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Geotechnical, geological studies on Sardar Statue site raise serious issues

Several senior activists and intellectuals, including Trupti Shah, Girish Patel, Mahesh Pandya, Ghanshyam Shah, Persis Ginwalla, Rohit Prajapati, Himanshu Thakkar, Nandini Oza, Prasad Chacko, Shripad Dharmadhikary, and others have asked the Secretary, Ministry of Environment, Forests and Climate Change,Government of India, to immediately halt of all activities related the Statue of Unity project, proposed in the memory of Sardar Vallabhbhai Patel in the midst of Narmada River, about 3.2 km downstream of Sardar Sarovar Dam, or face legal action. Text of the letter:

We were expecting after our letter dated July 17, 2014 that Sardar Vallabhbhai Patel Rashtriya Ekta Trust (SVPRET) and the Sardar Sarovar Narmada Nigam Ltd (SSNNL) would appoint a consultant to conduct the requisite Environmental Impact Assessment (EIA) for the project known as Statue of Unity. We are shocked to know that this process, required under environmental laws, has not been carried out, nor have you taken any of the steps to obtain the requisite Environmental Clearance. Rather as stated on your official website, http://www.statueofunity.in, a work order has been granted to Larsen & Toubro Ltd, Chennai, on October 27, 2014 worth Rs. 2,979 crore. There is also a press release dated October 28, 2014 on the L&T website (http://www.lntecc.com/homepage/common/p180.htm) stating that it has obtained the work order for the same.
The key issues which lead to the need for a comprehensive environmental impact assessment for the Statue of Unity Project are as follows:
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 statue is only 3.2 kms from the Sardar Sarovar Dam, it is certainly nearby Shoolpaneshwar Sanctuary.
The project involves construction on the riverbed of a perennial Narmada river and inside the proposed reservoir called Garudeshwar Weir, close to sanctuary, in eco-sensitive zone, and hence will have serious impacts on the ecology and environment. Hence, an EIA and EC are essential.
The project is also a project of tourism and will affect the downstream river, its biodiversity, people and livelihoods and other related aspects. Thus, not doing the impact assessment and not taking consent of the local community is also in violation of the Biodiversity Act.
A comprehensive assessment of the environmental and social impacts of the Statue of Unity and all the construction related to the same, including buildings, hotels, museums, jetties, guest houses, roads and its contribution to the cumulative impact of all the projects and activities in the area has not been done. Cumulatively, all this together are part of one project and the total construction area is certainly high enough to require EIA and public consultation as per EIA notification.
The project also needs public consultation, but none has happened so far.
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.
An informed decision in consultation with the local people and all concerned is necessary since this whole complex is being built directly downstream of the massive SSP Dam and reservoir and any disaster at SSP would also put the lives of all concerned with this project also at risk.
The project, as is abundantly clear from the official website (http://www.statueofunity.in/project-objectives.html) is not simply the construction of a “mute monument”. It is an elaborate tourism project which includes the creation of a 13-km-long artificial pond which will be used for boating, a Museum and Audio Visual Gallery, Research Centre, Memorial Garden, Public Plaza, roads, and railway lines.
A board which has been recently erected in front of the helipad at Kevadia Colony mentioning the inauguration by the Chief Minister of Gujarat of Shreshtha Bharat Bhavan built at the cost of Rs 176 crore as part of the Statue of Unity near the Sardar Sarovar Dam on Narmada River near Kevadia colony. This makes things very clear that the Statue of Unity project means not just the statue of Sardar Vallabhbhai Patel but number of such other sub-projects related to tourism. (http://anandibenpatel.com/hon-cm-lays-foundation-stone-of-shreshtha-bharat-bhavan-near-sardar-sarovar-dam-on-narmada/)
These activities are illegal and in violation of the Environment Protection Act, 1986, the EIA notification of September 2006 and a number of National Green Tribunal (NGT) and court orders about such massive construction on the riverbed. The social and environmental impacts of construction in the riverbed and proposed reservoir called Garudeshwar Weir, bringing lakhs of people per year close to the Shoolpaneshwar Sanctuary, and the eco-sensitive zone, have been shockingly ignored.
There was no response whatsoever from you as an authority. We only received response from the Sardar Sarovar Narmada Nigam Ltd (SSNNL) on the issue of environment clearance when we filed RTI applications. The SSNNL is not the appropriate authority to decide whether or not an Environmental Clearance is required. Despite our repeated requests and also through the Right to Information Act, 2005, there is no adequate proof of your exemption from the legally binding procedures is provided to us.
In view of the above facts on record, we demand before the Ministry of Environment, Forests and Climate Change that:
Direct the Government of Gujarat, Sardar Vallabhbhai Patel Rashtriya Ekta Trust (SVPRET) and Sardar Sarovar Narmada Nigam Ltd (SSNNL) 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, Sardar Vallabhbhai Patel Rashtriya Ekta Trust (SVPRET), Sardar Sarovar Narmada Nigam Ltd. (SSNNL), and Larsen and Toubro Ltd. 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 October 31, 2013 for the project called Statue of Unity of the then 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 to all our letters.
We call on you to cease all Statue of Unity Project activities and not commence further works until due process of environmental clearance is undertaken. If project activities are not immediately stopped, you will invite immediate legal action.

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