This appears to be a considerable improvement over his earlier position. But
elements of muddleheadedness still persist.

There is yet no straightforward underlining of the three defining aspects of
the draft Bill:
One, it is an attempt to enact a law defining and tackling civil liability
for nuclear damage, which does not obtain as of now, to facilitate
participation of foreign players in Indian nuclear market.
Two, the Bill is also a move towards joining the Convention
on Supplementary Compensation (CSC) regime by enacting a law in alignment
with that.
Three, the Bill is a stepping stone to ensure entry of private players,
whether foreign or indigenous, as "operators", as had been demanded by the
FICCI in its June 2009 Report. And the Bill proposes to go way beyond the
CSC framework to roll out a red carpet for he prospective private players to
assume the mantle of "operator".

The single point responsibility of the "operator" vis-a-vis the potential
victims is arguably a welcome feature.
There is, however, a clear provision to the effect that "operator" can claim
compensation from its vendor(s). But hat's between the "operator" and its
vendor(s). The implied "cap" for the vendor(s) is of course defined by that
of the "operator"; evidently, it cannot exceed that.

The entry of private players as "operators" must be opposed tooth and nail,
regardless of locations of their headquarters, given the unique nature of
nuclear power industry and its catastrophic potentials.
There cannot be any overall "cap" on compensation to potential victims. (The
CSC does NOT so obligate. Nor does it obligate entry of private "operators".
There is also no obligation to peg the "cap" for their "liability" any lower
than the first tier of compensation i.e. 300 million SDR, which amounts to
around Rs. 2,100 crore or 460 million US$.)

The immediate demand has got to be to open up the Draft for widest and
transparent public consultations.

That Brahma Chellaney is a nuclear (ultra) hawk is somewhat beside the point
in the current context.

Sukla

P.S.: For a treatment of this issue by this commentator, may look up <
http://www.europe-solidaire.org/spip.php?article16897>.
And protest the Bill at <http://www.petitiononline.com/no2cap/petition.html>
.

I/II.
http://economictimes.indiatimes.com/news/politics/nation/Revisions-in-N-liability-bill-a-must/articleshow/5765052.cms

<http://economictimes.indiatimes.com/news/politics/nation/Revisions-in-N-liability-bill-a-must/articleshow/5765052.cms>
*Revisions in N-liability bill a must*
6 Apr 2010, 0651 hrs IST,

 After the national furore, the government has begun to redraft its
nuclear-accident liability bill. It was left with little choice.
Unlike the  123
agreement or the latest reprocessing accord with the US, the proposed new
law on liability has to go before Parliament for scrutiny and approval.

The bill, circulated to members of Parliament last month, attempted to
fashion a new principle in international law — profits are private,
accident-related liabilities are all public. The bill gave foreign reactor
suppliers a free ride at the Indian taxpayer’s expense.

Limits on liability traditionally have been designed in the world to limit
the financial risks of private firms engaged in the business of
nuclear-generated electricity. But in India the state intends to own and
operate all nuclear power plants. That is the reason why the Atomic Energy
Act, which shuts out the private sector from nuclear power generation, is
not being amended.

But foreign reactor suppliers cannot complain as they are in a happy
situation. The government has earmarked separate nuclear parks for each of
the two American reactor-exporting firms as well as for the sole French and
Russian companies. It is acquiring land for them and freeing them from the
task of generating electricity at marketable rates. The government will run
the reactors through the state operator, subsidising the high-priced
electricity generated. Above all, foreign suppliers will have no direct
accident liability.

So, given this extraordinary mollycoddling, there are no risks for foreign
firms in entering the Indian market, only profits to rake in. Against this
background, the liability bill must contain seven essential revisions.

One, there is no need for a limit on liability as the Indian state, in any
case, will be the sole owner and operator. There is no maximum cap on
liability in the US, Germany, Finland, Japan, South Korea and Switzerland.
The proposed Indian law must mesh with the doctrine of absolute liability
and “polluter pays” principle set by the Supreme Court in response to the
Bhopal gas disaster.

Two, the minimum cap should reflect the international trend of providing
enough to deal with the long-term public health problems likely to be caused
by a nuclear accident. For example, Japan’s minimum liability is 120 billion
yen ($1.33 billion).

Three, the revised bill should not relieve foreign companies of direct
liability for any accident. Nor should victims be stripped of their right to
sue a culpable foreign firm in an Indian court, or through a foreign court.

India must follow the example set by US law, which permits “economic
channelling”, but not “legal channelling”, of liability, thereby allowing
criminal proceedings and other lawsuits against any party in courts. That is
the main reason why the US has not joined the Vienna or Paris convention —
the two main international liability instruments. But the US has become
party to the Convention on Supplementary Compensation (CSC). The CSC is
about compensation, to be paid “supplementary” to the liability limit. It
permits either “economic channelling” or “legal channelling” of liability.

Why shouldn’t India emulate the US example and permit economic (but not
legal) channelling of liability to the operator? That will leave suppliers
(foreign or Indian) legally liable for an accident, but allow for speedy
disbursement of compensation to victims following an accident.

Four, the Indian taxpayer ought to be the insurer of last resort, not of
first resort. In the existing bill, all liability falls on the Indian
taxpayer, whether it is the state operator’s slice or the Centre’s share. By
contrast, America’s Price-Anderson system is without cost to the American
taxpayer. It ensures that there is at least $10.5 billion in private-sector
funds available to cover a nuclear accident. As the US has no cap on
liability, the US Congress serves as the insurer of last resort. If a
catastrophic accident were to occur, Congress could raise its contribution
not by burdening the taxpayer but by imposing additional taxes and other
levies on the nuclear industry.

Five, the new bill must do away with the distinction between the operator
and the government when, in the Indian context, both are fused. Throughout
the existing Bill, the pretence of a US-style separation between the
operator and the government in maintained.

Under the existing bill, all nuclear-damage claims will be dealt with by a
Claims Commissioner or a Nuclear Damage Claims Commission, and any award
made “shall be final” and cannot be appealed in any court. It declares that
“no civil court shall have jurisdiction to entertain any suit or
proceedings” or grant any “injunction”.

Seven, while limiting liability in time, the bill must set a reasonable
timeline, given that damage to health from exposure to radiation can be
transmitted to future generations. The 10-year limit set in Clause 18 of the
existing Bill is simply untenable.

(Brahma Chellaney is professor of strategic studies at the Centre for Policy
Research.)

II.
http://www.livemint.com/2010/03/10204416/Kill-the-nuclear-liability-Bil.html

 *Kill the nuclear liability Bill*
Low accident liability and legal immunity mean reactor builders will have
perverse incentives for malpractices
Brahma Chellaney

 The Civil Liability for Nuclear Damage Bill is an unparalleled piece of
legislation: It aims to make foreign builders of nuclear reactors in India
immune from legal action, however culpable they may be for a catastrophic
accident. And it caps their liability at a ridiculously low Rs500 crore
($109 million) despite the billions of dollars in profit they are set to
make. Yet, the government set the parliamentary process for the Bill’s
consideration in motion under unusual circumstances—it circulated it to
members on 8 March when Parliament was in turmoil over the women’s
reservation issue.
Two issues stand out about the liability Bill. For one, it is an anti-market
measure: It constitutes a generous Indian state subsidy to foreign firms. By
seeking to shield foreign reactor builders from the weight of the financial
consequences of severe accidents, the Bill shifts the main burden for
accident liability from the foreign supplier to the Indian taxpayer.
For another, it weakens nuclear safety. After all, to grant foreign reactor
builders legal immunity upfront and to turn their legal liability for an
accident into mere compensation pegged at a pittance is hardly a way to
advance nuclear safety.
Broadly, the anti-market features of the government’s proposed import of
nuclear power reactors are manifold. First, the Bill seeks to help foreign
firms cut their costs of doing business in India by requiring them to take
accident liability insurance for a mere $109 million. Second, the government
is merrily procuring land for foreign reactor builders. It has designated
nuclear parks for foreign-origin reactors, reserving separate sites
exclusively for US, French and Russian firms.
Three, reactor deals will be signed government-to-government without open
bidding and transparency, just the way India has entered into contracts for
US arms worth billions of dollars in recent years. Four, foreign firms are
being freed from the task of producing electricity at marketable rates. The
government will run the reactors through the state operator, subsidizing the
high-priced electricity generated. And five, foreign suppliers will bask
under legal immunity.
The liability Bill essentially is intended to help out the two US reactor
exporting firms, Westinghouse and General Electric (GE) which, unlike their
state-owned French and Russian competitors, are in the private sector. With
India committed to importing at least 10,000MW of nuclear power generating
capacity from the US, Washington has been zealously prodding New Delhi to
enact the liability law. But in bending backwards to create a friendly
business environment for US firms, the government is making the Indian
taxpayer assume the principal financial burden in the event of a major
accident.
Actually, the Bill symbolizes the latest in a string of conditions thrust on
India under the much-trumpeted nuclear deal, which was approved by the US
Congress in 2008 but whose nuclear energy benefits are unlikely to start
flowing until nearly a decade from now, as the average global lead time for
reactor construction has stretched to eight years. Under the deal, India got
no legally binding fuel supply guarantee to avert a Tarapur-style cut-off,
and no right to withdraw from its obligations under any circumstance, though
the US has reserved the right for itself to suspend or terminate the
arrangements if it holds India not to be in compliance with stipulated
terms.
India is still negotiating with the US to secure the right to reprocess
foreign-origin spent fuel under international inspection. The state
department has notified the US Congress in writing, though, that “the
proposed arrangements and procedures with India will provide for withdrawal
of reprocessing consent” by the US.
Prime Minister Manmohan Singh had repeatedly promised to bring the nuclear
deal to Parliament and “abide” by its decision. For example, he stated on 30
June 2008: “I have said it before, I will repeat it again, that you allow us
to complete the process. Once the process is over, I will bring it before
Parliament and abide by the House”.
Yet, no sooner had the process ended, than the government signed the 123
Agreement with the US, sidelining Parliament. Having given no role to
Parliament on the main deal, the government now wants the two Houses to pass
a special law to provide foreign companies with accident liability
protection. In fact, as has been publicly revealed, the Bill was approved by
the cabinet after the Prime Minister’s Office rode roughshod over objections
raised by the finance and environment ministries to its provisions.
The Bill’s stated objectives and reasons seek to create the meretricious
impression that it is designed to bring India in compliance with
international nuclear liability instruments. The plain truth is that India
is under no obligation to enact liability legislation. If India wants, it
can follow the example of Russia, which has refused to pass legislation to
waive or cap accident liability for its foreign suppliers. Or it can follow
the lead of Germany, which has limitless liability and demands €2.5 billion
($3.4 billion) security from each plant’s operator.
Indeed, efforts to harmonize international rules on liability and
compensation have been frustrated by the failure to bring all relevant
international instruments into force. As the powerful World Nuclear
Association—the lobbying arm of 180 nuclear firms, including GE,
Westinghouse and Areva—admits, “States with a majority of the world’s 440
nuclear power reactors are not yet party to any international nuclear
liability convention, relying on their own arrangements.”
Take the case of the US: It has its own domestic liability law, the
controversial Price-Anderson Act, but it is not party to the main
international instruments—the Vienna Convention of the International Atomic
Energy Agency (IAEA) or the Paris Convention of the Organisation for
Economic Cooperation and Development (OECD).
In 1988, to bridge the geographical scope of the Vienna and Paris
conventions, a joint protocol was adopted. Then in 1997, another protocol
amended the Vienna Convention to set the limit of the operator’s liability
at not less than 300 million special drawing rights, or SDRs ($458 million).
The US has now become party to IAEA’s 1997 Convention on Supplementary
Compensation for Nuclear Damage, or CSC, which recognizes the potential
trans-boundary consequences of Chernobyl-type nuclear disasters, and thus
seeks a common approach on compensation. Compensation is distinct from
liability. CSC, as the name suggests, is about compensation, to be paid
“supplementary” to the liability limit. To join CSC, a state must be party
to the Vienna or Paris conventions, or certify that its national law
complies with the CSC annex on liability. The supplementary compensation
under CSC is to be provided through contributions by state-parties on the
basis of their installed nuclear capacity and a United Nations rate of
assessment.
The Indian government has misleadingly juxtaposed its liability Bill with
CSC, which has not even entered into force.
In theory, the Bill seeks to emulate the Price-Anderson Act, the US system
of indemnification for legal liability. But in reality, it picks the worst
elements from both worlds—the US system and IAEA’s Vienna Convention.
The Vienna Convention has no upper ceiling on liability, only a minimum one
(300 million SDRs, also reflected in CSC). But the minimum is so low that
few countries have pegged liability to that level. For example, Japan’s
operator liability now is 120 billion yen ($1.33 billion), while liability
in Finland is unlimited, with each plant licensee required to take at least
€700 million ($950 million) in insurance coverage.
The Price-Anderson system, for its part, provides for more than $10.5
billion in liability payouts for each disaster through a complex formula
that includes insurance coverage carried by the reactor that suffered the
accident, retrospective premiums from each of the operating reactors in the
US, and a possible 5% surcharge. The US government assumes liability for any
accident only above the $10.5 billion figure, which is inflation-adjusted
every five years and thus variable.
The Indian Bill, by contrast, pegs maximum liability, as its clauses 6 and 7
state, at “the rupee equivalent of 300 million SDRs”, or Rs2,087 crore ($458
million)—that is, 23 times lower than the Price-Anderson system. Of this,
the total liability of the foreign supplier has been limited to a trifling
Rs500 crore. The Union government will be liable for damages in excess of
Rs500 crore but up to Rs2,087 crore.
The Price-Anderson Act—effectively a subsidy measure—has been severely
criticized by independent groups in the US, where it has been mockingly
called “Half-Price Anderson”. The legislation the Indian government is
seeking to push through can be labelled “Free-Ride Anderson”. Under it, the
reactor builder is free to rake in unlimited profits without a real
liability on product safety.
What is worse is that while the Price-Anderson Act permits economic (but not
legal) channelling of liability, thereby allowing lawsuits against any
party, the Indian Bill grants foreign suppliers immunity from legal action
by introducing legal channelling of all liability to the Indian government.
It not only turns the “polluter pays” principle on its head, but also
forecloses the possibility of victims suing the foreign reactor builder for
additional damages even in Indian courts.
With the improvement in reactor safety systems, chances of a nuclear
accident are admittedly low. But the consequences of a single nuclear
accident would be colossal, with a serious radioactive release likely to
cause lasting public health problems, including genetic damage passing on to
future generations. Though it did not kill anyone, the 1979 partial core
meltdown at the Three Mile Island nuclear plant in the US led to 14 years of
clean-up costing at least $1 billion. Little surprise that Washington has
been pressing New Delhi hard on the liability issue.
More fundamentally, creating an artificial market with open-handed
subsidies, land acquisition for foreign firms, abysmally underrated accident
liability, and electricity supply at state-supported rates is no way to meet
energy needs, or to reduce carbon emissions, or to help India’s poor. The
Bill should be seen for what it is—an anti-market measure designed to
promote unfair business practices and cartelization by rigging commercial
terms in favour of select foreign suppliers.
Indeed, the Bill sends out a jarring message: Indian lives are cheap. It is
a message at odds with India’s pride in being the world’s largest democracy.
*Brahma Chellaney is professor of strategic studies at the Centre for Policy
Research in New Delhi. Comment at [email protected]*


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