Environmental public hearing for Dholera SIR "illegal" as it fails to address issues of climate change, say activists

By A Representative
In a letter to the Union secretary, Ministry of Environment and Forests (MEoF), two senior environmental activists, Rohit Prajapati and Krishnakant of the Paryavaran Suraksha Samiti, Vadodara, have said that the environmental public hearing (EPH), on January 3, for the proposed special investment region (SIR) in Dholera region, situated south of Ahmedabad, “is illegal” and “anti-constitutional”, as it has failed to take into account issues of climate change, which will take place two to three decades from now, when the SIR will develop.
Dholera SIR has been envisaged on around 900 sq km of land, and is planned as a modern industrial township, by acquiring arable and non-arable land, 43 per cent of which belongs to the government, hence is part of common village property.
The activists have said, “Dholera SIR project’s substantial part -- phase III comprising 27% of the planned development -- is proposed to start after 20 years and may be completed after 30 years as mentioned by the promoters. The consultant has completely ignored the hard reality of climate change in the environmental impact assessment (EIA) for the project which will come up after 20 years. We want to know if there is any precedence of EIA being sought for such a project in the country before and how it was processed.”
They claimed, the consultants – Senes Consultants India Ltd – “do not have any experience and expertise to prepare such EIA”.
The activists have insisted, “The project is not single industry specific or even on the lines of the established industrial cluster and instead is an ambitious project that seeks to combine industries of different nature that will also have residential and commercial infrastructure build to support it.”
A copy of the letter has been sent to the chairman, Gujarat Pollution Control Board, and the chairman/ collector, Environment Public Hearing Committee of Ahmedabad district.
The activists say, “In the EPH for the Dholera SIR project’s substantial part of consent is sought from the present generation of villagers for a project that is envisioned to be completed after 20 years. In the process it overlooks completely the potential future stakeholders, the young generation. How will the developers take consent of the very young (now below 5 years and also below 18 years who will grow to be the decisive stake holders later) and the unborn? This is unconstitutional and violates the basic fundamental rights given under the Constitution of India.”
Then, the activists, say, “as per the information available presently there is no clarity on the kind of industries, their specifics like raw material, products, by-products, manufacturing process, its pollution load on the people, their livelihood, environment etc for the EIA hearing to take place as per the EIA notification. Such details and specifications should be provided well in advance.” Since this is not the case, the EPH stands “null and void”. After all, “it is difficult to assess the possible pollution load and other environmental impact due to lack of required essential details.
In fact, the activists point out, the EIA for the project is “based on the 2001 data instead of the latest census data available of 2011.” They underlined, “The updates could have been included as the EIA hearing is being held in 2014. We want to know why updated data has not been used for projections and its impact.” Then, as 43% of the land to be used for the project is government land, which is largely used as community resources for common use, “common resources and cannot give consent to use this land without consulting people whose life and livelihood will be affected by it.”
Coming the technical issues of the EIA report prepared by the consultants, the activists say, “There are serious discrepancies in the land and coastline details provided in the EIA hearing which can be easily ascertained. For instance, the water level as per the coastal regulatory zone (CRZ) norms shown is at variance with ground reality as that region which is depicted as land is actually the village and land submerged under sea long back. We demand that the EPH committee should visit the area with the people to verify the facts.”
They wonder, “How these discrepancies are not being taken into account and who should be held responsible for misleading with such blatant factual inaccuracies? Also, how can EIA be deemed legal if it is based on factual inaccuracies and misleading information?”
Then, the activists say, “The EIA stands incomplete and in violation of prescribed terms of reference (TOR) for EIA report.” Thus, TOR No 3 specifically asks to ‘examine the details of land use around 10 km radius of the project site. Analysis should be made based on the latest satellite imagery for land use with raw images.’ The explanation provided for TOR No 3 in chapter 4, section 4.4 and chapter 2, section 2.3, has only the images of the SIR area and not the surrounding 10 km. Details and analysis of the 10 km radius area is missing. It appears that this is deliberate”.

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