NEERI submitted a report on the effect of air pollution on the Taj Mahal which was questioned by the Centre for Science and Environment. What followed is history
DOES a magazine like Down To Earth (DTE) have the right to
critique the research of a 'prestigious national institution' like the National Environmental Engineering Research Institute? NEERI, which belongs to the massive, government-funded CSIR (Council of Scientific and Industrial Research) family does not appear to think that way.
With the environmental concern growing in India, NEERI has been called upon by the Supreme Court and various government agencies to investigate many contentious issues and its reports have formed the basis of several government decisions and court orders. A series of reports had been produced by NEERI for the Ministry of Environment and Forests and the Supreme Court on the sources of pollution that could affect the Taj Mahal.
These reports played an important part in the decisions of these institutions. But when DTE correspondent, N Raghuram, found that many scientists, which included eminent environmental scientist and former deputy director of NEERI, J M Dave, and a retired professor of environmental sciences and a resident of Agra, S C Pandya, were not happy with the quality of NEERI's report, he sought the permission of the editor to investigate this controversy.
I gave this permission because my position was a very simple and straightforward one. If India has to reconcile the conflict between industrialisation and environmental sustainability, its technological and other choices will necessarily have to be built on good science, so that the pain of industrial closure and joblessness is reduced to an absolute minimum.
Therefore, a magazine like DTE must bring to the attention of the public and decision-makers all such debates and controversies within the scientific community which deal with the quality of scientific advice. Moreover, DTE would not be doing anything unique by taking up this function. Leading scientific publications like Nature and Science do this all the time. We, therefore, published in our April 15, 1996 issue an article by N Raghuram entitled 'The trouble with the trapezium'.
NEERI reacted with anger and asked us either to apologise or publish a 20-page typed rejoinder. I took the position that there was no question of apologising but I would be quite happy to publish their rejoinder, as long as it was of reasonable length, together with our rebuttal. All this would be in the interest of a public debate on a very important issue. NEERI, however, decided to complain to the Press Council. My own letter to the director-general of CSIR, R A Mashelkar, arguing that the behaviour of NEERI did not reflect a 'scientific temper' on the part of that institution went unreplied.
Let me give DTE readers an idea of what transpired at the hearing in front of the Press Council which did not last more than 45 minutes, as conveyed to us by our counsel. In view of the argument put forward by NEERI's counsel, Justice P B Sawant asked whether it was NEERI's contention that it could not be criticised. NEERI's lawyer answered that NEERI was a government organisation and the report in question had been prepared by it after much hard work and it was very proud of it. While she did not say so explicitly, her suggestion clearly was that DTE had no business to criticise such a report.
In response, the members of the council made it very clear that merely the fact that NEERI had been criticised would not give it a cause of action against DTE. The members told NEERI's counsel to advise NEERI to be more accepting of criticism since in scientific matters there could be a genuine difference of opinion and, ultimately, it is for the people to judge which is the correct view.
When further asked whether it was NEERI's contention that DTE had alleged malafide intentions on the part of NEERI's officers in preparing the report in question, her response was in the affirmative but she could not point out specific portions of the article which she found to be such. She did, however, point out to the contention in DTE's article that NEERI had not scientifically measured the ambient air quality in Agra and that there was evidence to suggest that in some cases the instruments had been placed right inside the factories which generated a high reading. She showed NEERI's report which provides the locations where the measurements had been made. But DTE's counsel pointed out that the exact locations were indeed not given in the report. Only the general area was indicated.
In reply, the DTE counsel pointed out that DTE had definitely tried to present NEERI's version in the article. But NEERI had contended that N Raghuram had distorted the statement of NEERI's A L Aggarwal. However, our counsel pointed out that NEERI had not clearly stated what he had or had not said and, therefore, it was difficult to ascertain what distortion had been made. Moreover, he pointed out that the editor was quite happy to publish NEERI's rejoinder as long as it was of reasonable length. Accordingly, the council asked NEERI to state their case in a concise manner so that it could be carried in DTE.
We are carrying below the reply of NEERI. Incidentally, the Press Council had asked NEERI that its reply should contain a reply by A L Aggarwal to the statements attributed to him in the DTE article. But no such reply was received. Nor does the point-by-point reply elaborate what he had said. Though the Press Council gave DTE the permission to publish its own rejoinder to this reply, I am refraining from doing so partly because readers can easily read the DTE article and NEERI's reply to judge the differences in opinion themselves and partly because of space constraints. But if any reader wants our point-by-point reply, I will be happy to send them a copy.
I just want to respond to NEERI's allegation that the editor has shown "vested interest" by publishing the article. In its first letter, NEERI had alleged that the editor has shown vested interest in the small-scale industries in the Taj Trapezium.
My simple reply to this is that I have a vested interest in not just small-scale industries of the Taj Trapezium but in all industries of India. I am all in favour of India's industrialisation as long as it is in harmony with environmental conservation. Which brings me back to the same old point. That this reconciliation will need good scientific advice.
Readers can see for themselves the intemperate language used by NEERI in its reply.
THE Ministry of Environment and Forests (MEF), Government of India, sponsored a project for the National Environmental Engineering Research Institute (NEERI), Nagpur, in November 1992, for a period of six months at the cost of Rs 15.80 lakh for conducting studies to redefine Taj Trapezium (TTZ) coordinates in the Agra-Mathura region. The institute submitted the following report to the ministry in July 1993:
Air Pollution Studies on the Taj Trapezium (This contained the status of ambient air quality current emission scenarios and the predicted ambient air pollutant concentrations in and around the growth centres in the region, and an effective air quality management plan to protect all sensitive receptors within the redefined trapezium, including the Taj Mahal.)
NEERI also submitted the following reports to the Supreme Court (SC) on its directions:
Precision and accuracy checks of ambient air monitoring systems at Mathura Refinery - September 1993
Report on sulphur dioxide emission control measures at Mathura Refinery - October 1993
Technical report on issues associated with fuel supply, alternatives for industries in Agra-Mathura Region - March 1994
Inspection of air pollution control devices in Taj Trapezium - April 1994.
All these reports have been defended by NEERI in the SC on February 20, 1996.
The article published in Down To Earth criticises NEERI and holds that the SC's directives in Taj Mahal case are based on an inaccuracy-ridden NEERI report. The replies to the allegations levelled against the Institute are summarised below:
In Report-a NEERI has identified all sources of air pollution, and quantified and apportioned the pollution load being generated from various sources. This report is based on field surveys and secondary data obtained from government agencies. No source, in particular, has been brought out as the sole polluter. The studies were carried out with the objective of redefining the Trapezium, as per the terms of reference assigned by the MEF. There is, also, no recommendation on shifting of small-scale industries out of TTZ, as alleged.
It is alleged that the Varadarajan Committee was appointed in 1994 following the criticism of the scientific validity of NEERI's report. In fact, the Varadarajan Committee was appointed by the MEF as per directives of the SC to obtain another opinion. Supreme Court records bear testimony to this fact. It is alleged that the Varadarajan Committee ruled out pollution related damage to the monuments and that NEERI has attempted to bail out the Mathura Refinery (MR) and target the local small-scale industries. The Varadarajan Committee Report - 1977 had predicted maximum ground-level sulphur dioxide (SO2) concentrations in the range of 2.5 to 7 microgrammes per cubic metre (g/m3) due to the mr up to 20 km. Report-a indicates that the contribution of mr ranges from 5 ug/m3 to 10 g/m3 of so2 up to a distance of 13 km from mr. In worst case scenario, 5 g/m3 contribution so2 from mr extends up to 34 km. Further, NEERI examined the issues related to pollution from mr and suggested measures to the SC for 90 per cent reduction in so2 releases over current levels (Report-c).
Report-e provides evidence that small-scale units did not meet the requisite emission standards though claimed otherwise by them in the SC. These reports do not favour or disfavour any sources responsible for pollution in TTZ.
As regards Professor Dave's remark and suggestion to use hf6 for tracer studies, the tracer used in such studies is sf6, and not hf6, and that such a study was recommended by NEERI in its Report-c. The protection of Taj Mahal requires attenuation of air pollution from all sources as delineated in Report-a. Thus, the allegation does not stand.
Apropos Professor Dave's reported comments for not giving conclusive evidence linking any industry with damage to the Taj Mahal, and discrepancies in ambient air quality (AAQ) data of the report, it is stated that NEERI was assigned the task of assessing the air pollution load in Taj Trapezium by the MEF, and to redefine the TTZ coordinates on a scientific basis. Report-a covered the tasks assigned by the MEF. The location details with altitude are described regionwise in Report-a. NEERI had also suggested a separate study on "The impact of air pollutants on Taj Mahal" in its Report-c. Thus, there are no discrepancies in the ambient air quality methodology and conservation data, as alleged.
It is alleged that NEERI's claim regarding acid rain and damage to monuments due to sulphation/nitration are contradicted by its own data. As the period of study assigned to NEERI by the MEF did not encompass rainy season, field studies pertaining to acid rain assessment were not carried out by NEERI. Report-a has quoted literature on chemical reactions of marble with acid rain components, and rain water analysis studies. The sulphation/nitration phenomena in the NEERI report are in relation to dry deposition of pollutants, while that on acid rain is in relation to wet deposition. In Report-a, the difference between wet and dry depositions are made very distinct.
In Report-a, dry deposition is discussed at length with the additional important factor of soot particles which act as a catalyst for so2 to so3 conversion, and as a carrier of sulphates formed in the process. The dust sulphate levels formed in this process do not lower the rain water pH. Aggarwal (of NEERI), in his statement, quoted in the article, has also substantiated the findings of NEERI. There is, therefore, no contradiction.
As regards Pandya's comments on gypsum formation, it is stated that NEERI had not conducted the petrographic and mineralogical studies for assessing the degree of damage to marble and sandstone in the Taj Mahal. The observations are based on UNESCO studies on Taj Mahal. Geologists K Lal Gauri and G C Holdren Jr (1981), who had worked on Taj Mahal building stones have also brought out that the sandstone was showing gypsum formation. The same observations have been made by the Varadarajan Committee in 1977. Thus, the allegation is baseless.
Javed Ashraf's comments on the Taj Mahal construction era and about climate in Agra are misleading. The climate description, presented in the Report-a as "semi arid", refers to the classification of global climates according to the Koppen system; and the word "subtropical" denotes the latitude-wise geographical location of Agra. Nowhere in the report has Bharatpur been shown located on the Yamuna bank, as alleged.
As regards comments on AAQ monitoring in TTZ, the AAQ monitoring, reported in Report-a was conducted by NEERI at 38 locations in the TTZ. No annual figure is drawn based on its data. The trend analysis is based on air quality monitoring for winter each year conducted at the Taj Mahal since 1980 by various agencies, namely, NEERI, Central Pollution Control Board (CPCB) and Uttar Pradesh Pollution Control Board (UPPCB). AAQ levels for January, representing winter season have been plotted in the Report-a. The figures indicate long terms trends for January data alone (for different years), not the "annual or otherwise", as concluded by the correspondent.
The contention that details of sampling locations for AAQ are not given is not correct. Report-a does provide the details of air monitoring sampling stations. The monitoring sites in Agra industrial estate were selected in consultation with the UPPCB, Agra. AAQ monitoring network in TTZ was designed based on prevailing meteorology, number of pollution sources, and location of sensitive receptors. Report-a gives directional bearing angles and distances to define coordinates of the monitoring sites keeping Taj Mahal as a focal point. Such an angular/distance demarcation is essential for prediction purposes. The location and height for sampling were selected as per the standard accepted monitoring norms in each zone. In a city with multistoreyed construction, the monitoring sites are always preferred at the top of tall buildings, ensuring free passage of air around sampling inlets. The allegation is thus incorrect. A L Aggarwal explained to the correspondent all aspects of AAQ as given in Report-a. The correspondent being a novice, could not follow the intricacies of AAQM, and presented a distorted version of Aggarwal's statement.
With reference to Pandya's reported comment on climatic conditions and wind flow parameters, (it is stated that) the meteorology in Agra-Bharatpur-Ferozabad region has been detailed in Report-a. Meteorological data for three consecutive years, obtained from the India Meteorology Department, was used for modelling and impact predictions.
The methodology for defining the impact zone of Ferozabad industrial emissions vis--vis industrial sources is described. The resulting impact zones for 10 g/m3 rise of the pollutant(s), in ambient air quality are presented. Pandya (or the Editor) did not care to comprehend the impact zone criteria.
It is wrong that NEERI has not considered the pollution load of rural settings. In fact, the pollution load from point, area and line sources have been quantified in Report-a. The emissions from point sources are maximum. In Report-a, reasons have been provided for high concentrations of ambient air in rural areas. Consideration of 739 and 519 g/m3 of spm concentrations as higher and lower values, respectively, is not acceptable in air pollution studies. Time averaged air pollution standards are the criteria to ascertain pollution levels. Shamsabad and other towns in TTZ with pronounced agricultural activities experience particulate pollution which is a localised phenomena of natural origin. In Agra city the agricultural activities are absent and hence the particulate pollution has been correlated with the prevailing anthropogenic activity. High concentrations of SO2 and NOx were recorded in Hatharas which need to be analysed further to identify the exact sources. The correspondent has not been able to comprehend the intricacies of AAQ as pointed out earlier.
NEERI had not blamed the small-scale industries (SSIS), as alleged. The figures used on the consumption of coal by foundries are those supplied by the District Industrial Centre, Agra. The basis for the calculation of coal consumption in the production of iron was taken from coke-iron ratio of 1:4 and working days of 240-250 in a year. These calculations have been defended by the institute in the SC on February 20, 1996. In April 1994, on SC directives, NEERI carried out emission studies for the foundries using different fuels like rice husk, coal and oil (Report-e) to generate comparative emission data. Further, it is an accepted practice to evaluate the worst case scenario by considering all registered units, to be in operating condition for delineation of air environment management plan. Thus, the allegation that NEERI's figures are imaginary is incorrect.
The statement of Raman in the article, "Pollution is not in our industry. It is among the scientists, government departments, and the judiciary" is extremely irresponsible. He has accused the SC for its decisions on various issues relating to the protection of Taj Mahal, besides the government and scientists. The Editor, by publishing the article, shows his own selfish motives. Through this article, the Editor has shown vested interest by publishing the aforesaid without comprehending the subject, and verifying the facts.
Aggarwal did not make the statement as reported in the article, "Normally such a report would have gathered dust in the ministry...". This reflects malafide on the part of the correspondent.
The Editor contended that the article under reference has been published in public interest and in the interest of informed scientific debate on the protection of Taj Mahal. If that is indeed so, there was no need for misinformation in the box item on issues totally unrelated to scientific debate on Taj Mahal protection. The Editor has deliberately published the article under reference without verification of facts from the reports submitted by the institute to the MEF and SC.
In sum, the so-self acclaimed public-spirited, scientific-debate oriented magazine should first look inwards before undertaking to clean-up the scientific, government and judicial domains in the country.
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