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Great Nicobar Port Project: The Red Flags in EIA Report That Have Gone Ignored

The unseemly haste with which the project is being pushed through, with shoddy studies to back it up, says a lot.

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The Central government recently moved to declare a proposed international transshipment port project at the pristine and environmentally significant Galathea Bay as a 'Major Port'. This is one of the components of the drastic – and likely non-viable – Great Nicobar Island Development Project.

What could have stood between the initial conception of the ill-advised port and its now seemingly imminent realisation is the mandatory Environmental Impact Assessment (EIA) report based on which the Ministry of Environment, Forest and Climate Change (MoEFCC) – the grandiose conflation that pays lip service to forests and climate change while allowing such grossly harmful projects in this day and age of growing realisation of climate change and resultant freak weather events that wreak destruction on habitats and man alike – gave clearance to the project.

Through this article, let me list out a few of the many superficial acknowledgements, inventive reportage, and the equally asinine recommendations made in the EIA’s 'study and analysis' of the said project.
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But First, What Does the EIA Policy Mandate Before a Project is Greenlit?

  • Multidisciplinary impact assessment studies by domain experts in fields as varied as geology, hydrology and seismic studies as well as social impacts, pollution-related factors, and innumerable other factors that can result from every ill-conceived infrastructure project – in the short and long term.

  • Public hearings for potentially affected citizens to voice their fears so that the project proponents can assuage their misgivings by citing hard facts or modify the proposal after getting highly localised experience-based knowledge.

  • Ground truthing of available maps, first by the EIA agency updated as per current changed circumstances using geospatial mapping, and then an onsite detailed verification by MoEFCC representatives before accepting the EIA report and considering it.

As per the EIA report of the proposed project, the actual physical survey on the remote and densely forested Great Nicobar Island was completed in a mere seven days.

The unseemly haste with which this project is being pushed through, with shoddy studies and analyses to back it up, speaks volumes.

It Begins with a Shaky Premise

"Many areas along the coast were not even approachable by sea. Similarly, thick forest vegetation with impenetrable shrubs and climbers was not accessible without clearing the vegetation and making the way. The hills are steep, slippery and totally covered by multi-storeyed vegetation. Whenever we could gain entry through some opening into the dense/thick forest, visibility was poor; humidity was high; soil was wet and slippery on account of intermittent sharp showers every day, [and there were] invisible streams of water under a thick carpet of dead leaves and twigs… It was impossible to use any measuring devices like tape to make any quadrat in the forest vegetation… There were some limitations to the survey. It is a rapid reconnaissance type of survey, and it was not intensive except in non-forest residential areas."
Environmental Impact Assessment for International Container Transshipment Terminal

One is stupefied by the audacity of the attempt to portray an initial, vague, and distant reconnoiter as a detailed study – at least to the extent that the EIA is based on this and accepted as such by the MoEFCC.

The attitude is evident with the preceding EOICTT document of 2015 calling for expression of interest by port operators and developers itself, which states:

"The proposed site is away from mainland/urban/city limits, and thus can be master planned and shaped by the professional and experienced developers as per their own efficient designs and needs... Ample backup land for CTT with FTWZ is available in form of forest land without any rehabilitation and relief issues. The diversion of required forest land for the project shall be processed by the Andaman & Nicobar administration and all clearances shall be obtained before proceeding to signing of concession agreement."
Environmental Impact Assessment for International Container Transshipment Terminal

This shows that in the eyes of the Ministry of Ports and the Port Management Board, the ancestral denizens of the island count for nothing, be they of any species, including man.

Great Nicobar Island is seen as some sort of vacant land just waiting to be monetised.

This also shows that even our valuable collective wealth reposed in forest lands can be unlocked at will by our government as they wish, harm to citizens and ecosystems be damned.

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It further reads:

"The EIA study covered the entire area required for all the phases including rehabilitation and resettlement, breakwater, capital dredging, reclamation etc… The site is away from any habitation… The backup area will have to be developed by reclamation which will extend up to the inter-tidal zone… A small part of the proposed port area falls under the tribal reserve. However, die-notification of tribal area of 84.1 sq.km is in progress."
Chapter 2A, EIA report of the port

In today's age when its widely understood that all species are crucial for maintaining the ecosystem that supports humanity, it's disheartening to see the methods espoused here.

It is clear that extensive dredging of 19.9 million cubic metres of undersea sand and soil, and 570 acres of reclamation needing 50 million cubic metres of soil are intended to this sensitive and ecologically rich bay, in sheer disregard of consequences to its endangered inhabitants of various species.

One even wonders where this much extra soil is going to come from: Imports from mainland India or do they plan to wreck some other unsuspecting island? 
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What About the Area Under Tribal Reserve?

After first stating that there is no human habitation, what the report later contradictorily claims as 'a small part' harbouring tribals is a whole 84.1 sq km – approximately twice the size of Alwar city.

Maybe, to bureaucrats and politicians, our endangered tribal humans do not constitute humans? Are we trying to say that 'die-notification' (sic) by a remote and uncaring government in faraway New Delhi supersedes the rights of inhabitants whose ancestors have 'owned' this land? 

"The total project area for the port is 966 ha (out of which 739 ha is on land and 227 ha shall be created through reclamation)."
Chapter 2A, EIA report of the port

Reclamation of natural sea is acknowledged to be one of the most harmful things humans could do to the ecosystem and balance of earth.

Such areas of the continental shelf and inter-tidal zone are known to have nature’s mitigation remedies against events like tsunamis, as well as harbouring unique species that balance life on sea and land.

"Out of the total land 228.4 hectare is Protected Forest and 48.5 hectare is deemed forest land. 1.58-hectare land is under revenue (0.54 hectare is owned by government and 1.04 hectare is private land)."
EIA Report

Under government and private ownership are just a tiny fraction of the overall land being blatantly appropriated for this port – a large fraction being forest lands that we so far thought inviolable in our interests and those of our children and their children.

The report omits to mention whom the most major part of this 966 ha land belongs to. It is obvious that if it is not under revenue, on this remote and nearly totally forested island, it must be none other than forest – whether recognised as such by Delhi’s records or not.

Also, the main road proposed to this busy large port squarely crosses the mangrove swamp that leads outwards from Re Kayil, as the Galathea River that empties into the bay is called by the displaced Great Nicobarese who inhabited this area pre-tsunami and are now being forcibly kept away from.

Even assuming that to be a bridge (though nowhere explicit), the level of tampering being proposed in one of earth’s most biodiverse spots, to bay, mangrove and forest alike, is mindboggling.

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More Misdescriptions: Threat to Ecosystem is Downplayed

"Over time there could be some deposits on the fan of the Galathea mouth. This area needs to be dredged periodically to the keep the mouth open so that the salinity of the estuary maintained… Therefore, the proposed disposal location is found to be more ideal, and it will not cause any adverse impact on the proposed port development facilities and the marine environment…"
EIA Report

These excerpts now pertain to first the constant dredging necessary to maintain the port's depth (with disturbance of undersea sediments affecting water clarity critical for the navigation of the marine denizen), necessary to maintain the ports depths and to the dispersal of the millions of cubic metres of initially dredged sediments. This level of cupidity and wishful obduracy envisaged to nature at a spot critical to many marine species, including 179 species of 61 genera of precious, and elsewhere fast disappearing, coral, the remnants of which, after a huge, unnecessary and risky re-location of the majority, are probably too soon be covered by soil a few feet thick, leaves much for the citizen to be stupefied by.

The 3.5 km-wide mouth of the bay will be blocked completely by breakwaters, barring a narrow 300 m portion, which is the mouth of the port and will be crossed by massive incoming and outgoing container ships of up to 60 m width and 400 m length, keeping the vulnerable giant leatherback and other turtles away from their nesting beach of millennia.

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Here are some more anodyne acknowledgements from the Final EIA report of the overall project:

“It is the most imperiled (sic) ecosystem in Nicobar Island, particularly after the December 2004 tsunami this ecosystem is endangered in this island. Anthropogenic impact like… tourism activities, major constructions and shore protection structures also have impacts on this beach ecosystem.
EIA Report

This document begins by acknowledging the fragile nature and stresses of sandy beaches (of this island). This is astonishing given the project is devised precisely to take a 3.5 km or more long beach to desecrate it with reclamations and dredging of its littoral and destroy by anthropogenic and deliberate ecocide the interests of the various species dependent on the beach, or its seaward and landward environments, for their life. 

“These developmental activities increase the stress on natural ecosystems mainly on sandy beaches, forest, mangroves only.” 
EIA Report

If this is recognised by the study performed by the agency for the project proponents, why then are they persisting in violating forests, beaches and mangroves for this project?

A comparison of the Land Use and Land Cover map within the document leaves much to be wondered at too.

When seen on Google Earth, the land is seen almost uniformly covered by dense jungle, the EIA map shows much of the land to be 'dense mixed scrub'.

When, by their own admission, much of the forest was impenetrable, one wonders on what basis they arrived at this conclusion regarding forest cover, and if this is some thinly disguised ploy to prepare the ground for urbanisation of additional forest lands.

And when we see that these conclusions have been arrived at merely based on satellite imagery 'Dense Vegetation / Dense Mixed scrub was identified imagery by its red tone, irregular shape and coarse texture' — with no actual ground truthing or detailed study – one’s trepidations are confirmed.

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“...the river mouths of Galathea, Alexandria, and Dagmar Rivers are popular leatherback nesting beaches on this island. Hence, (the) team cannot think of shifting the proposed port to the mouth of Alexandria and Dagmar Rivers."
Wildlife Institute of India (WII) in an RTI response

When Galathea Bay is acknowledged by WII itself to be the largest nesting site on this island, one wonders why it is singled out for the port: and lesser sites preserved?

Once the mouth is 92 percent blocked by the breakwater, with the narrow entry seeing heavy movement of huge container vessels, definite harm to incoming or outgoing turtles, along with the dugongs and dolphins habituated to using this bay, is certainly foretold.

The few turtles which may manage to make their determined (and deadly) way up to whatever little stretch of beach that is very optimistically supposed to exist after the illustrated drastic reclamation, are unlikely to lay eggs there or ever return.

This port, when it reaches its peak capacity (approximately 50 percent that of Singapore, the world’s busiest port) is likely to be too light polluted, leave alone polluted by oil discharges and all the debris that a busy port would exhibit – hardly a conducive nesting habitat for the giant leatherback which is extremely sensitive to light pollution and used to clean open seas. By robbing it of one of its largest nesting sites we are all set to do further harm to this species.

As noted in an illuminating article by Delft University in Scientific Reports, "Climate change and human activity pose many different challenges to sea turtles, including the flooding and erosion of their nesting habitats – sandy beaches. Although sea turtles have successfully evolved and adapted to habitat changes over millions of years, their slow population growth rates mean they are unable to recover quickly from population declines (recovery rates of sea turtle populations can range from several decades to 100 years). This makes them particularly vulnerable to relatively fast-paced changes to their nesting habitat, such as current human and climate-induced effects on nesting beaches”.

It is obvious that the giant leatherbacks are not meekly going to move their nesting activities to the next beach on the island. The world is set to suffer a decline in the numbers of this keystone species if the project is realised.

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The True Cost of The Project

Finally, from the 'mitigation measures' suggested by the MoEFCC, and sanctimoniously attached to every call for tenders, one finds these nuggets:

“Trees with nesting holes of endemic owls to be identified and geo-tagged... Such trees shall be safeguarded, as far as possible.” 
EIA Report

With a rankly underestimated 18,65,000 trees within the 160 sq km of land, the sheer impossibility of surveying the also underestimated identified ill-fated 9,60,000 trees, many as high as a 15-storeyed building, in a dense impassable forest (as per their own admission above) – to identify firstly the nesting hole locations, and then to know which exact species nests in them – given that owls nest only in winter and do not leave calling cards behind – would probably take a century of winters: if at all we had such hundreds of highly experienced experts to volunteer to live on this remote undeveloped island to undertake this task over many years.

And then, which sensible owl couple would elect to nest in a tree hole a spitting distance from one of the many buildings, or power plant, or a noisy airport or clanging port of the project, even if we kind humans were to leave the particular tree standing? 

One is even tempted to ask how these estimates of trees of a dense impassable tropical rainforest, which has intertwined trees of various heights, has been achieved – and whether it is in itself at all trustworthy. And yes, it seems it indeed is not.

A mere 1.86 million trees over a whole 160 sq km translates to trees spaced apart 85 metres from each other – hardly a dense rainforest. Experts, using previous detailed academic studies of this very island, estimate nearly a 1,000 trees per hectare, i.e. a total of 13 million trees in forest area alone – of which the half to be eliminated in this folly would be a staggering 6.5 million precious trees!

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“It was impossible to use any measuring devices like tape to make any quadrat in the forest vegetation. Hence, intensive survey was carried out on both sides of the Campbell-Indira Point for four days. It is about 45 km and the entire stretch was survey (sic) eight times in four days.” 
EIA Report

So, now we are called upon to accept an admittedly incomplete survey (that took over a mere four days) that completely omits to study the actual dense rainforest that supports many dozens of endemic species – nearly 25,000 species of vascular plants – 60 percent endemic – in Cretaceous era tropical wet evergreen forests, mountain ranges, coastal plains and shoreline, a wide variety of plant and animal species, including 650 species of angiosperms, ferns, gymnosperms, bryophytes, and lichens, as well as 14 species of mammals, 71 species of birds, 26 species of reptiles and 10 species of amphibians, many unique to this island itself?

These suggestions are alongside such wild imaginations such as translocating Nicobari Megapode nests (acknowledging more than 60 percent will be destroyed and only the "remaining population" can be conserved), and acknowledging that invasive species might overwhelm the native flora of the island given such huge influx of human population & shipping vessels, but for the sake of brevity cannot be dealt with fully here.

When the EIA study so totally departs from the intended spirit of true environmental assessment, by not studying the details of the surrounding “environment” to be able to extrapolate the project’s “impact”, and suggesting mitigation measures any one with better knowledge would scoff at, how is that in any manner acceptable to the MoEFCC and this process.

If the sole job of this ministry now is to merely rubber stamp projects that other ministries are the proponents of, India may as well save herself the money and space devoted to its thousands of staff and have a sole man with a rubber stamp in a small room in Paryavaran Bhawan.

(A more detailed understanding of the issues involved can be accessed via the underlined links within this article.)

(The author is a Delhi-based architect. This is an opinion piece and the views expressed above are the author’s own. The Quint neither endorses nor is responsible for the same.)

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