Public Hearing for Dholera SIR was based of incomplete, out-of-date facts provided in Environmental Impact Assessment report

A farmer in the midst of his bajri crop grown in Dholera SIR area
A farmer in the midst of his bajri crop grown in Dholera SIR area

Well-known environmental expert and campaigner Mahesh Pandya of the Paryavaran Mitra, Ahmedabad, has written a letter to M Veerappa Moily, minister of state for environment and forests, Government of India, objecting to the manner in which the environmental public hearing (EPH) was held on January 3 for the Dholera Special Investment Region (SIR), Ahmedabad, for building a modern township next to the Gulf of Khambhat in Ahmedabad district on a 920 sq km land. Asking for cancellation of the Environmental Impact Assessment (EIA) report, on the basis of which the EPH was held, Pandya says, a new EIA report should be prepared, as the current EIA report has failed to provide necessary information for EPH. Reproduced below is Pandya’s letter:

This is in reference to the environmental public hearing (EPH) of Dholera SIR for Ahmedabad district held on January 3, 2014. We have reviewed the minutes of the public hearing that has been uploaded on the Gujarat Pollution Control Board (GPCB) website. Based on the minutes, we have prepared a list of responses in which the project proponent has agreed, either at the EPH site (Dholera) or in writing, that it will incorporate several issues it had missed out while preparing the final EIA report.

The observations show that the project proponent has agreed to the fact that important studies like water source, power source, and allocation of land were either not carried out or were not done in detail. As the affected people and stakeholders will not be able to review the final EIA and cannot give their inputs now, we request you to cancel the draft EIA report submitted by the project proponent (Delhi-Mumbai Industrial Corridor Development Corporation), and come up with a new EIA report incorporating all the above studies or details which the project proponent has agreed that they do not exist in the EIA report. We also request you to reschedule the EPH as per the EIA notification, 2006, so that people can review the EIA report with all the necessary information and then give consent to the project.

Some of the responses given by the proponent to the questions raised during the EPH are not satisfactory. When questions were raised about lack of any “provision or responsibility in the law for the livestock keepers and resettlement of the local people”, the proponent gave a vague response, that “this area shall be developed under the Gujarat Town Planning and Urban Development Act, 1976. Since no land acquisition is involved in it, there is no question of rehabilitation/ resettlement. Farmers can cultivate their land till they wish to do so.”

Also, in the minutes the project proponent has claimed that “the 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.” The draft EIA report has mentioned that “approximately 14 per cent of the total site area, i.e. 12,804 ha, will be retained as farmland for the short term” and “this land will not be required for development until the city grows beyond a population of about two million inhabitants.” It means once the population of the DMIC exceeds two million, land will be acquired from the farmers!

The Delhi-Mumbai Industrial Corridor (DMIC) is a homogeneous and ambitious project but then it is also massively resource-intensive. Lakhs of people living in DMIC will get affected, because the project has refused to make them prime stakeholders. Instead of coming up with a very meticulous report at the important stage of public participation, the project proponent hasn’t spared a thought on the key issues like water source, power distribution, and allocation of land. Hence, we request you to cancel the EPH and demand a new draft EIA with details that the proponent has agreed to (in the minutes of EPH) and then hold EPH.

Following responses, cited in the minutes of the EPH by the project proponent, indicate insufficient study:

Only a few huts remain in the area of Dholera SIR where sea shore is shrinking

1. The project proponent has agreed in the minutes that on the basis of new “data, based on new satellite image, new survey and in consultation with the Central Salt And Marine Chemical Research Institute, Bhavnagar, the new Coastal Regulatory Zone lines shall be defined.”

2. People demanded increase in buffer zone of village from 150 to 500 metres, for which project proponent has assured that “the procedure to extend it to 500 mertres will be initiated.”

3. Regarding the objection to decommand the Narmada irrigation, the project proponent has responded that Sardar Sarovar Narmada Nigam Ltd has decided to provide canal in this area.

4. The project proponent has agreed that “details regarding environmental changes of village Bavaliyari and nearby region will be incorporated in the Final EIA.”

5. The project proponent has agreed in writing that “since Dholera SIR development would adopt maximizing re-utilization 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.”

6. The project proponent has agreed that “precise power distribution details for various phases with respect to total energy demand of 1,700 MW will be worked out at a later point of time. If possible, these details will be included in the Final EIA report.”

7. One of the responses says, “The fact that you felt the Draft EIA to be representing information on various sources of water to be haphazard is acknowledged. 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”.

8. Regarding comments on sources of water, the response was, “While preliminary  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.”

9. The Development Plan of Dholera SIR is prepared based on record of existing village map of the revenue department, which are old and not updated. The work of re-survey is done by the state government. After receiving new certified maps from the revenue department with necessary changes will be prepared.

10. The state government has initiated the exercise of resurvey in the entire area, and the process of record promulgation in 22 villages covered under Dholera SIR has been taken up. After completion of the same, the authority will take the necessary action.

11.  Regarding power requirement for the Dholera SIR, the response was, “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.”

12. For about 15 km East of Bavaliyari village exists the Gulf of Khambhat, and this coastal area is experiencing chronic erosion due to tides, at an average rate of around 1 cm per day. The Mandvipura village near to Bavaliyari has already lost its gamtal due to such coastal erosion. This fact is also in the records of the revenue department. The response was, “The Development Plan of  Dholera SIR is prepared, based on the record of the existing village map of the revenue department. The work of re-survey is done by the state government. After receiving new certified maps from Revenue Department necessary changes will be done accordingly.”


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