Sipatpower plant Report 1507

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    Accelerating the Mainstreaming of Climate Change inNational Policy Development using Environmental

    Impact Assessment (EIA) Processes

    An NGO Forum on ADB Initiative

    Study of the Sipat Thermal Power Plant, Chattisgarh, India

    EIA Resource and Response CentreEnvironics Trust

    New elhi

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    C!NTENTS

    "# $ac%ground

    Power Sector in

    India'# Sipat Pro(ect

    )# Current Impact*one

    +# imensions ofImpact

    # Climate ChangeImplications

    -# SafeguardsAppraisal

    .# Inferences

    /# 0ay Ahead

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    1. Background

    Climate change is today regarded as an urgent issue to 1e dealt at theinternational, national and local levels# India has also recogni2ed theneed to ta%e urgent measures to deal with the issue and several e3ortsin developing technologies and mar%et mechanisms are ongoing#

    4owever, climate change concerns are rarely if not ever considered inthe environmental decision ma%ing process especially during theprocess of evaluating and grant of approval to range of pro(ects# !n aaverage over a year .55 pro(ects related to mining, power pro(ects andother infrastructure pro(ects are approved 1y the 6inistry ofEnvironment and 7orests and in none of the approvals are climate

    concerns even 8nd a mention# Therefore there is not much to sayanything a1out mitigation#

    This assumes signi8cance in view of India9s path to achieve a highgrowth rate is heavily dependent on use of fossil fuels# This will 1edependent on development and e:pansion of e:tractive industries#Patently Climate ;unfriendly9 pro(ects in the form of coal and gas 8redthermal power plants e:ponentially increasing emissions the evere:panding coal, 1au:ite and iron ore mining into the forest rich andlast remaining forests of the 0estern alua1le natural forests have 1een lost ?over &+,555 S= @m of denseforest in last two years 7SI report of &55+ due to hydropower pro(ectsas well as mining#

    The pro(ect aims at mainstreaming climate change concerns inenvironmental decisionBma%ing process in India 1y focusing on theEnvironmental Impact Assessment process ?and soon to 1eimplemented Social Impact Assessment process# The EIA process is1eing focused in view of the following reasons

    The EIA is a mandatory procedure for a range of activities in

    order to assess in advance the environmental and social impactof a proposed pro(ect and therefore intended to guide thedecision ma%ers to ma%e an o1(ective decision#

    The EIA consultant is re=uired to incorporate the real impact of

    the pro(ect# Dnfortunately, an honest assessment rarely ta%esplace and climate concerns and especially how the pro(ect will

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    led to emission of

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    Climate impacts are often not directly visi1le and these need to 1eela1orate in order to esta1lish a 1asis and =uantify the implications#Some parameters may not 1e =uanti8a1le and appropriate =ualitativevalues have to 1e evolved#

    )# Identifying >iolations within the EIA regulations and guidelines

    In the study process we may come across several violations either ofthe law or the guidelines which enhance the level of impact# Thesehave to 1e identi8ed and will form the %ernel of information for futurefollowBup as well as estimating the 1ene8ts of good governance#

    +# Evaluating the Pro(ect within the A$ safeguard framewor%

    The results of the analysis have to 1e compared with the safeguard

    norms to identify areas of advocacy and input to the process ofmonitoring funds for Environmental and Climate Compliance#

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    2. Power Sector in India

    India has the 8fth largest generation capacity in the world with aninstalled capacity of "+&

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    generation capacity without loo%ing at a whole range of alternativesloc%s us into a highly polluting form of energy generation#

    7urther the per capita availa1ility does neither reMect upon the )& percent of the poor households which do not have power nor address the

    ineciencies within the current system# emand side managementthrough choice of industrial technologies and products and endBuseeciency improvements have 1een continuously neglected#

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    3. SIPAT Thermal Power Plant of NTPC

    Focation H Sipat, Tehsil 6asturi, istrict $ilaspur, Chhattisgarh

    Coordinates of Plant Site B &&O -+'QN, .&O"-'5#+/QE

    Stage I H '5 60 ?"/.5 60 using super critical technology

    Stage II H &+5560 ?"555 60 using conventional 1oilers or su1

    critical technology

    TechnoBeconomic clearances were also provided 1y Central

    Electricity Authority for Sipat in anuary &555

    Environmental clearance for stage I granted on "' anuary "//.

    and stage II granted . une &55)

    No o1(ection certi8cate granted 1y the Chhattisgarh StatePollution Control $oard ?SPC$ on anuary &55)

    >illages H Ran%, evri, @audia, an(i, Sipat, 6asturi K & others

    Pro(ect A3ected 7amilies H '"5

    The Pro(ect site is located near Sipat village, $ilaspur istrict, Chhattisgarha1out "+ %m northeast of $ilaspur city and is reached via the $ilaspurH$alodastate highway, which passes through Sipat# The site covers ",--' ha ?),'.&acres and consists of the main plant and switchyard ?&" ha, ash dy%es

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    ?'& ha, reservoirs and a township ?&+ ha, and a merryBgoBround + ?6igilance Commission, ?C>C, see%ing approval forma%ing additional payments as demanded 1y the Russian 8rm, which issee%ing more time to deliver the e=uipment and an upward revision in priceto the tune of around Rs"" $illion), citing rising input costs#

    'http://www.li(emint.com/2!!)/!)/2)211*2)/+TP,-e$d&-to-p$&-moe-"o-Sip.html

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    4. Current Imact !one

    The impact area is 1eyond the plant site itself as it involves air and waterregimes near the plant site enlarging the Focal Area of Impact# 7urther thereare upstream impacts such as Coal 6ining Areas for Supply of Coal,

    Transportation of Coal through 6

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    It is clear from the a1ove ta1le that nearly .5B/5 percent of the land isproductive and intricately lin%ed to the livelihoods of the localcommunity#

    "&5 6C6 of water is to 1e a1stracted from the 4asdeo $arrage, which

    is estimated to provide irrigation atleast to 5555 ha of farm land#

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    ". #imen$ion$ of Imact

    "# Fand Ac=uisition

    ""-' hectares of land U'+V for main plant and switchyard 'V underash dy%es indicates the waste proportion of #) million tonesLannum"+V for reservoirs and township ")V for merryBgoBaround for coaltransport from ipi%a minesW ac=uired for the pro(ect directly impacts'"5 families# A1out '+V of the land 1elonged to local people withgood agricultural potential# The proportion of land su1(ect to industrialand ancillary uses de8nitely ta%es away the direct land use practicesand also inclines in direction from productivity potential to pollutionpotential# 0e need to consider also the impacts of land ac=uisition in

    the mining area# The num1er of a3ected land oustees involved in thepro(ect is ')&-# The num1er of families involved in the pro(ect is ''+5including appro:imately "5 families in additional mineta%e area#Thus in all a1out 555 H -555 families are directly a3ected 1y mining#

    Village Area ofvillage(inhectares)

    Number ofhouseholds

    TotalpopulationPersons

    TotalpopulationMales

    TotalpopulationFemales

    SCPopulationPersons

    STPopulationPersons

    V V V V

    !an"i #$% &'% $$ **#+ **,, *-#$ ,'

    .an/ ,#& &-, -&, *-&$ *--$ ,&$ -

    0audia %,, &+' ##' *, *'+ ,& %1evri &%% $+* *'+# *-* '#& %%# *

    Masturi ,*+ '#- #-$$ ,*% &*# *$' $,

    Sipat *,-$ **'+ ,-# $-, ''' %-& $*$

    Total 4%&& 3'(1 2()141 1()3(% ')*34 &)'%* '21

    Source:

    !ne of the recent trends in land ac=uisition for mines and power plantsin India has 1een to e:clude small areas e:clusively used forsettlements# Thus 1y e:cluding poc%ets, the promoters claim thatphysical displacement has 1een avoided# 4owever when all livelihood

    sources have 1een ta%en away and the area made un8t for anycultivation it is eventually forces people to migrate out of the area# It isunfortunate that the NTPC as a pu1lic sector has also adopted such amechanism for its ac=uisition#

    Air and 0ater Pollution

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    The total coal consumption of the plant will 1e &,"&& tLhr ?".#+/ milliontLannum# The coal has a low gross calori8c value of ','55 @calL%g, ahigh ash content of !&8"-4, and a low sulfur content of a1out5#'V# The total S!& emissions from the plant will 1e !&&$% t9ay?&'+# tLday for stage I, "'"#' tLday for stage II, 1% t9ay or -$-4

    higher than the :orl an0 limit of !"# t9ay calculate forthis ;,%# M: plant#

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    &. Climate +ootrint

    Sipat STPP sources its coal from the ipi%a Coal8elds located )5 %ms NE fromthe plant site and water is sourced from 4asdeo Reservoir Mowing southwardsand would re=uire "')55 @F water per hour# Sipat STPP 1uilds up on twotechnological aspects, one 1eing "555 60 ?+55 60& 1ased on su1 criticaltechnology whereas the remaining "/.5 60 ?560' is 1ased on supercritical technology which is e:pected to 1e more ecient than the formertechnology# As a rule of thum1, the super critical technology ?SCT tends toenhance the eciency 1y 5#/V to "#)V and is more tolerant to coalcon8guration changes or =uality changes# It also tends to reduce theemissions 1etween "#-/V to )#&)V 1roadly# EPC apan suggested SCT forNTPC power generation and suggested some %ey parameters#

    NTPC9s Sipat thermal power plant ?phase I is 1uilt using super criticaltechnology with each of the three units of 560# The super criticaltechnology tends to operate at a higher pressure and temperature there1yimproves the eciency# NTPC is sourcing ;79 grade coal from @or1a Coal8eldswhich has a high ash content of '+B)V and a calori8c value of around ''55%CalL@g# Even though the technological interventions could prove to 1ringdown the car1on footprint to a marginal lower level Uimproved eciencyW 1utit cannot address the issue of emissions unless and until the lin%ed elementsli%e improved coal after processing in washery H which can provide a low ashcontent coal H is factored into the overall 1udgeting of the pro(ect and climateemissions accounted for# Also the Super Critical Technology pretends to 1e

    ecient 1ut the coal grades, which have high ash content, again lead togreater ash production, which in turn is to:ic in nature and indirectly shouldform part of the larger emission reduction strategy which is not addressedcomprehensively in the whole chain of product and 1y product cycle# Ashanalysis of @or1a STPP indicates high percentage of silica USi!&H "#'5VW andUAl&!'H &-#)& VW#

    evelopment 8nancing 1y 1an%s li%e A$ has always loo%ed at limited ;ris%s9through its safeguard policy 1ut it has never ta%en responsi1ility ofac%nowledging in open that whether the 8nancer loo% at the largerresponsi1ility of unforeseen 1ut predicta1le impacts of climate change andwhether the investments are climate proof or tend to reduce the car1on

    footprint# The changes in am1ient environment of the region are li%ely to 1emore or less natural if considered with ;no pro(ect9 situation and need to 1eclosely monitored as a &/.5 60 thermal power plant9s gas and particulateemissions are 1ound to change the environmental conditions# $y way ofpromoting the 8rst super critical technology at Sipat which would mean morepower production Uno cross comparison is provided on the di3erentialemissions in case of power generation from su1 critical units, say si: units of+55 60 eachW and higher coal re=uirements has a 1earing on the region Uas

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    per CEA, the improvement in eciency is of the order of "#/V at given1oiler pressure and steam temperatureW 1ut there are no e3orts in theComprehensive EIA document on the estimation of car1on emissions#

    The ultimate total coal consumption of the plant is &,"&& tLhr ?".#+/ milliontLannum# Considering the emissions from @or1a STPP which is also operated

    1y NTPC Uthree units of +5560 and three units of &55 60W the speci8cemissions arrived at 1y CEA in &55+B5 is 5#/- tC!&L60# It is also noteworthyto state here that the operating heat rate of stations deteriorated 1y ""#/&VUread H""#/&VW for the eastern region during an assessment carried out 1yCEA for &55-B&55.# Eciency gain of appro:imately &Vis envisaged due tohigher unit proposed# As per CEA9s methodology of arriving at emissions, ifwe consider the average emissions i#e# 5#." tC! &L60h the 1road emissionsfrom Sipat would amount to in the following manner560 -555 hours operation ' units X "'#. million 60hDsing the emission factor as per Com1ined 6argin-X 5#.5 tC!&L60h

    Total emission load X 5#.5"'#. X "" million t C!& per annum+55 60 -555 hours operation & units X - million 60h

    assuming the emission factor as per simple operating margin ?!6 X "tC!&L60h

    Total emission load X "- X - million t C!& per annum

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    %. Safeguard$ A$$e$$ment

    A$9s 8nancing"5 is 1eing applied to the 8rst super critical

    technology pro(ect 1eing implemented in India# 0ith '"5 PA7sdue to the construction of Sipat STTP and /" families loosingmore than " acre of land, the e3orts re=uired careful physical,economic and social reha1ilitation# Even when no homesteadland is ac=uired, the socio economic reha1ilitation 1ecomesprime as in the rural setBup farm land economics wor% closelywith the homestead land and attains signi8cance in terms ofsecurity, social well 1eing and community arrangements#Employment assurance to /& persons was given 1y the pro(ectauthorities which has failed misera1ly and points towards a verywea%ly drawn out policy and lac% of proactive measures re=uired

    during the pro(ect cycle# !nly "&) (o1s ?".V of the totalpromised have 1een provided till the last month and there is noproactive information dissemination to the villagers on theremaining persons eligi1le for (o1s# In anticipation that eachmem1er of the a3ected family would get employment has leftpeople confused as the timeline to ta%e decision over this issuehas overrun time and again and there has 1een no de8nitedecision ta%en up 1y the management of the company# As aresult, people have not 1een a1le to ta%e up any gainfulemployment opportunity either#

    Fand was ac=uired""under the Fand Ac=uisition Act of "./) whereasthe NTPC policy itself states negotiations"&as the prefera1le route# It isno surprise that the ;mar%et valuation9 under the FA Act does not factorthe prevailing mar%et price of land and there1y forcing people to 8lecases for enhanced compensation which has multiple implications#illage, which again poses =uestion of rights of people inthe gauchar land and post facto situation of 7RA &55#

    >AC which is formed as per the NTPC policy has 1een formed of

    people nominated 1y people in the villages li%e the head of

    1!The poposed A?8 lo$n exposue o" @* million to +TP, will 5e A?8s 1) thnonso(eeign in(estmentin Indi$% $nd the "ist lo$n to $ st$te-owned entepise in Indi$ without so(eeign gu$$ntee unde the PilotFin$ncing Instuments $nd od$lities11L$nd $cBuisition o" 1%*1! hect$es w$s completed 5etween 1)) $nd 1)))% **C o" which w$s 5$enDo(enment-owned l$nd. The l$nd eBuied 02'# hect$es "o the co$l t$nspot s&stem w$s $cBuied in2!!# $nd 2!!'.12whee$s $s $n essenti$l s$"egu$d% negoti$ted settlement is listed $s one o" the elements o" Ein(olunt$&esettlement s$"egu$d polic&

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    village, farmers loosing large chun%s of land etc# >AC meetingsare =uite irregular and follow up actions are not shared with thevillagers# istrict administration and NTPC have an interface 1utthe villagers complain of not sharing of decisions and the followup action to 1e ta%en for the a3ected#

    Pu1lic Information Centre is meant for promoting transparencyand informed decision ma%ing as per the NTPC policy# The PIC islocated near NTPC plant whereas the distance of villages fromthis PIC is almost +B %ms with no pu1lic transport availa1le#There is no su1stantial proBactive disclosure on the pendingpromises and future actions to the a3ected#

    *afeguarElement

    rief Details of Tas0s ane/uirement

    Actual Practice

    EN>IR!N6ENT

    ProperEnvironmentalAssessment

    Identify potential direct,indirect, cumulative and

    induced environmentalimpacts and determine theirsigni8cance and scope, inconsultation withsta%eholders, includinga3ected people andconcerned N

    The information must 1ecurrent and accuratedescription of the pro(ect andits impacts# The 1aseline mustcontain environmental and

    Neither all the direct impactsnor the indirect impacts have

    1een assessed# The A$9s EIAstatement is much generalisedwithout any meaning to thespeci8c communities a3ectedand is e:tremely poor in =ualityeven as compared with the EIAreport 1y the EIA consultant#

    No pu1lic hearing was held forstage I as it was not a

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    *afeguarElement

    rief Details of Tas0s ane/uirement

    Actual Practice

    social information s well a onthe !ccupational 4ealth andSafety aspects#

    Cumulative Impacts of thePro(ect and the Region needsto 1e addressed#

    Air pollution including

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    *afeguarElement

    rief Details of Tas0s ane/uirement

    Actual Practice

    t provided that compensation isused to provideEnvironmental $ene8ts of thesame nature and is

    commensurate with pro(ectsresidual impact#

    At times, a third party9sinvolvement will inMuenceimplementation of the E6P# Athird party may 1e, inter alia,a government agency, acontractor, or an operator ofan associated facility# 0henthe thirdBparty ris% is high andthe 1orrowerLclient hascontrol or inMuence over theactions and 1ehavior of thethird party, the1orrowerLclient willcolla1orate with the thirdparty to achieve the outcomeconsistent with there=uirements for the1orrowerLclient# Speci8cactions will 1e determined ona caseB1yBcase 1asis#

    1ene8ts of the same natureaccrues to the people#

    Informationisclosure

    The 1orrowerLclient willsu1mit to A$ the followingdocuments for disclosure onA$9s we1siteA full draft EIA7inal EIAEnvironmental 6onitoringReports#

    Pro1a1ly the plea is ta%en thatneither Prevailing Pu1licCommunications Policy ?PCPnor safeguard policies of A$during the time did not re=uireposting of such EIAs on the we1,only to 1e made availa1le onre=uest#

    Consultation KParticipation

    6eaningful Consultation?1asically 7PIC$egins early in the pro(ectpreparation Stage and is

    carried out on an ongoing1asis throughout the pro(ectcycleY

    Timely disclosure of relevantand ade=uate information#0hich is understanda1le andreadily accessi1le to a3ectedpeople ?PIC HNo intimidation Uchec% the 7IR

    No meaningful consultation hasever ta%en place# Stage II pu1lichearing which was held on&'#"&55', only three village

    representatives were present asper SEIA document# Theauthorities outnum1ered themas other - representatives fromstate government departments#

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    *afeguarElement

    rief Details of Tas0s ane/uirement

    Actual Practice

    against & people ontrespassingW HDnanticipatedEnvironmental Impacts

    0hether any such impactsmentioned in EIA

    Impacts li%ely to 1e caused 1ythe ash pond from which duringsummer months heavy dustloads are in the atmosphereImpacts on People whose wateris 1eing diverted where not

    $iodiversityConservation andNatural

    Resource6anagement

    Identify ma(or threats to1iodiversity6odi8ed ha1itatsLnaturalha1itats ?conditionalLwhether

    alternativesConsideredLCriticalha1itatsLlegally protectedareas etc#

    PollutionPreventionKA1atement

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    *afeguarElement

    rief Details of Tas0s ane/uirement

    Actual Practice

    INVOLUNTARY RESETTLEMENT

    Compensati

    on,Assistanceand$ene8ts forisplacedPersons

    4owLwhether people ofdi3erent categories have

    1eenL are left outZ

    The company ac=uiresagricultural and gra2ing landsfor the plant e:cluding their

    homestead and thus claiming nodisplacement# This ma%es iteasier for the company to getaway from any attempt toaddress issues of resettlement#!n the contrary, the agriculturallands so ac=uired haveimpacted their livelihoods andsocioBcultural fa1ric of thesociety#

    SocialImpactAssessments

    0hether the cutBo3 dategiven 1y govt# L 1orrowerZInventory details in thisreportZisadvantaged groups Htargeted measures

    A large part of the a3ected arenot even considered, ane:ample 1eing the farmerswhose water is diverted for theplant#

    Resettlement Planning

    $ase on SIA6eaningful consultation witha3ected persons

    Three essential things to8gure outi informed a1t# Their optionsK entitlements pertaining tocomp#, relocation Kreha1ilitationii consulted on resettlementoptions K choicesiii provided with resettlementalternatives

    To ensure timely availa1ility ofre=uired resources, landac=uisition and resettlementcosts may 1econsidered forinclusion in A$ 8nancing

    [interesting would be to knowwhether such safeguardswork on ground]

    No sincere dialogue let alonemeaningful or any consultationon poat ac=uisition future ofthose families

    NegotiatedFA

    Safeguard Re=uirement &doesn9t apply to negotiatedsettlements

    Fand Ac=uisition Act used forsecuring land

    economic value

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    *afeguarElement

    rief Details of Tas0s ane/uirement

    Actual Practice

    6eaningful consultationUengage e:ternal party todocument the negotiation andsettlement processesW

    Informationisclosure

    raft RP endorsed 1y1orrowerLclient 1efore pro(ectappraisal7inal RP after census ofa3ected persons is completeNew RP, duringimplementation ?if anyRP monitoring reports

    Not re=uired under thepresented circumstances

    Consultation KParticipation

    6eaningful consultation usedtime and again[[[[[4ost communitiesLcivilsocietyLgenderinclusionLdisadvantagedgroups

    Totally Ignored in the Process

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    *. Inference$

    "# A$ has sought to overloo% a variety of aspects pro1a1ly as the fund issupposedly for speci8c activity and perhaps %nowingly avoids ta%ingresponsi1ility for the environmental and social impacts of the pro(ect#

    The pro(ect authorities 1y e:cluding only the homesteads havemaintained that there is no displacement and hence many of thesafeguard features 1ecome inapplica1le# A$ has 1een o1livious tothis immense dishonesty#

    '# A$ has not even provided a sem1lance of opportunity to the localcommunities to participate in any of the decision ma%ing processes

    leading to the grant of the loan# $y listing the panel mem1ers as theparticipants in a pro(ect that a3ects people across a huge region, theA$ has clearly demonstrated the hallowness of its safeguard policiesin action#

    )# A$ remains silent on issues of communities who were promisedemployment in lieu of land ac=uired from them# Their grievances arenot heard despite several attempts 1y the local communities#

    +# A$ has fallen prey to loo%ing at the pro(ect narrowly from a warpedPower Sector development perspective, rather than of a $an% willing tolead Environmental, Economic and Social Stewardship which should 1e

    the real 1asis for a 6ultilateral $an%#

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    '. ,a- Ahead

    The study has revealed that there are several aspects on which the Asianevelopment $an% needs to clarify to the community#

    0e propose that at the following activities may 1e considered for followBupaction

    At the level of the pro(ect

    "# 0e ta%e these 8ndings 1ac% to the Community and draw up acharter of demands 1ased on the A$ safeguards in closeconsultation with the communities#

    0e ena1le a local wor%shop 1ringing together people from the

    mine site, dam site and other a3ected 1y transport lines etc ande:plore further actions at the local and regional level#

    At the level of A$ involvement in Power Sector

    '# See% immediate response on the speci8c issues raised in thisreport#

    )# 0e compile the details of the pro(ects and the Sector levelperspectives for their future entry must 1e clari8ed

    +# A strong demand on reviewing the Environmental and Social duediligence of the pro(ects funded#

    # emand a critical assessment of its car1on footprint and means

    to mitigate the impacts

    At the National Fevel

    -# Prepare ground for challenging the environmental compliance atthe