I vividly recall the anxiety in the conversation with small fish traders from Gandhidham and fishing community representatives in Tuna, as we sat on a boat together, discussing what a partnership between the Kandla Port Trust (KPT) and the Adani Group could mean for the area. It was April 2012, and news of their agreement had been floating around in the area with not many concrete details in hand.

"Go see the area, sister. God knows what will become of it in the future. The place is full of birds, mangroves and of course our brothers and sisters fishing in the area. Many of them live deep inside the inter-tidal area on stilts and earn their living through fishing," said Ayub Haji Manjalia, a local fish trader and a member of the Machhimar Adhikar Sangharsh Sangathan (MASS), a trade union working in the area, just before we set out in the boat.

We had to wait till the tide brought the water in to this vast inter-tidal area running across kilometres. The fishing boat could not be launched into the area otherwise, and would have got stuck in the mud flats minus the tidal water. Khamisa Ali Buchad, a resident fisherman from Tuna with us on the boat spoke proudly about the socio-ecological landscape we were about to witness.

Khamisa Bhai as everyone referred to him, pointed to the small artisanal fishing boats, nestled between the temporary fishing shelters on one side and the flock of flamingoes on the other. And then, as if all of a sudden, all conversation came to a stand still. Far at a distance, was the overpowering silhouette of a large container ship waiting to set course into Tuna.

All this came back in a flash, just recently. 18 December 2013 saw the public hearing on development of integrated facilities within the existing Kandla port at Tuna. Such a public hearing is mandatory as per the Environment Impact Assessment (EIA) notification, 2006. But the Gujarat Pollution Control Board (GPCB) and the district administration had fixed the venue: Near Nakti Bridge on Tuna-Kandla Road (link), an area served by minimal public transport. It was also fixed during the peak fishing season and at a time of the day when most fisherfolk are out earning their daily livelihoods.

Important to this context is KPT's existing agreement with the Adani group and their current bid to take on Kandla's expansion, which is pending decision at this point of time. The website of the Adani Group affirms that they have been entrusted with the task of developing the dry bulk cargo handling terminal in Tuna in Gandhidham block of Kutch district (near the existing Kandla port) in Gujarat (link). It further highlights that the Kandla Port Trust (KPT) has signed an agreement with the Adani Port & Special Economic Zone Limited (APSEZ Ltd) in February 2012 on a Build, Operate and Transfer (BOT) basis.

The EIA report casually mentions that marine impact assessment can be done post facto, without setting out any time lines, or even indicating if the assessment will form the basis of any decision on the project.

 •  Different reef, same barrier
 •  Women warriors of the sea According to the Adani Group's statement, KPT has done this for "logistics support required for deep draft berth in terms of backup space, railway tracks, road, etc.". This is touted to be the largest bulk terminal in the west coast of India, and will be able to reduce cargo-handling cost at Kandla Port "due to increased productivity and proximity to cargo generating centers."

In addition to this, APSEZ is one of only two groups to have submitted initial bids to the KPT for developing a container loading facility at Tuna-Tekra, which is predicted to be successful. Business dailies have quoted the current Chairman of KPT saying that the biggest competitor of this public sector port is the Adani group which has developed the Mundra port just sixty kilometres from Kandla (link)

Inadequate impact assessment

An Integrated EIA report was drawn up by Delhi-based Mantec Consultants Private Limited to collectively assess impact and suggest mitigation measures for nine sub-projects listed as part of this development plan. The "integrated" report includes development of:

• two barge jetties at Tuna and Khori creeks,
• oil jetty to handle liquid cargo at Old Kandla,
• upgradation of barge handling capacity at Bunder Basin,
• a railway line from NH 8A to Tuna Port,
• a multipurpose cargo terminal at Tekra off Tuna,
• construction of rail over-bridge at NH 8A near Nakti Bridge,
• mechanization of dry cargo handling facility at Kandla Port (Berth 7 & 8)
• ship repair/ building facilities, container terminal on a BOT basis and
• strengthening of two oil jetties.

These constructions will admittedly ease pressure on the existing berths and increase the capacity of dry and liquid cargo handling. However, this Integrated EIA report also informed its readers that the current document available to the public does not include a study of the marine environment and hence no assessment of impact thereupon. This, said the report, can only be evolved based on a list of six additional studies related to tides, currents, flora/fauna, water quality, circulation and so on.

What this means is that an integrated project involving large land-use change and impacting thousands of livelihoods in an inter-tidal area, has no marine impact assessment. The EIA report casually mentions that this can be done post facto, without setting out any time lines or even indicating that the assessment will be shared with affected people or will form the basis of any decision on the project.

What is also interesting is that the content and design of this EIA report was in violation of a 2010 circular of the Ministry of Environment and Forests (MoEF). The MoEF report dated 24 December 2010 states that for integrated projects such as the one in question, a combined EIA should be done of the entire project along with impact assessed for each of the individual components. The circular also says that the EIA has to be prepared for each of the individual components and the respective Expert Appraisal Committees (EACs) located within the MoEF has to consider the same.

Mantec's EIA report fell grossly short of this requirement and presented what they call "the most probable impacts of various components". The EIA report does not contain the impact assessment of the individual components as required and whatever is there has been done in a piecemeal manner.

All this and much more has been brought to the notice of the Gujarat Pollution Control Board (GPCB), the Ministry of Environment and Forests (MoEF) and the district authorities by the Mundra Hit Rakshak Manch (MHRM - Forum for the Protection of Rights in Mundra). They demanded the disqualification of the present EIA report and cancellation of the public hearing on various grounds. The letter was signed by Bharat Patel, (MASS), Kiritsinh Jadeja (member, MHRM) and Ayub Haji Manjalia (a leader of the fisherworkers and small fish trader).

The MHRM is an informal collective of villagers impacted by large-scale land use change due to large-scale industrial expansion in the neighbouring Mundra region, which has seen similar transformations over the last decade and a half. Members of the Manch had finalised a community-led ground truthing report highlighting violations by the Adani group related to their Waterfront Development Project in Mundra taluka of Kutch district. They had formally submitted these findings in October 2012 to the MoEF's Sunita Narain Committee set up to investigate violations by the Adani group in Mundra in September 2012.

The MHRM's letter brings out several other lacunae in the EIA report and also the validity of the EIA consultant to actually carry out the assessment, as they are accredited to do EIAs only for jetties and railway lines related to this project, and no other components. The letter also brings out that the EIA report is not in tune with the Terms of Reference (ToR) issued by the MoEF and has not presented alternative sites, which is also a mandatory requirement as per the EIA notification.

While highlighting that the Gulf of Kutch has been recognized as a Critically Vulnerable Coastal Area (CVCA) in the Coastal Regulation Zone Notification, 2011 (also issued by MoEF), the letter sought to bring out the range of socio-economic impacts that the integrated components will cause. Further, an incomplete EIA deliberately does not do justice to these extremely critical impacts.

The EIA report, say the Manch members, completely fails to understand the range of ecosystem-based livelihoods in the area. The letter highlights that the area has nine traditional fishing harbours on which approximately 10,000 people of the fishing community depend on. Further, there are over 37 functional saltpans in the area. The pastoral community (maldharis) who are predominant in the project-affected area and traditional potters who source clay from the Tuna region are completely missing in the EIA report.

Much might get lost in the legalese of procedure and the maladies of EIA science. But everyone who knows Mundra understands what will become of Tuna if these projects are allowed to sail through. If you don't already, it will definitely be worth witnessing the contrast in person. Pragmatists will say people of the area don't stand a chance. After all, one is dealing with one of the biggest conglomerates in India which is going strong having recently received an environmental nod for their Abbot Point in Queensland (Australia) as well.

I hope the odds work against that logic this time around.