Tuesday, 16 May 2017

Open washing of mining barges in Mandovi as Captain of Ports turns blind eye



This mining barge bearing number M V Mandovi PNJ 614 is captured on camera at 11.40 am today May 16, 2017 at Old Goa. The speeding barge is being openly washed in the middle of Mandovi by two people and third one supervises. One is forced to ponder was to why Captain of Ports is overlooking the erring barges? Why CoP is relaxed on this count? Earlier on April 18, 2017 another barge F SHARAD PNJ 222was caught on camera doing similar washing activity in Mandovi. You may visit the links here. 

Why affairs has gone so sloppy at Captain of Ports? Is mining companies taken control of Captain of Ports so that he is forced to maintain silence? Mining industry has looted and plundered Goa for past 60 years. Shah commission gave us some glimpse of the way it was done. Now all we need is immediate halt to molestation of Goa rivers by mining industry through their barges.Or did captain of Ports authorized open washing washing of barges in Rivers of Goa?  

Thursday, 11 May 2017

BMM objections to Jindal's coal handling at MPT

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



Thursday, 4 May 2017

Shocking disappearance of Zuari coast fishermen from WAPCOS EIA to MPT

Date: 28th April 2017
To,
Member Secretary,
Goa State Pollution Control Board,
Panjim, Goa

Subject: Objections to EIA on redevelopment of berth 8, 9 and Barge berth at MPT
Sir,

This is to bring to your notice that above mentioned Environment Impact Assessment (EIA) has totally ignored existence of fishing villages and fish landing stations on the Zuari river bank. Villages such as Madkai, Aggasaim, Siridao, Bambolim, Nauxim, Cacra, Odxel, Dona Paula and Caranzalem are totally missing in EIA even though they are located within 10 kms radius from MPT site of proposed re-development of berth 8, 9 and Barge berth.

Sir, we have an apprehension that this has been deliberately done by WAPCOS at the instance of MPT.  We strongly oppose the omission fishing villagers and fishermen from the above mentioned EIA. This is a great fraud on the part of MPT and the Government of India on Goa.

We also protest hiding of the key information of this project in the above cited EIA that all this has been done for the benefit of Vedanta owned Goa Sea Port Pvt Ltd. Vedanta Barges are already clashing with fishermen in Zuari and Mandovi, and Goa Fisheries department has served warning letters to several organizations of Fishermen all over Goa at the instance of Vedanta.

This project we apprehend will create a situation where in fishing in Goa’s rivers would be impossible. This situation is very grave considering that simultaneously Government of India has gone ahead and declared six rivers of Goa as National Highways.

Barges and existing shipyards along Goa’s rivers and particularly in Zuari river has already caused extensive damage. We here re-produce an extract from an exclusive interview of past Chairman of MPT Cyril George to Goa based newspaper named Herald 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.

Sir, When the Chairman of MPT itself speaks out the truth of barge transportation in public domain, how can MoEF grant them Environmental Clearance? Further we want to state that the Zuari river bay is within the Jurisdiction of MPT from May 24, 2000 and Chairman Cyril George’s above findings does not figure at all in above draft EIA. EIA does not share any light as to what measures MPT has taken to stop health hazards, environmental hazards and pollution caused by barges from the time its Chairman Cyril George spoke about it in public on 17/06/2015. Central Government issued gazette notification issued by Ministry of Surface Transport (Department of Shipping), (Port Wing) on May 24, 2000 declaring MPT jurisdiction over Zuari river and its coast covering Cacra, Nauxim, Bambolim, Odxel, Dona Paula, Siridao, Sancoale and Cortalim Coast signed by:
“On the East – All the waters of River Zuari, West of Agassaim – Cortalim Ferry (Excluding the ferry and the landing stages)”.
The Gazette of India (Extraordinary), Part II – Section 3 – sub – section (i) signed by K.V.Rao, Jt.Secy
Due to the above glaring fallacies in the EIA itself, EC must be rejected by MoEF. However in case EC is granted by MoEF then it will be further confirmation of Goa Chief Minister Manohar Parrikar’s statement carried widely in various newspapers by PTI 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.

Thanking you,

Yours sincerely,
       Sd/-
Maggie Silveira
President

Goa Unit

Arabian Sea Capital dredging at MPT reflects India's colonial mindset towards Goa

Date: 29th April 2017

To,
Member Secretary,
Goa State Pollution Control Board,
Panjim, Goa.

Subject:  Objections to Capital Deepening of Navigation Chennel at Mormugao Port Trust for Cape size vessels
Sir,
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.
Cyril George, MPT Chairman in an exclusive interview to Navin Jha in Herald, Panjim dated 17th June 2015.
The undersigned wish to state as under:

1.      We write this letter in the 199th year of the Bhima Koregaon revolt wherein the rule of Peshwayee was destroyed and slavery of the natives of India ended at the outskirts of Pune. Governments of India’s plans for Mormugao Port Trust are directed towards re-initiating of Peshwayee rule in India and we are left with only one option – to object. And we do object here. Kindly take note:
2.      On page 1-1 of the above cited EIA it is mentioned “Mormugao Port is a Major Port on the west coast of India and has completed 125 years of glorious service to the nation’s maritime trade.”  125 years ago Mormugao Port (MPT) Trust set up by collaboration between British and Portuguese Colonialism. From its inception in 1885 till 19 December 1961 MPT was operating in colonial context directly under Portuguese rule. EIA study has hidden this fact. Then in 1961 as per records of the USSR vetoed UN resolution of December 18, 1961 India invaded Goa. Later on Supreme Court of India confirmed this status in Gosalia mining case where in it was held that India annexed Goa by Conquest. Claims of MPT of glorious service to nation’s maritime trade are anti-national and amounts to glorifying prevailing colonial system. MPT carries forward the Colonial Heritage. MPT was born in the womb of Colonialism and flourished as colonial enterprise irrespective of which country it has served with glory.
3.      On page 1-2 it is stated “MPT presently imports about 7 million tons of coal. MPT has 2 dedicated coal berths which has a combined capacity of about 12 million tons per annum. 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.”  This shows that Goa is only used as corridor for coal transportation at the enormous risk of Public Health and environmental hazards. For past decade and a half there are constant voices of protest against coal pollution in Vasco city. This fact is hidden from this EIA.
4.      On Page 1-4 it is stated “The existing depth of the outer channel is 14.40 m and inner channel is 14.10 m. A fully loaded Panamax vessel can be handled under these conditions by taking advantage of tide. The proposal is to deepen the outer channel to -19.80 m and inner channel to -19.50 m. This will facilitate navigation of Capesize vessels at any state of tide.” Mormugao Port is a natural harbor this dredging will create enormous ecological hazard and must be avoided. Ecological damage to bio-diversity is confirmed in the study conducted by committee appointed for this purpose by National Green Tribunal (NGT). Further more dredging carried on by MPT has been stayed by NGT after terming the MOEF Environmental clearance without Public consultation “as illegal, arbitrary and violation of environmental notification of 2006.”
5.      Further it is stated on the same page 1-4 “MoEF&CC has accorded the Environmental Clearance to M/s Mormugao Port Trust for the above mentioned project vide letter 10-23/2014 dated 9 th February, 2015. However, Hon'ble NGT, Pune Bench vide order dated 2nd September, 2016 has quashed and set aside the EC letter dated 9th February, 2016.” Politically the decision of MOEF to grant permission for capital dredging without public consultation reflects colonial mindset of the Government of India towards Goa.
6.      It is further stated on page 1-5 “The total quantity to be dredged was estimated to be about 15.40 million cum. Most of the dredging work will be undertaken with a Trailer Suction Hopper Dredger (TSHD). A Cutter Suction Dredger (CSD) will also be deployed for hard material and weathered rock if encountered. Out of which about 55% work has been completed in the year 2015. Hence, remaining quantity of dredged material will be about 7 mm3.”  This confirms colonial mindset of Government of India towards Goa; 55% of work completed which is described by NGT as illegal, arbitrary and violation of 2006 notification. Those responsible for this at MPT and MoEF must be criminally booked and prosecuted.
7.      On Page 1-5 it is stated “The Study Area for the EIA Study shall be the area within 10 km radius of the proposed navigation channel at the Centre.” When the Study Area is 10 km in radius covering several villages and cities why while Public Hearing was underway did MPT chairman Jeyakumar told press on 28/04/2017 that people who are outsiders to Vasco are raising objections and People of Vasco are silent? Why is he creating distinction between Vasco residents and those from outside? What is the basis for such comment? MPT itself has not limited itself only to Vasco, it has extended its jurisdiction over Zuari river mouth up to Cortalim-Agassaim bridge and down south upto Betul from the year 2000. In 1997 MPT permitted illegal drilling at Cacra village on Zuari coast. In 2010 MPT leased out Zuari river to Marinas requiring enormous dredging of Zuari. Why MPT has stepped out of Vasco if it cannot tolerate People from outside Vasco expressing their views on affairs of MPT when they are invited through Public Notice from Goa State Pollution Control Board?
8.      On Page 1-12 there is confirmation of ecological damage already done by dredging “The Committee appointed by the NGT submitted its Report dated 27th May, 2016. As seen from the said Report, the Committee suggested that the actual damage already done to the estuarine environment, the biodiversity in particular, should be assessed after the completion of the proposed dredging.” When the damage has already been inflicted and confirmed why those responsible has not been booked? This shows colonial mindset of India towards Goa. This has to change. Immediately criminal proceedings must be initiated without delay against those responsible and further developments with regard to dredging must cease.  
9.      Pages 1-12 and 1-13 state “It has been the case of MPT that the proposed project of dredging undertaken by MPT is in larger public interest and deepening of the channel would enable navigation of cape size vessels in the Mormugao Port which would reduce the sea freight rates and attract Port users to use the Port and save effective costs of logistics.” No larger public interest is stated in EIA with example. There is only a public ruin in the form of dust pollution in Vasco city as visible Deepening through dredging only serving private interests of corporate such as Adani, Jindal and Vedanta.
10.   Page 2-1 states “The main user for MPT is currently JSW steel. JSW steel imports about 7 million tons of coal and exports about 1 million ton of finished steel products through MPT. However their coal requirement is in excess of 15 million tons and thus, has to depend on ports on the Eastern Coast like Krishnapatnam for coal imports despite the fact that MPT is closer to their steel plant situated at Toranagallu.” So it is clear that main user is JSW who needs to cut transport distance to steel plant at Torangallu in Karnataka. Main user is not public but Private Corporation. Goa is only corridor for Coal and Coke.
11.  Page 2-2 states “Coal imports for JSW at MPT are carried out at Berth No.6 which is operated by South West Port Ltd, a group company of the JSW. Another Coal Berth No.7 has recently been made operational by Adani Port Terminal Ltd. The approach channel is about 6 km long.” Here we have more evidence of who are the beneficiaries of deepening of approach channel JSW and Adani. Where is larger public interest?
12.  Page 2-5 states “SWPL has commissioned Rapid in Motion Silo facility in July 2014. Also Coal Berth No.7 operated by Adani Ports has become operational in June 2014. Adani Ports have also installed Rapid in Motion Wagon handling facility. Hence the coal traffic is set to rise further.” Who permitted them to install this facility? Profit driven Industrialization as it comes across here is damaging to ecology. Should ecology be allowed to damage because these two corporate has installed Rapid in Motion Wagon handling facility? No.
13.  Page 2-6 states that “The main importer of coal through Mormugao Port is JSW Steel Plant located at Toranangallu, Karnataka.” Should Goa tolerate enormous damage to its ecology and Public Health to satisfy JSW? We are opposed to Goa being treated as mere corridor for Coal.
14.  Page 2-6 further states “At present, coal meant for JSW are brought in gearless vessels of about 75,000 DWT size. Coal importers stand to gain substantial freight advantage by deploying Capesize vessels. The deepening of the navigational channel will not only provide impetus for existing steel companies to increase their capacities, but also encourage new steel plants to come up. The capacity Capesize ships will be of the order of 185,000 DWT.” This is 110% increase in the size of ships to enter MPT carrying Coal, Coke to JSW plant in Karnataka. Natural harbor at MPT is not suited for handling capsize ships and they must not be allowed at MPT. No deepening of approach channel must be carried on.
15.  Page 2-17 states “The dredge spoil will be disposed of in the offshore disposal area.” This is very risky proposition. Fish habitat will suffer dangerous blow. We are opposed to dredging activity for deepening of approach channel.
16.  Page 2-23 states “MPT one of the thriving major ports on the west coast of India, has recently lost its business substantially due to the closure of the Iron Ore mines in the State of Goa.” Even though MPT has lost its business nature got respite by mining closure in Goa, ground water re-charged and fresh air was available to breath again. People after many years cultivated vegetable in their gardens freed from mining dust air pollution. These effects of closure of mines in Goa are not reflected in this EIA.
17.  Page 3-11 states “Infrastructure wise Goa has an advantage over other exporting regions in the countries in view of its being endowed with a deep sea port and waterways that crisscross the territory facilitating barge transport.” Deep Sea Port and waterways are nature’s gifts to Goa. This does not justify declaring six rivers of Goa as National Waterways. This declaration is an abuse of Goa’s rivers.
18.  Same page 3-11 further continues “The two rivers Mandovi and Zuari, provide cheap river transport.” No study is mentioned on impact on these rivers’ fisheries and ecology due to transportation by barges of industrialists. Further page 5-8 warns “Due to the non-availability of reliable long-term fishery data, it is rather difficult to predict the actual impact of dredging activity on estuarine fishery; hence it is strongly suggested to carry out a detailed comprehensive study covering a year-around survey for fishery, fish spawning ground and ichthyoplankton of bay-estuarine system of Zuari. This is particularly important as the maintenance dredging will be conducted about 6-8 weeks of the years.”
19.  Cacra village is not mentioned as Fishermen habitation and as Fish landing centre any where in the EIA. MPT sanctioned illegal drilling in Cacra in 1997 and faced public opposition from the local people.
20.  Negative impacts on fisheries due to dredging are listed in EIA itself at page 4-6:
Dredging harms the ecology, limiting the ability of the dredged habitat
and nearby areas to function as a nursery area, or feeding ground for all
the marine fauna.
Physiological stress to marine fish and commercially important species
by creation of short-term higher sediment loads in the water column.
Adult fish are likely to move away from or avoid areas of high
suspended solids, such as dredging sites, unless food supplies are
increased later on as a result of increases in organic material
transformation through heterotrophy and their biomass build-up.
Increased bioaccumulation of contaminants in commercially important
species.
Increase in the population of undesirable species such as viruses and
parasites.
Reduction in habitat due to loss of benthic primary producer habitat.
Temporary reduction/increase or change in fish catch may occur due to the proposed activities.

21.  Cumulative impacts are listed on page 4-9:

The probable impacts might include, introduction of alien and invasive
species due to the combined action of long distance vessel movement
in and out of the port area and proposed dredging activity.
The transport and spillage (due to un-maintained and un-managed
transport) of ore and other chemicals may have exacerbated impacts
due to proposed activity.
Dolphins have been regularly sighted near Dona Paula bay area (4.5km
from the project site), the increased turbidity and noise levels may drive
away these highly sensitive species.
Like occurrence of unintended events such as vessel collision,
accidents, fire and other inadvertent events. These occur mainly due to
lack of coordination, casual approach, un-managed port and associated
activity and no timely communication within and between the agencies
involved in offshore activities. These events may result in human
casualties if there are no precautions taken.
Oil spills due to any unplanned eventuality is one of the major threat to
the marine biota and can have a major long term irreversible losses
depending up on the extent, quantity and expanse of spillage.

22.  Page 6-5 states “High diversity of Mangrove exist in this (Sancoale) area. Presence of schedule species such as windowpane oyster, and other commercially important molluscs such as clams, oyster, windowpane oyster and cephalopods etc. Chikalim-Sancole bay is considered as ‘Hotspot’ of marine biodiversity. Chicalim and Nauxim Bays in the Zuari estuary is home for windowpane oyster which is schedule species.” Dredging will have adverse impact on entire marine ecology of Sancoale- Chicalim bay.
23.  Page 6-6 states “Project proponent should make necessary attempt to declare the coral reef area as a “Biodiversity Conservation Zone” so that fishing and tourism activities can be regulated.” Project proponent here is MPT and  it has already destroyed bio-diversity while dredging of approach channel upto 55%. Destroyer of Biodiversity must be punished first. In this case it is MPT rather than bothering about Bio-diversity Conservation Zone.
24.  Page 1-4 states “Eastern Port have deeper channel to handle capsize vessels.” What is the size? Why data is not supplied? Even if this is true it is equally true that Ports have destroyed beaches on Eastern coast of India. Deepening of Port at MPT will certainly destroy beaches  putting fishermen and tourism stakeholders in tremendous hardships.
25.  On Pages 3-62 and 3-63 caste profile of study villages is presented. OBC category is omitted while SC and ST is prevalent. According to Mandal Commission report 52% of Indian Population is OBC. Why this EIA ignored OBC in study area? 
We oppose deepening of navigation channel at Mormugao Port for approach channel for the above cited reasons.
Thanking you,

Yours sincerely,
        Sd/-
Maggie Silveira

President, Goa Unit