Text of the letter by Mahesh Pandya, director, Paryavaran Mitra, to the Gujarat Pollution Control Board (GPCB) on the Environment Impact Assessment (EIA) report on Dholera special investment region (SIR), on the basis of which environment public hearing (EPH) for the SIR was held in Dholera town in Ahmedabad district on January 3, 2014:
We have studied the draft EIA report of the Dholera Special Investment Region (SIR) project. Following are our observation/comments/questions regarding project and draft EIA report:
1. Change of land use pattern and threat to food security: As per the EIA report’s section on land use/ land cover (LU/LC) (page E-4), agriculture is currently the most important activity, consisting of 467.46% of LU/LC of the study area. Dholera SIR is largely dry and the irrigated land. It comprises of 2.5% of total area irrigation facilities. The availability of irrigation will improve productivity of the crops and will provide an impetus towards a change in the cropping pattern from traditional to horticulture and cash crops due to assured irrigation. The EIA report demonstrates that approximately 3,400 hectares (ha) of land of the command area of Kalpasar project would fall within the Dholera SIR.
However, an RTI filed in October 2013 regarding the Narmada canal command area in the Dholera area suggests the whole area has been decommanded. As per the RTI information, and a letter of the Sadar Sarovar Narmada Nigam Ltd (SSNNL), 28,203 ha of land has been decommanded, i.e., 31% of the total land. Had this land been covered by the command area of Narmada, the fallow land would have been converted into irrigated agriculture land hence productive. A total of 31% plus 2.5% of Dholera SIR’s land would have become agricultural.
Yet, the fact is, this entire land is now proposed to be converted into industrial land. This will give raise issues of food insecurity, which is already a challenge in the coming years. Significantly, this area is the producer of bhaliya wheat, which is very high- quality wheat, and is found in the region only.
2. Need for phase-wise EIA report: The project will be developed on an area of 920 sq km (twice as big as Ahmadabad city). However, the number of industries which will come up in the area is not clear. Predicting environmental impact for an industrial cluster without any information on number and nature of industries would be inaccurate.
Moreover, Dholera SIR is planned over a period of 30 years and it will be developed in three development phases of 10 years. Clearly, many of the environmental impacts cannot be quantified for a project which has gestation period of 30 years, at a time when the biggest issue the world is facing today of global warming. We cannot predict overall impact of climatic change due to global warming, even as new technologies will keep coming in during the entire period to feed the industries to come up in the SIR. Hence, the EIA should be done phase-wise of 10-year period, so that the precise environmental impact of project on the area could be estimated.
3. Rights of landowners on developed land: As per the EIA report, “50% of the land owned by the landowner is earmarked for Dholera SIR. The other 50% will be developed with infrastructure including roads, electricity, drainage etc and given back to the land owner.” There is a need to explain the rights of the land owners for 50% land which will be given back to landowners after development in terms of right to sell, approvals for borewell etc.
4. Distance of gamtal from allotted agriculture land: The land which will be allotted to farmer in exchange of their own land will be far from the gamtal where the farmers will reside. One wonders if the project proponent considered this factor while allotting land to farmers for agriculture purpose.
5. Problems due to increase in labour wages/rates: The EIA report does not talk about the impact in and around Dholera SIR on wages for agriculture and other traditional works. Also, the land which is given to the farmers will be far from the gamtal. This will make it difficult for farmers to do farming in the allotted agricultural land. Subsequently, the farmers will be forced to convert agricultural land into industrial use, and thus the area surrounding the land and in Dholera SIR will ultimately become industrial.
6. Loss of gauchar land: Animal husbandry of the villagers who are residing in the gamtal inside Dholera SIR will be affected as they will not have enough land for feeding the animals. Moreover, the EIA report says that animal husbandry will be a significant source of livelihood as there will be a demand for fresh produce from Dholera SIR’s residential and commercial complexes. But how can animal husbandry be developed without gauchar land for feeding animals within Dholera SIR?
7. Environmental impact of Shenzhen project: The EIA report compares Shenzhen special economic zone with Dholera SIR, because China is a developing country like India and has similar demographic profile. The EIA report even talks about the planning criteria of these projects. But it fails to present the environmental impact that Shenzhen project is facing due to overdevelopment (click HERE to details).
8. Kalpasar project: The EIA report gives information about various sources of water for Dholera SIR in a haphazard manner. It says, the SIR will receive treated wastewater from the Ahmedabad Municipal Corporation (AMC), the Ahmedabad Urban Development Area (AUDA), the Pariyej reservoir and the Kanewal reservoir. In addition to all this, it talks about the desalination plant downstream of the Kalpasar. But it fails to precisely give water source details with quantity to be available at various phases of the project.
Then, it talks about the Kalpasar project, which was envisaged decades ago (in 1975), and remains controversial, with its environmental impact and net costs and benefits being widely debated. How can the EIA report provide the source of water from the project (Kalpasar), which has still not begun and remains controversial?
9. Source of water: About 240 million liters per day (MLD) of treated wastewater from the AMC and 240 MLD of treated wastewater from the existing sewage treatment plants (STPs) operating in the AUDA area, will be the source for industrial grade water. This can be hardly viable, because treated waste water might not be suitable for food and beverage industries. Moreover, looking at the current status of the treated water from STPs, one wonders if it is practical.
10. Technology for waste water treatment: Waste water generated in Dholera SIR will be treated at STPs and common effluent treatment plant (CETPs) so as to reuse the treated wastewater onsite. Two water treatment plants are proposed to be provided, one near Ottariya village (for phase 1 and phase 2) and another near Hebatpur (phase 2 and phase 3). The total generation of waste water in Dholera SIR will be 652 MLD, which is equal to the waste water generated from the entire Ahmedabad district. The technology used for the waste water treatment has not been discussed.
11. Power requirement for SIR: The EIA report talks about the power requirement of 1700 MW and has given details of supply and transmission line in Dholera SIR, out of which only 270 MW will be generated by power plants within the SIR, which will be commission in phases 2 and 3. Such huge requirement could put extra load on the present distribution system and can cause deficiency in the existing power supply.
12. Sources of power: The EIA report points towards various renewable sources of power, like wind power generation potential of about 313 million units (MU), solar power generation capacity from the solar park of 1161 MU, but it fails to give distribution details during different phases with respect to total energy demand of 1700 MW.
13. Land acquisition Act of 2013: The EIA report has detailed merits of land looping or readjustment method over land acquisition through the land acquisition Act, 1894, but it has not considered the new land acquisition Act, 2013 which was first introduced in Parliament almost two years ago and has come into implementation starting with 2014. The new Act was bought because the Land Acquisition Act, 1894 had many flaws.
This is the first law that deals with both acquisition and rehabilitation. Certain provisions of the new law include its implementation from retrospective effect, consent of the majority, return of unutilized land, share in profit if the land is sold to third party at a higher price, income tax exemption, protecting fair price, any damage to the crop to be included in the price, and acquisition only if required. Dholera SIR should implement the land acquisition Act of 2013 to undertake land acquisition to meet land requirements for the project.
Also, the new Act is to be implemented from retrospective effect, and will be applicable to the cases where land was acquired earlier and no compensation had been paid. As per the new Act, “The entire land acquisition process will take place according to the new provisions if the land acquisition has taken place five years ago without compensation or land possession.”