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10 Reasons Why Citizens Are Opposing Proposed WTE Plant At Bandhwari

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It was a rainy day. Umbrellas blocked the view of the project summary presentation made on a display screen. 150-200 attendees were concentrated at the front of the tent to make their voices heard and to be able to hear one another over the constant downpour. Some had umbrellas, most others were drenched by the rain falling through the tent. 

Picture of Bandhwari landfill on the day of the Public Hearing 2021
Picture of Bandhwari landfill on the day of the Public Hearing 2021

They had all come to attend the public hearing for the ‘proposed setup Integrated Municipal Solid Waste Processing Facility (IMSWM) with proposed expansion of Waste to Energy (WTE) plant from 15 MW to 25 MW capacity’ in Bandhwari village, Gurugram. The hearing was held on the 31st of August 2021 at the Bandhwari landfill site.

The project is being proposed by the Municipal Corporation of Gurugram (MCG), which has empanelled Ecogreen Energy Gurgaon Faridabad Pvt. Ltd as the project proponent. 

Panellists at the hearing were the Deputy Commissioner of the Municipal Corporation of Gurugram Yash Garg, Haryana State Pollution Control Board’s (HSPCB) regional officer of Gurugram, Kuldeep Singh, and Additional Commissioner Jaspreet Kaur. Representatives of Ecogreen – the concessionaire that has been managing the city’s waste since 2017 and many police officers were also present.

Also in attendance were residents, citizen groups  from various areas in Gurugram and surrounding villages who have been  opposing  the proposed project, as well as the conduct of its hearing on many counts:

1. Unlawful Conduct Of The Public Hearing

Citizens sent 232 emails to the HSPCB, demanding cancellation of the hearing since the Environmental Impact Assessment of the proposed project was made available online just four days before the hearing, instead of making it available in the public domain for 30 days prior to the hearing, as mandated by the EIA Draft Notification 2006.

“…Till 26th August 2021 evening, when we visited the HSPCB office at Vikas Sadan, the required documents were not available on the HSPCB website,” Neelam Ahluwalia from Aravali Bachao Citizens Group told Youth Ki Awaaz.

Kuldeep Singh, the regional officer from HSPCB said that as soon as they got to know that EIA was not available on the website on 26th August, they ensured it was uploaded.  “There was no case where someone requested for a copy of the EIA from any of the offices and we did not give it, it was available everywhere,” he said.

‘Water to Energy plant causes pollution. Waste segregation: recycle, composting (is the) only solution’- poster at the Public Hearing. Picture credits: Aravali Bachao Citizens Group
‘Water to Energy plant causes pollution. Waste segregation: recycle, composting (is the) only solution’- poster at the Public Hearing. Photo: Aravali Bachao Citizens Group

2. Inaccessibility Of The Public Hearing For Local Communities

Given India’s Draft EIA 2006, public hearings promise public consultation, ensuring the views of those who stand to be impacted by the project are taken into account. However, members of the local community deemed the knowledge about the public hearing itself and the project details inaccessible. 

Sunil Harsana, an environmental activist, wildlife researcher and resident of Mangar village, said, “When a Public Hearing is to happen, you advertise it in an English newspaper and you come and sit at the hearing. If you want to conduct a Public Hearing in the correct spirit, then why do you not visit the villages?

We have a population of thousands, of which 50% are our mothers and sisters who are unable to come here but are the ones who have to bear the brunt of the impacts of this waste… They are the ones facing all of the challenges because of this (landfill) in their daily lives, who will ‘hear’ their voices?

3. ‘Scientific Management’ And Other False Promises

In 2008, a delegation of sarpanches from around 40 villages demanded the cancellation of plans to construct the landfill. Their objections were related to concerns about groundwater and air pollution. Speaking with The Tribune, Municipal Commissioner at the time, Rajeev Sharma said that the harmlessness of the proposed project would be explained to the villagers and that the project would uphold environmental and social norms.

Fast forward to 13 years later, on the 7th of April 2021, the MCG was asked to pay INR 148 crore by the National Green Tribunal (NGT) as compensation for unscientific management of waste at the landfill site which has resulted “in continuing damage to the environment and public health”. 

At the public hearing, these assurances of ‘scientific management and the use of scientific technology were questioned –  both on the grounds of the poor track record of the MCG and Ecogreen, as well as the viability of the proposed WTE incineration plant in the Indian context. 

Harsana asked the authorities:  “You were just saying that this ‘WTE’ plant is a scientific technology. This scientific method you are talking about has completely failed….Your project began 15 years ago, and now there is a mountain of waste that you have erected, and you are lecturing us about science now? How can we accept this?” 

“15 years ago you made promises to us that you will appropriately manage the waste once you get it here, that you will give us jobs, and that you will not allow any kind of problems to arise. In today’s day,  poisonous water comes out of the trash- which in the language of you educated folks you call leachate, and you wash your hands off it. We know how many of our animals have died after drinking it, how many of our brothers, sisters and mothers have gotten cancer and died.

We do not have the financial ability to seek medical help for their cancer, but still, we are continuing to endure the suffering every day. Our animals are dying, the wild animals of this area are also dying. Who will even speak about wild animals- the poor wildlife does not give votes. Now you have come here with another ambitious plan because this is your experiment hall.

Despite people living here, they have no rights. You will come here, try and make electricity and if it fails you will leave and another 50m of waste will accumulate. I want to tell you that the lives of all those from the 10 villages nearby will become very difficult,” he said. 

Vaishali Rana, an environmental activist and resident of Gwal Pahari, commented that the residents had raised the same objections and suggestions during the Public Hearing for the 15 MW plant in 2018.

She said, “The only difference is that 3 years ago, we were talking about the water of 3 villages (Bandhwari, Mangar & Dera) being contaminated and now in today’s day it is on the records that the water of 5 villages is contaminated. There have been zero efforts from the Municipality…”.  She said that tests in the present day would be likely to show that the groundwater contamination from the leachate of the landfill has spread to further areas, such as Balola, Ghata, Sector 56, and even DLF Phase I.

From left to right: Mahesh Dayma- Councillor of Ward 30 Gurugram, Jaspreet Kaur- Additional Commissioner MCG, Yash Garg-Deputy Commissioner and Kuldeep Singh- Regional Officer of the Haryana State Pollution Control Board. Picture credits: Aravali Bachao Citizens Group
From left to right: Mahesh Dayma- Councillor of Ward 30 Gurugram, Jaspreet Kaur- Additional Commissioner MCG, Yash Garg-Deputy Commissioner and Kuldeep Singh- Regional Officer of the Haryana State Pollution Control Board. Picture credits: Aravali Bachao Citizens Group

4. Environmental Clearance For 15 MW Plant Obtained Based On False Information

As per an RTI filed with the Haryana Forest Department, the land intended for the construction of the plant is categorized as ‘Aravali Plantation’ and ‘Gairmumkin Pahad’, on which the ‘Aravali 1992 Notification is applicable’. Rana claimed that the MCG and Ecogreen had failed to mention this information in their application for the clearance of the 15 MW WTE plant, and thus the clearance had been obtained on false grounds. 

In response, Kuldeep Singh from HSPCB stated, “If any activity was undertaken here without Aravali clearance we will ensure the applicable action is taken against the MCG and the project proponent.”

Speaking to Youth Ki Awaaz, Vaishali further stated that the EIA of the proposed project fails to state that the area itself is critical wildlife habitat and corridor, as per studies published by the Wildlife Institute of India in 2017 and by the Centre for Ecology, Development, and Research (CEDAR) in 2019. These studies reveal that these areas have an even higher presence of wildlife than the notified sanctuary Asola Bhatti, yet receive no forest protection.

Harsana said, “Mangar Bani is the richest forest of the city, recognized by the government and it has 217 species of birds- if the WTE plant is built here, what will become of the lives of those birds and animals?… I am folding my hands and requesting you to keep this project away from us – we do not want your free electricity, we are fine with purchasing the government’s electricity.”

Picture of RTI provided by Vaishali Rana
Picture of RTI provided by Vaishali Rana.

5. Objections Raised By Communities Living In Proximity To Proposed Project Site

Residents from villages nearby expressed vocal opposition to the construction of the proposed project, on the grounds of severe health impacts of the mismanagement of the existing landfill by the MCG and Ecogreen over the years, along with an absence of any benefits or jobs. 

Rajkumar from Bandhwari village said, “When the landfill was constructed here, lots of promises were made that everything would be properly managed but till this day, none of those promises have been fulfilled. Hundreds of our people have died as a result of cancer, hundreds of our animals have died, our children are being born handicapped- we have not experienced a single benefit from this (landfill) till this day…and now planning is being done for the WTE plant, where the waste will be burned and we will be subjected to it.

We will not tolerate this, we have had enough of this.”

Mahesh Dayama, Councillor of Ward 30 Gurugram speaking at the Public Hearing
Mahesh Dayama, Councillor of Ward 30 Gurugram speaking at the Public Hearing. Photo: Bahaar Abbas

6. Viability Of Incineration Based WTE Plants In India

Monica Khanna Gulati, co-founder of NCR Waste Matters questioned the appropriateness of the technology choice of the WTE incineration plant. She said that these plants have not been commercially viable in India due to the extremely high cost of the electricity sold by them. And nor has the composition of India’s waste been suitable for the plant to run, given that more than 60% of it is organic and thus moisture heavy. She shared that attempts by these plants to process mixed waste have led to frequent breakdowns requiring expensive maintenance. 

7. Emissions And Health Impacts Of WTE Incineration Plants

Citizen groups strongly opposed the plant, on the grounds that WTE incineration based plants have a history of violating emission norms in India. Aravali Bachao stated that on numerous occasions the 3 incineration based WTE plants in Okhla in Delhi have been found releasing particulate matter, as well as cancer-causing gases such as dioxins and furans in excess of the Central Pollution Control Board (CPCB), ’s limits. They asked the authorities how the toxic ash generated by the plant would be managed since it is required to be stored in a separate landfill itself. 

Ruchika Sethi Takkar from Citizens for Clean Air said that the EIA report of the proposed plant itself notes that the levels of particulate matter (PM 2.5 and PM 10) in Bandhwari are already in excess of the limits set by CPCB. 

Dr. Sarika Verma, a military surgeon and resident of Gurugram said, “Every 4th child living in this city has an asthma issue and needs to use a nebulizer…It is already down in the records, that Gurugram is the most polluted city in the country- how many records do you want to break?.”

At Bandhwari landfill site. Picture taken by Hritik Bhatnagar
At Bandhwari landfill site. Photo: Hritik Bhatnagar

8. Absence Of Government Will And Implementation Of SWM Rules 2016

A representative of Ecogreen told the audience that they were proposing a 25 MW plant “because the 15 MW plant will be insufficient to manage the current waste that is accumulating”. 

Environmental groups and activists echoed recommendations from the Solid Waste Management (SWM) Rules 2016. They demanded that the municipalities enforce segregation at source and decentralized waste management systems at the ward level, instead of a centralized waste management system based on exorbitant and endlessly expensive technologies such as landfills and incineration based WTE plants.

These WTE plants which are environmentally ruinous, polluting, cause the loss of livelihoods of informal waste pickers and life-threatening health conditions to communities living in their proximity. 

Letters opposing the WTE incineration plant were submitted to the HSPCB by citizen’s groups and environmental NGOs such as Aravali Bachao Citizens Group, Citizens for Clean Air, NCR Waste Matters, Toxic Watch Alliance, Global Alliance for Incinerator Alternatives (GAIA), Vanashakti, Solid Waste Management Round Table, Students 4 Aravalis and by Dr Shyamala Mani, an SWM expert.

If you (MCG) are saying that there is no alternative way to manage this then you are in the wrong because the correct way of management has been given in the SWM Rules 2016.

In every sector and ward, in every society, why is the wet waste not being appropriately dealt with? The rules need to be strictly implemented by the Municipality over RWAs and Bulk Waste Generators (BWGs)…The Municipality is failing here, miserably,” Rana said at the hearing. 

Ruchika Sethi from Citizens for Clean Air, a collective of 90 RWAs, doctors, and mothers said that they had submitted a petition to the HSPCB against the proposed 15 MW WTE incineration plant in 2017.

She emphasized that 90% of what is being considered as waste are actually resources. She said that if decentralized waste management was followed, there would be no need for an incineration plant or tackling polluting leachate and emissions. She asked for the introduction of SWM by-laws in Haryana, as mandated by the SWMR, 2016.

Neelam Ahluwalia from Aravali Bachao said, “Indore has the same amount of waste generated as Gurgaon. If they are able to manage their waste through segregation, composting, biogasification, why can we not do the same in Gurgaon? ”

9. Wilful Ignorance For Livelihoods Of Informal Workers 

Around the world and even in Delhi, India informal waste pickers have protested against the construction of WTE incineration plants. These plants require dry waste in order to function. This brings them in direct competition with the informal waste sector whose livelihoods are dependent on recovering and recycling dry waste. 

Shashi Bhudahan from the Dalit Adivasi Shakti Adhikar Manch (DASAM) said, “Under the Prime Minister’s Swachh Bharat Mission, I am asking the municipality how many waste pickers have you provided with identity cards? How much waste have you composted at the ward level? How much waste have you ensured has been segregated?… I am asking on behalf of the waste pickers and the communities living in proximity to this site that the SWM Rules 2016 be implemented on the ground.”

‘90% of our waste are actually resources and can be recycled’- Ruchika Sethi Takkar of Citizens for Clean Air. Picture taken by Bahaar Abbas
‘90% of our waste are actually resources and can be recycled’- Ruchika Sethi Takkar of Citizens for Clean Air. Photo: Bahaar Abbas.

10. Objections On The Grounds Of Track Record Of Ecogreen, The Project Proponent 

Ecogreen Energy has been contracted by the municipalities of Faridabad and Gurugram for the collection and transportation of waste from the two cities to the Bandhwari landfill. Many attendees raised objections to the waste mixing practices of Ecogreen, claiming that they had personally witnessed them mix waste that had previously been segregated, as well as add mud to bulk up the quantities of waste collected.

Varun, a social worker, reasoned that this was because their payment or ‘tipping fee’ from the municipalities was based on the number of tons of waste collected by them. He asked, “How will they make electricity out of the mud?…”

Abhay Punia, the Vice President of Gurgaon’s Citizens Council (GCC) and General Secretary of NCR’s RWA collective, speaking on behalf of 700-750 RWAs said that they strongly oppose the WTE plant.

With regards to Ecogreen performance, he asked, “What have they been doing in the last 4 years? In the last 4 years, this (landfill) has gone from (a height) of 17m to 42m. They have made a mountain. Do they not have any shame on seeing this mountain? They have no right, they have dishonoured our municipal corporation, they should be expelled.”

Quoting news reports Rahul Khera, a composting expert said that since 2016 Ecogreen has been fined numerous times by authorities; 1.5 crores by the Municipal Corporation of Faridabad (MCF), 25 lakh by the HSPCB, 2.5 lakh by NGT. He shared that an RTI had revealed that MCG had fined Ecogreen on 400 instances.

He asked, “Why is such an agency which is continuously defaulting and being penalized by government agencies being given the responsibility of executing a task which requires a very high level of technical competency and the most important thing- ethics? How can we trust such an agency to set up a WTE plant which is a polluting incineration technology?”

Mahesh Dayama, Councillor for Ward 30 in Gurugram under whose jurisdiction Bandhwari falls said, “In a municipal corporation house meeting we voted for Ecogreen to be removed from Gurugram…for the last 4 years, the people nearby from Bandhwari have been experiencing severe- problems related to their health and water. Objections are being raised by people at this hearing, all the residents of Gurugram are in opposition to this. Our objections should be noted…”

Photo: Change ORG


After two and a half hours, the hearing was concluded- but not before some attendees requested a written acknowledgement of the letters submitted. The MCG made a verbal commitment regarding the holding of a roundtable with environmental groups and waste management experts to hear their recommendations. Ecogreen was directed to document responses to all the questions raised, which will be made available in the public domain.

However, it has been over sixty days since the hearing was conducted and the minutes of the meeting are yet to be made public.

As per the EIA Draft 2006, the details of the public hearing are to be included in the EIA of the proposed project, post which MCG can send in their application for environmental clearance (consisting of the EIA report, Environmental Monitoring Plan (EMP), and details of the public hearing). This will be reviewed by an Environmental Appraisal Committee which will either accept it, suggest changes, or reject it. 

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