Senior environmentalist Rohit Prajapati of the Paryavaran Suraksha Samiti has has sought the reply of prime ministerial aspirant Narendra Modi on 16 issues related with issues bogging Gujarat’s environmental hotspots. He faxed his letter to the Gujarat chief minister’s office on March 20, 2014. Excerpts:
The so-called success story of the two-digit growth and tall claims of capital investment in Gujarat has masked the several digit realities of loss of livelihood, land acquisition, displacement, irreversible damage to environment and permanent loss of natural resources, which are treated as free goods in this development model. The investment figure, without the figures for displacement, destruction and depletion of natural resources and the employment figure without loss of livelihood do not make sense. No wise person would talk about income without talking about the cost of acquiring that income or wealth. My questions relate to the ‘development model’ celebrated and propagated by you.
1. In 2009 the Central Pollution Control Board (CPCB) and the Indian Institute of Technology (IIT)-Delhi, in keeping with the demands of the people’s organisations working on environmental issues, decided to use a new method of indexing the pollution levels of certain polluted industrial areas. The method known as the comprehensive environmental pollution index (CEPI). CEPI includes air, water, land pollution and health risks to the people living in the area.
As per the agreed upon measures, industrial areas with a CEPI of 70 and above are considered ‘critically-polluted’ areas, while those with a CEPI between 60 and 70 are considered ‘severely-polluted’ areas. In our opinion, those industrial areas with CEPI between 40 and 60 ought to be labelled as ‘polluted areas’.
In December 2009 the CEPI of 88 polluted industrial estates was measured; it was then that the CPCB and the Ministry of Environment and Forest (MoEF), Government of India, were forced to declare 43 of those as ‘critically-polluted areas’ and another 32 industrial areas as ‘severely-polluted’ areas. Following this study, the MoEF on January 13, 2010 was forced to issue a moratorium (prohibition on opening new industries and/or increasing the production capacity of the existing industries) on the 43 critically-polluted areas. At that time, Paryavaran Suraksha Samiti (PSS) and other environment protection groups had asked for a moratorium on all the 75 (43+32) polluting areas, but it was not done under pressure from the powerful industrial lobby and state governments. The murky politics and economics of ‘GDP growth’ prevailed over the cause of life and livelihood of ordinary people and environment and conservation.
The process of declaring moratorium was started from Ankleshwar in Gujarat in 2007. The industries located in Ankleshwar, Panoli and Jhagadia GIDC estates treat their effluent in their Common Effluent Treatment Plant (CETP) and then, after giving further treatment at the Final Effluent Treatment Plant (FETP) at Ankleshwar, discharge the effluent into the sea. The FETP, from its inception, did not work as per the prescribed norms set by the GPCB. Even today it is not able to meet the prescribed norm. For this reason, on July 7, 2007, the Gujarat Pollution Control Board (GPCB), on directions of the CPCB, imposed a moratorium on the industrial areas of Ankleshwar, Panoli and Jhagadia.
With no improvement in the levels of pollution being shown by the CEPI of the CPCB, the MoEF again, through its order of September 17, 2013, re-imposed a moratorium for some industrial areas. In 2009, the Ankleshwar’s industrial area, with 88.50 CEPI, topped the list of ‘critically polluted areas’ of India. In 2011 and 2013, Vapi industrial area, with CEPI of 85.31, topped this list. The Gujarat Government is neither uttering a single word on this.
The Gujarat Government has consistently opposed these moratoriums, without acknowledging the environmental concerns brought up by affected people and environmental groups despite the obvious need. Given that the industries are facing moratoriums from the MoEF for the unabated cycle of pollution, which continues to impact adversely all kinds of lives – human, agriculture and livestock, I am interested to know what you, what is your position on environmental concerns that have led to the moratoriums?
2. Why does your government fail to have a land-use policy? Why is an abundance of chemical industries allowed on fertile land, including the ‘vegetable basket’ of Gujarat like Padra Taluka of Vadodara District?
3. On May 7, 2004 in a writ petition (civil) No 657 of 1995, the Supreme Court ordered Gujarat to provide clean drinking water to residents of villages near Vapi, Ankleshwar, and Effluent Channel Project of Vadodara, where the water supply was irrevocably damaged by industrial activities. Yet, there are ongoing actions contrary to what the court has ordered. This order is still awaiting implementation. When will your government implement this order?
4. The quality of groundwater in Gujarat has reached a critical stage and yet it is being contaminated continuously. Orders for clean drinking water are passed based on the visit of the Supreme Court committee, and the committee is not able to visit all the affected villages of the Golden Corridor. The groundwater of about 14 districts and about 74 talukas of Gujarat are critically affected by pollution, even if we consider the routine parameters like total dissolved solids (TDS), total hardness (TS), dissolved oxygen (DO), chemical oxygen Demand (COD), and some heavy metal like cadmium, copper, lead, mercury, iron etc.
Thus the condition of the groundwater of Gujarat requires immediate attention as the rural population is deprived of the very basic need of safe drinking water and clean water for their animals and crops.
Ahmedabad, Daskroi, Mehmedavad, Vadodara, Ankleshwar, Bardoli, Choryasi, Kamrej, Mangrol, Olpad, Palsana, Valod, Vyara, Navsari, Sanand, Dhoraji, Jetpur, Okha Mandal etc. talukas are critically polluted. Amreli, Jambusar, Junagad, Mandvi, Kalol, Morvi, Upleta, Mahuva, Chorila, Dhangadhar, Limdi, Bansda, Umbergaon etc. talukas are found moderately polluted. If we talk about Vatva to Vapi – the Golden Corridor – it is clear that 70% of the groundwater is contaminated and it has reached the irreversible level. When are you going to act on this serious issue of contamination of ground water?
6. The air pollution situation is also alarming in the Golden Corridor of Gujarat. The GPCB has admitted existence of HCl, SO2, NH3, H2S, NOx, PM2.5, PM10, VOCs, PAHs, PCBs, Vinyl Chloride. Benzene, VOCs, PAHs, PCBs, and vinyl chloride are not being monitored by the GPCB, as no measuring facility is available with it. This statement speaks for itself. In an “advanced state” like Gujarat, why do we not have facilities to take these basic measurements? Moreover, when will you take actions to clean up the air quality, which has become so poor?
7. You are chairman of the Gujarat State Disaster Management Authority (GSDMA) and the same authority has to implement the Gujarat State Disaster Management Act, 2003. The Act clearly states that “disasters” mean “an actual or imminent event, whether natural or otherwise occurring in any part of the state which causes, or threatens to cause all or any of the following: (i) widespread loss or damage to property, both immovable and movable; or (ii) widespread loss of human life or injury or illness to human beings; or (iii) damage or degradation of environment.” However, the GSDMA website states, “The Authority has been created as a permanent arrangement to handle the natural calamities.”
What about environmental disasters? There is no Comprehensive Chemical Emergency Plan’ with the Gujarat State Disaster Management Authority. The Director, Health and Safety Department has an Off Site Emergency Plan; but when I demanded a copy of it, I was told that it is secret. Kindly clarify your position on the crucial issue of a disaster management plan and its transparency.
8. A direct outcome of our persistent efforts since 1994 has been forcing GPCB/ government to act against Hema Chemicals of Vadodara, which was responsible for illegal dumping of hazardous chromium waste in Gorwa area of Vadodara. As per the direction of the Supreme Court Monitoring Committee, the company was ordered in 2004 to pay Rs 17 Crores as first instalment towards remediation of the site. Why has your government failed to remove the hazardous waste dumped by Hema Chemicals, and recover the Rs 17 crore fines from Hema Chemicals, as per the direction of the Supreme Court?
9. Which law allows the effluent that does not meet GPCB norms to be discharged from Tadgam Sarigam Pipeline, from FETP, Ankleshwar, ECP, Vadodara, CETPs of Ahmedabad? I would like you to clarify your position on the issue of such an open and blatant disregard of environment laws.
10. You have included in your book “Convenient Action: Gujarat’s Response to Challenges of Climate Change” (pages 132-133) a photo of the CETP of Vapi, a facility which has not been able to fulfil the environmental norms prescribed by the GPCB for many years. While the photo is very large, there is no discussion about the functioning of CETP of Vapi. Your book completely ignores the failure of all major industrial effluent treatment facilities of Gujarat. Why?
11. Most of the cities and towns are openly and brazenly violating the Municipal Solid Wastes (Management and Handling) Rules, 2000. For example, the Vadodara Mahanagar Seva Sadan (VMSS) is dumping its municipal solid wastes into the ravines, ditches, hillocks of Vishwamitri river by violating the rules. The action of the corporation is directly violating laws, which provide that water bodies should not be permitted to be polluted. Instead of protection and preservation, the government and its corporation are themselves destroying the VishwamitriRiver with their unlawful and unethical dumping of Municipal Solid Waste. This has repeatedly also led to terrible floods from river Vishwamitri. What is your reply?
12. Your book selectively presents information and data, which are convenient to defend the ‘development model’ being pursued by the state. The book completely ignores the information from the Gujarat Ecology Commission (GEC) of the Government of Gujarat, and the press coverage on pollution in Gujarat by almost all newspapers over the last 15 years. Even a Google search on ‘pollution in Gujarat’ would have provided plenty of information. The author could also have accessed basic information from the CPCB and the GPCB to find out the status of the environment of Gujarat. Even the GEC report and the recent Comptroller and Auditor General (CAG) report acknowledge the abysmal status of the environment in Gujarat. Why did you base your book on cherry-picked evidence that ignores the level of irreversible environmental degradation in the state of Gujarat?
On May 25, 2005 the GPCB chairperson had given clear directions to the municipal commissioner of Vadodara Municipal Corporation: (1) to stop dumping of Municipal Solid Waste on the banks of the river Vishwamitri and recollect all the waste from about 70,000 sq. meter area and dispose it on the landfill site, (2) to re-collect solid waste from the bank of the river and clean up natural waterway to avoid the flooding during monsoon season, (3) to re-collect solid waste from the site near Akota Garden and on the banks of the river near the Vadodara Urban Development Authority (VUDA) Circle and dispose of it at the landfill site, (4) to stop burning of municipal solid waste all over the city immediately, (5) to direct the concerned personnel to be more vigilant and careful, and (6) directed them to comply with the direction issued in the authorisation granted.
The VMSS does have a legal site, yet the direction dated May 25, 2005 is not implemented by the VMSS and illegal dumping continues at the illegal site. This is nothing but butchering of the Municipal Solid Wastes (Management and Handling) Rules, 2000. Why there is no legal action under the Act as initiated against the VMSS by the GPCB?
12. I had lodged a complaint against residential and commercial complexes coming up in the vicinity of hazardous solid waste sites in Ahmedabad (Vatva and Naroda) in violation of GPCB notification on industrial hazardous solid waste and The Hazardous Waste (Management & Handling) Rules, 1989. These complexes were in violation of the CPCB and GPCB guidelines and norms requiring a 500 metres safety distance from Treatment Stabilisation Disposal Facilities (TSDFs) to residential complexes.
Instead of punishing the violating builders/contractors, the Forest and Environment Department and the Urban Development and Urban Housing Department of the Government of Gujarat decided, in the meeting dated September 5, 2011, to relax the required 500 metres safety radius to only 100 metres for the purpose of legalising all illegal residential complexes, which came after the notification. For future, it was decided that the 500 metres distance would be enforced.
The original guideline was issued with the intention of preventing risk to the health and safety of the people. The revision obviously looks at the profit margin of unscrupulous contractors, not the innocent residents who will suffer in future. Why?
13. A new hotspot is taking shape near Sardar Sarovar Dam. The work for the Garudeshwar weir, proposed about 12 km downstream of the Sardar Sarovar dam, began without necessary environmental clearance from the Environmental Sub Group (ESG) of Narmada Control Authority’s (NCA). It is very clear if one looks closely at the letter dated March 24, 2013 written by a senior member Shekhar Singh of the ESG of NCA to its chairperson Dr V Rajagopalan, secretary, MoEF, Government of India. He expressed surprise over the Gujarat government’s decision to start work for the construction of the Garudeshwar weir without obtaining necessary environment clearances.
The six villages, which were the first to hand over the land way back in 1961-63 to build the Staff Colony, Government Offices and Guest House to build the Sardar Sarovar Dam, have even decades later not been considered “equal” to other project affected persons (PAPs), thus remaining deprived of all the facilities which other PAPs of Sardar Sarovar Dam of Gujarat, Maharashtra and Madhya Pradesh have been offered. In fact, there are about 70 adjacent tribal villages which cannot even access Sardar Sarovar Dam water for irrigation. Worse, the view is gaining ground among them that water is only for urban and industrial use.
The view is also gaining among the villagers that all this is being done at a time when the Gujarat government has decided to build the highest statue of the world in the memory of Sardar Patel by spending Rs 2,500 crore near the Sardar Sarovar Dam, around which tourism will be developed.
Lakhan Musafir and Rohit Prajapati of Paryavaran Suraksha Samiti and Savitaben Ganpatbhai Tadvi and Mavajibhai Jesangbhai Tadvi, residents of affected villages filed a case [Application No. 10 of 2014 (WZ)] before the National Green Tribunal (NGT)-Pune to stop construction of the Garudeshwar weir. Two hearings have taken place. At the last hearing, on February 25, 2014, the NGT agreed to a Gujarat government plea for “more time” to reply. Till April 27, 2014. This order makes it very clear that as of today the Government of Gujarat is not in a position to give any clear categorical answer on two counts: (a) whether Garudeshwar Weir has environment clearance or not, (b) under which law of the land or notification or permission the construction of Garudeshwar Weir is being carried out. Kindly clarify your position on this crucial issue.
14. Regarding the activity around Statue of Unity Project near the Sardar Sarovar Dam in the river downstream from the dam, just 3.2 km from the Shoolpaneshwar Sanctuary, in an eco-sensitive zone and involving massive infrastructure work has started without legally mandatory environment clearance, environment and social impact assessment or any public consultation process.
This is illegal, in violation of the Environment Protection Act, 1986 and EIA notification of September 2006 and a number of NGT and Court orders about such massive kind of construction on the riverbed. On October 31, 2013, the foundation stone was laid by you for the project amidst huge fanfare and media attention. Tenders have also been floated. Even the work for the Garudeshwar weir, proposed about 12 km downstream of the Sardar Sarovar Dam, began without any social or environmental impact assessment, public consultation and environmental clearance from the ESG of the NCA.
The website http://www.statueofunity.in/ states: “A 13km long water body (pond) will create an excellent tourist spot with available infrastructure on both the banks.” Further, “The Statue of Unity is planned to be erected on the river bed downstream of the main dam in the Garudeshwar Weir pond. A permanent standing water pool in and around the Statue of Unity will be created by Garudeshwar Weir, which will enable boating activity around the statue.” The estimated cost of the project is more than Rs 2,500 crore. The website adds, “A monument, that will not just be a mute memorial like the rest, but a fully functional, purpose-serving tribute that will boost tourism and facilitate development in the surrounding tribal areas”. The seismic hazard analysis claimed to have been done by the Gujarat Government’s in-house Institute of Seismological Research cannot be considered credible unless peer reviewed and put in the public domain.
In view of the above facts, we demanded that (1) direct the Government of Gujarat to submit application for environment clearance and till that is obtained, not to do any work related to the project, (2) direct the Government of Gujarat to immediately stop planned project called Statue of Unity and direct them to stop all other activities related to the Statue of Unity, (3) declare the action – of the foundation stone installation on October 31, 2013 for the project called Statue of Unity – of the Chief Minister of Gujarat State as illegal, in violation of the Environment Impact Assessment (EIA) notification of September 2006 and the Environment Protection Act, 1986. Till date, we have received no response from the concerned authorities.
Why are you and your office silent on this crucial issue?
15. Central and state governments are collectively pushing the 6000 MW Mithi Virdi Nuclear Power Plant. This is the area where the Manmohan-Modi governments have planned in tandem, to set up a 6000 MW nuclear power plant spread over 777 hectares of prime agricultural land, against which the local villagers have led a consistent, vocal protest.
Orchards of mangoes, chikoos, coconut trees, lush greenery, sea and ships passing by, describe aptly the Mithi Virdi – Jaspara area in the Talaja block of Bhavnagar district. This lush green area is the irrigated region of Shetrunji dam. In a time when Special Investment Region has become the most lobbied term in the state of Gujarat, this region too should be announced as SAR (Special Agriculture Region) for agricultural purposes. Situated on the Saurashtra sea coast, one might assume that the land is barren and uninhabited, but a visit here belies all these assumptions. It is perhaps from this mistaken presumption that the proposal for a 6000 MW nuclear power plant spread over 777 hectares on this green lush land must have taken place.
Presently on this 777 hectare of land spread in Jaspara, Mithi Virdi, Khadarpar, Mandva stand 50,000 fruit trees. Also, bajra, cotton, groundnut, onions and other crops are sown round the year because of the irrigation facilities. This area is therefore aptly called Bhavnagar’s food basket.
On June 11, 2013, while giving the so-called coastal regulatory zone (CRZ) clearance/ recommendation for CRZ clearance, the Gujarat Coastal Zone Management Authority (GCZMA) stated that “The authority deliberated the proposal of Nuclear Power Corporation of India Limited and after detailed discussion, the Authority decided to recommend to the MoEF, Government of India to grant CRZ clearance for construction of intake, outfall facilities, jetty and Desalination plant at Village: Mithi Virdi, Dist: Bhavnagar by M/S Nuclear Power Corporation of India Limited, only after submission of the following details to this Department: 1. Detailed note regarding the safety aspects and site selection criteria along with its advantage for this site and submit to this Department. 2. A site visit should be carried out by GCZMA member.”
This clearly means that the GCZMA is not serious about the CRZ clearance. Kindly explain such a dubious illegal action of Gujarat.
16. The Gujarat Government wants to forcibly take over agricultural land at low cost, it wants to ensure that workers are paid low wages, and it will do its best to ensure that industrialisation does not confront ‘stupid’ hurdles like workers rights and environment laws. It is evident from what the then Finance Minister of Gujarat, Mr. Vajubhai Vala, said while addressing a day-long pre-Vibrant Gujarat Summit seminar at Ahmedabad Management Association on ‘Industry Responsive Skill Development: The Emerging Trends in Gujarat’ on January 11, 2011: “A farmer engaged in agriculture on a five acre plot will earn enough only for his family. But if an industry is set up on that land, it will provide sustenance to families of 25-30 thousand workers.” He asked local industrialists not to spoil workers by giving them more than what is rightfully due to them.9 Thus, it is evident that for the Government of Gujarat, ordinary people do not matter at all. Kindly clarify your position on the viewpoint of your then Finance Minister of Gujarat.