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Letter to Prakash Javdekar, minister for Environment, Forests & Climate Change, Government of India, by Rohit Prajapati, Girish Patel and Himanshu Thakkar, seeking detailed environmental scrutiny of the Statue of Unity Project planned inside Narmada River, 3.2 Kms downstream of Sardar Sarovar Dam and Shoolpaneshwar Sanctuary:
This is to once again remind you of our letter dated November 7, 2013 and our reminder dated February 5, 2014 sent to the Secretary of MoEF and copy to the concerned authorities of Gujarat Government. In these letters we had called your attention to glaring gaps in meeting environmental, social and safeguard norms in the ‘Statue of Unity Project’ planned inside Narmada River, 3.2 kms downstream of Sardar Sarovar Dam and Shoolpaneshwar Sanctuary.
Till date, we have received no response from your office on issue that concerns statutory social and environmental safeguards. We had sought your authority to stop all activities related to this project in absence of necessary fulfilment of statutory requirements. Instead, it appears now following some discussion between Government of Gujarat and Union of India, they might have taken the decision that the ‘Statue of Unity Project’ does not require environment clearance from the concerned authorities, which is reflected in recent budget of Government of Gujarat and Union of India.
Surprisingly and shockingly, the Government of Gujarat had allocated Rs. 500 crores in the 2014-2015 budget and the Government of India also had allocated Rs. 200 crores in the 2014-2015 budget for the ‘Statue of Unity Project’ by presuming that the ‘Statue of Unity Project’ does not requires environment clearance from the concerned authorities.
Having not received any response from the authorities, we were forced to file RTI applications to find out from the Government of Gujarat about environment safeguards fulfilled for the ‘Statue of Unity Project’. The reply which was expected from the Gujarat Government, instead came from the Sardar Sarovar Narmada Nigam Limited (SSNNL) to our RTI application dated 3 June 2014. Similar RTI application dated June 3, 2014 was sent to office of the Chief Minister of Gujarat and Sardar Vallabhbhai Patel Rashtriya Ekta Trust. The PIO of Chief Minister of Gujarat forwarded the application to SSNNL and till date there is no response from the Sardar Vallabhbhai Patel Rashtriya Ekta Trust. The response we received from SSNNL on July 12, 2014 to the RTI application is tabulated here:
Surprisingly, the office of the Chief Minister of Gujarat had no idea about the legality of the ‘Statue of Unity Project’. That is why they have not categorically responded to any of the issues raised in our letter dated 7 November 2013, instead they directed the Principal Secretary of Departments of Forest and Environment as well as the Additional Principal Secretary of Narmada, Water Resources, Water supply and Kalpsar Department of Government of Gujarat to reply to our queries. Till date, we have not received any response from these departments. Having laid the foundation stone for this ambitious project, it was expected from the Chief Minister of Gujarat to be abreast with all the details the ‘Statue of Unity Project’.
The Sardar Vallabhbhai Patel Rashtriya Ekta Trust kept quite on the issue for the best reasons known to them and the Sardar Sarovar Narmada Nigam Limited which says that “Environment Clearance is not required.” The SSNNL had no idea about our RTI question number 6 (Copies of minutes of all the meetings in which the decision for the ‘Statue of Unity Project’ was taken.) & 7 (Copies of all the decisions, resolutions, notifications and letters issued for the ‘Statue of Unity Project’.) and that is why they might have forwarded RTI to the PIO and the Secretary (Narmada), Narmada, Water Resources, Water Supply & Kalpsar Department, 9th Block, 2nd Floor, Sachivalaya, Gandhinagar. But till date, we have not received any response from the PIO and the Secretary (Narmada), Narmada, Water Resources, Water Supply & Kalpsar Department.
This adds more and more confusion about the ‘Statue of Unity Project’.
Our earlier letters asks for the detailed environmental scrutiny of project called ‘Statue of Unity’ from the Ministry of Environment, Forests & Climate Change but instead ministry had chosen to keep quite on the crucial issue raised by us.
We are once again summarising our objection about the ‘Statue of Unity Project’.
The work on a project that proposes to build the world’s highest statue in the form of ‘Statue of Unity’ near Sardar Sarovar Dam in the river downstream from the dam, just 3.2 km from the Shoolpaneshwar Sanctuary, in eco-sensitive zone and involving massive infrastructure has started work without legally mandatory environment clearance, environment and social impact assessment or any public consultation process.
This is clearly illegal, in violation of the Environment Protection Act, 1986 and EIA notification of September 2006 and a number of NGT and Court orders about such massive kind of construction on the riverbed. On 31 October 2013, the foundation stone was laid for the project amidst huge fanfare and media attention. Tenders have also been floated. Even the work for the Garudeshwar weir, proposed about 12 km downstream of the Sardar Sarovar Dam, began without any social or environmental impact assessment, public consultation and environmental clearance from the Environmental Sub Group (ESG) of Narmada Control Authority’s (NCA).
The website http://www.statueofunity.in/ clearly state the purpose of tourism and involvement of the ‘Sardar Vallabhbhai Patel Rashtriya Ekta Trust’ (SVPRET) to build ‘Statue of Unity’, 3.2 km downstream of the Sardar Sarovar Dam inside the Narmada River on an islet called Sadhu Bet.
The website (http://www.statueofunity.in/execution.html#sthash.N9z6EHIu.dpuf)says:
“A 13 km. long water body (pond) will create an excellent tourist spot with available infrastructure on both the banks.
The Statue of Unity is planned to be erected in the river bed on downstream of the main dam in the Garudeshwar Weir pond. A permanent standing water pool in and around the Statue of Unity will be created by Garudeshwar Weir, which will enable boating activity around the statue.”
The estimated cost of the project is more than Rs. 2,500/- corers (Rs 2063 crores is the cost of “DESIGN, ENGINEERING, PROCUREMENT CONSTRUCTION, OPERATION AND MAINTENANCE OF THE STATUE OF UNITY D/S of Sardar Sarovar Dam, Village Kevadia Ta. Nandod, District of Narmada Gujarat State, India” as per tender notice, see: (http://www.statueofunity.in/tendernotice.html). The Government of Gujarat website (http://www.statueofunity.in/) clearly state that “A monument, that will not just be a mute memorial like the rest, but a fully functional, purpose-serving tribute that will boost tourism and facilitate development in the surrounding tribal areas.” and will involve huge infrastructure as described on the official website.
The key issues that beg immediate scrutiny are as follows:
(1) The project clearly needs environment clearance under the EIA notification of September 2006, but has not applied for or obtained the clearance at any stage.
(2) The Shoolpaneshwar Sanctuary boundary is touching the Sardar Sarovar Reservoir (as a part of the Environmental Protection measures of the Sardar Sarovar Project, the earlier Dhumkal Sloth Bear Sanctuary was extended to meet the reservoir boundaries and is called Shoolpaneshwar Sanctuary.) Since the statute is only 3.2 kms from the Sardar Sarovar Dam, it is certainly near by Shoolpaneshwar Sanctuary.
(3) The Project involves construction on the river bed and inside the proposed reservoir, close to sanctuary in eco-sensitive zone, and hence will have serious impacts on the ecology and environment. Hence, and EIA and EC is crucial.
(4) The project will affect the downstream river, its biodiversity, people and livelihoods and other related aspects.
(5) A comprehensive assessment of the environmental and social impacts of the ‘Statue of Unity’ and its contribution to the cumulative impact of all the projects and activities in the area has not been done.
(6) The project also needs public consultation, but none has happened so far.
(7) During the construction of the Sardar Sarovar dam due to hard rock digging, the seismic area already carries the burden of artificial activity in the bed rock and added load in what is deemed geologically fault line area. Public reports on geotechnical and geological studies on the proposed site have raised issues of structural stability as well as safety. This cannot be taken casually by authorities. The seismic hazard analysis claimed to have been done by the Gujarat Government’s in-house “Institute of Seismological Research” (http://www.statueofunity.in/execution.html#sthash.jEBrofSN.dpuf) or the Geological and Geotechnical investigation commissioned to another government institute WAPCOS cannot be considered credible unless peer reviewed and put in public domain.
In view of the above facts on record, we demand that:Direct the Government of Gujarat to submit application for environment clearance and till that is obtained, not to do any work related to the project.
Direct the Government of Gujarat to immediately stop planned project called ‘Statue of Unity’ and direct them to stop all other activities related to the ‘Statue of Unity’.
Declare the action – of the foundation stone installation on 31 October 2013 for the project called ‘Statue of Unity’ – of the Chief Minister of Gujarat State as illegal, in violation of the EIA notification of September 2006 and the Environment Protection Act, 1986.
We will look forward to your urgent action and also point wise response.
This is to once again remind you of our letter dated November 7, 2013 and our reminder dated February 5, 2014 sent to the Secretary of MoEF and copy to the concerned authorities of Gujarat Government. In these letters we had called your attention to glaring gaps in meeting environmental, social and safeguard norms in the ‘Statue of Unity Project’ planned inside Narmada River, 3.2 kms downstream of Sardar Sarovar Dam and Shoolpaneshwar Sanctuary.
Till date, we have received no response from your office on issue that concerns statutory social and environmental safeguards. We had sought your authority to stop all activities related to this project in absence of necessary fulfilment of statutory requirements. Instead, it appears now following some discussion between Government of Gujarat and Union of India, they might have taken the decision that the ‘Statue of Unity Project’ does not require environment clearance from the concerned authorities, which is reflected in recent budget of Government of Gujarat and Union of India.
Surprisingly and shockingly, the Government of Gujarat had allocated Rs. 500 crores in the 2014-2015 budget and the Government of India also had allocated Rs. 200 crores in the 2014-2015 budget for the ‘Statue of Unity Project’ by presuming that the ‘Statue of Unity Project’ does not requires environment clearance from the concerned authorities.
Having not received any response from the authorities, we were forced to file RTI applications to find out from the Government of Gujarat about environment safeguards fulfilled for the ‘Statue of Unity Project’. The reply which was expected from the Gujarat Government, instead came from the Sardar Sarovar Narmada Nigam Limited (SSNNL) to our RTI application dated 3 June 2014. Similar RTI application dated June 3, 2014 was sent to office of the Chief Minister of Gujarat and Sardar Vallabhbhai Patel Rashtriya Ekta Trust. The PIO of Chief Minister of Gujarat forwarded the application to SSNNL and till date there is no response from the Sardar Vallabhbhai Patel Rashtriya Ekta Trust. The response we received from SSNNL on July 12, 2014 to the RTI application is tabulated here:
The Sardar Vallabhbhai Patel Rashtriya Ekta Trust kept quite on the issue for the best reasons known to them and the Sardar Sarovar Narmada Nigam Limited which says that “Environment Clearance is not required.” The SSNNL had no idea about our RTI question number 6 (Copies of minutes of all the meetings in which the decision for the ‘Statue of Unity Project’ was taken.) & 7 (Copies of all the decisions, resolutions, notifications and letters issued for the ‘Statue of Unity Project’.) and that is why they might have forwarded RTI to the PIO and the Secretary (Narmada), Narmada, Water Resources, Water Supply & Kalpsar Department, 9th Block, 2nd Floor, Sachivalaya, Gandhinagar. But till date, we have not received any response from the PIO and the Secretary (Narmada), Narmada, Water Resources, Water Supply & Kalpsar Department.
This adds more and more confusion about the ‘Statue of Unity Project’.
Our earlier letters asks for the detailed environmental scrutiny of project called ‘Statue of Unity’ from the Ministry of Environment, Forests & Climate Change but instead ministry had chosen to keep quite on the crucial issue raised by us.
We are once again summarising our objection about the ‘Statue of Unity Project’.
The work on a project that proposes to build the world’s highest statue in the form of ‘Statue of Unity’ near Sardar Sarovar Dam in the river downstream from the dam, just 3.2 km from the Shoolpaneshwar Sanctuary, in eco-sensitive zone and involving massive infrastructure has started work without legally mandatory environment clearance, environment and social impact assessment or any public consultation process.
This is clearly illegal, in violation of the Environment Protection Act, 1986 and EIA notification of September 2006 and a number of NGT and Court orders about such massive kind of construction on the riverbed. On 31 October 2013, the foundation stone was laid for the project amidst huge fanfare and media attention. Tenders have also been floated. Even the work for the Garudeshwar weir, proposed about 12 km downstream of the Sardar Sarovar Dam, began without any social or environmental impact assessment, public consultation and environmental clearance from the Environmental Sub Group (ESG) of Narmada Control Authority’s (NCA).
The website http://www.statueofunity.in/ clearly state the purpose of tourism and involvement of the ‘Sardar Vallabhbhai Patel Rashtriya Ekta Trust’ (SVPRET) to build ‘Statue of Unity’, 3.2 km downstream of the Sardar Sarovar Dam inside the Narmada River on an islet called Sadhu Bet.
The website (http://www.statueofunity.in/execution.html#sthash.N9z6EHIu.dpuf)says:
“A 13 km. long water body (pond) will create an excellent tourist spot with available infrastructure on both the banks.
The Statue of Unity is planned to be erected in the river bed on downstream of the main dam in the Garudeshwar Weir pond. A permanent standing water pool in and around the Statue of Unity will be created by Garudeshwar Weir, which will enable boating activity around the statue.”
The estimated cost of the project is more than Rs. 2,500/- corers (Rs 2063 crores is the cost of “DESIGN, ENGINEERING, PROCUREMENT CONSTRUCTION, OPERATION AND MAINTENANCE OF THE STATUE OF UNITY D/S of Sardar Sarovar Dam, Village Kevadia Ta. Nandod, District of Narmada Gujarat State, India” as per tender notice, see: (http://www.statueofunity.in/tendernotice.html). The Government of Gujarat website (http://www.statueofunity.in/) clearly state that “A monument, that will not just be a mute memorial like the rest, but a fully functional, purpose-serving tribute that will boost tourism and facilitate development in the surrounding tribal areas.” and will involve huge infrastructure as described on the official website.
The key issues that beg immediate scrutiny are as follows:
(1) The project clearly needs environment clearance under the EIA notification of September 2006, but has not applied for or obtained the clearance at any stage.
(2) The Shoolpaneshwar Sanctuary boundary is touching the Sardar Sarovar Reservoir (as a part of the Environmental Protection measures of the Sardar Sarovar Project, the earlier Dhumkal Sloth Bear Sanctuary was extended to meet the reservoir boundaries and is called Shoolpaneshwar Sanctuary.) Since the statute is only 3.2 kms from the Sardar Sarovar Dam, it is certainly near by Shoolpaneshwar Sanctuary.
(3) The Project involves construction on the river bed and inside the proposed reservoir, close to sanctuary in eco-sensitive zone, and hence will have serious impacts on the ecology and environment. Hence, and EIA and EC is crucial.
(4) The project will affect the downstream river, its biodiversity, people and livelihoods and other related aspects.
(5) A comprehensive assessment of the environmental and social impacts of the ‘Statue of Unity’ and its contribution to the cumulative impact of all the projects and activities in the area has not been done.
(6) The project also needs public consultation, but none has happened so far.
(7) During the construction of the Sardar Sarovar dam due to hard rock digging, the seismic area already carries the burden of artificial activity in the bed rock and added load in what is deemed geologically fault line area. Public reports on geotechnical and geological studies on the proposed site have raised issues of structural stability as well as safety. This cannot be taken casually by authorities. The seismic hazard analysis claimed to have been done by the Gujarat Government’s in-house “Institute of Seismological Research” (http://www.statueofunity.in/execution.html#sthash.jEBrofSN.dpuf) or the Geological and Geotechnical investigation commissioned to another government institute WAPCOS cannot be considered credible unless peer reviewed and put in public domain.
In view of the above facts on record, we demand that:Direct the Government of Gujarat to submit application for environment clearance and till that is obtained, not to do any work related to the project.
Direct the Government of Gujarat to immediately stop planned project called ‘Statue of Unity’ and direct them to stop all other activities related to the ‘Statue of Unity’.
Declare the action – of the foundation stone installation on 31 October 2013 for the project called ‘Statue of Unity’ – of the Chief Minister of Gujarat State as illegal, in violation of the EIA notification of September 2006 and the Environment Protection Act, 1986.
We will look forward to your urgent action and also point wise response.
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