[SANDRP is happy to publish this open letter dated Feb 11, 2020 from Bangalore Environment Trust on the above subject. The letter is addressed to: The Chief Secretary & Additional Chief Secretary, Government of Karnataka; The Development Commissioner, Government of Karnataka; The Additional Chief Secretary, Urban Development Department; The Commissioner, Bengaluru Development Authority; The Commissioner, Bruhat Bengaluru Mahanagara Palike; The Chairman, Bangalore Water Supply and Sewerage Board; The Chairman & Member Secretary, Karnataka State Pollution Control Board; The Chairman & Member Secretary, Central Pollution Control Board; Regional Directorate (South), Central Pollution Control Board; Director General & Deputy Director General of Forests, MOEFCC; Regional Office (Mahadevpura zone), Karnataka State Pollution Control Board, Justice N Santosh Hedge, NGT appointed expert committee Chairman, Engineering Member, Bangalore Development Authority. The full text of the letter along with annexures is carried here.]
We are very glad that Karnataka Government is working hard under the ambit of NGT (National Green Tribunal) to rejuvenate Bellandur and Varthur Lakes. While we wholeheartedly thank you, for all your efforts to save the lake, we would also like to join hands with you.
We are putting forth some feedback on the process of rejuvenation. By doing that, we sincerely hope that the government will pause to assess the effectiveness of the actions taken so far and adjust future actions, in collaboration with citizens.
Our Feedback:
- Translocating toxic pollution to downstream water-bodies:
1.1 The rejuvenation approach of diverting approx. 500 Million Litres of toxic wastewaters entering Bellandur Lake, to Varthur Lake and subsequently to Dakshina Pinakini river, seems to us that the polluting matter is being pushed downstream, thus trans-locating pollution.
1.2 If the objective is pollution abatement, then diversion work is in contradiction to that objective, as it allows the toxic wastewater to travel long distances and thus increase the pollution load of the water-bodies downstream. Rejuvenation of one water-body should not spell a death knell to other water bodies. This activity is in contravention to Section 24 of Water Act. According to our constitution, people downstream of Bellandur Tank also have the right to clean and healthy environment.
1.3 Bellandur Tank wastewater has already been diverted to Varthur Lake. Varthur Lake diversion is in the works. We request the government to pause, validate the approach via an EIA (Environment Impact Assessment) and make the necessary course correction.
- The case of Desilting:
2.1 For the past 50 years, both Bellandur and Varthur lakes have been the recipient of municipal solid waste, industrial solid waste, construction and demolition, hospital waste, plastics, raw sewage, toxic industrial effluents and silt – a toxic cocktail. Hence based on precautionary principle, one can deduce that 19.4 million tonnes of Silt+Slush (SS) cocktail on Bellandur lakebed and 7.8 million tonnes of SS cocktail on Varthur lakebed is hazardous in nature, both biologically and chemically. (Refer Annexure – 2 for further details.)
2.2 The expert committee, in its submission to NGT, recommended that the lakes be de-silted to the original lakebed. That is to remove 19.4+7.8 million tonnes. De-silting this humongous quantity is a daunting task.
- The quantum of SS cocktail accumulated on the Bellandur lakebed is equivalent to the quantum of garbage Bangalore would take 10.5 years to generate. (@ the rate of 5000 tonnes/day that Bengaluru generates today).
- The quantum of SS cocktail accumulated on the Varthur lakebed is equivalent to the quantum of garbage Bangalore would take 4 years to generate.
- Mavallipuram landfill in Bangalore had close to 4 million tonnes of garbage before it was closed. The quantity of toxic cocktail in Bellandur lakebed is 4.8 times more than what is in Mavallipuram landfill and for Varthur lake it is 1.8 times more. In this context, de-silting seems like trans-locating a landfill or a lake-fill, in this case.
2.3 To practically de-silt, such huge quantities will take a long time. Even if we can remove 1000 tonnes per day, it will still take 53 years to completely de-silt Bellandur lakebed. It will take 20 years to de-silt Varthur lakebed. What about traffic, road wear and tear and air pollution and the related health hazards as the heavy trucks move in and out of these congested roads?
2.4 If the de-silting were to be carried out for a year, then only 1.8% of the total toxic cocktail on Bellandur lakebed and 4.9% on Varthur lakebed would have been removed. This is at a huge cost of hundreds of crores of rupees. Currently, Rs 300 crores is allocated for de-silting Bellandur lake alone. Compare that with Rs 9.23 crores allotted to Bellanduru ward. What measurable benefits are obtained from this expensive activity? Can the cost justify the benefits? Does the economics work out?
2.5 Where will the toxic cocktail go? Is it safe to be given to the farmers? Have the farmers been informed of the risk and the precautions they need to take? Our constitution provides the same right to clean and healthy environment to farmers as well. The produce they grow with such toxic inputs will come back on our food plate. Then comes the question of food safety and risk to public health.
2.6 Can the toxic cocktail be sent to quarries? We in Bengaluru have no place to put our garbage and suffer from a perennial garbage crisis. In that context, is there enough space to dump this toxic cocktail elsewhere?
- Environmental Impact Assessment:
The current measures of Diversion and De-silting are in-fact trans-locating polluting matter with significant and irreversible environmental impact. Such changes require an Environmental Impact Assessment (EIA) including cost-benefit analysis. EIA has a special place in environmentally sound management of lake ecosystems. This will ensure a level playing field and remove arbitrariness in decision making process.
- Stop Pollution at Source:
Lakes are by no means independent of the surrounding land systems. The pollution of the lake ecosystem is directly related to the activity in the catchment area upstream. The lake is just the receiving water-body. Any interventions to overcome pollution must be targeted upstream where the wastewater is generated. The thumb rule of pollution prevention is “stop pollution at source”. Enforcement programs for pollution prevention is a continuous activity and is cheaper than clean-up afterwards.
- Develop Lake Ecosystem Management Program:
5.1 A one-time capital-intensive engineering and infrastructure activity like diversion, de-silting and building sewage treatment plants, is NOT the panacea for mitigating complex pollution problems.
5.2 To restore and maintain the chemical, physical, and biological integrity of the Lake ecosystem, a Lake Ecosystem Management Program must be developed. This program must be rooted in science with quality water data, clearly defined goals and measurable objectives aligned with financial resources.
5.3 This can be notified and operationalized by the state government under section 3.(3) of Environment Protection Act of 1986, as recommended by government’s own report, “Expert Committee Report on Rejuvenation of Bellandur Lake” under the Chairmanship of Additional Chief Secretary, Sri Mahendra Jain, IAS.
Improving the health of the lake ecosystem is a gradual and continuous process. We the citizens are with the government in restoring the water-body. In the light of ecological fairness and justice, we request you to pause the current activities, carry out an EIA, develop a multi-disciplinary comprehensive action plan for the lake ecosystem and make the necessary course corrections. We kindly request you to give due consideration to our comments.
Thanking you in anticipation,
Yours Sincerely,
(A.N. Yellappa Reddy) Chairman, Bangalore Environment Trust
[Bangalore Environment Trust (BET) was founded in 1987 by a group of enlightened citizens. Since then BET has been working on multitude of environmental issues like lake restoration, urban tree protection, afforestation, pollution prevention and pollution related livelihood issues. We publish books from time to time. In 2014, BET published ‘Heritage Trees’, which captured the unique trees in Bengaluru. Some of our work can be witnessed in Cubbon Park, Lal-bagh, Nandi Hills, Bangalore University Campus, Agastya International Foundation Campus and Bylkuppe Tibetian Monastery.
Enclosed:
Annexure 1: Signatures of Citizen Experts & their profiles
Annexure 2: Fact Sheets
Annexure 1: Signature of Citizen Experts & their profiles
Annexure 2: Fact Sheets
- For Bellandur Lake
Indian Institute of Science, summary of 2017 Bathymetric Results ,as captured in the “Report of commission appointed by the hon’ble national green tribunal” submitted to the NGT on 31 may 2018 for Bellandur Lake.
Silt: 6.60 MCM * 1700 kg = 11.2 Million Tonnes (Density of 1700kg as mentioned IISC study)
Slush: 6.56 MCM * 1.25 tonne = 8.2 Million tonnes
(There is no bulk density given by IISc study. Due to lack of data, we considered the landfill density as given by CPHEEO manual for landfill : 1.25tonnes/cubic meter. Point to note here is that: slush and silt are mixed on the lakebed and thus the density can be more than estimated.)
Total quantity of silt/slush: 11.2 million tonnes + 8.2 million tonnes = 19.4 million tonnes
Magnitude of the quantum of silt/slush: Today Bengaluru generates 5000 tonnes/day. Based on that rate, it will take Bengaluru 10.5 years to generate 19.4 million tonnes
Time needed to de-silt: With 50 tippers/day, each carrying 20 tonnes of sludge from Bellandur Tank. To completely de-sludge and desilt 19.4 million tonnes will take 53 years.
- For Vathur Lake:
Indian Institute of Science, summary of 2017 Bathymetric Results ,as captured in the “Report of commission appointed by the hon’ble national green tribunal” submitted to the NGT on 31 may 2018 for Varthur lake.
Silt: 3.87 MCM * 1700 kg = 6.58 Million Tonnes (Density of 1700kg as mentioned IISC study)
Slush: 0.62 MCM * 1.25 tonne = 0.8 Million tonnes
(There is no bulk density given by IISc study. Due to lack of data, we considered the landfill density as given by CPHEEO manual for landfill : 1.25tonnes/cubic meter. Point to note here is that: slush and silt are mixed on the lakebed and thus the density can be more than estimated.)
Total quantity of silt/slush: 6.58 million tonnes + 0.8 million tonnes = 7.38 million tonnes
Magnitude of the quantum of silt/slush: Today Bengaluru generates 5000 tonnes/ day. Based on that rate, it will take Bengaluru 4 years to generate 7.38 million tonnes
Time needed to Desilt: With 50 tippers/day, each carrying 20 tonnes of silt+slush mixture from Varthur Tank. To completely desilt 7.38 million tonnes will take 20 years.
SANDRP 