EIA analysis of a multi project Special Economic Zone

July 19, 2010

The proposed project is the development of a Multi product special economical zone (MPSEZ) and a Domestic Tariff Area (DTA) proposed by M/s Sri City Pvt. Limited, Mr. Ravi Kanth from Hyderabad based NGO called Prakriti on behalf of the local communities of Andhra Pradesh has requested Centre for Science and Environment (CSE) to technically evaluate the Environmental Impact Assessment (EIA) document of:

1. Development of a Multi product special economical zone (MPSEZ) and a Domestic Tariff Area (DTA) in an area of 2185 ha.

M/s Sri city (p) Ltd., is developing a SEZ and DTA Multi product special economical zone (MPSEZ) and a Domestic Tariff Area (DTA) in an area of 2185 ha at Chittoor district near Tada, Andhra Pradesh. It will be housing industrial units like auto components, light engineering, electrical and electronic goods, garment and leather industries, gems and jewellery, IT/ITeS/BPO etc along with residential townships and commercial units.

About the project

M/s Sri City Pvt. Ltd., is proposing a MPSEZ and DTA in an area of 2185 ha. The project shall be developed in phased manner. The project will predominantly have industries and services from the following thrust sections: Auto components, light engineering, electrical and electronics goods (E – zone), agri industry zone, garment /apparel manufacturing, leather products, gems and jewellery, toys and sport goods, bio technology, Aerosphere, renewable energy, warehousing logistics and IT/Its/BPO. SEZ area constitutes of 1538 ha and the DTA covers 648 ha.

Project location: The proposed project of MPSEZ and DTA developed by M/s Sri city Pvt. Ltd., is situated at Satyavedu & Varadaiahpalem Mandala. Chittoor district, Andhra Pradesh. The site is approximately 65 Km from Chennai on NH-5 within the boundary of Andhra Pradesh. The Ennore port is about 40 Km from the site and closet railway station in Tada at a distance of 1 Km.

The basic objective of the project is to:

Bring Andhra Pradesh on the global map as an attractive destination for manufacturing and logistics facilities. Such a development would contribute to revenue generation in the state as well as provide employment opportunities.

Technical Report

There are several drawbacks in the quality of the EIA report. The report is poor in terms of assessing the impacts of the project on the environment. Some of these drawbacks/lapses are presented below:

1. Cumulative Impact: The SRI city is planning for industrial development. However there are already other industries located in the nearby areas. Page 55 of the report states that the surrounding industries in the area comprise of sugar factories, granite cutting, chemical industries, textile industries and various other industries. The report fails to give the current depiction of pollution in the area, overall impact of these industries on the environment is completely missing. The project would only add to the worsening of condition. The EIA speaks as an individual project basis, which would not suffice to predict or mitigate the impact on the environment that is already deteriorated. Such an important environmental concern cannot be neglected for an industry to starts its expansion project, which would only add on to the existing pollution. The report also fails to predict cumulative impact of these industries on air, water, land, soil and the surrounding community.

2. The site is located near to Pulicat Lake. However the report does not talk about the lake or its sensitive flora and fauna. Nor does it give any conservation plan to avoid any harm to this fragile ecosystem. The report fails to assess the impact of construction as well as operation phase impact on the lake due to various factors that would harm the lake as well as the ecosystem of the lake. Pulicat Lake is known to be feeding and breading ground for both aquatic and terrestrial birds. Being a highly sensitive area, the impact of construction as well impact when this SRI city starts functioning would be high but this is not being focused in the report.

3. Impact on Flora and Fauna: A list of flora and fauna in the study area is given in the report (Page 52, 53). However the report fails to assess the impact of the upcoming project on the flora and fauna of the area. But mere mention of these flora and fauna in the area does not suffice. Proper mitigation plan to protect these animals is necessary. Also whether the data taken into account is based on primary survey or not is not clear in the report. Such huge development of a MPSEZ would definitely impart ecological harm to the surrounding flora and fauna but the EIA fails to capture such an important issue pertaining to the project. The impact of air pollution by the industries on flora and fauna has been neglected.

4. Water consumption of the area is huge. The impact of withdrawal of water for the construction phase as well as operation phase is not discussed in the report. Construction phase would also last for a longer time, which is not mentioned in the report. The impact of construction phase is said to be less significant however it is not justified in the report. Also the impact on existing small water bodies in the site is not clear in the report. It does elaborate some steps to mitigate the impacts however this is inadequate considering the number of water bodies and the scale of construction.

5. The loading and unloading areas for the raw material are not clearly mentioned whether open or closed. This would give rise to dust and air pollution. This has to be closed in order to decrease the air pollution in the nearby areas and hazards that it might cause due to the dust to the flora and fauna during the construction phase in the nearby areas. Maximum amount of air pollution is generated in handling of raw material. This would create a nuisance for the nearby local people. This impact has to be mitigated using proper measure like covering the area. Loading and unloading mechanism has to be automated to the extent possible. During construction phase, huge amount of dust will be generated. This would have severe impact on the close by bio diversity; close by areas specially the Pulicat Lake as well as people residing in the nearby villages. Sprinkling of water is inadequate in terms of mitigation measure that is being proposed by the project proponent. Proper care with respect to air pollution during the construction phase has to be taken which the report fails to address. Solid waste generated during the construction phase is also not managed properly according to the report.

Solid waste during the operation phase is to be sent to landfill site however the site is not specified in the report. Mere mention of the final disposal point is inadequate seeing the scale of the project. Hazardous waste management for the locality is also inadequate.

The report also fails to give information regarding the extent of construction phase, which is significant for impact prediction during construction phase. Source and quantity of water required during the construction phase has been neglected by the report.

The report claims that after construction is over, the loose soil will be used to backfill the low lying area, however this is quite subjective in nature as quantity of soil excavated and land area that would be backfilled is not given. Hence impact prediction on land and soil is not justified.