The Tadadi port was proposed to service the Bellary-Hospet hinterland in northern Karnataka for exporting iron ore and steel. The port has been proposed to be developed in a Public Private Partnership (PPP) model with the Karnataka State Industrial and Infrastructural Development Corporation Ltd (KSIIDC) initiating the planning and clearance process. The private proponent has not been determined, although there are media reports that the Adani group has indicated an interest in the port.
The TOR for the EIA was prescribed by the EAC on 18 August, 2011, and the final EIA Report was submitted in September, 2015. The public hearing was held on 23 March, 2015. Eventually, on 26th December, 2016, the EAC recommended the project for clearance subject to certain conditions.
The EIA process of the port was flawed on many counts – procedurally and substantively. Procedurally, the baseline data was collected by the proponent even before the TOR was prescribed, and that too for a single season. Although additional studies were asked for by the EAC subsequently, they did not cure the initial defect.
The EIA Report itself does not question the viability or rationale of the project, particularly in the context of development of other ports along the same coastal stretch. In fact, the feasibility study notes that expansion of existing ports would affect the viability of the Tadadi port. The economic viability of the project itself is questionable. In terms of economic viability, the Aghanashini is prone to high siltation, and the de-silting operations would entail very high maintenance costs. The economic and ecological costs of such desilting are not accounted for.
The EIA Report is incomplete and misleading in many respects. The Aghanashini ecosystem features of the estuary and the dependent livelihoods have been considered in a perfunctionary manner. Studies on the changes in the drainage patterns, the impact of the diversion of water from the Gangaveli river, anticipated shoreline changes have not been conducted. The EIA Report mentions that detailed studies will be conducted by the proposed developer. While it acknowledges that the estuary supports a highly productive ecosystem for bivalve collection, it merely states that “prior to the development of the port, a detailed environmental management plan will be further firmed up”. Likewise, the impact on fishing is proposed to be taken up through a separate study at a later point. Though these concerns have been flagged at the TOR stage, they have not been addressed in the EIA Report. In fact, these additional ‘comprehensive’ studies, when they are conducted, will have no bearing on the decision on the project itself. More importantly, the clearance proposal considers cargo of 34.25 MTPA, but mentions in passing that the port would eventually be expanded to 62.36 MTPA. The eventual increased capacity to almost double the capacity has not been considered.
There was no meaningful public consultation. There were information gaps about the impacts of the port – most people were not aware of impacts of dredging, or the restrictions in accessing marine areas due to ship movements and port operations. The public hearing that was held was without an explanation of the impacts on the ecology and natural resource dependent livelihoods in the region. Attendants also claimed that the hearing was not conducted in a neutral manner. Persons speaking in opposition to the port were disrupted and the minutes of the public hearing did not accurately describe the objections that were raised. In addition to the public hearing, conservation scientists, ecologists and civil society organizations sent comments to the EAC. While these concerns were forwarded to the project proponent, the EAC did not examine whether the response of the port developers was satisfactory.
Finally, the recommendation of EC itself comes with several conditions, including mitigation and management measures. To illustrate, the conditions include drawing up management plans for the impact on the mudflats, maintaining free flow of river water and ensuring that there are no changes to the shoreline. These conditions, however, are impractical and futile. The decision-making on the port should have considered the viability of these assurances, rather than relying on these ‘management’ measures.
The EC process of the Tadadi port demonstrates the gap between the legal provisions and their implementation. This case study is symptomatic of the larger EIA processes in the country.