To, Prof. T. Haque, Retd. Director & CEO, Council for Social Development, 53, Lodhi Estate, New Delhi

Dr. N. P. Shukla, Ex. Chairman, MPPCB, H-44-B, Apsara Complex, Indrapuri, A-Sector, Bhopal - 462021, Madhya Pradesh

Dr. H. C. Sharatchandra, Ex. Chairman, Karnataka, SPCB "Belaku" 66, 3rd Cholanagara Main Road, Amarjyothi Layout , Bangalore - 560032, Karnataka

Sh. V. Suresh, Former CMD, HUDCO, 3203, Verona, Cliff Avenue, Hiranandani Gardens, Powi, Mumbai- 400076, Maharashtra

Dr. V. S. Naidu 307, A2 Wing, Dewan Mansion-I, Opp, Panchvati, Ambadi Road, Vasai (West), Dist Palghar -401202, Maharashtra

Sh. B. C. Nigam, IFS (Retd), A-804, Aims Golf Avenue-1, Plot No. 2, Sector-75, Noida-201304, Uttar Pradesh

Dr. Manoranian Hota, Advisor (Retd), MoEF&CC K-184, Gulshan Ikebana, Sector-143, Noida, Gautam Budha Nagar201301, Uttar Pradesh

Dr. Dipankar Saha, Addl. Director (Retd), CPCB 214/5, Banamalipur Road, Purbapara (Near Maitri Sangha Club), PS&PO-Barasat, 24 Parganas-North - 700124, Kolkata (West Bengal)

Dr. Jayesh Ruparelia, Professor & Head, Chemical Engineering Department, Institute of Technology, Nirma University, Ahmedabad, Gujarat

Dr. (Mrs.) Mayuri H. Pandya, Director I/C (Associate Professor), GLS Law College, Ahemdabad, Gujarat

Dr. M. V. Ramana Murthy, Project Director (Scientist G), National Institute of Ocean Technology (NIOT), - Main Road, Narayanpuram, , - 600 100,

Prof. Dr. P.S.N. Rao, Director School of Architecture and Planning, 4, Block B, I P Estate, New Delhi- 110002

Shri Kushal Vashist, Director Ministry of Environment, Forest and Climate Change Jor Bagh Road, New Delhi-110003.

Date: 26th January 2019

Subject: Consideration of “Proposed Revised Master Plan development of Port by Marine Infrastructure Developer Private Limited (MIDPL) at Kattupalli, Taluka, District, Tamil Nadu” in the 38th Meeting of the CRZ (Infra 2) EAC Meeting on February 06th 2019 Sir/Madam, This is with respect to consideration of project mentioned in subject above in the 38th Meeting of the CRZ

(Infra 2) EAC Meeting on February 06th 2019, and thereafter. We would like to bring the following points to your notice –

Ecological Sensitivity -

1. The facilities proposed in the “Revised Master Plan” of the Katupalli port involves the conversion of 1136 Hectares/2807 Acres of the Creek and its associated into industrial real estate for the expansion of the Katupalli port. These areas have been earmarked as Salt Pans, , Intertidal Areas and No Development Zone (CRZ 1-A, 1-B, CRZ III (NDZ) and CRZ IV) as per the approved Coastal Zone Management Plan 2018. Activities like reclamation for construction of such facilities is a prohibited activity in these areas. (Attached – Map Overlaying Project Boundary on CZMP 2018)

2. Through a letter dated 16.12.2014, Secretary (Environment & Forests). Government of Tamil Nadu while recommending conditional clearance to a proposal by Kamarajar Port made it very clear that Salt Pans are CRZ 1B (intertidal areas) as per Tamil Nadu's approved Coastal Zone Management Plan. Government of Tamil Nadu has expressly prohibited reclamation of saltpans. (Attached).

3. The Rules, 2010, state that wetlands or wetland complexes below an elevation of 2500 metres with an area equal to or greater than 500 hectares (1236 acres) shall be regulated as protected wetlands. With its more than 10000-acre water spread area, the and Backwaters is a “protected wetland” under these Rules. Activities such as reclamation, setting up of new industries or expansion of existing industries, manufacture, storage or handling of hazardous substances, and dumping of solid waste or discharge of untreated effluents are prohibited within protected wetlands.

4. The project map submitted by the project proponent on Survey of Toposheet reveals the intent of the project proponent to reclaim wetlands including saltpans and tidalmarshes for the proposed expansion. Such reclamation would be illegal. (Attached – Project Boundary on Survey of India Toposheet)

5. The project proponent admits that the project reclaims Intertidal Area, Salt Pans, and Coastal Beach Stretch etc. in the PFR, Section 4.4 on Page 24. It is unclear how the consultant claims this site is feasible despite the presence of such ecologically important features.

Impact on Ambient Air Quality and Public Health –

6. The Development is envisaged within the Ennore- brackish water ecosytem and the Kattupally dune complex. This region is already under severe stress due to the operation of large scale polluting industries in the area, illegal diversion of wetlands for industrial purposes, flattening of sand dunes and degradation of wetlands due to coal and flyash pollution.

7. Increased movement of heavy vehicles due to the presence of two port has worsened an al ready intolerable air quality by adding to the pollution caused by oil refineries (Manali), coal fired power plants and the Hinduja foundries.

8. Independent real time air monitors air quality monitoring in the Ennore Area deployed by Chennai Based HUMA Hospitals show high levels of particulate matter in the air. Air quality during the month 12 September, 2018 to 13 January, 2019 provides a case in point. Out of the 120 days monitored, daily averages of PM 2.5 for 32 days were above the permissible limit of 60 ug/m3. Hourly average readings show a maximum of 618 ug/m3 on some perticularly polluted days.

9. A health study conducted by Huma Hospitals among Kuruvimedu residents in April 2017 confirmed fears that air pollution was harming health: a) Out of 73 persons X-rayed in the camp, 14 persons (19.2 percent) -- a high proportion -- showed abnormalities in their chest X-rays. b) 36 out of 99 participants presented with "dry cough" suggesting cause of cough as a physical irritant rather than a pathogen-induced infection

The Sub-Committee from the EAC thermal that visited Ennore with regard to the ETPS Replacement plant also took cognizance of the prevailing public health condition in the area. The report and meeting minutes available here http://environmentclearance.nic.in/writereaddata/Form- 1A/Minutes/021120170QDPI8VH11thMoMEACTherma26102017.pdf

10. The MoEFCC's Expert Appraisal Committee (Thermal) while considering a LNG based power plant in the same locality has referred to the severe anthropogenic stress this region is under due to several industrial establishments along the creek which have reclaimed intertidal areas, mangroves, mudflats, saltpans, etc. to ask the project proponent to conduct alternative site analysis. - http://environmentclearance.nic.in/writereaddata/Form- 1A/Minutes/04062018NGRNM9OHFFinalMoM17thThermalnumbers.pdf

11. The proposed project falls in the same area and will contribute to the further degradation of the area, yet no analysis of alternate sites considered has been presented.

Impact on Shoreline and Ennore Creek

12. A 2006 Report titled “Shoreline Management Plan for Ennore Coast” prepared by Ministry of Earth Sciences, has stated that the construction of the Ennore Port has put the Ennore Coast at risk of accelerated erosion. The report warns of a threat to the ecologically sensitive Pulicat and the “Ennore Shoals”. - http://www.icmam.gov.in/slmennore.pdf

13. Shoals comprise of coarse sediment occupied along the offshore boundary of the shoal and finer sediments adjacent to the coastline. This aspect clearly demonstrates that the shoals while interacting with large waves, reduces the energy of the incoming wave that acts as a natural barrier, protecting the coast. The Map on Page 24 of the Proposed Terms of Reference Document submitted by the project proponent shows the presence of Shoals in the project area.

14. Coastal areas north of the existing L&T Shipbuilding are vulnerable to erosion due to the presence of two ports (4 breakwaters, Kamarajar Port and L&T Shipbuilding) block the net northward littoral drift of sand. According to the National Assessment of Shoreline Changes, July 2018, by the National Centre for Coastal Research, 14 km of coastline in Thiruvallur district is undergoing erosion. A major portion of the eroding coastline is located along the Kattupally barrier island where the proposed port is to be built. https://www.indiaspend.com/wp-content/uploads/2018/11/National-Assessment-of-Shoreline-Changes- NCCR-report.pdf

15. Numerous studies, including notably by Kasinatha Pandian1 et al highlights the importance of the Ennore Shoals in mitigating wave energy and erosion to the North of the breakwaters of existing ports. The width of the sand spit separating the from the is as narrow as 100 metres in places, as in Koraikuppam. The proposed port will not only disturb the Ennore Shoals and remove this natural mitigator of storm intensity and erosion, but also trigger dangerous erosion that can turn the Lake Pulicat from a brackishwater ecosystem to a marine system. See “Shoreline Changes and Near Shore Processes Along Ennore Coast, East Coast of ” http://www.jcronline.org/doi/abs/10.2112/1551- 5036%282004%2920%5B828%3ASCANSP%5D2.0.CO%3B2

16. The long-shore erosion that will be triggered of by the construction of proposed 12.1 KM of breakwater also mounts threat to Shriharikota Island, home to ISRO’s Satish Dhawan Space Centre.

17. The fishing villages of Goonankuppam, Vairavan Kuppam, Korai Kuppam, Lighthouse Nadukuppam, Kadal Kanniyur, Kattupalli, , , Arangankuppam, Thirumalai Nagar are likely to be affected by shoreline changes caused by the port, and will be at an increased risk of exposure to high-intensity storms and extreme weather events.

18. The project proponent is deliberately misleading the Expert Appraisal Committee by concealing facts about the geo-morphology of the area. Section III (4) of the Form I submitted has no reference to the 2807 acres of Ennore Creek – Katupalli Backwater they seek to reclaim. By stating that Kosasthalaiyar and Araniyar Rivers is 6.3 KM and 4.2 KM away respectively, the project proponent is providing partial information to the EAC.

19. In Section I (1.21) of the Form I, the project proponent makes no mention of the backwater reclamation.

20. Environmental Clearance given to L&T Shipbuilding Limited in 2009 prohibits the company from undertaking any dumping of dredged material in the sea. Now, the same company is proposing to reclaim more than 700 Hectares of area in the sea for its expansion activities.

21. The company has also been prohibited from handing/storing any hazardous chemicals in the CRZ Areas through the EC accorded in 2009, but the new project has proposed the handling of more than 20 hazardous chemicals (Pg.13 of PFR) in the port areas.

1 P. Kasinatha Pandian, S. Ramesh, M. V Ramana Murthy, S. Ramachandran, and S. Thayumanavan (2004) Shoreline Changes and

Resettlement & Rehabilitation -- Harm to Livelihood

22. Goongankuppam, Vairavan Kuppam, Korai Kuppam, Lighthouse Nadu Kuppam, Kadal Kanniyur, Katupalli, Kalanji, Karungali, Arangankuppam, Thirumalai Nagar are other villages in the coastline between the existing Katupalli port and Pulicat lake that in near-shore waters proposed to be reclaimed. Decline of fishing grounds will leave more than 50,000 people in the lurch, with no alternate livelihoods. Further, any damage to Pulicat lake will affect fisherfolk from more than 45 villages. Attached is a map showing fishing grounds over the proposed project site

23. Villages like Urnamedu, Sengenimedu, Kattur, Ramanathapuram, Neithalvoyal located on the western side of the backwater system that use the areas proposed to be reclaimed for grazing, fishing, hand picking and agriculture. Customary rights over these coastal commons will be affected if common lands are privatized for commercial gains. Attached is a map showing customary use of coastal commons by Urnamedu Village.

Resettlement & Rehabilitation – Living Spaces

24. The PFR also mentions no “Rehabilitation or Resettlement” as an advantage to this site. However, Katupalli Kuppam, which was evicted by L&T Shipbuilding to another location north of the village, falls right in the middle of the revised master plan site. Already, access to the sea and carrying out fishing as a livelihood in Katupalli Kuppam has become increasingly difficult. Now, with access being cut off and reclamation of the sea (fishing grounds) will have a very detrimental effect on the life and livelihoods of the villages in Katupalli Kuppam.

25. Living and Livelihood spaces of Goongankuppam, Vairavan Kuppam, Korai Kuppam, Lighthouse Nadu Kuppam, Kadal Kanniyur, Katupalli, Kalanji, Karungali, Arangankuppam, Thirumalai Nagar are located on the shoreline north of the existing katupalli port, and is likely to be displaced by erosion and privatising for the port. There is no mention of this in the PFR or the form I submitted.

26. The problem is further compunded by the absence of long-term housing plans in the coastal zone management plan prepared and approved by the state and central governments.

Climate Change, Sea Level Rise and Salinity Intrusion

27. A 2012 report titled “Coastal Zones of India” predicts the entire area currently proposed for expansion as being within the “Zone of Submergence” due to Sea Level Rise by 2100. Investing Rs.53, 031 Crores for the development of such a mega project in an area that is prone to climate changed induced sea level rise must be looked at critically, prioritizing protection of long term security of the ecology and communities dependent on it. - http://www.moef.nic.in/sites/default/files/Coastal_Zones_of_India.pdf

28. The entire backwater area area slotted for reclamation by the port falls within the ‘Hazard Line’ prepared by the Survey of India, taking into account the dangers of natural hazards, sea level rise due to global warming etc. Location of critical- high investment infrastructure like ports in areas predicted to be degraded/damanged by climate change needs to be looked at critically. 29. The AK-basin, or the area between Araniyar and Kosasthalaiyar, is a groundwater-rich area. Metrowater has six well-fields – , Panjeti, Thamaraipakkam, Poondi, Kannagiper and Floodplains -- that yield upto 100 million litres per day of water for Chennai during water-scarce times. Immense water scarcity for Chennai city has been predicted in 2019-2020, given the deficient Northeast monsoon in 2018. The AK- basin is witnessing aggressive salinity intrusion. This will worsen as sea levels rise due to climate change. Because the Creek stretches about 16 km in a north-south direction, tidal and storm surges are spread parallel to the coast rather than deep inland through rivers, and channels. The Ennore Creek's western edges – which are the areas that have been and are being encroached – are salt and abandoned salt pans. Compromising the creek will aggravate salinity intrusion and endanger Chennai's water sources.

30. Areas around Ennore Creek are already experiencing increased instances of flooding due to encroachments on the creek and flood plains, blocking the west to east macro-drainage pattern. Reclamation of the backwater in this case will only further exasperate the flooding sitatuon in .

31. In December 2016, Cyclone Vardah made landfall in the Ennore-Pulicat region. The resultant storm surge of more than 1 metre above the astronomic tide inundated low-lying areas in the region. Normally, the Creek is the first shock absorber to deter the storm surge. But with its water carrying capacity vastly reduced, the Creek's ability to absorb storm shocks has also declined. As the encroachment continues, storm surges will send seawater deep into the hinterland through the rivers, streams and channels and inundate areas that have never before experienced flooding due to tidal surges.

Given the eco-sensitive nature of this area, we request the EAC to exercise utmost caution while dealing with a project of this size, located in such a vulnerable location.

1. Conduct a site visit to understand the location, topography, hydrology and cumulative impacts of situating such a large project in this environmentally vulnerable place before issuing TOR or undertake any appraisal of the project in this present form. 2. Not permit the project proponent to reclaim Salt Pans, Salt , Mud Flats and Water bodies under any circumstance. 3. Explore alternate sites for expansion/situating the project and declare the Ennore Creek Backwater System as a “No Development Zone”.

Sincerely,