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SHODDY EIA REPORTS AT A GLANCE

Sr. No1

Name of EIA Consultant

Details of the EIA Key Issues

1.RITES Project Title: Pala Maneri

Hydro Electric project, Uttaranchal

Project Proponent: Uttaranchal Jal Vidyut Nigam Ltd.

Year of EIA: 2003 and 2005

§ Public Hearing in 2003, and Clearance granted in 2005 was based on two different versions of the EIA

§ The 2003 Report listed only 5 impacts and the 2005 report included tunnelling, vibrations, muck disposal and impacts on the village Aungu etc

§ Does not mention loss of a reserve forest area

§ Some people claimed to have been interviewed were not alive at the time the EIA was being prepared.

2.Agricultural Finance Corporation Ltd., Northern Regional Office, New Delhi (H.O Mumbai)

Project Title:  Tipaimukh Hydroelectric Multipurpose Project,

Project Proponent: North East Electric Power Corporation Ltd.,(NEEPCO)

Year of EIA:  2004

§ According to an indepen-dent expert opinion, the EIA/EMP final report "contains innumerable in-correct data, unverified and superfluous state-ments, and above all re-veals the casual approach on the part of both NEEPCO as well as AFCL towards an impor-tant issue."

§ The Expert Appraisal Committee, MoEF has considered this project proposal twice already in December 2006 and again in February 2007, and found data discrepancies

§ The number of affected villages, incomplete base-line environmental infor-mation, no landslide prone areas information, no soil analysis data, out-dated seismic hazards as-sessment parameters, in-accurate and erroneous bio-diversity and fauinis-tic information, below ac-cepted international stan-dards bio-diversity con-servation plan, non-in-

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volvement of PAPs and their families in formulat-ing R&R measures, and no benefit-cost analysis

§ The EAC rejected the clarifications provided by NEEPCO in February 2007, and has in fact re-quested NEEPCO, to re-survey the project site to include important base-line environmental infor-mation and an acceptable bio-diversity conservation plan according to existing international standards

§3.

Environment Resource Management (ERM)

Project Title: 192 MW Allain Duhangan Hydropower Project in Beas river basin in Kulu district in Himachal Pradesh h Group

Project Proponent: Bhilwara Group

Year of EIA: August 2003

§ Details of Carrying Capacity, Cumulative impacts of dams, Assessment of the project will impact wildlife migration routes

§ Disaster Management Plan not included

§ Height of dam unclear, therefore impacts are misleading or incomplete

§ Social impact assessment and R&R plan missing

4.National Environmental Engineering Research Institute (NEERI)

Project Title: Comprehensive EIA for of the 1000 MW Karcham Wangtoo HEP, Dist Kinnaur, Himachal Pradesh

Project Proponent: Jaiprakash Group

Year of EIA: 2003

§ Written to promote the project and expedite its clearance, rather than assess social and environmental impacts.

§ Inadequate assessment of Catchment Area Treatment, inaccurate reporting on earthquakes and an absence of reporting on impact of the project on the land slides, soil erosion, settlements, and no disaster management plan

5. RITES, in association with Scott Wilson Kirkpatrick Consulting Engineers, UK

Project Title: Bombay- Pune Expressway

Project Proponent: Government of Maharashtra, Public Works Department

Year of EIA: 1995

§ Overlooked the ecological and environmental importance of the Western Ghats and recommended a completely new road in the Western Ghats (which the MoEF realised and suggested the alternative of widening NH4, even though that is as ecologically destructive)

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§ Frequency of landslides and dumping of debris down the Ghats unaccounted for

§ Socio-economic impacts of bypassing Khandala and Khopoli, and disruption in route of the Dhangar nomads not studied

6.M/s EMTRC Consultants Private Ltd, New Delhi

Project Title: Expansion of Steel & Power Plant at Raigarh , JSPL

Project Proponent: M/s Jindal Steel & Power Ltd, Raigarh (Chhattisgarh

Year of EIA: 2004

§ No clear linkages made between the existing project and its expansion phase

§ Levels of carbon dioxide emitted is underestimated and downplayed

§ Computation of the ratio between the number of trees needed for carbon sequestration and number of trees planted missing. When calculated, it works out to 1:73

7.EQMS India Pvt. Ltd.

Project Title: Thermal Power Plant of 1200 MW at Jaigad, DistrictRatnagiri, Maharashtra.

Project Proponent: JSW Energy Ltd. Mumbai

Year of EIA: 2006

· The location of the ther-mal plant shown in the map is far north of actual location

· Location of Ashpond is not discussed, Project lay-out map absent.

· Distance from the HTL is grossly over-stated (as 2km while it actually is only less than 500 m and is well within CRZ).

· The source of fresh water for the project has only partly been identified

· Wrong wind direction and miscalculations of plume dispersion and GLC of Sox and NOx

· Impacts on Ratnagiri Alphonso Mangoes, fish-ing community, and local water security not ade-quately addressed

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8. National Environmental Engineering Research Institute (NEERI)

Project Title: Sethusamudram Ship Canal Project (SSCP),

Project Proponent: Tuticorin Port Trust.

Year of EIA: 2004

§ Submitted a Rapid EIA instead of a Comprehensive EIA

§ No Risk Analysis/Assessment and Disaster Management Plan as part of EIA

§ Does not fulfill Terms of Reference for EIA given.

§ Sub surface geo-technical investigations left out Palk Bay and Palk Straits

§ All studies based on normal weather conditions when the project area is know for its frequency of tropical cyclones

§ Consequently, impact on the ecosystems of the Gulf of Mannar and Palk Bay, especially the coral reefs and sea grasses, cannot not studied accurately and was not done in the EIA at all

§ oil spills and impacts of tsunami related shipping disasters on this eco-region not studied

9. National Environmental Engineering Research Institute (NEERI), Nagpur

Project Title: Common Hazardous Waste Disposal Facility at SIPCOT, Gummidipoondi, Tiruvallur District, Tamilnadu

Project Proponent: State Industries Promotion Corporation of Tamil Nadu (SIPCOT)

Year of EIA: January 2005

§ Preliminary Environmental Appraisal." Passed off as EIA

§ Survey numbers of site location wrong

§ No Environment Management Plan

§ No primary data on environmental baseline

§ Admits that impact on water not studied for lack of data about the specific nature of the hazardous wastes

§ Findings and conclusion

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don't match. Report finds that area unsuitable for TSDF, but nevertheless recommends siting.

§ Report dated January 2005 has data from February 2005

10. Water and Power Consultancy Services Ltd. (WAPCOS)

Project Title: Athirappilly Hydro Electric Project (163 MW) in Chalakudy River, Kerala

Project Proponent: Kerala State Electricity Board

Year of EIA: 2002

§ Options Assessment and Water Budgeting not carried out

§ Impact of daily change in the flow pattern and its impact on downstream drinking and irrigation missing

§ Cumulative impact of six dams upstream not studied

§ Socio-economic impacts on PAPs not addressed

11.VIMTA Laboratory

Project Title: Utkal Alumina International Limited (UAIL), Kashipur, Orissa

Project Proponent: Hindalco (India) and Alcan Aluminium (Canada)

Year of EIA: December 2004

§ Rampant duplication of data

§ Environmental Management Plan of the mine, presented the EMP of limestone mining

§ Cumulative impact on the Indravati River Basin and its resultant impact on people and habitat dependent on the river

§ No measures mentioned for controlling SO2 emissions from calciners

§ Ignored the issue of impact on forests

12.Bharat Foundation

Project Title: Expansion of Talabira –I Coal Mines, Sambalpur District, Orissa

Project Proponent: HINDALCO

Year of EIA: February 2005

§ Not mentioned the increase in the concentration of SOX, CO due to coal fire in the mining site

§ Cumulative impact on the ambient air quality due to cluster of industries in this area not studied

§ Impacts of mining on the ground water of the area not studied

§ Impacts on livelihood activities like activities like Kendu leaf collection, Bidi making, collection of mango fruit

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not considered 13.

VIMTA Laboratory Project Title: Vedanta Aluminum Smelter and Captive Power Plant, Jharsuguda, Orissa

Project Proponent: Vedanta Alumina Ltd

Year of EIA: September 2005

§ Cumulative impacts of both the CPP and Smelter plant on the environment not recorded

§ Siting criteria from the manual prepared by the Impact Assessment Division of MOEF violated with regard to distance from flood plains

§ The impact on the Biodiversity of Hirakud reservoir ignored

§ EIA based on a study period of 3 months which is totally insufficient for a study of this nature

14. Modular Consultants Private Limited

Project Title: Integrated Sahara Tourism Circuit at Sunderbans, West Bengal

Project Proponent: Sahara India Tourism Development Corporation Limited

Year of EIA: 2003

§ Project Report and the EIA were both prepared by Modular Consultants Pvt. Ltd, thus lack of objectivity

§ Exact location of two water based hubs was not identified and impacts not studied

§ Some project sites being nesting grounds for Olive Ridley turtles ignored

§ Impact on fishermen and fishing not studied

§ violates the CRZ Notification

15.WAPCOS Centre for Environment Water & Power Consultancy Services (I) Ltd 

Project Title: Teesta stage III hydroelectric project (1200 MW) 

Project Proponent: M/s Teesta Urja Limited, New Delhi 

Year of EIA:  2006  

§ EIA Report openly supports the project and shows no objectivity

§ Environment, risk assessment, dam break analysis and Environment Management Plan not included

§ Impact of flash floods; glacial recession and glacial lake outburst floods increased run-off and sedimentation on the project not considered

§ Seismicity related aspects

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inadequately dealt with

§ EIA Report admits that seismicity related aspects were still being studies at the time the EIA Report was submitted

§ Impact on agriculture and muck disposal not properly addressed

HOW SHODDY ARE EIA REPORTS?

CASE STUDY 1

EIA Consultant: RITESProject Title: Pala Maneri Hydro Electric project, UttaranchalProject Proponent: Uttaranchal Jal Vidyut Nigam Ltd.Year of EIA: 2003 and 2005

Key Issues: One of the biggest issues in this project is that the EIA report shared at the time of the public hearing in 2003 was not the same based on which the environment clearance was granted in 2005. The 2003 report was extremely inadequate and incorrect in many ways. To begin with, the 2003 report only listed 5 project impacts, where as the 2005 report added additional impacts including that of tunnelling, vibrations, muck disposal, loss of traditional cremation grounds, damage to village Aungu and so on. The forest area described in the 2003 EIA was 31 ha and the 2005 report had it mentioned has 53 ha. An entire reserve forest area which would be lost because of the construction of the project was not mentioned in the 2003 report available at the time of the public hearing. Apart from this, the EIA consultant has mentioned that interviews were consulted with a list of people mentioned in the EIA report, few of whom were not alive at the time the EIA was being prepared.

References:1) Personal Communication: Ritwick Dutta

CASE STUDY 2

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EIA Consultant: Agricultural Finance Corporation Ltd., Northern Regional Office, New Delhi (H.O Mumbai)) Project Title:  Tipaimukh Hydroelectric Multipurpose ProjectProject Proponent: North East Electric Power Corporation Ltd.,(NEEPCO) Year of EIA:  2004

Key Issues: The project has been widely and strongly objected by the people of Manipur ever since its inception, and the formulation of the initial DPR by Brahmaputra Board in the mid-80s. The main issue with this EIA is that it is considered to be full of false information, suppression of important facts and totally invalid by the people of Manipur. According to an independent expert opinion, the EIA/EMP final report "contains innumerable incorrect data, unverified and superfluous statements, and above all reveals the casual approach on the part of both NEEPCO as well as AFCL towards an important issue." The Public Hearings conducted in Churachandpur and Tamenglong, in Manipur are also subject to writ petitions before the Gauhati High Court challenging their exclusive, militarised conduct and validity of outcomes. The EIA and EMP were fed by data from previous project reports, and there was no field investigation done that was worth its name. The Expert Appraisal Committee, MoEF has considered this project proposal twice already in December 2006 and again in February 2007, and found many serious shortfalls in merit that included data discrepancies such as the number of affected villages, incomplete baseline environmental information, no landslide prone areas information, no soil analysis data, outdated seismic hazards assessment parameters, inaccurate and erroneous bio-diversity and fauna related information, below accepted international standards bio-diversity conservation plan, non-involvement of PAPs and their families in formulating R&R measures, and no benefit-cost analysis, among many others. The EAC rejected the clarifications provided by NEEPCO in February 2007, and has in fact requested NEEPCO (Vide its letter of 12 March 2007) to re-survey the project site to include important baseline environmental information and an acceptable bio-diversity conservation plan according to existing international standards that was omitted. NEEPCO had in its rejected clarification in February 2007 also said that much of the area was inaccessible and has many security related risks. How then was the EIA done?

References:1) Comprehensive Environmental Studies on Tipaimukh Hydro-Electric (Multi-purpose) Project; Final Report, January 2004. Environmental Impact Assessment (Vol I); Agricultural Finance Corporation Ltd., Northern Region Office, New Delhi (H.O. Mumbai) 2) Comprehensive Environmental Studies on Tipaimukh Hydro-Electric (Multi-purpose) Project; Final Report, January 2004. Environmental Management Plan (Vol II); Agricultural Finance Corporation Ltd., Northern Region Office, New Delhi (H.O. Mumbai) 3)Questionnaire for Environemntal Appraisal [for Tipaimukh Hydroelectric (Multipurpose) Project]submitted by NEEPCO as Form "A" Schedule II of the EIA Notification 1994 S.O.60(E), dated 27/01/1994 (incorporating amendments vide S.O. 356(E) dated 4/5/1994, S.O. 318(E) dated 10/4/1997, S.O. 319 dated 10/4/1997, S.O. 73(E) dated 27/1/2000, S.O. 1119(E) dated 13/12/2000, S.O. 737(E) dated 1/8/2001, S.O. 1148(E) dated 21/11/2001, S.O. 632(E) dated 13/06/2002 ) 4) Letter to Mrs. Kavita Devi, General Manager (Plg.) NEEPCO (No. J.12011/63/2006-IA.I; Dated 27.11.2006) from Government of India, Ministry of Environment and Forestsasking clarifications on 31 points 5) Action Committee Against Tipaimukh Project (ACTIP); Memorandum to Shri Man Mohan Singh, Prime Minister of India, 20 November 2006 6) Centre for Organisation Research & Education (CORE) Press Release, November 20, 2006

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7) Letter to Dr. P.G. Sastri, Chairman, Expert Appraisal Committee on River Valley & Hydroelectric Projects, Ministery of Environment and Forests, Government of India; Subject: Tipaimukh Hydroelectric (Multipurpose) Project Manipur: Information regarding recent Public Hearings in Manipur under EIA Notification S.O. 60(E) 1994; dated 10 December 2006 from CORE (ref: EC complaint_TMLph_core101206) 9) Letter to NEEPCO from MoEF Letter No. J.12011/63/2006-IA.I dated 12.03.2007 asking clarifications regarding Tipaimukh 10) Extracts (page 11 & 12) on Tipaimukh from "Summary Record of discussion of the 52nd meeting of the Expert Committee for River Valley and Hydroelectric projects held on 21st and 22nd February, 2007 in Paryavaran Bhavan, New Delhi." 11) Independent Expert, (undated) "Comments on the EIA of TIPAIMUKH Hydro-electric (multipurpose) Project"

CASE STUDY 3

EIA Consultant: Environment Resource Management (ERM)Project Title: 192 MW Allain Duhangan Hydropower Project in Beas river basin in Kulu district in Himachal Pradesh h GroupProject Proponent: Bhilwara GroupYear of EIA: August 2003

Key Issues:

This EIA report is inadequate and ambiguous. Details of carrying capacity, cumulative impacts of dams and other developments across the basin, Assessment of impact on wildlife migration routes, significance of floods, earthquakes and landslides on the project and project impacts on such events, Disaster Management Plan, etc. have not been studied in the EIA Report. Other studies that include the survey of environmental aspects across a year, full social impacts survey, base line study with respect to various ecological aspects, impacts of a number of project components (as the project component details are yet to be finalised), including roads, transmission lines, the number of trees to be felled for the project and downstream impacts were either incomplete or misleading. For instance, with respect to the height of the various dams, the EIA makes ambiguous statements like “likely to be”, “maximum height”, etc, all the heights, miraculously, is shown to be less than 14.5 mts, none shown above the deepest foundation level, which is against international norms.. In addition, it is claimed that the ADP is a run of the river project. In reality, the project diverts the Duhangan river to the Allain river and the diverted Duhangan is not to come back to the original stream, and therefore misleadingly labelled as a run of the river project. Also, the inadequate social impact assessment and lack of comprehensive R&R plan development in consultation with the affected people and the lack of compliance mechanisms to show that the Environment Management Plan will be implemented, characterises this EIA report a highly inadequate and insincere document.

References:1) Letter from Himanshu Thakkar, South Asia Network on Dams, Rivers & People, titled " Environment & Forest clearance and EIA of Allain Duhangan HEP (ADP) in violation of norms and notifications", addressed to: Chairman, Himachal Pradesh Pollution Control Board, Member Secretary, HP PCB, Chairman, HP State Electricity Board, Power Minister, Govt of Himachal Pradesh, Chairman, HP State Environment Impact Assessment and Monitoring Committee, Forest Minister, Himachal Pradesh, Director, Impact Assessment, Ministry of Environment and Forests, Govt of India dated 12.05.2004  

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2), Letter to Director, Impact Assessment, Ministry of Environment and Forests, Govt of India, and copied to Secretary, MoEF, Additional Secretary, MoEF, Joint Secretary, MoEF from Himanshu Thakkar, South Asia Network on Dams, Rivers & People, Titled "Environment & Forest clearance and EIA of Allain Duhangan HEP (ADP) in violation of norms and notifications", dated 04.11.20043) Letter from Affected People of Jagat Sukh and Prini Village, Kullu District, Himachal Pradesh, to the World Bank President, supported by a letter dated Oct 30, '03 from Kulbhushan Upamanyu (Navrachna, HP), Vimal Bhai (MATU) and SANDRP to the World Bank President and Executive Directors, followed by many other letters,dated 23.20.2003 4.) Letter from Ashish Kothari, Kalpavriksh, to the World Bank President and IFC Investment Officer respectively on implementing the recommendations of the Kalpavriksh report, including conducting full Environment and Social Impact Assessment dated 26.08.2004 and 22.09.2004 5) Letter from affected villages to IFC Compliance-Advisor-Ombudsman Office about violations in the Allain Duhangan Project dated 20.09.2004(& Others)

CASE STUDY 4

EIA Consultant: National Environmental Engineering Research Institute (NEERI)Project Title: Comprehensive EIA for of the 1000 MW Karcham Wangtoo HEP, Dist Kinnaur, Himachal PradeshProject Proponent: Jaiprakash GroupYear of EIA: 2003

Key Issues:

This EIA document leaves no doubt that it was indeed written to promote the project and expedite its clearance, rather than assess social and environmental impacts. The objective itself states that “The objective of study is to ensure that the development options under consideration in the KWP (1000 MW) are environmentally sound and sustainable”. This is a misrepresentation of the objective of the EIA study as objective should include full assessment of environmental costs, benefits and impacts of the proposal and its options to decide if the project should go ahead and if so in what form. Another statement that betrays the bias of this document is “It is, therefore, essential that the implementation of the project, which is techno-economically viable, is commenced as early as possible” Another internal contradiction within this document is that while it claims there were “no objections” to the project, it also claims that 26% of the people interviewed opposed the project. “In the background of the comprehensive environmental impact assessment studies, public consultation and information campaign has been organised at the earliest stage of the project to dispel misgivings about the project and to successfully overcome the problem, if any, of non-acceptability”. This precisely is not the role of an EIA agencyIn addition to the inadequate assessment of Catchment Area Treatment, inaccurate reporting on earthquakes and an absence of reporting on Impact of the project on the land slides, soil erosion, settlements, and no disaster management plan, the EIA also notes that the, “The bio-monitoring studies of dam upstream and downstream of Sutlej river will be conducted by HPSSEP&PCB at the cost of Rs 3 lakhs to determine baseline status”.

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Needless to say, these studies should have been done before or during EIA and not afterwards

References:1. Letter from SANDRP to MATU to Chairman and Member Secretary of HP PCB titled "Public Hearing of Karcham Wangtoo HEP on June 18, 2003” dated 12.06.2003 2. Letter " from SANDRP and MATU to Chairman and Member Secretary, HP PCB titled " Public Hearing of Karcham Wangtoo HEP on June 18, 2003 "in principle" forest clearance for the Karcham Wangtoo , dated 30.06.20033. Nov 28, 2003, Letter from Navrachna, MATU and SANDRP, to Chairman, Himachal Pradesh Pollution Control Board, Member Secretary, HPPCB, Director, Env Planning Unit, HP State Council for Science, Technology and Environment, HP Power Minister, HP Forest Minister, Chairman, HPSEB, Director, Impact Assessment, Ministry of Environment and Forests, Delhi, Secretary, Ministry of Environment and Forests, Govt of India titled: " EIA and Public Hearing of Karcham Wangtoo Project on Sutlej river in Kinnaur district in HP" dated 28.11.2003 4. Letter from SANDRP to Secretary, Ministry of Environment and Forests, Delhi, Chairman, HP PCB, Chairman, HP State Environment Impact and Monitoring Committee and copied to many others titled: "Public Hearing of Karcham Wangtoo HEP on November 9, 2004" dated 05.11.2004  5. Aug 5, 2005, Letter from SANDRP to Secretary, Ministry of Environment and Forests, Delhi, Additional Director (Impact Assessment), MoEF, All members of Expert Committee, River Valley Projects, MoEF, Chairman, HP State Environment Impact and Monitoring Committee, Chairman, HPPCB and copy to . Additional Secretary, MoEF, Forest Minister, HP, Power Minister, HP, Chairman, HPSEB, among others about the impending clearance of the Karcham Wangtoo Project dated 05.08.2005

CASE STUDY 5

EIA Consultant: RITES, in association with Scott Wilson Kirkpatrick Consulting Engineers, UKProject Title: Bombay- Pune ExpresswayProject Proponent: Government of Maharashtra, Public Works DepartmentYear of EIA: 1995

Key Issues:The EIA Report of this project completely overlooked the ecological and environmental importance of the Western Ghats and recommended a completely new road in the Western Ghats (which the MoEF realised and suggested the alternative of widening NH4, even though that is as ecologically destructive as well). The EIA report did not account for the frequency of landsides and its impacts, and neither did it address or account for the dumping of debris down the Ghats, thereby affecting the forests. The EIA Report was silent about the socio-economic impacts of the Expressway bypassing the towns of Khopoli and Khandala and therefore affecting the contribution of holiday-makers to the local economy. In addition, the report made no mention of the disruption of the route used by the Dhangars, a nomadic group of tribals who take their sheep every year between the Deccan Plateau and the plains and used NH-4.The EIA Report did not go into or assess the financial feasibility / viability of the project. NGOs, economists and individuals had said that the project is not financially viable. Today that has been proved to be true. The NH-4 is being widened as originally suggested by NGOs, economists and individuals. And now the toll that is proposed to be collected on NH-4 is far higher than the national average and the toll on NH-4 will go to cross-subsidise the cost of maintaining the expressway and its financial recovery.

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References:1) Civil Writ Petition No. 2677 of 2000 (Bombay Environmental Action Group & Anr. v/s Union of India & Ors.) in the Bombay High Court.

CASE STUDY 6

EIA Consultant: M/s EMTRC Consultants Private Ltd, New Delhi.Project Title: Expansion of Steel & Power Plant at Raigarh , JSPLProject Proponent: M/s Jindal Steel & Power Ltd, Raigarh (Chhattisgarh)Year of EIA: 2004

Key Issues:

Considering this EIA was supposed to be about the expansion of an existing project, Stack Emission -gaseous pollutant, Water Consumption, Solid Wastes Data refer only to the proposed expansion of the project and there were no clear linkage to the previous two phases of the project viz. Existing operations (approx 1 million TPA steel products) and capacity under construction. The EIA also claimed that the main air pollution would be due to dust during operation of plant. This is scientifically incorrect. The main air pollution would be due to CO2 which is a Green House Gas (GHG) which would be released due to the combustion of approximately 1.4 million tons of coal burnt in various operations such as blast furnaces, power plants, sinter plant, limestone and dolomite heating. Levels of air pollution were also underplayed, where every unit’s pollution “[would] be” limited to the miraculous figure of 150 mg/m3; with no existing background pollution considered, no calculations shown, yet dust from the simter plant and dust from the blast furnace quantities were unbelievable in quantitative terms. The EIA had also made no overall calculation of the CO2 released into the atmosphere, concentrated in one location. Further, with respect to carbon sequestration, while the EIA assumed that a fully grown tree sequesters ½ kg of carbon per day, 24,824,036 (approximately 25 million) would be needed to sequester carbon from CO2 released by the plant. However, only 338,578 trees were planted and thus the ratio between trees planted and trees needed for carbon sequestration works out to be 1:73 or less than 1.3%. This significant computation had not been done by the EIA Report, which instead limited itself to large absolute figures for trees planted

Reference:

1. Letter from Ramesh Agrawal, Raigarh Jila Bachao Sangharsh Morcha, Raigarh (Chhattisgarh) to Dr. T.S.Vijayaraghavan, Chairman Expert Committee on Industrial Projects, Ministry of Environment & Forests, and CC to Secretary, Ministry of Environment and Forests,New Delhi, Sri G.V.Subrahaniam, Director (Scientific) MoEF, Sri R.K.Garg Vice Chairman, EC(I) MoEF and Dr. B.Sengupta, Member Secretary, Central Pollution Control Board, New Delhi,dated 24.06.2005.

CASE STUDY 7

EIA Consultant: EQMS India Pvt. Ltd.Project Title: Thermal Power Plant of 1200 MW at Jaigad, DistrictRatnagiri, Maharashtra.Project Proponent: JSW Energy Ltd. Mumbai

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Year of EIA: 2006

Key Issues:

The EIA is filled with glaring omissions, factual errors, and deliberately misleading statements. There is no information given in the report regarding the authorship of the EIA report or the study team that conducted the EIA and their qualification and expertise etc. The map of the area showing the location of the Thermal power plant itself is totally wrong, the location shown in the map is in Guhaghar far north of actual location, while the geographical co-ordinates for the location (16o 59' N & 73o 20'E) corresponds to some location near Ratnagiri 37 km south west of the actual location and the distance from the HTL is grossly over-stated (as 2km while it actually is only less than 500 m and is well within CRZ). In addition, the source of Fresh water for the project has not been named in the rapid EIA: As per the rEIA report, the fresh water source identified for the project can supply only (5-6 mld) while the requirement for the project would be more than 7 mld and no information on where the remaining one or two million litres of water would be sourced from. As wind directions are wrongly mentioned and miscalculated the plume dispersion model and the Ground level concentration (GLC) of SOx and NOx that are estimated based on that are totally wrong. Further the GLC calculations are not valid because the study did not take into consideration the topography of area by its own admission because of the inability of the consultant to obtain topographic maps. This is most essential for a realistic estimation of GLCs. In addition, aspects of impact on the fishing community, local water security, and sensitive and endangered species have not been adequately dealt with.

References:

1) Mandar Phanse & Nitin Sukhija (03.03.2007) Power plants spoil coastal paradise. CNN-IBN2) Meena Menon (12.03.2007) Work on port unsettles fisherfolk, The Hindu (http://www.thehindu.com/2007/03/12/stories/2007031203821300.htm)3) Meena Menon(11.03.2007) Plan to set up thermal power plant in Konkan generates heat. The Hindu (http://www.thehindu.com/2007/03/11/stories/2007031104211100.htm4)MoEF (2001) EIA Manual (http://envfor.nic.in/..)5)Coastal Regulation zone notification ,1992 (http://envfor.nic.in/legis/crz/crznew.html)

CASE STUDY 8

EIA Consultant: National Environmental Engineering Research Institute (NEERI)Project Title: Sethusamudram Ship Canal Project (SSCP)Project Proponent: Tuticorin Port Trust.Year of EIA: 2004

Key Issues:

The Economic viability (Technical Feasibility and Economic Analysis, TFEAR) and environmental sustainability (EIA) being assessed by the same agency (NEERI in this case) results in conflict of interest situation and is not good practice.The EIA report for the Sethusamudram project was a Rapid EIA and not a Comprehensive EIA as is required by law for a project of this magnitude. A number of

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experts have found what is claimed to be a comprehensive EIA to actually be a Rapid EIA. One of them, published in a peer-reviewed journal Current Science is particularly critical of the fact that NEERI opted for a rapid EIA. The EIA contains very poor primary data and pointed out and summarized in the DPR itself in section 5.1.3 on page 5-4 which states about the EIA that “primary data collection in respect to the Met-Ocean parameters for the proposed ship channel project was limited”. It also does not fulfill ToR for EIA given it by the Ministry of Surface Transport to execute the EIA. No Risk Analysis/Assessment and Disaster Management Plan was done as part of EIA which is mandatory as per the notification. The need for risk assessment is also pointed by other experts who suggested a multi level approach to monitor the ecosystem and evaluate the risk assessment of the region. The sub surface geo-technical investigations was done only part of the project area namely Adams bridge and not in Palk Bay and Palk Straits. All studies were based on normal weather conditions (winds speed less than 35 km/hr) when the project area is know for its frequency of tropical cyclones. The sedimentation data and crucial latest secondary published literature (esp. in Palk Bay) was not incorporated in the EIA (a fact that was publicly acknowledged by the Director of NEERI). In light of lack of the knowledge base mentioned above the impact on the ecosystems of the Gulf of Mannar and Palk Bay, especially the coral reefs and sea grasses, cannot not studied accurately and in the EIA was not done at all. Oil spills and impacts of tsunami related shipping disasters on this eco-region not studied. Furthermore, the impact of tsunamis on sedimentation flow /regimes, changes in the seabed, oil spills and impacts of tsunami related shipping disasters on this eco-region had not been accounted for while preparing the Detailed Project Report, Techno-Economic Feasibility report or the EIA. This in affect means that the potential impact on the fragile ecosystems of the Gulf of Mannar and Palk Bay, especially the coral reefs had been ignored and not studied as part of the EIA. The Environmental Management Plan (EMP) suggested in the EIA is incomplete. For e.g. It does not contain an environmental monitoring program. This has been also pointed by the DPR again in section 2.5.4 on page 2-12 which states, “The Environment Management Plan reported is well presented but does not cover pre and post project monitoring requirements and mechanism for environmental management.” Doubts on many of these issues about the project were raised just a week prior to the environment clearance by both the Planning Commission as well as the Prime Ministers Office. These issues have also been brought to the notice of the Supreme Court which allowed for a special leave petition to be filed.

References:

1) Ramesh, R. 2004. Critique on the Methodology of NEERI EIA for the Proposed Sethusamudram Ship Canal Project. Doctors for Safer Environment (DOSE), Coimbatore. pp23.2) NEERI. 2004b. Technical Feasibility and Economic Analysis of Proposed Sethusamudram Channel, National Environmental Engineering Research Institute Nagpur, July 2004.3) NEERI. 2004a. Environmental Impact Assessment for Proposed Sethusamudram Ship Channel Project, National Environmental Engineering Research Institute, Nagpur. August 2004.4) Letter from Aarthi Sridhar and Mahalakshmi Parthasarathy to Chairperson, Tamil Nadu Pollution Control Board, regarding concerns regarding the Rapid Environment Impact Assessment report prepared by NEERI on the environmental impacts of the Sethusamudram Ship Canal Project (SSCP), dated 16.09.2004 5) L&T-Ramboll. 2005. Detailed Project Report and Evaluation of EIA Study for Sethusamudram Ship Channel Project. Larson & Toubro –Ramboll Consulting Engineers Limited.6) Sethusamudram Corporation/Ministry of Surface Transport , Terms of Agreement with NEERI: Sethusamudram Ship Canal Project Terms Of Reference, Annex - I Scope for Comprehensive Environment Impact and Ecological Risk Assessment. Available at http://sethusamudram.gov.in/Terms.asp

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7) Kathal, P.K. 2005. Sethusamudram Ship Canal Project: oceanographic/geological and ecological impact on marine life in the Gulf of Mannar and Palk Bay, South-eastern coast of India. Current Science, Vol. 89, No. 7.8) Ramesh, R. 2004a.Critique on the Methodology of NEERI EIA for the Proposed Sethusamudram Ship Canal Project. Doctors for Safer Environment (DOSE), Coimbatore. pp23.9) Ramesh, R. 2006. Sethusamudram Ship Canal Project - Further Inputs, Unpublished.10) PMO note on Sethu canal project evokes no response, Indian Express, 27.03.200511) Ramesh, R. 2005a. Is the Sethusamudram Shipping Canal Project Technically Feasible?, Economic and Political Weekly, 22.01.200512) Sudarshan Rodriguez, Pers. Comm., Marine Conservation Analyst, Chennai.

CASE STUDY 9

EIA Consultant: National Environmental Engineering Research Institute (NEERI), NagpurProject Title: Common Hazardous Waste Disposal Facility at SIPCOT, Gummidipoondi, Tiruvallur District, TamilnaduProject Proponent: State Industries Promotion Corporation of Tamil Nadu (SIPCOT)Year of EIA: January 2005

Key Issues:

In this case the most problematic issue was that the project document that was passed off as an EIA at the Public Hearing was titled “Preliminary Environmental Appraisal.” The document identified the need to conduct an EIA! An EIA report, as outlined in the document titled “Environment Impact Assessment: A Manual” developed by the Impact Assessment Division of the Ministry of Environment & Forests, an EIA requires: Collection of at least one season’s data (Rapid EIA) or several season’s data (Comprehensive EIA); Air Quality data, including details of primary and current data about ambient air quality, meteorological conditions, predictive modeling of emissions of air pollutants, impact zone; noise and water assessment, predictive modeling of impacts including characterization of toxic chemicals etc; assessment of flora, fauna, and project impacts on these; land use, land types, soil characteristics and drainage patterns, socioeconomic environment and health assessment, and risk assessment. However, none of these tests were performed and the Environmental Management Plan specific to project site was also not included. In the details that the report did cover, NEERI observed that the project area has highly permeable sand as overburden, is a potential area for groundwater exploitation, has “very good ground water quality” and is an alternative source of water supply for Chennai in summer. It even admitted that “the proposed landfill facility may not be located at the SIPCOT Industrial Complex, Gummidipoondi.” In the same breath, NEERI proposed to locate the facility at a site that by its own admission was inappropriate. NEERI also admitted that owing to the absence of data about the specific nature of the hazardous wastes, no attempt had been made to predict impacts. In addition, the report relied solely on secondary data. No information was provided as to when the data was generated, and no explanation was offered for the lack of current data in an EIA

References:

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1) Letter from Nityanand Jayaraman to District Collector, Thiruvallur District and others regarding Evaluation of Preliminary Environmental Appraisal of the proposed Common Hazardous Waste Disposal Facility, Gummidipoondi, dated 18,03.20052) Evaluation of Preliminary Environmental Appraisal of the proposed Common Hazardous Waste Disposal Facility at SIPCOT Industrial Complex, Gummidipoondi. By Dr. Mark Chernaik. March 20063) Preliminary Environmental Appraisal of the proposed Common Hazardous Waste Disposal Facility at SIPCOT Industrial Complex, Gummidipoondi. NEERI. January 2005.

CASE STUDY 10

EIA Consultant: Water and Power Consultancy Services Ltd. (WAPCOS)Project Title: Athirappilly Hydro Electric Project (163 MW), Chalakudy River, KeralaProject Proponent: Kerala State Electricity BoardYear of EIA: 2002

Key Issues:

This project was challenged before the Kerala High Court. The court ordered a Public Hearing in 2002 and recommended for study in the new EIA by the Public Hearing (PH) panel. However, the issues raised remained unaddressed in the EIA report prepared by WAPCOS. The report suffered from many omissions and suppression of data, for instance the Options Assessment was not carried out and the EIA also failed to mention the names of the experts who carried out the EIA study. Water Budgeting studies were not carried out as directed by the 2002 panel. Moreover flow data based on which clearance is granted was flawed and the impact of daily change in the flow pattern and its impact on downstream drinking and irrigation schemes had not been addressed. The cumulative impact of six dams upstream of which four dams are inter state diversions was an aspect that has not been accounted for either. The report was also silent about the impact on the 500 Vana Samrakshana Samithi families and 58 Kadar families living in the 7 km impact area. With respect to the dimension of impacts on flora and fauna, the study and impact assessment on fish diversity of a river with one of the highest fish diversity in India itself was incomplete, and its impact on avian diversity and the elephant migratory path had been downplayed.

References :

1) Letter from S.P.Ravi, Secretary, Chalakudy Puzha Samrakshana Samithi to Chairman, Central Water Commission dated 09.12.2003 2) Submission from S.P.Ravi, Secretary, Chalakudy Puzha Samrakshana Samithi to Hon. CEC Member Secretary, , dated 24.02.053) Letter from S.P.Ravi, Secretary, CPSS to Secretary, MoEF, demanding cancellation of Clearance granted on 10th February 2005, dated 30.05.20054) Letter to River Valley Committee requesting not to grant Clearance to violation ridden project from several people in the river valley dated 11-10-2006 5) Letter from S.P.Ravi,Convenor, Chalakudy River Protection Forum to Sri.A.Raja, Hon. Minister of Environment and Forests, dated 04.01.2007

6) Letter from C.G.Madhusoodhanan, Petitioner of Athirappilly case to Sri.A.Raja, Hon. Minister of Environment and Forests, dated 31.01.2007 7) Kerala High Court Judgment on OP No. 3581/2001 dated 17-.0.2001

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8) Kerala High Court Judgement on OP Nos Nos. 9542 , 11254 & 260763 of 23.03.2005

CASE STUDY 11

EIA Consultant: VIMTA LaboratoryProject Title: Utkal Alumina International Limited (UAIL), Kashipur, OrissaProject Proponent: Hindalco (India) and Alcan Aluminium (Canada)Year of EIA: December 2004

Key Issues:

This is a highly problematic EIA report as there were instances of material having been lifted from other EIAs. Take for instance, the Environmental Management Plan of the mine, which presented the EMP of limestone mining. In chapter 5 on Environment Management Plan, the EIA report quoted in a section on Occupational Safety and Health Management - “The main factors of occupational health in limestone mine are fugitive dust and noise” This clearly indicates that the EIA Consultants forgot to replace the word limestone with bauxite and this is reflective of the quality of the entire EIA. Other lapses in the EIA report were that it failed to address the issue of cumulative impact on the Indravati River Basin and its resultant impact on people and habitat dependent on the river. It also overlooked the aspect of the impact on the siltation of the Upper Indravati Reservoir. This reservoir supplies water to the water-scarce Kalahandi district of Orissa. Impact of water withdrawal from the Upper Indravati Reservoir: Upper Indravati Reservoir not only supplies water to Kalahandi district, it also houses a power plant. In the entire EIA report, no mention had been made about the impact of water withdrawal from the reservoir during the lean months on either the power plant or the water availability in the Kalahandi district. With respect to pollution control, there were no measures mentioned for controlling SO2 emissions from calciners, and despite the fact that UAIL’s proposed facility would be a major source of mercury emissions, the EIA for UAIL’s proposed refinery made no mention of mercury. The EIA report also ignored the issue of impact on forests by the proposed mining activity by the company even though the EIA report admitted that 5-reserved forests come under the vicinity of a 10 km radius of the plant site.

References:

1) Letter Submitted to Member Secretary, Orissa Pollution control Board, dated, 14.10.20062) Analysis report of EIA report of UAIL by Centre for science and Environment ( CSE) New Delhi3)   Evaluation of the Rapid EIA of the proposed capacity expansion of bauxite mines from 3.0 to 8.5 MTPA at Baphlimali plateau, Raygada/Kalahandi, Orissa prepaired by Mark chernaik staff scientist, Environment law alliance world wide, USA, October-2006.

CASE STUDY 12

EIA Consultant: Bharat Foundation

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Project Title: Expansion of Talabira –I Coal Mines, Sambalpur District, OrissaProject Proponent: HINDALCOYear of EIA: February 2005

Key Issues:

The Rapid EIA prepared for this project has not analysed environmental impacts with sufficient depth or understanding. The report has not mentioned the increase in the concentration of SOX, CO due to coal fire in the mining site. The chapter on Environment Management Plan does not reflect upon the possible mitigatory measures for SOX, NOX

and CO gas which have significant and serious impacts not only on Human health but also on global warming. Similarly the cumulative impact on the ambient air quality due to cluster of industries in this area has not been mentioned in the report. The report also fails to elaborate upon the impact of fugitive dust on the vegetation, on the fauna and on the population of the surrounding mine areas or health impacts due to increased production The report mentions that excess mine water is pumped to Hirakud reservoir through garland drains and de-silt pits. Yet it does not go into the possible impacts of mining on the ground water of the area. This is an important aspect that has not been covered by the EIA as with increase in the production of the mines it is obvious that discharge of such huge volumes of mine water would increase resulting in increased pollution of Hirakud Reservoir. In addition, the EIA does not account for the villagers who predominantly depend on seasonal activities like Kendu leaf collection, Bidi making, collection of mango fruit (for extraction of juice, pulp and kernels), and collection of broomsticks for which they are mostly dependent upon the nearby forests. The NTFP productivity would be adversely affected as the company directly dumps its mining waste over the Khinda forest.

References:1) Letter Submitted to Member Secretary, Orissa Pollution control Board, dated, 03.01.20062) Letter Submitted to Secretary, Ministry of Environment & Forest, New Delhi, dated 03.01.2006

CASE STUDY 13

EIA Consultant: VIMTA LaboratoryProject Title: Vedanta Aluminum Smelter and Captive Power Plant, Jharsuguda, OrissaProject Proponent: Vedanta Alumina LtdYear of EIA: September 2005

Key Issues:

The company has submitted a fresh EIA report dated Sept 2005, which contains the same information that has been provided in the previous report except certain minor modifications regarding the details of Captive Power Plant (CPP). However, nowhere in the report the cumulative impacts of both the CPP and Smelter plant on the environment been recorded. The town Jharsuguda (major human settlement area nearer to the plant site) is facing acute water problem during summers and the mercury levels shoot up to 500C. With respect to the site location, the EIA report states that the plant site will be located in Bhrukumunda/ Brundmal village. Bheden River is flowing very near to the

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proposed site (200 meters)]. It is a flood prone area and the Bheden River is considered highly unpredictable and is known to cause frequent floods. One of the hamlets of Bhrukumunda, Bhogimal was severely affected due to the flood in 2001 due to which the entire hamlet has relocated itself farther away from the river. The siting criteria manual prepared by the Impact Assessment Division of MOEF mentions that the siting of industries should be at least 500 meters away from flood plains or modified flood plains or by flood control systems, and this guideline has been completely violated. Also, the EIA Report mentions that water from Hirakud reservoir will be drawn at the rate of 2060m3 /hr to fulfill the water requirement for smelter plant but does not go into details of the impact on the Biodiversity of Hirakud reservoir, especially during summer days when the volume of water in the reservoir recedes drastically. Another significant fault of this EIA is that the study was prepared upon the data collected from 1st march to 31st may 2004 which is for a period of 3 months which is totally insufficient for a study of this nature. The time of data collection was made in summer days intentionally, so that the endangered migratory birds will not come into picture. In addition, among the 7 reserve forests around the project site, the study chose a monitoring site with comparatively less species diversity and richness, thus presenting misleading data in the EIA Report

Reference:

1)     Letter Submitted to Member Secretary, Orissa Pollution control Board, dated 09.12.20052)     Letter Submitted to Secretary, Ministry of Environment & Forest, New Delhi, dated 09.12.20053)      Evaluation of The environmental Impact Assessment for the Proposed Alumina Smelter (2,50,000 TPA) Near Jharsuguda, Orissa, Prepaired by Mark Chernaik, staff scienctist, Environment law alliance world wide, USA,

CASE STUDY 14

EIA Consultant: Modular Consultants Private LimitedProject Title: Integrated Sahara Tourism Circuit at Sunderbans, West BengalProject Proponent: Sahara India Tourism Development Corporation LimitedYear of EIA: 2003

Key Issues:

The Project Report and the EIA were both prepared by Modular Consultants Pvt. Ltd. Hence there is no objectivity as EIA Consultant will not say that the project is not recommended on environmental grounds. Thus the EIA recommended the project even though the exact location of two water based hubs was not identified, and therefore impacts on the environment were not studied by the EIA Report. Also, no modeling studies were done to asses the impact of the water based hubs on the water flow pattern, etc. In addition, some of the project sites were home of endangered species, specifically the nesting site of the Olive Ridley turtles. This was completely ignored in the EIA Report. The EIA was also completely silent on the impact of massive water based transport on the fishermen and on fishing. Most importantly, The EIA completely ignored the CRZ notification. The project completely violates the CRZ notification and the approved Coastal Zone Management Plan for West Bengal. The project also proposed development of coastal salt marsh land, mangrove land, dredging, disposal of waste,

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reclamation, drawal of groundwater within CRZ, topographical changes, etc. Sunderbans is CRZ-I. Hence no project can be permitted within 500 m. of the shore.

References:1) BEAG, EQUATIONS &PUBLIC, May 2004. “Resisting the sell-pot of Sunderban:Report of an Investigation Visit to Sunderban Biosphere Reserve”, EQUATIONS, Bangalore CASE STUDY 15

EIA Consultant: WAPCOS Centre for Environment Water & Power Consultancy Services (I) Ltd Project Title: Teesta stage III hydroelectric project (1200 MW) Project Proponent: M/s Teesta Urja Limited, New Delhi Year of EIA:  2006  

Key Issues:

 The language used at the very beginning of the EIA Report itself indicates the inherent bias in favour of the project even before the impacts of the project are laid out. It says; "the implementation of projects in the Teesta basin therefore needs to be taken up on top priority."  The EIA report is supposed to be an objective analysis of the environmental and social impacts of project and is not supposed to advocate the necessity of the project on non- environmental grounds. In addition, there is no environmental risk assessment included in the EIA report. The project area lies in the Eastern Himalayas which is prone to several environmental risks which can not only pose risks to people but also affect the long-term viability of the project, including considerable economic implications. These risks include flash floods; climate change related risks including glacial recession and glacial lake outburst floods (GLOFs), increased run-off and sedimentation. The dam break analysis and disaster management plan have also not been included. The EIA report also does not deal with the impacts of seismicity adequately. The report only speaks of seismicity with respect to the dam structure and does not talk of other environmental risks associated with hydroelectric projects vis seismicity. The Executive Summary even goes on to state that “Necessary studies are being carried out by DEQ, IIT Roorkee to determine and evaluate suitable seismic coefficient. The same will be incorporated in the design of major project structures". If this is so, then it means that the seismicity related studies for the project were yet not complete at the time the EIA was submitted. In addition, the EIA report only states the area and percentage of land in the study area under agriculture but does not give any details whatsoever of the kind of agriculture and the impacts on the same due to the project. The issue of muck disposal has also not been properly dealt with in the report.

References:1) Appeal No.8 of 2006 (Affected Citizens of Teesta Vs. Union of India & Others ) in the National Environment Appellate Authority: