http://bharatmukti.blogspot.in/2017/05/bmm-objections-to-jindals-coal-handling.html
Date: 29th April 2017
To,
The Member Secretary
Goa State Pollution Control Board,
Panjim, Goa
Subject: Objections to Proposed Terminal Capacity Enhancement at Berth 5A-6A of
Mormugao Port, Mormugao, Goa
I place my objections to the above mentioned subject as under:
1. Chapter 1 of the EIA of the above proposal prepared by WAPCOS Limited (A
Government of India Undertaking, 76 C, Sector 18, Gurgaon – 122015, Haryana,
India states “Mormugao Port is a Major Port on the West Coast of India has
completed 125 years of glorious service to the nation’s maritime trade.” MPT
was never part of nation’s maritime trade for 125 years. It became part of
India only in 1961 when India annexed Goa through conquest. Before that it was
developed to serve Colonial powers Portugal and England for colonial purpose.
Declaring 125 years as glorious service to nation’s maritime trade is
politically objectionable as it is vague. Which nation did MPT served
gloriously for 125 years?
2. EIA Chapter 1 further states “JSW Energy Ltd. (JSWEL) is the first
Independent Power Producer (IPP) set up in the state of Karnataka. The company
has set up 2 units of 130 MW each and two units of 300 MW each and all these
units are generating power using Corex gas and coal.” So it is assumed that
these MPT berths will be used for the import of coal for this independent power
producer in Karnataka. Goa should not be allowed to suffer due to coal for this
power producer.
3. EIA Chapter 1 continues “Mormugao Port Trust (MPT) is strategically
located to cater to the needs of the coal requirement of steel and power plants
of its hinterland in Karnataka. Although MPT is ideally located to serve the
industries in the hinterlands of Karnataka, a lot of cargo including coal is
imported through some of the ports situated in eastern coast of India despite
the fact that the rail distance from these port to the industries are much more
compared to Mormugao Port.” So Goa is only the corridor for Coal. We oppose
making Goa corridor for Coal.
4. EIA Chapter 1 continues “Imports/Exports through Capesize vis-à-vis
Panamax vessels will result in freight advantage and thereby the industries
stand to benefit.” So Goa no way benefits. Only industries stand to benefit.
People of Goa do not stand to benefit. They stand to loose their health due to
coal pollution.
5. Chapter of the mentioned EIA continues “The dust barrierisation and
pollution prevention-control of the existing facility will also be brought to
the level of state-of-art protection to ensure lesser total pollution from the
proposed facility.” So currently it is not at the level of state-of-art
protection. And even after bringing in state-of-art protection pollution will
not be stopped. So what is the use of inducting state-of-art protection? JSW
existing operations at these ports must be stopped, EC must be denied for
expansion.
6. EIA studies must be comprehensive and not fragmented. Fragmented impact
assessment is deceptive and misleading. Currently WAPCOS has done three EIA
studies: two for MPT and one for JSW in a fragmented manner.
7. Above mentioned EIA of JSW in Chapter 2 states ““Mormugao Port Trust
(MoPT) is strategically located to cater the needs of the coal requirement of
steel and power plants of its hinterland in Karnataka.” Just because MPT is
strategically located Goa must not be abused through coal pollution and
heightened risk to life.
8. Chapter 2 of this EIA notes “MPT has taken up the dredging of the
approach channel and the port area for permitting navigation of Cape Size
Vessels of up to 180,000 DWT.” Dredging for channel deepening has already
destroyed bio-diversity as per study report submitted to NGT in this matter. No
dredging of Arabian Sea must be permitted to be carried on by MPT or anybody
else.
9. Further Chapter 2 continues ““MPT has proposed to deepen the approach
channel to suit the navigational requirements of Capesize vessels. The outer
channel which are having present depth of -14.4 m will be deepened to -19.8 m
and the inner Channel from -14.1 m to -19.5 m. This will facilitate navigation
of Capesize Vessels at any state of the tide.” The success of this project
depends upon commitment from MPT to deepen the approach channel. So when one is
inter-dependent upon another why have Public Hearings fixed separately?
10. Chapter 2 of mentioned EIA continues “Ships presently calling at the Berths
are generally up to 80,000 – 90,000 DWT (Panamax size vessels). Consequent upon
the completion of dredging for the draft depth of 19.8m by Mormugao Port, the
port would be able to handle cape size vessels up to 180,000 DWT capacities.”
What are the ecological, environmental and social costs of this dredging from
14.1 m to 19.5 m ? There is no data in the EIA on this subject.
11. Silent feature listed in the above mentioned JSW EIA under Chapter 2 as “No
additional land area or waterfront is involved” is deceptive as the project is
entirely dependent upon dredging of water front by MPT and that is impacts not
discussed here jointly is clearly dubious.
12. JSW EIA states in Chapter 2 “Break Bulk Cargo (Import Cargo) (Coal, Coke,
Coking Coal, Limestone, Iron Ore, Bauxite, Dolomite etc.)” This has been the
scene of pollution for Vasco for very long and source of public outcry. This is
ridiculous, adding insult to the injury!
13. This EIA further notes in Chapter 2 “Steel Slab / Coil, Steel Finished
Products (Export Cargo)” So here is export of steel manufactured in Karnataka
exported through MPT. Goa is just a corridor. Why Goa has to suffer as corridor
for coal?
14. Chapter 2 of JSW EIA states “The maximum fully laden vessel draft that can
be accommodated within the harbour at all stages of the tide is 13.4 m allowing
for under-keel clearances. However, vessels are sometimes loaded up to 14.1 m
draft, departing only on the high tide. However, the present channel is planned
to accommodate the Cape Size vessels with a dredged depth of -19.8 m. Once
dredging is completed the Cape Size vessels would call upon the Port.” Once
again there is reference to the dredging, so the three Public Hearings must be
joint as ground operations are joined and dependent upon one and another.
15. Chapter 2 of JSW EIS continues “In the recent years the International price
for Iron Ore has gone down appreciably. This has made import of the Iron Ore at
low prices to the Indian Sub-continent affordable. The Western Australian and
Brazilian Iron Ore with higher Iron content has made the life of steel makers’
lot easier.” So because of lowered price of iron life of steel makers is lot
easier. Do people of Vasco has to suffer pollution only because of lowered
price of iron ore?
16. Chapter 2 of this EIA of JSW further states “The main importer of coal
through Mormugao Port is JSW Steel located at Vijayanagar, Karnataka.” So to
serve JSW Goa has to surrender and sacrifice itself as corridor? This is
ridiculous and must stop.
17. Further JSW EIA makes it very categorical disclosure ““Coal importers stand
to gain substantial freight advantage by deploying Capesize vessels.” What does
Goa and our People stand to gain? We cannot even breathe fresh air in Vasco
because of Coal air pollution. Destiny of Goa cannot be left in the hands of
Coal importers. Coal import from Vasco MPT Port must be stopped immediately.
18. Chapter 3 of this EIA points to “presence of coliform oranisms in two out
of five samples indicates anthropogenic source of pollution.” This is an
evidence of ground water pollution.
19. Table 3.41 in this EIA dealing with Fishermen population in the study area
completely ignores Fishermen population in Madkai, Agassaim, Siridao, Bambolim,
Nauxim, Carcra, Odxel, Dona Paula and Caranzalem. For what reason the entire
fishing villages are omitted from EIA? This is unacceptable and very dangerous
way of conducting EIA.
20. Chapter 04 of this JSW EIA has points “potential sources of environmental
impact from operations may include shipping movements, discharge of wastewater
and solid waste, accidental spillage, cargo unloading/loading and storage,
noise pollution, air pollution due to material transfer and handling.” When all
impacts are listed and are known this JSW project must be rejected.
21. Chapter 04 further states “the accidental spillage of oil or fuel from
construction machinery that may run off into near-by surface and groundwater
water bodies and/or uncontrolled liquid effluents from the construction site.”
So the possibility of ground water pollution is admitted in EIA itself. This is
again dangerous and unacceptable.
22. Chapter 04 further states “potential sources of impacts on marine water
quality during the Port operations are:
§ Disposal of Jetty related wastes
§ Disposal of ship generated wastes
§ Escapement of cargo, and
§ Effluent from coal stack yard”.
These are enough reasons to anticipate diversity of polluting
effects.
23. Chaper 04 of the above mentioned EIA further states “The International
Convention for the Prevention of Pollution from Ships, 1973, as modified by the
protocol of 1978 (MARPOL, 73/78), has issued guidelines for prevention of
Marine Pollution.” Present record of enforcement of this law is dismal. Several
barges release their waste and fuel into Mandovi and Zuari rivers. Barges
through left over ore into these rivers and also into Cumbharjua river. Barges
are washed in the middle of rivers causing pollution of water and environmental
hazard. Violations from ships carrying ore are known even to the highest
authority at MPT and yet this law is not enforced and pollution is ignored. We
quote here former Chairman of MPT from his exclusive interview to Herald in Goa
on 17/06/2015 “People should also understand that there are so many shipyards
not following environmental laws, besides there are barges along the Zuari
river bay and each of these barges has created health hazards, environmental
hazards besides pollution. These aspects are ignored.” These aspects are
ignored by MPT itself and possibility of enforcement is zero. Hence this
project must be rejected EC by MoEF.
24. On page 4-12 of this EIA it is stated “any fishing within the Jetty limits
will be prohibited for safety and security reasons.” This is a direct admission
of project that is bias against fishing and fishermen. Furthermore there has
already been restrictions placed on fishermen in Mandovi and Zuari rivers where
ore transportation is carried on through barges.
25. Page 4-15 states “Coal dust needs to be cleaned regularly from coal stack
pile areas using water sprays. The water can be channeled from various
locations and brought to a common point for treatment prior to disposal.” From
which locations in Goa the water is going to be brought for spraying of coal is
no disclosed.
26. The same page 4-15 admits air pollution from Coal “During unloading and
storage at
coal stockyard, the following sources/activities could lead to air
pollution:
· Dust caused by displacement of air
· Dust blown out by the wind
· Wind erosion from disposal sites”
27. This air pollution has turned Vasco city into a ghost town turning
everything black and caused enormous health and environmental hazard. Goa
cannot afford to be a corridor for coal. Dust blows already caused so much of
public outcry. In China some cities are so polluted that blue sky is invisible.
Companies make business selling packed plastic bags of pure air imported from
Canada. Several Children born after 1992 in Beijing have not seen the Sun. Its
all smog due to air pollution. Is that way we are heading?
28. Page 4-16 states “Water sprinkling dust suppression systems will be
provided at strategic transfer points.” How much water will be used for
sprinkling? From where the water will be supplied for sprinkling?
29. Page 5-1 states “The collected oily matter is stored in cans, etc. and
disposed at the landfill sites designated by the district administration.” Oil
waste will be disposed off in Goa. Where in Goa it will be disposed off? No
answers available in EIA.
30. Page 5-5 states “All the solid wastes arising in the premises shall be
properly classified and handed over to Goa Municipal Corporation for disposal.”
Goa Municipal Corporation does not exist. This is fraud committed by JSW.
31. Pages 5-5 and 5-6 states “The reduction in the emissions is achieved by
continuous spraying of water so that the surface remains moist and the dust
gets suppressed.” This entire process is of spraying of water to achieve
reduction in the emissions places huge pressure on Goa’s water sources. Goa
can’t afford to waste precious water on dozing off perennial coal fires. Hence
JSW handling of coal in Goa must be stopped. How much water will be needed for
spraying annually?
32. On page 5-2 to 5-3 there is promise “The project authorities will work
closely with representatives from the community living in the vicinity of
project area to identify areas of concern and to mitigate dust-related impacts
effectively (e.g., through direct meetings, utilization of construction
management and inspection program, and/or through the complaint response
program)”. The grammar of this is in future tense: the project authorities will
work closely. JSW has been functioning at MPT from 2001 onwards. Why from that
time till date no representatives from community living in the vicinity
involved? On the contrary there is tension with the entire community in Vasco
due to air pollution caused by Coal. Tension with local community is visible
here. Further boiling could throw situation out of control.
33. Figure 5.1: Water sprinkler system at ship unloader facility. From where
water will be supplied? What is the annual requirement?
34. Figure 5.2 A: The water spray/mist system in the berth hopper for dust
suppression. From where water will be supplied? What is the annual requirement?
35. Figure 5.2 B: The water spray arrangement on the berth conveyor with the
dust hood. From where water will be supplied? What is annual requirement?
36. Figure 5.2 C: Water spray system at the transfer towers and conveyor
systems. From where the water will be supplied? What is the annual requirement?
37. Figure 5.3: Layout showing sprinkler system for open stack yards. From
where the water will be supplied? What is the annual requirement?
38. Page 5-14 states “The water spraying is done periodically only to dowse the
fire during stack piling.” This means there is burning coal involved. This is
an insult to Goa and scandal to ecology.
39. Page 5-17 states “Mobilization procedures are required only in case the
spill is likely to affect the coastline and damage the marine sensitive areas.”
Possibility of oil spill affecting the coastline and damaging marine sensitive
areas is very real and dangerous scenarios could result.
40. Page 5-18 states “Prepare releases for public and press conferences”. So
this is a way public and press is going to be controlled? Is it brainwashing
and manipulation of public opinion?
41. Same page 5-18 further states “The National Oil Spill Disaster Contingency
Plan (NOS-DCP) describes the responsibilities of ports handling petroleum and
its products. Indian Coast Guard is the Central Coordinating Agency for marine
response.” So Oil spill can result in very serious disaster.
42. Figure 5.6 presents Water balance diagram during the operation phase with
MPT as credited source. JWS requires 3 lakh litres of water daily for dust
suppression and additional 1 lakh litres of water for fire fighting. Monthly
requirement for fire fighting will be 30 lakh litres of water. While
requirement for 365 days will be 365 lakh litres of water. Monthly requirement
of water for dust suppression at the rate of stated figures of 3 lakh litres
per day amounts to 90 lakh litres of water. While requirement for a year (365
days) it increases to 10,95,00,000 litres. Annual requirement of water for dust
suppression and fire fighting totals to 14,60,00,000 litres per year. All this
water is to be sourced from Goa. This is unacceptable. When water tanker comes
to localities each family not even get 200 litres of water per day. Several
schools children have no access to running water in toilets. Yet Jindals will
be using water for the destruction of Humanity.
43. This Jindals project has no benefit to Goa and hence must be rejected.
Project proponents and Government officials are colluding to destroy Goa. GSPCB
has intentionally fixed three separate Public Hearings in order to harass
people of Vasco and beyond. EIA report of this project is fraudulent document.
GSPCB should have assessed this report prior to Public Hearing. Cumulative EIA
needs to be prepared rather than three separate EIAs.
Based on above grounds we strongly oppose proposed Terminal Capacity
enhancement at berth 5A, 6A of Mormugao Port Trust by M/s South West Port Ltd,
Mormugao- Harbour, Goa. However in spite of such a credible public objection if
this project of JSW still gets EC from MoEF then it would be one more
confirmation of corruption in MoEF as publicly alleged in press by Goa Chief
Minister Manohar Parrikar on 06/09/2012 that MoEF is a corrupt Ministry and
grants EC clearances based on collection of bribes from corporate and turns
blind eye to rampant illegalities in Goa.
Moreover Jindals project at MPT represents return of Peshwayee in India. We are
in the 199th year of the destruction of Peshwayee in the battle of Bhima
Koregaon at the outskirts of Pune. It is fitting that MoEF reject EC to JSW for
this project.
Thank you.
Yours Sincerely,
Sd/-
Maggie Silveira
President
Goa Unit
