Q: Have the Feasibility Study, Initial
Environmental Examination and Environmental Impact Assessment on the Rampal
Power Plant been made public?
A: Feasibility Study and IEE were not made public
and not posted on the website. Recently, the EIA has been published on the
website. There remain lots of controversies in the EIA Report. In the EIA
Report some parameters are mentioned quantitatively and most of the negative
environmental effects have been mentioned qualitatively.
Q: Whether consultancy for the Feasibility
Study was awarded in a transparent way or not?
A: The Feasibility Study was assigned to the
National Thermal Power Company Ltd. (NTPC), India on 30 September 2010.
The whole procedure has violated the Article 13 of Public Procurement Act
of 2006 and Article 3 of Public Procurement Rules of 2008, as the PDB appointed
NTPC on sole-source basis without any competitive bid. Moreover, appointment of
the NTPC as Consultants for Feasibility Study being a Joint Venture partner is
not at all sensible. The consultant should have been an independent
organization, so that their professional ethics could not be questioned.
Moreover, feasibility report was not discussed publicly.
Q: Whether the IEE and EIA were conducted in a
transparent way or not?
A: The Center for Geographic and Environmental
Information System (CGEIS) was engaged for the IEE and the EIA on sole source
basis. Thus, no competitive bid was invited. This is again the violation of the
Public Procurement Act of 2006 and Public Procurement Rules of 2008. However,
the IEE Report was submitted on 6 October, 2010 and site clearance was given by
the Department of Environment (DoE) on 23 May 2011. It is pertinent to note
that the Environmental Clearance Permission issued by the DoE for Rampal Coal
Power Plant is much different from the one issued for Matabari Coal Power
Plant.
Q: Are all the parameters for the Feasibility
Study (FS) authentic and objective?
A: Many parameters considered in the FS are not
valid and objective. For example, Plant Factor (PF) was taken as 100% and
efficiency was taken as 44% for Rampal Coal Power Plant in the Feasibility
Study for economic analysis. It can be noted that the PF considered for
Matabari Coal Power Plant of similar size is 80% only. In case of all types of power plants, shutdown for regular
maintenance and emergency maintenance are common. Usually it takes 10-20% of
the available time to recover. But in some cases, major over handling causes
shutdown period much longer. So, the assumption of PF as 100% is impractical.
Similarly, the assumption of efficiency is also impractical. Both the PF and
Efficiency are impossible to achieve in a given condition in Bangladesh. The
following table shows the comparative pictures of maximum PF and efficiency
among some countries where it can be seen that the maximum PF and efficiency of
the existing power plants of Bangladesh is lower.
Table 1: Max PF and Efficiency
level of Coal Power Plants
Country
|
Max PF
|
Efficiency
|
USA
|
58%
|
-
|
China
|
55%
|
-
|
India
|
50%
|
29-33%
|
Bangladesh*
|
45.11%
|
32.39%
|
* The Bangladesh figure
has been mentioned for all Public Sector Power Plants in the Annual Report of
BPDB 2014-15.
If actual PF and
efficiency are less than what has been proposed in FS, then, it will have major
effect on the Economic Analysis and specially, on Cost of Energy (COE) and
Levellized Tariff (LT) calculation. COE and LT will increase with lower PF and
Efficiency. In that case, economic viability and sustainability of the project
cannot be justified. According to FS following are the per MW cost and COE per kWh:
Table 2: Per MW cost and
COE per KWH
Description
|
Project Cost
(IRs Cr/MW)/(Tk/MW) |
Levellised COE (IP/kWh
|
||
Fixed
|
Variable
|
Total
|
||
Base Case (Loan Interest 12.5%)
|
IR 6.59/
(Tk 10.48) |
IR 184/
(Tk 2.92) |
IR 312/
(Tk 4.96) |
IR 496/
(Tk 7.88) |
FR Cost
|
IR 8.23/
(Tk 13.06)* |
IR 226/
(Tk 3.59) |
IR 312/
(Tk 4.96) |
IR 538/
(Tk 8.55) |
* Tk = Bangladeshi Taka;
USD= 0.1096/kWh (1USD= Tk 78.00); IR = Indian Rupee
Source: EIA Report
According to the experts
the CoE may increase by minimum 50% and in such case Levellised Tarff
will be Tk. 12.829 (US$=0.1644).
Q.
What is the cost of such Coal Power Plants in India?
A. In India many USC
coal Power Plants are currently under construction and some of them are run by
BHEL in collaboration with foreign partners. Cost of such projects varies from $
0.9 to 1.1 million/MW. But the per MW cost of Rampal Coal Power Plant is now $
1.22 million and it is sure to be increased.
Q: What are the sources of funding?
A: The official estimate of the total capital cost
of the project has risen over time and currently stands at US$1.82 billion.
IEEFA would suggest a further capital cost reaching to at least US$2bn
approximately. Equity capital is proposed at 30% of the total, with 50% of the
equity owned by the Bangladesh Power Development Board (BPDB) and 50% by NTPC
Ltd of India. Debt is proposed to cover 70% of the capital cost. All of the
debt financing would be provided by loans from the Indian Export Import Bank.
The estimated Capital Structure of Rampal Power Plant (US$ m) is given below:
Table 3: Estimated
Capital Structure of Rampal Power Plant
Capital Structure
|
US$ m
|
Split
|
Split
|
US$ m
|
Local currency
|
112
|
|||
Foreign currency
|
1,488
|
|||
Indian ImEx Bank - Buyer's Credit Facility
|
1,600
|
|||
Buffer?
|
210
|
|||
Debt required
|
1,390
|
70%
|
1,390
|
|
NTPC Ltd of India
|
298
|
50%
|
||
BPDB of Bangladesh
|
298
|
50%
|
||
Total Equity
|
596
|
30%
|
596
|
|
Total cost (US$ m)
|
1,986
|
|||
Source: Project Documents, Institute for Energy Economics and
Financial Analysis (IEEFA) Estimate
Q.
Who will be the guarantor of the loan & how the profit & loss will be
shared?
A. Government of
Bangladesh (GoB) is the Guarantor of the loan. In case the project incurs
losses, burden will remain with the BPDB and GoB nothing with NTPC or India.
Exim Bank of India will reap all benefits being a lender. If the project is
delayed GoB will have to pay extra cost for it. If there is any profit it will
be equally shared by both BPDB and NTPC.
Q.
Who will run the management?
A.
During the entire construction period top Management (CEO, CTO, COO, CFO) &
Project Management (PD) Teams will be manned by the NTPC personnel. Bangladesh
will hold the position of Chairman of Board of Directors. In such case it might
be difficult to ensure accountability and transparency of the top and project
management teams. In order to ensure accountability and transparency both top
and project management teams should have been selected and hired through
international advertisement. As the EPC contractor and the management teams
both are from the same country, it might be difficult to ensure quality, cost
and timely completion of the project.
Q:
Are some costs hidden in the Economic Analysis?
A:
Yes, according to IEEFA some costs are hidden and it is worth of USD 3 billion.
The GoB will give tax free to NTPC for 15 years worth of US$ 936 million. The
BPDB will bear the cost of annual maintenance of worth US$26 million annually
for 25 years, totaling to the tune of US$ 650 million. The Exim Bank
India will provide a subsidy of US$ 988 million, a total of US$ 2.574 million.
If all these costs are included, both the COE and Levellized Tariff will increase.
Q: What are the interest
rate and discounting rate shown in the FS?
A: The rate of interest has been shown as 14% and
discounting rate as 12%. Under the terms of the EXIM Bank, the total loan would
be paid within 20 years and the regular repayments will start after 7 years. The
rate of interest is high for such a large-scale project, if compared with
others. For example, rate of interest of JICA financing for Matarbari Coal
Power Plant is 0.1% and the repayment period is 40 (30+10) yrs. In case of
Chinese fund, rate of interest is less than 2% and the repayment period 18
(15+3) years. Even in case of Chinese commercial loan rate of interest is 3 to
3.5% and the repayment period 12 yrs (10+2).
Moreover, the burden of
the total loan will be on Bangladesh though the ownership of the project is
said to be shared (fifty-fifty) between the two countries. The Government
of Bangladesh will be bound to give the ‘guarantee’ of this total amount of
loan. That means, if - (a) the project will face any loss (b) the project will
be stopped in the midway of implementation (c) there is any failure in terms of
installment payment, the Bangladesh Govt. will be solely responsible to repay
the loan.
Q: Is the quality of
coal defined? What will be annual coal
requirement?
A: From the FS, it is found that assumption is
made on the basis of Indonesian coal having Gross Calorific Value (GCV) 6000
kcal/kg, max ash content 15% and max. Sulphur content 0.6%. In EIA source of
coal has been shown as Indonesia, Australia and South Africa. Coal quality will
have quite good impact on COE and Tariff.
Table 4: Quality of the
Coal Available in Selected Source Country
GCV (Kcal/kg)
|
TM (% Max)
|
IM (% Max)
|
Ash (% Max)
|
VM (%)
|
FC (%)
|
TS (% Max)
|
HGI
|
Sizing (mm)
|
AFT Deg. C (Max)
|
ADB
|
AR
|
ADB
|
ADB
|
ADB
|
ADB
|
||||
For Indonesian Sources
|
|||||||||
5500 -5800
|
26-42
|
15-20
|
5-10
|
38-44
|
By diff.
|
0.5 - <1
|
42-60
|
50
|
1100-1250
|
For Australian Sources
|
|||||||||
6100 -7250
|
6.0 -18.5
|
1.0-13.5
|
8.7 - 21.0
|
19-50
|
By diff.
|
0.2 - 1.0
|
37 -82
|
50
|
1300 - 1600
|
For South African Sources
|
|||||||||
6100-6500
|
8 -12
|
3-5
|
15
|
20 – 22
|
By diff.
|
0-1.0
|
45-70
|
50
|
1200-1300
|
Source: EIA Report
Note: ADB: Air Dried
Basis; AR: As received; GCV: General Calorific Value; TM: Total Moisture; IM:
Inherent Moisture; VM: Volatile Matter; FC: Fixed Carbon; TS: Total Sulfur;
HGI: Hard-grove Grind-ability Index; AFT: Ash fusion temperature (flow temp. in
a reducing atmosphere), By Difference: 100- (IM + Ash + VM).
The daily coal
requirement of 2x 660 MW units shall be about 12,920 tones based on GCV of 6000
Kcal/kg, 100% plant load factor and 2,447 Kcal/kWh unit heat rate. The coal
requirement will be less with coal of higher GCV value. Coal requirement has
been estimated using the formula:
Annual Coal Requirement:
(2,447 Kcal/KWh x 1320 MW x 24 hours x 365 days) / 6000 kcal/kg = 4.715 million
ton.
Q: How are hazards and risks assessed?
A: Hazard and risk assessment is important for any
energy related industries. The proposed project may have mechanical risk from
turbine and generator; electrical risk from power transformer, switchyard, 400
KV and 230 KV switchyard control room, transmission line; risk of fire and
explosion from boiler, live steam line, and fuel stockpile; risk of
toxic/carcinogenic chemical exposure from chemical storage and accidental
discharge of sulfuric acid from SOx absorber. In addition, some hazards may be
resulted from malfunctioning of machinery and equipments like filter, ESP, air
pollution control devices, air circulating system of boiler, lightning
arrestor, safe working place, etc. To lessen these risks, required specific
measures have been identified in EIA report. The project may possess
occupational health risk. Hazards and risk related to shipping and barging
activities for coal transportation may also occur.
Q: What are the emissions from coal power plants?
A: Main emissions from coal fired thermal power
plants are CO2, NOx, SOx, and air-borne inorganic particles such as fly ash,
carbonaceous material (filth), suspended particulate matter (SPM), and other
trace gas species. The emissions per unit of electricity are estimated to be in
the range of 0.91 to 0.95 kg/kWh for CO2, 6.94 to 7.20 g/kWh for SO2, and 4.22
to 4.38 g/kWh for NO. In EIA report Resultant Impact on Plant Emission on Air
Quality of Sundarban is presented as below:
Table 5: Summary of
Resultant Impact of Plant Emission on Air Quality of Sundarbans
Emission
|
Emission contribution
of from each unit (24 hr avg.)
|
Emission contribution
of from two units (24 hr avg.)
|
Concentration in
ambient air *24 hr avg.) near Sundarbans
|
Resultant
concentration in air (24 hr avg.) near Sundarbans
|
M0EF’s Standard (ECR
1997)
|
SOx
|
21.2 ìg/m3
|
42.4 ìg/m3
|
8-11 ìg/m3
|
50.4-53.4 ìg/m3
|
80 ìg/m3
|
NOx
|
15.6 ìg/m3
|
31.2 ìg/m3
|
16-20 ìg/m3
|
72.2-51.2 ìg/m3
|
80 ìg/m3
|
SPM
|
100 ìg/m3
|
200 ìg/m3
|
.......
|
........
|
100 ìg/nm3
|
CO
|
200 ìg/nm3
|
||||
Sulfuric Acid
|
50 ìg/nm3
|
However, the resultant
impact of emission from all the industries, existing and proposed at Mongla and
Sundarban areas will create higher level of emission, which cannot be
tolerable. According to EIA concentration of Sulfur in the ambient-air of
Sundarban will be more than 50ìg/NM3, exceeding the
limit for National Heritage sites (30ìg/NM3).
Q: How do the combustion (burning) processes in
a coal power plant affect the emission of pollutants?
A: The combustion process of the grinded coal in
the boiler is a complicated non-linear event. The pollutants emitted from
thermal power plants depend largely upon the characteristics of the fuel
burned, temperature of the furnace, actual air used, and any additional devices
to control the emissions. Currently, electrostatic precipitator (ESP) is used
in thermal power plants to control the emission of fly ash (SPM). Some new
plants use low NOx burners for high temperature (> 1500 K) combustion
technologies and dry/wet SO2 scrubber, if chimney height is less than 275
meters. Mass emission factors for CO2, SO2, and nitric oxide (NO) are computed
based on the input data, such as chemical composition of the coal used at the
power plants and the actual air used during combustion. These calculations are
based on theoretical ideals and do not look over for the control devices.
Q: What is the
significance of emission control?
A: Technologies used for controlling SO2 and NOx
often consume energy and can reduce the overall efficiency of a power plant.
The level of SO2 and NOx control differs per country, depending e.g. on
national emission limits. Countries with high levels of SO2 and NOx control may
have lower efficiencies than they would have had if SO2 and NOx control is not
applied. In case of failure, any protective measure will result in increasing
the pollution in and around Sunderban which is sufficient to destroy the
Sunderban ecology.
Q: What is the impact of
coal transportation?
A: As per FS, for the Rampal plant daily coal
requirement will be 12.920 Tons and annual coal requirement will be 4.715
million Tons. The imported coal to fuel the plant would be transported to the
region on ocean-going ships. The ships would be anchored at Akram Point, which
is located within the Sundarbans. Transshipment from these larger ships to
smaller covered barges would also occur at Akram Point. Coal would be taken
from there on the Passur River to the Rampal project site, “making a total of
400-500 trips per year directly through the Sundarbans.” BIFPCL would need to
conduct dredging and widening of a 36-kilometre stretch of the Passur River to
make the river navigable between Akram Point and the project site. Coal
transportation and continuous dredging of the river flowing through Sundarban
will affect the flora and fauna, specially the aquatic faunal species, by
creating air pollution, water pollution and noise pollution. Coal
transportation is enough to destroy ecology of Sundarban.
Q: What is the overall
impact of Rampal project on the ecology of the Sundarbans?
A: The proposed power plant is 14 km away from the
Sundarbans Mangrove Ecosystem. The combination of various types of ecosystem
(forest, coastal and wetland) makes the Sundarbans a home to several uniquely
adapted aquatic and terrestrial flora and fauna with many threatened species.
The World Heritage Site of Sundarbans is 70 km away from the proposed plant
location. The following issues are necessary to be considered in order to
examine the overall impact of Rampal project on the ecology of Sundarbans. By
recognizing the impact of the project on these ecological factors, almost all
of them have been selected as IEC to identify and to assess impact of proposed
project on them.
Habitat
Habitat health and
diversity are very important for ecosystem. Different construction activities
may have impact on habitat due to disposal of waste and waste water, alteration
of existing landscape, increase of anthropogenic activities, etc. Emissions of
greenhouse gases, NOx, Heat, etc from power plant may have impact on
surrounding ecosystem habitat, which depend on the emission rate and nature.
Terrestrial flora
The potential impact on
terrestrial flora of riverside, roadside, homestead and agricultural land is
related to the site clearance activities, construction activities during
implementation phase, open-air coal storage facilities, management of coal
dust, fly ash etc. Smaller plants (herbs, shrubs) are sensitive to change of
their surroundings.
Terrestrial fauna
Different species of
frog, amphibians, reptiles, mammals, are found within the project area and they
are also under the threat of extinction due to the devastating impacts of the
plant.
Aquatic flora
Aquatic flora including
planktonic community is a good indicator of ecological health. The aquatic
flora and planktonic community of the river and adjoining freshwater sources
may be affected due to changes in water quality.
Aquatic fauna
The proposed coal-fired
plant is located close to the major river Passur. This river is notified as
regular roaming ground of endangered aquatic mammal – the Ganges River dolphin
and Estuarine Crocodile. The river also serves as the migratory route for many anadromous
species. Hilsa is a well know anadromous fish species. Among reptiles
like Dog-faced water snake (Cerberus rhynchops), White-bellied snake (Fordonialeucobalia),
critically endangered Estuarine River Terrapin (Batagurbaska) are few of
the known anadromous animals. These faunal species may have face the
risk of destruction of their habitats and breeding grounds.
Benthic community
Generally, benthic
communities are very sensitive to waste water discharge, thermal plume,
dredging operation, pollution from ships etc. Species composition of the river
may be changed due to any change in river water quality, heat gradient, etc.
Bengal Tiger and Deer
Bengal tiger is a
globally threatened species and the spotted deer is the major prey of tiger.
The existing navigational route in Passur River will be used for transporting
coal for the proposed power plant. The vessel movement and sound pollution from
vessel would create disturbance (feeding/ grazing, breeding, movement etc.) for
the tiger and deer.
Crocodile
Estuarial crocodile is
also found in Sundarbans mangrove forest’s river and estuaries. The movement of
ships through the rivers and creeks inside the Sundarbans, oil spills, and
sound from vessel may create disturbance (feeding territory, breeding behavior,
roosting and basking habitat) for such aquatic reptiles.
Dolphin community
The Passur River is an
important habitat for Dolphin. Bangladesh has established three new wildlife
sanctuaries for endangered freshwater dolphins in the Sundarbans. Officially
declared on January 29, 2012, the sanctuaries are intended to protect the last
two remaining species of freshwater dolphins in Asia - the Ganges River dolphin
and the Irrawaddy dolphin. The habitat and breeding place of this dolphin
community would have been affected by the coal transportation activities.
Invasive species
Invasive species may
become very harmful for ecosystem and its community. In general, maritime
vessels may carry invasive species. The proposed project includes maritime
transportation of coal from different international sources (Australia,
Indonesia and South Africa).
Ambient air
Land filling, site
establishment, earth works, construction materials processing, construction
activities, vehicle movement, etc. may generate fugitive dust particles. The
proposed project involves construction activities like civil construction,
mechanical construction, handling and stocking of construction materials, etc.
It is necessary to adopt management plan for controlling the fugitive
particulate matter during construction activities.
Emission of greenhouse gases
Carbon dioxide and
nitrogen oxides may be emitted from combustion of the petroleum products in
project related vehicles, machinery, generators, and vessels/barges etc during
the construction period. This impact may further be minimized by adopting
Environmental Management Plan.
Ambient noise
Operation of different
machineries and equipments for construction activities, running of heavy load
traffic for construction materials transportation, and regular traffic movement
may generate noise during construction period. The produced noise may have impact
on existing acoustic environment of rural category defined in ECR, 1997. Local
inhabitants may feel disturbed due to noise from line sources (traffic
movement).
Waste generation and disposal
Construction activities
may generate different categories of solid wastes and might have impact on
local environment only if not managed properly. Wastes may be generated from
earth works, site establishment, civil construction, stockpile of materials,
and domestic household activities. The wastes might be metals, concrete,
spoiled construction material, excavated spoils, spilled oil from machinery and
vehicles, etc. The EIA also suggests different management plan as EMP for
controlling generation and scattered disposal of wastes. If EMP is properly
implemented, there might be only some minor local and short term impact of
waste disposal on physical environmental resources i.e. water, land resources
and agriculture.
Water bodies and water resources
During pre-construction
phase the environmental quality of water resources may not be impacted
significantly, as there will be no activities on water resources except some
navigation for site visit. The construction activities and installation of
power plants may cause changes in the surface water and ground water quality
and potential. Little drawdown of local groundwater table may be noticed in dry
season due to withdrawing of groundwater for construction activities. In the
project area, lowest ground water table occurs during April-May. Therefore, it
is necessary to initiate proper management plan for limiting the use of
groundwater during dry season. However, the problem of this phenomenon will be
short term and consequences of this problem might not be significant as there
is no hand pump tube well within 1km of the project.
Surface Water Quality
Oil spillage from the
workshop, water vessel may contaminate surface water near the construction
site.
Impacts of dredging activities
Dredging operation may
increase turbidity of water at dredging locations. If the dredgers cannot be
managed properly, water quality of river may be contaminated by spillage of
oil, grease and effluent from dumping site. Dumping of dredged material and
seepage from dumped dredged material may also increase the turbidity of river
water at project site. Nevertheless, the dredging may improve navigability of
the Passur River. The implementing agency should be responsible for taking
necessary measures for mitigation of impact.
Fish Habitat
The only direct impact
during pre-construction phase is acquisition of agricultural cum shrimp
aquaculture area. Acquired land includes shrimp aquaculture farm, mangrove,
intertidal area, and tidal creeks which are used as, fish habitat. Construction
work including land filling by dredging, sand lifting, site clearance and
physical construction of plant setup etc. which may have impacts on open water
fish habitats, fish diversity and hence on fish production.
Fish Migration
The Passur, Chunkuri and
Maidara rivers are the main channels for open water fish migration. All the
migratory fishes move inward and seaward for their biological needs (e.g.
spawning, feeding). Navigational activities for transporting construction
materials through existing navigation route and dredging activities may result
minor disturbance to fish migration. Only during the dredging operation, fish
migration may be disturbed within the dredging operation area.
Fish Production
The only direct impact
of land acquisition would be loss of culture fish production from the acquired
shrimp aquaculture. The loss may stand up to a maximum of 564 tons annually.
This impact may be limited only within the project boundary. There may not be
any loss of capture fish from the Passur and Maidara rivers during construction
period. Only during dredging operation, local fisher may notice less catch from
the dredging operation area and its close proximity.
Q. Does the Rampal Coal
Power Project adhere to the Equator Principles (EP)?
A. The Equator Principles (EP) are understood to
be the minimum standard for responsible investment and management of
environmental and social risk in the project finance sector. The Rampal coal
plant fails to comply with even the minimum environmental and social norms
established by the Equator Principles.
The Rampal coal plant is
in Category A, with irreversible adverse impacts. Category A, the highest level
of risk, is assigned to a project if it is known to pose “potential significant
adverse environmental and social risks and/or impacts that are diverse,
irreversible or unprecedented.”
An Environmental and
Social Impact Assessment (ESIA) is required for all Category A projects.
Further, the assessment is required to be “an adequate, accurate and objective
evaluation and presentation of the environmental and social risks and impacts,
whether prepared by the client, consultants or external experts.” Assessment
documentation “should propose measures to minimise, mitigate, and offset
adverse impacts in a manner relevant and appropriate to the nature and scale of
the proposed Project.” The assessment process and documentation for the Rampal
coal plant falls far short of these minimum requirements under Principle 2.
Under EP - 3, the
borrower’s assessment process must address compliance with “relevant host
country laws, regulations and permits that pertain to environmental and social
issues”. The Rampal plant involves violations of key pieces of legislations
such as the Environmental Conservation Regulation 1997 (ACR 1997), the
Environment Conservation Act 1995, and the Forest Act 1927. Under Bangladesh’s
Forest Act 1927 and Section 5 (1) of the Environment Conservation Act 1995, the
Ministry of Forestry and Environment has established a protected buffer area of
10 kilometers in width around the entire perimeter of the Sundarbans Reserve
Forest. This protective zone is designated as an Ecologically Critical Area
(ECA) and Industries or projects that cause soil, water, air and noise
pollution to these areas are prohibited. The outer perimeter of the ECA around
the Sundarbans is located just 4 kilometers from the Rampal coal plant, raising
concerns about potential adverse impacts within the ECA itself.
Importantly, EP 4
requires that “the level of detail and complexity of the ESMP and the priority
of the identified measures and actions will be commensurate with the Project’s
potential risks and impacts.” No evidence has been found that an ESMS or an
ESMP has been prepared for this project. If correct, this is a clear violation
of Equator Principle 4.
The Principle - 5
requires that the consultation process be “tailored” to the risks and impacts
of the Project and should be “free from external manipulation, interference,
coercion and intimidation.” The Rampal coal plant has grossly violated each of
these Equator Principle 5 requirements.
The Principle 6
stipulates establishment of a grievance mechanism “designed to receive and
facilitate resolution of concerns and grievances about the Project’s
environmental and social performance” in all Category A projects. There is no
evidence that an accessible, legitimate, and functioning grievance mechanism
has been established to address and resolve the concerns of people who have
been harmed by the forcible acquisition of land and other resources that
formerly sustained them.