Journal of Threatened Taxa | www.threatenedtaxa.org | 31
December 2020 | 12(18): 17387–17454
ISSN 0974-7907 (Online) | ISSN 0974-7893 (Print)
doi: https://doi.org/10.11609/jott.6650.12.18.17387-17454
#6650 | Received 02 November 2020 | Final received 17 December
2020| Finally accepted 28 December 2020
On the inadequacy of environment impact assessments
for projects in Bhagwan Mahavir Wildlife Sanctuary and National Park of Goa, India:
a peer review
Girish Punjabi 1,
Anisha Jayadevan 2, Abhishek Jamalabad 3, Nandini Velho 4,
Madhura Niphadkar-Bandekar 5,
Pronoy Baidya 6, Ravi Jambhekar 7, Parag Rangnekar 8,
Omkar Dharwadkar 9,
Rhea Lopez 10, Marishia Rodrigues 11, Farai Divan Patel 12,
H.S. Sathya Chandra Sagar 13,
Sayan Banerjee 14, Manish Chandi 15, Nandini Mehrotra 16,
Shashank Srinivasan 17,
Sneha Shahi 18, Vidyadhar Atkore 19, Nirmal Kulkarni 20,
Gowri Mallapur 21,
Hanuman Gawas 22, Atul Borker 23, Rahul Prabhukhanolkar 24,
Harshada S. Gauns 25,
Dheeraj Halali 26, Vighnesh D. Shinde 27, Katrina
Fernandez 28,
Esme Purdie 29 &
Manoj R. Borkar 30
1 Wildlife
Conservation Trust, 11th Floor, Mafatlal Centre, Nariman Point,
Mumbai, Maharashtra 400021, India.
2 Foundation
for Ecological Research Advocacy and Learning, 170/3, Morattandi, Tamil Nadu
605101, India.
3 H.no. 44,
Kanara House, Mogul Lane, Mahim, Mumbai, Maharashtra 400016, India.
4 Srishti
Manipal Institute of Art, Design and Technology, N5 Campus, CA Site No.21, 5th
Phase, KHB Colony, Yelahanka New Town, Bengaluru, Karnataka 560064, India.
5, 8, 9 Foundation for Environment Research and Conservation,
Vasco, Goa 403802, India.
5,7 Azim
Premji University, PES Campus, Pixel Park, B Block, Electronics City, Hosur
Road, Bengaluru, Karnataka 560100, India.
6, 13 Centre
for Ecological Sciences, 3rd floor, Biological Sciences building,
Indian Institute of Science, Bengaluru, Karnataka 560012, India.
10, 11, 12 MSc Programme in Wildlife Biology & Conservation,
Centre for Widlife Studies, Tata Institute of Fundamental Research, National
Centre for Biological Sciences, GKVK, Bellary Road, Bengaluru, Karnataka
560065, India.
14 National
Institute of Advanced Studies, Indian Institute of Science Campus, Bengaluru,
Karnataka 560012, India.
15 Living
Heritage Foundation, Goa & Andaman Nicobar Environment Team,
North Wandoor, South Andaman, Port Blair,
Andaman & Nicobar Islands 744103, India.
16, 17 Technology
for Wildlife, C13, La Campala Colony, Miramar, Panjim 403001, Goa, India.
18 The Maharaja Sayajirao University of Baroda,
Pratapgunj, Vadodara, Gujarat 390002, India.
19 Forestry
Scholars Society, Near Hanuman temple, Ravi Nagar, Amravati 444607,
Maharashtra, India.
20, 22 Mhadei
Research Centre, 6, Hiru Naik Building, Dhuler, Mapusa, Goa 403507, India.
21 GaiaMitra
Collective Foundation, Aanaa Villa, Lane No 7, PDA Colony, Alto Porvorim,
Bardez, Goa 403521, India.
23 Luta
Innovation, 887/13, Kamat Nagar, Porvorim-Socorro, Goa 403501, India.
24 Mhadei
Research Centre & Indian Bat Conservation Research Unit, Mahalaxmi Plaza, 1st
Floor, RPD cross, Tilakwadi, Belgaum, Karnataka 590006, India.
25 Arannya
Environment Research Organisation, H. Number 7, Near Gram Panchayat, Morlem,
Goa 403505, India.
26 Parvatibai
Chowgule College of Arts & Science, Gogol, Margao, Goa 403602, India.
26, 27 Abasaheb
Garware College, Karve Road, Erandwane, Pune, Maharashtra 411004, India.
28, 29 Wild
Otters Research Pvt Ltd., No. 663/1, Gavona, Tiswadi, Chorao, Goa 403102,
India.
30 Biodiversity
Research Cell, Department of Zoology, Carmel College of Arts, Science &
Commerce for Women, Nuvem,
Goa 403713,
India.
1 girish@wctindia.org
(corresponding author), 2 anisha.jayadevan@gmail.com, 3 abhishek.jamalabad@gmail.com,
4 nandinivelho@gmail.com,
5 nmadhura@gmail.com, 6 titan2ae@gmail.com, 7 ravijambhekar04@gmail.com,
8 rangnekarparag@gmail.com,
9 omkardhr_27@yahoo.co.in, 10 rhealopez168@gmail.com, 11
marishiarodrigues@gmail.com,
12 faraipatel@gmail.com,
13 sathyachandrasagar@gmail.com, 14 sayan.workspace@gmail.com,
15 manish.chandi@gmail.com,
16 nandini@techforwildlife.com,
17 srinivasan.shashank@gmail.com, 18 sneha123shahi@gmail.com,
19 freshwater.biologist@gmail.com,
20 ophidian_nirmal@yahoo.co.in,
21 gowrimallapur@gmail.com, 22 hanumangawas91@gmail.com, 23
borker.atul@gmail.com,
24 pkrahul85@gmail.com,
25 harshada3120@gmail.com, 26 dhirajhalali@gmail.com, 27
vighneshshinde410@gmail.com,
28 katrina@wildotters.com,
29 esme.purdie@hotmail.co.uk, 30 borkar.manoj@rediffmail.com
Editor: Anonymity requested. Date
of publication: 31 December 2020 (online & print)
Citation:
Punjabi, G., A. Jayadevan, A. Jamalabad, N. Velho, M. Niphadkar-Bandekar, P.
Baidya, R. Jambhekar, P. Rangnekar, O. Dharwakar, R. Lopez, M. Rodrigues, F.D.
Patel, H.S.S.C. Sagar, S. Banerjee, M. Chandi, N. Mehrotra, S. Srinivasan, S.
Shahi, V. Atkore, N. Kulkarni, G. Mallapur, H. Gawas, A. Borker, R.
Prabhukhanolkar, H.S. Gauns, D. Halali, V.D. Shinde, K. Fernandez, E. Purdie
& M.R. Borkar (2020). On the inadequacy of environment impact assessments
for projects in Bhagwan Mahavir Wildlife Sanctuary and National Park of Goa,
India: a peer review. Journal of
Threatened Taxa 12(18): 17387–17454. https://doi.org/10.11609/jott.6650.12.18.17387-17454
Copyright: © Punjabi et al. 2020. Creative
Commons Attribution 4.0 International License.
JoTT allows unrestricted use, reproduction, and distribution of this
article in any medium by providing adequate credit to the author(s) and the
source of publication.
Funding: Manish Chandi
was supported by the Living Heritage Foundation, Bardez, Goa.
Competing interests: As a consultant, Vidyadhar Atkore was part of the
Freshwater fish assessment for the Railway Report by IISc. His contribution to
this paper is independent of the previous affiliation. The other authors declare no competing
interests.
Author details: Girish Punjabi is a Conservation Biologist with the Wildlife
Conservation Trust and is interested in animal distributions, population
ecology, and the role of science in conservation policy. Anisha
Jayadevan is an ecologist working with the Foundation for Ecological
Research Advocacy and Learning (FERAL), India. She currently studies elephant
movement in human-modified landscapes in South India, in the context of
land-use change. Abhishek Jamalabad is a biologist working mainly on marine
ecosystems, but also with terrestrial wildlife of the Western Ghats. He has
been part of avifauna surveys conducted by the Goa Forest Department and the
Goa Bird Conservation Network, and has been a consultant on amphibian surveys
in Karnataka’s Western Ghats. Nandini Velho is Faculty at Srishti
Institute of Art, Design and Technology and completed her PhD in James Cook
University and was an Earth Institute post-doctoral fellow at Columbia
University. Her research interests include studying the interface between
science and society and the human dimensions of wildlife management. Madhura
Niphadkar-Bandekar is a postdoctoral researcher with Azim Premji
University working on mapping land cover change in community-owned forests in
Maharashtra. She is Secretary of the Foundation for Environment Research and
Conservation (FERC) in Goa, a non-profit organization working for environmental
awareness, biodiversity documentation and sustainable tourism in Goa. Pronoy Baidya is a Senior Research
Fellow at the Centre for Ecological Sciences, Indian Institute of Sciences,
Bengaluru, studying ant communities in Goa for his PhD. He is an avid bird-watcher
and the Goa State Reviewer and Editor for ebird, and Vice-President of the Goa
Bird Conservation Network.Ravi Jambhekar is
a visiting scientist at the Centre for Ecological Sciences, Indian Institute of
Science, Bengaluru. He specializes in animal behaviour, community ecology
and effects of habitat fragmentation on animal populations and dispersal. He
combines art and science to make science more accessible to a wider
audience through visual mediums. Parag
Rangnekar is an ecologist with Foundation for Environment Research and
Conservation, Goa. He documents lesser-known fauna, especially butterflies and
dragonflies, and supports conservation action through community
participation. He is an Expert Member on the Goa State Biodiversity Board, Invertebrate
Conservation Information Network for South Asia and Founding President of Goa
Bird Conservation Network. Omkar
Dharwadkar is a professional naturalist for the last 8 years in Goa. He
has added several new records of birds, butterflies, and dragonflies and
discovered a species of dragonfly new to science. He is a Founding Member of
Foundation for Environment Research and Conservation (FERC) and also the
President of Goa Bird Conservation Network.
Rhea Lopez recently
completed her M.Sc. in Wildlife Biology and Conservation from the National
Centre for Biological Sciences. Her dissertation focused on the interaction of
traditional river fisheries with wild piscivores (smooth-coated otters and
mugger crocodiles) along the Mandovi river in Goa. Marishia Rodrigues is currently
finishing her Master’s in Wildlife Biology and Conservation from the National
Centre for Biological Sciences. She also works as an eco-educator with Terra
Conscious and is the hub manager for Conservation optimism India. Farai
Divan Patel is a Master’s student in Wildlife Biology and Conservation
at the National Centre for Biological Sciences, Bengaluru. His Master’s
research has addressed coral reef health in the Lakshadweep. H.S. Sathya Chandra Sagar is a field
biologist and a conservation scientist and Alumnus of CES, IISc. He is
currently a graduate (PhD) researcher at the Sound Forest Lab at the Nelson
Institute, and the Department of Forest and Wildlife Ecology, University of
Wisconsin - Madison, where he is studying the effectiveness of current
conservation practices to protect biodiversity across tropical forests. Sayan Banerjee is a PhD scholar at
National Institute of Advanced Studies, Bengaluru. He works on understanding
behavioural and political ecologies of human-wildlife relations in
North-eastern India in human-dominated mixed-use landscapes. He is also
interested in mainstreaming social sciences in the wildlife conservation
discourse in India. Dr. Manish Chandi was a senior
researcher in Human ecology with the Andaman and Nicobar Environment Team for
25 years, and is currently affiliated with the Living Heritage Foundation. His
interests and work is with human societies and natural resource use and
conservation. Nandini Mehrotra works
as a researcher for a conservation enterprise called Technology for Wildlife.
She is a conservation policy specialist and spatial analyst. She has a BA in
History from St. Stephen’s College and an MPA in Environmental Policy from
Cornell University. Shashank Srinivasan is a conservation geographer and drone pilot. He has
an MRes in Ecology and Environmental Management from the University of York and
an MPhil in Conservation Leadership from the University of Cambridge. He is a
National Geographic Explorer, Chevening Scholar and a Kinship Conservation
Fellow. Sneha Shahi is a conservationist and the UNEP Plastic Tide Turner
Champion, through which brought immense change in Vadodara using an impact
campaign. She led an urban stream restoration which received recognition from
UNICEF, WWF and UNEP. She currently works as an Assistant Director on a project
on the Impact of Linear Intrusions on Wildlife. Dr. Vidyadhar Atkore is based at the Forestry Scholar’s Society in
Amravati, Maharashtra. His interests lie in freshwater ecology and biodiversity
conservation. Nirmal Kulkarni is a herpetologist, field ecologist,
conservationist, and wildlife photographer. He is Director of Wildernest Nature
Resort, an eco-tel in the Chorla Ghats, & Chairman of the Mhadei Research
Centre, Team Lead of Hypnale Research Station, and promoter of HERPACTIVE, a
study initiative on Herpetofauna. Dr. Gowri Mallapur is a Goa-based
veterinarian and wildlife health professional. She is the Director of the
GaiaMitra Collective Foundation based in Goa. She is trained in herpetology,
sustainable development and natural history management. Hanuman Gawas is an MSc in Ecology and
Environmental Sciences from Pondicherry University. He is presently associated
with the Mhadei Research Centre. Atul Borker is a multidisciplinary innovator
and an educator at Luta Innovation. He is the West Asia Coordinator for
IUCN/SSC Otter Specialist Group & the Smooth-Coated Otter Species
Coordinator for the IUCN/SSC Otter Specialist Group. He has been instrumental
in building conservation capacity for otters in Goa. Rahul
Prabhukhanolkar works as a consultant in environment sustainability and
natural resource management in the northern Western Ghats with Mhadei Research
Centre. He has a keen interest in studying Bat ecology and
conservation, and other lesser-known flora and fauna in the region. Harshada S. Gauns is the Founder
President and Treasurer of Arannya Environment Research Organisation in Goa.
She is a trained zoologist with many years of experience in biodiversity
research, community engagement and management planning at the
village-level. Dheeraj Halali completed his B.Sc. in Zoology from
Parvatibai Chowgule College of Arts & Science, Goa. He is currently
enrolled in a Master’s in Biodiversity at Abasaheb Garware College, Pune.
He has a keen research interest in evolutionary ecology, in the evolution of
phenotypes and phenotypic plasticity, anti-predatory strategies, and
life-history. Vighnesh D. Shinde is from Goa and pursuing his MSc.
in Biodiversity from Abasaheb Garware College, Pune. He is interested in the
ecology of dragonflies. Dr.
Katrina Fernandez is interested in various aspects of conservation
biology, including community ecology, population dynamics and population
viability of meso mammals. She also has a strong interest in communicating
conservation issues and science to the public and engaging people in
participatory approaches to conservation. She has worked in Africa, Asia and
Australia. Dr. Esme L. Purdie specialises in Environmental Toxicology,
focussing on natural chemistry and the impacts of pollution throughout the
environment. She is currently affiliated with Wild Otters Research Pvt., Ltd.
(Goa, India) working to conserve the mangrove ecosystem and reduce adverse
human impacts, while also serving as the Science Council Director for the
Organics Council UK. Dr. Manoj R. Borkar is an Associate
Professor & Head, Dept. of Zoology at Carmel College for Women, Goa, for
the last 33 years. He is a Fellow of Indian Academy of Environmental Sciences,
& served on the Goa State Biodiversity Board, Goa State Wildlife Board and
Goa State Experts Appraisal Committee for EIA. He researches arachnids;
especially Tarantulas, Whip Spiders and Whip Scorpions.
Author contribution: All authors contributed to different sections of the
review based on their expertise. The manuscript was compiled and edited by
Girish Punjabi, Anisha Jayadevan, Abhishek Jamalabad, Nandini Velho, Madhura
Niphadkar-Bandekar, and Pronoy Baidya.
Acknowledgements: Meghna Agarwala is thanked for critical comments which
improved the manuscript. Akshatra Fernandes is thanked for help with collating
the checklist of plants.
Abstract: The Environment Impact Assessment (EIA) is a
regulatory framework adopted since 1994 in India to evaluate the impact and
mitigation measures of projects, however, even after 25 years of adoption, EIAs
continue to be of inferior quality with respect to biodiversity documentation
and assessment of impacts and their mitigation measures. This questions the credibility of the
exercise, as deficient EIAs are habitually used as a basis for project
clearances in ecologically sensitive and irreplaceable regions. The authors reiterate this point by analysing
impact assessment documents for three projects: the doubling of the National
Highway-4A, doubling of the railway-line from Castlerock to Kulem, and laying
of a 400-kV transmission line through the Bhagwan Mahavir Wildlife Sanctuary
and National Park in the state of Goa.
Two of these projects were recently granted ‘Wildlife Clearance’ during a
virtual meeting of the Standing Committee of the National Board of Wildlife
(NBWL) without a thorough assessment of the project impacts. Assessment reports for the road and railway
expansion were found to be deficient on multiple fronts regarding biodiversity
assessment and projected impacts, whereas no impact assessment report was
available in the public domain for the 400-kV transmission line project. This paper highlights the biodiversity
significance of this protected area complex in the Western Ghats, and
highlights the lacunae in biodiversity documentation and inadequacy of
mitigation measures in assessment documents for all three diversion
projects. The EIA process needs to
improve substantially if India is to protect its natural resources and adhere
to environmental protection policies and regulations nationally and globally.
Keywords: Biodiversity, development, highway, National Board for
Wildlife, protected area, railway, transmission line, Western Ghats.
Abbreviations: Bhagwan Mahavir Wildlife Sanctuary and National
Park—BMWS & NP | EC—Environmental Clearance | EIA—Environment Impact
Assessment | FC—Forest Clearance | IUCN—International Union for Conservation of
Nature and Natural Resources | NP—National Park | PAs—Protected Areas | WC—Wildlife
Clearance | WPA—Wildlife (Protection) Act | WS—Wildlife Sanctuary |
MoEFCC—Ministry of Environment, Forests and Climate Change, Government of India
| UNESCO—United Nations Educational, Scientific & Cultural Organization.
1. BACKGROUND
The Environment Impact
Assessment (EIA) process is a standard framework for appraisal and evaluation
of development projects. The first EIA
notification in India was published in 1994 by the Ministry of Environment and
Forests. This was followed by a new EIA
notification in 2006 that made it mandatory for most projects in the mining,
power, infrastructure, and industrial sectors to seek Environmental Clearance
(EC) prior to new developments or the expansion of existing ones. If a project is sited in a protected area or
passing through a notified forest it may additionally require a Forest
Clearance (FC) and/ or Wildlife Clearance (WC).
While India has been following the EIA process for over 25 years,
studies have frequently highlighted sub-standard and deficient EIA and other
assessment reports used by proponents to obtain these clearances by diluting
the spirit of the exercise (Comely 2018; Datar et al. 2019; Sheth et al. 2020).
EIA and other assessment
reports have often been found deficient in documenting biodiversity, assessing
direct, indirect, and cumulative impacts, and proposing mitigation measures
(Datar et al. 2019; Khera & Kumar 2010; Sheth et al. 2020). In this Review, the authors present an
analysis on three projects that will cumulatively affect Bhagwan Mahavir
Wildlife Sanctuary and National Park (BMWS & NP), formerly known as Mollem,
in the state of Goa (Figure 1, Image 1–3).
These forests are an important part of a larger landscape that affords
connectivity not only to other forests in Goa but also across the border to
Kali (Dandeli-Anshi) Tiger Reserve in Karnataka. The three projects are as follows:
a. Road: The four-laning of the
National Highway 4A (153km in total length, of which 70.07km falls within Goa,
with 13km bisecting the BMWS & NP, now redesignated as National Highway
748), that is being carried out by the National Highways Authority of India and
by the Public Works Department in Goa.
The proposal involves the diversion of about 31.015ha of protected
forest area (24.265ha in the NP and 6.75ha in the WS). At present, the road passing through the
protected area has a 7m wide two-lane carriageway. The proposal involves widening specific
sections of the road, thus creating new intrusions into the forest that have
not yet faced the direct and indirect impacts of fragmentation. On the other side of the border in Karnataka,
the highway expansion passing through the protected area (PA) has been halted
by the Karnataka High Court. The total
forest land required is 63.615ha and the total number of trees to be felled are
20,340, of which 12,097 trees will be felled from the PA.
b. Railway: The second project is the
doubling of the Castlerock–Kulem railway line, which is part of the larger
Hospet–Tinaighat–Castlerock–Kulem–Madgaon–Vasco line. The total length of this railway line is
345km, of which 26km passes through the BMWS & NP, that is being undertaken
by MS Rail Vikas Nigam Ltd. The total
forest land required is 138.37ha and the total number of trees to be felled are
22,882; of which 20,758 will be felled from the PA. Four underpasses measuring 12m in width and
5.65m in height have been proposed as mitigation measures along the railway
line. The existing railway line from
Hospet to Vasco was laid in 1900 and presently connects iron ore mining and
industrial areas in Hospet to Mormugao Port in Vasco. The alignment of the second proposed railway
line runs parallel to the existing line and passes through forest tracts in and
around Kali Tiger Reserve and in the BMWS & NP.
c. Transmission line: The third project is the
laying of a 3.15km transmission line through BMWS & NP. The line will be set between Narendra,
Karnataka and terminating with a 400 kV substation at Xeldem, Goa. This project is being undertaken by M/s Goa –
Tamnar Transmission Project Ltd (Sterlite Power) with 12,097 trees that will be
felled and 11.54ha of forests being diverted, with the power line being 46m in
width. The project also requires
diversion of 30.412ha of protected forests of Kali Tiger Reserve in Karnataka. In reality, there are five forest diversion
proposals for one single project involving diversion of total 323.596ha of
forest land through the state of Goa (146.505ha) and the state of Karnataka
(177.091ha). The entire project in the
state of Goa would require felling of 43,456 trees and felling of another
62,289 trees in the state of Karnataka.
The total trees enumerated to be felled for implementing the entire
inter-state project is 1,05,745 trees.
The Indian Ministry of
Environment, Forests and Climate Change (MoEFCC) has a web portal, Parivesh,
which makes public all project documents required for clearances sought by
project proponents. The Parivesh website
does not have the Biodiversity Impact Assessment Report of the transmission
line project uploaded (as on 1 July 2020), despite in-principle approval being
afforded at the 57th National Board for Wildlife meeting held on 7
April 2020.
In this Review, we first
present the biodiversity significance of BMWS & NP by reviewing published
literature on taxonomic groups, and referring to unpublished sources such as
dissertations, reports, and checklists that have been at least peer-reviewed
among expert groups, where published information is scarce. We then present a critique of the two
assessment studies (the railway study prepared by the Indian Institute of
Science, Bengaluru and the highway study prepared by Aarvee Associates,
Hyderabad) and a summary on the impact of the transmission line given that the
project report is not available in public domain.
2.
ABOUT BHAGWAN MAHAVIR WILDLIFE SANCTUARY AND NATIONAL PARK
Bhagwan Mahavir Wildlife
Sanctuary and National Park comprises wet evergreen, semi-evergreen, and moist
deciduous forests in the Western Ghats.
Both PAs are contiguous and span an area of 240km2, with
133km2 as WS and 107km2 as NP.
Both PAs are classified as
Important Bird and Biodiversity Area by the Bombay Natural History Society and
Birdlife International, UK (Rahmani et al. 2016).
A summary of the known
status of taxonomic groups is provided here to enable a reliable assessment of
the ecological value of the PA complex (Image 4).
2.1
Plants and Fungi
BMWS & NP comprise
more than 700 plant species (Datar & Lakshminarasimhan 2013; See Appendix
II). Of these, at least 127 species are
endemic, making about 18% of the total flora (Datar & Lakshminarasimhan
2011).
The region is a hotspot
for fungal diversity in the Western Ghats.
Nearly 1,200 fungi species are known from Goa, of which at least 500
mushroom species have been identified and many are yet to be described
(Nandkumar Kamat in litt. 27.xii.2020).
A total of 18 lichen species are known from the PA, although the overall
diversity is likely to be higher.
2.2
Insects and Arachnids
Both PAs together support
219 butterfly species (Appendix V) and 80 species of odonates (Appendix VI), of
which 14 species of butterflies and 18 species of odonates are endemic to the
Western Ghats. Two odonate species Idionyx
gomantakensis (Subramanian et al. 2013) and Cyclogomphus flavoannulatus
(Rangnekar et al. 2019) have been described from within and immediate outskirts
of the PA. A few butterfly species found
in the BWWS & NP such as the Danaid Eggfly Hypolimnas misippus,
Common Mime Papilio clytia, Common Pierrot Castalius rosimon,
Blue Nawab Polyura schreiberi, Kanara Oakblue Arhopala alea,
Orchid Tit Hypolycaena othona, Short-banded Sailor Neptis columella,
and Crimson Rose Pachliopta hector are protected under Schedule I of the
Wild Life (Protection) Act, 1972 (henceforth WPA 1972). Two endemic butterfly species found here are
the Malabar Rose Pachliopta pandiyana and the Southern Birdwing Troides
minos. A 2011 report on moth
diversity from the northern Western Ghats reports at least 418 moth species out
of which 116 species were unidentified, and potentially new to science
(Shubhalaxmi et al. 2011). A total of 75
ant species are recorded from the WLS of which seven are endemic (See Appendix
IX). Six scorpion species, 16 spider
species, and one species each of Whip Scorpion and Whip Spider have been
recorded from both the PAs (Bastawade & Borkar 2008). An isolated population of Whip Spider Phrynichus
phipsoni and Whip Scorpion Labochirus tauricornis occurs in the
proximity of this PA (Borkar et al. 2006; Borkar 2018).
2.3
Fish
The Western Ghats supports
over 300 fish species of which more than 65% are endemic (Kumar & Devi
2013). New fish species and range
extensions are being described from this region as yet, suggesting that fish
species assessments and distribution patterns remain incomplete (Molur et al.
2011). A comprehensive study in the
Mhadei sub-basin (which includes BMWS & NP) has the presence of 49 fish
species, of which 18 species are endemic to the Western Ghats (Atkore 2017; See
Appendix IV).
2.4
Herpetofauna
The reptilian diversity of
the region is represented by 52 species from Crocodylidae (Crocodiles),
testudines (freshwater turtles & tortoises), and squamates which includes
Sauria (Lizards) and Ophidia (Snakes) (See Appendix VII). Amongst the diversity of reptiles, the Indian
Rock Python Python molurus, Indian Monitor Lizard Varanus bengalensis,
and King Cobra Ophiophagus hannah are some species in the Schedule I and
II of WPA, 1972. Other endemics such as
the Malabar Pit Viper Trimeresurus malabaricus and the Large-Scaled
Shieldtail Uropeltis macrolepis are also reported from the region.
In the past 15 years, 112
new amphibian species have been discovered from the Western Ghats, indicating
high species richness and a need for more systematic studies in the
landscape. Among the 218 known species
of amphibians, 87.8% (158 species) are endemic to the Western Ghats (Nirmal
Kulkarni pers. obs. 01.vii.2020). The
two PAs together contain at least 36 amphibian species (See Appendix VIII). Castlerock is the type locality of Nyctibatrachus
petraeus (Das & Kunte 2005) and Raorchestes bombayensis
(Annandale 1919). Biju et al. (2014a)
described 14 new dancing frogs, of which one species Micrixalus uttaraghati
is found in the streams that cut across the existing Castlerock-Kulem railway
line. Similarly, these streams are home
to Indosylvirana caesari and Indirana chiravasi, two new frog
species that were described recently (Biju et al. 2014b; Padhye et al.
2014). Seven new amphibian species have
been discovered in the past two decades from Goa.
2.5
Birds
The first ornithological
study in Goa was conducted by Grubh & Ali (1976). During their 16-day survey that included
Mollem, the team recorded a total of 97 bird species. Presently, 286 species have been recorded
from the BMWS & NP (Rahmani et al. 2016; see Appendix I). The list includes species such as the
Critically Endangered Indian Vulture Gyps indicus, Endangered Egyptian
Vulture Neophron percnopterus and other globally threatened species such
as the Lesser Adjutant Leptoptilos javanicus, Woolly-necked Stork Ciconia
episcopus, Nilgiri Wood Pigeon Columba elphinstonii, and Malabar
Pied Hornbill Anthracoceros coronatus.
A total of 14 bird species recorded from BMWS & NP are endemic to
the Western Ghats and 32 of the recorded species are listed in the Schedule I
(Part III) of the WPA, 1972. Six bird
species are classified as Near Threatened by International Union for
Conservation of Nature and Natural Resources (IUCN).
2.6
Mammals
BMWS & NP, along with
the Kali Tiger Reserve and surrounding reserved and protected forests cover an
area of at least 2,000km2 and form an important Bengal Tiger Panthera
tigris habitat (Gubbi et al. 2016).
The National Tiger Conservation Authority has recommended bringing
together the protected areas of Goa and Karnataka for Tiger conservation and
improved management. In a document
released by the MoEFCC titled “Connecting Tiger Populations for Long-term
Conservation” the forests of Goa are mentioned as one (Sahyadri-Radhanagari-Goa)
of 32 major Tiger corridors in India. A
breeding population of Tigers has been recorded from the tri-junction of
Goa–Karnataka–Maharashtra (Girish Punjabi pers. obs. 19.iii.2019; Jhala et al.
2020). In May 2019, the Forest
Department of Goa photographed an individual Tiger using trail cameras in the
BMWS & NP, and expect more individuals to be present (The Goan Everyday
2019). On the 5 January 2020, carcasses
of four Tigers – a female and her three cubs were found in the neighbouring
Mhadei Wildlife Sanctuary (Kerkar 2020).
The four tigers were poisoned in retaliation for depredating livestock
(Kerkar 2020).
More than 60 mammal
species are likely to occur in the PAs, of which 11 species belong to Schedule
I of the WPA 1972 (See Appendix III).
Gad & Shyama (2009) found that Gaur Bos gaurus was widespread
and fed on 32 plant species belonging to 17 plant families in the PA. Sengupta & Radhakrishna (2013)
encountered a higher number of Bonnet Macaques Macaca radiata in BMWS
& NP as compared to other parts of Goa.
Krupa et al. (2017) reported two sympatric otter species, the Asian
Small-clawed Otter Aonyx cinereus and Smooth-coated Otter Lutrogale
perspicillata in the buffer region of Mhadei WS, which adjoins BMWS &
NP.
3.
REVIEW OF EIA FOR THE NH-4A HIGHWAY EXPANSION PROJECT
After compiling lists of
taxonomic groups known from the PAs, the authors reviewed the EIA for NH-4A
Highway Expansion (henceforth Road Report) for information provided on
taxonomic groups, environmental and social impacts of the project. We found inadequacies in most aspects and as
such the Road Report was observed to be of poor quality. The relevant issues are discussed here.
3.1
Plants
i) Several issues were
found with the reported methodology for the baseline survey on plant species in
the Road Report. The sampling strategy
was not clearly indicated. The Report
says that the number of quadrats in each habitat type was proportionate to the
land in the habitat type, but no further information is provided whether a
randomized or systematic sampling protocol was used. In the absence of a protocol, sampling
locations would be biased and not fully representative of the habitat type.
ii) Resultantly, the list
on floral species in the Road Report is inadequate when compared to existing
species list of the area (Datar & Lakshminarasimhan 2011).
iii) The sampling
methodology outlined was likely not followed.
The data were finally compiled and based on a reconnaissance trip and
secondary literature (Section 5.8.2, Page 79).
No analysis of species diversity or dominance were performed, and the
findings are only provided in the form of a brief species list (Table 5.15,
Page 79). This list excludes understory
species, herbs, and lianas. No data are
presented on tree girths, size classes or age structure, which could help in an
assessment of the damage to the forest.
iv) The Road Report is not
clear about which agency will plant trees as part of the project and the
figures provided are inconsistent. It
states that the intention is to plant 20,000 avenue trees next to roadside
parking areas, toll gates, bus bays, and truck lay-bys (page 82). The Report later revises this number to
50,000 trees (Page 96), then to ~27,000 trees (based on planting 333 trees per
km2 in wildlife sanctuary and 666 trees per km2
elsewhere) and finally back to 20,000 trees (Page 137).
v) The Road Report has
also not specifically identified plant species that will provide appropriate
and compensatory ecosystem services for the tree plantation. The species to be planted on the edge of the
highway are Mahua Madhuca longifolia and Khair Acacia catechu,
which are not typical of the Western Ghats and Bougainvillea sp., an ornamental
that is not native to India, but is to be planted in the median.
3.2
Insects and Arachnids
i) The Road Report has no
impact assessment of linear intrusions on insect and arachnid diversity, with
no details on species richness in the area.
No attempt has been made to compile secondary information from published
and unpublished sources.
ii) There are many studies
from India and the world which have examined the impact of roads on
insects. Insects suffer a high mortality
while crossing roads or may avoid crossing roads altogether (Muñoz et al.
2015). Studies report that vehicle
lights attract many insects, causing mortality during the night (Seshadri &
Ganesh 2011). The barrier effect of
roads is higher for slow-moving insects (Muñoz et al. 2015), but even flying
insects such as butterflies are affected by fragmentation created by roads, as
the nature of patch-edge affects their dispersal ability (Ries & Debinski
2001; Dover & Settele 2009). Studies
on grasshoppers have demonstrated that males increase their call frequency in
response to road noise, which may have population-level consequences (Lampe et
al. 2014).
iii) Despite evidence of
high levels of diversity and endemism in the BMWS & NP, odonates have not
been surveyed. Species of hill streams
are more narrowly-distributed and are indicators of water quality (Simaika et
al. 2016). A new dragonfly species Idionyx
gomantakensis (Subramanian et al. 2013) was reported in 2013 from the PAs,
a fact that has been overlooked in the Road Report. This raises doubts whether secondary data has
been reviewed while compiling the faunal list for the project area.
iv) No details are
provided for Arachnids in the Road Report.
In so far as the amblipygid, urropygid, and theraphosid spiders of these
areas are concerned, given their fidelity to their habitat type and their
rather restricted movement, any alteration of the habitat, due to road
construction and widening, shall decimate these small and isolated populations
beyond recuperation and renewal, even leading to local extinctions
(Maelfait & Hendrickx 1998).
3.3
Fish
i) No fish species or
impacts of road expansion have been described in the Road Report. It states that “since most of the water
bodies remain dry during the non-monsoon months, this [sediment] impact will be
negligible” (Page 98). This
statement is inaccurate, as several perennial streams and pool habitats contain
water and act as refuges for various fish species in the non-monsoon
months. A study cautions against the
effects of sedimentation and run-off on the fish communities due to rampant
vehicular traffic in the neighbouring Mhadei Sanctuary (Atkore 2017).
ii) Many other impacts are
envisioned which the Road Report has not assessed. Soil erosion due to the removal of riparian
vegetation would have short-term as well as long-term impacts on stream
dwelling communities. Riparian
vegetation plays an important role in maintaining ambient temperature in the
headwater catchment (region from numerous streams originates) enabling
persistence of diverse, endemic and habitat specialist fish species such as Balitora
sp., Glyptothorax sp., Schistura sp., Bhavania sp., and Garra
sp. (Sreekantha et al. 2007).
iii) Increased soil
erosion due to the road expansion is likely to multiply the sedimentation load,
which may impair water quality greatly due to high turbidity. Sediment deposition is likely to reduce food
availability to aquatic communities.
Bottom-dwelling fish such as Balitora sp., Glyptothorax
sp., and Schistura sp. feed on benthic insects (Daniels 2002), and have
a very narrow range of distribution and tolerance level to certain water
quality variables.
iv) Higher suspended
solids and silt deposition can also affect spawning grounds and various life
stages of fish. A few highly sensitive
fish species such as Deccan Mahseer Tor khudree and Hypselobarbus
sp. are known to migrate upstream for feeding and breeding, either once or
twice a year. Mahseer, in particular,
are known to choose definite and special spawning grounds which usually are
rich in dissolved oxygen content, neutral pH, and cool water temperature. Eggs, fry and fingerlings stages of this fish
are highly sensitive to the slight alterations in their environment and
spawning habitats (Daniels 2002). Soil
erosion and high deposition of silt along with stream flow are expected to
destroy their habitat, and could reduce their population in Dudhsagar and other
adjoining waterbodies.
v) Surface dwelling fish
such as Devario sp., Barilius sp., and Salmostoma sp. feed
largely on insects falling from the canopy (Johnson & Arunachalam
2010). Higher turbidity due to sediment
load would reduce their ability to forage and may restrict these fishes to
downstream habitats, affecting their survival.
3.4
Herpetofauna
i) Details on
herpetofaunal diversity in the PAs is not mentioned in the Road Report. Section 5.8 (Page 74) mentions that Goa has a
high snake population. While this may be
a general statement, it is not backed by any references.
ii) Further, data from
exsiting literature points to an increase in the number of snake and amphibian
road-kills with existence of roads (Garriga et al. 2012; Santhoshkumar et al.
2017). There is, however, no mention of
the impact of road expansion on herpetofaunal diversity of the PA in the Road
Report.
3.5
Birds
i) Although the Road
Report mentions that a field survey has been carried out (Section 5.8.2 (v),
Page 78), there is no bird checklist provided, except for one mention of the
Indian Robin Copsychus fulicatus along with other fauna (Table 5.16,
Page 82). Bird species richness and
abundance were not quantified in the project area that may be affected due to
the project construction. This is a
serious shortcoming given that 286 bird species have been recorded in the BMWS
& NP (Rahmani et al. 2016, See Appendix I).
ii) A section (Page 74) of
the Road Report matches the Wikipedia page “Flora and Fauna of Goa” (Wikipedia
contributors 2020), which mentions that the state bird of Goa is “the
Ruby-throated Yellow Bulbul, which is a variation of Black-crested
Bulbul”. This is inaccurate, as the
state bird of Goa is the Flame-throated Bulbul Pycnonotus gularis, which
recent studies have elevated to a full species (Rasmussen & Anderton
2012).
iii) There is further
confusion about the state bird of Goa; section 5.8.1 of Page 78 of the Road
Report refers to the Yellow-throated Bulbul Pycnonotus xantholaemus as
the state bird. The Yellow-throated
Bulbul is endemic to peninsular India and has no known distribution in
Goa. The faunal statistics presented in
section 5.8.1 have been taken from Kumar & Somashekar (2008) with no
attribution to the original source. The
absence of any data on birds, either quantitative or qualitative, from an area
that has been classified as an Important Bird and Biodiversity Area (IBBA),
undermines the purpose of the EIA.
3.6
Mammals
i)
To assess faunal diversity, field surveys and a local consultation were
conducted in the Road Report, however, it does not contain any methodological
specifications or sampling strategy.
Sampling methods for different taxa are also not clearly differentiated. The species list is limited with only 16
species recorded. This is a clear
underestimate as more than 60 mammal species are known to inhabit this region
(See Appendix III).
ii)
The presence of the Bengal Tiger in the area is also not mentioned. The report states that no endangered species
are found in the area which is clearly misleading considering three Endangered
mammal species occur, including the Tiger, Dhole, and Indian Pangolin. One of the species mentioned in the Road
Report, the Red Giant Flying Squirrel Petaurista petaurista is not found
in the Western Ghats. Common species
such as the Bonnet Macaque and Chital Axis axis, are also not
reported.
iii)
The Road Report states that the road expansion will not affect faunal species,
and instead claims that species “may increase in number because of the road
structures as the project will not obstruct their movement rather can create
new habitats for them” (Section 5.8.1, v, Page 82). This statement is misleading as wide roads
are known to create an obstruction to movement for a wide variety of species,
including mammals (Bennett 2017). Roads
also create forest edges that can harmfully affect native vegetation and rare
wildlife due to edge effects, which extend far beyond the area of the road (Gubbi
et al. 2012; Poor et al. 2019). Small
mammal communities near roads have also been found to differ from those away
from roads (Goosem 2002).
iv)
Section 5.8.1 (Page 78) of the Road Report mentions the Leopard and Black
Panther as two separate species, however, these are colour morphs of the same
species Panthera pardus. The Gaur
Bos gaurus, which is the State Animal of Goa, does not find mention in
the checklist. Section 5.8.1, (v) also
states that none of the faunal species found here are “endangered or
extinct”. This is unsound as endangered
species such as the Bengal Tiger, Dhole, and Indian Pangolin are found in the
region, while extinct species are found nowhere in the wild.
3.7
Land-use
i) A land-cover map for
this project was acquired as a secondary data source, without clarity on how it
was prepared. The map presented is for
the entire state of Goa (Figure 5.23, Page 75), and not specific to the project
site. The impacts on the land-use and
land-cover specific to the project area have not been assessed in the EIA. The land-use table (Table 5.14, Page 73) has
an error in summation of all land-use types.
Further, the land-cover classes in the table do not match the ones in
the map. These errors create confusion
about which land-cover types will be affected by the project.
3.8
Water
i) The Road Report
mentions that there are declining water level pockets in South Goa, indicating
the need to strictly regulate groundwater extraction in these pockets, however,
Section 5.1.4. (Page 40) of the Report has insufficient information on the
river basins in the region. Only water
depths are provided, without any data on the coverage area, volumes, or a
reasonable level of water extraction that is possible from rivers during road
expansion.
ii) Section 5.5.1. (Page
51) states that chloride concentrations are “well within the desirable and
permissible limits”. This statement is
misleading. Samples GW-02 and -06 both
had detected values above the desirable limit range and are at risk of
exceeding the Bureau of Indian Standards’ drinking water standards. Thus, there is insufficient evidence to
support the statement that there is ‘good’ scope for groundwater exploitation
in all the five affected taluks in the South Goa District.
iii) There is inadequate
information on the water assessment sampling procedure in the region. Section 5.5.1 (Page 51) suggests that single
samples were collected from five separate surface water sites and eight
separate groundwater sites, during one sampling visit. No indication of the season or sampling date
is provided, nor of repeated sampling to ensure accuracy or reliability. The statement that “total hardness observed
to be constant in all samples” is flawed, as notable variation was observed
between hardness in the different sample locations of the Road Report.
3.9
Air
i) Air quality would be
negatively affected after the road expansion, but there is scarce attention
paid to any robust evaluation in the Road Report. The statement that with the “proposed
four-laning project, traffic may further come down and ease the vehicles
movement and traffic congestion, which may lead to reduce the pollution levels”
lacks substantial evidence and cannot be a justification for road expansion
within a PA and ecologically-sensitive area.
ii) Table 6.5 (Page 102)
proposes that greenhouse gases and other pollutant emissions may be
significantly reduced based on the assumption of a small increase in traffic
burden along with the avoidance of stopping, idling and congestion, however,
traffic projections in the report show that total traffic is projected to only
increase over the years, at all the three points where present traffic was
surveyed (Table 2.15, Page 20). It is
doubtful that vehicular emissions will be reduced with increased number of
lanes, when scientific literature indicates that road widening leads to
increased emissions which negatively affect air quality (Roberts et al. 2010;
Font et al. 2014)
3.10
Soil
i) According to Table
5.13. (Page 72) of the Road Report, among the trace metals likely to
contaminate soils due to large-scale construction and traffic pollution, only
Lead (Pb) and Iron (Fe) are noted, however, this is this is insufficient, as
several heavy metals such as Cadmium (Cd), Copper (Cu), Zinc (Zn), and
Manganese (Mn) originate from material abrasion, fuel combustion and road dust
(Chen et al. 2010; Abdel-Latif & Saleh 2012; Świetlik et al. 2013). Heavy metals have been associated with high
levels of genotoxicity and mutagenicity in soils contaminated with heavy metals
(Husejnovic et al. 2018) and their concentrations should be monitored and
potentially reduced in PAs, particularly in view of the risk of trophic
transfer, migration, and bioaccumulation (Zhang et al. 2018; Chouvelon et al.
2019).
3.11
Social Impacts
i) Datar &
Lakshminarasimhan (2011) documented around 90 floral species to be important
for local consumption and livelihood.
While the Road Report lists flora of the affected area and people’s
reliance on non-timber forest produce (NTFP), it does not mention the potential
impacts on the floral community that can hamper NTFP-based livelihoods of the
local community around BMWS & NP.
ii) The Road Report
mentions that apart from forest land, almost 70.42ha of non-forest land would
be acquired affecting 377 civilian and governmental structures (Table 5.17,
Page 85). It is not clear what the
extent of damage to these structures would be.
Further, the assessment does not delve deeper into the livelihood
impacts and possible mitigation plans for families affected by the
project. It mentions that a separate
land acquisition plan would be devised for these aspects and has no concrete
mitigation plans for social impacts.
4.
REVIEW OF ASSESSMENT STUDY FOR THE RAILWAY EXPANSION PROJECT
While the assessment study
(hereafter Railway Report) for railway expansion was informative and detailed,
it suffered from several shortcomings as well.
The authors reviewed it for information on the same parameters –
assessment of taxonomic groups, environmental, and social impacts. It is noteworthy that the railway expansion
will affect not only the BMWS & NP but also the neighbouring Kali Tiger
Reserve in Karnataka State. Therefore, a
project which will fragment the only intact tiger and elephant population in
the north-central Western Ghats will have severe ramifications for wildlife and
biodiversity. The Railway Report,
however, does not stress on the ecological impacts of railway expansion and
instead presents a neutral portrait of the project impacts by emphasizing
uncertain mitigation measures.
4.1
Plants
i) In the section on
vegetation characteristics, it is mentioned that 255 species of flowering
plants were recorded (Page 64), but Appendix 2.1.a. of the Railway Report lists
224 woody trees. The IUCN Red List status
is not provided, and a few common endemic species that occur in the region are
not mentioned in the tree species list.
ii) The floristic survey
results (Page 83) only records seedlings of woody trees but not herbs and
orchids, some of which are rare with restricted distribution in the Western
Ghats (Joshi & Janarthanam 2004).
iii) Plant species are
misspelled or outright erroneous in the Appendix which makes it difficult to
identify the plants that will be impacted.
For example, Euonymus undulatus is misspelled (correct name: Euonymus
angulatus), while Lapisanthes microphylla is an invalid scientific
name as per our knowledge.
iv) Appendix 2.1.a of the
Railway Report mentions 13 plant species (including vulnerable and endemic
species) which are yet to be recorded from Goa.
Three of those species may not occur in the BMWS & NP and need
further scrutiny as to the validity of their inclusion, however, even if they
do occur, it only reveals the importance of the region for plant diversity, and
therefore the region should not be diverted for the railway expansion.
4.2
Insects
i) The Railway Report
follows standardized protocols to document butterfly diversity of the region
but covers a very small area which might not represent all the habitats
affected by the project, a fact acknowledged in the study (Page 87).
ii) The survey was carried
out from April (2013) to May (2014), however, there is no mention of the
duration of data collection, including details on whether surveys were
undertaken every month or a few days every season. This would have a bearing on the findings.
iii) There is no mention
of whether sampling effort was replicated.
This precludes an understanding of how many times a transect was
sampled, and whether the same transects were sampled repeatedly in subsequent
seasons. Quantitative analysis of data
collected with inadequate sampling protocols may lead to incorrect estimates of
insect diversity.
iv) The Railway Report
mentions that the Family Lycaenidae and Hesperiidae were represented by 33 and
18 species, respectively. The number of
species, however, might be under-represented given the difficulty in visual
identification of species belonging to these Families. No effort was made to account for detection
issues in the Railway Report.
v) The Railway Report also
does not provide an assessment on moth diversity. Moths are ecologically important and even
more diverse than butterflies and dragonflies.
At least 418 species of moths of which 116 species are unidentified,
were reported from the north Western Ghats (Shubhalaxmi et al. 2011). Given that the study site is a PA in the
Western Ghats, it is likely to have high moth diversity.
vi) There are
discrepancies in the listing of species in the Railway Report. For example, butterfly species such as Neptis
columella, Doleschallia bisaltide, Actolepis puspa, and
Castalius rosimon which are Schedule I species are left out of the
scheduled species list and the text, with only a passing mention in the
Appendix of the Railway Report (Appendix 2, Page 89).
4.3
Fish
i) The Railway Report
records the presence of 23 fish species, however, a comprehensive study in the
Mhadei sub-basin (which includes BMWS & NP) reported 49 fish species with
18 endemics from the Western Ghats (Atkore 2017; see Appendix IV).
ii) The Railway Report does
not assess potential impacts of the project on fish community structure, even
though studies have found that alteration of stream environment (changes in
water quality and flow alteration) by anthropogenic pressures have negative
influences on fish guild composition (Atkore 2017; Atkore et al. 2020).
4.4
Herpetofauna
i) The Railway Report has
a fairly comprehensive assessment of amphibians and reptiles. It reports key details about the diversity of
herpetofauna, including endemics, however, it only mentions the impact of the
railway-line in causing mortality of reptiles (Page 140), and remains
inconclusive of impacts on amphibians (Page 135).
ii) The survey on
amphibians clearly finds that 13% of endemic Western Ghats species (14 species
out of 24) were found in the project area.
This number is likely higher and points to the sensitivity of the region
for anurans (See Appendix VIII of this paper).
iii) For reptiles, the
Railway Report finds 27 species, which is an underestimate (See Appendix VII of
this paper). The report does not have an
exhaustive assessment of impacts due to the railway expansion on herpetofauna,
reasoning that the study was carried out “during the inactive period of
reptiles (winter) where the intensity of the impact could not be assessed
properly due to their high seasonal activity, secretiveness and less
conspicuousness” (Page 140).
4.5
Birds
i) The Railway Report
mentions that a two-day survey for birds was carried out in September 2014 and
May 2015. It is not clear why a short
survey effort was employed to compile the checklist. The survey enumerates only 35 species, of
which nine were endemic species. This is
an underestimate, compared to the 286 bird species recorded in the BMWS &
NP in a comprehensive checklist (Rahmani et al. 2016; eBird 2017).
ii) Data is collected only
for cavity-nesting birds. This omits
species that do not nest in cavities, but are dependent on trees and vegetation
for nesting and feeding. The reason for
surveying only cavity-nesting birds is not provided. Further, migratory birds are
under-represented in the survey, given that the survey was not carried out
during the migratory season between October–March.
iii) The Railway Report
mentions, “The loss of tree specially >10 and >60cm dbh would impact the
nesting of birds in the proposed project area” (Page 145). Again, this focuses only on cavity-nesting
birds, and undermines the importance of shrubs and undergrowth for passerines
and understorey insectivores, which will also be impacted. Such impacts of the loss and fragmentation of
the forest cannot be mitigated or compensated for, with respect to
ground-nesting and understorey insectivorous birds (Lampila et al. 2005).
iv) The project area
description (Page 19) mentions the state bird of Goa as the Ruby-throated
Yellow Bulbul Pycnonotus dispar.
This is an error. The state bird
of Goa is the Flame-throated Bulbul Pycnonotus gularis, while P. dispar
is a bird found in the forests of Java and Sumatra.
4.6
Mammals
i) The Railway Report
suffers from multiple lacunae such as inadequate sampling effort. Species accumulation curves, which could have
accounted for this limitation, were not generated.
ii) The sampling methods
also do not account for detection issues (i.e., false negatives; Sollmann et
al. 2013). This is especially pertinent
given that a much higher number of mammal species occur in the region, which
find either inconsistent, or no mention in the Railway Report (See Appendix III
of this paper). For example, the
Executive Summary (Page 5–6) mentions 42 mammal species were found using a
literature survey, but the presence of the Bengal Tiger (India’s National
animal) is not explicitly stated.
Appendix 2 of the Railway Report (Page 166) mentions 23 species of
mammals, but does not mention which of those are Schedule I species, even
though the region has 11 Schedule I mammal species. The ecological value of the region may have
been underemphasized due to these inadequate methods as many more mammal species
that occur in the region are likely to have been missed as they were not
accounted for (Hayward et al. 2015).
iii) The description of
the methods is very sparse and limits clear understanding (Page 153). The sampling unit was undefined — signs were
recorded both inside and outside of belt transects. The study description lacks any detail about
statistical methods used to assess species richness or percentage occurrence or
relative abundance, using indirect signs or direct sightings.
iv) Randomly placed
belt-transects used in the Railway Report are not a suitable choice to assess
large and small carnivore species richness and occurrence (Barea-Azcón et al.
2007). Further, signs were recorded
opportunistically from outside of belt transects (Results, Page 153–154), but
no clear analytical framework is provided for this data. Carnivores often tend to move on forest
trails, roads, dry streams therefore a non-random or systematic sampling
approach (within beats or grid cells) would be more appropriate to specifically
assess carnivore occurrence in the study region (Karanth et al. 2011).
v) Camera-traps are one of
the best tools available to assess the occurrence, density, and abundance of
mammals (O’Connell et al. 2011). But,
the Railway Report uses a sparse sampling effort by surveying only 16 sites
(camera-traps malfunctioned in nine of the 25 sites surveyed). In addition, the cameras were placed for less
than six days in most sites. Studies
have found a minimum of 20 to 30 error-free days of camera-deployment are
required for stable estimates of species occurrence (Hamel et al. 2013). The standard duration for density assessment
of large cats in Tiger Reserves and PAs of India is 25 days (with a closure
period of 45–60 days). Therefore, a
sampling duration of less than six days used in the Railway Report translates
to poor data collection, which eventually affects any ecological inferences
derived from such studies (Burton et al. 2015).
vi) The camera-trapping
protocols lacks any detail about the camera models used, mode of deployment,
camera-settings, and study design (Meek et al. 2014).
vii) Table 2.8.1 (Page
154) reports the species Viverra zibetha (Large Indian civet) which is
not found in the Western Ghats, but in northeastern India. The table also mentions the occurrence of an otter
species, Lutra lutra, the Eurasian Otter, which has not been recorded
from the region. The Railway Report
provides no evidence of its presence in the form of photographs. Two other species of otters which have been
recorded and photographed in the region, the Asian Small-clawed Otter and the
Smooth-coated Otter are not mentioned (Punjabi et al. 2014; Krupa et al.
2017). Page 161 of the Railway Report
has erroneously labelled Wild Pig Sus scrofa as Indian Porcupine Hystrix
indica.
viii) Appendix 2 in the
Railway Report (Page 166) has incorrect coding for species: Langur and Bonnet
Macaque are listed as herbivores (when they are actually primates); Asian Palm
Civet is coded as a carnivore, but the Small Indian Civet, Brown Palm Civet,
and Stripe-necked Mongoose are incorrectly coded as herbivores; the otter and
Indian Pangolin are coded as large mammals, but the Asiatic Wild Dog, which is
larger in size is coded as a small mammal.
This reveals a naive understanding of mammals and the impacts that railway
expansion could have on low-density species such as carnivores.
4.7
Land-use
i) The land-use land-cover
map was derived from classification of single date satellite data, acquired in
April 2013. Since the project area
supports different types of vegetation which have variation in spectral
signatures during different seasons, an ideal mapping exercise should have
considered seasonal data, for at least two different seasons within one year.
ii) Out of six effective
bands of Landsat and eight for vegetation discrimination, only four bands have
been used for classification. This
essentially leaves out the details of land-cover class categories that are
clearly identified by the other two short-wave infra-red bands. These two short-wave IR bands demarcate the
response of vegetation to moisture stress, and thus improve the classification
of the forest types (Ferreira et al. 2016).
iii) The reasoning behind
the number of sampling points used for each land-cover category is not
clear. It is stated that unsupervised
classification, which yielded 15 classes, was used as a basis for ordering the
landscape into distinct units. It is
unclear, however, if these ‘distinct units’ were further assigned land-cover
classes on the basis of any reference map.
A reference map could have informed the locations where ground truth
data was necessary for ascertaining land-use types.
iv) The exact methodology
for land-cover classification, parametric (maximum likelihood, minimum distance
to means), or non-parametric (support vector machines or any other) has not
been mentioned. This prohibits a nuanced
understanding of the method of classification for a forest complex.
v) Ancillary data such as
topographical information from an elevation model have not been utilized for
assessments. A simple elevation profile
of the proposed railway route indicates an elevation range of 80–500 m. In a high elevation area with varying
gradients, the topography of the land determines much of the vegetation
assemblages, and this could be important information to include in the
classification process. The importance
of topographic information for vegetation mapping is a widely accepted
methodology (Das et al. 2015; Roy et al. 2015) and earlier work in the Eastern
Ghats region has used topographic information effectively to this end (Balaguru
et al. 2003).
vi) The basis for accuracy
assessment has not been mentioned. An
overall accuracy of 88% is indicated, but no reference map seems to have been
used for calculation. The report also
does not mention the percentage of samples used for training and testing the
classification, which is a standard accuracy assessment procedure.
4.8
Water
i) Water pollution is a
major concern during the construction as well as during the operation phase.
Water pollution analysis, however, was minimal with no monitoring of pollutants
done for polycyclic aromatic hydrocarbons (PAHs) and heavy metals because of
the existing railway-line, despite high concentrations being often reported in
waterways bisected, or bordered by railways (Wiłkomirski et al. 2011;
Wiłkomirski et al. 2012; Levengood et al. 2015).
ii) Furthermore, Escherichia
coli bacterial contamination was reported in all sampled streams,
indicating faecal contamination, which may be attributed to waste disposal from
passing trains. The total coliform count
ranged from 221/100mL to 542/100mL, while the safe threshold value is 100
count/100mL. The increased risk of
coliform contamination resulting from the railway expansion is a severe threat,
as many streams that cross the tracks harbour sensitive wildlife, and also
supply water to villages downstream for drinking and farming.
4.9
Air
i) No air quality
monitoring was performed to provide baseline levels or to establish the risk of
railway expansion in this region. The
Railway Report assumes that engines will be electrified; however, if existing
diesel engines are used then the doubling would increase the amount of
pollutants associated with combustion and diesel emissions.
ii) The main constituents
of diesel engine exhaust emissions are Carbon (CO, CO₂), Nitrogen (N), Nitrogen
Oxides (NOx), Sulphur Oxides (SOx), Hydrocarbons (HC), Methane (CH4),
Non-Methane Volatile Organic Compounds (NMVOC), PAHs, and particulate matter
(PM) (Borda-de-Água et al. 2017).
Monitoring of the current pollutant levels should have been performed at
least twice a year to avoid data bias due to seasonal variation, although
quarterly (or even monthly) sampling events could have been employed
(Jayamurugan et al. 2013; Manju et al. 2018).
4.10
Soil
i) Chemical properties of
soil and baseline levels of soil pollution were not established during sampling
and analysis. Soil and plants
surrounding the railway lines should be monitored for organic and inorganic
compound contamination, resulting mostly from used lubricant oils and condenser
fluids, the transportation of oil derivatives, metal ores and other chemicals,
as well as from application of herbicides and other treatments to the train
vehicles. These pollutants, however,
were not considered in this assessment.
ii) PAHs, heavy metals,
oil-derived HC, and to some extent, polychlorinated biphenyls (PCBs) should be
monitored in soils, with risks comprehensively assessed as they exhibit
toxicity, long-term stability and a cumulative effect in the environment (Wiłkomirski
et al. 2011; Wiłkomirski et al. 2012; Levengood et al. 2015; Pereira et al.
2015). PAHs are carcinogenic and
mutagenic to living organisms (IARC 1989).
The main source of PAHs in railway areas are machine grease, fuel oils
and transformers oils. Heavy metals
(such as Pb, Cd, Cu, Zn, Hg, Fe, Co, Cr, Mo) originate mainly from material
abrasion and fuel combustion in diesel and electric locomotives, therefore the
railway expansion will lead to further heavy metal contamination in soils.
4.11
Social Impacts
i) The Railway Report’s
socio-economic survey of 60 families conducted in four villages does not report
the total number of affected families, demography and livelihood patterns of
concerned villages. The sampling strategy
and the criteria for selection of households is unclear. The questionnaire was focussed on the
perception of transport models by local communities. The questionnaire did not have open-ended,
non-leading questions to bring out local concerns towards the project, and
possible impacts on their livelihood and environment. Instead, it addressed questions such as
preferred mode of transport, where 90% of the respondents listed trains.
ii) The Railway Report
mentions a public consultation meeting regarding the railway expansion project
that occurred in June 2016 at Kulem Panchayat (Hindi: Village Council) office
(Page 190). The Kulem Panchayat raised concerns about the impact of the project
on the Dudhsagar waterfall which contributes revenue from tourists to the local
economy, availability of medicinal plants and disturbance to the temple close
to Sonalium Station (Page 191). The
consultation meeting was attended by only 14 members, most of whom were
panchayat office bearers and members of the biodiversity committee, but not by the
general public who would be affected by such developmental projects. As this meeting took place in 2016, before
the Railway Report was published (in 2017), it is unclear whether a public
hearing took place after the report was published. This suggests that the affected public is
unaware of the damage the expansion may bring to their livelihoods.
iii) The Railway Report
mentions that NTFPs and medicinal plants from the forest area were important
for local use (Pages 169–171), but the specific impacts of the railway
expansion on such NTFP and medicinal plant species were not assessed. Datar & Lakshminarasimhan (2011) reported
that local communities around BMWS were dependent on the forest for wild edible
mushrooms, fruits, herbal medicinal plants, and specific plants for cultural
use. This indicates that it is important
to assess the impact of the proposed project on NTFP collection.
iv) The Railway Report
finds that existing faecal contamination in the streams near to the railway
tracks and the level of contamination is already 2–5 times the prescribed
limit. Waste generation due to
construction debris within the forest can further pollute soil and water
resources in this sensitive region, thereby also affecting human
communities. Increased waste dumping by
railway passengers near villages can attract wildlife to these villages, which
can result in human-wildlife conflict scenarios.
5.
REVIEW OF THE 400kV TRANSMISSION LINE
The
transmission line project did not have the assessment study in the public
domain and therefore this limited our review to aspects of this project for
which information was available in the public domain on the Parivesh
portal. The key concerns with the
transmission line project are discussed here.
i)
The construction of new power lines in forest areas of high conservation value
should be avoided (Eldegard et al. 2015).
The transmission line project passes through a PA (11.54 ha inside PA)
and the total forest land required for the project is 48.3 ha (almost 50 ha,
for which an EIA is necessary from a socio-ecological point of view). The minutes of the meeting of the Goa State
Board for Wildlife held on 02 December 2019 mentions that “the Biodiversity
Impact Assessment studies and Biodiversity Management Plan has been prepared by
ERM India Pvt. Ltd, Gurgaon has been submitted”. The same, however, is not available in the
public domain to allow a clear assessment of projected impacts.
ii)
The detailed project report that is available for the transmission line makes
contradictory statements about the location of the transmission line in the
BMWS & NP. It first states that
2.51km of the transmission line is within the NP, clearing an area of 11.54ha
(Table 1, Page 2, Detailed Project Report).
Subsequently, when justifying the reason for choosing between
alternative routes of the transmission line, it states that the chosen route
fully avoids the NP. These statements
severely weaken the report and hinder an effective assessment of the impacts of
the transmission line, which already lacks sufficient public scrutiny. An inspection report by the forest department
indicates that over 4,146 trees and 985 cane clumps in the PA are to be cut for
the project.
iii)
The project proponent claims that “transmission line projects are environment
friendly and do not involve any disposal of solid effluents and hazardous
substances in land, air and water.
Moreover, forest area trees are felled below each conductor to
facilitate stringing. On completion of
construction only one strip is maintained for O & M purpose. Therefore, the actual loss of forest is
restricted to some selected areas only.”
These statements do not recognize the larger effects of the transmission
line on birds and volant mammals such as bats and gliding squirrels, or on arboreal
species such as the Slender Loris, Giant Squirrel, Bonnet Macaque, and Grey
Langur. For example, due to the absence
of tree cover along transmission lines, arboreal mammals such as Lorises are
forced to use electric wires of power lines to cross, causing mortality due to
electrocution (Raman 2011).
iv)
The project requires a clearance for 35 years, during which there will be
regular cutting below the transmission line.
This is especially concerning given that the project cuts through the
PA, so the effects of this project are long-term.
v)
The statement “the actual loss of forest is restricted to some selected areas
only” fails to take into account existing evidence that power lines are linear
intrusions that prevent animal movement, fragment communities of small mammals
(Goosem & Marsh 1997), and cause mortality due to electrocution and
collision (Jenkins et al. 2011; Rioux et al. 2013; Loss et al. 2014; Uddin
2017). Large mammals have also been
electocuted due to sagging power lines (Raman 2011). The area underlying the proposed transmission
line currently (i.e., without the construction of the power line) offers low
resistance to large mammal movement, indicating that the area is important for
animal movement (Jayadevan et al. 2020; https://indiaunderconstruction.com). In their paper, Jayadevan et al. (2020)
recommend avoidance of new infrastructure in areas that currently pose a low
resistance to movement.
vi)
Transmission lines have several impacts on birds. Studies have shown that birds avoid areas
between 0.25 and 0.6 km of transmission lines (Dunkin et al. 2009; Gillan et
al. 2013). Transmission lines cause bird
mortality due to electrocution and collision (Uddin 2017; Biasotto & Kindel
2018). For example, many birds use
structures of transmission lines as a perch, which often leads to electrocution
(Biasotto & Kindel 2018). The
clearing of trees for the transmission line affects the movement and nesting
success of birds (Biasotto & Kindel 2018).
vii)
The conservation value document uploaded by the wildlife warden details the
damaging effects of the project. The
document, however, concludes that the movement of faunal species will not be
affected by the project, and the loss of trees can be compensated via
afforestation. This is inaccurate, as
transmission lines would impact movement of fauna, in addition to other
deleterious impacts including mortality, as we detail above. Further, compensatory afforestation at a
different site does not ameliorate any of the ecological impacts within the PA,
as mentioned in the document.
6. DISCUSSION
We
argue that mitigation measures proposed in the Road Report, Railway Report, and
documents for the transmission line are inadequate and will not alleviate
serious damage to the BMWS & NP or ecologically-sensitive regions around
the PAs. We have explained this in
detail in the following sections.
6.1 INADEQUACY OF MITIGATION MEASURES FOR NH-4A
i)
For the mitigation measures, the Road Report merely notes that “Mitigation of
man versus animal conflict is going to be the important issue that will
threaten wildlife in Sanctuary area” (Page 97, Section 6.3.9 (i)). There are, however, no mitigation measures
recommended to reduce the conflict created by road expansion. An acknowledgement of an important socio-economic
and environmental problem will not equip the Goa Forest Department, National
Highways Authority of India, or the Public Works Department of Goa to
effectively manage the problem created by road expansion without detailed
mitigation plans.
ii)
For terrestrial fauna, the Road Report states that no impact on the wildlife is
anticipated and hence does not outline any mitigation measures (Page 97,
Section 6.3.9 (II)). Given that nearly
32ha of forest land will be diverted for the project, there is likely to be an
impact on wildlife. There is growing
scientific evidence demonstrating that building new roads and their upgradation
or expansion has serious impacts on wildlife in protected areas. For example, Garriga et al. (2012) found a
total of 2,013 wildlife mortalities on roads within protected areas of
Catalonia, of which 267 were mammals (13.3%), 253 birds (12.6%), 245 reptiles
(12.2%), and 1,248 amphibians (62.0%). A
total of 85 different species were affected across all taxa due to roads within
PAs over just two seasons, Spring and Autumn, in one year.
iii)
As a measure to mitigate vegetation and habitat loss, the Road Report mentions
that “an avenue plantation programme shall be promptly adopted to restore and
further enrich the loss of vegetation” (Page 96, Section 6.3.9 (i)). Such measures may increase green cover, but
they do not mitigate the impacts of road construction on vegetation or
wildlife. Instead, it also puts people
at risk due to the increased likelihood of vehicular collision with mammals
(Case 1978; Jaren et al. 1991; Putman 1997; Cain et al. 2003).
iv)
The Road Report proposes “periodic maintenance of drains to check
scouring of soil” to decrease soil erosion (Page 92, Section 6.3.5). Soil erosion is expected to be higher in
tropical forests, such as BMWS & NP, due to its wet climatic conditions and
steep terrain (Sidle et al. 2006; Sidle & Zeigler 2012). Deposition of eroded soil into rivers at an
increased rate is responsible for increasing turbidity and temperature of the
water, reducing the amount of dissolved oxygen and changing existing flow
regimes, while accelerating eutrophication (Beevers et al. 2012; Douven &
Buurman 2013). The proposed clearing of
land for the development of the road is likely to make cut sections highly
susceptible to soil erosion. Drainage
structures and culverts are essential to allow better above-ground water
drainage, and prevent drastic changes to the hydrology of the landscape and
decrease flooding along the road during monsoon seasons (Sidle et al. 2006;
Laurance et al. 2009). No site-specific
hydrological survey has been carried out to arrive at the optimal number of
culverts and bridges, and their spatial placement.
v)
Although the Road Report aims to reduce the impact of the developmental project
in the “direct path” of the roadworks, it is pertinent to understand that the
impacts of road construction are rarely limited to the direct path. Environmental impacts of roads extend beyond
the direct impacts of construction and tree clearing, to indirect impacts
because of increased human access and vehicular traffic. This includes, but is not limited to, air,
water, and noise pollution, disturbance effects, fragmentation due to edge
effects, and hindrances to migratory corridors (Alamgir et al. 2017).
6.2 THE IMPACT OF ROADS
We
further expand on biotic and abiotic impacts of roads here, for which no
mitigation measures have been suggested.
i)
Roads compound the impacts of natural disasters
Constructing roads in
hilly and mountainous terrain increases the risk of natural disasters such as
landslides and flooding (Sidle et al. 2006; Larsen & Torres-Sánchez 1997;
Larsen & Parks 1998). There is no
information on the susceptibility of the proposed site to extreme weather
events in the EIA. Such dissemination of
information regarding the socio-economic and environmental risks involved in
the project is critical to the decision of investors, decision-makers and
taxpayers, whose money is being utilized for the project. Road projects that pass through forested
areas and lack proper planning can lead to major cost overruns, corruption, and
damage to the environment (Trombulak & Frissell 2000; Alamgir et al. 2017)
ii)
Roads are a cause for wildlife mortality (roadkills)
Enabled by the expansion of
the highway, an increase in vehicular traffic in the area can be expected. This will likely increase the rates of
wildlife-vehicle collisions, impacting species of most terrestrial fauna. A study from Mudumalai Tiger Reserve found
road mortality of 40 animal species, including amphibians, reptiles, birds, and
mammals (Baskaran & Boominathan 2010).
Additionally, animals that are slow-moving or burrowing, such as
freshwater turtles, amphibians, snakes, and soil-living fauna, get killed
during road construction. The impacts of
earthwork and annual maintenance operations on terrestrial fauna are usually
overlooked (Clevenger et al. 2003; Fahrig et al. 1995; Trombulak & Frissell
2000; Goosem et al. 2010).
iii)
Roads are barriers to wildlife movement, and cause habitat fragmentation
For many species,
particularly in the Western Ghats, the expansion of the NH-4A is an additional
fragmentation of an already fragmented habitat (Nayak et al. 2020). The resistance to potential large mammal
movement posed by the existing NH-4A is higher than the median resistance to
mammal movement in the Western Ghats (Jayadevan et al. 2020;
https://indiaunderconstruction.com).
Expansion of the road can, thus, lead to an increase in the resistance
posed to movement, and lead to increased isolation between forest patches on
either side of the road.
Subdivision of remnant
forest patches due to various linear intrusions such as highways and roads
causes “internal fragmentation” (Goosem 1997; Goosem 2007). Such internal fragmentation with wide,
cleared roads and their edges, physical barriers such as fences and crash
barriers, cuttings, fill batters, and culverts with drop structures, could be a
serious threat to movement of wildlife and lead to increased negative
human-wildlife interactions (Goosem et al. 2010). For example, many animals in tropical forests
avoid even narrow linear clearings (< 30m wide; Holderegger & Di Giulio
2010; Laurance et al. 2009). Increased
traffic and continuous vehicular movement can stress the animals or make
species alter their behaviour in the vicinity of roads (Trombulak &
Frissell 2000). While certain species
such as macaques are attracted to roads for scrap food from travellers (a
potential ecological trap), species such as Elephants have been observed to
avoid roads and highways due to associated risks, or suffer mortality from
collisions (Blake et al. 2008).
Behavioural avoidance of the road may also be exhibited by animals that
can fly over the width of the road (e.g., birds and bats), due to the noise,
pollution, and risk of crossing (Laurance et al. 2009).
The problem of
fragmentation by roads is particularly acute for canopy dwelling species that
use closed-canopy structures to move and do not generally use the ground to
cross. In the absence of tree cover,
tree-dwelling animals are forced to either use the ground or cross using power
lines, which can lead to mortality due to vehicular collisions or
electrocution. This is especially the
case for primates, arboreal rodents, and some carnivores (Radhakrishna &
Singh 2002; Raman 2011).
iv)
Roads affect the genetic diversity of animals
Decreased movement of
animals across roads leads to decreased genetic variation, due to reduced
genetic exchange between populations.
For example, studies from India show that roads negatively affect tiger
connectivity (Joshi et al. 2013; Dutta et al. 2018; Thatte et al. 2018). Such impacts can be seen after just a few
generations in populations of large mammals that have been separated by newly
built roads and highways (Holderegger & Di Giulio 2010).
v)
Roads affect biodiversity due to increased noise pollution
Although monitoring of
noise quality levels created by the existing highway was carried out at eight
sites designated as commercial, industrial and residential, there was no
monitoring carried out on existing highway stretches within the protected
area. Noise quality levels were found to
be “within the limits” for commercial and industrial categories but “exceed the
limits” in the residential category. Noise pollution associated with roads has been
shown to decrease reproductive capacity in bird and amphibian species, as well
as in mammals such as Tigers (Kerley et al. 2002; Hoskin & Goosem 2010; Qin
et al. 2014; Laurance 2015), with impacts seen at the community level as well
(Francis et al. 2009; Slabbekoorn & Halfwerk 2009).
vi)
Roads lead to increased human accessibility
Roads passing through
forested areas increase human accessibility and can increase movement,
settlement and human activity in frontier forest areas. This has manifold repercussions including
forest fires, waste disposal and pollution, illegal timber harvest, poaching
and hunting (Alamgir et al. 2017). Studies
from protected areas in developing economies show that road expansion and
improved accessibility to the market can result in expansion of agricultural
and livestock frontiers with reduction in nearby forest areas of the protected
area (Ratner et al. 2007; Lama & Job 2014; Phaipasith & Castella 2017;
Walelign et al. 2019). Conversion from
subsistence agriculture to cash crops, emergence of commercial service
economies such as mass tourism resulted in transition from a low-impact economy
to a high-impact one (Walelign et al. 2019).
Local socio-economic inequality also increased after road-expansion
(Ratner et al. 2007). In the long run,
the negative impact on the forest, waste generation and excessive use of
agro-chemicals resulted in lesser availability of clean water, reduced soil
fertility and local extinction of NTFP species (Phaipasith & Castella
2017). This also affected local
governance systems negatively and people often could not revert to their
subsistence economies which were relatively sustainable (Lama & Job 2014).
vii)
Roads as a cause for habitat loss and degradation
During the construction
and maintenance of roads and highways, habitat loss and degradation is observed
due to direct clearing of vegetation, dumping of excavated earth and materials,
regular usage of access roads by heavy machinery, and construction of labour
camps. Within tropical forests,
disturbance from roads due to fluctuations in light, temperature and humidity,
increased mortality of trees beside roads, and spread of exotic species to a
width of least 100m from the road (Laurance et al. 2009). Thus, “each kilometre of road directly and
detrimentally affects at least 10 ha of habitat”, and the impacts may persist
for decades (Laurance et al. 2009; Raman 2011).
viii)
Roads as corridors for invasive species
Roads have been found to
be a major factor in the spread of invasive flora and fauna into forests
(Mortensen et al. 2009; Meunier & Lavoie 2012). These invasive species can use the edge
habitats along the road and invade forests by secondary wind dispersal, that
would have otherwise been inaccessible (Kowarik & von der Lippe 2011).
6.3
THE IMPACT OF RAILWAY-LINE DOUBLING AND INADEQUACY OF MITIGATION
i)
Air quality
No potential impacts on
air quality were studied, as the railway line between Castlerock and Kulem was
assumed to be electric. If the trains in
the proposed stretches run on traditional diesel engines, increased locomotive
traffic due to the doubling of the railway line will lead to an increase in
harmful exhaust components. The main
pollutants from diesel locomotives are Carbon Dioxide (CO2), Carbon Monoxide
(CO), Sulphur Dioxide (SO2), Nitrous Oxide (N2O), particulate matter (PM),
hydrocarbons (HC), among others. Many of
these pollutants are carcinogenic and responsible for health and environmental
impacts (Lucas et al. 2017).
The report suggests
monitoring of air quality and minimizing air pollution due to dust particles,
vehicular and locomotive emissions, during the construction and operational
phase. Although necessary, such general
recommendations on controlling impacts on air quality during the construction
phase will minimally help in reducing pollution as the project will take three
years to construct and the operational impacts will be near permanent. Abrasion of brakes, wheels, dust, mineral
transport will all still produce PM emissions even if electric locomotives are
used (Levengood et al. 2015). No amount
of mitigation will compensate for the long-term impacts of air pollution due to
the proposed expansion.
ii)
Sound (Noise pollution)
The noise levels at various
regions within the areas of the proposed project were already noted to be above
the permissible level of 91dB, posing a serious threat from noise
pollution. Anthropogenic noise can
affect acoustic communication among bird species that use calls and songs for a
variety of functions such as attracting mates and defending territories
(Collins 2004; Marler 2004). Noise
emission from railways has also been documented to reduce the density and
nesting behaviour of birds, with nests that are farther away from railway lines
being more successful (Mundahl et al. 2013).
To reduce noise pollution,
the Railway Report recommends switching to electric engines, planting native
tree species along the railway line and building sound barriers on both sides
of the track, particularly within the biodiversity-rich Kali Tiger Reserve
(from Castlerock station – Goa border) and BMWS & NP. All of these three recommendations, however,
have serious drawbacks which the report has overlooked.
a. Switching to electric engines will not greatly reduce
noise pollution. This is because, at a
speed of 30–200 km/h (the speed at which most trains will be travelling between
stations), all trains, including the electric trains, produce a “rolling noise”
which is the dominant source of noise pollution (Clausen et al. 2012).
b. Recovering vegetation beside roads and railways is known
to attract wildlife and increase their vulnerability to get killed by moving
vehicles (Case 1978; Jaren et al. 1991; Putman 1997; Cain et al. 2003).
c. Sound barriers will further intensify the impacts of
forest fragmentation caused due to railways.
While the size and structure of sound barriers are not mentioned in the
report, they are usually artificially built, vertical walls of a solid
structure, which blocks the noise created by moving trains. While this could be a reasonable mitigation
measure for railway lines that pass through human habitat, it will have
detrimental ecological impacts inside a forest ecosystem. Sound barriers can cause various negative
impacts on wildlife, particularly through isolation of populations (Bank et al.
2002). Given that the minimum height of
such barriers is as high as the train, and with electric lines proposed to be
running on top of the railway, it would make it impossible for any terrestrial
species to freely move to the other side of the track and will be a death trap
for wildlife trapped between the barriers.
iii)
Water quality
The
Railway Report states that the current water quality in streams along existing
railway track is pristine (Bureau of Indian Standards 2012), but with harmful
levels of bacteria Escherichia coli in all streams (221 to 542 per
100mL), it indicates widespread faecal contamination of waterbodies mostly due
to exisiting train traffic (threshold is 100 per 100mL). Creation of new railway embankments for the
proposed double gauging will further lead to vegetation loss, soil compression
and changes in water drainage, thus increasing runoff, promoting erosion of
topsoil and increasing water turbidity (Ferrell & Lautala 2010; Chen et al.
2015). Turbid water has been found to
affect the diversity and abundance of aquatic wildlife communities such as
odonates and freshwater fish (Luce & Mountain 2002).
The Railway Report
mentions that the new railway coaches will be fitted with bio-toilets, hence
reducing the likelihood of E. coli infiltrating streams along the
railway route. Construction of dykes and
retaining walls along the railway line to restrict the movement of sediments
during the construction phase has been recommended. While this may address sediment runoff, it
may indirectly inhibit animal movement, adding to the effects of tree clearing,
noise, and train movement.
iv)
Biodiversity
The major focus of the
studies appears to be to create baseline information on species diversity and
abundance, rather than to explicitly study the impact of the proposed expansion
on biodiversity. The Railway Report only
cursorily mentions that animal movement will be impacted by the doubling of the
railway line (Chapter 18, Page 207) and does not address long-term impacts to
landscape connectivity that all the taxa under study face from the proposed
expansion of the railway line. There is
strong evidence of the negative impacts of railway lines on biodiversity.
Railway lines have been
shown to be barriers to movement for large mammals such as the tiger (Dutta et
al. 2018). The current railway line
between Kulem and Castlerock poses a high degree of resistance to large mammal
movement (Jayadevan et al. 2020).
Doubling of the railway track will lead to a higher frequency of trains,
and further increase resistance to movement.
This can isolate the forest patches on either side of the railway
line. In addition to its impacts on
movement, noise and vibrations from railways affect insects, amphibians, and
birds. Further, the availability of food
(solid food waste; carcases of dead animals) and vegetation along the railway
edges attracts reptiles, few species of birds, and several mammals acting as an
ecological trap and leading to higher mortality due to collision with trains
(Lucas et al. 2017).
The mitigation measures
suggested in the Railway Report are very general. The suggestion of the creation of
‘biodiversity parks’ for conserving birds and mammals is not compensatory, when
the protected area, which is a biodiversity-rich region, will be
fragmented. For aquatic life, it is
suggested that railways should adopt the ‘best construction procedures’ to
reduce turbidity, siltation, etc., but what these procedures comprise of is
unexplained.
The Railway Report
highlights cases of Gaur and Sambar being hit by trains on the existing single
track, reaffirming that the doubling of the railway line will lead to increased
risk of accidental collisions with wildlife.
Although the report identifies 42 animal-crossing points for mammals, a
bare minimum of four animal underpasses are finalized at Ch 32/200, Ch 41/100,
Ch 45/500, Ch 49/500 (RVNL Letter No.PlU/UBLllLN654 dated 06.10.2018 to deputy
forest officer). The report suggests
many other mitigation measures to be followed (Pages 207–208), but such
mitigation measures are undetailed, and without strong supervision during
implementation have poor application in practice.
6.4
INADEQUATE MITIGATION MEASURES FOR THE TRANSMISSION LINE
i) On the subject of
mitigation measures for the transmission line, the inspection report of the
transmission line mentions only that “the user agency has agreed to cut minimum
trees requirements and to adopt wildlife-friendly mitigation measures.” It adds that “trees listed for felling under
this project will be compensated in the long term through the proposed
compensatory afforestation programme covering double the degraded forest land.” It is not clear how ‘minimum tree cutting’
will be calculated or enforced. No
details are provided on where and when the compensatory afforestation will be
executed. Further, without an impact
assessment of the transmission line, it is not clear what ‘wildlife-friendly
mitigation measures’ will be implemented.
ii) The inspection report
fails to take into account the ecological impacts of the transmission line as
we have detailed in this paper (Section 5).
A background paper for the National Board for Wildlife (Raman 2011)
recommends that the first priority for power lines in forests should be
prevention, followed by re-alignment.
The third option of a mitigation measure is suggested only where the
first two have been comprehensively considered and ruled out with sufficient
justification (Raman 2011). In case a
transmission line passes through a biodiverse region, recommended mitigation
measures for transmission lines include insulators on wires to avoid bird
electrocution, placing of perch deterrents on cross-arms and poles and using
large line-markers on earth wires to increase their visibility during the day
and night, thus avoiding collisions by birds and volant mammals (WII
2016). But neither of these are
considered as mitigation measures for this project.
7.
CONCLUSION
Any major infrastructure
projects should be avoided within PAs, unless there are exceptional
circumstances that will clearly show forest diversion will benefit wildlife (as
per the WPA, 1972). Utmost importance
should be given to all environmental and ecological impacts of any project, and
as per the background paper of the National Board for Wildlife itself,
ecologically-harmful projects should be avoided. In the present case, there is not one, but
three large projects which are planned in this ecologically-sensitive
region. It is noteworthy that the
Western Ghats is a designated Natural World Heritage Site by UNESCO. The cumulative impacts of these three
projects may change the entire ecology of the BWWS & NP, as well as the
neighbouring Kali Tiger Reserve, and will result in irreparable damage to its
fragile environment. Further, such
damage will impact the quality of human life within and near the PA. Multiple projects also call for an in-depth
investigation into cumulative impacts on the PA. Cumulative impact studies have been considered
mandatory in many countries (Braid et al. 1985), and are implemented rigorously
for their added value in understanding irreversible changes to existing natural
systems (Xue et al. 2004).
It is pertinent to note
that two of these projects (NH-4A and transmission line) were awarded wildlife
clearances in the 57th meeting of the Standing Committee of the
NBWL, held on 7 April 2020 through a video conference, which is unlikely to
have had critical evaluation. Our review
details how the EIAs and assessments for these projects are considerably weak,
and evidently overlooked by the highest statutory authority that is mandated to
protect wildlife in the country.
Socially- and environmentally-just development is important, but none of
these projects provide any benefit to wildlife or the environment in the BMWS
& NP. Environmental costs and
mitigation measures are not comprehensively assessed in the EIAs and assessment
studies. Information on the land area
for compensation, overseeing agencies for mitigation measures, monitoring and
penalties for non-compliance are also not laid out in detail.
Faulty EIAs and other
assessment studies continue to be condoned by successive appraisal boards and
governments, with a lack of due process.
Such practices consider environmental concerns as a burden on
development, rather than a process that guides sustainable development, which
should, therefore, be strengthened. This
further weakens socio-ecological governance in a country which is ranked a 168
(out of 180 countries) in the Environmental Performance Index (Wendling et al.
2020). Considerable opportunities exist
to improve the EIA and assessment process in India (Paliwal 2006). Incentivising post-clearance monitoring and
evaluation is vital (Duflo et al. 2013); however, a rational screening process
which fortifies existing legislation and avoids forest diversion proposals in
protected areas at the outset itself is most necessary (Rajaram & Das
2011).
For figure
& images - - click here
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Appendix
I. Checklist of birds in Bhagwan Mahavir Sanctuary and National Park.
The
List is compiled from data available on eBird (2017) from multiple hotspots and
checklist locations within BMWS NP and Rahmani et al. (2016).
ENDEMISM
TO WG (WESTERN GHATS): Species, whose global distribution range is restricted
to within the biogeographical boundaries of the Western Ghats. In other words,
they are unique to Western Ghats, and are not found anywhere else in the world.
IUCN:
Evaluation of species as per IUCN Redlist 2020-1 CR: Critically Endangered; EN:
Endangered; VU: Vulnerable; NT: Near Threatened
WPA
(1972): Species listed and protected under five different categories (Schedule
I to IV, and VI) in accordance to the Wildlife Protection Act of 1972
STATUS:
Evaluation of migratory status of a species. R: Resident; M: Migrant; LM: Local
Migrant, making short movements out of the political boundaries of Goa; R/M:
Resident population supplemented by a migratory population; VG: Vagrant
migrants recorded away from their known migratory range; S: Residents of the
Indian Subcontinent with no known resident populations in Goa attributed to as
stray; UC: Unclear
RARITY: A species that has less
than ten independently confirmed records form within the political boundaries
of Goa, post 2000.
|
|
Species |
Endemism
to WG |
IUCN |
WLPA
(1972) |
Status |
Rarity |
|
|
I.
Anseriformes |
|
|
|
|
|
|
|
1. Anatidae (Ducks, geese,
swans) |
|
|
|
|
|
|
1 |
Lesser Whistling Duck Dendrocygna
javanica |
|
|
4 |
R |
|
|
|
II.Galliformes |
|
|
|
|
|
|
|
2. Phasianidae (partridges,
pheasants, grouse) |
|
|
|
|
|
|
2 |
Indian Peafowl Pavo cristatus |
|
|
1 |
R |
|
|
3 |
Jungle Bush Quail Perdicula
asiatica |
|
|
4 |
R |
|
|
4 |
Grey Junglefowl Gallus
sonneratii |
|
|
2 |
R |
|
|
5 |
Red Spurfowl Galloperdix
spadicea |
|
|
4 |
R |
|
|
|
III.
Columbiformes |
|
|
|
|
|
|
|
3. Columbidae (pigeons) |
|
|
|
|
|
|
6 |
Rock Pigeon Columba livia |
|
|
4 |
R |
|
|
7 |
Nilgiri Wood Pigeon Columba
elphinstonii |
|
VU |
4 |
R |
|
|
8 |
Oriental Turtle Dove Streptopelia
orientalis |
|
|
4 |
R |
|
|
9 |
(Western) Spotted Dove Streptopelia
chinensis suratensis |
|
|
4 |
R |
|
|
10 |
Orange-breasted Green Pigeon Treron
bicinctus |
|
|
4 |
R |
|
|
11 |
Grey-fronted Green Pigeon Treron
affinis |
|
|
4 |
R |
|
|
12 |
Asian Emerald Dove Chalcophaps
indica |
|
|
4 |
R |
|
|
13 |
Green Imperial Pigeon Ducula
aenea |
|
|
4 |
R |
|
|
14 |
Mountain Imperial Pigeon
(Nilgiri Imperial Pigeon) Ducula badia cuprea |
|
|
4 |
R |
|
|
|
IV.
Caprimulgiformes |
|
|
|
|
|
|
|
4. Podargidae (frogmouths) |
|
|
|
|
|
|
15 |
Sri Lanka Frogmouth Batrachostomus
moniliger |
|
|
1 |
R |
|
|
|
5. Caprimulgidae (nightjars) |
|
|
|
|
|
|
16 |
Jungle Nightjar Caprimulgus
indicus |
|
|
4 |
R |
|
|
17 |
Jerdon's Nightjar Caprimulgus
atripennis |
|
|
4 |
R |
|
|
18 |
Indian Nightjar Caprimulgus
asiaticus |
|
|
4 |
R |
X |
|
19 |
Savanna Nightjar Caprimulgus
affinis |
|
|
4 |
R |
|
|
|
6. Hemiprocnidae (Treeswifts) |
|
|
|
|
|
|
20 |
Crested Treeswift Hemiprocne
coronata |
|
|
|
R |
|
|
|
7. Apodidae (swifts) |
|
|
|
|
|
|
21 |
White-rumped Spinetail Zoonavena
sylvatica |
|
|
|
R |
|
|
22 |
Brown-backed Needletail Hirundapus
giganteus |
|
|
|
R |
|
|
23 |
Indian Swiftlet Aerodramus
unicolor |
|
|
1 |
R |
|
|
24 |
Asian Palm Swift Cypsiurus
balasiensis |
|
|
|
LM |
|
|
25 |
Alpine Swift Tachymarptis
melba |
|
|
|
R |
|
|
26 |
Indian House Swift Apus
affinis |
|
|
|
R |
|
|
27 |
Common Swift Apus apus |
|
|
|
M |
X |
|
|
V.
Cuculiformes |
|
|
|
|
|
|
|
8. Cuculidae (cuckoos) |
|
|
|
|
|
|
28 |
Greater Coucal Centropus
sinensis |
|
|
4 |
R |
|
|
29 |
Blue-faced Malkoha Phaenicophaeus
viridirostris |
|
|
4 |
R |
|
|
30 |
Pied Cuckoo Clamator
jacobinus |
|
|
4 |
R/M |
|
|
31 |
Asian Koel Eudynamys
scolopaceus |
|
|
4 |
R |
|
|
32 |
Banded Bay Cuckoo Cacomantis
sonneratii |
|
|
4 |
R |
|
|
33 |
Grey-bellied Cuckoo Cacomantis
passerinus |
|
|
4 |
R |
|
|
34 |
Fork-tailed Drongo Cuckoo Surniculus
dicruroides |
|
|
4 |
R |
|
|
35 |
Large Hawk Cuckoo Hierococcyx
sparverioides |
|
|
4 |
M |
X |
|
36 |
Common Hawk Cuckoo Hierococcyx
varius |
|
|
4 |
R |
|
|
37 |
Indian Cuckoo Cuculus
micropterus |
|
|
4 |
M |
X |
|
38 |
Common Cuckoo Cuculus canorus |
|
|
4 |
M |
|
|
|
VI.
Gruiformes |
|
|
|
|
|
|
|
9. Rallidae (rails and coots) |
|
|
|
|
|
|
39 |
Slaty-legged Crake Rallina
eurizonoides |
|
|
4 |
M |
|
|
40 |
White-breasted Waterhen Amaurornis
phoenicurus |
|
|
4 |
R |
|
|
41 |
Purple Swamphen Porphyrio
porphyrio |
|
|
4 |
R |
|
|
|
VII.
Ciconiiformes |
|
|
|
|
|
|
|
10. Ciconiidae (storks) |
|
|
|
|
|
|
42 |
Lesser Adjutant Leptoptilos
javanicus |
|
VU |
4 |
R |
|
|
43 |
Asian Openbill Anastomus
oscitans |
|
|
4 |
R |
|
|
44 |
Black Stork Ciconia nigra |
|
|
4 |
M |
X |
|
45 |
Woolly-necked Stork Ciconia
episcopus |
|
VU |
4 |
R |
|
|
|
11. Ardeidae (herons) |
|
|
|
|
|
|
46 |
Malayan Night Heron Gorsachius
melanolophus |
|
|
4 |
R |
|
|
47 |
Striated Heron Butorides
striata |
|
|
4 |
R |
|
|
48 |
Indian Pond Heron Ardeola
grayii |
|
|
4 |
R |
|
|
49 |
(Eastern) Cattle Egret Bubulcus
ibis coromandus |
|
|
4 |
R |
|
|
50 |
Grey Heron Ardea cinerea |
|
|
4 |
R/M |
|
|
51 |
Purple Heron Ardea purpurea |
|
|
4 |
R |
|
|
52 |
(Eastern) Great Egret Ardea
alba modesta |
|
|
4 |
R |
|
|
53 |
Intermediate Egret Ardea
intermedia |
|
|
4 |
R |
|
|
54 |
Little Egret Egretta garzetta |
|
|
4 |
R |
|
|
55 |
Western Reef Egret Egretta
gularis |
|
|
4 |
R |
|
|
|
12. Threskiornithidae (ibises) |
|
|
|
|
|
|
56 |
Black-headed Ibis Threskiornis
melanocephalus |
|
NT |
4 |
R/M |
|
|
|
VIII.
Suliformes |
|
|
|
|
|
|
|
13. Phalacrocoracidae
(cormorants) |
|
|
|
|
|
|
57 |
Little Cormorant Microcarbo
niger |
|
|
4 |
R |
|
|
58 |
Indian Cormorant Phalacrocorax
fuscicollis |
|
|
4 |
R |
|
|
|
14. Anhingidae (darters) |
|
|
|
|
|
|
59 |
Oriental Darter Anhinga
melanogaster |
|
NT |
4 |
R |
|
|
|
IX.
Charadriiformes |
|
|
|
|
|
|
|
15. Recurvirostridae (stilts and
avocets) |
|
|
|
|
|
|
60 |
Black-winged Stilt Himantopus
himantopus |
|
|
4 |
M |
|
|
|
16. Charadriidae (plovers &
lapwings) |
|
|
|
|
|
|
61 |
Little Ringed Plover Charadrius
dubius |
|
|
4 |
R |
|
|
62 |
Yellow-wattled Lapwing Vanellus
malabaricus |
|
|
4 |
R |
|
|
63 |
Red-wattled Lapwing Vanellus
indicus |
|
|
4 |
R |
|
|
|
17. Jacanidae (jacanas) |
|
|
|
|
|
|
64 |
Bronze-winged Jacana Metopidius
indicus |
|
|
4 |
R |
|
|
|
18. Scolopacidae (sandpipers) |
|
|
|
|
|
|
65 |
Common Snipe Gallinago
gallinago |
|
|
4 |
M |
|
|
66 |
Common Sandpiper Actitis
hypoleucos |
|
|
4 |
LM |
|
|
67 |
Green Sandpiper Tringa
ochropus |
|
|
4 |
M |
|
|
|
19. Turnicidae (buttonquails) |
|
|
|
|
|
|
68 |
Barred Buttonquail Turnix
suscitator |
|
|
4 |
R |
|
|
|
20. Glareolidae (coursers and
pratincoles) |
|
|
|
|
|
|
69 |
Little Pratincole Glareola
lactea |
|
|
|
M |
|
|
|
21. Laridae (gulls and terns) |
|
|
|
|
|
|
70 |
Gull-billed Tern Gelochelidon
nilotica |
|
|
4 |
R |
|
|
71 |
River Tern Sterna aurantia |
|
NT |
4 |
R |
|
|
|
X.
Accipitriformes |
|
|
|
|
|
|
|
22. Accipitridae (kites, hawks
and eagles) |
|
|
|
|
|
|
72 |
Black-winged Kite Elanus
caeruleus |
|
|
1 |
M |
|
|
73 |
Oriental Honey Buzzard Pernis
ptilorhynchus |
|
|
1 |
R |
|
|
74 |
Egyptian Vulture Neophron
percnopterus § |
|
EN |
1 |
S |
X |
|
75 |
Crested Serpent Eagle Spilornis
cheela |
|
|
1 |
R |
|
|
76 |
Short-toed Snake Eagle Circaetus
gallicus |
|
|
1 |
S |
|
|
77 |
White-rumped Vulture Gyps
bengalensis |
|
CR |
1 |
S |
X |
|
78 |
Indian Vulture Gyps indicus |
|
CR |
1 |
S |
X |
|
79 |
Mountain Hawk Eagle (Legge's
Hawk Eagle) Nisaetus nipalensis kelaarti |
|
|
1 |
R |
X |
|
80 |
Changeable Hawk Eagle (Crested
Hawk Eagle) Nisaetus cirrhatus cirrhatus |
|
|
1 |
R |
|
|
81 |
Rufous-bellied Eagle Lophotriorchis
kienerii |
|
|
1 |
R |