Shankar Sharma, Power & Climate Policy Analyst, in a representation to Nirmala Sitharaman Union Finance Minister, with copy to Prime Minister Narendra Modi,
Prime MInister, regrets that while nuclear energy stocks gain as FM announces 100 GW nuclear energy target, the move is "part of irrational energy policy".
Excerpts:
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This has reference to a PIB release of 2nd Feb. 2025, indicating the intention of the Union Government to open the Nuclear Power sector for private participation, and with a goal of increasing the nuclear power capacity from the present level of 8.1 GM to 100 GW of by 2047. Quoting you and the PM, the PIB notification has stated that nuclear energy is essential for the country's energy transition efforts, and that opening the Nuclear Power sector for private participation will be historic.
The apparent success of DAE in persuading the finance ministry and the PMO to believe in its 'pie in the sky' goal of adding about 92 GW of nuclear capacity in the next 22 years, as compared to our own record of installing only 8.1 GW of nuclear power capacity in the last 65-70 years, should indicate an apparent inability of the policy makers at the highest levels of the governance in the country to be rational and diligent in such strategic planning/ policies. Keen observers of the operation of the nuclear power sector across the world may also call the catastrophic events at Chernobyl (at the then USSR) and Fukushima(Japan) as 'historic'.
Some of the modern terms being abused with gay abandon can be listed as: 'energy security', 'nuclear power', 'energy transition', 'affordable power'. 'demand for power', 'private participation', 'investment' etc. It is impossible to notice any sort of cohesive/ integrated approach in an objective application of these terms in the India scenario; especially when we consider the sustainable development of all sections of our society.
With multiple reports/ concerns on the topic of nuclear power for India, there is a critical and urgent need for our authorities to take a holistic view of the overall welfare of all sections of our country, including the flora, fauna, general environment, and the vulnerable sections of our people, while formulating and implementing strategic policies in energy sector; especially w.r.t the conventional technology based energy sources such as coal, nuclear and dam based electricity.
It seems evident that your advisors in the finance ministry are either unaware OR indifferent to some of the harsh realities of nuclear power, as are evident even as late as 2025. It would be useful to our country if you can seek clarification from the concerned officials of DAE about some of the high level issues, at the least: is it not a fact that the nuclear energy is the costliest among all the established technologies, not only w.r.t the capital cost but also w.r t the life cycle costs as well as the levelized cost of electricity over its life cycle; no nuclear power project is known to have been completed without cost and time overruns in recent years; there is no known technology as yet to protect the environment from the nuclear radiation from the spent nuclear fuels and waste, without spending horrendous amounts of money to keep them cool for hundreds of years at humongous cost to the society; the direct/ indirect costs to our people, due to any unfortunate nuclear accidents in any nuclear reactor site close to densely populated places, can be unacceptably high, as experienced in Chernobyl and Fukushima, and which can put our society back by few years/ decades; can our densely populated and resource constrained country afford to lose thousands of sq. kM area of our land (primarily the forest and agricultural lands) for the project sites and saftey zoens, and divert millions of gallons of fresh water for the purpose of cooling the associated processes, etc.
There seems to be a preference to adopt the SMR technology to build small size nuclear power reactors at a large number of sites all over the country with the help of private sector; which raises serious concerns about the potential proliferation of the associated safety and radiation leakage risks for a large number of communities, as compared to what it is at present with only a few sites having nuclear reactors.
It will be a sad day for the ecological upkeep of our country, if SMRs are preferred to be installed even in densely populated states like Kerala.
The humongous resources needed to add this much of nuclear power capacity, totalling to trillions of Rupees, should be well spent on effectively meeting our electricity/ energy needs on a sustainable basis at the lowest overall societal level costs, through imaginative application of renewable energy sources such as solar, wind and bio-energy technologies in distributed mode, and supported by battery energy storage systems (BESS), micro/ mini/ smart grids, and through operational measures such as highest possible efficiencies, demand side management (DSM), and energy conservation.
Without a diligently prepared "national energy policy" having an unwavering focus on true welfare of all sections of our society, including flora, fauna and the general environment, which also could have taken serious cognisance of all these associated issues, our country is grappling with unsustainable, irrational and non-coherent energy policies, such as nuclear energy policy, for which our country has been paying a very heavy price, and which will soon bring unmitigated climate related disasters to all, but certainly to the vulnerable sections of our country; possibly much before the too small and too late target of net zero carbon emission of 2070.
In the continued absence of even a token acknowledgement of the civil society's legitimate concerns by our authorities, despite repeated representations such as ones in the attached files, it would be great injustice to our people for the finance ministry and PMO to succumb to the lobbying by the DAE by pumping a lot of our meager resources to build more of nuclear power plants.
Please take serious cognisance of the fact that the ever changing lobbying focus of the nuclear advocates in the country, from the earlier preference for huge size and multiple nuclear reactors in a single site, to the latest fancy of small modular reactors (SMRs) all over the country, without ever satisfactorily clarifying the numerous concerns raised on the associated issues, can only push our people into uncertain but a scary future of huge societal level costs, risks and possible devastations due to the ever increasing risk of nuclear accidents, which will be inevitable if private sector companies start constructing SMRs all over the country.
I request you to seek satisfactory clarifications to each and every one of the concerns/ issues raised by civil society groups all these years, as in two attached representations, and share the same with the larger society.
Whereas, this representation primarily refers to the serious concerns w.r.t the unsubstantiated, and apparently an irrational nuclear power policy, our civil society has similar concerns on other conventional technology based electricity sources, ie Coal, natural gas, dam based hydro,and the associated infrastructures like dams, coal mines, ash ponds, water supply, huge power lines etc. The associated deleterious impacts such as the demand for diversion of forest and agricultural lands, impediments to the free flow of rivers, the associated direct/ indirect costs to the society, pollution/ contamination of air, water and soil, etc. should all be diligently considered from the overall welfare perspective of the society. But sadly, the associated national level policies/ practices have led to serious compromises pollution/ contamination of air, water and soil; and of course to the community welfare.
These concerns are also escalating with the passage of each year because there has been no integrated or cohesive approach to the true welfare of the society. Each of these technologies seem to have only focused on demand/ supply of electricity without adequate attention to the associated operational measures such as highest possible efficiencies, demand side management (DSM), and energy conservation.
The latest example in such a sordid scenario of complete lack of due diligence in our governance mechanism is the obsession of our authorities for a large number of Pumped Storage Plants (PSPs) across the country (aiming at the total potential of about 100,000 MW of PSP capacity) in the name of addressing the variation in the output of solar and wind power technologies. Whereas, the deleterious impacts to the local forest and riverine ecology is huge, none of the credible alternatives, at much lower societal level costs to achieve the same objective, appear to be diligently considered.
A number of such PSPs are being planned/ built in the Western Ghats, thereby further aggravating the already scary scenario of fresh water demand/ supply in peninsular India. A recent study report by The International Union for Conservation of Nature (IUCN) has reiterated what many other science based credible govt. agencies have been highlighting for decades; that Western Ghats in peninsular India is a Key Freshwater Biodiversity Hotspot. The MoEF&CC itself has called Western Ghats as the fresh water fountain of peninsular India. If our governance structure chooses to continue to ignore such telltale signs of serious threats to our people from climate change, which is basically due to the abuse of our forests, rivers and biodiversity, the critical welfare related aspects such as food and agriculture, fresh water availability, community health etc. will face ever worsening scenarios.
"The study pinpoints pollution, dam construction, water extraction, invasive species, and agricultural practices as primary threats to freshwater biodiversity in the Western Ghats. The iconic Humpbacked Mahseer, a critically endangered fish species weighing up to 60 kg, is among the species under threat in this region. The findings stress the need for urgent conservation measures to prevent further species losses and preserve freshwater ecosystems."
"The Western Ghats harbors over 300 freshwater fish species, making it one of the richest regions in freshwater biodiversity." The study emphasizes the need for urgent conservation measures to prevent further species loss. It says that the conservation strategies must address pollution, dam construction, overharvesting, and climate change impacts.
In the context of escalating threats to our people from global warming/ climate change, I may please be excused to say that the keen observers of environmental degradation in the country are shocked at the level of indifference/ ignorance of the concerned authorities towards the serious consequences of such unsubstantiated policies/ practices in the energy/ electricity sectors, and the gross neglect of even the credible recommendations from civil society.
In this context, your attention is drawn to my earlier email of 21st Jan, 2025, wherein the humongous costs to the global society in general, and to our own people in particular, due to the social, environmental and economic damages caused by the escalating degradation of our natural resources, and leading to Climate Change phenomenon, were highlighted.
The global climate scenario, as well as in India, can be stated as very grim, as exemplified by the statement of the UN Secretary General on the occasion of World Environment Day in June 2024. He had said:" … the battle to secure the planet's future will be won or lost in the next 18 months".
Whereas, various ministries, departments and agencies seeking to build large size projects and seeking the diversion of forest and agricultural lands, and large quantities of fresh water supply, seem to be reluctant/ indifferent to the overall impacts on ecology, the finance ministry must have a much better outlook to all the associated issues, because in the medium to long term the overall economic impacts of all the associated policies/ practices should be critical. If the ecological cost to the country of a large number of such irrational projects lead to unsustainable exploitation/ degradation of our natural resources, the country's economy will suffer, even if the financial numbers associated with a high GDP growth rate look good for a few years. Consequently, the future generations will face serious issues associated with the degraded natural resources, and from the heavy impacts of climate change. A recent example of importance to us can be that of China, which is reported to be facing serious ecological costs due to very high growth rate for a number of years during the last 20-30 years.
In such a scenario even a 10-20 trillion Dollar economy by 2040-50 may not matter much, if the climate change impacts become unbearable to many sections of our country by then. Assuming an extremely difficult climate change scenario by 2060-70, which cannot be entirely ruled out, does a high growth till then really matter if our economy suffers losses to the extent of 40-50% of the GDP due to climate change consequences; as projected by actuaries?
In this larger context, a question that should be addressed at present is: what should be the medium to long term objective of our country - should it be one with a frenetic set of economic activities from now till 2070 with a GDP growth rate of 7-10% CAGR, but which would possibly take our natural resources to a point of no return; OR one with a lower GDP growth rate through 2070, but which will keep our natural resources in much better condition?
It may be seen as a serious question on the integrity and competence of our authorities when the question is being raised frequently about why distributed kind of renewable energy sources, such as solar, wind and bioenergy units are not diligently considered in comparison to unsubstantiated preference for nuclear, coal and dam based projects.
I urge the Union govt, through your good offices to diligently review a number of policy level issues, such as the ones discussed above in the energy sector, and suitably modify them to ensure sustainable development goals for our country? None of the conventional technology electricity sources, including nuclear power, can be a suitable option for our country. In any of the project proposals, seeking the diversion of forest and agricultural lands, and large quantities of fresh water supply, a thorough analysis of all the costs and benefits to the society, as well as all credible options, from the overall welfare perspective of our people must be diligently followed, along with the active participation of the domain experts from civil society, and those concerned members of civil society in taking the final decision as to which of the options is most suitable to our people.
Without such an objective approach in formulating and implementing every one of the critical/ strategic policies, and in the case of all high cost & high impact project proposals, the country cannot avoid witnessing accelerated degradation of our natural resources, and inevitably the calamitous future to our communities sooner rather than later.
Your ministry may also make efforts to bring in the necessary improvements in the functioning of each of such project implementing agencies, departments and ministries, by providing the due weightage to the well considered opinions/ recommendations from civil society groups on such projects.
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