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Earlier this month, Stage-1 clearance was given in favour of South Western Railway; Rail Vikas Nigam Ltd in connection with the Double Tracking project. This approval comes despite some of the largest and most vibrant citizen and youth-led efforts to save Goa’s largest protected area, including the protests at Chandor, where thousands of citizens did a night vigil on the railway track in November, 2020. Goans and others who have supported these efforts from across the board, said their voices and their resolve will only get stronger.
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The Regional Empowered Committee,
Integrated Regional Office, Bengaluru.
Ministry of Environment Forest and Climate Change
Forest Proposal No: FP/GA/RAIL/22041/2016
Forest Proposal No: FP/GA/RAIL/28650/2017
Forest Proposal No: FP/KA/RAIL/34288/2018
In principle approval dtd. 4th February, 2021 F.No.4-GOB 1205/2019-BAN
Respected Chairperson, Member Secretary and Members,
It has come to our notice that the forest diversion proposal involving diversion of forest land in Goa and Karnataka for double tracking of the Vasco-Hospet railway line was discussed and deliberated by this esteemed committee in its 49th meeting held on 27th January 2021. Four proposals were submitted by the project proponent for the project, which were all recommended for Stage-I clearance on 27th January, 2021 and granted in-principle approval on 4th February, 2021. The entire project involves diversion of 148.841 ha of forest land and felling of 25,239 trees.
On perusal of the in-principle approval and the conditions of recommendation, we raise the following issues with the project, to be considered by you before granting any further approvals:
1. Approval granted on basis of inadequate and faulty EIA: A peer reviewed paper titled ‘‘On the inadequacy of environment impact assessments for projects in Bhagwan Mahavir Wildlife Sanctuary and National Park of Goa, India: a peer review’ has been published in the Journal of Threatened Taxa and shows that 19 plant species were not recorded in Goa before. The Railway EIA mentions the occurrence of the Eurasian otter (Lutra lutra) which was not recorded before, as also the Large Indian Civet (Viverra zibetha) which is only found in north-east India so far but recorded in this study. A plant species Euonymus undulates is either not a scientifically-valid species or is in the process of being described newly to science by the Railway EIA team. Diverting forests is highly unsuitable with such rare species and new range extensions found for the first time in Goa. The only other possibility is that the Railway EIA study was poorly conducted. The other lack of due process is an unacknowledged conflict-of-interest. There is an overlap in the assessment agency and the NBWL member involved in passing the project. Such inadequacies need the consideration of the authorities at the time of considering the proposals.
2.Inadequate Mitigation Measures: That the conditions for compliance in the Stage-I approvals involve implementation of mitigation measures proposed by IISc. In this regard, a representation letter dated 4th August, 2020 was sent to the Environment Minister, Goa by scientists, ecologists, environmentalists, naturalists and such academicians highlighting the inadequacies of the studies carried out for the projects. With respect to the railway project, one of the most glaring inadequacy was that of the mitigation measures. It has been reflected in the letter that “The EIA report of railway-doubling does not propose any adequate mitigation measure Though the report does suggest measures to reduce air, water, and noise pollution, while mitigating habitat loss and enabling animal movement; the measures were found to be unscientific and even potentially harmful. For example, recovering vegetation beside railway through plantations is known to attract wildlife and increase their vulnerability to get killed by moving vehicles. Similarly, artificial sound barriers (usually vertical walls of a solid structure) will completely isolate wildlife populations, making free movement across the road impossible for terrestrial species. Additionally, with regards to mitigating biodiversity impacts, the EIA provides only baseline information on species diversity and abundance, rather than explicitly studying, and proposing mitigation for, the impact of the proposed expansion.
3. Cumulative Impact Assessment needs to be carried out: NTCA carried out the site appraisal of the area where the project is proposed in Karnataka. The “Site Appraisal Report...” observes “...four laning of an existing road and doubling of railway line within an aerial distance of 5-6 km from each other in one of the most ecologically sensitive and biodiversity rich part of Western Ghats will definitely have far reaching implications for the wildlife due to habitat destruction, disturbance, habitat fragmentation, road kills and train collisions.
In Ossie Fernandes and Ors. v. MoEF and Ors. (Appeal No. 12/2011), the Ld. National Green Tribunal held:
It is always desirable that a cumulative impact study is conducted invariably in all the cases where more than one project of similar nature or different nature are involved. The cumulative effect of any discharge from the industry/project would definitely have an adverse effect on the carrying capacity of environment and ecology...All the more, it is essential to have cumulative effect study of the projects to avoid any danger to human life and the marine life equally.
Given the nature of the project and the ecological significance of BM WLS and NP, it is imperative that Cumulative Impact Assessment studies be carried out for the Highway expansion, railway and transmission line projects, within the affected region of Goa and Karnataka.
We urge you to reconsider this project in light of the submissions made herein. It is further requested that no work order be granted by the Forest Department permitting tree felling for the project, till the same is reconsidered.