Date: 29th April 2017
To,
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,
Sd/-
Maggie Silveira
President
Goa
Unit
