Date: 29th April 2017
To,
Member Secretary,
Goa State Pollution Control Board,
Panjim, Goa.
Subject: Objections to Capital Deepening of Navigation
Chennel at Mormugao Port Trust for Cape size vessels
Sir,
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
species.
Increase
in the population of undesirable species such as viruses and
parasites.
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.
Thanking you,
Yours sincerely,
Sd/-
Maggie Silveira
President, Goa Unit
