Thursday, November 25, 2010

Cavrem letter to Indian Bureau of Mines on illegal mining


c/o. Nilesh Gaonkar,

Gaonkarwada, Caurem,

Quepem taluka, Goa

REF NO. 23/10 Date: 24th November 2010


The Indian Burean of Mines,

Fatorda, Margao, Goa


REF: 1) Our earlier letter to you dated 31st August 2010

2) Our earlier letter to you dated 12th October 2010, received by you on 25th October 2010

Dear Sir,

We, the members of the Caurem Adivasi Bachao Samiti, living in the Caurem village of the Quepem Taluka, request your immediate intervention to stop the mining and dewatering operations going on at the 'Devapan' mine, TC 01/51, Caurem village, Quepem taluka. In addition to the grounds stated in our earlier letters referenced above, we bring to your attention the following violations by the ongoing activities at the said mine.

1. Destruction of ground water aquifer and springs: 'Devapan' literally translates as 'God's sacred grove', signifiying the exceptional significance of the life giving ecological wealth of this hill. This hill has some of the most exceptional aquifers in Goa and is the origin of numerous perennial springs, including major ones called 'Paikachi Zor', Khaspurus Zor', 'Talyepat Zor', 'Bulmeachi Zor', 'Khuteachi Zor Ghogho', 'Mestan Zor', 'Gaunkaran Zor', 'Vanvshan Zor' and 'Gallachi Zor'.The present mining pit has already gone deep into the ground much below the permitted levels, and has burst one water aquifer, thereby destroying its integrity, the water quality and quantity, which is serious violation of the conditions imposed by the Environmental Clearance. This has already caused significant reduction in the quantity and quality of water flowing from many of our springs. The last two of the springs named above are inside the active mining area, with the 'Gallachi Zor' being destroyed completely and the 'Vanvshan Zor' is surrounded by mining activities on all side, with the water being used for washing mining equipment. Every day, the mining activities continue to destroy this crucial source of perennial water, and one of main sources of Kushawati River, which is the lifeline of tens of thousands of families living in our village, and in dozens of villages along the route of Karka River, Kushawati River and the Zuari River. We are afraid that if the mining activities are not stopped immediately, more compartments of this aquifer shall be compromised, causing total and irreversible destruction in our village and in other parts of Goa.

2. Destruction of nallahs and buffer zone: The subject mining lease includes three nallahs, which used to carry perennial waters to our fields for cultivation of second and third crops of paddy, sugarcane, chillis, vegetables and for horticulture. The mining company has not only compromised the buffer zones of the nallahs, but has also destroyed the nallahs themselves, in blatant violation of the law.

3. Mining Operations without necessary permissions: The Consent to Operate for the said mine has expired on 1st January 2010, after which the mine has been operating illegally. During this period the mining company has excavated and transported huge quantities of ore illegally. As per the Orders of the Bombay High Court dated 20th September 2010 (copy attached), read with the submissions made by the Government Departments, the mine is supposed to be inoperational. During a Hearing held at the office of the Chairman of GSPCB on 19th November 2010, the representatives of the mining company stated that no mining operations are taking place at the mine. However, the mining activities are continuing till date with impunity, with accelerated speed and urgency.

4. Pollution of water and paddy fields: The illegal mining operations are causing havoc to the water and agriculture in our village, as confirmed by the Show Cause Notice issued by the Goa State Pollution Control Board on 22nd October 2010 and their Test Reports (copies attached). During the Hearing held at the office of the Chairman of the GSPCB on 19th November 2010, it was stated by the mining company representatives that the pump(s) in the mining pit are only for emergency purposes. However, the mining company continues to operate the pump illegally till date, and is thereby dumping large amounts of mud in the lands, rivers and paddy fields downstream of the mining pit and destroying them.

5. Forest Rights: The residents of Caurem village are scheduled tribe members and other forest dwellers. The attached copy of the Table no. 20, on page 100 of the “Survey Report on Scheduled Tribes of Goa” states that during the 2001 census, 699 tribal households were ennumerated in our village, which corroborates the actual number of more than 2000 tribal residents of our village. Our Traditional Rights over our Forest Lands, which includes the lands under this mining lease and lands contiguous with them, are now finally recognized by the Union Government under the Forest Rights Act, 2006. The ongoing mining is undermining the objectives of this new enactment and is destroying our Rights before they are even verified by the Government, and is therefore in violation of this enactment. The Environmental Clearance is also based on the false data included in the Rapid EIA & Management Plan Report, which states that there do not exist any tribals in the 22 villages in the study area (copy of page 3.9 of the Report attached). This is abolutely false, since all these villages are predominantly populated by tribals, as verified also by the government data in the Table no. 20, on page 100 of the “Survey Report on Scheduled Tribes of Goa”, which is attached herewith. Secondly, we have not had a proper opportunity to have a Public Hearing as mandated under the EIA Notification, since majority of the villagers were not aware of the Hearing held on 28th April 2008. Thirdly, attached herewith is a copy of the unanimous Gram Sabha resolution dated 19th December 2007 resolving to stop the mining which was forced upon the villagers in spite of their opposition. This resolution also is evidence proving that the mining had started even before the so-called Public Hearing held on 28th April 2008, reducing the entire exercise to a farce.

6. Violation of Forest (Conservation) Act, 1980: A large portion of the mining land includes forest lands, both private forest and government owned reserve forest. The mining activities are going on in the private forest area without any permissions.


We pray that you may therefore:

1. carry out a thorough investigation into the illegalities mentioned in this letter and into the adherence by the mining company to its other statutory responibilities under the various laws applicable, and the terms and conditions imposed under the various clearances and permissions obtained by the company;

2. pass an interim Stay Order against any mining or dewatering operations at the Devapan Dongor mine to prevent further irreversible damage to us and our environment, in the pendency of the investigation;

3. to take steps necessary to ensure that the mining comany cannot physically operate their machinery and pumps illegaly, as they have been doing in blatant violation of their own assurances given to the Chairman of the GSPCB in our presence.

We are determined to save our village from any further destruction and shall greatly appreciate your support and co-operation in stopping the irreversible polution of our surface and ground water resources, and upholding the Law and our Constitution.

Thanking you,

Yours sincerely,


Tulshidas Velip


Encl: 1) Copies of documents mentioned in the body of this letter

Cc: 1. Regional office of MOEF, Banglore. 2. MOEF, Delhi.

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