Toxic Emissions: Muzaffarnagar Locals Owed Millions in Health Costs. Who Pays?

“Polluter pays principle” would estimate dues between US $250-500 million dollars annually to the residents.

Nearly 14 million tonnes of waste paper is used by the paper recycling mills in India, of which nearly 70 per cent is imported into India - the largest imports of which are from Canada and USA. While legal norms allow up to 2 per cent contamination of this waste paper, reports have found there is nearly 3x the amount of contamination in imported waste paper.

Contamination, a term used to describe elements such as plastic waste in paper, is currently pegged at 500,000 tonnes in the waste paper imported to India for recycling - akin to 50 Eiffel Towers or five USS aircraft carriers!

Another National Green Tribunal order has noted that over 900,000 tonnes of imported cheap waste paper and road sweet waste ends up being used for firing brick kilns.

NCR Paper Mills Association Presents Costs to SC To Transition Away From Solid Fuel Burning

As recipients of this paper waste, Indian paper mills potentially end up burning these waste plastics along with coal and biomass, adding to their solid fuel requirements but also, crucially, contributing to the toxicity of the emissions generated - emissions from plastic incineration is known to be 4100 times more toxic than wood combustion.

In an affidavit filed to the Supreme Court in November 2021, the Delhi-NCR Paper Mills association representing 44 large Paper Mills of the city, have presented staggering costs to transition away from solid fuel burning, that include a fuel subsidy of nearly Rs.15 crores ($2 million) a day and capital expenditure of Rs. 40-100 crores to convert each of these 44 paper mill units from coal & biomass to PNG.

An official notification issued by the Supreme Court-appointed Commission for Air Quality Management (CAQM) has banned the use of coal and other unapproved fuels in all industries in the NCR region, except in thermal power plants.

The use of unapproved fuels is said to lead to immediate closure of the plants and heavy EC fines. Where does this leave the paper mills in the region?

The NCR paper mills association, in its December 2021 submissions to the CAQM has outlined the huge challenges it faces - engineering and technology wise, economically and from a loss of jobs perspective in transitioning away from Coal and Biomass to alternate fuels like PNG.

The submission from the association claims that Online Continuous Emissions Monitoring Systems (OCEMS) have been installed in all the mills and are sufficient proof that the mills are meeting all the regulated norms as outlined by the state and central pollution control boards.

It is well documented that the OCEMS data is not accessible to the normal citizens & residents who are most affected by this pollution - even though there are parliamentary and supreme court directives in making the OCEMS data public.

Transition to PNG Will Cost Rs. 2,250 Crore Capital Expenditure

The economic implications of this transition from coal to alternate fuels like PNG is pegged at a staggering Rs. 2,250 Crore capital expenditure to install Gas based boilers and turbines over a time-period of 4 to 5 years.

More importantly, the difference in the cost for transitioning to PNG fuel is pegged at an additional Rs. 5,500 Crore per year, as compared to their existing costs from using solid fuels like coal and biomass.

Who should bear this cost and what are the implications to the nearby residents for not undertaking this transition?

This transition needs to be made in the context of the reality that the waste paper, a raw material used in many of the paper mills, potentially contains thousands of tonnes of plastic waste which has no other applications and may end up being incinerated.

Let’s look at what the import of waste plastic in such epic proportions means for the social cost to individuals and society bearing the impact of these emissions.

An elementary estimate, using globally established Social Cost of CO2 (SC-CO2) metrics, suggests compensation for just the CO2 part of the emissions at around $185 million annually.

This value factors in the more recent estimates of $185 per tonne of CO2 ($44–$413 per tCO2: 5%–95% range, 2020 US dollars), a value 3.6 times higher than the US government’s current value of $51 per tCO2.

And this doesn’t even consider the health costs of other associated emissions from toxic pollutants like PM2.5, PM10 and PAHs (Polycyclic Aromatic Hydrocarbons), well known to be carcinogenic and considered amongst the most harmful emissions from plastic waste incineration.

I will argue the health costs of these toxic and carcinogenic particulate matter emissions (dubbed HC-PM2.5 - Health Cost of PM2.5) would most certainly be several times over the SC-CO2 emissions, as health implications from Particulate Matter emissions play out in one’s own lifetime versus carbon emissions that play out over a century.

Take Muzaffarnagar for example, the city studied in the Bloomberg story and a paper mill hub of India.

EU and OECD supported “polluter pays principle” would estimate dues of anywhere between US $250 million to 500 million dollars annually to the residents of this city, social and health costs combined.

And who would pay these dues? The largest plastic waste generators would be first to be on the hook, global consumer goods companies, well documented for using and transporting this plastic waste into India. And who should be the recipients of these dues?

Without argument, the residents living in the immediate vicinity of these paper mills. These should be paid out in various ways, including but not limited to, compensations and/or subsidies.

(Ronak Sutaria is the Founder & CEO of Respirer Living Sciences. This is an opinion piece and the views expressed above are the author’s own. The Quint neither endorses nor is responsible for the same.)