Does Tourism need to be within the EIA?
- Stella James and Nayana Udayashankar*
To many of us, travel has become an important part of our lives. With bike trips in the Himalayas to discover oneself, luxury cruises to escape the monotony of daily lives, adventuring, honeymooning, and bachelorette trips, young people in India have taken travel to the next level. Popular culture has honed and hyped the potential for travel to build and rebuild relationships, explore creativity and excitement, and sometimes escape difficult experiences. But unlike what is oft portrayed, travel does not solely impact the traveller.
Travel, and tourism in particular, is a structural socio-cultural and economic phenomenon. It is introduced into, and impacts, the lives and livelihoods of local communities in the “destination”. Further, it brings about several changes to the local environment. The development of tourism can have both positive and negative ramifications. It has the potential to contribute directly to the economy by increasing government revenues, generating employment and demand for goods, and bringing in foreign exchange. On the other hand, it can also produce a multitude of adverse effects on the social, cultural and economic fabric of the landscape, and even have a severe impact on the ecology of the area.
Tourism is heavily dependent on several supporting industries, and one of the primary ones in this regard is construction. The construction of accommodation units and eateries, of parking lots and public amenities for tourists is indispensable for the promotion of the sector. Tourism also relies on transportation infrastructure, roads and railways, and the provision of “last mile connectivity”. Apart from these physical changes that have the potential to alter the landscape, it is also important to assess the impact of tourist visitation.
Tourism has the potential to completely alter the physical, ecological and social environment of a place. Tourists consume on average 5-10 times the water that residents use, are responsible for a significant amount of garbage and waste, as well as for plastic pollution.
The severe ecological and social impact on different places due to tourism has been well documented. In Goa, the popular beach capital of India, the inequality over sharing of water resources means that households get only limited water supply, while hotels have no such restrictions. Places like Mahabaleshwar and Kodaikanal have tourist numbers that far exceed the population. Shimla faces a water shortage situation every year, which got particularly acute in 2018. The destruction and loss of lives due to the massive floods in Uttarakhand in 2013 has largely been attributed to unplanned constructions of roads, hotels, shops and multi-storey housing in the fragile mountain slopes. Despite this, tourism has largely been kept out of the Environment Impact Assessment (‘EIA’) framework in India.
In the first part of this series, we looked at the EIA framework itself and some of the issues with it. In the second part of this series, we outline the environmental impact assessment that is currently being carried out with respect to the tourism sector, and critically analyse the gaps within the same.
I. Is the EIA doing enough for tourism impacts?
The original EIA notification of 1994 included tourism in its mandate, requiring that all tourism projects within two hundred – five hundred metres of the high tide line (along the coast) or those that were at an elevation of more than one thousand meters with an investment of more than Rs. 5 crores needed an environmental clearance. This covered a large gamut of coastal and mountain tourism. Though insufficient, the 1994 notification still provided for some measure of the environmental impact as a result of tourism. This was the period when tourism was seeing an upward trend in India. In spite of the growing evidence of unregulated and unplanned tourism, the industry of tourism was completely dropped from the subsequent EIA notification of 2005.
However, other industries like construction, highways/airports, roads and ropeways are connected to the tourism industry. Some of these projects are envisaged on a limited scale within the EIA. As highlighted in the sections ahead, even these are covered under the EIA only when they cross a certain area threshold or cost threshold. Moreover, even with a few allied industries covered, leaving out ‘tourism’ as an industry means that only the impact of these particular industries will be covered. This implies that larger tourism impacts like water and electricity usage, waste generation, biodiversity impacts, and social impacts are not considered.
In the next section, we illustrate with a few examples, how tourism and tourism-related projects that have major environmental and social impacts are not the subject of scrutiny under the Environment Impact Assessment Framework.
A. Construction for Tourism: Two wrongs make a right
The 1994 notification did not have a specific category for construction and building projects. It was introduced in the 2006 notification under the separate categories of “Building and Construction Projects” and “Township and Area Development Projects”, the difference between them being the extent of the built-up area and total area.
Even in the 2006 notification, these projects were only put in Category B, and therefore only required state-level clearance. In the latest notification, there have been further changes - the sub categories have been collapsed into one category of “Building Construction and Area Development Projects”. Additionally, projects with large area requirements have been moved into Category B2. This means that these projects no longer require an EIA report, public consultation and, in some cases, even an appraisal is not considered necessary. The table below enlists the same in detail.
Over the years, successive governments have been pushing for the development of mega tourism projects - huge land parcels which are developed for large tourism projects. Many of them are enclaved spaces for tourism with hotels, malls, markets, golf courses and other facilities built within the boundary. These projects are included under the categories of building and construction or township and area development projects.
A logical assumption would be that such a large project would be examined holistically and in a lot of detail, and the serious environmental impacts of such large projects would be considered in totality before giving such projects an environmental clearance. However, not only has their categorization under the EIA notifications been insufficient, but the monitoring and scrutiny of these projects has also been lax and ineffective.
Let us take the case of two such mega projects - Lavasa City in Maharashtra and the Shamukha Beach Tourism project in Odisha. Both of them are large tourism projects that take up acres of land in ecologically fragile landscapes.
B. Beach cities and EIA - Case of Shamukha and Lavasa
Samukha Beach Resort is a project proposed to be set up in coastal Odisha by the Department of Tourism and Culture, Government of Odisha. Located a few kilometers from the popular pilgrimage town of Puri, the beach tourism project is envisaged to be one large golf course surrounded on all sides by buildings such as hotels, housing, village, condonuims, shopping complexes etc.
Figure 2: Shamukha Beach Resort layout. Photograph taken by Shamukha (EMP Report)
Such a large project, with so many different components, is bound to bring many changes to the landscape. Furthermore, the proximity of the project to the sea also means that there will be a significant discharge directly into the ocean, polluting the ocean. Nevertheless, the project was started without any EC or the mandatory CRZ clearance. In 2015, the project was stopped by an interim order of the National Green Tribunal, but it was given post-facto clearance in April 2019.
About eighty-two thousand people along the coast of Odisha are expected to be affected by the project, of which fifteen thousand people will be directly affected by the land acquisition itself. Additionally, about 35% of the project area is covered with trees like casuarina, which are critical to protect coastlines. The project will likely cut many of these trees, but the exact figures have not been specified. For a project located along the east coast, which is extremely vulnerable to cyclones and had already resulted in the felling of several trees prior to obtaining the EIA, there are serious concerns about granting post-facto clearance. Many of these impacts were also visible in the case of Lavasa, that had a similar record.
Lavasa City is a large planned township built in Pune district, Maharashtra which was planned to attract tourists as well as residents. If completed, Lavasa would have occupied five thousand hectares along the edges of the Sahyadri mountains of the Western Ghats. The project was started without any EC from the central government, and attracted a lot of controversy. But in 2011, the Ministry of Environment and Forest gave a post-facto EC for the project.
The Lavasa project, however, has turned out to be an ecological disaster, and has also brazenly flouted numerous environmental norms. Despite clear conditions that disallowed the cutting of hills, the Sahyadri were callously cut for the township.
Figure 3: Hills cut to make roads in Lavasa that have caused landslides
Additionally, the waters of Warasgaon Lake, which run through Lavasa, were also dammed without the authorities seeking any permission or approval to provide for a continuous supply of water to the township.
Figure 4: A view of the Warasagaon lake and the vast expanse of Lavasa city
The construction of the mega township was also done at the cost of dispossession and displacement of several adivasi villages, who fought for their rights in court battles over a period of many years.
Both the Lavasa and the Samukha projects were commenced without environmental clearance and both were given post-facto clearance, even though the projects were clearly in violation of environmental norms. Under the 2020 notifications, this kind of post-facto clearance has been systematized.
Under Paragraph 22 of the 2020 notification, violations can be reported suo-moto by the project proponent or directly by authorities. But contrary to the principle upon which EIA has been formulated, the draft notification allows for regularisation of violations after payment of penalty. Projects with violations do not face the threat of closure or criminal charges. Instead, all the notification does is put a price tag on the violations.
II. Road Projects - Small roads, big impacts
Highways have been a matter of controversy for many years now, as environmental regulations continue to be diluted for them at many levels. Much of this dilution is done on the basis of claims that ‘linear projects’ like roads do not have serious ecological impacts on the landscape. However, even small road construction can lead to serious environmental impacts as has been shown by several experts, and even the World Bank.
In the original notification of 1994, tarred roads in the Himalayas, and in forest areas required clearance. This was changed in the 2006 notification, which restricted the requirement for EC to only highways, and then imposed specific restrictions on their length. In 2020, the provisions have been further diluted to increase the length thresholds.
In the tourism sector, there is a great focus on ‘last mile connectivity’; while highways may connect far off places, last mile connectivity ensures that tourists are able to travel to the remotest areas with ease. Many of these roads cover short distances, about 2-3kms, and may be narrow. But these roads are often built in ecologically and socially fragile areas, where the adverse effects of such projects being undertaken is highly accentuated. These small road projects also reduce transaction costs, and facilitate more tourist projects coming through in the area. Below are two small examples from our work of how roads, even across small stretches, can threaten both the ecological stability of an area and its social fabric.
A. Shifting sands of Dhanuskodi
Figure 5: Aerial view of Dhanuskodi. Photo courtesy: Wikimedia
Dhanuskodi is a thin strip of land near Rameswaram in Tamil Nadu. Until 1964, Dhanuskodi was a thriving town, but was completely destroyed in the aftermath of a massive cyclone. According to the members from the fishing community in the area, the survivors were relocated to other areas. But many of those belonging to the fishing community had their fishing grounds in and around this area, and have lived here for generations. As a result, in a few months, many of them returned to their old homes, setting up palm-roof huts and returning to fishing activities. In 2017, the National Highway No. 87, which went up to Dhanuskodi, was further extended till the end point, Arichal Munai, where the land meets the sea. The numerous objections raised by the locals, that the road would change the fragile shoreline dynamics, fell on deaf ears. Since the inauguration of the road, there have been several issues with sand and erosion leading to frequent closing off of the road.
Figure 6: Sand on the newly built highway is a frequent phenomenon
While some of the locals seemed happy about the road for its convenience to commute to and from Rameswaram when required, that has not reduced the increasing pressure on the fishing community to evacuate the area for further construction. Although there is no clear indication, the tourism officer has stated that since the road has already been constructed, further developments could be thought of. In his words, “Right now there are no facilities in Dhanuskodi. It is not suitable for habitation, so we cannot make resorts or anything in that area. But maybe we can plan for some restaurants and such for tourists.” Although the members of the fishing community in Dhanuskodi protested the order, and continue to live there at the moment, it remains to be seen whether there will be further, more successful attempts to evict them.
B. Cutting dunes in Kanyakumari
Another example of the adverse effects of ‘last mile connectivity’ road projects can be seen in Kanyakumari.
Buffeted by the ocean from all directions, Kanyakumari is extremely vulnerable, from an ecological standpoint. It was hit by Cyclone Ockhi in 2017, which killed eighty, and by the tsunami in 2004 that took a further eight hundred lives. However, a more systematic vulnerability that Kanyakumari faces is from shoreline changes. The coastal zone of Kanyakumari sees high erosion on one side, and accretion on the other, with research showing that the Kanyakumari coastline is one of the major erosion-prone coasts of India.
Kanyakumari is, of course, a renowned tourist destination, famous for its cape and for being at the tip of mainland India. Recently, under ‘last mile connectivity’, Rs. 2 crores have been spent on laying a road and a promenade that shorten the distance between two tourist spots - Triveni Sangam and Sunset Point.
Figure 7: Newly built promenade to sunset point
This road and promenade, only about 2.7 km in length, cuts across through the rocky beach and the vegetation-covered dunes right next to them.
Figure 8: Morning glory left in a very small part of the dune after the road
Experts point to the importance of sand dunes and plants like morning glory for coastal ecosystems, since they not only act as a filter, preventing salt-water intrusion into freshwater aquifers, but also function as barriers that protect the seashore.
By excluding such road projects in highly vulnerable areas from impact assessment and mitigation measures puts ecosystems and human lives at a tremendous and unacceptable risk.
III. Aerial Ropeways - Rethink ‘environment friendly’
In the last few years, state and central governments have been exploring the increased usage of ropeways, both for cargo transport as well as for tourism. Under the 2020 notification, provisions for ropeways have been severely diluted. In the 2006 notification, all ropeway projects were classified as Category B and those in sensitive areas as Category A. Under the 2020 notification, only ropeway projects in ecologically sensitive areas require any clearance and that too as Category B2 meaning that they do not require an EIA report, public consultation or Appraisal (see Part 1 for details on the different categories).
Despite the government portraying ropeways as an ‘environment friendly’ option, ropeways also present a number of threats to the environment. The Ministry itself identified several adverse effects of ropeways, such as soil erosion, wastewater generation etc. Down to Earth has pointed out the threat of a ropeway through Girnar Wildlife Sanctuary to the nesting of Girnar vultures, of which only sixty nine vultures are left.
Analysing the EIA reports undertaken for ropeways also illustrates the significant impact of ropeways on the environment clearly. For example, below are a few of the adverse effects underlined by the EIA report of a ropeway in Guwahati, in their own words:
● During the construction phase, wastewater shall be generated from labour activities on site. Wastewater generated would be characterized by high levels of BOD, SS, Nitrogen and E. Coli.
● During the operation phase, it is assumed that 80 % of the water supplied will be discharged as wastewater. Approximately 11.61 m3/day of wastewater will be generated.
● The major impact will be on mammals and birds whose breeding cycle depends upon light period. Their breeding cycle will get altered due to change in light period. (emphasis supplied by the authors)
Additionally, ropeways are rarely built in isolation, and are usually planned as a part of larger tourism projects. For example, a ropeway has been planned in the suburban area of Gorai in Mumbai. The area of Gorai is surrounded by dense mangroves, and is home to fishers and farmers. There are two important tourist points in Gorai - the Vipassana Pagoda, and the amusement park Essel World.
Several infrastructure projects have been planned in Gorai for many years, including bridges, jetties and now the ropeway.
Figure 9: A visual representation of ropeway connectivity between mainland Mumbai and Gorai. Image Courtesy: Vivek Rakotu EQUATIONS
While many of these plans in Gorai are currently in abeyance, the main reason for their recent inactivity has been the strong resistance to these projects by the communities in Gorai, Manori and Utthan. These communities have long held that any form of connectivity, through bridge or ropeway, will lead to the rapid increase in tourism, leaving their mangroves and their livelihoods completely destroyed.
While the ropeway itself may have a limited impact, it has the potential to become an important facilitator for other projects. Hence, as discussed in more detail in the next section, the impact of any project needs to be looked at in a more holistic manner.
IV. How should Tourism Impacts be measured?
One of the biggest criticisms of the current structure of environmental impact assessment is that it is done at an individual project level and not at a landscape level. That is, an environmental impact assessment is done each time a new project is proposed in an area and the impact is measured.
From the examples already mentioned, let us analyse the Recreational Tourism Development Zone in Gorai-Manori-Uttan in Maharashtra in greater detail. A development plan has been proposed and prepared by the MMRDA for developing the 8 villages in twelve hundred acres of land area into a tourism zone. The zone is expected to have tourist amenities and facilities such as wider roads, newer bridges and jetties, mangrove parks, and a series of hotels, restaurants and tourist activities along the beaches.
However, each of the individual pieces of this large development plan are expected to go through the EIA separately, i.e. the bridge, the ropeway, the jetty will all have separate ECs applied for. But while each of these projects may have a limited impact in and of themselves, the entire project as a whole will devastate the region. One of the biggest impacts would be the loss of mangroves, and the livelihoods of the members of the fishing community.
Figure 10: Mangroves surround the Gorai-Manori-Uttan area
Additionally, there is no way to know and assess the viability of a tourism zone against other environmental parameters such as water pollution, waste generation, noise, impacts on biodiversity etc - all of which is clearly observable from the increasing tourism footfalls.
In fact, in 2011, the MoEF&CC had also mulled over a proposal to suo-motu undertake EIA for projects coming up in eco-sensitive areas, as well as undertake cumulative impact assessments for areas that have multiple industrial units. Similarly, including tourism as a separate industry under the Schedule is not sufficient. It is imperative that a cumulative impact assessment of the entire area is carried out as well.
Tourism has several negative effects on the socio-ecological landscape of a place, as is well documented. Within the context of this information, the Ministry needs to not only include tourism as an industry within the EIA, but strengthen the existing provisions to cover them.
For tourism hotspots, like the mountain towns of Shimla and Kodaikanal, or popular beach destinations like Goa and Puri, a cumulative impact assessment from the perspective of tourism - a tourism impact assessment - is required. Additionally, small infrastructure projects, which are tourism related, may have severe ecological impacts that are either left out of the EIA framework, or have been insufficiently covered. To adequately address the same, infrastructural projects like ropeways and roads, in ecologically fragile areas should be included in the EIA as Category A or B1, without size thresholds.
The proposed draft EIA Notification falls short in many ways, particularly with respect to tourism. Given the lessons that have been learnt from this crisis, it is important to rethink and restructure the EIA framework in India, so that it may become the lifeline of environmental governance, bringing the much needed balance between environmental sustainability and development.
A detailed and constructive public consultation process takes stock of the current status of the environment and assesses the impact on communities across India as a result of the various projects that are currently underway. Given these fundamental concerns, the Ministry should withdraw the draft EIA notification 2020, conduct a detailed and broad public consultation, involving all stakeholders and the public, and draft a strong and robust Act for environmental impact assessment.
*Stella James and Nayana Udayashankar are affiliated with Equitable Tourism Options (EQUATIONS). EQUATIONS is a research, campaign, and advocacy organization, working on supporting environmentally sustainable and people-centered forms of tourism.
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