Lost in power

Energy drives the world, especially in the form of power. It, however, comes at a hefty cost to the environment, a fact that is particularly true of coal-based power. Not only does it pollute by emitting an enormous amount of suspended particulate matters (SPM), sulphur dioxides (SO2), oxides of nitrogen (NOx) and mercury (Hg) in the atmosphere, it also puts severe stress on natural resources and climate. As one of the cheapest sources of power, coal-based power dominated the world for decades, starting a race led by industrialised nations and followed by the developing ones. Now, when the world realises its devastating impacts, the race has slowed down but leaving a number of complicated questions ahead — What would be the new energy balance? How should environmental obligations be met? What would be the shared national and international responsibilities? These questions are for survival since the implications know no boundaries.

The abundance of coal makes coal-based power a primary source of power in India. With approximately 370-gigawatt (GW) power generation capacity, India ranks third in the world, after China and the USA. Around 54 per cent of total capacity and 75 per cent of total generation comes alone from coal, making it one of the top potential polluting industries in India. It, alone, contributes to around 60 per cent of SPM, 50 per cent of SO2, 30 per cent of NOx and over 80 per cent of Hg emission of the industrial sectors in India. A joint research report published by Conservation Action Trusts, Greenpeace and Urban Emissions in 2011-12 conveys that the sector's SPM emission itself costs up to USD 4,600 million on health and 80,000-150,000 premature deaths every year. Not only this, due to inefficient technology and operation, the industry also releases nearly 45 per cent more CO2 and consumes 250 per cent more freshwater to produce per megawatt-hour (MWh) of power generation, compared to a global-best plant. Revival of the sector was, therefore, much needed.

New norms

The environmental performance of the sector has been worrisome-largely owing to its old fleet, outdated technology and poor pollution control. The relaxed pollution norms, inadequate monitoring and reporting, and toothless regulatory system were plaguing it further. Earlier, the pollution norm was set only for SPM emissions that were 5-12 times more relaxed than that of Chinese and the European Union plants. Long-awaited, the new set of norms was finally notified by the Union Ministry of Environment, Forest and Climate Change (MoEF&CC) in December 2015 that underwent a few relaxations until it arrived in its current form. The water consumption norm was relaxed in 2018 from 2.5 to 3 m3/MWh and 3.5m3/MWh whereas NOx limit was, in principle, relaxed from 300 to 450 Nm3/MWh.

Current norms

Since there is a wide diversity in the fleets' age and their scope of improvement, the new norms were devised accordingly. The plants installed before 2003 are mostly smaller with inferior technology having limited options to improvise, therefore, were given relaxed norms as compared to the larger and better technology plants that came 2003 onwards. The norms were to be met by January 1, 2017. Those planned to be commissioned after this were expected to come up with modern technology enough to meet strictest norms. The new set of norms not only tightened SPM limits but also introduced limits for SO2, NOx and Hg emission and water consumption for the first time.

Economics of compliance

The new norms have clear targets of improving control of SPM, SO2, NOX and Hg emissions. Since the industry generally uses electrostatic precipitators (ESPs) for SPM control, with the exception of new plants already having low emissions, most needs solutions like upgradation of ESP, partial baghouse addition, flue-gas conditioning and better coal blend for firing, etc., that may cost Rs 5-15 lakh per MW capacity. Except those already have flue gas desulphurisation (FGD) system for SO2 control, others expecting significant improvement need installation of full or partial FGD costing Rs 20-60 lakh per MW capacity. The plants in need of marginal SO2 control improvement may opt for cheaper solutions like dry sorbent injection. For NOx control, the technologies in use are selective catalytic reduction (SCR) and, or selective non-catalytic reduction (SNCR) device that may cost Rs 20-25 lakh per MW capacity, but most may need marginal improvements to meet relaxed norms doable with cheaper solutions such as the installation of low NOx burners, overfire air supply, etc., costing 10-15 lakh per MW capacity. Improvement in SPM and SO2 control is expected to be good enough for Hg emission compliance. Neither all plants need solutions nor any plant needs all solutions. A combination of solutions based on plant's age, size, technology, installed pollution-control equipment, emission levels and norms, will do.

Since, the Indian coal-based power industry is a relatively younger fleet, having around 75 per cent capacity with less than 15 years old plants, mostly the problematic and older plants need major up-gradation apart from those to be retired. To retire old plants require an alternative source of power whereas up-gradation needs investment. Since the business investment demands payback and profit, it can't be an excuse of naysay to the much needed new norms. The cost of improvement is an economical choice if the environment and health cost of pollution is added to the cost of power; and above all, the cost of life is beyond comparison, period.

In denial

The industry stood in complete denial to the norms and tried to justify the stance with an imprecise assessment on required investment, technology and feasibility, etc. It is not to be missed that industry had some genuine concerns that needed due attention from the government which were not addressed. There were enough indicators for upcoming challenges in the implementation of new norms, but the Government's negligence in realising the problems and acting suitably on time, made things worse lately.

Numerous concerns were raised, troubled business economics of implementation was central. Industry conveyed the need of investment at Rs 2 crore per MW capacity, making it a whopping total of Rs 3-4 trillion for the sector; investment required to meet water consumption norms was additional. The challenge with most polluting, aged plants, mostly state-owned, was unique as these could also not be closed so easily as the power demand needed them operational and at the same time, investing on them was not a wise option.

Technology concerns were next. Since the technologies were expected to be imported mostly, high cost, suppliers' capability of meeting timely requirements was among the highlighted ones. Plant's space constraints for new technology, limitations of retrofitting in aged plants, challenges of the new waste stream and increase in water demand were among some additional concerns. It is well understood that shutting power plants was nearly impossible — it not only affects a home or a factory but also the political blocks at the state and the Centre. The mighty power proved itself, the industry chose headlock with new norms, the Union Ministry of Power (MoP) stood by it and the MoEF&CC was left helpless. None of these sides were in the wrong, but what was evident was the lack of serious and constructive efforts to make implementation possible.

At loggerheads

Whereas the industry chose to loggerhead, obstruct, evade and then delay the implementation, the MoP and the MoEF&CC entered into discussions, only when failure of the first deadlines became evident. Gradually, as pressure started building up and judicial intervention became unavoidable, a general agreement among industries started emerging that new norms are inevitable and the concerns of industries can be resolved. The industry, however, kept all eyes on what the sector leader, the NTPC, chose to do.

Meanwhile, the Central Electricity Authority (CEA), in December 2016, came-up with an estimation that 26 per cent of the sector's capacity needed ESP up-gradation whereas 53 per cent needed FGD installation. NOx norm was proposed to be relaxed from 300 to 600 mg/ Nm3 that could be met with a cheaper solution during overhauling for the next two years. This clarified that the sector doesn't need investment for each and every plant. The needed investment, however, is significant but not as enormous as it was portrayed by industry earlier. However, the MoP, taking the side of the industry, had proposed a seven-year deadline push for SPM and SO2 compliance and three-year push for NOx compliance, an agreement was arrived at with MoEF&CC for a deadline pushed up by five years till 2022. During a case hearing on Delhi's pollution when 'amicus curie' sought the Supreme Court's direction for notified norms, MoEF&CC submitted the agreed plan and accordingly, the CPCB issued the directions to the industry for implementation of new deadlines. This was not the end, now the MoEF&CC and the Environmental Pollution Control Authority (EPCA) were at loggerheads which contended the extension of the deadline and relaxation of norms. Rounds of reports contending each other continued in the SC, until August 2019 when the SC directed the parties to take actions of agreed consensus, giving a rest to the matter.

Ignominious mistakes

The new norms for the sector was an important milestone that brought on appreciation across the world for India's commitment towards the environment and climate change, but it was a big task that needed a good implementation strategy and support from the sector. Unfortunately, the Ministry and CPCB neglected this and paid no heed to the genuine concerns of the industry. This led to an inglorious event where the Government grossly failed to implement the notified norms, probably for the first time in history. Not only was it forced to delay the norms for another five years but also to dilute them.

Finally, the plant-wise deadlines, between 2018 to 2022, were given by the CPCB based on the factors such as plant's age, installed technology, difference from norms, efforts and time required for improvements etc. Since SPM norms already existed in the past, nearly 60 per cent of the sector's capacity, mainly private ones, were either already complying or ready to comply immediately. SO2 compliance was a major challenge, so merely 10 per cent was proposed to comply by the end of 2019 and remaining by 2021 and 2022. For NOx norms, except a small proportion of plants in Delhi-NCR, deadlines were pushed towards the end. Compliance to water consumption norms was largely not in focus, except those with a once-through cooling system given a deadline of 2022.

Deadline to be missed

The compliance check is itself a challenge since it is still based on manual monitoring which is not credible. Real-time monitoring which started 2014 onwards, is also not accurate, mostly because of incorrect installation, set-up, operation and maintenance and standardisation. Lapse and leniency of the system are additional factors as even the regulator fails to have complete access to pollution data from all the plants.

If the available data was to be believed, the failure of the second deadline is evident. Around 60 per cent of the capacity is expected to comply with the SPM norm and merely 25 per cent is expected to comply with SO2 norms by 2022. Actions are coming mostly from Centre owned plants whereas state and privately-owned plants remain big-time laggards. For NOx compliance, the majority of the plants are expected to meet the in-principle relaxed norm with minor cheaper solutions. The issue of investment is nearly resolved by the MoP's direction clarifying that the cost will be recovered by tariff increase without affecting merit-order-dispatch. Unexpectedly, only a few petitions for tariff revision has been filed by the plants and most of them are yet to get clearance, mainly, because of the need of supporting documents, CEA's approval and other bureaucratic requirements.

The sector's compliance progress can be understood from the performance of Delhi-NCR based plants which is at the centre of focus — 10 out of 11 plants missed the 2019 deadline for SO2 compliance, four plants are non-compliant with SPM norms and eight plants are non-compliant with NOx norms. What's more, the COVID-19 episode, a 'force majeure' event added further woes by forcing the industry to completely halt for over a quarter giving critical financial distress. This expects the implementation plan to be pushed further. Though compliance status was already miserable before COVID episode, now, it would be almost impossible for the Government and the Judiciary to push industry for compliance within the existing deadline.

Compliance is possible

Despite the fact that the delay of already delayed deadlines is inevitable, compliance is possible with the right strategy and approach. Learnings from the past mistakes can help in keeping track of the progress, resolve the bottlenecks, take the industry into confidence and carry periodical reviews with the industry involved. Taking implementers along multiplies the efforts, resolves the barriers and eliminates confusion on time. All these are paramount when such big tasks are to be accomplished. Since the assessment is largely dependent on correct emission data availability, strengthening the real-time monitoring and reporting system will be very significant. It should be, therefore, taken out of dormancy, and immediately regularised.

As far as the industry is concerned, it must realise that delaying implementation has its own consequences, including the increase of implementation cost, non-compliances and regulatory and legal actions. While regulators and the Government are becoming a guide and mentor to them, the industry needs to be proactive, transparent and supportive.

The good news for the environment is that better economics of renewable energy and its prioritisation have made it a preferable choice and a good amount of in-pipeline coal-based projects are stopped and existing sick ones are agreed to be retired, making the existing fleet cleaner and efficient. Fingers crossed, the post-Covid era is expected to bring a better and environment-friendly mix to the energy sector. It must, for a better future.

The writer is an environmental research & advocacy expert