Excerpts from the minutes of the environmental public hearing (EPH) for the Dholera special investment region (SIR), held on January 3, 2014, at Dholera, south of Ahmedabad, suggest grave apprehensions of farmers about loss of land in the name of development. They also suggest environmentalists’ concern about the adverse impact on the Blackbuck National Park and the existing fragile eco-system. Official replies suggest the government is defensive:
Pradhyumnsinh Ranubha Chudasama, Bavaliyari: The proposed development will be initiated after 30 years, which includes the land of village Bavaliyari. Mandvipura village was submerged in the sea 25 years back. It shows rapid changes in environment near the sea shore of Gulf of Khambhat. As the proposed project will be executed after 30 years the public hearing held for the project on is not as per the order of Supreme Court and Central Government’s Ministry of Environment & Forests (MoEF). The Velavadar national park is 200 meters from Bavaliyari village boundary, which is included in the SIR. As per the guidelines of Central Government, area within 10 km radial distance is considered as restricted area. So we request you to cancel the public hearing.
Under the Sardar Sarovar Narmada project the agricultural land of 22 villages constituted in Dholera authority has been identified to be taken for irrigation. As per the order of the Narmada Tribunal and the guidelines of the Supreme Court, no one has the right to change it. As per the rules of Central government, in agricultural land no project such as industries and urban development should be allowed, so we request you to cancel the public hearing.
Development map and plan of the Dholera Authority should be canceled because it is prepared by violating the government rule of Costal Regulation Act. Similarly, proper mapping of study area is not done. Has public hearing ever been conducted anywhere else in the country for development that will take place after 30 years, at the same time and that too at a single place? Under which law of the constitution has this provision been made of seizing all livelihood rights of human beings, and the rights that nature has provided to human life, animal life, aquatic ecosystem, birds etc., 30 years in advance?
REPLY: Public hearing is the part of the process of environmental clearance. For planning development of any city, development plan/master plan is to be prepared. Any development plan of a city is to be prepared under the provision of the Gujarat Town Planning (GTP) Act and the Urban Development (UD) Act, 1976 for a long period. So the development plan of Dholera SIR as a new city is planned in three phase for 30 years. As per the GTP and UD Act 1976, the development plan will be reviewed within 10 years. Long term environmental changes have been considered during the environmental study. The details regarding environmental changes of village Bavaliyari and nearby region will be incorporated in Final EIA. Considering the above matters environmental clearance will be obtained from MoEF.
Dholera regional development authority (RDA) has applied for wildlife clearance for Velavadar National Park, and development permission in the influence area will be given considering the approval conditions of MoEF. Development will be done on basis of applicable rules of State and Central Government. Narmada Nigam has decided to provide canal in this area. In Dholera SIR area, farmers/ land owners can cultivate their land at their will, whether their land is rain fed or canal irrigated.
CRZ survey is done by MoEF recognized institution and finalization of the same is in progress. As per the EIA notification 2006 public hearing should be held in area of district in which project is proposed, so it is held at Dholera which is the taluka headquarters of the 22 villages. In SIR all lands like gauchar, rivers, forest land, pond, lake, sea, coastal zone etc have been retained, and therefore all rights are retained. Draft EIA report is prepared on the basis of terms of reference (TOR) given by MoEF, and the Gujarat Pollution Control Board (GPCB) has arranged this public hearing as per the Environmental Impact Assessment (EIA )Notification 2006, under the chairmanship of District Magistrate, Ahmedabad.
Chudasma Pradhyumansinh Ranubha, Bavaliyari: We request you to arrange separate public hearings for each village, as a single public hearing is held in this huge area of 900 sq km area consisting of 39 hamlets including 22 revenue villages. There is also clear violation of Central Government’s rules of National Park and Sanctuary in Dholera SIR. Development Plan of Dholera SIR should be finalized only after a detailed study of the national park and its ecosensitive zone by specific experts. There is severe erosion of coastal land of Dholera SIR. There is clear violation of rules of Coastal Regulation Zone.
Public hearing cannot be held, as the environmental impact assessment EIA report based on which this public hearing is held is prepared without assessment, incomplete, misleading. Proposed is the development of industrial township on 100 per cent area of 22 villages, but still there is neither any law nor any provision in the Development Plan for the resettled local people. We object the de‐commandment of Narmada Irrigation project. In the revenue village boundary of Bavaliyari village, it is a question of maintaining 200 ponds. Animals and ecosystem of Velavadar sanctuary will be ruined. It is not possible to get Environmental clearance 20 years prior to implementation of the plan.
REPLY: As per the EIA notification 2006 public hearing should be held in area of district in which project is proposed, so it is held at Dholera which is the taluka headquarters of the 22 villages. Development plan of Dholera SIR is aligned keeping in mind the proposal for Eco sensitive zone around the National Park. Any development near the National Park will be done as per the rules of Central and state government. Detailed study of the Velavadar national park and its ecosensitive zone have been carried out by GEER (Gujarat Environmental and Ecological Research Foundation) which is a government recognized institution for ecology, and the Draft EIA report is prepared based on the same.
The Strategic Environmental Action Plan as part of the Draft EIA does consider long-term environmental changes. Any activity in Coastal Regulation Zone (CRZ) will be carried out as per the rules of State and Central government and MoEF’s Notification of CRZ 2011. Following agencies with expertise in different fields have prepared the report: 1. EIA – SENES Consultants, Mumbai; Physical Environment, CSMCRI, Bhavnagar; forests and flora, fauna – GEER foundation, Gandhinagar and GUIDE, Bhuj; Flood, Disaster Management Study – WAPCOS, GSDMA, Gandhinagar; Socio‐Economic – TERI, OIKOS; Seismological study – ISR, Gandhinagar; CRZ – ISRO, Ahmedabad and Anna university, Chennai.
The development of industrial township is not proposed on 100 per cent land of Dholera SIR, but only 17 per cent of the total area is proposed as industrial zone, in the development plan. Neither land acquisition nor resettlement is involved, as gamtal will be retained. The Narmada Nigam has decided to provide canal in the area. In the Development Plan and Draft Town Plan, no deduction of land for notified rivers / ponds / water bodies and have been retained. The Velavadar sanctuary is outside of SIR area, and the land of forest department has been retained without any interference.
Ramdevsinh Chudasama, Bavaliyari: Bavaliyari is boundary of Velavadar National Park, and as per the Supreme Court 2011 guidelines no hazardous development is permitted nearby national park.
REPLY: Dholera SIR boundary is located at 600 metres from the boundary of the Blackbuck National Park. Current laws do not allow development within National Park, and regulates development within eco‐sensitive zone around any National Park. While the proposed development is outside the National Park, it is also outside the eco‐sensitive zone around the Blackbuck National Park that is currently awaiting notification from the MoEF.
Paryavaran Mitra, Ahmedabad: There are dangers on several scores, including change of landuse pattern and threat to food security. There is need for phasewise EIA report. Other issues which need answers include the rights of landowners on developed land, distance of gamtal from allotted agricultural land, problems due to increase in labour wages / rates, loss of gochar land, failure to look into environmental Impact of Shenzhen project, impact of the Kalpasar project, source of water, technology for waste water treatment, power requirement for SIR, sources of power and the Land Acquisition Act 2013
REPLY: A significant portion of land currently with better agricultural productivity is reserved for agriculture and it will be ensured that the region is in command area for irrigation. Nature of irrigation network in the central and eastern parts of the Dholera SIR region will be planned based on technical assessment by the Sardar Sarovar Narmada Nigam (SSNNL). Farmers can continue to carry out agriculture on their land, till the time they desire to do so in the re-allotted land that is given to the farmers after deducting the specific amount of land for basic infrastructure.
Resource support services will be provided to the farmers for increasing the agricultural productivity including that of Bhaliya wheat, by the Dholera SIR Welfare Society in co‐ordination with agricultural department and/or other competent agencies. Traditional livelihood pattern is anticipated to be substituted with better work and life opportunities for the native communities. Occupations such as agriculture and animal husbandry is expected to continue and aligned to cater to new needs of the area, as well as increased market linkages due to connectivity and logistics, and agricultural/ animal husbandry produce storage and processing facilities.
The nature of industries which are currently proposed to come up and as specified in the Draft EIA, include electronics, high tech and emerging technologies, pharmaceuticals and biotechnology, heavy engineering, automobile and auto ancillary industries, general manufacturing, agro and food processing, Metals and Metallurgical Products, IT/ITES. The Draft EIA does recognize the limitations on impact quantification, and also those relating to climate change. Therefore, the Draft EIA commits to adoption of a dynamic control system based on Dholera SIR region specific environmental standards.
Climate change related impact on sea level rise, is proposed to be addressed in the flood risk assessment. While this Draft EIA is for the entire development plan, future environmental impact assessments of development plans will be linked to major review of plans every 10 years proposed as per the Gujarat SIR Act ‐2009 and GTP and UD Act‐1976 as well as micro‐citing plans as indicated in this Draft EIA report. All the original agricultural rights will be retained.
As far as possible, the re‐allotted land is located on the original land parcel or its nearby vicinity. The problem of agriculture wages not being able to compete with wages in other sectors, brought out as a concern, is well appreciated. Dholera SIR Welfare Society will put in the required efforts to establish market linkages of farm produce through agri based industries and also for the new population that is expected to flow in Dholera SIR. The project therefore anticipates agriculture to be made equally attractive for wages, in comparison to other sectors.
Existing gochar land is retained. The environmental and social impact assessment of the proposed development has considered short, medium as well as long term impacts of most of the major urban and industrial developments not only in India, but also across the world. The provided weblink in the letter could not be accessed, and therefore in case any major impacts specifically learnt from the Shenzhen project may be shared with us, the impacts can be reviewed and improvements will be made in the plan, accordingly.
The Draft EIA has information that various sources of water in the area are haphazard. Improvements in the Final EIA report will be made, to represent water source details with quantity for various phases of project to the best extent possible at this stage. It is to be however understood that precision in these details might not be feasible to be provided at this stage of planning, for a development of this scale and size. A detailed strategy for water resource planning is therefore committed in the Environmental Strategic Action Plan, which will evaluate in further details the various water sourcing options and in concurrence with recommendations from EAC of MoEF.
This will also consider citing of appropriate location of desalination plant in accordance with marine ecology related sensitivities in the Gulf of Khambat. A detailed assessment and preparedness plan to align Dholera SIR development with Kalpsar project is also committed in the Action Plan. While preliminarily the feasibility is established, a detailed feasibility study is in the process of being commissioned to plan the proposed solution of further treating the treated wastewater from sewage treatment plants of Ahmedabad city and using it as a source for industrial grade water demand. Large environmental benefits are anticipated by further treating the wastewater from the sewage treatment plants of Ahmedabad.
We do recognise water to be a key concern area in Dholera SIR development. Therefore, Dholera SIR commits to exploring the best and state‐of‐the‐art technology options to address water reuse and recycling needs for the entire development planning and screening individual developments within Dholera SIR. A strategic and rigorous framework will be prepared specifically for water management and conservation for the entire Dholera SIR, and will guide water related aspects of the entire development. This will consider all feasible options towards avoidance of wastewater disposal and avoidance of conflicts between water users and risks to water availability.
None of the proposed industrial manufacturing sectors in the industrial zones proposed in Dholera SIR region are water intensive, except a few sub‐sectors in the pharmaceuticals and biotechnology and agro and Food processing sectors. The Water Management and Conservation Plan will also consider selection of particular industries in these sectors which will adopt technologies that have higher water use efficiencies and lower wastewater generation.
Moreover, the proposed development being very forward looking, expects several new technological developments to be fed into this process. Since Dholera SIR development would adopt maximising reutilisation of wastewater and use of recyclable wastes – a detailed framework on Waste Management will be developed based on the latest technology options available for adoption. Moreover, Water Resource Management Planning and Waste‐ Resource Management Planning will be in concurrence.
Environmentally compatible power generation facilities to meet the power needs for Dholera SIR will be planned either within Dholera SIR and/or as part of the DMIC Development Corporation’s comprehensive power infrastructure augmentation plans for various DMIC nodes including Dholera SIR. Precise power distribution details for various phases with respect to total energy demand of 1700 MW will be worked out at a later point of time. If possible, these details will be included in the Final EIA report.
While we do recognize the merits in the new Land Acquisition Act 2013, land pooling and land readjustment as per town plan (TP) schemes is demonstrated to be successful in Gujarat and the local communities have already expressed their acceptability on this, during the various consultations undertaken in the past 2 years. But in non‐TP areas, any land requirement for the development will be met through the Land Acquisition Act as applicable at the time.
Dharmakumarsinhji, Nature Conservation Society, Bhavnagar: Boundary of Dholera SIR is only 600 metres from the boundary of Blackbuck National Park. Isn’t it a violation of law? Blackbuck National Park is unique in its biodiversity. It is the largest breeding ground for lesser floricans, it is the world’s largest wintering ground for migratory harriers, it has highest density of wolves in India, it is a wonderful habitat for globally threatened species like Dalmatian pelicans, Imperial eagle, Houbara bustards and Stolokza’s bush cat. All above diversity would be certainly affected! What would be solution regarding this?
The Bhal areas’ entire Dholera SIR proposed site has been identified as Important Bird Area (IBA No IN GJ‐02), by Indian Bird Conservation Network of Bombay Natural History Society, Mumbai. About 1536 ha area with dense mangrove will be lost due to Dholera SIR! About 46% of the area of Dholera SIR is fertile agricultural land and traditionally indigenous types of wheat, cotton and gram are cultivated which will be lost. This loss is great loss to biodiversity of the cultivars! How flood mitigation would benefit the Blackbuck National Park? Water logging is fatal for blackbucks. How the habitat loss of threatened fauna will be compensated?
Destruction to habitat of threatened fauna is violation of wildlife protection act 1972! More than 1000 ha of wetlands would be lost? How this habitat loss would be compensated? Dholera SIR is within the migratory route of wintering birds to India. Any development in the migration route is against the law. Location of threatened species in entire Dholera SIR proposed area. How this habitat loss would be compensated. Location of dens of wolves and foxes in the Dholera SIR proposed area. Both these mammals are endangered and enlisted in Schedule I of Wildlife Protection Act 1972. Ancillary developments will take place and there is no explanation on how adverse effects of the project would be mitigated. Effluents and air pollutants will directly affect the endangered fauna of Blackbuck National Park. Mitigation measures to be taken by the Dholera SIR authority. This project proposal should be placed in state wildlife boards and National wildlife board for clearance.
REPLY: Current laws do not allow development within National Park, and regulates development within eco‐sensitive zone around any National Park. While the proposed development is outside the National Park, it is also outside the eco‐sensitive zone around the Blackbuck National Park that is currently awaiting notification from the MoEF. We do recognize the uniqueness of biodiverisity of the Blackbuck National Park and the eco‐sensitive zone surrounding it, currently awaiting notification from the MoEF. The proposed development is outside both the National Park and this ecosensitive zone.
However, considering that the National Park is only at a distance of 600 metres from the Dholera SIR boundary, a detailed review of ecological experts was undertaken to understand the need of conservations zones within Dholera SIR. Based on this study, and a detailed review of concern on loss of biodiversity due to urbanization, it is proposed that forest areas located in Dholera SIR region and that which are within 5 km zone around the national park will be reviewed in further detail to set‐up a conservation zone. In addition to this, developmental activities in Dholera SIR will be aligned in accordance with Development Controls within and in the peripheral areas of the Dholera SIR region.
The dense mangrove patch will not be lost due to Dholera SIR – since nothing will be constructed in this area. Agricultural biodiversity of the area, its significance as a faunal and avian habitat has been understood in detail. A major part of the most productive agricultural land is proposed to be retained for agriculture, and a significant part of agricultural activities are likely to either continue or enhanced due to upcoming Narmada Canal distribution and the proposed efforts of Dholera Welfare Society, to support the farmers.
Based on detailed ecological studies undertaken, there have been previous recorded incidents of fatalities of blackbuck population due to flooding in and around the Blackbuck National Park. Flooding is identified as one of the major threats being faced by blackbuck population in this area. The proposed flood mitigation measures under Dholera SIR are anticipated to reduce flooding in also those areas where there is large habitat of blackbucks and in areas where such incidents were recorded previously. Detailed ecological surveys have classified threatened habitats in accordance to conservation priorities under Indian laws as well as international regime.
Habitat loss avoided to a significant extent, followed by adoption of planning compatible developments, and developing conservations zones in areas that are close to important habitats. All wetlands and their importance for the communities, as well as biodiversity habitat, have been studied in detail. A detailed wetland conservation action plan will be formulated in accordance with size and biodiversity habitat importance of the identified wetlands. All the community wetlands will be conserved for community use. Migratory birds do visit this area, and their habitats have been studied in detail. Development Planning in Dholera SIR is proposed to either conserve a majority of the habitat for these birds primarily consisting of coastal zone, or align conservation zones along most of the existing surface water bodies.
Relationships between the threatened species and their supporting habitats have been studied in detail. Based on this, habitats and their corridor linkages have been identified to be protected as conservation zones. Relationships between these threatened species and their supporting habitats have been studied in detail. Based on this, habitats and their corridor linkages have been identified to be protected as conservation zones. The Draft EIA is at a master plan level, and developmental activities are broad based and all such ancillary developments are described in detail in the Draft EIA report.
Section 6.0 of the Draft EIA report explains in detail the adverse effects of the proposed development and how they would be mitigated. All key threats to the endangered fauna is identified and mitigation measures are detailed in Section 6.0 of the Draft EIA report. Setting region specific ambient environment standards, and keeping a close monitoring on the selection of units This proposal is seeking wildlife clearance as required under the law, due to proximity of Dholera SIR to the Blackbuck National Park, and this aspect is detailed out in the Draft EIA report.
Paryavaran Suraksha Samiti, Vadodara: Climate change in the EIA for the project, which will come up after 20 years, has been completely ignored. Is there any precedent of EIA being sought for such a project in the country, and how it was processed? The consultants are not experienced and do not have expertise to prepare such EIA . What is the Basis on which consent for this long-term development is being sought? It is difficult to assess possible pollution load and other environmental impacts due to lack of required essential details. EPH therefore stands null and void for want of such details.
Why updated census data not used for projects and its impact? Government is custodian of common resources available on government lands, and cannot give consent for use of this land for the proposed development, without consulting people whose life and livelihood will be affected. EIA based on factual inaccuracies and misleading information. Re‐allotted land not fit for agriculture. EIA is incomplete and in violation of prescribed terms of reference (TOR).
REPLY: Climate change impact on sea level rise and resulting impact on flooding and the coastal zone is considered as part of flood risk assessment separately carried out and summarized in the Draft EIA. The assessment has also considered impact of climate change to meet the energy requirements and consumption for the proposed development. Moreover, the region specific standards proposed to be implemented for the proposed development will factor in impact due to climate change. There are other similar developments under the DMIC for which EIAs have been sought by the MoEF, and are being processed in similar lines.
The selection of the consultant has been done based on national accreditation requirements in addition to demonstrated international competencies, and supplemented with reputed government agencies possessing expertise in individual functional areas. While village level census data of 2011 could not be used due to unavailability, a sample survey in each of the village falling in the proposed Dholera SIR was also undertaken. Impact does consider the updated information on social infrastructure in the area. No significant demographic changes observed in this region, based on broad comparisons of the provisional census 2011 data now available.
Extensive consultations undertaken with the local people on this aspect, and all common resources such as rivers, streams, lakes, ponds, forest land, grazing land, cultural resources, etc., will be retained and not impacted for the proposed development. Specific factual inaccuracies and misleading information if brought to our notice will be verified and corrected in the Final EIA accordingly. CRZ related demarcation has already undergone ground truthing through recognized government agencies, and minor variations in tide lines will be updated in the Development Plan. Impact assessment made on broader parameters, since it is at a Master Plan level.
Laljibhai Ladhrabhai, sarpanch, Bhangadh-Mahadevpura group gram Panchayat, Mahadevpura: Is there a provision to provide Narmada water for people who want to cultivate sources?. If the land is seized, what about our livelihood? If our cultivable land is seized, than where will we produce Sansiya wheat? If there will be no land for cultivation, how will we survive? Will you give government job to us for our livelihood? If government will establish Gujarat Industrial Development Corporation (GIDC) on productive land than will the government imports grain from outside. Do we have to migrate for survival? Land is being acquired forcefully.
REPLY: Experts’ consultants hired by Dholera Authority have studied all details regarding these matters in the Environmental Impact Assessment. Once this assessment is approved, the development will be carried out as per the approval conditions from MoEF Farmers can continue agricultural activity on their land allotted under TP Scheme, till they wish to do so. Development will be carried out only if the farmer sells the land. There will be increase in employment opportunities, due to this development.
Dholera SIR Welfare Society has been formed to provide technological and other guidance for better production of Sansiya wheat. In TP scheme 50% land remains with owner. In addition to this the compensation will be given as per the Jantri 2011 for the deducted land. Dholera SIR is being developed using Town Planning Schemes, under the Town Planning Act 1976 where 50% land will be taken after giving the compensation as per the Jantri 2011 and remaining 50% will remain with the owner. No land acquisition is involved.
Dholera SIR Welfare Society will encourage the industries to give priority to local people in employment, and to cater to the new employment and entrepreneurial opportunities, provide skill development centers to develop skills and Entrepreneurship Development Centers. State Government recruits persons as per the eligibility of the person and rules/regulations from time to time. The SSNNL has taken the decision to supply canal water to this region.
Sarpanch, Mundi village: While Public Hearing is being conducted, what is the assurance that the project does not fail?
REPLY: Dholera SIR is part of the Government of India’s large and ambitious project of Dedicated Freight Corridor connecting Delhi and Mumbai, and is under the influence area of Delhi‐Mumbai Industrial Corridor. There will be increase in employment opportunities due to industrialization in this area. In addition, Dholera SIR Welfare Society will encourage the industries to give priority to local people in employment, and to cater to the new employment and entrepreneurial opportunities, provide skill development centers to develop skills and Entrepreneurship Development Centers.
Chudasama Vikrambha Narubha etc., Hebatpur: Agricultural land is taken in SIR, where can we graze our cattle?
REPLY: In TP scheme 50% land remains with owner and the farmers can cultivate their land till they wish to do so. Gauchar land has been retained.
Bhalajibhai Narsangbhai Hayani, Hebatpur: Where can we graze our cattle? • Village lands should be kept free from pollution, as pollution will not allow us to produce crop within 1 km. Our village does not want SIR.
REPLY: In TP scheme 50% land remains with owner, and the farmers can cultivate their land till they wish to do so. Gauchar land has been retained. Only low or non‐polluting industries will be permitted. No chemical industries will be permitted. Industry water will disposed only after necessary treatment. The activities relating to Dholera SIR undertaken as per the regulatory provisions of the Act, and land acquisition is not involved.
Dharajiya, Hebatpur: Where will the labourers go for job and who will provide employment to them?
REPLY: Due to industrialization the source of income will increase. In addition to this Dholera SIR Welfare Society will encourage the industries to give priority to local people in employment, and to cater to the new employment and entrepreneurial opportunities, provide skill development centers to develop skills and Entrepreneurship Development Centers.
Dharamshibhai Savabhai and Others, Hebatpur: There is a need to reduce the percentage of land deduction. At the time of NA (non‐agriculture) process, one should stop considering collection of development charges, service charges or amenity fees.
REPLY: With a view to provide world class infrastructure and premium civic amenities in Dholera SIR, a policy decision has been taken on a percentage deduction of land. At the time of NA process, no process of imposing collection of such development charges, service charges or amenity fees has been started.
Nagjibhai Savabhai Bavariya, Hebatpur: TP has been declared prior to finalization of DP. The deducted land may be sold through public auction. Priority should be given to the original owners. Compensation may be given in parity with the nearby region of the Sanand Nano Plant. Is FSI correlated with plot size and road width under the TP Scheme? It is told that there will be no change in zone. We demand that the same should also be applicable to the authority. There should be provision for judicial control over the Apex authority.
REPLY: Under the provisions of the Act for preparing DP and TP, sufficient opportunity and time have been provided to public at each stage, to file their objections/ suggestions, and process has been completed accordingly. As a result, we have received and considered 4,101 objections/ suggestions. The deducted land from original plot, allotted for public purpose will be sold as per the regulations made by the apex authority. The General Development Control regulations will also be applicable to Dholera Authority. The apex authority has set‐up a DRF (Dispute Resolution Forum) under the Gujarat SIR Act 2009. As per the provision of the Act, State Government may form a Dispute Settlement Mechanism.
(In all, 462 persons participated in environmental public hearing for Dholera SIR on January 3. Excerpts here have been selected from among 241 written representations given ahead of the hearing, to which KD Chandnani, CEO, Dholera SIR Development Authority, Gandhinagar, provided reply in writing)