To, Date: 31 August 2021 The Chairman, Haryana State Pollution Control Board, C-11, Sector 6, Panchkula Subject: Objections of the Aravalli Bachao Citizens Group against the proposed waste to energy plant, its further expansion at Bandhwari landfill site, Gurugram and the public hearing on 31 August 2021 being conducted in violation of the EIA Notification 2006. WHY PUBLIC HEARING NEEDS TO BE DECLARED NULL & VOID AND A NEW PUBLIC HEARING NEEDS TO BE CALLED FOR AFTER A MONTH? Aravalli Bachao Citizens Group representing thousands of citizens from Gurugram, Faridabad, Delhi, other NCR cities and across India objects to the public hearing that is being held on 31st August 2021 in violation of the rules of the EIA Notification 2006. The attached Public Hearing Notice issued by the Haryana State Pollution Control Board (HSPCB), Panchkula clearly states that the Executive Summary of the project and the EIA study will be available on the HSPCB website ( hspcb.gov.in ) and the offices of the Deputy Commissioner of Gurugram, Municipal Corporation Gurugram, Zila Parishad Gurugram and Regional office of the Haryana State Pollution Control Board in Vikash Sadan, Gurugram. According to Appendix 4 of the EIA Notification 2006, copy of the EIA report needs to be made available to the public 30 days prior to the date of the Public Hearing so that sufficient time is given to citizens to study the document and give their views. The EIA Notification also states that the Executive Summary of the EIA report needs to be translated in local language and be made available to the public 30 days prior to the date of the Public Hearing. Both these criteria have not been met for the Public Hearing called on 31st August 2021 as until 26th August 2021 evening, the required documents were not available on the HSPCB website. In Covid pandemic times when people are being advised by the government to avoid going to public places, accessing and studying the documents online is the safest and most convenient way for citizens to give their suggestions / objections to the said project. In blatant violation of the law, HSPCB has failed to give this option to the public. Aravalli Bachao team members spoke to the office of the Deputy Commissioner on 27th August 2021 to check if these documents are available at this office. We were told that they do not have these documents in their office when according to the Public Hearing Notice these documents should be available in the DC Gurugram’s office for the public to view. After Aravalli Bachao team’s visit to the Regional office of HSPCB at Vikash Sadan in Gurugram on the evening of 26th August 2021 and after submitting our letter demanding cancellation of the Public Hearing, on 27th August 2021 (4 days prior to the date of the Public Hearing on 31st August 2021), the required documents were uploaded on the HSPCB website. So, instead of the mandatory 30 days period required to be given by law, the government authorities in Haryana have only given the public 4 days to go through the required documents. How are citizens expected to go through 400+ pages of the EIA report in just 4 days, analyse its implications and give suggestions / objections on the Public Hearing scheduled on 31st of August 2021? Aravalli Bachao Citizens Group wrote an email to the Haryana government authorities on 27th August 2021 demanding cancellation of this Public Hearing scheduled on 31 August 2021 which is in violation of the EIA Notification 2006 and demanded that this be held after a month’s time which will give citizens the required time under law to study the said documents. Also, all the offices mentioned in the Public Notice should keep copies in English and Hindi of the Executive Summary of the project and the EIA report for the public to go through. Copy of this email is attached herewith. In the last 2 days, citizens have sent 213+ emails to the Haryana State Pollution Control Board and the Haryana government authorities demanding cancellation of this public hearing on 31st August 2021. This link shows the numbers. Image of screenshot is attached. http://letindiabreathe.in/cancelWTEHearingSaveAravallis Since HSPCB is still going ahead with the public hearing in violation of the law, Aravalli Bachao Citizens Group will list our objections to the proposed project. WHY THE PLAN TO CONSTRUCT A WASTE TO ENERGY PLANT IN THE ARAVALLIS NEEDS TO BE CANCELLED? Aravalli Bachao Citizens Group strongly condemns the decision of the Haryana government to operate the polluting Bandhwari landfill in the ecologically fragile Aravallis and their plan to build a polluting waste to energy plant in the Aravalli forest. OBJECTION 1: Site for the proposed waste to energy plant at Bandhwari is in the eco sensitive Aravalli belt which sustains life in India’s National Capital Region A waste to energy plant releasing toxic emissions and bottom ash cannot be constructed in NCR’s green lungs and key water recharge zone. According to the Central Ground Water Authority, this area of the Aravallis where the Bandhwari landfill is situated and the waste to energy plant is proposed to be built is a very critical water recharge zone for the extremely water stressed cities of the National Capital Region. Bottom ash generated by waste to energy plants is extremely toxic and must be disposed in a properly built hazardous treatment facility. However, in India, it is common practice for waste to energy plants to dump this toxic ash in the open thereby polluting our land, surface water bodies, ground water and air. Toxic ash coming out of the proposed waste to energy plant at Bandhwari will completely destroy the surface water bodies in the Aravalli forest, pollute the air and contaminate the underground water aquifers feeding the NCR cities threatening the life of millions of residents living in India’s National Capital Region. OBJECTION 2: Site for proposed waste to energy plant at Bandhwari is a wildlife rich zone This stretch of the Aravalli forest where the waste to energy plant is being proposed at Bandhwari is very rich in wildlife acting as a wildlife corridor between Asola Bhatti wildlife sanctuary in Delhi and Sariska wildlife sanctuary in Rajasthan. A survey of Aravalli forests of Gurugram, Faridabad and Delhi conducted in 2019 by the Centre for Ecology Development and Research (CEDAR) revealed that these forests are home to a rich diversity of wildlife especially rare native species of the Aravallis such as Honey Badger, Indian Fox, Hyena, Ruddy Mongoose, Grey Langur etc. Two species - the Leopard and the Honey Badger are classified as endangered under Schedule I of the Wild Life (Protection) Act while three of the meso-carnivore species found in the region are thought to be declining in the northern Aravallis and in other parts of India. These are the Golden Jackal, Jungle Cat and Ruddy Mongoose. A survey by the Wildlife Institute of India in the Haryana Aravallis, in 2017 had also shown significant presence of wildlife, including Leopards, Hyenas, Jackals, Nilgais, Porcupines, Palm Civets, Rhesus Macaques, Reptiles and Birds in this region. OBJECTION 3: Site for building waste to energy plant is close to Mangar Bani, NCR’s last remaining patch of original Aravalli native forest and the place where the recent discovery of Palaeolithic cave paintings that are among the oldest in India has been made. a) Ecological importance of Manger Bani: For centuries, residents of Manger village near Bandhwari where the waste to energy plant is being proposed have revered the vegetation in the grove and abstained from cutting the trees. As a result, the grove hosts the best-preserved vegetation of Aravallis in Haryana such as native forests of Dhok, Salai etc. Mangar Bani is also the primary pathway for the north-south movement of wildlife. It connects Damdama lake in the south of Gurugram to Asola Bhatti wildlife sanctuary in the north. Signs of leopards have been spotted regularly in the valleys and paths of Mangar Bani. Apart from mammals, Manger Bani boasts a rich diversity of birds reflecting its “high conservation value”. A year-long survey of birds carried out in 2019 by the Centre for Ecology Development and Research (CEDAR) found that the forests of Mangar host 219 species of birds. Most of these are not very frequently seen in other dry forests in NCR. These include rare species such as the Grey-Bellied Cuckoo, Crested Bunting, Tickell’s Blue Flycatcher, Eurasian Wryneck, Crested Serpent Eagle, Indian Pitta, Red Munia, White-Bellied Drongo and Common Woodshrike. Five “nationally endangered raptor species” including King Vulture and Egyptian Vulture, and six bird species that have been showing a “national-level decline” including the Yellow Crowned Woodpecker and Short-Toed Snake Eagle are also found to be “thriving” in the Mangar landscape. Conservation of Mangar Bani, along with the surrounding Aravalli forests is critical for maintaining NCR’s native flora and fauna biodiversity. A polluting waste to energy plant at Bandhwari, close to Manger Bani is a huge threat to the Aravalli forest and its rich wildlife. b) Historical and cultural significance of Manger Bani: In the summer of 2021, archaeologists have discovered 20,000 to 30,000 year old cave paintings close to Mangar Bani. The cave paintings site is extremely close to Bandhwari where the waste to energy plant is being proposed. These paintings belong to the Upper Palaeolithic age, which could potentially make them one of the oldest cave arts in the country. Unlike Central India and other places that are rich in rock paintings, no rock paintings have been found in Aravallis until now.