v) NEERI CEIA Study incomplete biased and inadmissable.
The envisaged scope of CEIA, as mentioned in 1.5 (page 1.22) includes interalia identification and quantification of significant impacts of mining operations and associated activities on the environment.
Unfortunately, the CEIA has ignored the KIOCL pipeline and the further processing of Iron Ore at Mangalore, where the ore pumped from the pipeline is stock piled in a 400,000 tonne storage area. The concentrate in filter cake form is conveyed either to a ship loader directly or to the pellet plant. In the pellet plant the filter cake is mixed with lime stone, bentonite and coal and further conveyed to pelletising discs for production of green pellets. These are screened, dried and pre-heated, fired at high temperatures and cooled. The operations at Kudremukh and Mangalore are linked by a advanced telecommunication network. The company claims to have installed effluent treatment plant at Mangalore to treat effluent water before disposal.
The NEERI has conducted its studies only at the mining area. The pipeline and further processing activity at Mangalore involves considerable air and water pollution and high risk to environment and marine ecology, and has been completely ignored by the NEERI study team, even though a mention has been made in the scope / terms of reference for the EIA study.
As such the study remains incomplete and the CEIA submitted to the Government is also inadequate and biased therefore NEERI Report is not admissable in its present form.
vi) Diverting the river without permission
It is mentioned in 1.3.5 (a) (11) of the CEIA that two rock dams have been constructed, in addition to the Lakhya Dam and also mentions that the company has diverted Kudremukh hole, by constructing a channel of 900 m. length at a cost of Rs. 103 lakhs.
The above acts are in violation of Section 46, of the Karnataka Irrigation Act 1964, which prohibits putting up construction across water bodies or control of water bodies without the previous sanction of the State Government, as evidenced in our report.
The company has not obtained the requisite permissions for putting up the above constructions, but has pleaded with the Government for ex-post facto approval for its misdemeanors!
vii) NEERI bungles with floral and faunal studies
Random sampling by adopting quadrate method with quadrate divisions to study the density of species, diversity of species, frequency of occurrence, and distribution pattern have not been adopted. Density determination is one of the tools in impact determination. The diversity is determined by natural or anthroponic activities and some species have greater tolerance compared to others in a given situation.
To know the effect of mining, the study team should have looked into the number of species and total number of individuals in all quadrates and tabulated them to indicate the richness in species. Diversity index by applying Shannon and Wieners method or any other method should have been adopted. Frequency estimation studies are inadequate and missing.
Even the distribution pattern viz., regular, contagious and random have not been projected in the floral studies, which is important to detect the pattern of distribution and determine the characterisation of vegetation. Intrinsic and extrinsic factors affecting the vegetation pattern are not discussed.
Only such studies can throw light on the impact of mining on vegetation and forest cover.
The NEERI study team has not conducted any studies at all on flora and fauna. They have blindly compiled the data from Forest Dept or KIOCL publications of and reported them in the CEIA.
The company claims to have afforested 1224.20 ha by planting 75 lakh saplings.
It does not offer a clue as to the density or survival ratio of these saplings. While many of them are stunted and hardly 6 to 12 inches in circumference at shoulder height, many others have wilted and perished.
This is especially so in the abandoned mine area.
Just to prove our point we would like to reproduce some paras from the KIOCL letter the The Chief Engineer, WRDO, on Nov. 16/1991
4. With a view to preserve the ecology and improve the afforestation after complete of the project and full mineral resources are exhausted, we have developed a plan by which a large number of seedlings will be planted on the tailings deposit to enable good forest growth. We as an experimental measure, have planted seedlings on the terrace of the existing Lakhya dam and the survival rate has been very good. In the circumstances, a good forest tree growth is assured on the terrace of tailings deposits and thus there can be no wash off of any silt etc., into river even during heavy monsoon in future.
Exactly opposite a finding has been noticed by CES in its report which has confirmed that there is very low diversity and there is no regeneration in the abandoned mine belt. This has been further endorsed by the Deputy Conservator of Forests, Kudremukh Wildlife Division, in letter No. C3/CR/30/KNP/99-2000, dated 30.6.2000 to the D.C. and Settlement Officer, Chikmagalur.
Exposure of these areas the soil cover and disturbs the site. The already existing mining site is a proof of this as not even a blade of grass grows in the mined area, where the top soil has been disturbed. The Forest Officer wrote added in the same letter The loss of soil cover is too evident from a mere look at the mined area as well as the colour of the water of Bhadra river before and after it passes through the mining site. Though the technical studies have been initiated to assess the actual extent of soil loss, but the facts are too visible and easy to understand. The use of heavy machinery will lead to soil compactation which cannot allow regeneration of the area in any manner.
So it is clearly evident that the NEERI study team has blindly collected the data from the KIOCL and projected them.
How can any one consider these failed afforestation programmes as sound environment management plans.
Certainly, the NEERI study has no earthly use at present. No wonder a similar report of NEERIs was rejected by the environment committee of Gujarat, after a public hearing held in May 2001, to clear the motor spirit quality upgradation project of Indian Oil Corporation.
The environment impact assessment prepared by NEERI was rejected following the hearing of eminent environmentalists of Gujarat and IOC has to now engage another organisation to prepare a fresh EIA report.
ix) NEERI Report - Howlers Galore ?
The CEIA prepared by NEERI has many short commings in respect of floral and faunal studies. Many species are repeated or synonyms included separately in the list and the occurrence of some are doubtful in the region. Some strange names are mentioned for eg : - Wild Sheep is included in the list of wildlife and the occurrence of Black-Buck (194 in number) takes the cake. Among birds Black-naped circle is mentioned, which needs some soul searching. But one misfit statement stands the best of all (Page no. 2.15) Assessment of fauna due to the availability of food in local forests, the wildlife in the study do not migrate from one forest to another in search of food.
To counter this statement, we are providing a note by a CES Scientist, from a Newspaper Report
Kudremukh, the key link in elephant corridor?, Indian Express, dated 7th July 2000
Even as the Centre plans to denotify the Kudremukh National Park in Chikmagalur district to accommodate further mining in the area, a small number of elephants are trying to make this region their new habitat.