The July 30, 2013 public hearing for Adani’s proposed ship breaking facility is based on the Draft Environmental Impact Assessment (EIA) prepared in May 2013 by Mecon Limited, a Government of India Undertaking under the Union Ministry of Steel. Earlier, the Adani group had entered into an agreement with the Gujarat Maritime Board (GMB) for developing port and related activities at Mundra but its plan to enter the ship-building business did not materialise. Now it is proposing to re-enter the business.
The TWA has been involved in research and advocacy with regard to hazardous waste trade and has been an applicant in the Supreme Court, before Parliamentary Committees and relevant UN bodies. The letter has been written by senior activist Gopal Krishna of the TWA.
Krishna claims, apprehensions were expressed "that the sinking of Panama flagged MV Rak Carrier carrying on board 60,000 tonnes of coal for Adani Enterprise Limited at Mumbai on August 4, 2011 may have been staged to claim insurance money for its cargo of coal on board." He wonders, "The ship sank and caused oil spill. Was it an exercise meant to test waters and the regulatory strength of agencies involved? This may be looked into. The matter with regard to MV Rak is before the National Green Tribunal."
The proposed ship recycling facility will handle ships to recover about 300,000 tonnes per year of various materials. It will be located near the Mundra West Port off Vandh village in Mundra taluka at an aerial distance of about 16 km south-west of Mundra town. The project is within the port limits notified as Special Economic Zone (SEZ). The proposed ship recycling facility measures 40.7432 hectare adjacent to the existing Mundra West Port.
Krishna notes, "Citing massive pollution as a reason, Sachana shipbreaking plots in Jamnagar district, Gujarat, has been closed as per the order dated November 22, 2011 from the Office of Chief Forest Conservator, Gujarat government. The order is specifically meant 'to cancel the plots allotted of Sachana ship braking yard. These plots are in the land of Forest / Marine Sanctuary'."
The order reads: “Because of ship-breaking, harmful objects like arsenic, mercury, asbestos, oil, etc could harm marine life in the long time. This leads to complex problems for protecting and conserving the Marine National Park and Marine sanctuary.”
The activist underlines, "These observations are quite relevant for the proposed ship-breaking operations in the coastal environment of Mundra West Port given the fact that it is admitted that 'at present most of the land is still submerged and only a minor portion is located in the inter-tidal zone'.”
Earlier, Kheti Vikas Sewa Trust and Machimar Adhikar Sangharsh Sangathan (MASS) had sent complaints to Union Ministry of Environment and Forests regarding "severe impact upon environmental safety and integrity in the Mundra Port and SEZ Limited area committed by the Adani company in question." The Ministry constituted a Committee for inspection of the Adani Port and SEZ Ltd., Mundra, Gujarat. The Committee’s terms of reference is relevant in this case as well since by implication it underlines why Adanis' proposed ship breaking facility too should not come up in this ecologically fragile zone.
The committee, led by well-known environmentalist Sunita Narayan, examined the allegations regarding bunding/diversion/blocking of creeks and reclamation etc., and distortion of original High Tide Line (HTL), the HTL submitted by the proponent and HTL of the approved Coastal Zone Management Plan (CZMP), compliance to the conditions of the Environmental Clearance (EC) and Coastal Regulation Zone (CRZ) clearance granted, the destruction of mangroves and leveling of sand dunes, and the likely impacts on agriculture due to ingress of salinity.
Pointing out that these concerns are manifestly pertinent for the proposed ship breaking facility, Krishna says, "It is clear that in a tactical and clever manner the company has taken environmental clearance for its various projects in the proposed region in installments by outwitting the regulatory agencies. This ploy is apparent when one reads in its claim in the Draft EIA report that 'APSEZL had received Environmental and CRZ Clearance for Water Front Development Clearance from Ministry of Environment and Forests, Govt. of India, vide letter no.10-47 / 2008 – IA-III dated 12th January, 2009 and addendum dated 19th January, 2009.'"
Krishna questions the Technical EIA Guidance Manual for Ship breaking prepared for the Union Ministry of Environment and Forests terming it myopic. The manual states, “The economics of the system was very straightforward - the owner receives money for his ship; the breaker receives enough money for his scrap to pay his expenses and make a profit.”
Krishna comments, "This straightforward economics does not include the human and environmental cost of the hazardous ship breaking activity. Adani has been in the shipbreaking business in USA. US is a non-party to Basel Convention unlike India and has adopted a policy to transfer its obsolete ships to countries like India. Its attempts faced legal challenge in the case of SS Norway, SS Independence and Exxon Valdez."
Noting that the beaching method of the Indian sub-continent relies heavily on low labour cost, since it involves very little mechanisation, the activist says, "The beaching method which Adanis propose in Mundra is fatally flawed. The four fatal flaws of the beaching method for ship breaking include: cranes cannot be placed alongside ship, lack of access by emergency vehicles and equipment, no possibility for containment and coastal zone, intertidal zone is environmentally sensitive and managing hazardous wastes in the intertidal zone can never be environmentally sound."
Suggesting that the Adanis' shipbuilding yard will only add to the "colonisation" of Gujarat beaches by foreign shipowners, the activist believes, this type of colonisation has been supported by Nikos Mikelis, head of the Marine Pollution Prevention and Ship Recycling Section of International Maritime Organisation (IMO), who argues that it was "neither logical nor ethical to stop sending ships to South Asia".
Krisha comments, this demonstrates "complete disregard to the fragile coastal environment which has been heavily contaminated and it is crying for remediation. The way Alang beach has been colonized by the foreign ship owners in the same way Mundra too is sought to be handed over to shipping companies from the industrialized countries for dumping their end-of-life ships against the cardinal principal of hazardous waste management."
He further argues, "Permitting free trade in hazardous wastes like end-of-life ships is anti-national, anti-nature and anti-worker. It is well known that waste follows the path of least resistance. Indian regulatory agencies have either failed to see through the linguistic corruption being indulged in by foreign ship owning countries and companies to bulldoze hazardous wastes in the name of recycling or they are colluding with IMO which is undermining UN’s Basel Convention on Transboundary Movement of Hazardous Wastes and Their Disposal hard earned by developing countries like India at the behest of the traditional enemies of this Convention."
"The steel scrap generated from ship recycling contributes to around 1% of India’s domestic steel demand and is primarily a source of raw material for the re-rolling mills which convert this scrap to mainly produce rods and bars which find application in construction industry. Ship breaking activities contribute to total scrap steel supply and a significant number of re-rolling mills are increasingly dependent on them. This has also given birth to the issue of radioactive steel because of which the secondary steel products from India are globally under scrutiny", he adds.
A copy of the TWA's letter has been sent, among others, to Prime Minister Manmohan Singh, Union minister of steel Beni Prasad Verma, Union minister of commerce and industry Anand Sharma, Union minister of shipping G K Vasan, Union defence minister AK Antony, and Union minister of environment and forests Jayanthi Natarajan.
Pointing out that these concerns are manifestly pertinent for the proposed ship breaking facility, Krishna says, "It is clear that in a tactical and clever manner the company has taken environmental clearance for its various projects in the proposed region in installments by outwitting the regulatory agencies. This ploy is apparent when one reads in its claim in the Draft EIA report that 'APSEZL had received Environmental and CRZ Clearance for Water Front Development Clearance from Ministry of Environment and Forests, Govt. of India, vide letter no.10-47 / 2008 – IA-III dated 12th January, 2009 and addendum dated 19th January, 2009.'"
Krishna questions the Technical EIA Guidance Manual for Ship breaking prepared for the Union Ministry of Environment and Forests terming it myopic. The manual states, “The economics of the system was very straightforward - the owner receives money for his ship; the breaker receives enough money for his scrap to pay his expenses and make a profit.”
Krishna comments, "This straightforward economics does not include the human and environmental cost of the hazardous ship breaking activity. Adani has been in the shipbreaking business in USA. US is a non-party to Basel Convention unlike India and has adopted a policy to transfer its obsolete ships to countries like India. Its attempts faced legal challenge in the case of SS Norway, SS Independence and Exxon Valdez."
Noting that the beaching method of the Indian sub-continent relies heavily on low labour cost, since it involves very little mechanisation, the activist says, "The beaching method which Adanis propose in Mundra is fatally flawed. The four fatal flaws of the beaching method for ship breaking include: cranes cannot be placed alongside ship, lack of access by emergency vehicles and equipment, no possibility for containment and coastal zone, intertidal zone is environmentally sensitive and managing hazardous wastes in the intertidal zone can never be environmentally sound."
Suggesting that the Adanis' shipbuilding yard will only add to the "colonisation" of Gujarat beaches by foreign shipowners, the activist believes, this type of colonisation has been supported by Nikos Mikelis, head of the Marine Pollution Prevention and Ship Recycling Section of International Maritime Organisation (IMO), who argues that it was "neither logical nor ethical to stop sending ships to South Asia".
Krisha comments, this demonstrates "complete disregard to the fragile coastal environment which has been heavily contaminated and it is crying for remediation. The way Alang beach has been colonized by the foreign ship owners in the same way Mundra too is sought to be handed over to shipping companies from the industrialized countries for dumping their end-of-life ships against the cardinal principal of hazardous waste management."
He further argues, "Permitting free trade in hazardous wastes like end-of-life ships is anti-national, anti-nature and anti-worker. It is well known that waste follows the path of least resistance. Indian regulatory agencies have either failed to see through the linguistic corruption being indulged in by foreign ship owning countries and companies to bulldoze hazardous wastes in the name of recycling or they are colluding with IMO which is undermining UN’s Basel Convention on Transboundary Movement of Hazardous Wastes and Their Disposal hard earned by developing countries like India at the behest of the traditional enemies of this Convention."
"The steel scrap generated from ship recycling contributes to around 1% of India’s domestic steel demand and is primarily a source of raw material for the re-rolling mills which convert this scrap to mainly produce rods and bars which find application in construction industry. Ship breaking activities contribute to total scrap steel supply and a significant number of re-rolling mills are increasingly dependent on them. This has also given birth to the issue of radioactive steel because of which the secondary steel products from India are globally under scrutiny", he adds.
A copy of the TWA's letter has been sent, among others, to Prime Minister Manmohan Singh, Union minister of steel Beni Prasad Verma, Union minister of commerce and industry Anand Sharma, Union minister of shipping G K Vasan, Union defence minister AK Antony, and Union minister of environment and forests Jayanthi Natarajan.
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