Thursday 11 May 2017

BMM objections to Jindal's coal handling at MPT

Date: 29th April 2017
The Member Secretary
Goa State Pollution Control Board,
Panjim, Goa

Subject: Objections to Proposed Terminal Capacity Enhancement at Berth 5A-6A of Mormugao Port, Mormugao, Goa
I place my objections to the above mentioned subject as under:
1.    Chapter 1 of the EIA of the above proposal prepared by WAPCOS Limited (A Government of India Undertaking, 76 C, Sector 18, Gurgaon – 122015, Haryana, India states “Mormugao Port is a Major Port on the West Coast of India has completed 125 years of glorious service to the nation’s maritime trade.”  MPT was never part of nation’s maritime trade for 125 years. It became part of India only in 1961 when India annexed Goa through conquest. Before that it was developed to serve Colonial powers Portugal and England for colonial purpose. Declaring 125 years as glorious service to nation’s maritime trade is politically objectionable as it is vague. Which nation did MPT served gloriously for 125 years?
2.    EIA Chapter 1 further states “JSW Energy Ltd. (JSWEL) is the first Independent Power Producer (IPP) set up in the state of Karnataka. The company has set up 2 units of 130 MW each and two units of 300 MW each and all these units are generating power using Corex gas and coal.” So it is assumed that these MPT berths will be used for the import of coal for this independent power producer in Karnataka. Goa should not be allowed to suffer due to coal for this power producer.
3.    EIA Chapter 1 continues “Mormugao Port Trust (MPT) is strategically located to cater to the needs of the coal requirement of steel and power plants of its hinterland in Karnataka. 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.” So Goa is only the corridor for Coal. We oppose making Goa corridor for Coal.
4.    EIA Chapter 1 continues “Imports/Exports through Capesize vis-à-vis Panamax vessels will result in freight advantage and thereby the industries stand to benefit.” So Goa no way benefits. Only industries stand to benefit. People of Goa do not stand to benefit. They stand to loose their health due to coal pollution.
5.    Chapter of the mentioned EIA continues “The dust barrierisation and pollution prevention-control of the existing facility will also be brought to the level of state-of-art protection to ensure lesser total pollution from the proposed facility.” So currently it is not at the level of state-of-art protection. And even after bringing in state-of-art protection pollution will not be stopped. So what is the use of inducting state-of-art protection? JSW existing operations at these ports must be stopped, EC must be denied for expansion.
6.    EIA studies must be comprehensive and not fragmented. Fragmented impact assessment is deceptive and misleading. Currently WAPCOS has done three EIA studies: two for MPT and one for JSW in a fragmented manner.
7.    Above mentioned EIA of JSW in Chapter 2 states ““Mormugao Port Trust (MoPT) is strategically located to cater the needs of the coal requirement of steel and power plants of its hinterland in Karnataka.” Just because MPT is strategically located Goa must not be abused through coal pollution and heightened risk to life.
8.    Chapter 2 of this EIA notes “MPT has taken up the dredging of the approach channel and the port area for permitting navigation of Cape Size Vessels of up to 180,000 DWT.” Dredging for channel deepening has already destroyed bio-diversity as per study report submitted to NGT in this matter. No dredging of Arabian Sea must be permitted to be carried on by MPT or anybody else.
9.    Further Chapter 2 continues ““MPT has proposed to deepen the approach channel to suit the navigational requirements of Capesize vessels. The outer channel which are having present depth of -14.4 m will be deepened to -19.8 m and the inner Channel from -14.1 m to -19.5 m. This will facilitate navigation of Capesize Vessels at any state of the tide.” The success of this project depends upon commitment from MPT to deepen the approach channel. So when one is inter-dependent upon another why have Public Hearings fixed separately?
10. Chapter 2 of mentioned EIA continues “Ships presently calling at the Berths are generally up to 80,000 – 90,000 DWT (Panamax size vessels). Consequent upon the completion of dredging for the draft depth of 19.8m by Mormugao Port, the port would be able to handle cape size vessels up to 180,000 DWT capacities.” What are the ecological, environmental and social costs of this dredging from 14.1 m to 19.5 m ? There is no data in the EIA on this subject.
11. Silent feature listed in the above mentioned JSW EIA under Chapter 2 as “No additional land area or waterfront is involved” is deceptive as the project is entirely dependent upon dredging of water front by MPT and that is impacts not discussed here jointly is clearly dubious.
12. JSW EIA states in Chapter 2 “Break Bulk Cargo (Import Cargo) (Coal, Coke, Coking Coal, Limestone, Iron Ore, Bauxite, Dolomite etc.)” This has been the scene of pollution for Vasco for very long and source of public outcry. This is ridiculous, adding insult to the injury!
13. This EIA further notes in Chapter 2 “Steel Slab / Coil, Steel Finished Products (Export Cargo)” So here is export of steel manufactured in Karnataka exported through MPT. Goa is just a corridor. Why Goa has to suffer as corridor for coal?
14. Chapter 2 of JSW EIA states “The maximum fully laden vessel draft that can be accommodated within the harbour at all stages of the tide is 13.4 m allowing for under-keel clearances. However, vessels are sometimes loaded up to 14.1 m draft, departing only on the high tide. However, the present channel is planned to accommodate the Cape Size vessels with a dredged depth of -19.8 m. Once dredging is completed the Cape Size vessels would call upon the Port.” Once again there is reference to the dredging, so the three Public Hearings must be joint as ground operations are joined and dependent upon one and another.
15. Chapter 2 of JSW EIS continues “In the recent years the International price for Iron Ore has gone down appreciably. This has made import of the Iron Ore at low prices to the Indian Sub-continent affordable. The Western Australian and Brazilian Iron Ore with higher Iron content has made the life of steel makers’ lot easier.” So because of lowered price of iron life of steel makers is lot easier. Do people of Vasco has to suffer pollution only because of lowered price of iron ore?
16. Chapter 2 of this EIA of JSW further states “The main importer of coal through Mormugao Port is JSW Steel located at Vijayanagar, Karnataka.” So to serve JSW Goa has to surrender and sacrifice itself as corridor? This is ridiculous and must stop.
17. Further JSW EIA makes it very categorical disclosure ““Coal importers stand to gain substantial freight advantage by deploying Capesize vessels.” What does Goa and our People stand to gain? We cannot even breathe fresh air in Vasco because of Coal air pollution. Destiny of Goa cannot be left in the hands of Coal importers. Coal import from Vasco MPT Port must be stopped immediately.
18. Chapter 3 of this EIA points to “presence of coliform oranisms in two out of five samples indicates anthropogenic source of pollution.” This is an evidence of ground water pollution.
19. Table 3.41 in this EIA dealing with Fishermen population in the study area completely ignores Fishermen population in Madkai, Agassaim, Siridao, Bambolim, Nauxim, Carcra, Odxel, Dona Paula and Caranzalem. For what reason the entire fishing villages are omitted from EIA? This is unacceptable and very dangerous way of conducting EIA.
20. Chapter 04 of this JSW EIA has points “potential sources of environmental impact from operations may include shipping movements, discharge of wastewater and solid waste, accidental spillage, cargo unloading/loading and storage, noise pollution, air pollution due to material transfer and handling.” When all impacts are listed and are known this JSW project must be rejected.
21. Chapter 04 further states “the accidental spillage of oil or fuel from construction machinery that may run off into near-by surface and groundwater water bodies and/or uncontrolled liquid effluents from the construction site.” So the possibility of ground water pollution is admitted in EIA itself. This is again dangerous and unacceptable.
22. Chapter 04 further states “potential sources of impacts on marine water quality during the Port operations are:
§  Disposal of Jetty related wastes
§  Disposal of ship generated wastes
§  Escapement of cargo, and
§  Effluent from coal stack yard”.
           These are enough reasons to anticipate diversity of polluting effects.
23. Chaper 04 of the above mentioned EIA further states “The International Convention for the Prevention of Pollution from Ships, 1973, as modified by the protocol of 1978 (MARPOL, 73/78), has issued guidelines for prevention of Marine Pollution.” Present record of enforcement of this law is dismal. Several barges release their waste and fuel into Mandovi and Zuari rivers. Barges through left over ore into these rivers and also into Cumbharjua river. Barges are washed in the middle of rivers causing pollution of water and environmental hazard. Violations from ships carrying ore are known even to the highest authority at MPT and yet this law is not enforced and pollution is ignored. We quote here former Chairman of MPT from his exclusive interview to Herald in Goa on 17/06/2015 “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.” These aspects are ignored by MPT itself and possibility of enforcement is zero. Hence this project must be rejected EC by MoEF.
24. On page 4-12 of this EIA it is stated “any fishing within the Jetty limits will be prohibited for safety and security reasons.” This is a direct admission of project that is bias against fishing and fishermen. Furthermore there has already been restrictions placed on fishermen in Mandovi and Zuari rivers where ore transportation is carried on through barges.
25. Page 4-15 states “Coal dust needs to be cleaned regularly from coal stack pile areas using water sprays. The water can be channeled from various locations and brought to a common point for treatment prior to disposal.” From which locations in Goa the water is going to be brought for spraying of coal is no disclosed.
26. The same page 4-15 admits air pollution from Coal “During unloading and storage at
            coal stockyard, the following sources/activities could lead to air pollution:
·         Dust caused by displacement of air
·         Dust blown out by the wind
·         Wind erosion from disposal sites”
27. This air pollution has turned Vasco city into a ghost town turning everything black and caused enormous health and environmental hazard. Goa cannot afford to be a corridor for coal. Dust blows already caused so much of public outcry. In China some cities are so polluted that blue sky is invisible. Companies make business selling packed plastic bags of pure air imported from Canada. Several Children born after 1992 in Beijing have not seen the Sun. Its all smog due to air pollution. Is that way we are heading?
28. Page 4-16 states “Water sprinkling dust suppression systems will be provided at strategic transfer points.” How much water will be used for sprinkling? From where the water will be supplied for sprinkling?
29. Page 5-1 states “The collected oily matter is stored in cans, etc. and disposed at the landfill sites designated by the district administration.” Oil waste will be disposed off in Goa. Where in Goa it will be disposed off? No answers available in EIA.
30. Page 5-5 states “All the solid wastes arising in the premises shall be properly classified and handed over to Goa Municipal Corporation for disposal.” Goa Municipal Corporation does not exist. This is fraud committed by JSW.
31. Pages 5-5 and 5-6 states “The reduction in the emissions is achieved by continuous spraying of water so that the surface remains moist and the dust gets suppressed.” This entire process is of spraying of water to achieve reduction in the emissions places huge pressure on Goa’s water sources. Goa can’t afford to waste precious water on dozing off perennial coal fires. Hence JSW handling of coal in Goa must be stopped. How much water will be needed for spraying annually?
32. On page 5-2 to 5-3 there is promise “The project authorities will work closely with representatives from the community living in the vicinity of project area to identify areas of concern and to mitigate dust-related impacts effectively (e.g., through direct meetings, utilization of construction management and inspection program, and/or through the complaint response program)”. The grammar of this is in future tense: the project authorities will work closely. JSW has been functioning at MPT from 2001 onwards. Why from that time till date no representatives from community living in the vicinity involved? On the contrary there is tension with the entire community in Vasco due to air pollution caused by Coal. Tension with local community is visible here. Further boiling could throw situation out of control.
33. Figure 5.1: Water sprinkler system at ship unloader facility. From where water will be supplied? What is the annual requirement?
34. Figure 5.2 A: The water spray/mist system in the berth hopper for dust suppression. From where water will be supplied? What is the annual requirement?
35. Figure 5.2 B: The water spray arrangement on the berth conveyor with the dust hood. From where water will be supplied? What is annual requirement?
36. Figure 5.2 C: Water spray system at the transfer towers and conveyor systems. From where the water will be supplied? What is the annual requirement?
37. Figure 5.3: Layout showing sprinkler system for open stack yards. From where the water will be supplied? What is the annual requirement?
38. Page 5-14 states “The water spraying is done periodically only to dowse the fire during stack piling.” This means there is burning coal involved. This is an insult to Goa and scandal to ecology.
39. Page 5-17 states “Mobilization procedures are required only in case the spill is likely to affect the coastline and damage the marine sensitive areas.” Possibility of oil spill affecting the coastline and damaging marine sensitive areas is very real and dangerous scenarios could result.
40. Page 5-18 states “Prepare releases for public and press conferences”. So this is a way public and press is going to be controlled? Is it brainwashing and manipulation of public opinion?
41. Same page 5-18 further states “The National Oil Spill Disaster Contingency Plan (NOS-DCP) describes the responsibilities of ports handling petroleum and its products. Indian Coast Guard is the Central Coordinating Agency for marine response.” So Oil spill can result in very serious disaster.
42. Figure 5.6 presents Water balance diagram during the operation phase with MPT as credited source. JWS requires 3 lakh litres of water daily for dust suppression and additional 1 lakh litres of water for fire fighting. Monthly requirement for fire fighting will be 30 lakh litres of water. While requirement for 365 days will be 365 lakh litres of water. Monthly requirement of water for dust suppression at the rate of stated figures of 3 lakh litres per day amounts to 90 lakh litres of water. While requirement for a year (365 days) it increases to 10,95,00,000 litres. Annual requirement of water for dust suppression and fire fighting totals to 14,60,00,000 litres per year. All this water is to be sourced from Goa. This is unacceptable. When water tanker comes to localities each family not even get 200 litres of water per day. Several schools children have no access to running water in toilets. Yet Jindals will be using water for the destruction of Humanity.
43.  This Jindals project has no benefit to Goa and hence must be rejected. Project proponents and Government officials are colluding to destroy Goa. GSPCB has intentionally fixed three separate Public Hearings in order to harass people of Vasco and beyond. EIA report of this project is fraudulent document. GSPCB should have assessed this report prior to Public Hearing. Cumulative EIA needs to be prepared rather than three separate EIAs.

Based on above grounds we strongly oppose proposed Terminal Capacity enhancement at berth 5A, 6A of Mormugao Port Trust by M/s South West Port Ltd, Mormugao- Harbour, Goa. However in spite of such a credible public objection if this project of JSW still gets EC from MoEF then it would be one more confirmation of corruption in MoEF as publicly alleged in press by Goa Chief Minister Manohar Parrikar on 06/09/2012 that MoEF is a corrupt Ministry and grants EC clearances based on collection of bribes from corporate and turns blind eye to rampant illegalities in Goa.

Moreover Jindals project at MPT represents return of Peshwayee in India. We are in the 199th year of the destruction of Peshwayee in the battle of Bhima Koregaon at the outskirts of Pune. It is fitting that MoEF reject EC to JSW for this project.

Thank you.

Yours Sincerely,


Maggie Silveira
Goa Unit

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