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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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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
16 | P a g e
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
22 | P a g e
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
23 | P a g e
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).
24 | P a g e
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,
25 | P a g e
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
26 | P a g e
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).
27 | P a g e
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
28 | P a g e
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
29 | P a g e
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.”
30 | P a g e
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
31 | P a g e
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)
Japan for
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32 | P
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33 | P a g e
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)
34 | P a g e
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
35 | P a g e
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)
36 | P a g e
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)
37 | P a g e
Map V Quepem taluka land use map (Source; savegoa.com)
3.2.4 Land use of Quepem Taluka
38 | P a g e
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
39 | P a g e
Map VI Bicholim taluka land use map (Source; savegoa.com)
3.2.6 Land use of Bicholim Taluka
40 | P a g e
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)
41 | P a g e
Map VII Sattari taluka land use map (Source; savegoa.com)
3.2.8 Landuse of Sattari taluka
42 | P a g e
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)
43 | P a g e
Map VIII Bardez taluka land use map (Source; savegoa.com)
3.2.10 Landuse of Bardez Taluka
44 | P a g e
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)
45 | P a g e
3.2.11Ponda taluka
Map IX Ponda taluka land use map (Source; savegoa.com)
46 | P a g e
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)
47 | P a g e
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
48 | P a g e
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
49 | P a g e
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)
50 | P a g e
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
51 | P a g e
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.
52 | P a g e
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)
53 | P a g e
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)
54 | P a g e
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.
55 | P a g e
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
56 | P a g e
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.
57 | P a g e
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
58 | P a g e
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
59 | P a g e
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
60 | P a g e
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.
61 | P a g e
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
62 | P a g e
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).
65 | P a g e
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.
85 | P a g e
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
86 | P a g e
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
87 | P a g e
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
88 | P a g e
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.
89 | P a g e
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
90 | P a g e
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.
91 | P a g e
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
92 | P a g e
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
93 | P a g e
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
94 | P a g e
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
95 | P a g e
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
96 | P a g e
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
97 | P a g e
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
98 | P a g e
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
99 | P a g e
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
100 | P a g e
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
101 | P a g e
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.
102 | P a g e
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
103 | P a g e
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
104 | P a g e
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.
105 | P a g e
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
106 | P a g e
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
107 | P a g e
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
`.
110 | P a g e
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
112 | P a g e
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
113 | P a g e
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
114 | P a g e
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.
115 | P a g e
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
116 | P a g e
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]
117 | P a g e
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