Date: 29th April 2017
Goa State Pollution Control Board,
Subject: Objections to Capital Deepening of Navigation Chennel at Mormugao Port Trust for Cape size vessels
People should also understand that there are so many shipyards not following environmental laws, besides there are barges along the Zuari river bay and each of these barges has created health hazards, environmental hazards besides pollution. These aspects are ignored.
Cyril George, MPT Chairman in an exclusive interview to Navin Jha in Herald, Panjim dated 17th June 2015.
The undersigned wish to state as under:
1. We write this letter in the 199th year of the Bhima Koregaon revolt wherein the rule of Peshwayee was destroyed and slavery of the natives of India ended at the outskirts of Pune. Governments of India’s plans for Mormugao Port Trust are directed towards re-initiating of Peshwayee rule in India and we are left with only one option – to object. And we do object here. Kindly take note:
2. On page 1-1 of the above cited EIA it is mentioned “Mormugao Port is a Major Port on the west coast of India and has completed 125 years of glorious service to the nation’s maritime trade.” 125 years ago Mormugao Port (MPT) Trust set up by collaboration between British and Portuguese Colonialism. From its inception in 1885 till 19 December 1961 MPT was operating in colonial context directly under Portuguese rule. EIA study has hidden this fact. Then in 1961 as per records of the USSR vetoed UN resolution of December 18, 1961 India invaded Goa. Later on Supreme Court of India confirmed this status in Gosalia mining case where in it was held that India annexed Goa by Conquest. Claims of MPT of glorious service to nation’s maritime trade are anti-national and amounts to glorifying prevailing colonial system. MPT carries forward the Colonial Heritage. MPT was born in the womb of Colonialism and flourished as colonial enterprise irrespective of which country it has served with glory.
3. On page 1-2 it is stated “MPT presently imports about 7 million tons of coal. MPT has 2 dedicated coal berths which has a combined capacity of about 12 million tons per annum. Although MPT is ideally located to serve the industries in the hinterlands of Karnataka, a lot of cargo including coal is imported through some of the ports situated in eastern coast of India despite the fact that the rail distance from these port to the industries are much more compared to Mormugao Port.” This shows that Goa is only used as corridor for coal transportation at the enormous risk of Public Health and environmental hazards. For past decade and a half there are constant voices of protest against coal pollution in Vasco city. This fact is hidden from this EIA.
4. On Page 1-4 it is stated “The existing depth of the outer channel is 14.40 m and inner channel is 14.10 m. A fully loaded Panamax vessel can be handled under these conditions by taking advantage of tide. The proposal is to deepen the outer channel to -19.80 m and inner channel to -19.50 m. This will facilitate navigation of Capesize vessels at any state of tide.” Mormugao Port is a natural harbor this dredging will create enormous ecological hazard and must be avoided. Ecological damage to bio-diversity is confirmed in the study conducted by committee appointed for this purpose by National Green Tribunal (NGT). Further more dredging carried on by MPT has been stayed by NGT after terming the MOEF Environmental clearance without Public consultation “as illegal, arbitrary and violation of environmental notification of 2006.”
5. Further it is stated on the same page 1-4 “MoEF&CC has accorded the Environmental Clearance to M/s Mormugao Port Trust for the above mentioned project vide letter 10-23/2014 dated 9 th February, 2015. However, Hon'ble NGT, Pune Bench vide order dated 2nd September, 2016 has quashed and set aside the EC letter dated 9th February, 2016.” Politically the decision of MOEF to grant permission for capital dredging without public consultation reflects colonial mindset of the Government of India towards Goa.
6. It is further stated on page 1-5 “The total quantity to be dredged was estimated to be about 15.40 million cum. Most of the dredging work will be undertaken with a Trailer Suction Hopper Dredger (TSHD). A Cutter Suction Dredger (CSD) will also be deployed for hard material and weathered rock if encountered. Out of which about 55% work has been completed in the year 2015. Hence, remaining quantity of dredged material will be about 7 mm3.” This confirms colonial mindset of Government of India towards Goa; 55% of work completed which is described by NGT as illegal, arbitrary and violation of 2006 notification. Those responsible for this at MPT and MoEF must be criminally booked and prosecuted.
7. On Page 1-5 it is stated “The Study Area for the EIA Study shall be the area within 10 km radius of the proposed navigation channel at the Centre.” When the Study Area is 10 km in radius covering several villages and cities why while Public Hearing was underway did MPT chairman Jeyakumar told press on 28/04/2017 that people who are outsiders to Vasco are raising objections and People of Vasco are silent? Why is he creating distinction between Vasco residents and those from outside? What is the basis for such comment? MPT itself has not limited itself only to Vasco, it has extended its jurisdiction over Zuari river mouth up to Cortalim-Agassaim bridge and down south upto Betul from the year 2000. In 1997 MPT permitted illegal drilling at Cacra village on Zuari coast. In 2010 MPT leased out Zuari river to Marinas requiring enormous dredging of Zuari. Why MPT has stepped out of Vasco if it cannot tolerate People from outside Vasco expressing their views on affairs of MPT when they are invited through Public Notice from Goa State Pollution Control Board?
8. On Page 1-12 there is confirmation of ecological damage already done by dredging “The Committee appointed by the NGT submitted its Report dated 27th May, 2016. As seen from the said Report, the Committee suggested that the actual damage already done to the estuarine environment, the biodiversity in particular, should be assessed after the completion of the proposed dredging.” When the damage has already been inflicted and confirmed why those responsible has not been booked? This shows colonial mindset of India towards Goa. This has to change. Immediately criminal proceedings must be initiated without delay against those responsible and further developments with regard to dredging must cease.
9. Pages 1-12 and 1-13 state “It has been the case of MPT that the proposed project of dredging undertaken by MPT is in larger public interest and deepening of the channel would enable navigation of cape size vessels in the Mormugao Port which would reduce the sea freight rates and attract Port users to use the Port and save effective costs of logistics.” No larger public interest is stated in EIA with example. There is only a public ruin in the form of dust pollution in Vasco city as visible Deepening through dredging only serving private interests of corporate such as Adani, Jindal and Vedanta.
10. Page 2-1 states “The main user for MPT is currently JSW steel. JSW steel imports about 7 million tons of coal and exports about 1 million ton of finished steel products through MPT. However their coal requirement is in excess of 15 million tons and thus, has to depend on ports on the Eastern Coast like Krishnapatnam for coal imports despite the fact that MPT is closer to their steel plant situated at Toranagallu.” So it is clear that main user is JSW who needs to cut transport distance to steel plant at Torangallu in Karnataka. Main user is not public but Private Corporation. Goa is only corridor for Coal and Coke.
11. Page 2-2 states “Coal imports for JSW at MPT are carried out at Berth No.6 which is operated by South West Port Ltd, a group company of the JSW. Another Coal Berth No.7 has recently been made operational by Adani Port Terminal Ltd. The approach channel is about 6 km long.” Here we have more evidence of who are the beneficiaries of deepening of approach channel JSW and Adani. Where is larger public interest?
12. Page 2-5 states “SWPL has commissioned Rapid in Motion Silo facility in July 2014. Also Coal Berth No.7 operated by Adani Ports has become operational in June 2014. Adani Ports have also installed Rapid in Motion Wagon handling facility. Hence the coal traffic is set to rise further.” Who permitted them to install this facility? Profit driven Industrialization as it comes across here is damaging to ecology. Should ecology be allowed to damage because these two corporate has installed Rapid in Motion Wagon handling facility? No.
13. Page 2-6 states that “The main importer of coal through Mormugao Port is JSW Steel Plant located at Toranangallu, Karnataka.” Should Goa tolerate enormous damage to its ecology and Public Health to satisfy JSW? We are opposed to Goa being treated as mere corridor for Coal.
14. Page 2-6 further states “At present, coal meant for JSW are brought in gearless vessels of about 75,000 DWT size. Coal importers stand to gain substantial freight advantage by deploying Capesize vessels. The deepening of the navigational channel will not only provide impetus for existing steel companies to increase their capacities, but also encourage new steel plants to come up. The capacity Capesize ships will be of the order of 185,000 DWT.” This is 110% increase in the size of ships to enter MPT carrying Coal, Coke to JSW plant in Karnataka. Natural harbor at MPT is not suited for handling capsize ships and they must not be allowed at MPT. No deepening of approach channel must be carried on.
15. Page 2-17 states “The dredge spoil will be disposed of in the offshore disposal area.” This is very risky proposition. Fish habitat will suffer dangerous blow. We are opposed to dredging activity for deepening of approach channel.
16. Page 2-23 states “MPT one of the thriving major ports on the west coast of India, has recently lost its business substantially due to the closure of the Iron Ore mines in the State of Goa.” Even though MPT has lost its business nature got respite by mining closure in Goa, ground water re-charged and fresh air was available to breath again. People after many years cultivated vegetable in their gardens freed from mining dust air pollution. These effects of closure of mines in Goa are not reflected in this EIA.
17. Page 3-11 states “Infrastructure wise Goa has an advantage over other exporting regions in the countries in view of its being endowed with a deep sea port and waterways that crisscross the territory facilitating barge transport.” Deep Sea Port and waterways are nature’s gifts to Goa. This does not justify declaring six rivers of Goa as National Waterways. This declaration is an abuse of Goa’s rivers.
18. Same page 3-11 further continues “The two rivers Mandovi and Zuari, provide cheap river transport.” No study is mentioned on impact on these rivers’ fisheries and ecology due to transportation by barges of industrialists. Further page 5-8 warns “Due to the non-availability of reliable long-term fishery data, it is rather difficult to predict the actual impact of dredging activity on estuarine fishery; hence it is strongly suggested to carry out a detailed comprehensive study covering a year-around survey for fishery, fish spawning ground and ichthyoplankton of bay-estuarine system of Zuari. This is particularly important as the maintenance dredging will be conducted about 6-8 weeks of the years.”
19. Cacra village is not mentioned as Fishermen habitation and as Fish landing centre any where in the EIA. MPT sanctioned illegal drilling in Cacra in 1997 and faced public opposition from the local people.
20. Negative impacts on fisheries due to dredging are listed in EIA itself at page 4-6:
Dredging harms the ecology, limiting the ability of the dredged habitat
and nearby areas to function as a nursery area, or feeding ground for all
the marine fauna.
Physiological stress to marine fish and commercially important species
by creation of short-term higher sediment loads in the water column.
Adult fish are likely to move away from or avoid areas of high
suspended solids, such as dredging sites, unless food supplies are
increased later on as a result of increases in organic material
transformation through heterotrophy and their biomass build-up.
Increased bioaccumulation of contaminants in commercially important
Increase in the population of undesirable species such as viruses and
Reduction in habitat due to loss of benthic primary producer habitat.
Temporary reduction/increase or change in fish catch may occur due to the proposed activities.
21. Cumulative impacts are listed on page 4-9:
The probable impacts might include, introduction of alien and invasive
species due to the combined action of long distance vessel movement
in and out of the port area and proposed dredging activity.
The transport and spillage (due to un-maintained and un-managed
transport) of ore and other chemicals may have exacerbated impacts
due to proposed activity.
Dolphins have been regularly sighted near Dona Paula bay area (4.5km
from the project site), the increased turbidity and noise levels may drive
away these highly sensitive species.
Like occurrence of unintended events such as vessel collision,
accidents, fire and other inadvertent events. These occur mainly due to
lack of coordination, casual approach, un-managed port and associated
activity and no timely communication within and between the agencies
involved in offshore activities. These events may result in human
casualties if there are no precautions taken.
Oil spills due to any unplanned eventuality is one of the major threat to
the marine biota and can have a major long term irreversible losses
depending up on the extent, quantity and expanse of spillage.
22. Page 6-5 states “High diversity of Mangrove exist in this (Sancoale) area. Presence of schedule species such as windowpane oyster, and other commercially important molluscs such as clams, oyster, windowpane oyster and cephalopods etc. Chikalim-Sancole bay is considered as ‘Hotspot’ of marine biodiversity. Chicalim and Nauxim Bays in the Zuari estuary is home for windowpane oyster which is schedule species.” Dredging will have adverse impact on entire marine ecology of Sancoale- Chicalim bay.
23. Page 6-6 states “Project proponent should make necessary attempt to declare the coral reef area as a “Biodiversity Conservation Zone” so that fishing and tourism activities can be regulated.” Project proponent here is MPT and it has already destroyed bio-diversity while dredging of approach channel upto 55%. Destroyer of Biodiversity must be punished first. In this case it is MPT rather than bothering about Bio-diversity Conservation Zone.
24. Page 1-4 states “Eastern Port have deeper channel to handle capsize vessels.” What is the size? Why data is not supplied? Even if this is true it is equally true that Ports have destroyed beaches on Eastern coast of India. Deepening of Port at MPT will certainly destroy beaches putting fishermen and tourism stakeholders in tremendous hardships.
25. On Pages 3-62 and 3-63 caste profile of study villages is presented. OBC category is omitted while SC and ST is prevalent. According to Mandal Commission report 52% of Indian Population is OBC. Why this EIA ignored OBC in study area?
We oppose deepening of navigation channel at Mormugao Port for approach channel for the above cited reasons.
President, Goa Unit