In a letter to Hardik Shah, member-secretary, Gujarat Pollution Control Board (GPCB), Gandhinagar, senior Gujarat environmentalist Falguni Joshi, who is convenor of the Gujarat Forum on the Clean Development Mechanism (CDM), has raised several objections to the Environmental Impact Assessment (EIA) report of the National Highway Authority of India (NHAI) for its proposed expressway project between Vadodara and Mumbai. Its public hearing is scheduled at Unity Hall, Near Ren Basera Hotel, NH 8, Killa-Pardi, district Valsad, on February 18, 2014. Text of the letter:
We have reviewed draft Environmental Impact Asssessment (EIA) report of the above-mentioned project. Following are our comments /suggestions /observations regarding project and EIA report:
1. The proposed Vadodara-Mumbai expressway starts from Thane (0 km) to Vadodaram then why the construction has not been planned from the starting point, i.e. Maharashtra-Thane?
2. As per EIA, 90.648% of land used for the proposed national highway is agricultural and related land. During the public consultation it has already been discussed that the land is having a good irrigation facility. Also as per the Terms of Reference (TOR) Annexure-I (iii) “Describe various alternatives considered, procedures and criteria adopted for selection of the final alternative with reason”, but EIA fails to consider any alternative study or route for the proposed highway.
3. In the EIA summary, pg ES 14, it is given that “30,786 numbers of trees are present on the corridor” whereas in Additional TOR (iv) the no. mentioned is 12314 trees. Please clarify.
4. Additional TOR (iv) asks for protected endangered species of trees, but EIA report gives no details about the endangered species.
5. In the draft EIA, Table 1.2 has heading “Clearances and Permissions Ganga Expressway Project“ and on page 7-3, its mentioned “Expressway connectivity will also help in import of new techniques of agriculture to the most backward areas of Uttar Pradesh”. Mention of Ganga expressway and Uttar Pradesh in the report shows that the consultant has forgotten to replace it while doing copy paste. Please justify.
6. The images and maps in the EIA are not clear and details are not readable. (refer:Fig 3.3, 3.6, 3.8, 3.9, 3.10, 3.11,4.1,4.2,4.3,4.4,4.5). Please justify such poor image quality.
7. The proposed expressway passes through flood prone regions (Ahmedabad, Surat and Bharuch are also located on the flat alluvial plains of large rivers and are prone to flooding. Source: http://www.gsdma.org/hazards/flood.aspx), but EIA has failed to asses flood as an anticipated impact. Please give justification for lapse in the study.
8. As per the EIA report, Dadra and Nagar Haveli wildlife sanctuary is 200 metres distance from the proposed project. What are the special measures taken by NHAI so that the wildlife in not in danger?
9. Additional TOR, Annexure-I (ix) requires to “indicate location of wayside amenities, which should include petrol station/service centre, rest areas etc.” for which project proponent has replied that as it is a Greenfield project it has majorly avoided settlements. Does this mean that in the length of 379 km of expressway, there are no petrol pumps or rest areas? Justify.
10. Additional TOR, Annexure-I (xii) require submitting the details of use of fly ash in road construction, but the details are not mentioned. Project proponent has only mentioned some of the sources. Please provide the details.
11. Additional TOR, Annexure – I (xxxii) require submitting details about properties, houses, businesses, etc activities likely to be affected by land acquisition and their financial losses annually has been asked to be carried out, but EIA report fails to give such details. Please give the above detail.
12. As per additional TOR, Annexure-I (xxxiv), a detailed rehabilitation and resettlement (R&R) plan based has been asked on various, but EIA fails to give such plan. It fails to mention the broad plan for resettlement, civil & housing amenities for displaced people, alternative livelihood concerns/employment and rehabilitation of the displaced people.
13. Additional TOR, Annexure-I (xxxv) requires submitting details of corporate social responsibility budget, which is lacking in the EIA report.
14. What are the special concerns in regards to construction of expressway in the coastal regulatory zone (CRZ) region for a length of 2.175 km?
15. As per EIA report, page 3-6, ‘13 major wet ponds covering area of 14 hectares would be converted to paved surface.’ But the location and distance of these wet ponds from project site is not given in the report and the map showing wet ponds location is not visible. Also report fails to mention the existing use of pond, if the livelihoods of people dependent on it etc.
16. The distance of surface water & ground water monitoring station from the proposed road is not mentioned in the EIA report. Moreover, in the entire route of 379 km only 8 monitoring stations are taken which is not enough to monitor the quality of air for more than 140 villages.
17. Baseline monitoring is done in April 2010, which is almost 4-year old data. How this data represents present environmental scenario of the region?
18. Table 4.5(a)/(b) on page 4-19 gives the detail of the total forest land requirement for development, but it does not give the details of forest land involved in Gujarat such as village name or block etc.
19. The EIA has taken census of 2001 for the study of population and livelihood, but has not considered estimated growth of population till 2011. For the futuristic project like expressway which will take long time to complete, at least a decadal growth in population should have been considered.
20. As mentioned on page 3-55 there is tribal population in these areas that will be affected by the expressway. So we request you to acquire land in these areas in line with the Panchayats (Extension of Scheduled
Areas) (PESA) Act.
21. Please mention the region where the compensatory afforestation will be carried out by the project authority.
22. EIA has not mentioned any details about the 960 private properties,107 community properties, etc. other than religious place that will be demolished in Gujarat. Neither does it says anything about the compensation and rehabilitation. Please give details.
23. Please specify the species of trees which are to be planted under greenbelt development.
24. Whether top soil analysis before and after construction is proposed to assess impact on soil?
25. What would be impact on surrounding agriculture land during construction phase on both side of road? Will the farmers get compensation for this?
26. Please give detailed list of the people who are responsible for implementation of environmental management plan.
27. What is the schedule of the implementation of the project? Please mention phase-wise schedule.