New Delhi: A right-to-information query has revealed how the union environment ministry eased environmental requirements for upcoming water aerodrome projects for seaplanes, yielding to pressure from the civil aviation ministry and going against the recommendations of its own expert committees.
Prime Minister Narendra Modi is an enthusiast of seaplanes and water aerodromes, and ever since the launch in Gujarat of what his government claimed as India’s ‘first’ seaplane flight, the civil aviation ministry has put pressure on the environment ministry to downgrade environment-approval requirements for seaplane projects.
The downgrade was worked into a revised charter for environmental impact assessments (EIA)—a draft notification 2020 made public in March 2020 for comment and scrutiny, receiving numerous objections when it was.
The draft notification placed seaplanes and water aerodromes in a category called B2, projects that require a simple two-step process for environmental permission and do not require an EIA, instead of category A, which need rigorous vetting at multiple levels—local, state and central.
“Water aerodromes as category B2 projects means environmental assessment and audits will be bypassed,” Kanchi Kohli, legal researcher at the Centre for Policy Research, a think tank, told Article 14. “The decision revealed little weightage was given to the spirit of precautionary approach in prior environment impact assessments.”
Research and advocacy group Manthan Adhyayan Kendra used India’s transparency law, the Right to Information Act (RTI), 2005, to obtain documents that revealed the environment ministry’s own expert and appraisal committees had recommended for water aerodromes the same category A environmental clearances as for any other airport.
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Modi’s ‘Visionary Guidance’
Seaplanes are among Modi’s flagship projects, operationalised under his “visionary guidance”, according to the Gujarat government. On 31 October 2020, Modi inaugurated a seaplane service between the Statue of Unity, located on the Sardar Sarovar dam in Gujarat’s Kevadia, and Sabarmati Riverfront in Ahmedabad, a 30-minute flight to the dam’s southeast. The government said that, “these are part of a series of water aerodromes planned to bring last-mile connectivity”.
These new projects defined a seaplane as a fixed-wing aeroplane designed to take-off and land on water. They included amphibious vessels that could also operate on ground.
Seaplanes require water aerodromes, defined as any identified area, 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.
Seaplanes were proposed to connect remote religious/tourist spots and to promote short distance air-connectivity especially in hilly regions or across rivers/lakes etc.
Why Water Aerodromes Require Highest Environmental Clearance
Eight water aerodrome projects are currently being assessed and audited for environmental clearance under category A as per the existing EIA notification 2006, according to the Parivesh portal of the environment ministry.
Of the eight, three are in Andaman & Nicobar Islands at Swaraj Island, Shaheed Island and Long Island; three in Gujarat at Sabarmati Riverfront in Ahmedabad, Statue of Unity Kevadia and Shatrunjay dam in Bhavnagar; two in Assam at the Guwahati Riverfront and at Umrangso dam in Dima Hasao district. The portal shows the Ahmedabad and Kevadia aerodromes are still awaiting environmental clearance though they were made operational, a point elaborated later in the story.
In January 2021, locations of 19 more proposed seaplane hubs were shown on dams, rivers/ riverfronts and coasts, largely fragile ecosystems. Experts expressed concern over the development.
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“Coastal and island ecosystems are extremely unique and vulnerable,” said Kohli. “The decision to categorize emerging water aerodrome projects as B2 must be viewed in the light of the fragility of these ecosystems in the face of multiple cyclones, climate-induced weather events that we are witnessing so much more starkly in the last two and a half years.”
Final recommendations for category A projects are made by a central expert appraisal committee (EAC) on the basis of an EIA report and public hearings.
For category B2, environment permission as opposed to clearance can be obtained by mere submission of an “environment management plan” and a verification of ‘completion of applications’.
Water aerodromes are not mentioned as such under existing regulations of EIA 2006. However, item 7(a) in the Schedule of EIA 2006 requires all airports (including airstrips for commercial use) to have environmental clearance.
For the eight seaplane/water aerodrome projects planned between December 2019 and September 2020, the environment ministry’s EAC stated in its terms of reference (TOR), which specify how the EIA is to be prepared, that these are classed under category A.
The committee said that as seaplanes were emerging “as a new mode of transport involving sea/river fronts... its likely impacts on water, air and aquatic biodiversity including flora and fauna” would require the same due diligence as clearance for airports.
Aviation Ministry, Airports Body Sought Exemption
The RTI documents showed that in 2018 the civil aviation ministry requested exemption from environment clearance for water aerodrome projects. An environment ministry committee discussed this in a meeting on 11 October 2018.
The committee noted that “it appears this project will require environmental clearance”. It also said that “aquatic ecology, impact on fishing community, other social aspects related to land requirement, coastal habitats and issues related to logistics support systems, etc. are required to be studied with site specificity”. The expert committee sought more time for comments from field experts.
The matter was posted for a meeting on 16-17 May 2019 with civil aviation ministry experts expected to make their case for exemption to the environment ministry’s committee headed by S R Wate, PhD. No civil aviation representative attended the meeting. The matter was deferred.
Six months later on 20 November 2019, the Airports Authority of India (AAI) requested that the environment ministry consider water aerodromes projects under category B2 within the 2006 notification itself.
In its reply on 30 December 2019, the environment ministry drew AAI’s attention to the EAC’s report on three AAI proposals for water aerodromes in the Andaman & Nicobar Islands.
The EAC report stated that, “activities proposed under the project would have similar impacts as of a normal airport”. The letter reiterated that water aerodromes would be included as category A projects under the purview of the EIA notification which is ‘under review’.
The expert committee held fourteen meetings between April 2019 and 6 March 2020 for a revised EIA notification based on suggestions and comments on the zero draft. Only three of these meetings took place after 30 December 2019, when the environment ministry clearly indicated that water aerodrome plans would be category A projects in the draft notification.
Three months later, the draft notification 2020 finalised in the last meeting held on 5-6 March 2020 included water aerodromes in category B2.
Article 14 sought comment over email on 15 October from Sharath Kumar Pallerla, a director at the ministry of environment. He forwarded the mail to J D Marcus and A K Agarwal of the impact assessment division of the environment ministry. We will update this report if they respond.
It is imperative, Kohli said, that environmental risks of such projects were taken into account. “It eventually affects development itself,” she said.
Kohli could well have been talking about the status of 200-km flights between Statue of Unity, Kevadia and Sabarmati Riverfront in Ahmedabad, Gujarat, which have dwindled to a fraction of the planned frequency. Services were suspended four times over the last year and remained suspended for at least 221 days since the seaplane’s high-profile inauguration on 31 October 2020.
A Grounded Seaplane?
While the flight between Statue of Unity and Sabarmati Riverfront was hailed as a “historical achievement” of the Gujarat government, attempts to book the seaplanes in October 2021 met with the response “bookings are not being taken at the moment and we do not know when services will resume”.
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The union environment ministry granted only a ToR—or terms of reference, a set of standards—for water aerodromes at both the Statue of Unity and Sabarmati Riverfront had been granted only ToR by the Union environment ministry. Having a ToR signals stage one has kicked off in the process to an environmental clearance under the purview of EIA Notification 2006.
The “prior” environmental clearance for both projects, which means clearance is mandatory before any construction starts, is still pending a year after Modi inaugurated the seaplane flight.
The EAC in May 2020, while granting the ToRs, had directed the “project proponent” to “submit an affidavit signed by authorised representative… that there is no violation and no part of the project has been implemented without Environmental Clearance”.
Mudita Vidrohi of Gujarat Lok Samiti, an advocacy, said the Statue of Unity-Sabarmati Riverfront water-aerodromes project had indeed bypassed the environmental-clearance process and believed that the project would never have been cleared if it took into consideration environmental concerns.
More than 300 crocodiles were relocated from ponds around the terminals for the seaplanes in 2019, Vidrohi told Article 14. Pond 3, which hosted the crocodiles, was selected as the seaplane terminal.
“Developing tourism by disturbing the natural being of the environment and labelling it tourism is not the path of progress,” Vidrohi told Article 14.
“The two ends are already well-connected by road and railways; there are boating and cruising activities around the Statue of Unity,” said Vidrohi. “There was no need to develop a seaplane route in such haste. Especially when the aircraft has to fly to Maldives for maintenance so often.”
A draft report by CSIR-NEERI (Council of Scientific and Industrial Research-National Environmental Engineering Research Institute) on the draft EIA Notification 2020 also urged that recommendations by the expert committee and by the EACs as given from time to time be followed to suitably amend and improve the draft EIA Notification 2020.
Disregard For Norms, Scindia In A Hurry
In 2019, the civil aviation ministry announced four water aerodrome projects on the Andaman & Nicobar Islands and two on Lakshadweep to promote tourism.
Three of these projects—Swaraj Island, Shaheed Island and Long Island—were granted ToRs with mandatory public hearing on 16 December 2019. Within months, the EIA report was prepared and public hearings held at the end of September 2020 for all three projects.
The EAC granted clearance to only the Shaheed Island project on 27 May 2021, subject to specific conditions, such as preparation of conservation and management plan for corals and marine ecosystems in the project area. In the five months since it received an all-clear, the environment clearance letter has not been uploaded on Parivesh.
The EAC “expressed displeasure on the inadequate preparation of EIA” reports for Swaraj Island and Long Island projects and deferred both, citing “several gaps” in the assessment report. For the EIA report on Long Island, the EAC said mitigation on the biological environment was “poorly described”, impact on corals and their mitigation insufficiently defined, and there were “inconsistencies in the budgetary provisions of the Environmental Monitoring Plan”, among other issues.
Yet, in September 2021, civil aviation minister Jyotiraditya Scindia pushed the chief ministers of Haryana and Manipur, and lieutenant-governors of Union Territories Jammu & Kashmir, Andaman & Nicobar Islands and Dadra & Nagar Haveli to expedite the process of approvals for all three projects. He even suggested the administration identify a new location at the earliest for a water aerodrome at Port Blair.
All the proposed aerodrome locations are in the vicinity of protected areas. Rani Lakshmi Marine National Park is within 2.8 km of the site at Swaraj Island; Sir Hugh Ross Island Wildlife Sanctuary 7 km as the crow flies from the one at Shaheed Island and Cone Island Wildlife Sanctuary is within 5.6 km of the site at Long Island.
Livelihood concerns of boat operators in these areas were captured in documents about the public hearings for each as part of the assessment. Yet, if water aerodrome projects are pushed into category B2, as per the draft EIA 2020, seaplane projects will be allowed to take off without taking into account the impact on the environment, or on social structures and livelihood of local communities.
(Avli Verma, an M Phil from the Indian Institute of Technology Bombay, is a researcher with Manthan Adhyayan Kendra. She studies the impact of human activity, including pollution, on India’s rivers.)