From:
Dr. Sebastiao A. Rodrigues
Convenor,
Bharat Mukti Morcha, (Goa State)
48/2,Vanxim, P.O. Piedade,
Ilhas, Goa
Mobile: 9923336347
Date: 11 August 2013
To,
The member secretary,
Goa State Pollution Control Board,
Saligao, Bardez, Goa
Subject: Objections to the commissioning of Block-I Bicholim Mineral Block by Vedanta Limited
Madam,
We strongly object to the commissioning of Block-I Bicholim Mineral Block by Project Proponent (PP)Vedanta Limited on following grounds:
1. PP applied to MoEF & CC for Terms of Reference to Prepare EIA report on 16 March 2023. In their application PP disclosed that their period of baseline data collection lasted from 01 October 2020 to 31 December 2020 covering one post monsoon season. Executive summery (Page 04) of Block-I Bicholim Mineral Block states that MoEF&CC accorded Terms of Reference on 16 June 2023 and Baseline Data was collected during the period from March to May 2023. So there is fraud committed by PP by providing two different dates of periods of baseline data collection. This is indeed a fraud because EIA report does not mention anything about baseline data collection period of 01 October 2020 to 31 December 2020. Moreover that was time of Covid-19 lockdown in Goa. In view of these fraudulent manipulations and inconsistencies observed baseline data collection period is a suspect. PP therefore be directed to prepare fresh EIA without any inconsistencies on period of data collection and conduct fresh Public Hearing as per ToR no.70.
2. Neither the PP nor the Goa Government has consulted local decision making bodies namely the Panchayats before going for auctioning of the mine. This way of functioning is completely anti-democratic. We therefore strongly object to the way auctioning process itself has been carried on.
3. We take strong objections to the Reference to this mine in EIA as "Green Field Project". This amangation of 05 mines is operating as per available records from the year 1941 and has completes 82 years of its functioning on 20 August 2023. Moreover as per online sources PP is associated with these Mines from 2009 and as per records with Department of Mines and Geology PP proponents logo appears on large number of correspondence concerning these amalgamated Mines like the letter of Agent M.K. Reddy to the Central Empowered Committee (CEC) dated 14 November 2012 denying illegal mining and encroachment by M/s Dempo & Souza (Sesa Resource). Moreover page 16 of EIA admits that there are totally 5 pits within the proposed mining lease and Table 2.5 even presents details of Active pits. Further Mines Minister and Chief Minister of Goa Dr. Pramod Sawant on 09 August 2023 has stated on the floor of the Goa State Assembly that these amalgamated Mines in under EIA consideration are granted for the same company who used to operate before 2012 Supreme Court ban. Video online Facebook link to the entire mining debate under reference here is available here: https://fb.watch/mjb2PK3tbt/?mibextid=Ol9HDD
4. PP therefore inherit all the liabilities of all the five Dempo amalgamated Mines: 11/1941, 12/1941, 13/1941, 14/1941 and 15/1941. Dempo mining corporation private limited was renamed as Sesa Mining Corporation Limited on 18 November 2010. There already exists sufficient evidence of public nuisance and environmental security threats already created by these amalgamated Mines over the past 82 years of which PP is associated directly and indirectly from 2009 for 14 years. Research Article published in Research Journal of Environmental and Earth Sciences 11(1): 1-13, 2019 titled "Impact of Past Iron Ore Mining on the Sediment Ore of Rivers of Goa: West-coast of India by N.T.Rane and V.M. Matta of the Department of Marine Science, Goa University has made critical observations regarding Bicholim River that according to the Executive Summery flows at the distance of 0.23 kms from the Lease boundary carry large amount of polluted water into its waters. Abstract of this scientific study notes "the study revealed that the Bicholim river is strongly polluted with Fe & Pb...High contamination of Fe and MN and considerable contamination for Pb and Cr in Bicholim River sediment core can be attributed to enormous mining activities and discharge of wastes in this region." In the light of this study commissioning of Block-I Bicholim Mineral Block will further aggravate ecological health of Bicholim River that connects Mandovi river. Thus study has been ignored by PP thereby for their ulterior motives to contaminate and pollute Bicholim River.
5. North Goa Disaster Management Plan 2023 on page 184 foresees landslides due to mining in three Villages due to this amalgamated mine. In Mulgao survey numbers 116 and 117, 80 houses and 55 hectares of land is forecasted to be impacted. In Maem 30 houses and 25 hectares of crops are predicted to be negatively affected. In Sirigao survey numbers 81 & 85 are classified to be likely damaged due to mining triggered landslides. Goa Government has already accepted landslides threats due to mining. Actual threats are much more serious and dangerous. On this ground too Block -I Bicholim Mineral Block must not be permitted to be commissioned.
6. Modification to Approved mining Plan dated 26 October 2017 presented on the floor of the Goa Legislative Assembly by Chief Minister Dr. Pramod Sawant in response to LAQ from Yuri Alemao states name of this mining lease as M.L. No. 08/AMLG(MG-5)SMCL/17. This information is concealed in EIA. Further page no. 07 states that out of 478.5206 Ha lease area of this mining lease 407.7446 Ha is acquired. That means 70.7446 Ha of land is not aquired. Which are the survey numbers and villages where this yet to be aquired land is located? This information is concealed in presented EIA report by PP. Further Page no. 09 of the modification to Approved mining Plan states that Bicholim Amalgamated mine was granted lease on 20 August 1941 and expires on 21 November 2027. All these details are concealed from EIA report. Information furnished in EIA Study is defective and misleading and PP be directed to prepare fresh EIA and hold Public Hearing afresh.
7. This amalgamated Mine PP is involved illegal mining activities and owes more than 100 crores of Rupees to the Goa State as revealed from the LAQ discussion on the floor of Goa Legislative Assembly on 09 August 2023. Print copy of the colored Google map attached as Annexure I in the 11/1941 mining lease file at the Goa Department of Mines and Geology, reveals investigations by Shah Commission revealing expansion of mining activities beyond lease boundary taken by hand held GPS and Sesa Goa Limited Lease boundary taken by DGPS. Its illegalities are confirmed. EIA reports has not attached any document certifying that PP are not involved in illegal mining at this amalgamated mining site. This I in violation of ToR no. 07 and among major grounds for rejecting PP application to commission mining at the proposed site.
8. EIA report does take into account destruction of paddy fields, drying of ground water of 60 wells in Sirigao village due to mining activities of the PP together with other two existing Mines of Chowgules and Bandekars. Cummilitive impact of the village due to operation of these Mines is already a mega disaster encompassing human habitation and religious structures. The to Assanora river due to seepage of river water into mining pit is grave and have not been dealt with in adequate manner. Moreover objections of the villagers against commissioning of auctioned Mines in the village filed before the Goa Government authorities are ignored by the PP. NEERI report has already proved thar siltation of Sirgao paddy fields is due to mining leases operating in the village including the mine that PP desires to commision.
9. PP has pathetic track record in treatment of people and ecology. They are involved in Nadidihi Iron Ore mine of ESL Steel Limited in Jharkhand, India. Currently people residing nearby are compeled to use polluted and untreated beneficiated water from its mines for drinking purpose.
10. Such glaring violations are carried on by PP by efficient Public Relations. In fact one ex-officer of PP is currently Chairman of the Goa State Pollution Control Board named Mahesh Patil.
11. Conduct of the PP can be understood from the observations made in its Judgement in T.N.Godavarman Thirumulpad....(Petitioner) versus Union of India....(Respondents)and in the matter of Vedanta Alumina Ltd ...(Applicant) of 23 November 2007. Four observations of construction Supreme Court we quote here. (1) NORWAY has dropped British mining and metals group Vedanta Resources from its $ 350 billion oil fund at the recommendation of the Fund's Ethics Council, which blamed it for environmental damage and human rights violations, the Finance Ministry said. (2) Vedanta Resources is accused of having caused environmental damage and contributed to human and labour rights violations. (3) We cannot take the risk of handing over an important asset into the hands of the company unless we are satisfied about its credibility. (4) In the corvumstances keeping in mind the totality of the above factors, we are not inclined to clear the Project. Company with such a dubious record must not be allowed to commission the amalgamated lease.
12. Major water bodies such as lakes five lakes in Mulgao and seven lakes in Lamgao village are not included in the baseline data of the presented EIA/EMP report. Lakes in Mulgao occupy 21,050 square meters of land covering survey nos. 71/0, 69/1, 61/2, 257/1 and 117/1. In Lamgao seven lakes cover area of 6,925 square meters of land covering survey nos. 5/18, 8/1, 14/1, 14/3, 22/9 and 25/1. Additionally several fresh water springs in Maem village is excluded from baseline data in EIA. Total lake area amounts to nearly 03 ha. PP be directed to conduct fresh EIA with correct baseline data and go go for fresh Public Hearing.
13. Maem lake springs numbering two dried up. Before the mining pit was excavated for the ore for more than 50 years resulted in drying up of two springs that emptying water into Maem lake. This is because ground water regime got disrupted as the depth of the mining pit increased steadily.
14. In the close proximity of this mining project there are 25 wells in Bicholim with water. PP carried on the study on ground water from the various villages beyond Bicholim Town. Wells are the indicators of the ground water existence in the region. There are at least 25 wells in the close proximity of mining area. Consultants should have studied water levels in the wells in the lean period of summer that is May but this is not done as per EIA. Sirigao and Pissurlem are classic example where wells have dried up due to the mining pits which have gone below 50 to 60 meter depth and resulted in drying up of wells. This fact has been denied by all the mining companies in Sirigao that their mining pit caused it. Histoy of wells going dry will repeat in all the wells situated in close proximity to the mine and trigger off blame game between the locals and the PP. PP should have consulted Water Resources Department, Government of Goa on the question of ground water. In Maem at the foot hill of 2 Top Hillock there are 2 small lakes ( tanks) which go dry in the month of March, April and May. Springs also dry up due to the mining pit on the other side of 2 Top.
15. EIA Executive summery page 07 states “Mine does not have any forest land within the lease. The area is located on the foot hills of western ghats belt.” It is not true that the area is located on the foot hills of the western ghats belt. The distance between this mining project and the foot hills of western ghats is around 22 kms. In the foot hills of the Western Ghats is Taluka of Sattari. Whereas the Bicholim Taluka where this mine is located is Plateau region. Therefore the baseline data appears to be the cut and paste job. Hence this EIA study cannot be accepted for this Public Hearing to avail EC.
16. EIA Executive summery comment on page 07 “Mine does not have any forest land” is misleading. Name of at least one of the amalgamated mine 12 of 1941 indicates that there was forest here when the lease was granted 82 years ago. The name of this mine is Vagachiper that mean tiger favoured spot.. Tiger need forest as habitation and this mine was forest in 1941 until mining destroyed the same. Similarly mining lease 14 of 1941 that is part of amalgamated mine is named Toticho mor which means Peacock with a beak. This indicate that then existed forest where there were plenty of Peacocks. There is still Government Forest that is encroached by mining company in Mayem village. Boundary limit of 2 top in Maem is covered under forest land currently under company’s illegal possession.
17. Mining as serial disaster:This amalgamated mine has a history of triggering disasters. BIcholim was flooded on 13 June 1981 causing huge damage to the property. Government appointed expert committee to investigate the occurrence of flood in BIcholim. Page 236 of Fish, Curry and Rice: A source book on Goa, its ecology and lifestyle (2002) has reported that government appointed committee concluded that 1981 Bicholim floods were because of nearby mine. Nearby mine then belonged to Dempo Mining Corporation. In Accident of 1991 at Valshi in Bordem wherein 04 pople were killed, 06 injured and 144 farmers lost their paddy crop. Mining accident on 20 November 2011 in Mulgao caused breach of bund leading to siltation of paddy fields, siltation of arecanut plantations and silt entered nearby village temple. There was huge run off in 2009 at Paj wadda, Bicholim during rainy season. Water gushed down into locality carried mining silt, stones, mud on the entire road from Zantye Cashew factory to the building where LIC office is located. Cause stretched upto Petrol Pump and Shops. Nearly all the houses in Paj wadda had generous deposit of mining silt.
18. Page 07 of Executive Summery notes “The general elevation of ML area varies from 169.14 m to -37.24 m above MSL.” With 169.14 m elevated location disasters cannot be managed. In spite of all the precautions disasters are bound to occur. We recommend that since disasters cannot be avoided this mining project must be closed.
19. EIA does not mention anything about beneficiation plan. It gives an impression that ore will be exported without washing. However the approved modified plan tabled in the Goa State Legislative Assembly mentions wet beneficiation plan for at Mine portion at Top Pit 1.
20. Page 16 of EIA notes that the “slope of Overburden and Mineral benches shall be maintained at 70 degree and overall slope of <26 degrees respectively.” What is the gradient of highest point of the core zone with respect o Town of BIcholim, River Bicholim, villages of Lamgao, Mulgao, Sirigao, Bordem and Maem? With 3500 mm of rainfall mentioned in the EIA report with 70 degrees gradient of overburden disaster in monsoon season is inevitable with elevation of 169.14 meters. Gradient of mining site without overburden is not given in EIA study.
21. Page 17 of EIA has Table 2.7 Raw Ore Material (ROM) quantity if given as 3000000 tonnes. According to Vedanta letter dated to the Director General (Statistics), Nagpur ROM was reported as NIL. Letter is filed as page 277/C in Mining lease file of 11/1941 at Goa Department of Mines and Geology. In 2015 there is no ROM and then suddenly PP has reported huge quantity of ROM as 3000000 tones. How this discrepancy can be accounted?.
22. EIA of 2003 of Dempo mining corporation gave ore to waste ration as 1:2.5 and the production of 2 million tonnes per annum. The present PP is trying to win 3 million tonnes per annum and also encountering ore to waste ratio as 1:8.39. This is absurd. Possible the exaggerated figure of the ore to waste ration is intentionally given to go for robbing of ore. Considering that illegalities committed by Vedanta in parts of the world and in India too the possibility of the PP carrying day light robber of Goa’s ore is highly possible.
23. Page 149 of EIA at point 4.10 has table that provides trips per day as 1205 tones of iron raw. On calculation it was found that for 30 days it is 36150 tones. Therefore figure for 12 months is 433800 tones. PP has given figure as 3000000 tones. But based on calculations of trips per day annual production doesn’t touch half a million tones per annum. The figures given of tones per day and trips per day do not match the quantity given of 3000000 tones.
24. From 2011 to 2013 Vedanta was alleged by Directorate of Mines and Geology of carrying on illegal mining of 2076746 tones worth Rs. 97.48 crore. Vedanta is habitual perpetrator of economic crimes related to mining. Therefore PP cannot be expected to function at any point without committing illegalities.
25. According to Supreme Court of India Vedanta land for University in Odisha was illegal along Puri and Konark marine drive. Supreme Court stated “It is not appreciable why the government offered such an undue favour in favour of one Trust/Company”. Replica of the this situation has happened in Goa. Vedanta owes 100 crore to Goa Government as per the proceedings of the Goa legislative assembly on 09 August 2023.
26. PP has not consulted any bio-diversity registers at any of the 56 Panchayats and 12 Municipalities in core zone and buffer zone of the mine. Therefore flora and fauna baseline data collection method is faulty and strong ground to reject EIA and direct to prepare fresh one with correct method.
We hereby suggest that EIA having more than 600 pages to read for a common people is very difficult but beyond that to expect common man to study and participate in the Public Hearing is an impossible task. So either the Pollution Control Board or the consultant of the concern EIAs should bear the responsibility to explain how to study and comprehend technical data by going to the Panchayat or Municipalities. Or if the EIA study exceed 300 pages Public Hearing should be conducted after 60 days.
Thanking you,
Yours sincerely,
Sd/-
Dr. Sebastiao A. Rodrigues
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