June 7, 2021
Study Report
Assessment of the Banskhali S. Alam coal power (SS Power I) project EIA
SS Power I, also known as Banskhali S. Alam powerproject is a 1320 (2x660) MW coal power station under construction in Chattogram, Bangladesh. The plant is being built by Shandong Electric Power Construction Corporation (SEPCOIII), a subsidiary of PowerChina, a Chinese central government enterprise. 70% of the project’s cost is financed through a $1.8 billion loan from a consortium of Chinese banks including the Bank of China (lead arranger), the Export-Import Bank of China (export credit agency), China construction bank, China Development Bank, among others.
CREA obtained the Environmental Impact Assessmentof the unit 1 (660 MW) of the project and has evaluated the key air quality-related parts of the document, discovering several instances of erroneous or false information, as well as unlawful emissions.
The assessment makes a false claim that baseline airquality in Banskhali is in compliance with Bangladeshi air quality standards. This is not true even in light of the measurement data presented in the EIA.
There is absolutely no mention of the health impactsof air pollutant emissions under the impact assessment.
The impacts of the plant’s mercury emissions are completelyomitted.
The air quality modeling is flawed, resulting in predicted pollution levels multiple times lower than would be obtained with appropriatemodeling. There are inconsistencies in emissions data used inthe EIA, as well as a systematic failure to model worst-case, rather than average, emissions.
The project plans to apply very weak emissions standards,which would not be legal in China, and the flaws and omissions in the EIA help justify this.
The EIA contains errors and omissions that would havebeen caught by the environmental regulator if appropriate oversight was in place. This is an alarming indication of lack of oversight by Bangladeshi authorities, and disregard for Environmental Impact Assessment guidelines and standards by the project proponents. The EIA is not publicly available, which in itself is a major transparency issue. A CREA assessment (Myllyvirta 2020a) of the air quality and health impacts of proposed coal power plant projects in Chattogram found that, collectively, their emissions would be responsible for an estimated 30,000 air pollution-related deaths over an operating life of 30 years. Furthermore, mercury emissions from the plants would lead to potentially dangerous levels of mercury deposition in an area with an estimated 7.4 million inhabitants. The scale of these impacts shows the severity of the omissions made in the preparation of the EIA.