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Seismic activity along Narmada dam: Why is no eco-clearance for Statue of Unity?

About 20 experts and activists* have written a letter to secretary, Ministry of Environment Forests & Climate Change , with copies to Gujarat chief minister Anandiben Patel and other senior officials seeking immediate halt of all activities related to the Statue of Unity project in view of recent seismic activity at the Narmada dam site. Copy of the letter:

We seek your immediate response following two recent developments related to the Statue of Unity project. News reports dated February 27 and 28, 2015 of the local newspapers detail the latest seismic activity at the Narmada Dam in the Sardar Sarovar region and how locals panicked, coming out of their homes. This was not the first seismic shock experienced in the region. It occurs at regular intervals. This clearly indicates that the region is seismically active with earthquakes of varying intensity vividly experienced by everyone residing there. A February 4, 2015 news report indicates that construction activity is soon to start with a geological survey being undertaken for the project in the region.
We seek your clarification on how and to what extent the fact about active seismic activity is considered while envisaging the project, the various preliminary studies and also during the geological survey being recently undertaken.
Yet another news report dated February 26, 2015 indicates that to avoid the environmental clearance for the project, the Government of Gujarat has proposed that the Ministry of Environment and Forest & Climate Change (MoEF & CC) to reduce the eco–sensitive zone of the Shoolpaneshwar Sanctuary so that the project will no longer require recommendation from National Board for Wildlife under the Wildlife (Protection) Act, 1972. This clearly suggests that Government of Gujarat now is wilfully manipulating constitutional norms and violating environmental and wildlife safeguards.
As we wrote to you in our letter dated January 7, 2015, we were expecting after our letter dated July 17, 2014 that the 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. We are shocked to know that this process required under environment laws has not been carried out, nor have you taken any of the steps to obtain the requisite Environmental Clearance (EC).
Rather as stated on your official website, www.statueofunity.in, work order has been granted to Larsen & Toubro Ltd., Chennai on 27th October 2014 worth Rs. 2,979 crore. This is also confirmed a press release dated October 28, 2014 on the L&T website (http://www.lntecc.com/homepage/common/p180.htm). Pursuant thereto we have also observed certain activities on the site of the project in the last two weeks and fear that preparation for commencement of construction of the project may have been initiated, without compliance of environmental and other laws and without following due process.
The key issues which indicate the need for a comprehensive environmental impact assessment for the Statue of Unity project are as follows:
(1) 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 project of the Statue of Unity is only 3.2 km from the Sardar Sarovar Dam, it is certainly near the Shoolpaneshwar Sanctuary.
(2) The Project involves construction on the active 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.
(3) 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 Biological Diversity Act, 2002.
(4) A comprehensive assessment of the environmental and social impact 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 the project and the project requires EIA and public consultation as per EIA notification and the existing environmental laws and requires EC. The project also needs public consultation, but none has happened so far.
(5) Due to the construction of the Sardar Sarovar dam involving hard rock blasting and massive reservoir, the already seismic area carries the additional burden 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 and unless it is in consonance with Government studies and the prevailing guidelines in this regard.
(6) 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 Sardar Sarovar dam and reservoir and any disaster or sudden floodwater release from 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 Center, 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 on 100,000 square meters area 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 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 and EIA notification of September 2006 and a number of National Green Tribunal (NGT) and Court orders about such massive kind of 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. This is even more alarming in as much as no environmental clearance has been accorded to the Garudeshwar Dam Weir project in reservoir of which the “Statue of Unity” is proposed to be constructed as a part of the said Project and a dispute in respect of the same is pending before the NGT, to which addressee nos. 1, 4 and 6 above are also parties.
There was no response whatsoever from you MoEF&CCe as an authority. We have only received response from the SSNNL on the issue of environment clearance when we filed right to information (RTI) applications. The SSNNL has no authority in law to decide whether or not an Environmental Clearance is required. Despite our repeated requests and also through the RTI Act, 2005, no valid or adequate explanation or proof of your exemption from following due process and obtaining environmental clearance in respect of the said Project has been provided.
In view of the above facts on record, we demand before the MoEF&CC that:
Direct the Government of Gujarat, SVPRET and SSNNL to follow process provided in law including but not limited to conducting mandatory environmental and social impact assessment, holding public consultation and hearing in accordance with the EIA notification of September 2006 and to submit application for environment clearance in respect of the said Project and till that is done and Environmental Clearance in respect of the said Project has been obtained after following due process, not to do any work related to the project.
Direct the Government of Gujarat, SVPRET, SSNNL, Larsen & Toubro Ltd. and any other concerned body/authority to immediately stop planning, commencement or construction of the said Project and direct them to stop all other activities related to the said Project .
Declare all actions undertaken by the Government of Gujarat,SVPRET and(SSNNL) or any other concerned authority/body concerned with the said Project as illegal, in violation of the EIA notification of September 2006 and the Environment Protection Act, 1986, and contrary to law.
Make public the report following the geological survey undertaken in the region before any kind of construction activity for the said Project which shall be deemed illegal, begins. Also, to make public the antecedents of the agencies involved in the geological survey, experts consulted, details of the processes in survey and how it compares to the earlier Government of Gujarat study for the said Project and Sardar Sarovar Project.
Make public on what grounds has Government of Gujarat proposed revision that will lead to reduction of the eco sensitive zone in the peripheral area of he Shoolpaneshwar sanctuary and what biological, zoological, botanical, aquatic life and environmental changes have been noticed.


Signatories: Trupti Shah, Girish Patel, Krishnakant, Mahesh Pandya,Ghanshyam Shah, Chinu Srinivasan, S Srinivasan,Persis Ginwalla, Rohit Prajapati, Saroop Dhruv, Rajni Dave, Lakhan Musafir, Himanshu Thakkar, Nandini Oza, Prasad Chacko, Shripad Dharmadhikary, Anand Mazgaonkar, Swati Desai, Xavier Manjooran, Hiren Gandhi, Ishwarbhai Prajapati, Raju Deepti, Deepti Raju,and Amrish Brahmbhatt

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