Rama Setu -2

[Bodhi]

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To,       
Tmt. Girija Vaidiyanathan, I.A.S.,
Chairperson, Tamil Nadu Pollution Control Board,
76 Anna Salai, Guindy,
Chennai- 600032

Dear Madam,

Subject: Concerns regarding the Rapid Environment Impact Assessment report prepared by NEERI on the environmental impacts of the Sethusamudram Ship Canal Project (SSCP)

We are environmental researchers working on issues related to marine conservation and coastal development along the Indian coastline. We are of the opinion that the Central Government’s proposed Sethusamudram Ship Canal Project will have serious impacts on the biodiversity and the livelihoods of fisherfolk of the East Coast of India and the Gulf of Mannar region. Bearing this in mind and our concern for the Indian coastline, we would like to bring to your urgent attention our objections to the Rapid Environment Impact Assessment (EIA) Report prepared by NEERI.

We would like to place on record that the EIA Notification, dated 4th January 1994, states the following: 

Point 4: Concealing factual data or submission of false, misleading data/reports, decisions or recommendations would lead to the project being rejected. Approval, if granted earlier on the basis of false data, would also be revoked. Misleading and wrong information will cover the following:

False information
False data,
Engineered reports,
Concealing of factual data,
False recommendations or decisions

We would like to state at the outset that our basic contention is that the Rapid EIA report prepared by NEERI is completely inadequate, does not provide critical data on impacts of the SSCP, contains false information, conceals factual data, is an engineered report and provides false recommendations. Above all this Rapid EIA report appears to have only one objective - to understate and conceal the true environmental impacts of the SSCP.

Our objections to the project is based on the fact that a falsified incomplete and inadequate document has been palmed off to the citizens of this country to push through a mock process of public hearing where the public has been given no information regarding it. We substantiate:

1. Environmental Impact Assessment or Promotional document? Unethical elements in the document

Our objections are illustrated in the entire tone of the EIA report itself. Both the EIA and the Executive Summary begin and continue expounding incredible merits of the project in blatantly promotional fashion. The EIA is meant to be an objective report giving facts and explanations regarding the impacts of a proposed project. It is not meant to be a document to justify the environmental impacts of a project but to explicate the same in an impassive and objective manner.
The EIA prepared by NEERI however is replete with sloganeering and jingoism. Some examples are quoted below:

Chapter1 Page1: ‘It is unfortunate that despite having such a coastline, India does not have within her territorial waters, a continuous navigable sea route...’

Chapter1 Page 2: ‘The proposed canal on commissioning is expected to join the ranks of the sea-canals like Suez an Panama and usher in bright future, plenty of prosperity and industrial growth in the India  hinterland lying along the proposed ship canal...There are many other benefits which are difficult to quantify such as (a) surge in the development of coastal trade, (b) development of industries in Ramanathapuram, Pasumpom Muthu Ramalingam and Tuticorin districts, © amelioration of distress due to droughts visiting annually Ramanathappuram and Pasumpon district which are the most backward districts in the Tamil Nadu State ’

Section 1.2 on Earlier Studies which provides a historical overview of the ‘dream’ SSCP was uncalled for in a document that is meant to assess the manner in which this project is going to impact the environment.

The inherent propaganda evident in these statements reveals that this is not an objective document and much less an EIA.

2. False information: Only a Rapid EIA not a comprehensive EIA

Section 1.5.1 of the report states that ‘the objectives of the EIA study is to carry out rapid and comprehensive assessments for delineating environmental management plan for Sethusamudram Ship Canal Project to enable the Ministry of Shipping to obtain environmental clearances from concerned local, state and central Government authorities’.

How an EIA study for an area like the Gulf of Mannar and Palk Bay region can be both rapid and comprehensive at the same time is unimaginable! This aside, the report is essentially a Rapid Assessment Report and not a comprehensive EIA Report. The report itself mentions that the comprehensive EIA report will be prepared later based on the primary data collection for the region.

The EIA notification does not state that a rapid EIA will suffice. It explicitly states in Point 2.I (A) that any person who desires to undertake any new project in any part of India or the expansion or modernization of any existing industry or project listed in the Schedule-I shall submit an application …the application shall be made in the proforma specified in Schedule-II of this notification and shall be accompanied by a project report which shall, inter alia, include an Environmental Impact Assessment Report, an Environment Management Plan and details of public hearing as specified in Schedule-IV

Thus it is amply clear that the MoEF requires a complete EIA and not a Rapid EIA.

Schedule IV of the notification related to procedure for public hearing also states that whoever applies for a project should submit an execute e summary along with an Environment Impact Assessment Report. It does not state that a Rapid EIA will suffice for the public hearing.

A public hearing cannot be conducted on the basis of a Rapid EIA. It is clear that the project proponents in this case have sought to only provide a makeshift document to primarily overcome the ‘hurdle’ of environmental clearances. This is unacceptable. Therefore the Rapid EIA in question cannot be used and need not be viewed by the public as a serious document for impact assessment. As far as the general public is concerned, no EIA has been provided to the public, only a Rapid EIA was provided, which is totally inadequate to assess the impacts of the project.

The report by NEERI does not state that it is a rapid EIA on its cover page. It is only as the reader explores the document further that one realizes that the document is only a Rapid EIA without information from more than one season’s data, particularly the monsoon season. Many of the sources of data on the biodiversity of the region are outdated and cannot be sued for a project of this magnitude and with its attendant impacts.

3. Instances of inadequate information in the report

1. Overall, we find that the Rapid EIA maintains a deafening silence when it comes to justifying or giving an explanation for about details and statistics regarding impacts – something that the document is mandated to do in the first place.

2. While mentioning that there is going to be a spurt in the shipping traffic in the region, the report does not state anywhere what will be the impacts of a single oil spill in the region. A report prepared for the Directorate General of Shipping, on the Development of Coastal shipping and Minor Ports by the Tata Consultancy Services mentions that the highest percentage of cargo that passes between the East and the West Coast are Coal, Crude Oil and POL products and cement. The impacts of a breaching of a vessel carrying any of these goods have not been studied or even mentioned in the EIA. Whereas the EIA goes on to expound about the benefits of coastal shipping without taking into consideration the impacts of increased coastal shipping in this region.

3. The EIA mentions that there will be attendant development all along the coast in the form of industries, workshops, minor ports etc, but nowhere is there a mention of the cumulative impacts of these on the environment of the Gulf of Mannar

4. The EIA report completely undermines the marine biodiversity of the region. It has failed to record the impacts on the dugongs for example. Without conducting primary studies in there region, it mentions that all corals along the alignment at dead corals. It also provides false information stating that the endangered dugongs and dolphins are only confined to the Gulf of Mannar National Park!  This is not only false data, but also a ridiculous statement. The UNEP report titled ‘Dugong, Status Report and Action Plan for Countries and Territories’ states that dugongs have been noted even in deep waters between India and Sri Lanka. The Marine Protected Area in the South Asian Seas Volume 2: India Needs Region  states the following about the dugongs of the region:

The extensive seagrass beds around Musal Island off Mandapam Camp and around Appa and Balayamunai Islands, off Kilakarai are the main grazing grounds (Jones, 1967; Silas & Fernando, 1985) where large herds used to occur. Catches were higher in Palk Bay between Devipattanam and Pamban on Rameswaram Island than in the Gulf of Mannar between Musal and Appa Islands and the mainland. There maybe coast to coast migration between India and Sri Lanka through Palk Bay which is shallow while migrations across the deeper Gulf of Mannar may take place around the coast (Jones, 1976).

5. The Rapid EIA mentions that the navigational route is to be 20 kilometers away from the Shingle Island. The EIA also mentions that the route will only be 6 kilometres away from the Van Tivu Island which is also part of the Gulf of Mannar Marine National Park. This will be a violation of the MoEF’s circulars that state that there is to be a buffer zone of 25 kilometres around all National Parks and Sanctuaries.

6. The EIA also does not give any data or details regarding impacts on the flow of currents once the barrier at Adam’s bridge is dredged. The current flow will have impacts on sedimentation in the Gulf of Mannar and also on the coral reef areas in the region. This is despite common knowledge that sedimentation is damaging to areas 

7. The Muthupet and the Vedaranyam areas are sensitive areas which run parallel to the canal alignment. There are no details in the EIA about the impacts of oil spills on the coastal areas. This is significant especially when one notes that there is absolutely no oil spill modeling keeping in mind a worst case scenario.

8. The document most shoddily mentions that exotic species from the Bay of Bengal region can enter the Palk ay and vice versa. But it does not state what the impacts of such invasion of exotic species would be. In which case one wonder what impact has been assessed!

9. There is no mention of a disaster mitigation plan anywhere in this report, clearly meaning that the report seeks to conceal the fact that there can at all be any disaster in a busy shipping route carrying POL, crude, coal, naphta and other such cargo!

10. The 51 million cubic metres of dredge spoil is proposed to be dumped in an area frequently referred to as a wasteland – the site is a well known proposed bird sanctuary! There is a proposal lying with the Tamil Nadu Forest Department for the declaration of the area as a Wild Life Sanctuary. The report predictably ignores this.

11. While the report faithfully makes passing mention of the impacts of construction activity and dredging etc on the traditional fisherfolk, including their displacement, it sheds no light on any compensation amply exposing the project’s commitment to safeguard the livelihoods of the fishing communities.



4. Invalidity of the public hearing process

We would like to state that a Rapid EIA report is inadequate to assess the damage that may occur to an area of national and global significance such as the Gulf of Mannar. We are also of the opinion that no project such as the SSCP should take place along the Adam’s bridge due to the sensitivity of the entire region. We therefore do not demand a fresh EIA but state that a project  of this nature should not take place in this region and at any rate cannot rely on a document such as the Rapid EIA report prepared by NEERI.

From all of the above, we therefore contend that the commissioning and preparation of the Rapid EIA by NEERI, the distribution of the document to the public and the conducting of public hearings based on this incomplete and false EIA, is illegal and criminal.

We also state that the associated process of the public hearing (which we have pointed in another letter addressed to your office as being characterized by violence and intimidation by political thugs) is also null and void. 

Sincerely,

Aarthi Sridhar, Research Fellow, Ashoka Trust for Research in Ecology and the Environment, and Mahalakshmi Parthasarathy, Environmental Researcher

Bangalore Karnataka, India


CC. For information
The Secretary, Ministry of Environment and Forests, Paryavaran Bhavan, C. G. 0. Complex, Lodhi Road, New Delhi- 110 003
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