of pending judicial scrutiny in a case before Hon’ble AP High Court (WP No. 13341/2008) in which both the Central Ministries and the State government are respondents. To ignore such an important aspect of hydrocarbons extraction in the KG Basin implies the casualness with which the report has been prepared and its inadequacy. Such a report will surely mislead the public.
7. There is another serious omission in the EIA report on the risks associated with natural gas/ shale gas extraction. Last year, there was a disastrous blow-out and a fire at Baghjan in Assam at a field being developed by OIL India. The fire could not be put out for 173 days. It caused loss of property, injuries and displacement of the people. Not mentioning this anywhere in the EIA report shows that the project proponent has suppressed information that is vital for a meaningful public hearing.
8. The DGH guidelines also reveal that natural gas/ shale gas extraction are highly water intensive. Use of large quantities of water in the KG Basin which has already come under water stress according to the Central Ground Water Board will adversely impact paddy cultivation which in itself is critically dependent on water. This will have adverse economic and social implications. The socio-economic costs have not been assessed in the EIA report adequately.
9. Holding a public hearing on the basis of such an inadequate and misleading EIA report will defeat the very purpose of arranging a public consultation process.
10. In addition, Scientists for People have analysed the EIA report in much greater detail and pointed out its lacunae, which I feel should be taken seriously.

In view of the above concerns, I request you to 

(i) call off the public hearing

(ii) revoke the EIA report in its present form and order an EIA study afresh.

Regards,
Yours sincerely,
E A S Sarma
Former Secretary to GOI
Visakhapatnam
7-4-2021