Shri. Lalit Kapur,
Director (IA-III),
Ministry of Environment and Forests,
Government of India
Sub: Please for granting im...
documents published by VISL as part of the EIA process, please note the following points in
this regard, as propagated by ...
been actively trying to spread negative feedback with the community with malicious intent,
using such tactics as poster ca...
beach is formed with rocky cliffs and sea wall protection and these would by itself prevent
any erosion at this strip of l...
average of 0.025m per year, a negligible volume. Records from the Harbour Engineering
Department, Kerala (HED) indicates t...
Larssen) and is noted to exist approximately 40 Kms South West of the proposed port
location. This Wadge bank is also loca...
of a total of 500 rooms in all the affected resorts and a cost of Rs 30 Lakhs/key which is the
industry standard for 3 or ...
12) Finally, it is to be noted that in view of the increasing security threats in the Indian
Ocean region (piracy, Chinese...
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Letter to the Expert Appraisal Committee for clearence


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Letter to the Expert Appraisal Committee for clearence

  1. 1. Shri. Lalit Kapur, Director (IA-III), Ministry of Environment and Forests, Government of India Sub: Please for granting immediate Environmental Clearance for the Vizhinjam Deep-water Port and Container Transshipment Terminal project Respected Shri. Kapur, We are writing to you to express our strong support for the Vizhinjam deep-water port and container transshipment terminal project in Kerala that is currently awaiting Environmental Clearance from the Ministry of Environment and Forests. The project has been a long cherished dream of the people of Kerala, and has perhaps the most public support of any port project proposal in India. It has support from the entire community, except from a small group of vested interests who are opposing the project for very selfish reasons. The project has received massive support during the public hearing, as you may well be aware of, which is truly representative of the voice of the people from the State. The proponent of the project, VISL had also taken all steps to educate the local community on all possible environmental and social impacts and we understand that the project has undergone all studies for assessment of the environmental and social impact, including mitigation measures, as necessitated by the Central Government. We are fully aware of the likely minimal environmental and social issues the project may manifest in the locality. The project will significantly improve the logistics and trade portfolio of our nation by putting South India on the International Maritime Map, thus stimulating the potential for massive industrialization. We request that the Ministry not indulge the machinations of a handful of shadowy resort owners with very dubious environmental records of their own who are intent on trying to delay or scuttle a major infrastructure project, that not only has bipartisan political and public support, but which can also significantly improve the livelihood of large numbers of people, especially the economically disadvantaged sections of society whom these owners also claim to represent. The complainants who have been opposing the project, are actively spreading negative sentiments about the project among the local community and have spared no expense to harness the media to spread negative news about the project. Based on our understanding of the allegations raised by these vested interests, from publicly available sources including media reports, various complaints filed by them and
  2. 2. documents published by VISL as part of the EIA process, please note the following points in this regard, as propagated by the complainants: 1) The complainant has raised the allegation that the project shall impact the fishing ground at the port location. It is to be noted that the selected location is currently not having any fishing activity except for limited mussel collection owing to the rocky patches and is only a fish landing harbour. All the existing activities shall thus continue status quo and indeed only improve with the project being implemented creating a new fishing harbour as well as with mussel beds being formed at the outer breakwater location. 2) The complainants have alleged significant loss of income for local community. The loss of income has to be noted for only a very handful of people, including the owners of the small number of resorts that are directly affected by the project and a very small community of fishermen for initial 3-4 years of construction activity. It is to be noted that this loss of income is temporary in nature, as any displaced resorts can relocate to other locations in the Kovalam-Poovar tourism belt and the mussel fishermen can resume activities once the port has been built. Considering a project of this magnitude that can significantly improve the livelihood of a large community, this temporary income pales into insignificance with the future economic benefits. The tourism and resort industry as a whole stands to benefit the most from the project with the cruise terminal in place. Many of the complainants are resorts such as Travancore Heritage and Somatheeram that are not directly affected by the project as well as shopkeepers in the vicinity. These parties suffer no direct economic harm and instead stand to benefit from the tens of thousands of highend tourists who would be brought in by the port’s cruise terminal. Thus the allegations of widespread economic loss are only intended to stir up concerns in the local community as well as to try to paint a grim picture of overall economic loss. 3) The complainants have alleged obstruction of access to existing fishing harbour. As the Ministry is well aware of, (and according to the UN International law of Seas UNCLOS), the fishing vessels stand priority among any other motorable vessel and thus the allegation stands invalid at any case. There are a large number of ports in India and abroad where fishing harbours and major ship terminals co-exist within the same facility, the Cochin port being nearest and best example to cite. Moreover, the frequency of ship movements will be limited, about three ships a day which will cause only minimal disruption to the passage of fishing boats. The local fishing community also understands the matter well and has supported the project with a single voice, however the complainants have
  3. 3. been actively trying to spread negative feedback with the community with malicious intent, using such tactics as poster campaigns and disinformation communicated through religious institutions. 4) The complainants alleged that the dredging and reclamation of the sea would severely impact the environment. Reclamation is a widely accepted infrastructure asset creation process with almost all of the largest ports in the world operating on reclaimed land. The Vizhinjam project envisages only 60 hectares of reclamation. In comparison, the existing Colombo port sits on a 210hectare parcel of reclaimed land. Singapore port is currently operating on 500 hectares of reclaimed land whereas in Rotterdam 700 hectares of land was reclaimed for the newly constructed Maasvalakte II port project. Middle Easten port projects include Jebel Ali Port, Dubai (100 hectares), Khalifa Port, Abu Dhabi (270 hectares), New Doha Port (600 hectares) and Sohar Port (130 hectares) to name a few. In comparison to the above projects, Vizhinjam is envisaged to reclaim only a very small portion and the precedence being that reclamation process can be implemented with minimal environmental hassles if properly planned and executed as envisaged in the EIA. The complainants also make nonsensical allegations such as the fact that sediments from the Western Ghats would fill in the harbor basin during each monsoon season and that the shipping channel would be filled in by sediments. It’s clear even to a layman that a protected basin like at the Vizhinjam port will not be filled in by sediment run off. Moreover there is not inflow channel in the area that could bring additional sediments to the port basin. Similarly, the natural draft at the port sight (18 m at 500 m from the shore and 21 m at 1 Km from the shore) are the best proof of the fact that sediment movement in the area is minimal and stable, precluding the allegations that the approach channel (itself only 21 m deep) will be continually filled in. Such allegations have been made by hired consultants on the payroll of the resort owners and are totally baseless and desperate attempts to sabotage the project’s environmental clearance. 5) The complainants alleged that the project would increase the sea erosion and bring significant shoreline changes. It has been scientifically accepted by all concerned authorities and research institutes that the littoral drift pattern at Vizhinjam is negligible compared to other locations in South India. Moreover, the littoral drift pattern is bidirectional based on seasonal changes at Vizhinjam against unidirectional pattern tomost other locations. Studies by INCOSIS state that additional land would be created south of the port and the possibility of negligible erosion to the North. It should be noted that to the north of the project site, Poonthura
  4. 4. beach is formed with rocky cliffs and sea wall protection and these would by itself prevent any erosion at this strip of land. Proper design of the port will further ensure minimal impact on the shoreline and littoral transport patterns. Thus the allegations by the complainants are only aimed to create a panic among the local community and are totally baseless. 6) The complainant had alleged that the proposed port would be silted annually in the order of 5 million cubic metres of sediments after every monsoon. This silt would be created from the monsoon runoff from the nearby land towards the sea. It has to be noted that the above mentioned scenario stands valid only in the case of riverine or estuary ports that too in worst case scenario. To note is that this chosen location at Vizhinjam has no rivers nearby, nor does the land behind is sandy or silty enough to pour the sediments to the basin. It is a known fact that the coast along Kovalam and Vizhinjam is lined with rocky patches and these rocks by themselves would be a natural barrier against any silt flow from the land. This is also one of the reasons why Vizhinjam was chosen for a deep-water port against Poovar area, the latter having the presence of the Neyyar River. The complainant also had missed out a key component of the port – its Quay Wall or the Berthing Structure where the ships berth against the wharf. This structure also acts a barrier against the silt to be formed inside the basin by the virtue of pavements and geotechnical protection. Further, the 500m long South Side revetments will prevent any siltation due to littoral drift (shore based movement). Any accretion due to silt transport is expected to form at South of the basin and will be less than 50m (26m as per the modelling studies) and the remaining 450m shall prevent any such siltation in the port. The siltation volume at the existing fishing port, due to littoral drift, was recorded as 3,000 m3 per year. Once the new port is built this volume is expected to be as low as 200 m3 per year. Hence it can be concluded that the issue of siltation as alleged is baseless and the siltation volumes are very minimal owing to the protected terrain at Vizhinjam and by the virtue or how ports are built. 7) The complainant had alleged that the proposed port would be requiring significant amount of annual maintenance dredging. The siltation volumes at the proposed port site are relatively very low and the mathematical modeling conducted by L&T Ramboll, an accredited agency for conducting such studies, states that the annual maintenance dredging volumes expected are only in the order of a maximum of 30,000 m3/year. When compared to the area of approach channel within the port would get distributed along and the sediment would decrease the draft only by an
  5. 5. average of 0.025m per year, a negligible volume. Records from the Harbour Engineering Department, Kerala (HED) indicates that only 92,615 m3 of capital dredging has been undertaken until 2002 in the existing fishing harbour which includes creation of a basin inside the harbour. There was no capital or maintenance dredging within the harbour from 2002 to 2011 and a maintenance dredging of 25000 m3 inside the harbour was undertaken after 10 years during 2011-12. Based on the above analysis, it may be concluded that the rate of sediment transport is low in the area. Hence it can be concluded that the proposed port would not need any kind of maintenance dredging for many years or decades. 8) The complainant had alleged that the construction of the breakwater at the proposed port is non-feasible owing to the distance from quarry and transportation of quarry materials in barges from Muthalapozhy during monsoon season need high amount of maintenance dredging. The construction of breakwater at Vizhinjam is currently proposed under an Engineering, Procurement and Construction (or EPC) package. This means the responsibility of sourcing any material, including the mentioned quarry, rests with the construction contractor. The proposed quarry location and transportation method would only be a guide for the contractor and he could use it during the non-monsoon seasons which the claimant himself has agreed to. There are also multiple source locations identified and multiple transport options for the rock needed for the breakwater. In the case of transport of rock via barges, these are of relatively shallow draft and will not need sort of dredging that is alleged. Indeed, the drop barges that place breakwater material are designed to have minimal drafts so that they can place rocks as close to the sea surface as possible, after which further rocks are placed via crane. During monsoon season, if demand may arise the contractor may use alternate transportation of such materials. Also as per the current design the outer layer of breakwater is proposed as a concrete armour unit to minimise the use of rocks. These contracts are also typically written under strong clauses laid down by international laws such as FIDIC or similar which would also impose performance warranty for the engineers and contractors. The core of the breakwater construction which needs most of the rocks will be completed in one year and even if construction takes two seasons, work will most likely be suspended during the worst of the monsoon. All of this is factored into the timeline and cost estimates prepared. Thus the fear of the claimant is baseless. 9) The complainants allege that the Wadge Bank would be destroyed when the port becomes operational. Wadge banks are fish breeding grounds which by virtue of their fertility have been scientifically acknowledged as rich in biodiversity and marine ecology. The Wadge bank nearest to the port site spreads over 3000 square miles (The Fishing Chart of India, Kare
  6. 6. Larssen) and is noted to exist approximately 40 Kms South West of the proposed port location. This Wadge bank is also located 50m to 200m deep from the sea level. It is to be noted that the Europe – Far East international maritime sea route lays exactly on top of the Wadge bank which already experiences large numbers of vessel movements on daily basis. Thus the allegation that the Wadge bank would be destroyed due to the port being built such a significant distance away from it under discussion is completely baseless and is only to create apprehensions among the local fishing community. 10) The complainants allege that the loss of income due to the project outweighs its economic benefits. Even with a throughput of 1.5 Million TEUs / year as envisaged in Phase I of the project, the container terminal at Vizhinjam alone will generate revenues of Rs 900-1200 Crores a year. At full capacity, the project could generate revenues of over Rs 2500-3000 Crores a year. The actual economic impact of port projects is mostly indirect in nature, by spurring industrial development and employment in the surrounding region. A world-class container port spurs the develop of industries such as logistics and manufacturing, as is evidenced by the economic development witnessed in Singapore, Rotterdam, Barcelona, Los Angeles, Savannah and other global ports across the world. This economic impact has not been studied in detail in the EIA but can easily be expected to generate thousands of Crores of incremental economic activity each year. Thus the boost to Kerala and India’s economy would be manifold than any estimate of the direct benefit. Moreover, it would save hundreds of millions of dollars of invaluable foreign exchange that is currently being spent by Indian exporters/importers in transshipment at foreign ports like Colombo, Singapore, Dubai and Tanjung Pelapas. On the other hand, the resorts falsely claim that they have a greater role in the economy than the port. While the claim that the port will affect 31 resorts is very suspect, even if this is accepted at face value, the great majority of these are small properties, the largest two having less than 50 rooms. They may have no more than 300-400 rooms in all. None of the resorts directly affected by the project are higher than the 3 star category. Considering the prevailing market rates in Kovalam, a quick back of the envelope calculation shows that their total annual revenue is of the order of Rs 30-35 Crores (400 rooms X Rs 3000/night X 365 days X 60% occupancy). This is probably a very generous estimate. As per the records made public in the complaints submitted by the resorts, most of them have turnovers of less than Rs 1-5 Crores, with only a very few recording revenues in excess of Rs 5 Crores/year. The complainants deliberately exaggerate the magnitude of the economic value and employment supported by their establishments. For example, even with an upper estimate
  7. 7. of a total of 500 rooms in all the affected resorts and a cost of Rs 30 Lakhs/key which is the industry standard for 3 or 4 star facility (most of the resorts are in fact less than 3 stars in terms of classification), the total value of the resorts works out to about Rs 150 Crores (this assumes that all the resorts have been newly built, which is not the case!). Similar gross exaggerations have been made about the quantum of employment at the resorts, which is probably less than or about 1000 in all. Most of these employees will be able to relocated if the resorts move to other nearby locations or if the tourist industry in general expands on account of the port’s cruise terminal. 11) The complainants allege that the project will have a wider adverse economic impact for the tourism industry. They have deliberately brought in references to the turnover and employment numbers of the aggregate tourism Industry in the Kovalam-Poovar belt to deliberately mislead the Ministry and other concerned authorities as to the economic value supposedly at risk because of the project, when the truth is that there’s absolutely no detrimental impact to the wider tourist industry. Indeed, they will all benefit from the port’s cruise terminal. It is to be noted that no resort outside the immediate project area has filed a complaint or raised a protest. The vast majority of the resorts in the Kovalam-Poovar tourist belt lie outside the project area and have not joined the complainants in their dire predictions that beaches in the vicinity will vanish. Indeed, the Trivandrum Chamber of Commerce, the local chapter of the Confederation of Indian Industry and other commerce-minded organizations have consistently come out in support of the project. It’s understood that the broader tourism industry and the business community are in favor of the project and thus the claims of the complainants that tourism in the entire region will be destroyed are gross exaggerations and not shared by other stakeholders in the vicinity. The construction of a cruise terminal in the port could bring at least 50-60 ships a year and over 100,000 new tourists to the area, because of Vizhinjam’s proximity to the shipping lanes that carry hundreds of cruise ships each year. (The port in Cochin, which is 200 Km further away from the shipping lanes and which does not have a dedicated cruise terminal, received over 40 ships and 60,000 tourists last year alone). It has been estimated that on average a cruise tourist spends about $200 on a shore excursion and up to $250/day if beginning or ending the cruise at Vizhinjam. Even with rather conservative assumptions, this works out to over Rs 100 Crores/year of additional revenues to resorts in the area. This would be a massive boost to the tourism industry around the project, especially to resorts in the immediate vicinity.
  8. 8. 12) Finally, it is to be noted that in view of the increasing security threats in the Indian Ocean region (piracy, Chinese naval expansion into Sri Lanka and Myanmar etc) and the request by the Indian Navy and Indian Coast Guard to build a major naval facility as part of the Vizhinjam project, the port assumes very strategic importance and should be considered a vital national security asset. In short, MOEF has been asked to sit in judgment on a complaint that has no basis in truth, science, sincere concern for the environment or for the welfare of the community. This is an attempt to pervert the very purpose of an institution like the MOEF to serve very narrow vested interests of a small group of individuals. The Vizhinjam port project has been the dream of an entire State for over five decades and I certainly hope that you will help it reach fruition at the very earliest. As Indians who have earnest aspirations about the Nation’s progress, it is our sincere and urgent request that MOEF may grant all required clearances for commencement of the project at the earliest. We are ready and willing to support in any way to make this project a reality. Looking forward to your early action, Sincerely, Ajay R Kamath