Reply to MoEF by Deepak Kantawala

30^th May 2011

Mr. Bharat Bhushan,

Director (IA-III),

Ministry of Environment & Forests,

Paryavaran Bhavan,

CGO Complex,

Lodhi Road,

New Delhi-110 003

Sub: Environmental Impact Assessment and Metro Projects

Ref: Your Letter F.NO. 20-83/2011-IA-III dated the 9^th of May 2011

Dear Shri Bharat Bhushan,

I am in possession of an RTI reply from your office dated 9^th May 2011 in response to few queries raised by a Citizen Group regarding Metro Line II in Mumbai. I am writing this letter as an environmental engineer with more than 40 years of experience in the field of environmental engineering, to express my dismay at not subjecting the Mumbai Metro project to a comprehensive Environmental Impact Assessment (EIA).

We are aware that the Railway and Metro Projects are not listed under the schedule of activities/projects in the EIA Notification, 2006 and do not require prior environmental clearance. The question is about the rationale for such exclusion.

A large number of concerned citizens had submitted a petition requesting the Ministry of Environment and Forests to include the Metro Projects in the Schedule to no avail. It is difficult, if not impossible, to understand the logic behind this exemption to a project that is expected to have significant environmental and socioeconomic impacts and would affect the lives of millions of people.

Environmental Impact Assessment is the only tool that will provide a priori assessment of environmental and socio-economic impacts, will permit a formalized public consultation and require the formulation of an Environmental Management Plan to mitigate and minimize the impacts.

We also are not able to comprehend, how a piece meal environmental clearance to commercial components would mitigate the overall impact. We do not know how environmental clearance would be processed for these “ components”. Would that be based on EIAs limited to the “components?” Is it not more appropriate to undertake a comprehensive EIA of the entire project rather than “adding up the” component clearances? In fact my understanding is that almost all the international funding agencies like the World Bank, Asian Development Bank etc. insist that if a component of a project requires an EIA the entire project must be subjected to the EIA. This seems to be a logical recommendation.

How would the following questions agitating the minds of citizens, and which are part of a comprehensive EIA, be answered?

1.  Is there a Master Plan for Mumbai Transportation  including the existing network of suburban trains, buses, private transport, proposed water transport etc.?
2.  Metro the only alternative and does it form a component of such a master Plan?
3. Which of the two alternative approaches, over ground or underground, would have minimum environmental and socio-economic impacts and long term advantage of phased expansion?
4. What alternatives routes are possible and which would have the least impact?
5. Have the people expected to be affected consulted and have their inputs considered dispassionately?

When irrigation projects, highways, housing projects and even sewage treatment plants and sewage disposal systems have to undergo EIA it is truly amazing, if not mind boggling, that a project estimated to cost thousands of crores of rupees and impact millions of lives is exempted!

I would once again request you to subject the Metro Projects across the country and especially in Mumbai to a comprehensive Environmental Impact Assessment.

Thanking you,

Very truly yours,

(Deepak Kantawala)