Mining Expose: Environment Impact Assessment Reports Tampered

GoaChronicle.com brings its readers yet another explosive expose on how Environment Impact Assessment reports were altered and fabricated to allow for environmental clearances to some mines in Goa. The nexus of illegal mining goes right up to the Centre…

An Environment Impact Assessment (EIA) is an important process in the granting of environmental clearances to mining companies to extract ore. It is on this report basis that the Union Ministry of Environment gives it environmental clearances to operate mines. However, GoaChronicle.com has learnt through its study of the Centre of Science and Environment (CSE) – Mining in Goa report that there cases in which the EIA report on mines are fabricated. We have so far got details of five mines

Analysis of EIA report of Jolreacho Dongor iron ore mine, Quepem, South Goa

The Shantilal Kushaldas & Bros. Pvt. Limited owns the iron ore mine. It is a small mine with an area of 63.35 ha in the village Maina in Quepem taluka of South Goa.

Some of the critical features of this mine are as follows:

•    Impact on steel price: The project seeks to use opportunity to export iron ore to countries like China, S. Korea and Japan as demand there has increased tremendously. As most of the iron ore is exported from Goa, this is having serious implications for the country’s steel prices.

•    Cumulative environmental impact: Several mines in all directions surround the Jolreacho Dongor Mine. Therefore, the cumulative effect of the pollution load will be severe in the region. According to the report, the emission level in the nearby villages is below the standard norms. But there should be a cumulative environmental impact assessment of all the nearby mines in the region. 

•    Full of false statements: According to locals, the report is full of false statements. According to them the project location map is incorrect.  One of the serious allegations by the localities is that although the mine has not got clearance work has been going on since January 2008. This has serious legal implications, as work in the mine cannot start till it gets the clearance from State Pollution Control Board. The report also states that the area is rocky with scanty vegetation and bushes and there are no perennial water courses/river/water bodies within the lease hold area. However these claims have been strongly opposed by the local people. According to them there is thick vegetation in the core zone area and perennial watercourses within the lease hold area.  According to the report 46.8 per cent of total area in buffer zone is forest but the villagers state that this figure is incorrect. The area under forest in the buffer zone is as high as 95 per cent.

Further the report states that there are reptiles like Kraits, House lizards, garden lizards and fresh water snakes in the core zone. But the report forgets to mention ‘King Cobra’ which could be seen in the core zone. The report states that faunal species observed are wild boars, bisons, rabbits, deer, etc. However it forgoes the fact that leopard and tiger can also be seen in the core zone area.

The report gives conflicting data it report states that life of the mine is 28 years with planned production of 0.10 million per annum; whereas another part of the report states that life of the mine is expected to be 20 years with production of 0.10 million per annum.

According to the locals the distance of the villages mentioned in the report from the mines is also not correct. They are much closer to the mines, therefore will have significant environmental problems.

•    High ore to waste ratio: EIA report states that very limited rejection will be generated from this mine. However, in another part it shows that ore to waste ratio will be quite high (1:9.42 to 1:2.21) during the first three years. Therefore, the company needs to have proper waste management programme to minimize disaster due to failure of waste dump.

•    No resettlement: The EIA report states that there are no dwellings with-in the lease area. However, the localities strongly protest this statement and inform that there are houses within the lease area. Therefore, there should be a proper resettlement policy for people living in the lease area.

•    Extent of mechanization: Though the report mentions that there will be no drilling and blasting operation and work will be carried out using manual labour as far as possible, the locals fear that use of rock breakers of small capacity mentioned in the EIA report will take away the jobs from them rather than providing them employment.

•    Poor CSR policy: The EIA report makes big claims on the CSR policy. However they are subjective in nature and cannot be crosschecked in future. The company needs to provide quantitative figures on how it is going to invest on upliftment of villagers in the area through education, health services and other programmes.

Analysis of EIA report of Matheapan E Sataracarachem iron ore mine, Quepem Taluka, South Goa

The Shantilal Khushaldas & Bros. Pvt. Limited owns this mine. It is a small mine with an area of 23 ha in the village Maina in Quepem taluka of South Goa. The EIA report is for mine lease renewal, which was due in November 2007. 

Some of the critical features of this mine are as follows:

•    Cumulative environmental impact: The Mathepan mines are coming up in an area, which is already surrounded by several other iron ore mines. The Quepem taluka is one of the core areas producing iron ore to meet the growing Chinese demand. Therefore, the cumulative impact of all these small iron ore mines will be quite high. Already Quepem taluka of South Goa is facing several protests against iron ore mines. It is therefore advisable that a cumulative environmental impact assessment of all nearby mines is conducted. 

•    At one point it is said that the mines were granted operational permission in 1953 by the Portuguese Administration, which was later converted to mining lease and were operational till late 70s. But subsequently in project description section the report says that the exploration was carried out in 80s. It also says that the leasee is yet to commence the mining operation. It is not clear if this is a renewal of mining lease, which was operational or if this is lease renewal of an area where no mining has been conducted earlier.

•    In project description, the report says that mostly rocks with scanty vegetation and bushes cover the area. However, in the biological environment table, the report talks about a large number of trees (Mango, Gulmohar, Coconut, Sisam, etc) and shrub grasses (Bor, Pitkuli, bomboo, etc) in the core and buffer zone.

•    The mine is on hilly terrain and Goa receives heavy rainfall due to which sedimentation can be a big problem. The EIA report does not provide any measures to control sedimentation.

•    The Mine is located just 12 km from Netravali wildlife sanctuary and 11 km from Cotgao wildlife sanctuary. Since, there are a large number of mines in such a small area, the cumulative environmental load is surely going to have some impact on wildlife sanctuary. The EIA report needs to deal with this issue. 

•    The mines will be operated completely manually but it will employ only 135 people out of whom 116 will be semi-skilled and 12 unskilled laborers. It means there will not be sufficient job opportunity for the local people. 

Analysis of EIA report of Careamol iron ore mine, Quepem Taluka, South Goa

The iron ore mine is owned by Shri Jaisinh Maganlal. It is a small mine with 98.76 ha in the village Pirla in Quepem Taluka in South Goa.

Some of the critical features of this mine are as follows:

•    EIA report states that the area is a series of low hills and rainfall averages around 3600 mm. Therefore, the area is going face sedimentation problem. This will be severe because they are many mines nearby. But the EIA report does not talk about sedimentation problem.

•    According to the report, Cotigao sanctuary is 4.6 km from the lease area. Plus, there are other mines also nearby. Thus, the cumulative impact of the mining on the sanctuary is a possibility but again the EIA reports does not talk about any measures to protect the sanctuary.

•    The EIA report says that backfilling of pit will be subsequently started, but the report as such does not have any reclamation plan or mine closure plan. The company must provide in detail how the reclamation work will be carried out in subsequent years. 

•    The mine is to generate 0.382 million tons of waste every year. However, the executive summary does not explain in detail how the waste will be collected or where it will be dump. The report even does not have any map of project. It only talks about some of the best practice for waste management.

•    The executive summary does not make any statement on occupational health and safety hazards. Since lease is in low hill areas and with heavy rainfall, there should be a proper occupational health and safety hazard policy.

•    The executive summary just talks in few lines on CSR policy of the company without making any commitment. The company needs to provide in detail what kinds of CSR policy it intends to take for upliftment of the nearby villagers.

Analysis of EIA report of Devapan Dongor Iron and Manganese Ore Mine, Quepem Taluka, South Goa

Shaikh Salim owns the iron ore and manganese mine. The total reserve is around 5.99 million tones. The mine lease area is 83 ha with an annual production rate of 3.11 lakh tones per annum. It is expected that the mine will produce ore up to 22 years. The land use pattern of mine lease consists of private land and forestland.

The report not only contains factual mistakes but also is poor in terms of assessing the significant impacts of the project on environment. In addition to this, the report gives contradictory statements and suggests mitigation measures that seem very superficial.

Some of the critical features of this mine are as follows:

•    EIA says that the acquired land for the mines lease is a combination of private and forestland. But no information is available on the land use pattern of mine lease such as, areas under forest, irrigation land, wasteland etc.

•    Under heading of existing land use pattern in core zone, instead of proving land use pattern, the EIA has mentioned about the lands to be used for mining activities. Interestingly, land use pattern for buffer area is correct. It clearly indicates that the EIA developer is trying to hide the land use pattern in the core zone.

•    The report mentions that the lease area has elevated topography and consists of small isolated hillock extending in southwest to southeast direction. It also mentions that the land surrounding the mine lease is agricultural and receives high rainfall (around 3800 mm). If this is the scenario, then impact on land is anticipated to be high. However the EIA fails to quantify the impact on land such as erosion potential of catchments area, erosion potential of waste dumps, and direction of runoff. Based on the topography, it can be anticipated that Cavorem village, which is located at 0.29 km from the mine lease will be the worst affected by air pollution and mine runoff.

•    The EIA report makes contradictory statement on mining technology. On page no 6, it mentions about the drilling and blasting operation, however  in another part of its report EIA states that no drilling and blasting will be carried out, instead a riper will be used.

•    EIA report is also incomplete in terms of the number of existing mines and proposed mines in the area. EIA states that the villages surrounding the mine lease are dependent on agricultural and mining activities. The huge number of operational mines in the area clearly exhibits the plight of the region in terms of air and water pollution and once the project becomes operational these effects will be enhanced.

•    EIA is poor in portraying the impact of mining on groundwater and also provides misleading information on the same.  On one page it states that GW is available at 15 to 25 meter and working depth of a mine is below the water table. On another suddenly it says “No occurrence of ground water in the mine lease”. In addition to this, the report also fails to provide information on final quarry depth, mine seepage, groundwater flow pattern and impact of draw down.

•    Mine reclamation is an important issue in mine management and has been poorly represented in the EIA report. It mentions “management is committed to reclaim the entire broken area”. But the report fails to address the basic information on mine reclamation such as type of reclamation, area to be reclaimed, timeframe and monetary requirement for the same.

•    Overburden management is a crucial aspect of mine management, but the report fails to provide some basic information on overburden management and most of the mitigation suggested seems very superficial. EIA report is also silent on stripping ratio and storage area characteristic for waste such as – slope of land, length of the overburden storage area, runoff direction and erosion potential from the waste dumps. These are some of the significant parameters for the assessment of silt load and its impact on water bodies and on land. The assessment of these parameters is crucial for this project because the mine is located on an elevated area receiving high rainfall and surrounded by sensitive receptors such as human settlement, agricultural land and forest area.

•    EIA also fails to provide a clear picture on the forest cover in the core zone (i.e. mine lease) and forest area to be diverted for non-forest use. The report also provides contradictory information on the fauna; animals listed are different from those mentioned in another part of the report (presence of wild boars, bison, and deer etc). It appears that biodiversity assessment has been poorly done. Moreover, the term of reference given by MOEF clearly states that the biodiversity assessment should be authenticated but no letter of authentication for biodiversity assessment is provided in the report.

•    Point number ten of the term of reference (given by MOEF) mentions about fund for the maintenance of village road through which transportation of ores is undertaken. The EIA is completely silent on this.

Analysis of EIA report of Chuninimola Iron Ore Mine, Sanguem Taluka, South Goa

The Shantilal Kushaldas & Brother Pvt Limited own the iron ore mine. The total mine reserve is around 2.46 million tones. The lease area of mine is 42.91 ha with an annual production rate of 2.18 lakh tones per annum. It is estimated that the mine will produce ore up to 15 years. The land use pattern of mine lease consists of private land and forestland. This mine is very close to the Devapan Dongor mine.

Some of the critical features of this mine are as follows:

•    Chuninimola Iron ore mine is located in village Rivona in the South Goa district. However, the only difference between the Devapan Dongor and Chuninimola mine is the difference of mine owner. The consultant who prepared the EIA report is same (M/s Bhagavathi Ana labs Ltd, Hyderabad). Topography of both the mine is also almost same except that Chuninimola Iron ore mine is close to Kushavathi River (almost 50 to 60 meter from the mine site), therefore runoff impact is expected to be very high, which is not captured in the EIA. Further, the information on forest cover is conflicting, on page no 31, the forest cover in the study area is given as 40 per cent, but on another page in the report it is mentioned as 33.6 per cent.

•    Kalka Nadi which passes close to the mine lease (this river is no where mentioned in the EIA report, drainage network in the watershed) will be worst affected by siltation because slope of land is toward SW and river is also flowing in the SW direction. The EIA report chooses to remain completely silent on this. The same consultant has prepared both the EIA reports, and it comes across as a copy-paste job from the Devapan Dongor mine report.

•    The biggest drawback of the EIA studies of Devapan Dongor and Chuninimola Iron ore mine is that each mine talks about project specific impacts and shows that after mitigation the project will benefit the surrounding areas. Both fail to address the runoff threat, which is very significant bearing in mind the topography of the region, intensity of rainfall and presence of sensitive receptors. Hence siltation impact is critical and requires detailed investigation.

GoaChronicle.com has managed to get it hands on five EIA analysis done by CSE, the question however is how many more EIA reports were tampered with.

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