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Karachi – June 02, 2020: Experts from the energy and environmental sector have come forward and refuted the claims, forecasts and projections made in a study titled as ‘Air quality, health and toxic impacts of the proposed coal mining and power cluster in Thar, Pakistan’ issued by Centre for Research on Energy and Clean Air (CREA).

The first of the Thar coal power project and associated mine were commissioned in July 2019 as priority national projects, and since then have been fulfilling the requirement of base load power generation – which is the minimum level of demand on an electrical grid over a span of time. The supply of electricity to national grid from Thar is a significant achievement given that it provides an indigenous fuel resource and curtails our reliance on foreign fuel.

Thar Coal was discovered in 1992 and is the 7th largest coal reserves with a potential to generate up to 100,000MW of electricity for many decades. Pakistan remained indebted to imported energy/fuel sources whereas the Thar coal project remained dormant – with limited development – for almost two decades resulting in chronic power shortage, expensive electricity, substantial forex outflow for imported fuels and loss of GDP. In this backdrop and carrying the burden of hope of 220 million Pakistanis, the project developers of Thar coal mine and power projects took a leap of faith and laid the foundation for indigenous, affordable and economical power for Pakistanis – thereby providing much needed energy security to the country. The cluster of power projects and mine in Tharparkar are not only a pioneering project for Pakistan but also present a model case for a successful public-private partnership where the role of Government of Sindh – and Government of Pakistan – cannot be understated in providing support and framework of ancillary services needed to complete the projects on time as early-harvest projects of the CPEC initiative.

The said report, however, does not take into account the complete environmental, economic and social aspects of the projects. It is important to highlight that the mine & coal-fired power projects have been designed, developed and are being executed & operated under all applicable regulatory environmental guidelines. Based on the studies conducted by reputable international consultants, these projects were designed to comply not only with the Sindh Environmental Quality Standards (SEQS) as a mandatory requirement but also voluntarily compliance with IFC (a subsidiary of World Bank) emission & air quality standards.

Moreover, monitoring of air quality from nearby villages & areas (conducted by independent third party monitoring consultants) also show minimal incremental impact of emissions which are within the allowable environmental limis. Inspite of this, continued initiatives and studies are being taken by the project developers to study and understand the long term impact on the air quality in and around the projects while ensuring use of best available control technologies and operational excellence so that all such emissions remain well within the provincial, national and IFC emission limits.

Moving on to the research conducted by the authors the report claims that the cluster of Thar coal-fired power plants could expose around 100,000 people to harmful emissions exceeding safe limits and 29,000 people could allegedly die from air pollution related causes over the 30-year operating life of the plants. These claims & analyses are based on just one desktop study – using predictive numbers and data models which have not been tested or validated based on actual ground data in Thar. It is important to keep in mind that the first of the power plants have been commissioned just 10 months ago and hence a proper health impact assessment needs to be done to determine the on-ground effects of emissions.. The study does not present any definitive data on what health assessments they have undertaken specifically in Thar with respect to existing causes of death; and while the report focuses on the cluster of power parks in Thar, it mistakenly uses data from the rest of Pakistan to extrapolate its effects in Thar and arrive at their conclusions, which is both misleading and an incorrect approach.

Secondly, the claims and value judgements in the report seem to have been made without taking into account the ground reality. Thar is a semi-arid desert region which historically has had a relatively poor air quality index due to sparse vegetation and arid topography further deteriorated due to sand-storms and dry weather. Resultantly, Thar has traditionally shown high baseline numbers for PM2.5 concentrations, and this is not just true for Thar but also for other key cities in Pakistan. Take the example of Jamshoro, where naturally occurring particulate matter concentration in the air has generally been high – does this make for a case that there should be no industrialization in such cities or country and/or the government need to relocate entire populations from these regions? No, the answer lies in the fact that world over, for such types of regions, a baseline is first established and then projects are evaluated on the incremental impact they make on the air quality. Hence, it is very important to look at the incremental impacts these projects pose on air quality of the surrounding region, and for that a detailed EIA & ESIA has to be conducted prior to the project execution which adequately covers the baseline air quality parameters as well as incremental PM2.5 & PM10 emissions. All projects in Thar Coal fields have conducted ESIA studies followed by Public hearings and approved by experts committees of SEPA, prior to starting construction works.

Thirdly, the report alleges that “the proposed plants would constitute one of the largest air pollutant, mercury and carbon dioxide (CO2) emission hotspots in South Asia”; this again is a mere exaggeration which does not reflect the reality. The data used for the environmental modelling is not in-line with power plant’s actual design data & hence the results are not reflective of the true picture. Additionally, the report ignores the special type of Thar Coal – i.e. lignite – as well as utilization of CFB technology which when taken into account would show the emissions data to be in compliance with environmental regulations. The report makes assumption for operations of the power stations in contrary to their technology; for instance for the mercury absorption in the boilers an assumption is made pertinent to Pulverized Coal boilers for all cluster which is not the case for projects planned in Thar. Unlike PC boilers, the CFB boilers are expected to have higher rate of absorption for mercury emissions as part of the ash rather than predominantly being released into the air in gaseous form.

Fourthly, the report adopts the position that coal is not ‘economically sustainable’ for Pakistan with renewables being the cheapest source of energy for the country. While the cost of electricity generated from renewable sources has come down over the past few years, their intermittency means that they can only be substituted up to a point given the continuous requirement of power in the country. Given that baseload cannot be entirely replaced by renewables at this stage and hydel is seasonal, one has to carefully consider the thermal options available to Pakistan and look at the energy mix of the country. Pakistan is a net energy importer with fuel accounting for ~30% of its import bill. It is for this reason that while making its economic case, the report fails to distinguish between Thar Coal and imported coal, masking one of the key advantages of Thar coal which is that it is an indigenous resource. Experts estimate that at full capacity the Thar power cluster will save ~USD 1 billion/ annum of foreign exchange for the country. Similarly versus imported coal, this saving will be ~USD 700 million/annum.

CREA’s biased approach in the report is also evident from the fact that it claims that ‘coal is fast becoming the fuel of the past globally’, which is an incorrect assumption. The data available with New Energy Outlook 2019 as released by Bloomberg® ascertains that a number of countries have planned additions of coal-fired power plant to their energy mix including planned additions of over 200,000MW in China; more than 51,000 MW in India; almost 11,000 MW in Japan and approximately 27,000MW in rest of the world from 2018 to 2025.

Lastly, a crucial element of the social impact assessment of these power projects which has been largely and completely ignored by the study is the positive externalities that have been created as part of the power cluster in Thar. It cannot be denied that significant socio-economic benefits have been created in the local communities in the form of provision of local employment; skills-based training programs; improved public infrastructure; availability of clean drinking water; and civic services (including hospitals, clinics & school network) amongst other aspects. It is primarily due to these socio-economic benefits that the Thar coal projects have been appreciated across the board both nationally and internationally.

At the superficial instance, therefore, is this report another targeted attempt to malign and hijack the country’s attempt to secure its energy mix by utilizing its indigenous energy sources and remain subservient to the international fuel lobby? The current COVID-19 pandemic has already exposed vulnerability of countries depending on imported energy sources and the need for developing indigenous energy resources in countries like Pakistan can not be overlooked. - PR

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