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Research Project on Assessing Quality of Environmental Impact Assessment (EIA), Compliance of Environmental Clearance (EC) Conditions and Adequacy of Environmental Management Plan (EMP) of Mining Industry in Goa Report October 2013 Principal Investigator : Sujeetkumar M. Dongre Overall Guidance : Prof. Madhav Gadgil CEE Centre for Environment Education Supported by The Department of Science, Technology and Environment, Government of Goa

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Page 1: EIA Report Final 151013 - India Environment Portal | News ... Report Final... · Ms. Suvarna Dongre, Ms. Gausiya Khadri, Shri Akash Gauns, Ms. Apeksha Malvankar, Dr. ... Annexure

Research Project on Assessing Quality of Environmental 

Impact Assessment (EIA), Compliance of Environmental 

Clearance (EC) Conditions and Adequacy of 

Environmental Management Plan (EMP) of Mining 

Industry in Goa 

  

Report 

October 2013 

 

Principal Investigator  :   Sujeetkumar M. Dongre 

Overall Guidance    :   Prof. Madhav Gadgil  

 

CEE

Centre for Environment Education

Supported by The Department of Science, Technology and Environment, Government of Goa

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Credit:

The Government of Goa has commissioned the Centre for Environment Education (CEE), Goa to

undertake a two-year research project, commencing April 2011 to assess the quality of the

Environmental Impact Assessments (EIA) submitted, compliance with Environment Clearance

(EC) conditions and the adequacy of the EMPs with respect to 105 mines in operation in Goa.

The project was guided by Prof. Madhav Gadgil, then a member of the Goa Golden Jubilee

Development Council, and currently D D Kosambi Visiting Research Professor of Goa

University.

Project Team:

Principal Investigator: Sujeetkumar M. Dongre

Overall Guidance: Prof. Madhav Gadgil

Overall Supervision: Shri Kartikeya V. Sarabhai and Ms. Sanskriti R. Menon

Project Staff:Ms. Prishila Fernandes, Ms. Suvarna Dongre, Ms. Gausiya Khadri, Shri Akash

Gauns, Ms. Apeksha Malvankar, Dr. Varsha Raikar, Shri Chandrakant Shinde, Shri Shivam

Powar,

About CEE:Centre for Environment Education (CEE) was established in August 1984 as a

Centre of Excellence supported by the Ministry of Environment and Forests, Government of

India. CEE, a national institution with its headquarters in Ahmedabad, has a mandate to promote

environmental awareness nationwide. CEE is affiliated to the Nehru Foundation for

Development and inherits the rich multi- disciplinary resource base and varied experience of

Nehru Foundation for Development. CEE is committed to ensuring that due recognition is

given to the role of EE in the promotion of sustainable development. CEE develops innovative

programmes and educational material, and builds capacity in the field of education and

communication for sustainable development. It undertakes demonstration projects in education,

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communication and development that endorse attitudes, strategies and technologies that are

environmentally sustainable

Acknowledgements

The study was an outcome of consultations organized as a part of the preparation of Goa

Golden Jubilee Development Council’s vision document on Environment and Sustainable

Development of Goa. One of the concerns raised by the locals in the mining affected area was

that of quality of EIA and EMP and compliance of EC conditions of mining industry. When this

concern was shared with the then Minister for Environment Shri Aleixo Sequiera he took the

lead in supporting a systematic research study on the issue. We thank him for his initiatives and

support. Thanks to Shri Michael D’souza, Jt. Secretary (Finance) who was instrumental in

granting this study and monitoring of its progress. Shri Sanjeev Joglekar, Environmental

Engineer, Goa State Pollution Control Board (GSPCB) extended his support by providing all the

EIA, EC and EMP documents for desk analysis, writing letters to all the mining industries and

concerned government departments for their cooperation, facilitating the visits to mining sites.

Without his support the study would not have been possible. Dr. Mohan Girap, Scientist GSPCB

provided critical comments on the analysis tool, citizens manual and draft report.

Thanks to Shri Kartikeya V. Sarabhai, Director CEE and Ms. Sanskriti R. Menon,

Programme Director CEE Central Pune for their continued support and guidance during the

project implementation and for valuable comments on the draft.

Thanks to Shri Glenn Kalavampara, Secretary MOEA for coordinating all the meetings and

workshops among the officers of mining industries and providing valuable suggestions and

comments on the analysis tool and draft report. Thanks to all the Mines Managers and

Environment Officers who participated in the workshops, gave valuable comments and

facilitated the field visits in the mine sites and provided all the detailed information required for

the study. Their support was highly commendable.

Thanks to Dr. Satish Shetye, Vice Chancellor, Goa University, Dr. Ligia Naronha, TERI Dr.

Claude Alvares, Director Goa Foundation, Shri Ramesh Gauns, Teacher, Dr. Aaron Lobo,

Marine Biologist, Dr. Manoj Borkar, Associate Professor, Carmel College for Women, Dr.

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Gurdeep Singh and Dr. Agarwal of School of Mines, Dhanbad, Shri Anand Lele, Consulting

Geologist for offering expert comments on the process of assessment, participating in the

discussion/workshop and commenting on the draft report/Synopsis. Thanks to Shri Rajendra

Kerkar, for providing list of sacred groves located in the buffer zones of mining areas

Thanks to Villagers and local community representatives Shri Hanumant Parab from

Pissurlem, Shri Pandurang Patil from Rivona, Shri Nilesh Gaonkar from Caurem, Shri Shankar

Jog from Sancordem, Shri Dinanath Gaonkar from Shirgao, Shri Madhu Goankar from Betki

Khandola, Fr. Bismark Dias, Shri Rama Velip from Colamb, Shri Abhijeet Prabhudesai from

Goancho Xetkaryacho Ekvot, Nitin Tendulkar from Dabal and Shri Gaurav Shirodhkar for

providing inputs, coordinating and providing logistics during the field visits and discussion

among the locals and providing all information pertaining the mines located in their vicinities.

Their support in the entire study was very much helpful and many of the findings highlighted in

the report has come from the villagers and their representatives.

Thanks to all the Panchayat who accepted the EIA documents for assessment.

Thanks to the CEE Goa State Office staff who worked on the project Ms. Prishila Fernandes,

Ms. Suvarna Dongre, Ms. Gausiya Khadri, Shri Akash Gauns, Ms. Apeksha Malvankar, Dr.

Varsha Raikar, Shri Chandrakant Shinde, Shri Shivam Powar, for their dedicated efforts in

development of analysis tool, assessing EIA documents using the assessment tool, field visits to

verify the findings and interviewing locals by using the citizens manual.

Thanks to Ms. Diniz Fernandes, an Intern from TERI University, New Delhi and Ms. Cheryl

Fernandes who have helped in interviewing the locals using the citizen manual and developed

sketches and graphics to be used in this report. Thanks also to Shri Rajiv D’Silva and Ms.

Talulah D’Silva for digitizing the mining map and developing maps showing various eco-

systems in the Western Ghats.

Thanks to CEE colleagues Dr. Shriji Kurup, Shri Praveen Prakash, Shri Tushar Patil, Shri

Kishor Choudhari, Ms. Shyamala Nayak for their involvement in the assessment study and

providing valuable comments whenever required

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Thanks to National Institute of Oceanography for providing research articles related to

mining and its impact on water and estuaries, Goa University for organizing a one day workshop

involving Professors and students to discuss the draft findings of the study. We thank all the

Professors who participated for their valuable suggestions and guidance on drafting the report.

Thanks to the Goa State Pollution Control Board and Department of Science, Technology and

Environment for their continuous support during the study. Thanks to the Director TISS,

Tuljapur Campus for sending the intern to work on the assessment study. Thanks to all the

interns from TISS, Tuljapur Campus.

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Contents 

1. Executive Summary ....................................................................................................... 17

2. Background .................................................................................................................... 24

2.1 Preamble ....................................................................................................................... 24

2.2 Tools of Environmental Management .......................................................................... 25

2.3 Environmental Regulations pertaining to Mining ......................................................... 27

2.4 Goan experience ............................................................................................................ 28 2.4.1 Illegalities in the Mining Sector .......................................................................................... 28

3. The setting ...................................................................................................................... 30

3.1 Mining in Goa ............................................................................................................... 31

3.2 Land Use pattern ........................................................................................................... 34 3.2.1 Sanguem taluka ................................................................................................................... 35 3.2.2 Landuse of Sanguem taluka ................................................................................................. 36 3.2.3 Quepem taluka ..................................................................................................................... 36 3.2.4 Land use of Quepem Taluka ................................................................................................ 37 3.2.5 Bicholim taluka ................................................................................................................... 38 3.2.6 Land use of Bicholim Taluka .............................................................................................. 39 3.2.7 Sattari taluka ........................................................................................................................ 40 3.2.8 Landuse of Sattari taluka ..................................................................................................... 41 3.2.9 Bardez taluka ....................................................................................................................... 42 3.2.10 Landuse of Bardez Taluka ................................................................................................. 43 3.2.11 Ponda taluka ...................................................................................................................... 45 3.2.12 Landuse of Ponda Taluka .................................................................................................. 46

4. Mining Impacts: potential and actual ............................................................................. 47

5. Materials and methods ................................................................................................... 63

5.1 Mandate of the project, ................................................................................................. 63

5.2 Mode of conduct ........................................................................................................... 64 5.2.1 Chronology of interactions with various stakeholders .................................................... 69

6. Results ............................................................................................................................ 71

6.1 Desk study ..................................................................................................................... 72 6.1.1 Environmental Impact Assessments .................................................................................... 72

6.2 Inputs from public ......................................................................................................... 84

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6.3 Deficiencies with regard to Public Hearings ................................................................ 88

6.4 Environmental Clearances ............................................................................................ 90

6.5 Environmental monitoring ............................................................................................ 94

6.6 Environmental Management Plan ................................................................................. 95

6.7 Field Visits and observations ...................................................................................... 100

7. Way ahead .................................................................................................................... 111

8. References .................................................................................................................... 115

9. Annexures ..................................................................................................................... 119 

 

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List of Annexure:

Annexure I Prof. Gadgil letter to Mr. Shaikh Salim (Page No 25)

Annexure II Letter from Mr. Shaikh Salim to Prof. Gadgil (Page No 25)

Annexure III EIA Notification 1994 and 2006 with amendments of 2009(Page No 26)

Annexure IV Mining leases located in Sanguem taluka with area in ha(Page No 35)

Annexure V Mining leases located in Quepem taluka with area in ha(Page No 35)

Annexure VI- Mining leases located in Bicholim taluka with area in ha(Page No 35)

Annexure VII Mining leases located in Sattari taluka with area in ha(Page No 35)

Annexure VIII Mining leases located in Bardez taluka with area in ha(Page No 35)

Annexure IX Mining leases located in Ponda taluka with area in ha(Page No 35)

Annexure X Sacred grove article of Mr. Rajendra Kerkar (Page No 58)

Annexure XI ToR of the project proposal (Page No 64)

Annexure XII Letter from GSPCB on EIAs given for analysis (Page No 64)

Annexure XIII Notes and report of field visits (Page No 65)

Annexure XIV Citizen Manual(Page No 65)

Annexure XV Letter to the Panchayat for feedback on quality of EIAs (Page No 65)

Annexure XVI Order of ST (Amendment), 2002 including the Velip, Gawada

and Dhangar in ST(Page No 75)

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Annexure XVI I(a) List of EIAs and their year of preparation (Page No 76)

Annexure XVII (b) Discrepancies in distance from PA to lease boundary mentioned in

EIA and ECs (Page No 76)

Annexure XVII (c) Year wise public hearing and their venue (Page No 76)

List of Tables:

Table I Goa state land use patter (Page No 34)

Table II Sanguem taluka land use pattern (Page No 36)

Table III Quepem taluka land use pattern (Page No 38)

Table .IV Bicholim taluka land use pattern (Page No 40)

Table V Sattari taluka land use pattern (Page No 42)

Table VI Bardez taluka land use pattern (Page No 44)

Table VII Ponda taluka land use pattern (Page No 46)

Table VIII EIA, EC and EMP received from GSPCB for evaluation (Page No 65)

Table IX List of Panchayats that were supplied EIA documents for their comments

(Page No 66)

Table X Citizen’s feedback using Citizen Manual for their feedback (Page No 68)

Table XI Chronology of interaction with various stakeholders (Page No 70)

Table XII Analysis of EIA, EC and EMP using the Citizen Manual (Page No 83)

Table XIII Citizen response using the Citizen Manual (Page No 87)

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Table XIV Citizen response on public hearing using the Citizen Manual (Page No 89)

Table XV Citizen response on the EC using the Citizen Manual (Page No 93)

Table XVI Citizen response on EMn using the Citizen Manual (Page No 94)

Table XVII Citizen response on EMP using the Citizen Manual(Page No 99)

Table XVIII Field visits and observations (Page No 110)

List of Maps

Map I Goa vegetation map (Page No 30)

Map II Location of mining sites in Goa (Page No 31)

Map III Talukawise mining operation sites in Goa (Page No 33)

Map IV Sanguem taluka land use map (Page No 35)

Map V Quepem taluka land use map (Page No 37)

Map VI Bicholim taluka land use map (Page No 39)

Map VII Sattari taluka land use map (Page No 41)

Map VIII Bardez taluka land use map (Page No 43)

Map IX Ponda taluka land use map (Page No 45)

MapX Location of mines near water bodies (Page No 47)

Map XI Mining leases located near Protected Areas (Page No 47)

Map XII Sketch depicting impact of ore transport and dust on surrounding areas

(Page No 48)

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Map XIII Sketch depicting impact of mining on the water table and ground water

aquifer (Page No 48)

List of Figures

Fig I Decade-wise export of ore from Goa from the year 1940 to 2010 (Page

No 32)

Fig II Year-wise exports of ore from the year 2001 to 2010(Page No 32)

List of Photos

Photo I Siltation in water body (Page No 49)

Photo II Increased water turbidity and siltation in river(Page No 50)

Photo III Impact of siltation on agriculture land and on surrounding areas

(Page No 52)

Photo IV Impact of silt on the Kulaghars(Page No 52)

Photo V Siltation in agriculture land (Page No 53)

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Abbreviations

ASCI Administrative Staff College of India, Hyderabad

BMC Biodiversity Management Committees

CEC Centrally Empowered Committee

CEE Centre for Environment Education

CFR Community Reserve Forests

CPCB Central Pollution Control Board

CSE Centre for Science and Environment

CRZ Coastal Regulation Zone

CZMA Coastal Zone Management Authority

DMG Department of Mines and Geology

DSTE Department of Science, Technology and Environment

EC Environmental Clearance

EIA Environmental Impact Assessment

EMn Environment Management

EMP Environmental Management Plan

EPA Environment (Protection) Act, 1986

ESA Ecologically Sensitive Areas

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ESZ Ecologically Sensitive Zone

FCA Forest (Conservation) Act, 1980

GGJDC Goa Golden Jubilee Development Council

GFD Goa Forest Department

GMOEA Goa Mineral Ore Exporters Association

GSPCB Goa State Pollution Control Board

IBM Indian Bureau of Mines

IBWL Indian Board for Wildlife

IBIS Indian Biodiversity Information System

IIT Indian Institute of Technology

MoEF Ministry of Environment and Forests

MM (DR) Mines and Mineral (Development Regilation), Act 1957

NBA National Biodiversity Authority

NCERT National Council of Education, Research and Training

NEERI National Environment Engineering Research Institute

NGT National Green Tribunal

NP National Parks

OB Over Burden

PA Protected Area

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PAC Public Accounts Committee

PIB Public Investment Bard

ToR Terms of Reference

RDP Regional Development Plan

RO Regional Office

RPG Regional Plan of Goa

RP Regional Plan

SC Supreme Court

SC Scheduled Caste

SD Sustainable Development

SCERT State Council of Education, Research and Training

SEIAA State Environmental Impact Assessment Authoriy

SEIAC State Environment Impact Assessment Committee

ST Scheduled Tribe

TERI The Energy and Resources Institution

WGEEP Western Ghats Ecology Expert Panel

WLS Wildlife Sanctuary

WPA Wildlife (Protection) Act, 1972

ZASI Zoning Atlas for Sitting of Industries

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Preface:

In January 2011, Prof. Madhav Gadgil intended to undertake public consultations as part of

Goa Golden Jubilee Development Council’s vision document 2035 on Environment and

Sustainable Development. The objective of the consultation was to understand people’s

perception and views on issues related to sustainable development of Goa. Centre for

Environment Education (CEE) was asked by the Government of Goa to facilitate such

consultation involving all stakeholders. CEE conducted more than 15 consultations across the

state. Most of the participants who attended the consultation were of the opinion that, Goa is

currently facing a serious environmental challenge due to unscientific and hap hazard mining

activities.

When CEE organized a consultation with locals in Caurem village of Quepem taluka, all

participants complained about drying up of their perennial spring due to mining activity in the

hills. When Prof. Gadgil and team of CEE Goa State Office visited the site, it was seen that the

spring existed and mining had a very serious effect. In fact, the Environmental Impact

Assessment (EIA) report of the mining company does not make any mention of existence of any

such water course in the core zone of mining, but the Environmental Clearance (EC) conditions

obtained from the Ministry of Environment and Forests, Govt. of India makes a mention that if

there are any water course existed, the project proponent will have to leave 50 meters buffer area

on both sides of the water course and enrich its sides by planting native vegetation.

Unfortunately, the condition was violated. Upon close look at the EIA reports, most of the have

serious lacunae of information with respect to environment, social and economic parameters.

When the issue was discussed with the then Hon. Minister for Environment, Government of

Goa, he felt that a systematic study of assessment of quality of EIAs, compliance to the EC

conditions and adequacy of EMPs of mining industry in Goa is necessary and commissioned a

two year study to CEE to under the overall guidance of Prof. Madhav Gadgil, the then Member

of Goa Golden Jubilee Development Council.

CEE has objectively assessed the quality of EIAs of 79 mines by using scientifically

designed assessment tool based on guidelines prepared by the Administrative Staff College of

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India, Hyderabad, undertook field visits to mining sites, conducted workshops involving Mines

Managers, locals and NGOs. The Goa State Pollution Control Board made available all the

documents necessary for assessment. I thank everyone who have helped and contributed in this

study. I wish to that Prof. Madhav Gadgil for his valuable guidance through the project period.

I hope the outcome of the study will be meaningfully used in improving the quality of EIA,

strict compliance of EC conditions and better Environment Management and monitoring in

future.

Kartikeya V. Sarabhai Director, CEE

 

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1. Executive Summary 

Goa, India’s smallest state is flanked to the east by forested, biodiversity rich Western Ghats

and is adorned by nine rivers coursing through its hilly midlands, and coastal plains with

mangrove fringedestuaries and brackish and sweet water paddy fields. The Western Ghats tracts

are extensively protected by National Parks and Wildlife Sanctuaries. Goans cultivate rice, betel

nut, coconut, cashew and mango, and enjoy rich river and coastal fisheries. The hilly tracts are

rich in iron and manganese ore that has been tapped over last sixty years with a large number of

small scale leases. Nearly half the iron ore exported from India comes from Goa, and the pace of

its exploitation has increased dramatically in the last decade.

This mining activity has been the focus of public scrutiny in recent years as reflected in

Justice Shah Commission’s (2012) Report on Illegal Mining in Goa. The Report states that “Part

IV. Section 24 of the Mines and Minerals (DR) Act, 1957 was not observed at all and that no

inspection was carried out of iron ore mines…. which has caused loss to the ecology,

environment, agriculture, ground water, natural streams, ponds, rivers, biodiversity, etc.”

As a part of such public scrutiny, The Government of Goa assigned to Centre for

Environment Education (CEE), Goa State Office a two-year research project to assess the quality

of the Environmental Impact Assessments (EIA) submitted, compliance with Environment

Clearance (EC) conditions and the adequacy of the Environmental Management Plans(EMP)

with respect to 105 mines in operation in Goa. The study was ably supported by The Department

of Science, Technology and Environment, Government of Goa and enjoyed full cooperation of

the mine management as well as the people of the state. It has been conducted in an open,

transparent and participatory manner by organizing various workshops, and consultations with a

wide range of stakeholders and field visits to the mining sites.

The EIAs coupled to public hearings are meant to bring to notice avoidable negative

environmental impacts, so that the projects may be reformulated in ways that may avoid them, or

rejected in case the negative environmental impacts, including socio-economic impacts are of

such large magnitude that they outweigh positive benefits of the mining activities. The ECs

stipulate conditions to ensure that adverse environmental impacts are strictly avoided, and EMPs

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to ensure good environmental management during the conduct of the project. The monitoring of

environmental parameters is meant to ensure that conditions of EC are being fulfilled and EMPs

are being actually implemented. The process is now being guided with the help of sector specific

Terms of Reference (TOR) and specific Guidance Manuals for Mining and Beneficiation of

Minerals prepared by the Administrative Staff College of India (ASCI), Hyderabad in 2010.

The objective of EIA exercise mandated under the Environment (Protection) Act 1986 is to

protect the environment. This Act defines the “Environment” as including water, air and land and

interrelationship which exists among and between water, air and land and human beings, other

living creatures, plants, microorganisms and property. Hence, the scope of the EIA exercise is

broad, and should not be interpreted in a restrictive fashion, even though specific guidelines were

not issued till 2010. These guidelines also clearly underline the broad scope as indicated by its

mention that “Vehicular traffic density outside the mine lease area, existing and after beginning

of the mining activities should be given. The mode of transport of mineral and waste including

loading, unloading in mining area should also be discussed. Vehicular load must be calculated.

Further, the mineral transportation outside the mining lease area (road, rail, conveyor, rope way,

water way, pipeline etc.) may be specified.” The EIA Notification (1994) is also explicit about

ensuring truthfulness of the EIA reports stating that concealing factual data or submission of

false, misleading data/reports, decisions or recommendations would lead to the project being

rejected.

We examine the Goa EIA, EC, EMP experience on this background. We use as a checklist

the 2010 Guidelines, since these are the only guidelines issued so far. The fact that these

guidelines were not available does not justify incompleteness of information, such as complete

neglect of ore transport away from mines. It does not justify ignoring ST populations in EIAs

prepared in 2003 and beyond, as the Scheduled Caste (SC) and Scheduled Tribes (ST) Order

(Amendment) Act, 2002 had declared Velip, Gawada and Dhangar communities as STs. It does

not justify lack of information or its falsification regarding nearness to water bodies as also false

information on absence of hill streams. It does not justify ignoring National Park (NP) and

Wildlife Sanctuaries (WLS) falling within 10 km of the Protected Areas (PA) when Indian Board

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for Wildlife (IBWL) resolution of 21 January 2002 had mandated that these should be

constituted as Ecologically Sensitive Areas.

The EIAs, ECs and EMPs were found to be highly deficient in information pertaining to

major environmental parameters such as land use pattern, water resources, biodiversity,

demographic profile, dependency of people on agriculture, air quality and impact of air pollution

on the health of local people. It may be noted that ECs have been sanctioned to as many as 182

mining leases. The total production of these leases would amount to an annual removal of 70

million tonnes of ore. As the standard ore to waste/overburden is 1:3, this means the ECs

sanctioned permitted in principle the removal of some 200 million tonnes of earth in the state of

Goa every year. Obviously it is necessary to consider the cumulative environmental impacts of

such a huge turnover of soil in an ecologically sensitive area like the Western Ghats, with its

forests protected under the Wildlife (Protection) Act, 1972, Indian Forest (Conservation) Act,

1980

Neither is there a proper recognition of the impact of the large-scale mining activity on the

water regime of the area under mining which includes a substantial fraction of the water

catchment areas of the State. The Ministry of Environment and Forests (MoEF), Govt. of India

was advised by its Regional Office, Bangalore in the year 2005 not to grant environment

clearances till a proper groundwater study and impact analysis was carried out. However, mines

were permitted to continue their operations, subject to the study being done. The problem seems

to have been resolved by inappropriately referring to the ground water utilisation of the entire

taluka in which the mine was located instead of focusing on specific aquifers. Mining has been

permitted even in the catchment of the largest water reservoir of south Goa, namely, Selaulim

Dam.

Mining has substantial impacts that pervade through the entire state of Goa, impacting the

Western Ghats, the midland plateaus and the coastal regions, the land and the waters, the forests,

the agriculture and human settlements. These need to be viewed in a comprehensive and

integrated manner if the environmental impact of mining is to be properly assessed and

addressed through appropriate management measures. Such a holistic view has been lacking, and

the following important issues have been completely neglected:

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1. Loss of agricultural productivity due to [a] deposition of dust on the leaves, [b]

depletion of ground water and water supply, [c] destruction of springs and other

water sources, [d] siltation of agricultural land and orchards, [e] breaking of

estuarine Khazan land bunds due to over barge traffic movement in rivers, [f] oil

pollution of water and soil, and [g] excess iron and manganese content in water

and soil

2. Destruction of grazing resources for livestock

3. Loss of fish and shellfish productivity due to [a] turbidity in water, [b] increased

sedimentation [c] oil, iron and manganese pollution

4. Destruction of sacred groves

5. Destruction of special ecological habitats like hill plateaus (sada), and hill streams

6. Depression of productivity of forest vegetation due to air pollution and deposition

of dust layer on the leaves

7. Noise and vibrations leading to disturbance to wildlife and its movement

8. Impact on coastal fisheries of increased riverine barge traffic and of increased ore

loading points and of barge and ship movement in the coastal and offshore waters

9. Reduction in availability of land based as well as aquatic wild food to people

10. Traffic congestion and road accidents

11. Impacts of air, water and noise pollution on health Loss of employment in

fisheries, agriculture, horticulture and forestry sector

12. Social conflicts resulting from unequal distribution of economic gains, influx of

immigrants, and increased liquor sales

Furthermore, the EIAs suffer from;

1. Improper documentation of the existence of water sources within leases and

adjoining the leased boundary

2. Improper documentation of information relating to demographic profile, and

socio–economic status

3. Discrepancies with respect to actual distances between the boundaries of mine

leases and protected areas

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4. Improper documentation of the flora and fauna of the mine lease and buffer areas

5. Inadequate air, noise and water monitoring

The citizen respondents were unanimous in stating that while preparing the EIA, the

consultants have never involved the local people for any information, nor are the people aware

that such an exercise was being undertaken, and that data given in EIA relating to social,

economic aspects, to biodiversity, agriculture and demography are often not correct.

To be properly effective the Public hearings are required to be held at the project site.

However, out of 95 EIAs received for processing, 56 EIA public hearings were held in the

district headquarters of Margao and Panaji, 38 public hearings were held at taluka headquarters

in Sanguem, Quepem and Bicholim and only one public hearing actually happened at the project

site. In most of the cases, the public have raised very valid objections, but these find no mention

in the final EIAs.

An important issue in relation to compliance of conditions imposed in the ECs relates to

management of overburden dumps. It may be noted that the ECs sanctioned are often at variance

with the mining plans. While mining plans do not permit disposal of wastes outside lease areas,

some ECs permit such dumping. Often, the dumps have greater impacts than the mining

operations, so that they should have required separate proper environment clearances.

In the absence of any proper system of inspection of mines, it appears inevitable that there

has been no proper implementation of Environmental Management Plans either. While there has

been some implementation of social welfare measures, citizen respondents are unanimous in

reporting that there has been little implementation of environmental protection measures.

There are obviously serious deficiencies in the EIA, EC, EMP process and it is imperative

that we take appropriate steps to remedy these. The whole process is aimed at fulfilling the social

objectives of promoting environmentally and socially sustainable development. Hence the

process should examine any development intervention in the broader context of other on-going

development interventions and processes as also the broader environmental and socio-economic

context. It should stimulate a proper scrutiny of various possible alternatives for meeting a

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particular development objective, such as mining of iron ore or construction of a highway or

generation of thermal power, so as to lead to the selection of the most desirable alternative,

namely, one that maximizes the net gain from the development intervention, i.e. maximizes the

balance of economic, environmental, social benefits minus the economic, environmental, social

costs. If the balance is considered substantial enough to justify the intervention, the most

desirable alternative should be selected, and the project accepted while specifying due

safeguards. Otherwise, the project should be rejected. An on-going monitoring of the

consequences of the project, including environmental and socio-economic impacts should be put

into place to ensure that the stipulated safeguards are being adequately implemented. Moreover,

in real life many unforeseen impacts may materialize and the monitoring process should be so

designed as to bring these out. In order to ensure that this is properly taken into account, the

Environmental Clearances should not be once for all, but should be reviewed periodically, for

instance, every five years. The project proponents should not be permitted to make substantial

changes to the project without due environmental impact assessment of the changes proposed.

We suggest that the Ministry of Environment and Forests, Government of India working with

the Government of Goa take the following steps:

1. Empower local bodies, i.e. Gram, Taluk and Zilla Panchayats and Municipal

Councils and City Corporation to make decisions on environmental issues

2. Put in place Biodiversity Management Committees in all local bodies, fully

empowered under the Biological Diversity Act, 2002, to regulate use of local

biodiversity resources, and to charge Collection Fees

3. Initiate registration of crop cultivars as called for by Protection of Plant Varieties

and Farmers’ Rights Act, 2001, and give grants to Panchayats to build capacity

for in situ conservation of crop genetic resources

4. Implement fully the Scheduled Tribes and other Traditional Forest-dwellers

(Rights over the Forest) Act, 2006, in particular, assigning the forested

Communidad lands as Community Forest Resources and involve the Gram

Sabhas in prudent management of the biodiversity resources

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5. Reinstate the system of empowering citizens to monitor status of environment

under the environmental monitoring schemes such as Paryavaran Vahiniof

Maharashtra

6. Carry out a radical reform of Environmental Clearance (EC) process through [a]

assigning preparation of EIA statements to a neutral competent body that does not

depend on payment by project proponents, [b] making mandatory the involvement

of local Biodiversity Management Committees in the process of Environmental

Impact Assessment (EIA) preparation, [c] making mandatory taking on board all

information submitted and suggestions made during public hearings, [d] making

mandatory periodic environmental clearance requirement, preferably every five

years, [e] making mandatory involvement of local Biodiversity Management

Committees (BMCs) in the process of monitoring of implementation of conditions

laid down while granting Environmental Clearances, [f] making mandatory

preparation of regional Cumulative Environmental Impact Analyses

7. Enhance the scope of Regional Development Plans (RDP) to include key

environmental concerns and make mandatory involvement of local BMCs in the

process of preparation of Regional Plans

8. Promote full access to all pertinent information, for instance, through freely

making the currently suppressed Zoning Atlas for Siting of Industries (ZASI)

available.

9. Take action on organizing an Indian Biodiversity Information System (IBIS) in

line with the proposals before the National Biodiversity Authority since 2006.

10. Organize a public transparent, participatory database on Indian environment by

drawing on student Environmental Education projects as recommended by

Curriculum Framework Review, 2005 of the National Council for Educational

Research and Training (NCERT).

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2. Background 

2.1 Preamble 

It was Pandit Jawaharlal Nehru who set India on to a path of planned economic development.

Since the focus of our project is on guiding an important economic activity, mining, on to a path

of environmentally and socially sustainable development, we would like to begin by quoting

from his Autobiography: “I find in the Rajatarangini, the thousand-year-old Kashmiri historic

epic of the poet Kalhana, that the phrase (dharma) is repeatedly used in the sense of law and

order, something that it was the duty of the ruler and the State to preserve, is dharma and abhaya

– righteousness and absence of fear. Law was something more than mere law, and order was the

fearlessness of the people. How much more desirable is this idea of inculcating fearlessness than

of enforcing ‘order’ on a frightened populace!

In the modern day India the ‘dharma’ of the rulers must be to uphold the basic objectives and

values of the Indian Constitution, namely, Sovereignty, Socialism, Secularism, Democracy,

Republican Character, Justice, Liberty, Equality, Fraternity, Human Dignity and the Unity and

Integrity of the Nation. It was during Mrs Indira Gandhi’s premiership that the objective of

socialism was incorporated in the Constitution. Socialism, of course, does not mean opposition to

creation of wealth. As the father of Chinese economic reform Deng Xiaoping has famously

stated: “Poverty is not socialism. To be rich is glorious.” But socialism as an objective of the

Indian Constitution does stand for an end to all forms of exploitation in all spheres of our

existence. It directs the state to ensure a planned and coordinated social advance in all fields

while preventing concentration of wealth and power in few hands. Recent developments in

context of mining in Goa have certainly raised questions as to whether our Constitution is being

respected, and if the people are indeed fearless.

This contradiction is strikingly brought out by Justice Shah Commission’s (2012) Report on

Illegal Mining in Goa. The Report states that “Part IV. Section 24 of the Mines and Minerals (DR)

Act, 1957 was not observed at all and that no inspection was carried out of iron ore mines.” It

goes on to remark that “But no inspection has been carried out resulting into fear-free

environment which has caused loss to the ecology, environment, agriculture, ground water,

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natural streams, ponds, rivers, biodiversity, etc.” The fear-free environment that the Report talk

about is not one that is enjoyed by the people, but by mining industry supported by all arms of

the state. A striking example of this has been the attack on Nilesh Gaonkar, a tribal activist of

Cauvrem village in Quepem talukain May 2011(The Hindu, 2011).

In fact it was a visit by Madhav Gadgil, then a member of the Goa Golden Jubilee

Development Council to Cauvrem village and the associated mines that prompted the

Government of Goa to commission this project. The pertinent mine (TC no. 1/51 operated by Mr.

Shaikh Salim) is called the Devpan or Devdongar mine. These Konkani words mean the mine of

the Sacred Grove or the Sacred Hill. From this grove originate several springs that are a life-line

to the neighboring settlements. It transpired that EIA submitted for this mine did not record the

existence of any water-courses. A field visit confirmed that the springs did exist as reported by

the villagers and that they had been tampered with in violation of the conditions laid down while

granting the EC. In consequence a letter was addressed to Mr. Shaiks Salim (Annexure I). The

surprising reply stated that the “government land survey plans show the drainage lines within the

lease as dry (as there is no blue colour) while further downstream, beyond the lease the water

courses are shown in blue colour, which indicates that these alone are of perennial nature

(Annexure II). This is obviously mere play on words and technicalities and deserves to be

looked into more closely.

2.2 Tools of Environmental Management 

What then are the tools that we deploy as a part of our planned development to ensure that

economic activities like mining are so conducted as not to unduly deplete the capital of natural

resources or adversely impact the health and livelihoods of local communities? These include

Environmental Impact Assessments (EIA), Environmental Clearances (EC) and Environmental

Management Plans. After EC, the implementation of Air and Water Acts and Water and Cess

Act comes into play.

Environmental Impact Assessments were initiated in India in 1976-77 when the Planning

Commission asked the Department of Science and Technology to examine the river-valley

projects from an environmental angle. This was subsequently extended to cover other projects

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requiring the approval of the Public Investment Board (PIB). Till 1994, environmental clearance

from the Central Government was an administrative decision and lacked legislative support.

On 27 January 1994, the Union Ministry of Environment and Forests (MoEF), Government

of India, under the Environmental (Protection) Act 1986, promulgated an EIA notification

making Environmental Clearance (EC) mandatory for expansion or modernization of any

activity or for setting up new projects listed in Schedule 1 of the notification. Since then there

have been 12 amendments made in the EIA notification of 1994, the latest amendment dates

from December 2009(Annexure III). This notification makes it mandatory for various projects

such as mining, thermal power plants, river valley, infrastructure (road, highway, ports, harbours

and airports) and industries including very small electroplating or foundry units to get

environment clearance.

The EIAs coupled to public hearings are meant to bring to notice avoidable negative

environmental impacts, so that the projects may be reformulated in ways that may avoid them, or

rejected in case the negative environmental impacts, including socio-economic impacts are of

such large magnitude that they outweigh positive benefits of the mining activities. The ECs

stipulate conditions to ensure that adverse environmental impacts are strictly avoided, and EMPs

to ensure good environmental management during the conduct of the project. The monitoring of

environmental parameters is meant to ensure that conditions of EC are being fulfilled and EMPs

are being actually implemented.

Following the EIA Notification 2006 and subsequent amendment in 2009, it was considered

necessary by MoEF to make available EIA guidance manuals for the various development

sectors. Accordingly, at the instance of the MoEF, the Administrative Staff College of India

(ASCI), Hyderabad, with the assistance of experts, undertook the preparation of sector specific

Terms of Reference (TOR) and specific Guidance Manuals for Mining of Minerals. These

manuals provide the most up-to-date guidelines for the whole process, and the investigations

undertaken as a part of this project are primarily based on these manuals (ASCI, 2010).

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2.3 Environmental Regulations pertaining to Mining 

The objective of EIA exercise mandated under the Environment (Protection) Act 1986 is to

protect the environment. This Act defines the “Environment” as including water, air and land and

interrelationship which exists among and between water, air and land and human beings, other

living creatures, plants, microorganisms and property. Hence, the scope of the EIA exercise is

broad, and should not be interpreted in a restrictive fashion, even though specific guidelines were

not issued till 2010. These guidelines also clearly underline the broad scope as indicated by its

mention that “Vehicular traffic density outside the mine lease area, existing and after beginning

of the mining activities should be given. The mode of transport of mineral and waste including

loading, unloading in mining area should also be discussed. Vehicular load must be calculated.

Further, the mineral transportation outside the mining lease area (road, rail, conveyor, rope way,

water way, pipeline etc.) may be specified.”

The EIA Notification (1994) is also explicit about ensuring truthfulness of the EIA reports.

Concealing factual data or submission of false, misleading data/reports, decisions or

recommendations would lead to the project being rejected. Approval, if granted earlier on the

basis of false data, would also be revoked. Misleading and wrong information will cover the

following:

False information

False data

Engineered reports

Concealing of factual data

False recommendations or decisions

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2.4 Goan experience 

We examine the Goa EIA, EC, EMP experience on this background. We use as a checklist

the EIA Guidance Manual of Mining of Minerals, 2010 developed by ASCI, since these are the

only guidelines issued so far. The fact that these guidelines were not available does not justify

incompleteness of information, such as complete neglect of ore transport away from mines. It

does not justify ignoring ST populations in EIAs prepared in 2003 and beyond, as the Scheduled

Castes and Scheduled Tribes Order ( Amendment) Act, 2002 published in Gazette of India dated

8th January 2003, Extraordinary, Part II, had declared Velip, Gawada and Dhangar communities

as STs. It does not justify lack of information or its falsification regarding nearness to water

bodies as also false information on absence of hill streams. It does not justify ignoring National

Parks and Wildlife Sanctuaries falling within 10 km of the PAs when Indian Board for Wildlife

(IBWL) resolution of 21 January 2002 had mandated that these should be constituted as

Ecologically Sensitive Areas (ESA).

2.4.1 Illegalities in the Mining Sector 

It is pertinent to note that there is substantial evidence of illegalities in the activities of the

mining sector in Goa. According to the report of the Public Accounts Committee (PAC) headed

by Shri Manohar Parrikar, the then Opposition Leader, filed in 2011, almost half of the active

iron ore mines in the State of Goa were illegal and had caused an estimated loss of Rs 3,000

crore to the exchequer since 2005. Subsequently, the Government of India, Ministry of Mines

appointed a Commission of Inquiry headed by Justice Shah to inquire into the illegalities of

mining activities in Mining states in India including Goa. This Commission notes the following

type of irregularities:

1. Granting of leases in eco-sensitive zones

2. Granting of leases without following the prescribed procedure of environmental clearances

3. Operation of mines without fulfilling the conditions stipulated in environmental clearances or

adopting adequate measures for mitigating adverse impacts on humans and the environment

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Justice Shah Commission and the Centrally Empowered Committee (CEC) appointed by the

Supreme Court to recommend follow up action has recorded many serious issues pertinent to

environmental clearances, management and monitoring in the mining sector. These include:

1. Environmental clearances granted for the mining leases located within the National Parks

/ Wildlife Sanctuaries.

2. Mining leases located within 1 km from the National Parks / Wildlife Sanctuaries.

3. Mining leases located within 10 kms from the boundaries of the nearby national parks /

wildlife sanctuaries.

4. Mining leases being operated in flagrant violation by persons other than the Lessees.

5. Complete lack of control on production and transportation of mineral from the mining

leases, illegal mining and over-burden dumps outside the lease areas and associated

issues.

6. Illegal mining by way of illegal mining pits and illegal over burden dumps outside the

sanctioned lease areas.

7. Production of iron ore beyond the permissible quantities by the mining lease holders.

8. Infrastructure inadequacies for the present level of mining.

Indeed, the Justice Shah Commission has recorded that: “Part IV. Section 24 of the Mines

and Minerals (DR) Act, 1957 was not observed at all and that no inspection was carried out of

iron ore mines.” It goes on to remark that “But no inspection has been carried out resulting into

fear-free environment which has caused loss to the ecology, environment, agriculture, ground

water, natural streams, ponds, rivers, biodiversity, etc.”

 

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3. The setting 

Goa is India’s smallest state by area and the

fourth smallest by population. It is renowned for

its world heritage architecture, places of worship,

beaches, and is endowed with a rich flora and

fauna owing to its strategic location on the

Western Ghats. These Western Ghats have been

recognized as one of the mega biodiversity

hotspots of the world. Geographically, the state

of Goa covers a total area of about 3,702 square

kilometers and has a coastline of 105 kms.

Topographically, three distinct zones may be

identified – the Western Ghats, the mid-upland

region, and the coastal plain. Almost about 43%

of Goa’s geographical area comprising of Sattari,

Sanguem, Dharbandora and Canacona talukafalls

in the Western Ghats. The main peaks in the Western Ghats in Goa are Sosogod (1166 meter),

Catlanchimauli (1066 meter), Vaguerim (1066 meter) and Morlemchogod (1036 meter), all in

Sattari taluka. Between the Ghats and the coast lies Goa’s hinterland comprising of Ponda,

Bicholim, Pernem and Quepem. These are mostly lateritic plateaus ranging in elevation from 30

to 100 m and forming about 35% of the total geographical area of Goa. The coastal plain

consisting of estuaries, khazan lands and mangroves constitutes about 22% of the geographical

area and falls in the talukas of Bardez, Tiswadi, Marmugoa and Salcette.

Goa has nine major rivers, all of which, except the Sal in South Goa, originate on the

Western Ghats and subsequently meander over falls and rapids (during young/initial stage), from

where they tend to become sluggish (during mature stage) and then ultimately form the mouths

of estuaries and drain into the sea (old stage). Most of these rivers are subject to tidal variations

and salinity upto a distance of 20-40 kms upstream from their respective estuarine mouth

regions. Most of these rivers are excellent navigational channels used extensively for

Map I Goa Vegetation Map (Source: Goa Forest Department

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transporting ore through barges from ore loading jetties to Mormugoa harbour for onwards

export.

Many of Goa’s tidal rivers are flanked on either banks with mangroves that thrive on the

saline soils and provide a unique habitat for birds and marine life. The inland areas – the khazan

lands – are those reclaimed through the construction of bunds or embankments. These support

brackisn water paddy cultivation as well as fish and shrimp production.

The State has rich forests spread over of 1,224 sq. km, covering 33.06% of its geographical

area. Of this, the reserve forest constitutes 20.67%, protected forest 69.04% and un-classified

forest 10.29% of the total forest area. The entire stretch of forests in the Western Ghats in Goa

have been classified as National Park/Wildlife Sanctuaries. There is one National Park and Six

Wildlife Sanctuaries covering an area of 107 Sq. km and 648 Sq. km respectively. Rice, pulses,

and finger millet (ragi), are the main food crops cultivated in the State. Rice cultivation covers

about 47,237 ha. Other main cash crops include coconut, cashewnut, arecanut, and sugarcane,

and fruits such as pineapple, mango, jackfruit, and banana.

3.1Mining in Goa 

Nearly half the iron ore exported from India comes

from Goa. Such minerals-rich rocks, largely in forested

hilly areas, trend along north-west- south-east direction.

Although, the occurrence of iron and manganese was

known in the early 1900s, the Portuguese government

started allocating concessions to private entrepreneurs for

the recovery of mineral ores from the 1940s. Over 800

concessions were granted by the Portuguese government

to private entrepreneurs covering an area of about 660 Sq.

km, that is around 16% of total geographical area of the

state of Goa. Most of the concessions given were less

than 100 ha. After World War II, the demand from Map II Mining Sites in Goa: (Source Goa; Sweet Land of Mine)

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The Iron-Manganese bearing mineral-rich belt of Goa is located mainly in Bicholim, Sattari,

Sanguem, Dharbandora and Quepem talukas

covering approximately 700 sq. km. The mining

belt is divided into the northern, central, and

southern zones. The Usgao river divides the

northern and central zones and the Sanguem

river divides the central and southern zones. The

largest tract of land under mining is in Sanguem,

followed by Bicholim, Sattari and Quepem

talukas.

The mining operations in Goa are open-cast

type of mining. Open-cast mining is done by the

cutting of benches of regular heights on the tops

and slopes of hills. The pits are laterally extended

in a gradual manner in all directions with increasing depth. Bench height and width are generally

maintained at 7m and 10m. The configurations of each pit are pre-planned such that the overall

pit slopes remain at 30° with the horizontal (i.e. angle of repose). An important feature of such

type of open-cast mining operations is the high overburden to ore ratio, which requires a large

volume of ore to be handled and extensive sites for discarding rejects.

Mining operations generally follow the following sequence:

1. Systematic removal of lateritic overburden

2. Dozing and ripping are used to remove soft laterite

3. Drilling and blasting are employed for removal in hard laterite. Extraction of ore initially

from the lumpy ore zone, followed subsequently from powdery ore zone.

4. Wet or dry processing of the mined material to attain the desired cut-off grade.

    

Map III Talukawise Mining Operation Sites (Source: Mineral Foundation of Goa)

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3.2 Land Use pattern 

Goa is dominated by forests and paddy fields.

(Table 1 Land use pattern of Goa (Source: RPG-21 Draft Regional Plan for Goa-2021)

Land use categories Area in

Sq. kms

% of total

Forest (Proected/reserved/national Park/Wildlife Sanctuaries ) 1315.25 35.528

Mangrove forest 5.64 0.15

Private forest 44.99 1.22

Waterbodies 196.80 5.32

Paddy fields/khazan lands 431.61 11

Orchard 842.99 22.77

Cultivable land 123.08 3.32

Salt pans 2.34 0.06

Fish farm/mud flats 4.92 0.13

Settlement 526.31 14.22

Industrial 41.96 1.13

Transport 150.88 4.08

Miscellanious 15.22 0.41

Total 3702 100

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The mining activities are mainly confined to four talukas in the state of Goa (now

Dharbandora has been an additional taluka), they are, Quepem, Sanguem, Dharbandora,

Bicholim and Sattari. However there are few mines also located in the talukas of Bardez and

Ponda too. The land use pattern of these talukas is as follows. The mining leases along with their

TC numbers and area in ha for all following mentioned talukas is attached in Annexure No. IV, V,

VI, VI, VII VIII and IX.

3.2.1 Sanguem taluka 

Map IV Sanguem taluka land use map (source

savegoa.com)

 

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3.2.2 Landuse of Sanguem taluka 

 

   

           

3.2.3 Quepem taluka 

Land use categories Area in

Sq. kms

% of taluka

total

Forest (Proected/reserved/national Park/Wildlife

Sanctuaries )

570.47 68.17

Mangrove forest 0 0

Private forest 15.78 1.89

Waterbodies 38.79 4.63

Paddy fields/khazan lands 21.31 2.56

Orchard 149.58 17.87

Cultivable land 3.32 0.40

Salt pans 0 0

Fish farm/mud flats 0 0

Settlement 27.88 3.33

Industrial 0.87 0.10

Transport 7.15 0.85

Miscellaneous 1.60 019

Total 836.82 100 Table II Sanguem taluka land use pattern (Source; RPG-21 Draft regional plan for Goa 2021)

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Map V Quepem taluka land use map (Source; savegoa.com)

3.2.4 Land use of Quepem Taluka 

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3.2.5 Bicholim taluka 

Table III Quepem taluka land use pattern (Source; RPG-21 Draft regional plan for Goa 2021)

Land use categories Area

in Sq. kms

% of

taluka

total

Forest (Proected/reserved/national Park/Wildlife Sanctuaries ) 101.58 31.92

Mangrove forest 0 0

Private forest 3.49 1.10

Waterbodies 5.76 1.81

Paddy fields/khazan lands 37.13 11.67

Orchard 132.03 41.48

Cultivable land 8.54 2.68

Salt pans 0 0

Fish farm/mud flats 0 0

Settlement 21.74 6.83

Industrial 2.56 0.81

Transport 4.55 1.43

Miscellanious 0.87 0.27

Total 318.25 100

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Map VI Bicholim taluka land use map (Source; savegoa.com)

3.2.6 Land use of Bicholim Taluka 

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3.2.7 Sattari taluka 

Land use categories Area in

Sq. kms

% of

taluka

total

Forest (Proected/reserved/national Park/Wildlife Sanctuaries ) 12.20 5.11

Mangrove forest 0.12 0.05

Private forest 0.06 0.03

Waterbodies 5.70 2.39

Paddy fields/khazan lands 31.34 13.12

Orchard 119.43 50.01

Cultivable land 25.65 10.74

Salt pans 0 0

Fish farm/mud flats 0.73 0.31

Settlement 30.59 12.81

Industrial 4.75 1.99

Transport 5.12 2.15

Miscellanious 3.10 1.30

Total 238.80 100

Table IV Bicholim taluka land use pattern (Source; RPG-21 Draft regional plan for Goa 2021)

 

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Map VII Sattari taluka land use map (Source; savegoa.com)

3.2.8 Landuse of Sattari taluka 

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3.2.9 Bardez taluka 

Land use categories Area in

Sq. kms

% of

taluka

total

Forest (Proected/reserved/national Park/Wildlife Sanctuaries ) 278.40 56.88

Mangrove forest 0 0

Private forest 8.88 1.81

Waterbodies 12.36 2.52

Paddy fields/khazan lands 22.27 4.55

Orchard 118.11 24.13

Cultivable land 15.16 3.10

Salt pans 0 0

Fish farm/mud flats 0 0

Settlement 20.82 4.25

Industrial 2.45 0.50

Transport 9.81 2

Miscellanious 1.20 0.25

Total 489.46 100

Table V Sattari taluka land use pattern (Source; RPG-21 Draft regional plan for Goa 2021)

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Map VIII Bardez taluka land use map (Source; savegoa.com) 

3.2.10 Landuse of Bardez Taluka 

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Land Use categories Area in Sq.

kms

% of

taluka total

Forest (protected/reserve/national

park/wildlife sanctuary

0 0

Mangrove Forest 2.90 1.10

Private Forest 4.66 1.76

Water bodies 25.10 9.51

Paddy fields/Khazan lands 60.61 22.96

Orchard 44.16 16.73

Cultivable Land 13.67 5.18

Salt Pans 0.53 0.20

Fish farm/mudflats 1.20 0.45

Settlements 94.15 35.67

Industrial 2.27 0.86

Transport 10.77 4.08

Miscellaneous 3.96 1.50

Total 263.97 100

Table VI Bardez taluka land use pattern (Source; RPG-21 Draft regional plan for Goa 2021)

 

 

 

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3.2.11Ponda taluka 

 

Map IX Ponda taluka land use map (Source; savegoa.com)

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3.2.12Landuse of Ponda Taluka Land Use categories Area in Sq.

kms

% of taluka

total

Forest (protected/reserve/national park/wildlife

sanctuary

53.69 18.34

Mangrove Forest 0.195 0.07

Private Forest 0.92 0.31

Water bodies 7.82 2.67

Paddy fields/Khazan lands 29.69 10.14

Orchard 130.25 44.49

Cultivable Land 3.32 1.13

Salt Pans 0.00 0.00

Fish farm/mudflats 0.00 0.00

Settlements 46.00 15.71

Industrial 13.13 4.48

Transport 5.90 2.01

Miscellaneous 1.87 0.64

Total 292.78 100

Table VII Ponda taluka land use pattern (Source; (Source; RPG-21 Draft regional plan for Goa 2021)

 

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4. Mining Impacts: potential and actual 

Mining has substantial impacts that pervade

through the entire state of Goa, impacting the

Western Ghats, the midland plateaus and the

coastal regions, the land and the waters, the

forests, the agriculture and human settlements.

These need to be viewed in a comprehensive and

integrated manner if the environmental impact of

mining is to be properly assessed and addressed

through appropriate management measures. Such

a

holistic

view

has

been

lacking,

and we attempt to provide below a check-list of 35

items, along with an indication of available, regrettably

rather scanty, evidence. The numbers in the brackets

after each item refer to the serial number of other items

to which it is closely linked. Thus item number (1), air

pollution is linked to item number (10), deposition of

dust on the leaves and loss of agricultural productivity

and item no (26), depression of productivity of forest

vegetation due to air pollution and deposition of dust

layer on the leaves and so on.

Map X Location of mines near water bodies

Map XI Mining leases located near Protected Area (Source; Goa; Sweet Land of

Mine

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1. Air pollution, increased dust content in the air [10, 26, 34]

Air pollution is

recognized as a significant

issue and monitoring of air

pollution levels is mandatory

as a part of EIA preparation,

EMPs, as well as

Environmental Monitoring

(EMn) programmes. However,

the attention is focused on

mining lease site. Air pollution does occur at sites of overburden dumps, and very significantly

during ore transport. The latter often takes place in overloaded trucks and trucks not adequately

covered with tarpaulin. The air pollution certainly impacts agricultural and forest productivity.

Since the trucks may ply through inhabited areas, this has grave health consequences as well.

While air pollution monitoring stations are set up, the location of the stations is not properly

indicated in EIA documents. It is likely that these stations are positioned in such a way that they

do not bring out actual impacts. Furthermore people have expressed doubts about the

genuineness of the air monitoring effort.

2. Lowering of ground water level [11]

A very large fraction of the

mines have been operating below

the level of the water table, thereby

sucking away water from drinking

water and irrigation wells, many of

which have dried up (NEERI,

2009). The MOEF was advised by

its Regional Office in the year

Map XII Sketch depicting impact of ore transport and dust onsurrounding areas

Map XIII Sketch depicting impact of mining on the water table and ground water aquifer

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2005 not to grant environment clearances till a proper groundwater study and impact analysis

was carried out. However, mines were permitted to continue their operations, subject to the study

being done. The studies that followed appear to be highly defective failing to note serious

problems of water scarcity already emerging in areas like Pissurlem and Shirgao. In none of

these cases, was any follow up done of the water situation as required by the study itself. The

problem seems to have been resolved by inappropriately referring to the ground water utilization

of the entire taluka in which the mine was located instead of focusing on specific aquifers.

Mining has been permitted even in the catchment of the largest water reservoir of south Goa,

namely, Selaulim Dam. By and large, this significant impact is almost totally ignored in EIA and

EMP and EMn process. The Water Resources Department of the state government ought to

actively monitor this parameter; it seems to have never done so.

3. Drying up of springs and other water courses on the hills [12, 25]

Most mines are located on flat hill tops that are the source of springs sustaining the

agriculture, horticulture and settlements on the slopes and the valleys. The very existence of

these tends to be denied in EIAs with no appropriate provisions in EMPs. The Water Resources

Department of the state government ought to actively monitor this parameter; it seems to have

never done so.

4. Siltation & shallowing of streams, river beds and estuaries [5, 13, 19]

The ore to overburden ratio is roughly 1:3. Thus, for every ton of ore excavated three tons of

overburden material is generated. This

material is piled into steep and high

dumps. Poor dump management coupled

with the heavy monsoons experienced in

Goa results in large-scale soil erosion

from these dumps. This silt-laden water

enters the drainage network and also

enters adjacent low-lying paddy fields

resulting in the accumulation of silt in Photo I Siltation in water body (Photo; Ramesh Gauns)

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fields and water bodies (TERI 2002). The runoff from the overburden dumps, the pit water

discharge and the tailing pond overflow together imposing substantial sediment loads on

river/streams/nallahs. The worst affected rivers are Bicholim, Mhadei, and Khandepar. Some of

the mines have dumps right on the river banks from which there is runoff directly into the rivers

during the monsoon (TERI, 1997).This significant impact is completely ignored in EIA and EMP

and EMn process. The Water Resources Department of the state government ought to actively

monitor this parameter; it seems to have never done so.

5. Change in the flow of water in the river and increased floods

The serious havoc caused by floods of Bicholim river in 1981 was attributed by people to

siltation from the mines. Gauns (2012) reports of serious levels of siltation of Khandepar, Kudem

rivers, and lakes at Mulgao and Lamgao in Bhicholim. This significant impact is completely

ignored in EIA and EMP and EMn process. The Department of Water Resources of the state

government ought to actively monitor this parameter; it seems to have never done so.

6. Formation of waves due to barge movements [14, 22]

Large quantities of ore have been transported on river barges to the ships waiting off the

coast. These are reported to cause waves during their movments. This significant impact is

completely ignored in EIA and EMP and EMn process. The Captain of the Ports of the state

government ought to actively monitor this parameter; it seems to have never done so.

7. Increased water turbidity [18]

The runoff from the overburden dumps, the

pit water discharge and the tailing pond

overflow together bring in substantial sediment

loads into river/streams/nallahs and reportedly

make the water turbid. This significant impact

is completely ignored in EIA and EMP and

EMn process. The State Pollution Control

Board ought to actively monitor this Photo II Increased water turbidity and siltation in

river (Photo; Ramesh Gauns

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parameter; it seems to have never done so.

8. Increased nitrate, iron and manganese content [16, 20]

The runoff from the overburden dumps, the pit water discharge and the tailing pond overflow

together add substantial amounts of iron and manganese to river/streams/nallah waters. Mining

rejects also act as a source of nitrate to the estuary. Large quantities (10 tonnes per month) of

ammonium nitrate, used for rock blasting, are discharged in to the river, and carried both

upstream and downstream by tidal currents (de Sousa, 1999). These significant impacts are

completely ignored in EIA and EMP and EMn process. The State Pollution Control Board ought

to actively monitor this parameter; it seems to have never done so.

9. Oil pollution [15, 21]

The barges transporting ore in the rivers and the transport ships in the coastal waters are

reportedly responsible for oil pollution. This significant impact is completely ignored in EIA and

EMP and EMn process. The State Pollution Control Board ought to actively monitor this

parameter; it seems to have never done so.

10. Deposition of dust on the leaves and loss of agricultural productivity [1]

Substantial amount of dust generated by mining operations and ore transport gets deposited,

especially on leaves of horticultural crops leading to lowering of photosynthesis and pollination.

As a result it has been reported that yields of cashew, mango and arecanut, have been drastically

affected (Velip and Nilesh Goankar, 2012, Naik and Madhu Goankar, 2012). This significant

impact is completely ignored in EIA and EMP and EMn process. The State Agriculture

Department ought to actively monitor this parameter; it seems to have never done so.

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11. Depletion of ground water and water supply to agricultural farmlands and orchards and loss of agricultural productivity [2]

NEERI (2009) has documented the

correlation of fracture of ground water table

by mining and lowering of the water table of

nearby village wells, which has affected

availability for domestic use and agriculture

in Shirgao. The mining activity adjoining

Pissurlem has dried its entire ground water

and fields are completely silted (Parab,

2012). The Advoi nalha which flows from

the dumping site of M/s Sesa Goa has been blocked and has changed the course of its flow

(Dessai, 2012). Due to mining activities, there is depletion of ground water in the wells, and

Kulaghars are suffering from scarcity of water, nor is vaingan (Rabi crop) cultivation practiced

in mining affected areas (Velip, 2011 and Dessai, 2012). Large tracts of crop-land is being

converted into play ground due to non cultivation ( NileshGoankar, 2011). Although the mines

do provide routine hydrogeological studies, this significant impact is ignored in EIA and EMP

and EMn process. The State Agriculture Department ought to actively monitor this parameter; it

seems to have never done so.

12. Destruction of springs and other water sources and consequent disruption of irrigation to farms and orchards and loss of agricultural productivity [3]

A large number of springs fall in

the buffer/core zone of the mining

sites in villages like Colamb,

Caurem, Rivona, Dabal and Surla

(Velip, 2011). Caurem village is

entirely dependent on the water

being supplied by the spring that

originates in Devapann hill (Nilesh

Photo III Impact of siltation on agriculture land and on the surrounding areas

Photo IV Impact of silt on the Kulaghars (Photo; Ramesh Gauns)

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Gaokar, 2011). Rivona, known for its agriculture and Kulaghars, is dependent on the natural

springs originating in the hills adjacent to the village. Kushavati river, which is considered holy,

has numerous seasonal/ perennial tributary nallahs which make it perennial. It feeds large tracts

of agriculture land along its length (Patil, 2012). In Pissurlem, Advoi and Shirgao springs are the

major source of water for irrigation and domenstic uses (Dinanath Gaonkar, 2012). The sacred

pond in Shirgao gets water from a spring that originates in the hills adjoining it. Due to mining

adjacent to this pond, little water is stored in the holy pond (Gauns, 2012). This significant

impact is completely ignored in EIA and EMP and EMn process. The State Hydrogeology and

Agriculture Departments ought to actively monitor this parameter; they seem to have never done

so.

13. Siltation of agricultural land and orchards loss of agricultural productivity [4]

Waters, laden with silt from the

mines, extensively impact agriculture

and horticulture in Goa. The runoff from

dumps has affected 320 ha of

agricultural land in mining affected areas

due to silting (TERI, 1997). Rejects/

Over burden (OB) dumps normally

attain much more height than what has

been permitted in EC, ie, 30 m. The

gradient of dumps also goes far beyond

the permissible 28˚-30˚ to 60˚-70˚.

Because of such a geological structure, the over burden and waste material are carried with

monsoon run off into the downward areas. This causes siltation of springs, tanks, lakes, rivers,

paddy fields, areca nut plantations etc. There is a serious siltation problem at Khandepar, Kudem

rivers, lakes at Mulgao, lake at Lamgao in Bhicholim. Siltation of river Bicholim led to floods in

1981 and havoc. In south Goa, Kushavati river and the Selaulim Dam have had high siltation. In

villages like Sirigao, Kothambi, Mulgao, Surla etc the paddy fields and plantations have been

affected with siltation (Gauns, 2013). The Panjim Bench of Bombay High Court had directed

Photo V Siltation in agriculture land (Photo; Dessai)

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that mining companies should deposit compensation amount of over Rs 3.6 crores before August

30, 2007. This compensation is for the 761 aggrieved farmers in Surla village, North Goa, whose

fields have been destroyed due to mining activities (Alvares, 2002).

This significant impact is completely ignored in EIA and EMP and EMn process. The State

Water Resource and Agriculture Departments ought to actively monitor this parameter; they

seem to have never done so.

14. Breaking of estuarine Khazan land bunds due to over barge traffic movement in rivers leading to loss of agricultural productivity [6]

Premanand Mhambre(2011), a retired school principal in Chorao, reports that the waves

created due to the movement of barges in the Mandovi and Zuari rivers are responsible for

breaking of bunds along the river banks which have been built to prevent the ingress of salt water

into the fields. This problem is especially acute in Chorao where several farmers have to deal

with salt water in their fields. Young seedlings of the mangrove Rhizophora are broken by the

boats passing through the plantation (Hong, 1996. Rajiv Kumar Extn Division, FRI Dehra Dun

as cited by Alvares and Saha 2008).This significant impact is completely ignored in EIA and

EMP and EMn process. The State Hydrogeology and Agriculture Departments ought to actively

monitor this parameter; they seem to have never done so.

15. Loss of agricultural productivity due to oil pollution of water and soil [9]

Mines related oil pollution reportedly adversely impacts agricultural production. This

significant impact is completely ignored in EIA and EMP and EMn process. The State Pollution

Control Board and Agriculture Department ought to actively monitor this parameter; they seem

to have never done so.

16. Loss of agricultural productivity due to excess iron and manganese content in water and soil [8]

Mines related iron and manganese pollution reportedly adversely impacts agricultural

production. This significant impact is completely ignored in EIA and EMP and EMn process.

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The State Pollution Control Board and Agriculture Department ought to actively monitor this

parameter; they seem to have never done so.

17. Destruction of grazing resources for livestock

Hill tops where mining is concentrated traditionally provided good grazing grounds for

village cattle. For instance, the Devapann dongor is traditionally used by locals for cattle grazing.

Due to commencement of mining uphill in Devpann Dongor, the mines management is not

allowing the locals to use that land for grazing animals (Velip, 2011). Since there is no grazing

land left in the village vicinity, Pissurle villagers are not maintaining livestock (Parab,

2012).This significant impact is completely ignored in EIA and EMP and EMn process. The

State Animal Husbandry Department ought to actively monitor this parameter; it seems to have

never done so.

18. Turbidity in water, impact on photosynthesis and plant productivity, as well as productivity of filter feeding crustaceans in streams, rivers and khajan lands [7]

The aquatic life in Mandovi and Zuari is reportedly impacted due to increase in the turbidity.

A farmer from Khandola, Shri Madhu Gaonkar, has reported (2013) that they used to face

problem of fish catch due to turbidity of water in the Mandovi river while mining was in

operation, However, now in the period on ban on mining, there seems to be an increase in the

fish catch and also the diversity of fish available for the human consumption. This significant

impact is completely ignored in EIA and EMP and EMn process. The State Pollution Control

Board and Fisheries Department ought to actively monitor this parameter; it seems to have never

done so.

19. Increased sedimentation and choking of bottom dwelling shell fish and other organisms in streams, rivers and khajan lands [4]

Benthic fauna like clams in Mandovi and Cumbarjua canal estuarine system of Goa has been

severely affected by massive inputs of mining rejects and the resulting environmental stress has

caused irreversible ecosystem instability. Reduced dissolved oxygen concentration; high

suspended solids and blanketing of bottom deposits by mining rejects, has resulted in more than

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70% reduction in clam production; near extinction of resident fauna and the appearance of a low

diversity bottom fauna, comprising of tolerant but vagrant species (Parulekar, Ansari and Ingole,

1986) . A total of 10 surface sediment samples were collected in the pre-monsoon season in 1990

from the Mandovi estuary, Goa, India. Study revealed presence of 14 species of foraminifera.

The foraminiferal data is of special significance because the same can be compared with

foraminiferal data of Rao (1974) based on the samples collected in 1972 from the same area. The

study reveals that during 18 years total foraminiferal number (TFN) came down considerably (2

to 42 specimens/gm in 1990 as compared to 10 to 139specimens/gm in 1972). Similarly, total

species number (TSN) also declined from 18 (in 1972) to 14 (in 1990). It is postulated that

decline in fauna is due to continuously increasing suspended load (2-4 mg/l in 1972, 4.5 – 8 mg/l

in 1982 and 6.69 – 114.49 mg/l in 1990) in the estuary (Nigam, Nayak & Naik 2002). This

significant impact is completely ignored in EIA and EMP and EMn process. The State Pollution

Control Board and Fisheries Department ought to actively monitor this parameter; they seem to

have never done so.

20. Iron and manganese pollution impact on aquatic organisms in streams, rivers and khajan lands [8]

Bivalves such as Crassostrea gryhoides (Oysters) and Paphia malabarica (Venerid clams)

are an important part of the diet of the coastal Goan community. However, mining along Goa’s

rivers is causing metal seepage into the aquatic environment. This has raised concern for human

health, as well as aquaculture (MFF, 2011). This significant impact is completely ignored in EIA

and EMP and EMn process. The State Pollution Control Board and Fisheries Department ought

to actively monitor this parameter; they seem to have never done so.

21. Oil pollution impact on aquatic organisms in streams, rivers and khajan lands [9]

Barges carrying mine ore along rivers leads to oil pollution that has reportedly adversely

impacted aquatic organisms. This significant impact is completely ignored in EIA and EMP and

EMn process. The State Pollution Control Board and Fisheries Department ought to actively

monitor this parameter; they seem to have never done so.

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22. Disturbance to aquatic animals due to waves created by barge movements in streams, rivers and khajan lands [6]

Barges carrying mine ore along rivers create huge waves, and this has reportedly adversely

impacted aquatic organisms. This significant impact is completely ignored in EIA and EMP and

EMn process. The State Pollution Control Board and Fisheries Department ought to actively

monitor this parameter; they seem to have never done so.

23. Destruction of biodiversity rich forest vegetation

2500 ha of forest land were lost to mining in the period between1988-1997. No studies to

assess the loss in forest area have been done since then. Biodiversity loss associated with the

land use and cover change resulting from mining operation in the region is very serious

(WGEEP, 2012). Temporal analysis of visually interpreted land-use/land-cover maps, based on

aerial photograph and satellite images, revealed the increase in the spread of mining area and

built-up land at the expense of vegetation cover over the past sixteen years(1973-1989) (IIT,

Mumbai 1997)

Mining leases are chiefly located in or close to the Western Ghats, which therefore bear the

brunt of environment degradation in the form of destruction of forests, disruption of wildlife

habitats, damage to flora, depletion of water sources and altering of the natural landscape.

Wildlife-human conflicts are also seeing an unprecedented spurt, indicating disturbance of

wildlife habitats (Alvares, 2011). This has threatened the Bhagwan Mahaveer Wildlife

Sanctuary, Mollem National Park, Bondla Wildlife Sanctuary, Netravali Wildlife Sanctuary,

Mhadei Wildlife Sanctuary and Cotigao Wildlife Sanctuary (WII as cited by Claude Alvares and

Reboni Saha, 2008).Velip (2011) of Cauvrem village in Quepem reports that due to destruction

of wildlife habitat, wild animals are invading into the villages creating man and animal conflict.

Monkey menace is increasing. All the banana plants are being destroyed by the monkeys (Velip,

2011).

This significant impact has not been paid adequate attention in EIA and EMP and EMn

process. The Forest Department ought to actively monitor this parameter; however, they have

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been lax, and as reported by the Shah Commission have been guilty of according improper

Forest Clearances.

24. Destruction of sacred groves

Sacred groves is a very significant traditional conservation practice and a large number of

such groves that are a rich repository of biodiversity have been recorded from the forests in the

talukas of Sanguem, Sattari, Quepem and Canacona. Several of these are close to the mines and

have in consequence suffered disturbance. For instance, the Devpan mine of Quepem taluka has

affected the grove of Kashi Purush, the Kuldev of the village Caurem (Velip, 2011). A partial list

of these has been compiled by Rajendra Kerkar (2012)(Annexure X)

The impact on sacred groves is completely ignored in EIA and EMP and EMn process. The

State Wild Life and Biodiversity Boards and Forest Department ought to actively monitor this

parameter; they seem to have never done so.

25. Destruction of special habitats like hill plateaus (sada), hill streams [3]

Most of the mines are located on hill plateaus or sadas that appear to be areas scantily

covered by scrub and grass in the dry season, but are a rich repository of rare and endangered

herbs that carpet them with most attractive floral displays during the monsoon. A floristic survey

of endemic plants of the Western Ghats in Goa resulted in the collection of 113 endemic species.

Plateaus in the study area harbour the largest proportion of these endemic species, especially

herbs (Joshi and Janarthanam, 2004). The hill streams of Western Ghats are also rich in

endemic species of freshwater fishes. Both these special habitats have been seriously impacted

by mining. However, this significant impact is completely ignored in EIA and EMP and EMn

process. The State Wild Life and Biodiversity Boards and Forest Department ought to actively

monitor this parameter; they seem to have never done so.

26. Depression of productivity of forest vegetation due to air pollution and deposition of dust layer on the leaves [1]

Mines of Goa are all close to forested areas, some even encircled by WLS and NP. Large

amounts of dust are therefore deposited on forest vegetation and visual observations certainly

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suggest significant depression in forest productivity as well as possible increase in mortality

because of this factor. However, this significant impact is completely ignored in EIA and EMP

and EMn process. The State Wild Life and Biodiversity Boards and Forest Department ought to

actively monitor this parameter; they seem to have never done so.

27. Noise and vibrations leading to disturbance to wildlife and its movement

Mines of Goa are all close to forested areas, some even encircled by WLS and NP. Indeed, it

is to be noted that a number of mining leases have been granted ECs in violation of the fact that

they are located within 10 km zone of the National Parks/Wildlife Sanctuariesin violation of the

clear recommendation of to the contrary of the Indian Board of Wild Life in 2002. Lot of noise is

therefore generated during mining operations and ore transport and reportedly leads to significant

disturbance to wild life. However, this significant impact is completely ignored in EIA and EMP

and EMn process. The State Biodiversity Board and Forest Department ought to actively monitor

this parameter; they seem to have never done so.

28. Impact on coastal fisheries of increased barge traffic in rivers

After the recent mining boom, the number of barges carrying ore in the rivers has increased

to almost double to what it was a few years ago. The consequent slippage of ore, along the

Mandovi river bed, had made the river shallow and reduced the navigation channel to a bare few

dozen meters in width (The Hindu, 2012). This has reported adversely affected the coastal

fisheries. However, this significant impact is completely ignored in EIA and EMP and EMn

process. The State Pollution Control Board, the Captain of the Ports and Fisheries Department

ought to actively monitor this parameter; they seem to have never done so.

29. Impact on coastal fisheries of increased ore loading points and of barge and ship movement in the coastal and offshore waters

Several big open cast iron and manganese ore mines operate in the drainage basins of the

rivers. Fe, Mn ores brought from mines are stored on the shore of the estuary, loaded on to

barges at loading points and transported through the estuary to the port or mid-stream point, from

where the ore is exported in giant ships. Mandovi has 37 loading points with 1500 trips of barges

per year while Zuari has 20 loading points with 1800 trips per year. Ore transport through rivers

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increased from 14 million tonnes (mt) in 1980 to 30.7 mt in 2004. Of this, 19.1 mt of ore was

transported through the Mandovi and 11.6 mt was through Zuari. Part of the ore (11 mt) carried

through the Mandovi is diverted to the port through Cumbarjua Canal during the monsoon

(Rangaraj and Raghuram, 2005 as cited by Kassarkar et al, 2013). During heavy monsoon rains

abundant ore material is being flushed into the estuaries. Since ore handling i.e., loading in

barges, transporting and reloading at the port or mid-stream in giant ships, is done in an open

system one would expect abundant spilled-over ore material into the estuaries (Kassarkar, 2013).

All of this has reportedly adversely affected coastal fisheries. However, this significant impact is

completely ignored in EIA and EMP and EMn process. The State Fisheries Department ought to

actively monitor this parameter; they seem to have never done so.

30. Reduction in availability of land based as well as aquatic wild food [4,6,8,9]

The hilly, forested land of Goa with abundant freshwater, estuarine and coastal resources has

provided the populace with substantial quantities of highly nutritious naturally produced food

ranging over tubers, leafy vegetables, berries, crabs, shrimp, mollusks and fish. All of these have

reportedly declined through manifold adverse impacts of mining. However, this significant

impact is completely ignored in EIA and EMP and EMn process. The State Wild Life and

Biodiversity Boards and Forest, Fisheries and Health Departments ought to actively monitor this

parameter; they seem to have never done so.

31. Traffic congestion and road accidents

There has been an enormous increase in the number of trucks plying on roads of Goa, both

loded with Goan ores and bringing in ore from Karnataka. This has reportedly resulted in serious

traffic congestion and road accidents, with trucks racing up and down narrow village roads with

scant respect for people’s safety (Alvares, 2011). However, this significant impact is completely

ignored in EIA and EMP and EMn process. The State Home, PWD and Health Departments

ought to actively monitor this parameter; they seem to have never done so.

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32. Impacts of air, water and noise pollution on health

The study by TERI conducted in 1997 shows that exposure to air pollution (respirable

suspended particulate matter, RSPM) is high in the mining clusters and transport corridors. More

than 90% of the population in the mining clusters and corridor areas are exposed to RSPM levels

over 150 µg/m3, beyond the threshold level for industrial areas. Similarly, self-reported health

assessments and observed health assessments (through chest x-rays and lung function tests) show

higher respiratory problems in the mining and corridor areas than in the control group. A study to

identify the extent of respiratory illnessin the community as result of exposure to particulate

matter and to value the cost of ill health as a result of air pollution in the mining regions of Goa,

suggests a strong correlation between high levels of exposure to suspended particulate matter and

respiratory ill-health. The total annual cost of ill health due to doctors’ visits and wages for the

mining region is estimated as Rs 71,236,788 (US $ 1,548,626) (TERI, 2006).

However, this significant impact is completely ignored in EIA and EMP and EMn process.

The State Health Department ought to actively monitor this parameter; they seem to have never

done so.

33. Extra burden on women because of depletion of drinking water, fuelwood and other resources

DevPann Dongor and adjoining areas were being used for the grazing of animal, collecting

firewood and other minor forest products. Today, the mine owners do not allow the villagers to

collect fire wood or take their cattle to graze in these areas. Because of this, the women have to

go far away to collect firewood, which is inconvenient (Elderly women, 2011). However, such

significant impacts are completely ignored in EIA and EMP and EMn process. The relevant

agencies of the State Government such as Health and Social and Tribal Welfare also ought to

actively monitor these issues; they seem to have never done so.

34. Loss of employment in fisheries, agriculture, horticulture and forestry sector

There is no proper data available either on employment in various capacities in the mining

sector or in the other unorganized sectors. However all India figures suggest that an

overwhelming proportion of Indian population, 93% is employed in the unorganized sector, and

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this is likely to be so for Goa as well. Reportedly fisheries, agriculture, horticulture, animal

husbandry and forest based livelihoods have all declined because of the impact of mining in Goa.

However, such significant impacts are completely ignored in EIA and EMP and EMn process.

The relevant agencies of the State Government such as Fisheries, Agriculture, Horticulture,

Forest and Social and Tribal Welfare also ought to actively monitor these issues; they seem to

have never done so.

35. Social conflicts resulting from unequal distribution of economic gains, influx of immigrants, and increased liquor sales

Operation of mines has reportedly created fissures in the society with truck owners and other

sections of local population including government servants and political workers who are

recipients of substantial bribes favouring mining activities and farmers, fishermen and others

opposing it (Mine managers, 16th March 2012). This strife is further fueled by the fact that a

large proportion of people employed in the mining sector including labour, and truck drivers are

immigrants. To cater to some of these sections, liquor shops have multiplied leading to other

social problems. All these are very significant issues that should be dealt with in the sections

dealing with Socio-economic impacts of mining in the EIA reports. However, such significant

impacts are completely ignored in EIA and EMP and EMn process. The relevant agencies of the

State Government such as Health and Social and Tribal Welfare also ought to actively monitor

these issues; they seem to have never done so.

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5. Materials and methods 

5.1 Mandate of the project 

The Government of Goa has commissioned the Centre for Environment Education (CEE),

Goa to undertake a two-year research project, commencing April 2011 to assess the quality of

the Environmental Impact Assessments (EIA) submitted, compliance with Environment

Clearance (EC) conditions and the adequacy of the EMPs with respect to 105 mines in operation

in Goa. The project was guided by Prof. Madhav Gadgil, then a member of the Goa Golden

Jubilee Development Council, and currently D D Kosambi Visiting Research Professor of Goa

University.

The components of the project include:

a. Desk study of EIA, EC and EMP

i. Collection of EIA,EC and EMPs and other relevant

information relating to all mining firms which are involved in

mining from Goa State Pollution Control Board (GSPCB)

ii. Characterization of the total population of 105 mines in terms

of geography, topography, hydrology, environmental and

socio-economic matrix and operational history, with a view to

determining the stratified sample

iii. Developing tools for the analysis of EIA,EC and EMPs

iv. Selection of individual mines for rapid and in depth study on

the basis of stratified random sampling process.

b. Assessment and ground truthing of the EIA, EC and EMPs over a one year

period with respect to:

i. Land environment

ii. Water environment

iii. Air environment

iv. Noise environment

v. Biological environment

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vi. Socio-economic environment

vii. Public utilities

viii. Mine waste Management

ix. Mine closure

x. Risk Analysis and disaster management

xi. Natural Resource conservation

xii. Rehabilitation and resettlement

xiii. Occupational safety and health

c. Development of recommendations so as to improve the quality of EIAs, ECs

and EMPs

The context of this investigation was explained above in the section on Tools of

Environmental Management. More specifically, the Guidance Manuals for Mining and for

Beneficiation of Minerals, provide the most up-to-date guidelines for the whole process and the

investigations undertaken as a part of this project are primarily based on these manuals

(Administrative Staff College of India, 2010).

5.2 Mode of conduct 

The study was ably supported by the Goa Government, Department of Science, Technology

and Environment for the period of two year (March 2011 to 2013). Annexure XI givesthe terms

of reference of the project. The Goa State Pollution Control Board (GSPCB) provided us with

pertinent material including EIAs, Public Hearings records, ECs and EMPs for 95 mines of the

state (before the State Government halted all mining operations in September 2012 in response to

the Justice Shah Commission of Enquiry Report into Illegal Mining in Goa) (Annexure XII).

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Table no. VIII indicate documents received from Goa State Pollution Control Board for the

purpose of assessment

The Government also facilitated visits to mining sites. It must be put on record that the mines

management too fully cooperated during these field visits(Annexure XIII). The manual on EIA

developed by the Administrative Staff College, Hyderabad served as the benchmark against

which the Goa mining EIAs were assessed through a desk study covering all the documentsWe

also developed a Citizen’s Manual based on this benchmark and circulated it among the various

stakeholders calling for feedback(Annexure XIV). A total of 15 Panchayats (Table IX)were

provided with the EIA, EC and EMP documents with a request they review them and give us

their feedback (Annexure XV).

Talukas Number of

EIAs

provided by

the GSPCB

Number of

ECs

provided by

the GSPCB

Hydrogeo

logical

reports

available

Public

Hearing

Reports

Forest

Clearance

Sanguem 51 47 33 44 18

Quepem 9 9 0 7 0

Bicholim 21 20 14 20 3

Sattari 11 11 5 11 1

Bardez 2 2 1 2 0

Ponda 1 1 1 1 0

Total 95 90 54 85 22

Table VIII Receipt of EIA, EC and EMP from GSPCB for evaluation

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Sr

. No.

Date Panchayat Tc. No. ( EIA documents given )

1 15/02/12 Uguem 8/50, 68/53, 2/57.

2 15/02/12 Caurem 29/51, 11/53, 6/61, 12/53, 44/51, 1/57, 59/51.

3 15/02/12 Netraval 38/52, 27/50.

4 15/02/12 Rivona 100/53, 75/52, 17/49, 14/51, 6/49.

5 15/02/12 Vadde 65/51, 63/51, 3/51, 40/54.

6 15/02/12 Bhati 5/53, 40/57 42/57, 19/54 3/57 33/57, 31/58.

7 17/02/12 Srigao 11/41 12/41 13/41 15/41, 5/49 13/49, 4/49.

8 17/02/12 Sarvona 28/53.

9 17/02/12 Pissurlem 55/51, 110/53, 95/52, 28/51, 70/51 2/Fe/71.

10 17/02/12 Cudnem 92/52, 51/52, 45/52,48/58, 98/52, 14/53.

11 17/02/12 Surla 62/A/52, 1/55

12 17/02/12 Pale 31/53, 41/56, 86/53, 8/61, 84/52.

13 17/02/12 Maulinguem 9/49 10/49 3/54, 39/53.

14 17/02/12 Honda 5/54 20/54 21/54, 83/52 29/54, 6/55.

15 17/02/12 Advalpal 76/52.

Table IX List of Panchayats given EIA documents for their comments

While there was no response from Panchayats, 24 respondents from 13 villages, as noted

below in Table X were interviewed and provided substantial feedback on the issues listed in the

Citizen’s Manual and on the following questions / topics:

a. Land use pattern in the village

b. Households in the village

c. Employment/ livelihood in the village

d. Average income levels

e. Extent dependence on mining

f. Water sources and the effects of mining on them

g. Dependence on the forest and forest produce

h. Health, Educational and Transportation facilities

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i. Agriculutral Produce

j. Extent of Dependence on agriculture

Name of the respondent TC no and

name of the mine

Village Date

Mr. Hanumant C. Parab

along with two

representatives

06/55, Sociedade

Timblo Irmaos ltd.

Honda, Sattari 26.06.2012

Mr. Hanumant C. Parab 28/51, Sesa Goa

Ltd.

Pissurlem, Sattari 26.06.2012

Mr. Vijaykumar Dessai

along with three

representatives

110/53 Jose Cosme

Da Costa

Pissurlem, Sattari 26.06.2012

Mr. Hanumant C. parab 55/51 Geetabala

M. parulekar

Pissurlem, Sattari 26.06.2012

Mr. Hanumant C. Parab 2Fe/71 Damodar

mangalji

Pissurlem, Sattari 26.06.2012

Mr. Ramesh Gauns 89/52 Lithoferro Advalpal, Bicholim 27.06.2012

Mr. Ramesh Gauns 61/53 Bondra

Advona Iron Ore

Mine

Codli,

Dharbandora,

Sanguem

27.06.2012

Mr. Bhagwat Bhaskar

Gaonkar

5/49, 13/49,

Chougule Mine

Shirigao 30.06.2012

Mr. Ramesh Gauns 11/41, 12/41,

13/41, 14/41, 15/41

Dempo Ining Corp

Ltd

Lamgao, Bordem,

Bicholim, Mulgao

27.06.2012

Mr. Dinanath Gaonkar along

with two representatives

4/49, Bandekar

Mines

Shirgao, 30.06.2012

Mr. Shankar Jog along with 2/51, Saniam Mine Sacordem, 28.06.2012

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one representative ( M. S. Talaulikar

Mines)

Sanguem

Mr. Nilesh Goankar 12/53, Vaikunt

Cadnekar

Caurem

Mr. Nitin S Tendulkar 14/58, Codli mines Codli, Dabhal 28.06.2012

Mr. Shankar Jog 4/52, 16/49 S.

Kanthilal

Sacordem,

Sanguem

28.06.2012

Mr. Rama Velip along with

seven representatives

6/49, Hiralal

Khodidas

Colamba 25.06.2012

Mr. Nilesh Goankar 59/51 Zoiram

Neogi

Caurem, Quepem 25.06.2012

Table X Citizen feedback using citizen manual for their feedback

We also visited 17 mines in the field(Table XVII). The study has been conducted in a

transparent and participatory manner by organizing various workshops, consultations and field

visits to the mining sites(Annexure XIII). Our focal concerns have been discussed with various

stake-holders including the mines lease-holders, managers, local communities and NGOs. (Table

X and XI)provides full details of the interactive process undertaken.

       

 

 

 

 

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5.2.1 Chronology of interactions with various stakeholders  

Sr. No Date Activity Participants

1 12 to 22 Jan

2011

Field visits/ public

discussions for GGJDC

report

Cauvre, Rivona, Pilgaon field

visit /discussion, Discussion

with mine owners/ managers,

Goa Govt officials

4 18th Jan 2011 Letter to the Hon. Minister

for Environment, Govt. of

Goa

Prof. Madhav Gadgil

Shri Sujeet Dongre

2 18th January

2011

Discussion with Minister,

Goa Dept of Environment

regarding project

Minister for Environment, Goa

Dept of Environment, Prof

Gadgil and Sujeetkumar Dongre

3 15 Feb 2011 Discussion on project design

at Garware College, Pune

Prof. Madhav Gadgil, Shri.

Sujeet Dongre, Dr. Anil

Kharshikar, Mr. Gaurav

Shirodkar Dr.Ankur Patwardhan,

Ms. Amruta Joglekar, Ms.

Medhavi Tadwalkar

5 2 March 2011 Multi Stakeholders

workshop

NGO, Govt. Researchers, Mines

managers

6 19 and 20

July 2011

Youth consultation Youths from different parts of

Goa

7 18th to

25thAugust

2011

TISS Tuljapur Interns field

visit

TISS students from Tuljapur

Campus

8 28th and

29thSeptember

2011

Project plan discussion CEE and ISM, Dhanbad staff,

Gurudeep Singh, Agarwal

10 21 to 23 Feb

2012

Field visits around Colamb,

Cauvrem, Pisuurlem

Citizens and Mines Management

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11 5th April 2012 Field visits around Shirgaon

and Bicholim

Citizens and Mines Management

12 9th May 2012 Field Visit to Sacorda,

Dharbandora

Citizens and Mines Management

12 10th May

2012

Mines Managers’ 2nd

Consultative meeting

included discussion of

analysis revised in light of

feedback from Mining

Industry

Mines Managers

13 21st April

2012

Visit to Velge, Surla and

Pissurlem

Mines management

14 16th

January 2013

Discussion with the

Professors, researchers and

NGOs.

Professors and researchers

Table XI Chronology of interaction with various stakeholders

 

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6. Results 

The EIAs, ECs and EMPs are highly deficient in information pertaining to major

environmental parameters such as water resources, land use pattern, biodiversity, demographic

profile, dependency of people on agriculture, and impact of air pollution on the health of local

people. The assessments are narrowly focused on areas within and adjacent to lease boundaries

and no measures are contemplated to mitigate broader environmental damages that clearly

extend well beyond the individual lease boundaries. A number of substantive issues are not

addressed at all, as was discussed above on the section on ‘Mining Impacts: potential and actual’.

Furthermore, it may be noted that ECs have been sanctioned to as many as 182 mining

leases. The total production of these leases would amount to an annual removal of 70 million

tonnes of ore. As the standard ore to waste/overburden is 1:3, this means the ECs sanctioned

permitted in principle the removal of some 200 million tonnes of earth in the State of Goa every

year. Obviously, it is necessary to consider the total environmental impacts of such a huge

turnover of soil in an ecologically sensitive area like the Western Ghats; for there are many

threshold effects so that the total impacts can be vastly greater than the sum. To take a simple

example, 100 trucks plyig with ore from a mine may have negligible impacts, but when

thousands of trucks from several mines start plying on the same roads, this can lead to horrible

traffic jams and accidents. Such possibilities of build-up are completely neglected. In

consequence, as emphasized in the report of the Shah Commission, there has been substantial

damage to the environment of the State as a whole and its ecological assets far beyond the

mining area.

It seems as if the EIA, EC and EMP exercises are not being viewed and implemented by

lease-holders and statutory authorities in their true spirit of being a tool to encourage and

promote environmentally and socially sound development, but are being treated instead as an

irksome requirement somehow to be complied with.

Availability of guidelines

Out of 95 EIAs received by us from the Pollution Control board, 65 EIAs were conducted

under the 1994 EIA notification and 27 under the 2006 EIA notification. It is true that there were

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no detailed guidelines developed till 2010. However, this does not justify the misrepresentation

of facts and neglect of many significant issues evident in many EIA exercises.

6.1 Desk study 

6.1.1 Environmental Impact Assessments 

Out of total 95 EIA obtained, 79 EIA were evaluated using the ASCI Guidelines of 2010. We

review below some of the important issues that emerge from this evaluation. Out of 92 EIA

documents, 79 were completes in all respect. Hence, only 79 EIA, ECs and EMPs were analyzed

using the citizen manual

1. Improper documentation of the existence of water sources within leases and adjoining the leased boundary

1. Western Ghats’ Sahyadris span nearly 600 sq. km of geographical area in Goa.

Most of the 700 and odd mining leases granted by the erstwhile Portuguese

government fall in this region. This part is rich not only in terms of mineral ore,

but is a very significant reservoir of ground water resources, forests and wildlife.

The state's eight major rivers originate in these Ghats. Apart from the rivers, the

Sahyadri range is the original source of numerous perennial and seasonal springs.

The inhabitant of these areas and the state population as a whole depend on these

rivers and springs for their domestic and agricultural needs. With respect to

documentation of water sources, none of the EIA have properly surveyed the area

and documented the existence of water sources (Springs/Nallahs/River/Rivulet)

thoroughly. There is no study or reference in almost all the EIA regarding

dependency of local population on the water coming from the mining areas as

springs or nallah.

2. Majority of the mining sites are located in the Western Ghats region. All have

such water courses in their core and buffer areas that need to be properly recorded

and measures proposed for their protection in the EIA-EC-EMP process.

However, the Environmental Impact Assessments have no proper documentation

of these water sources, and whether these are seasonal or perennial, etc. This lack

of understanding is reflected in the ECs issued. For instance:

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3. T.C. No. 14/52 of M/s Badrudin H. Mavani documents the presence of a nallah

flowing about 6 km away from the lease area, but does not make any mention of

the major Kushavati river whose river bank adjoins the mine lease boundary.

4. The EIA of T.C. No. 1/51 belonging to Shaikh Salim situated at Devapon Dongor,

located in Caurem village in Quepem taluka does not make any mention of the

existence of perennial water springs within the mining lease area. The EC,

however, had a specific condition that prohibits the lease owner from disturbing

the water courses and requires him to maintain 50 meters buffer on each side,

besides enriching this area by planting native species of vegetation. This condition

was completely violated by the lease owner, leading to high levels of discontent in

the village located below the lease.

5. The EIA of TC No. 35/51 (although this was not granted the EC and was not part

of the EIA supplied to CEE by the Goa State Pollution Control Board) had serious

flaws related to the watercourses in the lease area. Hence, the villagers petitioned

the state government to assess the watercourses existing in the lease areas. As per

the survey carried out by the Water Resources Department, Govt. of Goa, ref.

WRD/WDII/SDIII/F35/322/2009-10 dated 18.12.2009 there are around 30-40

springs on the lease including the famous Takazor. The Agriculture Department

of Government, vide their report No. 3/5/ext/46/mining/2009-10/D.AGREE/489

dated 5th Nov. 2009, also mentions that the area has 30 natural springs that help

in providing water recharge to the Kushawati river besides supporting plantation

crops and paddy fields plus drinking water (input from Shri Pandurang Patil,

Rivona. This TC number has not received an EC).

6. With respect to TC numbers 4/55, 8/50, 2/57, 60/52 and 19/52, the EIA document

does not mention of water courses in and adjoining mining lease but EC issued by

the Ministry of Environment makes mention of water courses.

7. The river Bicholim is classified as a flood prone river and touches the lease

boundary of TC number 28/53 of M/s Zantye and Co. It finds no mention at all in

the EIA document (input from Mr. Ramesh Gauns).

 

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2. Improper documentation of information relating to demographic profile, and socio–economic status

1. People in the Western Ghats of Goa practice a stable, productive system of

horticulture called ‘Kulagars’, most often a spice plantation dependent on

perennial water sources coming from the Ghats. This activity generates

substantial employment opportunities for the locals but has never been considered

in any EIA as a significant economic activity of the locals. The impact of mining

on these kulagars has also not been considered. The EIA of TC No. 35 of 1951 at

Chiunim Dongor of village Rivona, mentions that the agriculture is characterised

by dependence on monsoons as irrigation facilities are available only for one

percent of the land (page No. 49). The report of the Agriculture Department

however indicates that Rivona is a prosperous agricultural locality having its own

perennial irrigation systems by way of springs flowing from Chiunim Dongor.

2. All the EIAs fail to verify and assess the effect of mining on society in terms of

economy, socio-cultural changes, health and human and agricultural activities.

Employment through agriculture and allied businesses is in fact underplayed in

the EIAs. The EIAs merely casually mention the effect of mining on the

environment and health, and overstate the positive effect of mining on

employment and the economic well-being of the society.

3. The population data is taken from the census and put in the EIA document

without assessing/ correlating its importance to the EIA study. The statistics

become just an annexure and a part of compliance requirements.

4. The Western Ghats harbours substantial tribal populations that have been staying

in these areas for centuries. Most of the mining leases are situated in the vicinity

of these tribal populations. It is essential to assess the impact of mining on the

tribal populations based on an actual assessment of the tribal populations in

project-affected areas. However, a majority of EIA documents fail to even

acknowledge the presence of tribal populations in their project areas. When they

do acknowledge the presence of ST populations, they only quote 1991 census that

vastly underestimates ST populations. This is improper since most of the EIAs

have been prepared after 2003 and the Scheduled Castes and Scheduled Tribes

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Order (Amendment) Act, 2002 published in the Gazette of India dated 8th January

2003, Extraordinary, Part II, declared Velip, Gawda and Dhangar communities as

STs (Annexure XVI). For instance, as per the latest survey report of the ST

population in villages of Quepem taluka are like this: Caurem- 148, Cazur-101,

Mangal- 52, Caurem-pirla-30, Maina-3. Sanguem taluka- Carmona-64, Bhandol-

92, Kirlapal-218, Kirlapal-Dabhal-10, Dharbandora- 225, Davacond- 105,

Tamsoda-02, Thalod-15, Dhullei-19, Tathode-25, Amai-12, Honda-136, Mulgao-

204, Pilgao-218, Pissurlem-244, Sancordem- 65, Panas-35, Satpal-2, Surla-345,

Velguem-11 (Dept. Of Social Welfare, 2013)

5. Tribal communities have low landholdings. Therefore, the EIA documents tend to

record that an insignificant population is dependent on agricultural activity.

However, they do not evaluate their intimate association with the surrounding

non-cultivated land for their livelihood and sustenance.

6. The Forest Rights Act {Scheduled Tribes and Other Traditional Forest Dwellers

(Recognition of Rights over the Forest) Act} enacted in 2006, came into force on

1st January 2008. Essentially the entire population in settlements around the

mining leases is either Scheduled Tribes or Other Traditional Forest Dwellers and

all have rights over forest lands, including communidad and private forest lands,

that must be granted as per the provisions of this act. As many as eleven EIAs

were prepared in the year 2006, 8 EIAs in the year 2007 and 6 in the year 2008.

All these documents ought to have considered the implications of FRA, but never

did so. In fact, a total of 26 mining leases were granted FCA clearance after

January 1, 2008 without completing the prescribed procedures, including full

involvement of Gram Sabhas as required under the Forest Rights Act. As the

Saxena Committee report on Niyamgiri has clarified, and as has been confirmed

by the Supreme Court order of April 2013, these clearances are invalid.

3. Discrepancies with respect to actual distances between the boundaries of mine leases and protected areas

1. Goa has officially protected its entire Western Ghats as a Protected Area. The

Indian Board for Wildlife during its XXI meeting held on 21st January 2002

adopted a ‘Wildlife Conservation Strategy 2002’ wherein point No 9 envisaged

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that “Land falling within 10 Kms of the boundaries of National Parks and

Sanctuaries should be notified as eco-fragile zones under section 3 (v) of the

Environment (Protection) Act and Rule 5 Sub rule (VIII) and (X) of Environment

(Protection) Rules.” In Goa, almost all the mining leases are situated within this

10 km zone. Subsequently, a Public Interest Litigation was filled vide the writ

petition No.460/2004 before the Hon’ble Supreme Court regarding the issue of

eco-sensitive zones. During its hearing, the Supreme Court by an order dated 4th

December 2006, directed the Ministry of Environment and Forests, Govt. of

India, to ensure that all those projects for which environmental clearance was

granted where the activities were within the 10 km zone, would be referred to the

Standing Committee of the NBWL.

2. As per the CEC report 44 Mines, for which EIAs were provided to CEE are

within 10 kms of buffer zone. The EIA documents, almost all of them prepared

after 2002, however, failed to correctly and objectively state the distance of the

mining lease from the boundaries of the protected areas. There was often also a

mismatch between the distance given in the EIA document and the distance

mentioned in the Environmental Clearance letter (Annexure XVII (a) (b) (c)). As

per our assessment, 30 mines have not mentioned the distance of the mining lease

from the boundary of the wildlife sanctuary, while in the case of 46 mines there

are discrepancies in the distances provided in the EIA documents and the

Environmental Clearance letter.

1. Improper documentation of the flora and fauna of the mine lease and buffer areas

1. The Western Ghats are recognized as a world mega biodiversity hotspot. All the

EIA documents have failed to properly document the biodiversity of the region.

The same list of flora and fauna – mostly common species -- is found repeated in

the majority of EIA documents. Endemic species, of significance since India can

claim sovereign rights over these species under CBD, are generally not listed at

all.

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2. There is lack of data with respect to amphibians, reptiles, birds and insects. Very

few common species of each of these category of species are mentioned in the

documents

3. The consultants appear to be completely dependent on the list provided by the

Forest Department. No effort appears to have been made to visit the area and

document the biodiversity. Besides mere listing of species found in the area, the

EIAs have failed to assess the impact of the proposed mining activity on the

biodiversity.

4. The Western Ghats are known for their unique diversity of agricultural and

horticultural crops. None of the EIAs documents have documented the diversity

of agricultural/horticultural crops, cattle and other livestock.

5. The majority of EIAs refers to the mines as being located on plateaus or on barren

land with no top soil. In fact, these areas are rich in terms of several rare and

endemic species of annual herbaceous plants, as well as smaller animals.

6. A few EIAs have explicitly listed species such as fox, grey fox, etc. As per the

wildlife census of Goa, no foxes are found in the state.

7. No studies on the migration pattern of the animals seem to have been carried out

and there is no mention of animal migrations in the documents. The location of

the mines often within wildlife corridors is also not brought out.

8. None of the EIAs has documented species of aquatic animals and plants. Goa has

eleven rivers and estuaries and mining has extensive impacts on the aquatic life.

This is completely ignored.

9. There are no adequate wildlife management plans provided in any EIA document.

2. Air, noise and water monitoring

1. The EIA reports do not give the exact location of the air monitoring stations either

in the core zone or in buffer areas. They only state the number of stations situated

in specific villages for the purpose of getting the readings. The maps given in the

EIA documents are not to scale and very crude and do not help to calculate the

location and distance from each other.

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2. The public raises serious doubts that they have never seen any EIA consultant

erecting any kind of instruments for the purpose of taking readings for air

monitoring.

3. Goa is a small state and the mining sites are located in a cluster within 10 kms of

radius. In this case, one mines buffer zone becomes another’s core zone. The EIA

documents do not make any mention of this situation but simply present readings

and conclude that all parameters related to the air monitoring are within the

permissible limit and hence clearance may be given.

4. No EIA makes any mention of nor has monitored air pollution due to truck traffic

in core or buffer zone. This activity has very high level of SPM and RSPM in air.

This crucial reading is missing in all EIA reports.

5. EIAs have not taken into consideration noise generated from the high earth

moving excavation machines, trucks plying in core and buffer zones. These

readings are crucial to determine whether the noise limit is within the permissible

limit or not.

6. The EIAs have mentioned that as per the CPCB and MoEF guidelines, water

monitoring stations were set up in core and buffer areas for monitoring the surface

and ground water resources. Most of the EIAs have selected wells upstream and

downstream of a river/nallah for the ground water monitoring. All the EIA

documents state that stations are set up in core and buffer zone, but their exact

locations are not mentioned. The maps given are crude and generally not to scale.

7. The monitoring of water is done mainly for chemical and physical parameters but

not related to the water level. As EIA have been done for expansion of several

mines, this assessment becomes very important to understand the mining effect on

ground water. Though, subsequently the companies have done their hydrogeology

study, but assessment as part of EIA done is very crucial.

Table XIIpresents an analysis of 79 EIAs (out of 95) obtainedusing the ASCI Guidelines of

2010. Only 79 EIAs assessed because they were complete in terms of all information and

annexure provided by the GSPCB. It is apparent that although these Guidelines are still not

comprehensive enough, most EIAs provide only very fragmentary information.

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Element Extent of information provided

None Partial Complete Total

Overall note on mineral reserves, rated capacity, life of the mine 9 2 68 79

Detailed justification in case lease area/buffer zone is

ecologically fragile

26 12 41 79

Period of mining lease and calendar programme of ore and waste

production

41 2 36 79

Status and stages of regulatory clearances such as approval of

mining plan, forest clearance, consent to establish from State

Pollution Control Board etc.

22 20 37 79

Solid waste dumping strategy and management 3 4 72 79

Energy demand/specific energy consumption 79 00 0 79

Water requirement and reliability of its supply 32 10 37 79

Market conditions vis a vis validity of the project 79 0 00 79

Capital cost estimate 79 00 00 79

Manpower recruitment 45 3 31 79

Location, longitude, latitude, topographic map (1: 50,000 scale,

digitized map) of vicinity within 10 kms showing the locations

of beneficiation plant, tailings dam, water intake point, natural

nallah, rivers, settlements etc.

06 56 17 79

General description of unit process operations. 45 00 01 79

If the beneficiation plant is on the mine site owned by the same

entrepreneur, brief details of mining activities (Note: out of 10

beneficiation plant only 9 have provided information)

09 00 01 10

(10

leases

were

invol

ved in

Benif

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icatio

n)

Details of mineral ore quality, the beneficiation process

technology to be adopted for up gradation of mineral/ore and

expected mineral/ore quality after beneficiation

8 0 02 10(10

leases

were

invol

ved in

Benif

icatio

n)

Details of tailings generation, its composition and management

strategy with material balance

76 01 02 79

Detailed description and design with contour of the tailings

dam

78 00 01 79

Detailed layout plan showing the locations of all proposed

activities

48 3 28 79

Township description 79 00 00 79

Details of diesel generator set, if any 00 00 00 79

Water requirement and sources 34 10 35 79

Maps (appropriate scale) of the study area (core and buffer

zones), clearly delineating the locations of various monitoring

stations (air/water/noise/soil), superimposed on locations of

habitats are to be shown.

22 40 17 79

A locational digitized map based on the remote sensing

showing the major road, railway, settlements, water bodies with

mining lease area

79 00 00 79

Presentation of ancillary features such as existing surface

features, quarry, contour, natural nallah, lease boundary,

road, exhausted quarry (if any) to be developed in the vicinity

79 00 00 79

Contour map of acceptable contour intervals as required by the 60 2 17 79

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study of core zone and site

Plan of the area showing the proposed break-up of the land. 4 10 66 79

Description of the project site, geology, topography, transport

and connectivity

06 16 57 79

Demographic aspects, socio-cultural and economic aspects,

villages, settlements (Note: Invariably restricted to 1991 Census

data)

06 8 65 79

Meteorological data 01 00 78 79

Notified restrictions limitations from environmental

considerations etc.,

02 00 77 79

Environmental data relating to history of natural calamities

and so on.

79 00 00 79

The details of mineral beneficiation such as Beneficiation

flowchart with equipment, Capacity, Tailings management

11 00 00 11

The details of total power and water requirement during

development and operational changes with source.

79 00 00 79

Consideration of alternatives and alternatives for activities

relating to mine development and exploitation, technology etc

79 00 00 79

Study with the help of satellite imagery data of the existing

land use / land cover pattern in the study area.

79 00 00 79

The drainage pattern such as nallahs, rivulets, rivers in the

study area with their features.

62 17 00 79

Discussion on the natural surface drainage pattern of

proposed mine site if required to be changed.

79 00 00 79

The groundwater potential 74 00 05 79

Groundwater recharge calculation 77 00 02 79

Identification of sources of surface water in the study area and

presented on the map

26 20 33 79

The river flow measurement of the streams flowing adjacent to

the mine lease area and areas of ancillary operations such as

79 00 0 79

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dumps.

Water samples from available surface water and groundwater

from both core as well as buffer zone.

06 10 63 79

The sampling stations and frequency should represent the full

range of space-time variability

79 00 00 79

Planned field monitoring of sampling and analysis. 01 00 78 79

Location of monitoring stations in a tabular format 2 50 26 79

The noise level monitoring in the study area to be done at the

ambient air environment monitoring locations.

15 8 55 79

Collection of secondary data on flora and fauna from the state

forest department, field survey and consultation with the locals.

6 70 01 78

The study on phyto-sociology of the vegetation, covering

frequency, density, abundance & species diversity, in the area

falling both in core as well as buffer zone through survey in

selected patches.

79 00 00 79

Distribution, Abundance, Rarity, Species diversity and critical

habitat requirements, Migratory and travel routes, Predator –

prey balance, Habitat residence of flora and fauna of the core

and buffer areas

79 00 00 79

Village wise demographical profile of the study area from

census record

24 00 49 79

A survey representing cross-section of people in the study area

such as composition and size of the family, educational status,

homestead land, information in agricultural situation,

employment and annual income etc; Information on family

budget, Savings,Family assets, Respondent’s perception about

the proposed mining project

35 43 01 79

Vehicular traffic during mine development and operation. 79 00 00 79

Vehicular traffic density outside and in mine lease area,

existing and after beginning of the mining activities.

79 00 00 79

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Nearness to water body/reservoir 37 9 33 48

Details of forest conservation plan 75 4 00 79

Study to ascertain Impact of blasting on the core and buffer zone 12 2 1 11

Details of ground water availability and recharge 77 00 02 79

Table XII Analysis of EIA using the citizen manual

 

 

 

 

 

 

 

 

 

 

 

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6.2 Inputs from public 

An in-depth understanding of the local context is vital to a proper assessment of the

environmental and socio-economic impacts of mining activities. We therefore provided 15

Panchayats with relevant documentation and requested for their feedback. Regrettably, not a

single Panchayat responded. This is possibly related to the fact that as reported by the Mine

Managers in the consultations with Western Ghats Ecology Expert Panel on 16th January 2011 a

very large number of elected representatives, from Panchayat level upwards are being regularly

bribed by the industry. However,24 respondents from 13 villages assessed 21 TCs and provided

their overall comments, as well as their assessment of the completeness of the information in the

framework of the Citizen’s Manual based on the ASCI Guidelines of 2010. The major points

brought out by the citizens include:

1. While preparing the EIA, the consultants have never involved the local people for

any information, nor are the people aware that such an exercise was being

undertaken. Data given in EIA relating to social, economic aspects, to biodiversity,

agriculture and demography are often not correct.

2. The EIAs have not mentioned the ill effects of air pollution on public health and

agricultural crops.

3. The majority of the villagers in mining areas are dependent on agriculture. Due to

inadequate EMPs, the silt during the rainy season accumulates in the agricultural

fields, invariably leading to drastic reduction in productivity.

4. The mines have gone below the water table, and the villagers face scarcity of

water. In Pissurlem village in Sattari and Shirgao village in Bicholim, all the wells

have dried up and a majority of the population is dependent on water supplied to

them by the mining companies in tankers.

Table XIII presents an analysis of 16 or fewer EIAs (out of 95) which pertained to localities

with which the citizen respondents were familiar. We have left out the rows for which they did

not record any responses. Their responses suggest that most EIAs provide only very fragmentary

information.

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Element Extent of information provided

None Partial Complete Total

Overall note on mineral reserves, rated capacity, life

of the mine

2 1 13 16

Detailed justification in case lease area/buffer zone

is ecologically fragile (understanding of 10 km

buffer zone considered as a eco-sensitive zone)

2 2 4 8

Period of mining lease and calendar programme of

ore and waste production

7 1 8 16

Status and stages of other regulatory clearances 1 2 12 15

Solid waste dumping strategy and management 1 1 13 15

Energy demand/specific energy consumption 15 1 0 16

Water requirement and reliability of its supply 0 0 16 16

Market conditions (validity of the project) 13 1 0 14

Capital cost of project 0 0 16 16

Manpower recruitment 9 0 6 15

Maps of the study area clearly delineating the

locations of various monitoring stations

superimposed on locations of habitats

2 0 7 9

A locational digitized map based on the remote

sensing showing the major road, railway,

settlements, water bodies with mining lease area in

the scale of 1: 25,000.

16 0 0 16

Ancillary features like, Quarry, contour, natural

nallah on lease boundary, road, exhausted quarry

etc.

15 0 0 15

Presentation of the mining leasehold area with forest

type and name

4 0 1 5

Plan of the area showing various proposed break-up. 3 3 8 14

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Description of the project site, geology, topography,

transport and connectivity

1 6 9 16

Demographic aspects, socio-cultural and economic

aspects, villages, settlements

0 4 10 14

Meteorological data 1 1 12 14

Notified restrictions limitations from environmental

considerations etc.,

1 0 14 15

Environmental data relating to history of natural

calamities and so on

15 0 0 15

Details of total power requirement during

development and operational changes with source

14 1 1 16

Details of source of water supply, type of treatment

and break-up for different use

1 6 8 15

Details of other infrastructure such as grid, DG

set, workshop etc.

14 0 1 15

The existing land use / land cover pattern in the

study area.

13 0 0 13

Topography details of the study area 16 0 0 16

The drainage pattern in the study area explained

through maps and satellite imagery (nallahs,

rivulets, rivers in the study area with their

features).

14 2 0 16

Data related to river flow management taken

adjacent to mine lease area

7 1 0 8

Water samples taken for study from available

surface water and groundwater from both core as

well as buffer zone

1 0 14

15

Monitoring and sampling analysis of air from the

core and buffer zones

0 0 15 15

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Location of monitoring stations in tabular form and

also on the map.

0 0 15

15

The noise level monitoring in the study area. 0 0 15

15

Detailed study of the biological environment. 4 10 2 14

Collection of data from the authentic sources. 8 5 3 16

The study on phyto-sociology of the vegetation,

covering frequency, density, abundance & species

diversity, in the area falling both in core as well as

buffer zone.

16 0 0 16

Scientific data collection of species, abundance of

species, migratory and travel routes, predator and

prey balance, habitat residence

13 2 0 15

Details of project benefits to local community in

terms of socio-economic upliftment etc

0 9 6 15

Village wise demographical profile of the study area

from census record

3 1 11 15

A survey representing cross-section of people in the

study area to evaluate the socio-economic status of

local inhabitants.

6 9 0 15

Baseline information on existing public utility

infrastructure and service etc.

7 4 4 15

Information related to Vehicular traffic density

outside core zone

15 1 0 16

Nearness to water body/reservoir 8 2 5 15

Details of forest conservation plan 9 1 1 10

Blasting vibration study 9 0 0 9

Table XIII Citizen response using the citizen manual

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6.3 Deficiencies with regard to Public Hearings 

Public Hearings are an important tool of Environmental Impact Analysis complementing the

report prepared by a Consultant engaged by the Project Proponent. The Consultants are naturally

motivated to facilitate Environmental Clearances for the Project Proponents who are their current

paymasters and future clients. This is the root cause of the serious deficiencies in the EIAs and

ECs reported in this investigation, and commented upon by the Shah Commission. It is therefore

vital that independent inputs from people intimately familiar with the local situation complement

the information provided in EIAs, and that this information be taken on board in the final EIA

that goes before the Environmental Clearance Committees. Unfortunately, this is not happening

in an effective fashion, with the Public Hearings being viewed not in a positive light as they

should be, but as a requirement somehow to be gotten over with.

To be properly effective the Public hearings are required to be held at the Project Site.

However, the hearings are often held in district or taluka headquarters. Out of 96 EIAs received

for processing, 56 EIA public hearings were held in the district headquarters of Margao and

Panaji, 37 public hearings were held at taluka headquarters in Sanguem, Quepem and Bicholim

and only one public hearing actually happened at the project site (Vathadev, Sarvan village, for

the T.C. No. 28/53 of M/s Zantye and Co). Organizing public hearings away from the project site

has deprived the truly knowledgeable and affected people of proper opportunity to participate

and deliberate in the public hearing. The Citizen respondents have reported that as a

consequence, an adequate number of people could not attend them and raise their concerns.

Sometimes, the hall in which the public hearing was conducted was so small that no more than

40 people could be accommodated.

In most of the cases, the public have raised very valid objections, but these find no mention

in the final EIAs submitted to us for the assessment. A written application of Kushavati Bachao

Andolan objected to the mine of T.C.No. 17/49 (Hunantlo Dongar manganese mine, Columba

village, Sanguem), stating that the lease area lies on the bank of a rivulet of river Kushavati; this

is ignored in the EIA which also glosses over details of the mining impact on the residents. This

submission also records that the EIA report was not made available to the affected people before

the public hearing.

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The Citizen Respondents provided comments on many aspects of their experience of Public

hearings (Table XIV).

Element Compliance Total

None Partial Complete

Public hearing organized at the project affected

site

10 0 3 13

Each Public Hearing should address one specific

mine; there should be no multiple hearings at the

same site and time

5 3 8

The summary and EIA document be made

available before 30 days of actual public hearing

7 1 5 13

Wide coverage in local news paper 3 4 2 9

Video documentation of the public hearing 4 0 6 10

The objections raised are considered and

incorporated in the EIA

6 0 0 6

Minutes of the public hearing are read and

finalized

7 0 3 10

Modified or supplementary report following

Public Hearing

4 0 0 4

After completion of the public consultation, the

applicant shall address all the material

environmental concerns expressed during the

process, and make appropriate changes in the

draft EIA and EMP.

5 0 0 5

Incorporation of the public comments and

suggestions into the draft EIA document and

finalized document

3 0 0 3

Table XIV Citizen response on public hearing using the citizen manual

 

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6.4 Environmental Clearances 

An important focus of Shah Commission report has been the improper granting of a large

number of ECs. The Shah Commission has noted two particularly significant issues: [1] Granting

of ECs to mines within ten kilometers of WLS and NPs, without reference to NBWL as required;

and [2] Illegal transfer of mining leases to third parties. The first is clearly an important issue

from the perspective of our investigation as well, and the EIAs often provide wrong information

in this context. Furthermore, the distances to WLS and NP mentioned in ECs are different from

those claimed in EIAs (See Annexure 6). The Goa Government has sponsored the preparation of

an excellent Google earth based spatial database on land use in Goa for the purpose of GRP2021.

This database should have been put in Public Domain long ago, and would have provided clarity

on this matter. Regrettably the government has refused to do so, despite earlier requests by

Western Ghats Ecology Expert Panel and also on behalf of our current research project.

An important issue in relation to compliance of conditions imposed in the ECs relates to

management of overburden dumps. It may be noted that the ECs sanctioned are often at variance

with the mining plans. While mining plans do not permit disposal of wastes outside lease areas,

some ECs permit such dumping. Often, the dumps have greater impacts than the mining

operations, so that they should have required separate proper environment clearances.

Our field visits highlighted certain problems in relation to ECs. For instance, in the case of

TC no 110/53- Jose Cosme Da Costa, the entire lease is under operation. The EC mentions that

the total lease area of the project is 62 ha which is a private land. No forest land is involved. Area

proposed for mining is 60.5 ha and an inadequate area of 1.5 ha is kept for infrastructure. The

overburden will be disposed at a distance of 2 kms from the mine lease. Notably, the EC

condition allows working up to 186 meters bgl, which would be 56 meter below mean sea level.

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Table XV presents observations of citizen respondents with respect to compliance of

Environment Clearance Conditions in 18 or fewer mines with which they are familiar

Element Compliance

None Partial Complete Total

Whether a 50 m barrier of no mining zone on the side(s)

of the nallahs flowing across or adjacent the lease is

demarcated

14 1 0 15

Whether the barrier is thickly vegetated with native

species of trees and shrubs

6 0 0 6

Proper management of silt and overburden by the mining

company.

16 0 0 16

Maintenance of village roads through which

transportation of ores by the company.

14 1 0 15

Information related to fugitive dust pollution from the

nearest human habitation to the mine site

8 0 0 8

Transportation of ore shall be done by covering the trucks

with tarpaulin or other suitable mechanism

1 6 9 16

Transportation shall be done only during day time 1 3 14 18

Permission from the competent authority for extraction of

ground water (if any) shall be obtained.

10 0 0 10

Regular monitoring of surface and ground water quality 3 0 0 3

Measures for prevention and control of soil erosion and

management of silt.

13 4 1 18

Protection of dumps against erosion using the geo textile

matting or other suitable material, and thick plantations of

native trees and shrubs on the dump slopes.

8 11 0 19

Dumps shall be protected by retaining walls 4 12 3 19

Ensuring the waste dump location is such that

overburden should not flow down.

17 1 0 18

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Proper design of the check dam to prevent downstream

flow of the silt and regular desiltation of the check dam by

the company.

12 5 1 18

Provisions such as housing the labourers within the site

with all necessary infrastructure and facilities such as fuel

for cooking, mobile toilets, mobile sewage treatment Plant,

safe drinking water, medical health care, crèche etc. The

housing may be in a temporary form

4 0 0 4

Adequate drainage to deal with rain for overburden dumps,

stockpiles of topsoils, saleable and subgrade ores etc.

11 7 0 18

Construction of Surface drains and trenches / garland

drains at the foot of dumps and coco filters installed at

regular intervals to arrest silt from being carried to water

bodies.

6 10 0 16

Construction of adequate number of Check Dams and

Gully Plugs across seasonal/perennial nallahs (if any)

flowing through the ML area.

10 7 1 18

De-silting at regular intervals to be carried out 11 7 0 18

The company shall engage a full time qualified doctor who

is trained in occupational health. {Note: The Fomento

group of Company has a medical facility for the workers

and also for the locals around the mining site}

8 0 4 12

Periodic monitoring for exposure to respirable mineral dust

on the workers.

2 0 2 4

Awareness programme for workers on impact of mining on

their health and precautionary measures like use of

personal equipments etc

1 1 0 2

Regular review of impact of various health measures

undertaken

11 3 0 14

Green belt development and selection of suitable plant 8 10 0 18

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species including the herbs, shrubs and trees.

Regular monitoring and control of fugitive dust emissions

from all the sources.

11 5 0 16

Water spraying arrangement on haul roads, loading and

unloading and at transfer points.

8 10 0 18

Establishment of ambient air quality monitoring stations

both in core and buffer zones.

15 1 0 16

Noise control measures 12 1 0 13

Setting up of a separate Environmental Management Cell

with suitable qualified personnel

9 2 7 18

Table XV Citizen response on the EC using the Citizen Manual

                           

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6.5 Environmental monitoring 

As Shah Commission has noted “Part IV. Section 24 of the Mines and Minerals (DR) Act,

1957 was not observed at all and no inspection was carried out of iron ore mines.” It goes on to

remark that “But no inspection has been carried out resulting into fear-free environment which

has caused loss to the ecology, environment, agriculture, ground water, natural streams, ponds,

rivers, biodiversity, etc.” Under these circumstances, it appears inevitable that there has been no

proper implementation of provisions for Environmental Monitoring either. We have the

following observations from citizen respondents relating to 17 mines that they are familiar with.

Element Compliance

None Partial Complete Total

Proper coordination to apprise environmental

performance of the mine of Environment

Management Cell of the company and with the

general public, regulatory authorities, local

administration

17 0 0 17

Proper monitoring of quality of water, air,

noise, vibration and occupational health status

of project personnel and surrounding

habitations

15 1 0 16

Table XVI Citizen response on EMn using the Citizen Manual

         

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6.6 Environmental Management Plan 

In the absence of any proper system of inspection of mines, it appears inevitable that there

has been no proper implementation of Environmental Management Plans either. It appears that

while there has been some implementation of social welfare measures, there has been little

implementation of environmental protection measures. We have the following observations from

citizen respondents relating to 18 mines that they are familiar with.

Element

   

Compliance

None Partial Complete Tot

al

Preparation of a welfare plan with funding from the

project proponent to assist the affected people

(Note: There are CSR activities carried out by

various companies)

3 14 1 18

Infrastructure facility such as educational institutes,

water supply, health care etc to be extended to

people without any cost or minimal cost: (Note:

Mineral Foundation helps the local school

management committees to build classrooms and

libreries etc. Some times companies such as

Fometo, Salgaonkars, Sesa etc have their own CSR

activity and provide assistance for infreastrure

development projects)

10 5 1 16

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Compensatory packages such as monitory

compensation, resettlement plan, compensation in

kind, site remediation insurance etc

Training to locals to develop skill should be

promoted by the project. All the above should be

exhaustively dealt in the report:

(Note: Fomento company has its own Training

centre for drivers and other mechanical course

related training. Football academies are set up by

Sesa and Salgaonkars etc)

11 3 1 15

Compensation and rehabilitation of affected people

to reduce the distress caused by the loss of land and

land-based livelihood.

6 8 0 14

Implementing adequate protection and

conservation plan for the conservation of topsoil

13 0 0 13

Plantation activities on non-mineral zones and

open areas

12 2 0 14

Proper treatment of mine drainage to meet the

prescribed standard and to discharge into water

bodies and land

6 10 0 16

Planned compensatory afforestation activities on

the catchments in core and buffer zone to improve

the land and overall quality of environment

9 6 0 15

No use of productive land for waste /ore

dumping/for construction of structures

12 2 0 14

Protecting the top-soil by keeping it in a designated

site

3 0 0 3

Preventing the siltation of agricultural land. 16 0 0 16

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Overall drainage planning in such a manner that the

existing pre-mining drainage conditions are to be

maintained to the extent possible so that run off

distribution is not affected

14 0 0 14

Construction of garland drains on all side of

quarries and external dumps.

2 1 0 3

Building a retaining walls with weep holes all

round the external dumps so as to allow the water

to pass through weep holes to the garland drains

10 5 0 15

Providing properly treated surplus mine water into

local ponds and agricultural fields that act like a

constant source of recharge to improve the

groundwater level in the area

13 3 2 18

Rainwater harvesting by constructing check dams

on natural nallah and developing water bodies for

groundwater recharge.

17 1 0 18

Construction of stone barriers across the drain to

check the water current and arrest soil erosion

9 9 0 18

Stone pitching at different intervals to regulate

water flow and prevent soil erosion

14 3 0 17

De-siltation of settling pits and drains 12 6 0 18

Proper treatment of water coming from vehicle

workshop

10 1 0 11

Minimizing dust emissions from paved surfaces by using the following measures

a. Prevent spillages of materials on the paved

surfaces during materials transportation.

9 5 4 18

b. Minimize mud and dust track-out from

unpaved areas by the use of wheel wash

facilities

15 2 0 17

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c. Regular cleaning of paved surfaces, using

mobile vacuum sweeper or a water

flushing system

14 3 0 17

d. Avoid spillage from the loaded trucks 10 1 4 15

e. Wind reduction control by plantation 15 3 0 18

f. Water sprinkling on unpaved areas during

dry wind periods, using a water tanker/or

fixed sprinklers

6 8 0 14

g. Revegetation of exposed surfaces. This

should be done wherever practicable at

mines.

3 15 0 18

h. Surface improvements may be done with

concrete or asphalt, or the addition of

gravel or chemical dust suppression to the

surface for stabilization

1 0 0 1

Noise mitigation

Engineering noise controls by noise reduction at the source and by interruption of the noise path

from the source to the receiver

Administrative noise controls to the receiver

Combination of one or all of the above control measures which can be technologically achievable

Selection of new low-noise equipment from the

manufactures failing which use of additional

retrofits if available.

11 1 0 12

Dump protection measures

The individual dump to have maximum slope of 14 0 0 14

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37 deg and an overall slope not exceeding 28 deg

The external dump to have stretches of retaining

wall at suitable locations

4 10 0 14

The wall to have suitable height and top surface

and to have weep holes to drain out water to the

garland drain

1 0 0 1

Back-filled areas to be leveled to match with

adjoining ground level

1 0 0 1

The over burden and top soil dumps to be

stabilized by plantation and anchoring with coir

nets / blankets

3 10 0 13

Health monitoring

A plan for monitoring health of workers and

community in vicinity along with financial

allocation.

1 2 0 3

Risk assessment and reduction 8 3 3 14

Mine Disaster Management Plan:

8 2 2 12

Table XVII Citizen response on EMP using the citizen manual

              

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6.7 Field Visits and observations 

TC no and

name of

the mines

Date General Observation on Site Observations by local community

members

06/49

Hiralal

Khodidas

22/2/12 Series of three settling ponds.

Lime is being used as

Flocculation agent

An external agency has been

appointed to monitor the air

and water quality

Natural growth of local

species was seen on the

mining dumps. Company also

planted few species like

bamboo, jamun, etc

Management: Parapet Wall

was made around the dumps

to restrict the soil erosion

Permanent doctor along with

an ambulance, Computer

Literacy Programme for local

students

Though half the lease is identified

private forest, EC says there is no forest

land involved.

Of two springs used by villagers, one is

already dead

Soil fertility has been reduced; crop

productivity has been badly affected.

Agriculture fields face water scarcity.

Traffic has increased due to ore

transportation.

Blasting done in 2006 has resulted in

development of cracks in houses of

adjoining villagers.

Inadequate compensation being given.

Value of loss is underestimated

Company has filed hundreds of cases

against villagers of Caurem restraining

them from entering the mine. Police

have acted against villagers on many

occasions.

59/51-

Zoiram B

23/2/12 No pumping of pit water Mining going on despite forest on the

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Neugui Parapet walls, settling ponds

along the ore stack. Discharge

to the nallah through series of

settling ponds and check dams

No permanent monitoring

stations for the air and water

monitoring

Plant Nursery and compost

pits are being maintained

Overburden and ore stocks

covered with tarpaulin and

geotextiles.

lease-land and without forest clearance

The company could not show proper

documents as to location of the air,

water monitoring stations located in the

buffer zone.

Wells in the villages are not monitored.

Due to mining, there has been a large

impact on water sources and agricultural

fields

The trucks carrying iron ore do not

follow the transport guidelines and they

always carry ore more than permitted.

The roads in the villages are narrow,

chances of accidents are more.

75/52-

Voicunta

kadnekar

23/2/12 Runoff water directed into

mine pit

Flocculants used: Lime and

Magnasol

Dump slopes stabilized by

laterite compaction

Garland drains present

No use of geo-textiles

Concern raised over the issue of Forest

lands and its FCA clearance

Impact on water sources and agriculture

Excessive traffic plying on the road

The farmers are not adequately

compensated

110/53- 24/2/12 Entire lease is under A major dump failure on V.D.

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Jose

Cosme Da

Costa

operation. The EC mentions

that the total lease area of the

project is 62 ha which is a

private land. No forest land is

involved. Area proposed for

mining is 60.5 ha and an area

of 1.5 ha is kept for

infrastructure. Overburden

will be disposed at a distance

of 2 kms from the mine lease

Notably, the EC condition

allows working up to 186

meters bgl, which would be

56 meter below mean sea

level.

Mr. Jagdish Dessai, Manager

Environment informed us that

there is no impact of mine on

the ground water in nearby

villages.

The mine pit is being operated

much below the ground water

table which is approximately

200 meters below ground

level.

A conical depression has been

formed due to which all water

bodies in adjoining villages

Chowgule dump can be seen.

The Jose Cosma Da Costa dumpsite is 6

kms away from the original mining area.

The height of the dump is approximately

70 meters with a slope of 28 degree.

According to the EIA guidance Manual

for Mining of Minerals, the individual

dump should have maximum slope of

37˚and overall slope should not exceed

28˚. This is an angle of repose.

Dump is extended and deforestation is

carried out at unprecedented rate

The original channel has been buried

and there has been diversion of the

nallah (machine marks from ripper

dozer can be observed) without any

consent from the concerned authorities.

Once a perennial nallah, is now

completely dry.

At the Marsado iron ore mine 2 pits are

completely under water.

7 pumps of 150 hp each pump water 24

hrs a day

The pumped water is diverted via

Dhankal village to the Harvalem

waterfall, which finally drains into the

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have dried out

The dump management we

saw was not in accordance

with the EMP plan submitted.

Mandovi river.

Almost all wells in Pissurlem are dry.

Water is provided through tankers

Mining silt has entered agricultural

fields.

Health problems such as sinus and

respiratory related diseases are rampant

95/52

Damodar

Mangalgi

& Co

24/2/12 The Mine is closed. However,

it was noticed that the mining

pit stores large amount of

water. The water from the pit

is pumped out into a nallah. It

is evident from the

observation that even after

pumping the water by using

high power motor, the water

is not subsiding, hence there

may be few springs

underneath feeding into the

large pit. Consequently,

villagers in the village do not

have water in their wells.

In Pissurlem village, total 10

wells were observed and

found that none of the wells

have water in it.

The traditional water tank that existed in

the village has gone dry thereby creating

hardship for the farmers and livestock

Locals demand that the company instead

of pumping water from mine pit and

releasing it into the nallah, same can be

diverted to the existing tank to be used

for growing agriculture crops and for

fish culture

Large tracts of paddy field are fallow

and not being cultivated due to non-

availability of water.

Dust and traffic is a major problem

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The mining companies

supply water to the villagers

in water tanks.

5/49, 13/49

Shirgao

iron ore

mine of

Chowgule

& co. Pvt

Ltd.

5/4/12 Air Monitoring stations were

not seen

Villagers are supplied water

in a water tank. The bill

towards water is paid by the

company

Company representatives

showed a well that is being

monitored as part of EMP.

The well had water in it

The company claimed that

they are providing water for

the agriculture

Afforestation is being done on

the dump site. However, the

species is mainly Acacia.

Nevertheless, the company

has tried to plant some of the

local species

Garland trenches are dug so

as to arrest the soil erosion,

drains are dug and excess

water is drained out in a

EIA documents of this company does

not show proper information related to

the people’s dependence on agriculture

The Villagers claimed that there is not a

single well with water in it. All the

water in wells is dried due to mining

activities in the village

Agricultural fields have gone infertile.

Water is not available for the crop. The

company’s claim of providing water is

denied by the locals

Traffic on the roads is a major issue.

Dust pollution and road accidents are on

rise

The traditional water tank being used for

bathing during the local Jatra now is

facing scarcity of water in it.

Mining companies have encroached

onto their private lands.

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nearby nallah

As part of the CSR activities,

the company is contributing to

the Gram Nirman Project of

the Mineral Foundation of

Goa

4/49 Monte

de iron

Shirgao

ore mine of

Rajaram

Bandekar

5/4/12 One of the oldest mining

companies operating in this

area.

The mining pit is deep and

has gone below the water

table

There is no proper

Environment Management

Plan being implemented in

field

Information related to the socio-

economic and people’s dependence on

agriculture is given wrong in the EIA

report

Water is a major problem in the village

of Shirgao along with air pollution and

road congestion

Villagers deny that the company has

paid electricity bills of the locals

Company claims that they release water

for agriculture crops; this claim is false

11/41,

12/41,

13/41,

15/41

Bicholim

Iron ore

mine of

M/s

Dempo

mining co.

5/4/12 The entire lease area was

broken for iron ore extraction

The lease boundary touches

the village Mulgao, in some

cases village is part of the

lease

The dumps have shown

cracks as they are not

properly stacked

Due to pits going below the water table,

there has been a major impact on the

water table in the village. The wells in

village have gone dry.

Villagers especially in Mulgao face

severe scarcity of water for their

agriculture crop.

The lake is silted thereby not holding

enough water

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Plantation was not carried out

on the dumps

Information relating to the

village demography,

biodiversity and people’s

dependence on agriculture

was not properly documented

and depicted in the EIA report

Issue of transportation and its

pressure on the road was not

considered in the EIA report

Major issue with the transportation of

iron ore on the road especially near the

Dhabdhaba and Sar manas

2/51

Saniem

Sancorda

iron ore

mine of

M/s.

Talaulikar

& sons pvt

ltd

9/5/12 The Mines Manager of

Fomento Mr. Hegde informed

that the mine is being

operated by Talualikar with

the technical support from

Fomento.

The information given in the

EIA regarding the distance of

Bondla Wildlife Sanctuary

and Bhagwan Mahaveer

Wildlife Sanctuaries is wrong

Entire lease area is broken for

the iron ore extraction. The

office space does not form

part of mining lease

The community rejects the claim of

management of protected area distance.

Bondla is less than 3 kms and Bhagwan

Manhaveer is less than 4 kms

The depth of the mine pit has gone

below the water table violating EC

conditions.

The people of the village Sacorda claim

there used to be agricultural fields

within and adjoining the leased area.

The Ragda river is adjoining the dump

at a distance of less than 6 meters.

During the rainy season, the eroded silt

enters the river and pollutes it.

The seasonal nallah on the eastern

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The Ragda River which is a

perennial river flows adjacent

to the dump separated by a

road of 6 meters

The eastern part of the lease

boundary touches the seasonal

nallah.

There is an overhead water

tank attached to a source of

water that probably forms part

of the flow of nallah. Upon

asking its source, the Mines

Manager could not answer

The dump management is of

poor quality. It shows lot of

cracks and plantation done on

the dump have not survived

boundary of the leased area is actually a

perennial nallah (tributary) of river

Ragda which the company has diverted

and filled with the mining rejects. This

has created hardships for the people

living downstream for water

requirement for agriculture and

domestic consumption.

The overhead tank which supplies water

to the mining activities is actually built

on this perennial nallah and the water

flow is diverted.

This mine has been closed due to the

order from the Honorable High Courts

with respect to the lack of validity of

this environment clearance.

83/52,

29/54,

19/58, 62/

(B)/52

Velguem/S

urla iron

ore mine of

M/s V.M

Salgaonkar

&Bro Ltd.

9/5/12?

The EMP of the said mine

seems to be in order.

The company has broken up

part of their lease area and is

working in the same.

The mine shares a boundary

with Sesa Goa mining

company which is divided by

Since this company also forms a part of

a cluster on the Surla plateau it

contributes to the hard ship for local

people in terms of traffic congestion on

roads and air pollution.

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a perennial nallah called

Advoi nallah.

The company does not have

any control nor have spoken

to the SESA Goa (now

Vedanta) mining company for

illegally dumping the mining

rejects on/ very close to the

Advoi nallah which in turn

closes the flow of nallah. We

witnessed dippers/ dumpers

dumping the iron ore rejects

right on the bank of Advoi

nallah by SESA Goa.

The old dumps of the

company have been fairly

covered with Acacia

plantation and trenches have

been dug all around to arrest

soil erosion.

The dumps are systematically

designed and dumped in a

designated place.

The company has built bunds

and other water harvesting

structures in the leased area.

Company has created a

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garden called “Matoli Van”

As part of the CSR activity,

the company undertakes

school environmental

activities promoting

agriculture in the vicinity and

the villages of Velguem.

55/51

Guelliem -

e- gaval

iron ore

mine of

Geetabala

Manohar

Naik

Parulekar

9/5/12 This mine is being operated

by Fomento resources.

The dumping site of this mine

is almost 3 km away from the

core area and is outside the

lease area.

The mining pit has gone

below the water table.

At the dump site the company

has taken measures to develop

garland trenches to restrict

soil erosion.

Series of settling points have

been created for the purpose

of arresting silt.

The company managers claim

that air and water quality

monitoring is being done

`.

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periodically by an external

consultant.

Table XVIII Field visits and observations

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7. Way ahead

There are obviously serious deficiencies in the EIA, EC, EMP process and it is imperative

that we take appropriate steps to remedy these. The whole process is aimed at fulfilling the social

objectives of promoting environmentally and socially sustainable development. Hence the

process should examine any development intervention in the broader context of other on-going

development interventions and processes as also the broader environmental and socio-economic

context. It should stimulate a proper scrutiny of various possible alternatives for meeting a

particular development objective, such as mining of iron ore or construction of a highway or

generation of thermal power, so as to lead to the selection of the most desirable alternative,

namely, one that maximizes the net gain from the development intervention, i.e. maximizes the

balance of economic, environmental, social benefits minus the economic, environmental, social

costs. If the balance is considered substantial enough to justify the intervention, the most

desirable alternative should be selected, and the project accepted while specifying due

safeguards. Otherwise, the project should be rejected. An on-going monitoring of the

consequences of the project, including environmental and socio-economic impacts should be put

into place to ensure that the stipulated safeguards are being adequately implemented. Moreover,

in real life many unforeseen impacts may materialize and the monitoring process should be so

designed as to bring these out. In order to ensure that this is properly taken into account, the

Environmental Clearances should not be once for all, but should be reviewed periodically, for

instance, every five years. The project proponents should not be permitted to make substantial

changes to the project without due environmental impact assessment of the changes proposed.

While the process has been adopted with these broad social objectives in view, it is being

implemented in a very restricted framework of the project proponents getting the legally

mandated clearances as quickly and with as little effort or involvement of the society at large as

possible. So, the project proponents themselves select an agency and commission and pay for the

EIA. Naturally, the project proponents are interested in maximizing their own economic gains

and ignoring, as much as they can, the costs imposed on the environment and society at large.

Since the agency undertaking the EIA is being selected and paid by the project proponents, they

are under pressure to serve as advocates of the project for the project proponents and not as

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objective evaluators. This is the first flaw that must be remedied. The Public Hearing process is

meant to partially correct this deficiency of the professional agency preparing the EIA neglecting

or misrepresenting the costs imposed on the environment and society at large. For Public

Hearings to serve this function the administrative agencies organizing Public Hearings must also

act impartially and the professional agency preparing the EIA must be obliged to take the

submissions made at the Public Hearing seriously and redo the EIAs. This, too, is not happening

and is another shortcoming that must be corrected.

The process of sanctioning Environmental Clearances must be conducted with due care and

not be treated as part of a process of quickly getting over the hurdle of environmental and social

considerations so as to promote more and more economic activity as is happening today. This is

a serious problem that must be overcome. Finally, an assessment of the benefits gained and the

costs imposed on the environment and society at large must be an on-going process so that

appropriate mid-course corrections are instituted. This kind of comprehensive monitoring is not

happening at all, and needs to be put in place. What is clearly needed is to inject into the system

ways of ensuring that justice is done to the broader social objectives. This calls for ensuring

transparency, accountability and broader social participation.

Our constitution and laws have many excellent provisions that are being side-lined today, but

should be activated to remedy all these defects and to ensure that the broader social objectives

are indeed fulfilled. Such provisions include (1) 73rd and 74th Amendments to the Constitution

that assign a significant role to local self- governments in planning and implementation of

developmental activities and management of the natural resources within their jurisdiction, (2)

The Extension of Panchayat raj to Scheduled Areas Act that assign a significant role to gram

sabhas in planning and implementation of developmental activities and management of the

natural resources within their jurisdiction, (3) Biological Diversity Act that assigns a significant

role to local self- governments in documentation and management of the biodiversity resources

within their jurisdiction, (4) Scheduled Tribes and Other Traditional Forest Dwellers

(Recognition of Rights over the Forest) Act that assigns a significant role to gram sabhas in

planning and implementation of developmental activities and management of the natural

resources within their jurisdiction, (5) Protection of Plant Varieties and Farmers’ Rights Act

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that provides for registration of farmers’ varieties and for making grants to Panchayats to build

capacity for in situ conservation of crop genetic resources, (6) Introduction of compulsory

Environmental Education projects at all levels of School and College education.

The Government of Goa has taken some pioneering initiatives in this regard. Acting on the

provisions of the 73rd and 74th Amendments to the Constitution it involved the Gram Sabhas in

the process of development of its Regional Plan 2021. In the process it prepared an excellent

spatial database on land use in Goa. It has an active Goa State Biodiversity Board. It also has an

active Environmental Education programme. But much more can and should be done. We

suggest that the Central Ministry of Environment and Forests working with the Government of

Goa take the following steps:

1. Empower local bodies, i.e. Gram, Taluk and Zilla Panchayats and Nagarpalikas

and Mahanagarpalikas to make decisions on environmental issues

2. Put in place Biodiversity Management Committees in all local bodies, fully

empowered under the Biological Diversity Act, 2002, to regulate use of local

biodiversity resources, and to charge Collection Fees

3. Initiate registration of crop cultivars as called for by Protection of Plant Varieties

and Farmers’ Rights Act, 2001, and give grants to Panchayats to build capacity

for in situ conservation of crop genetic resources

4. Implement fully the Scheduled Tribes and other Traditional Forest-dwellers

(Rights over the Forest) Act, 2006, in particular, assigning the forested

Communidad lands as Community Forest Resources and involve the Gram Sabhas

in prudent management of the biodiversity resources

5. Reinstate the system of empowering citizens to monitor status of environment

under the Paryavaran Vahini scheme

6. Carry out a radical reform of Environmental Clearance process through [a]

assigning preparation of EIA statements to a neutral competent body that does not

depend on payment by project proponents, [b] making mandatory the involvement

of local Biodiversity Management Committees in the process of EIA preparation,

[c] making mandatory taking on board all information submitted and suggestions

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made during Public Hearings, [d] making mandatory periodic environmental

clearance requirement, preferably every five years, [e] making mandatory

involvement of local Biodiversity Management Committees in the process of

monitoring of implementation of conditions laid down while granting

Environmental Clearances, [f] making mandatory preparation of regional

Cumulative Environmental Impact Analyses

7. Enhance the scope of Regional Development Plans to include key environmental

concerns and make mandatory involvement of local Biodiversity Management

Committees in the process of preparation of Regional Plans

8. Promote full access to all pertinent information, for instance, through freely

making the currently suppressed Zoning Atlas for Siting of Industries (ZASI)

available.

9. Take action on organizing an Indian Biodiversity Information System (IBIS) in

line with the proposals before the National Biodiversity Authority since 2006.

10. Organize a public transparent, participatory database on Indian environment by

drawing on student Environmental Education projects as recommended by

Curriculum Framework Review, 2005 of the National Council for Educational

Research and Training.

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8. References

Scientific papers and reports

1. Administrative Staff College of India (2010) Environmental Impact Assessment

Guidance Manual for Mining of Minerals (Online). Available from

http://environmentclearance.nic.in/writereaddata/Form1A/HomeLinks/miningofminer

als_10may.pdf (accessed on 30 July 2013)

2. Alvares Claude (ed) (2002) Fish Curry and Rice: A source book on Goa, its Ecology

and Life Style, Goa Foundation Publication

3. Alvares Claude, Saha Reboni (ed) (2008) Goa: Sweet Land of Mine. Goa, Goa

Foundation Publication

4. Department of Social Welfare (nd) Survey [online] Avalaible from

http://www.goasocialwelfare.com/survey.htm [Accessed on 30th April 2013)

5. de Sousa S. N. (1999) Effect of Mining Rejects on the Nutrient Chemistry of Mandovi

Estuary, Goa (Online). Available

fromhttp://drs.nio.org/drs/bitstream/2264/1734/2/Indian_J_Mar_Sci_28_355.pdf

(Accessed on 20th january 2013)

6. D’Souza N. and Ishwar N. M. (2012), Coastal Sustainability: Learnings from MFF

(India) Projects,IUCN India Country Office, New Delhi, 32pp

7. Gauns R (2011) Mining havoc: Impact of mining on water resources in Goa - Article

from Dams, Rivers and People [Online] Available from

http://www.indiawaterportal.org/articles/mining-havoc-impact-mining-water-

resources-goa-article-dams-rivers-and-people [Accessed 20th June 2013)

8. Joshi, Vaishali C and M K Janarthanum (2004): The Diversity of Life-form type,

habitat preference and phenology of the endemics in the Goa region of the Western

Ghats, India, Journal of Biogeography (J. Biogeogr.) 31, 1227–1237

9. Kessarkar Pratima M. et al, (2013) Geochemistry of the suspended sediment in the

estuaries of the Mandovi and Zuari Rivers, Central west coast of India. [Online]

Available from

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http://drs.nio.org/drs/bitstream/2264/4288/1/Environ_Monit_Assess_185_4461a.pdf.

[Accessed on 31st July 2013]

10. NCAER (2010) A Study of Contribution of Goan Iron Ore Mining Industry. Goa, Goa

Mineral Ore Exporters association

11. Nigam R, Nayak G N, Naik S (2002) Does Mining Pollution Affect Foraminiferal

distribution in the Mandovi Estuary, Goa, India?[Online) Available

fromhttp://drs.nio.org/drs/handle/2264/1327 (Accessed on 31st July 2013)

12. Parulekar A H , Ansari Z A, Ingole B S (1986) Effect of Mining Activities on the

Clam Fisheries and Bottom Fauna of Goa Estuaries India, Proceedings Of The Indian

Academy Of Sciences - Animal Sciences (Online). Available from

http://link.springer.com/article/10.1007%2FBF03179367#page-2 [Accessed on 31st

July 2013)

13. Planning Commission (2011) Goa Development Report. New Delhi, Planning

Commission

14. TERI (1997) Area-wide environmental quality management (AEQM) plan for the

mining belt of Goa for Directorate of Planning and Statistics, Government of Goa.

(Online) Available from: http://www.teriin.org/teri-wr/projects/aeqm.htm (Accessed

on 20th July 2012) Goa

15. T E R I (2002 WR41) Environmental & Social Performance Indicators and

Sustainability Markers in Minerals Development: Reporting Progress towards

Improved Ecosystem Health & Human Well-being - Phase III. The Energy and

Resources Institute, [Project Report No. 2002WR41]

16. Venkataraman G et al, (1997) Open cast mine monitoring and environmental impact

studies through remote sensing- a case study from Goa, India. [Online] Availabe

from

http://www.tandfonline.com/doi/abs/10.1080/10106049709354584?journalCode=tgei

20#preview [Accessed on 31st July 2013]

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Official Reports

1. Jiwrajka M. K (2012) Report (Interim) of the CEC in Writ petition (Civil) No. 435

of 2012 filed by the Goa Foundation regarding alleged continued illegal mining in

the state of Goa and Associated issues. New Delhi, CEC

2. Shah Commission report (2012) (Online) Available from

http://mines.nic.in/index.aspx?level=1&lid=673&lang=1 (Accessed on 31st July

2013)

3. WGEEP. (2012), Western Ghats Ecology Expert Panel Report.

Personal/Oral communication

3. Desai Krishna (22nd Feb 2012)

4. Desai Vijaykumar (16th April 2012, 26th June 2012)

5. Gaonkar Dinanath (5th May 2012, 30th June 2012)

6. Gaonkar B B (30.06.2012)

7. Goankar Nilesh (14th Jan 2011, 22nd Feb 2012, 5th May 2012, 25th June 2012)

8. Goankar Nalcal (5th May 2012)

9. Gaonkar Sadanand (5th May 2012)

10. Gauns Ramesh (22nd Feb 2012, 27th June 2012)

11. Jog Shankar (9th May 2012, 28th June 2012)

12. Kerkar Rajendra (23rd Feb 2012)

13. Mine Managers consultation with WGEEP ( 16th January 2011)

14. Parab Hanumant C (23rd Feb 2012, 24th Feb 2012, 26th June 2012)

15. Patil Pandurang (15th Jan 2011, 21st Feb 2012)

16. Rane Umesh (24th Feb 2012)

17. Tendulkar Nitin S (28th June 2012)

18. Velip Rama (14th Jan, 2011, 22nd Feb 2012, 25th June, 2012)

19. Velip Tulsidas (14th January 2011)

20. Yeshwant Gaonkar (5th May 2012)

Written Communication

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1. Kerkar Rajendra 15th march 2013 List of Sacred Groves

2. Kerkar Rajendra 15th March 2013 Article with photos

Personal Observation

1. Dongre Sujeet (14th January 2011, 22nd Feb, 2012,23rd Feb 2012, 24th Feb 2012,

25th Feb, 2012, 5th may, 2012, 9th May 2012)

2. Gadgil Madhav (14th January 2011, 22nd Feb, 2012,23rd Feb 2012, 24th Feb 2012,

25th Feb, 2012, 5th may, 2012, 9th May 2012)

3. Gauns Akash (14th January 2011, 22nd Feb, 2012,23rd Feb 2012, 24th Feb 2012,

25th Feb, 2012, 5th may, 2012, 9th May 2012

4. Powar Shivam(14th January 2011, 22nd Feb, 2012,23rd Feb 2012, 24th Feb 2012,

25th Feb, 2012, 5th may, 2012, 9th May 2012)

Reports in Media and Website

1. The Hindu (2012) Goa puts a freeze on new barges [Online] Available from

http://www.thehindu.com/todays-paper/tp-in-school/goa-puts-a-freeze-on-new-

barges/article3607595.ece [Accessed on 31st July 2013]

2. The Hindu (2011) Attack on Nilesh Gaonkar: CABS seeks action against

assailants:16th May 2011

3. www.savegoa.com

4. www.mfgoa.com

5. www.moef.gov.in

6. www.goasocialwelfare.com

7. www.gov.gov.in

8. www.dstegoa.gov.in

9. www.forest.goa.gov.in

10. www.timesofindia.com

11. www.navhindtimes.in

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9. Annexures