To,
The Director,
Directorate of Mines and Geology,
Udyog Bhavan,
Panaji, Goa. 403 001
20th October 2008
Sub: Comments/Objection on Draft Mineral Policy – Goa
Sir as per notification of Draft Mineral Policy – Goa published in Official Gazzette series I No. 21 21st August 2008 we wish to state the following:
Introduction of the Policy reads as “ In order to facilitate planned and systematic exploitation of mineral resources in a sustainable manner, a mineral policy for Goa is being formulated.”
Mining trade is governed through central legislations namely Mines and Minerals (Regulations and Development) Act, 1957 and The Mineral Conservation and Development Rules, 1988 that are already ensuring that Minerals can be exploited as long as they become uneconomical. In fact “Abandonment of mine - means final closure of a mine either whole or part thereof when the mineral deposits within mine or part thereof, have been fully extracted or when the mining operations have become uneconomical” [Section (3) (a) of The Mineral Conservation and Development Rules, 1988]. Sustainability has no criteria in both these legislations that will override Goa’s Mineral Policy.
All the abandoned mines for over 20 years are brought under operation when there was demand from China even for a low grade ore that was earlier uneconomical.
No mine in Goa complies with special conditions in Environmental Clearance order accorded by Ministry of Environment and Forest. Violations of Water Act, 1974 and Air Act 1981 are open and consistent. None of the responsible government authorities such as Goa Pollution Control Board, Department of Mines & Geology, Conservator of Forest and Wild life; Central Authorities such as Indian Bureau of Mines, Director General of Mines and Safety are executing their powers to curb these violations.
Illegal mining is still in continuation and which was brought to the notice of State Government yet government failed to check illegal mining activities.
Therefore draft Mineral policy is just an eye wash and therefore it is to be scrapped. In the context of above mentioned things this draft Mineral Policy must be scrapped with immediate effect. Instead the State government has to go severely against the mining activities with the existing rules, laws, acts and in particular Section 23(c) of The Mines and Minerals (Development and Regulation) Act, 1957 empowers State Government to make rules for preventing illegal mining, transportation and storage of minerals as per. Goa Government is doing nothing on this.
State government for the wellbeing and hazardous mining activities which in no way an economic backbone or generates revenues for the socio-economic development of the State, The State government has to stick to the Mineral Concessions Rules 1960 for the appropriate actions. According to this law, power to terminate the mining leases lies with the State Government and Goa Government is not invoking the same.
State government must make list of all the mining leases which was not operated consecutively for two years and more be publicly listed and terminated for sustainability of mineral resources.
The sustainable mining is therefore a myth. No mining can be sustainable. Mining is undesirable activity that needs to be stopped in Goa once and for all. We need policy to ensure that mining – particularly open cast iron ore, manganese and bauxite mines all over Goa are closed down as it has proved to be source of ecocide for Goa and its people.
Sd/-
Sebastian Rodrigues
Convenor
Goa Federation of Mines Affected People (GOAMAP)
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