One More Attempt to Dilute or Rollback SO2 Emission Norms for Coal-based Power Plants

An Office Memorandum (OM) dated 24 Sep 2024 by the NITI Aayog has surfaced recently, which is essentially the Minutes of the Second Stakeholders Meeting (MoM) held in Aug 2024 to discuss the report “Analysis of Historical Ambient Air Quality Data Across India for Developing a Decision Support System by CSIR-NEERI”. This is one more attempt to question, and push for dilution of the SO2 emission norms for coal-based power plants. Hence this needs to be looked at in detail.

 

Stack emissions from a coal-based power plant in central India. Image for representational purpose only. Photo: Shripad Dharmadhikary

What the Minutes Say, and Some Comments

1. The Minutes record the key Conclusions and Recommendations of the study carried out by NEERI and also presented by it in the meeting.
2. NEERI representative said the study “aimed to assess the necessity and effectiveness of the current FGD regulations considering the specific context of India’s reliance on low-Sulphur coal.” Thus, intent of study is clearly to question the extant norms.
3. One implication of this stated aim is that the Ministry of Environment, Forests and Climate Change (MoEFCC), when working out and notifying the said regulations, did not consider this or other India specific contexts.
4. The meeting does not record MoEFCC’s or the Central Pollution Control Board (CPCB)’s views on this though both agencies were represented in the meeting. Its not clear if their comments were not recorded or they did not make any comments.
5. Key findings of the NEERI study presented include 
   

   “The data do not suggest that SO2 emissions from coal base power plants is adversely impacting the ambient air quality”, and

   “Sulphur or sulphate ions present in ambient air Particulate Matter (PM) is very low. The SO2 emitted from TPP is so low and not able to contribute significantly to ground level particulate matter.”

   Hence
   

   “In respect of SO2, only the ambient air quality standards need to be met”

   This is implying perhaps that there is no need for the emission standards for SO2. 
6. Again, views of MoEFCC which in the first place specified the emission standards are missing.
7. While one needs to see the actual details in the NEERI study, it appears that these findings are in contradiction to an earlier study by IIT Delhi of June 2022 which states that
   
   

   

   Cover of the IIT Delhi Report

    “… implementation of FGD in TPPs can result in significant decreases (up to 55%) in SO2 concentrations that are mostly confined in the immediate surrounding areas of the TPP and up to a maximum distance of 60-80 km from the location of the TPP … significant decreases (up to 30%) in the surface concentrations of sulfate (SO4) aerosols can be expected at locations which could be as far as 200 Km from the location of the TPP”, and

    “Our results suggest that while the maximum contribution to sulfur dioxide (SO2) surface mass concentration over Delhi NCR for the December month came from the energy sector emissions (~63%), maximum contribution to sulfate (SO4) aerosol surface mass concentration over Delhi NCR for the same month came from the transportation sector emissions (~33%) followed by the energy sector emissions (26%).”

   
   Thus, this IIT Delhi study clearly indicates that SO2 emissions from TPPs can significantly contribute to both, SO2 concentrations in ambient air and also to sulphate aerosols concentrations, and do so upto significant distances. It also presents evidence to show that use of FGD can significantly reduce these impacts of SO2 emissions. Of course, whether this contribution (of SO2 from TPPs to ambient air pollution), combined with other sources can lead to ambient air concentrations of these pollutants exceeding safe limits is an important, related but separate question. Its not clear whether the NEERI study has dealt with this or not.
8. Another highlight of the NEERI study is “Major pollutant emitted from Indian TPP is particulate matter, which is exceeding the emission regulations… Therefore PM control should be the focus area.” Undoubtedly, PM control definitely needs to be focused.
9. Among the key recommendations of NEERI study noted in the MoM is that new orders for installation of FGDs should be stopped. 
10. Ironically, the MoEFCC Standards do not at any place specify or mandate installation of FGD in power plants. MoEFCC has notified only the norms for limits on SO2 emissions; the method of achieving this is not specified and if the TPP can ensure these limits without FGD, it is free to do so. 
11. It appears (though not fully clear) that the NEERI study is asking for doing away with the emissions norms themselves (and certainly recommending to avoid FGD installations). 

 Some odd issues

1.  For the Minutes of a stakeholder meeting, where 25 stakeholders from 8 organisations participated, it is odd that NO comments by any of the stakeholders except 2 have been recorded or noted. 
2. In particular, the views of representatives of the MoEFCC – the very Ministry which has notified the norms – are not recorded. Views of Central Pollution Control Board (CPCB) are also not recorded. It is not clear whether they made any comments which are not recorded, or whether they chose to stay silent. Either way, this is inexplicable. 
3. Interestingly, the Chairperson, Central Electricity Authority (CEA) presented views which are recorded. 
4. The MoM, dated 24 Sept 2024 seem to have surfaced only after a month or so, and that too, seem to have been accessible to only some select stakeholders. 
5. Further, the NEERI study, for which the meeting had been convened, is also not available in the public domain. 

In Conclusion 

Given the importance of the issue – whether to continue or do away with the SO2 norms for coal based power plants – it is critical that the processes related to this be done in a transparent and open manner. Thus, among other things: 

• The NEERI report draft should be made publicly accessible so that members of the public and others apart from a very narrow set of invited stakeholders can comment on the same.
• The minutes of the stakeholder meetings conducted by NITI Aayog should be revised to include the comments of all participating stakeholders, and should also be made publicly accessible.
• MoEFCC’s comments and response to this issue are critical since it is the nodal ministry responsible for the Notification setting the standards. It is imperative that it puts out the thinking (and evidence) on which the standards have been based, and also its response to the issues now being raised by NEERI report and other stakeholders. This is important also because otherwise an impression is being created that the MoEFCC had not considered all these points when it notified the norms.
• Lastly, rather than push for dilution or roll back of the norms, it would be much better if all the Ministries, official agencies and others worked together to ensure faster and better implementation so that we can achieve the health benefits of controlling these emissions. This is all the more important  considering that coal based electricity is going to remain a significant part of the total electricity generation in the country for the next couple of decades at least.