By Rohit Prajapati, Krishnakant*
In the current scenario of Covid-19, where the entire country is struggling for survival, safety, and security, the government of the day is working suo moto (on their own) very proactively, 24×7, to “help” the industries and other mega projects.


An eye-opening example is the recent Draft Notification Environmental Impact Assessment 2020 by the Ministry of Environment, Forests and Climate Change (MoEF&CC). Even industries would not have been able to devise such a Draft. Obtaining the Terms of Reference (ToR) for EIA from MoEF&CC is analogous to booking a vehicle and getting a RTO Receipt.


Almost all of us must have experienced how easy it is to apply and get a ‘Vehicle Registration Number’ at the RTOs all over India: Hire an Agent (Consultant), apply, submit documents, pay the stipulated fee and get the permit! Believe it or not, obtaining an “Environment Clearance” (EC) for any big “Development” project, according to the Government of the Day, is just like and as easy as applying for and getting a ‘Vehicle Registration Number” (EC).
It is apparent that the MoEF&CC is practically playing the role of the Ministry of Commerce and Industries, trading the environment and the resources for short-term monetary gain. Both the Ministries can undergo a merger process, like many corporates, and be renamed as ‘The Ministry of Environment for Commerce and Industries’. They can then chart out newer strategies to obliterate our undervalued resources and then also apply for international loans for the same.

Water Aerodromes

The government of the day, amidst the increasing Covid-19 chaos in the month of April and May 2020, considers planning for tourism as an important need and a priority. The Government has promptly planned for Water Aerodrome Projects near Statue of Unity Project Panchmukhi Lake (Lake 3) of Sardar Sarovar Dam at Limdi Village, Narmada District, Gujarat, and at Shatrunjay Dam, village Vadal Village, Bhavnagar District, Gujarat both by M/s Civil Aviation Department, Government of Gujarat.
Once planned and approved during the lockdown period, these projects will be ready for implementation, when things return to the new normalcy and by the time people realise the potential impacts, they would already be built.
The minutes of the Expert Appraisal Committee (EAC) of MoEF&CC dated April 22-24, 2020, at Page No 8 mention:
“The project proponent informed the EAC that Water Aerodrome is primarily on water, intended to be used either wholly or in part for the arrival, departure and movement of seaplanes, and any building and equipment on ground or water. Sea plane operation from coastal/ river/ canal as well as terrestrial water bodies will extend the connectivity to those areas where there is no land-based airport.
“The high capital investment for airside infrastructure development required in land-based airport can be avoided. Thus, there is a necessity to establish water aerodromes for seaplane operations. It was also confirmed by the project proponent that M/s Civil Aviation Department, Government of Gujarat shall follow safety regulations, maintain good housekeeping and judiciously operate pollution control facilities to meet the prescribed norms and shall promote environment friendliness. This project can be set-up with minimal or negligible adverse environmental impact.”

 Once planned and approved during lockdown, these projects will be ready for implementation when things return to normalcy

One of the Terms of References, we feel necessary to reiterate, is that:
“…Public hearing is to be conducted. Issues raised during public hearing and commitments made by the project proponent on such issues should be included in final EIA/EMP Report in the form of tabular chart with financial budget for complying with such commitments.”
If we read in between the lines of this ToR, it clearly indicates that the EAC of MoEF&CC expect that affected and concern people should not say ‘No” to ‘The Project’ and only have to think about the demands to allow this project to happen. The EAC has made it clear that they are not going to consider if affected and concern people say ‘No’ to The Project.

Proposed aerodrome site near Palitana, Saurashtra

The ‘Water Aerodrome Project’ proposal near the Statue of Unity (SoU) Project is completely silent about the fact that it is surrounded by the serene environment with Vindhyachal and Satpuda mountain ranges on either side, there are projects like: 

  • Sardar Sarovar Dam, 
  • Garudeshwar Weir, 
  • Statue of Unity Project, 
  • Shrestha Bharat Bhavan (Hotel), 
  • Valley of Flowers, 
  • Vishwa Van, 
  • Jungle Safari, 
  • Cactus Garden, 
  • Butterfly Garden, 
  • Ekta Nursery, 
  • Arogya Van, 
  • Zarvani Eco-tourism & Adventure Sports, 
  • Khalwani Eco-Tourism Site, 
  • Ekta Mall, 
  • Ekta Auditorium, 
  • Children Nutrition Park, 
  • Mirror Maze, 
  • Ekta Food Court and 
  • Various Accommodation Facilities. 

These projects completely lack any holistic planning and their shoddy implementation will most likely cause throwing good (public) money after bad (public) money that are already wasted in these projects.
Looking at the government’s on-going activities, one might conclude that the SoU Area is ‘Special Government Zone’ (SGZ), and, therefore, the following laws do not apply to this area: 

  1. The Wildlife (Protection) Act 1972; 
  2. The Environmental Impact Assessment Notification 2006; 
  3. The Environment (Protection) Act 1986; 
  4. The Wetlands (Conservation and Management) Rules 2010; 
  5. The Solid Waste Management Rules, 2016; 
  6. The Water (Prevention and Control of Pollution) Act, 1974; 
  7. The Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013, and 
  8. The Street Vendors (Protection of Livelihood and Regulation of Street Vending) Act, 2014.

In such a scenario, the environmental impacts due to the Aerodrome project would be compounded and exemplified, to which the MoEF&CC seems to be in convenient denial. And, it is assumed that tourism activities do not have adverse and grave environmental impacts.The MoEF&CC is a mute spectator of such a manipulative approach of the Government of Gujarat to ignore the real irreversible damage to the ecosystem and their functions in the area by looking at them in isolation.
Until now, the Narmada waters were expected to fulfilling the basic as well as extravagant requirements of Gujarat; be it provision of drinking and waters for agricultural activities for the Kutch and Saurashtra region or quenching the thirst of the Sabarmati Riverfront.   

Rohit Prajapati at Statue of Unity

The overarching question is that where will the water come to fulfill the needs of the pompous projects near SoU on River Narmada? The EAC has ignored the constitutional provisions of Schedule V for forested areas inhabited by indigenous tribals and the Panchayats Extension to Scheduled Area Act, 1996 (PESA) – both of which apply to this area.
It is shocking and surprising that the EAC of MoEF&CC is able to digest the line “This project can be set-up with minimal or negligible adverse environmental impact.” It is important to note the Government of Gujarat is so “sensitive” to “Protect and Help” people of Gujarat from Covid 19, is also able to plan for the Tourism Projects as an immediate need for the people of India.
In summation, the Central Vista Project is the priority of the Government of India and Water Aerodrome Projects are the priorities of the Government of Gujarat. Moreover, shockingly MoEF&CC is proactively ready to help fulfil these priorities so that Doing Business as Usual can continue at an exponential rate, no matter what.

*Rohit Prajapati is environment activist, researcher and writer; Krishnakant is environment activist

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