The Chief Secretary, Government of Goa,
Panaji G O A January 19th, 2015 Dear Sir, We write with respect to the public hearing being conducted by the North Goa Collector and District Magistrate under your instructions on Feburary 1, 2015 at Simechen Adven, Pernem on the Environmental Impact Assessment (EIA) report for the proposed greenfield airport project at Mopa. The Mopa plateau abuts the mountain chain of the Western Ghats, older than the Himalaya mountains and deemed a World Heritage site by UNESCO since it represents geomorphic features of immense importance with unique biophysical and ecological processes. As the UNESCO document points out, the Western Ghats of India are a geomorphic feature of immense global importance. As the document further goes on to state, the Outstanding Universal Value of the Western Ghats is manifested in the region’s unique and fascinating influence on large-scale biophysical and ecological processes over the entire Indian peninsula. The mountains of the Western Ghats and their characteristic montane forest ecosystems influence the Indian monsoon weather patterns that mediate the warm tropical climate of the region, presenting one of the best examples of the tropical monsoon system on the planet. The Ghats act as a key barrier, intercepting the rain-laden monsoon winds that sweep in from the south-west during late summer. A significant characteristic of the Western Ghats is the exceptionally high level of biological diversity and endemism. This mountain chain is recognized as one of the world’s eight ‘hottest hotspots’ of biological diversity along with Sri Lanka. UNESCO goes on to point out that the forests of the site include some of the best representatives of non-equatorial tropical evergreen forests anywhere and are home to at least 325 globally threatened flora, fauna, bird, amphibian, reptile and fish species. The effect of the Western Ghats on the rainfall and climate of the country, will surely make not only every Goan, but every Indian an affected persons with respect to this proposed Mopa airport project being constructed on a massive chunk of 84 lakh square metres of land in such an ecologically sensitive zone. Hence kindly consider us as affected persons, who are approaching you to express our serious concerns regarding the EIA. In fact, we are shocked that such an unacceptably casual, shoddy and shallowly constructed document on such an important issue for Goa and future generations of Goans is even being considered for acceptance by the State Government and its administrative machinery. After closely examining and analysing the above mentioned EIA, we put before you the our following concerns : 1. In the interest of obtaining an authentic and realistic picture of the potential impact this proposed airport will have on the Mopa plateau and the Western Ghat region, we are sure you will agree that the above EIA study should have been conducted over a period of at least one year, in order to reflect the impact during the seasonal variations, particularly the monsoon season, when the rich biodiversity comprising flora, fauna and various water bodies are at their peak. Hence if the EIA study conducted by EIL was truly serious about reflecting the cycle of seasonal ground realities prevalent, logically, it should have surely been conducted for the period of an entire year at the very least as the biodiversity assemblage changes as per the season. 2. The IUCN status of each floral species listed has not been mentioned in the EIA. This surely should have been incorporated in the report. 3. The report mentions that the data on biological study has been obtained from secondary sources like published literature, but has not mentioned the sources/references as needed to be done. 4. Last year, a bison was killed in the neighbouring area of the site in question, thus proving the presence in the area of the state animal Gaur, which is a Schedule I species as per the Wildlife Protection Act 1972. Needless to say, there is no mention of this in the EIA. 5. While the presence of the Indian Chameleon has been recorded in the report it has failed to mention the crucial fact that it is a Schedule II species as per Wildlife Protection Act 1972. 6. The presence of Schedule II species and some of the vulnerable species such as Porcupine, Indian Monitor Lizard, Langoor, Barking Deer, Indian Rock Python, Russell’s Viper, Saw Scaled Viper etc. find no mention in the EIA, although these species are regular in plateau habitat. 7. Although the report states that fish fauna were surveyed, it has failed to include the list in the report. 8. Some of the butterfly species highlighted in the report are listed in Schedule I of the Wildlife Protection Act 1972. This very relevant fact however, has strangely not been mentioned in the report. 9. The Plateau serves as grazing ground for domestic livestock and is the breeding ground for many avian species. In addition to the above, which relate to biodiversity issues, as Goa’s Chief Secretary, you will surely appreciate that the State is presently facing an extremely acute environmental crisis caused by serious losses of its surface water and ground water resources due to mining related destruction, loss of plateaus to industrial estates, quarries and real estate, urban sprawl, real estate and tourism related pollution, unsustainable land conversions in the coastal plains and other over intensive uses of its limited land resources. Pernem taluka already faces acute water shortages and is in the unfortunate situation of having to rely on the Tillari Dam built in Maharashtra for its water supplies. This Dam, which was supposed to provide water for irrigation purposes, is now being sought to provide water for the construction of this proposed second Mopa Airport project, which is almost certainly doomed to economic unviability as it is in the vicinity of airports like Dabolim, Chipi, Kolhapur, Hubli and Belgaum to name a few. It is unthinkable to foist a massive project like the Mopa Airport on an area that is not even self sufficient in water. What is also extremely troubling is that despite the fact that the EIA report itself states that the existing Dabolim Airport is sufficient until 2040 without compromising service levels, this superfluous project is being brazenly pushed ahead despite condemning Goa to unnecessary and untimely economic, environmental and social collapse. In the light of the very valid and pertinent points raised by us above, we believe that as Goa’s Chief Secretary, it would be appropriate for you to immediately stay the ongoing processes undertaken by the authorities, including the Public Hearing hastily scheduled for February 1st, 2015, until you have reviewed the EIA report perhaps in consultation with the State Biodiversity Board and the State Pollution Control Board, to establish the thoroughness and veracity of its contents. We therefore request you to kindly do all that is necessary to ensure that a proper and credible EIA study is first conducted on the impact of the proposed airport on the State of Goa and the local residents in particular, and to stop all proceedings related to environmental approvals for Mopa Airport until such a study is completed and closely analysed and considered, for which we shall be extremely grateful. Thanking you and looking forward to your co-operation, Yours truly, For GOANS FOR DABOLIM ONLY Fr. Eremito Rebelo Convenor Copies for information and necessary action to : 1. Minister of Forests & Environment / Chairperson, Goa State Biodiversity Board 2. Chairperson, Goa State Pollution Control Board 3. Member Secretary, Goa State Biodiversity Board
