Bring Metro Rail Projects under EIA Notification Appeal to Shri Jairam Ramesh, Indian Minister of State for Environment and Forests Dear Shri Ramesh, Over the past decade several cities in India have decided to implement MRPs. Largely based on the Delhi Metro design, these MRPs are essentially elevated corridors aligned over key traffic corridors and is one technological response to the need for mass rapid transit systems (MRTS) in our densely crowded cities. If MRPs are a choice amongst various technological options to resolve the problem of mass transit, then it is only just to expect that such decisions are taken in a transparent manner and fully compliant with public consultation and planning norms. It is also natural to expect that such large mega projects are conceived and implemented after duly consulting affected communities and on careful and transparent consideration of the impact of such initiatives on the economy, culture, environment and social character of our cities. Finally, if more eminent and economically viable MRTS solutions exist, it is all the more reason to subject investment in a MRP to a thorough public debate that fully justify India's commitment to the Principle of Prior and Informed Consent. Quite in contrast to such reasonable expectations of a public project, MRPs are instead being thrust on Indian cities as stand alone projects and without any public consultation whatsoever. Public accountability is weak as select groups of consultants formulate proposals in secrecy and rush decisions through Central and State Cabinets sidestepping even compulsory debates in Parliament and Legislatures over allocation of massive financial resources to such mega projects. If MRPs are developed in a carefully considered, consultative and public manner, it could possibly aid in relieving the enormous pressures our cities are under in delivering traffic and public transport solutions. But it must also be recognised upfront that MRP systems potentially displace communities, cause extensive loss of homes and livelihoods, and fundamentally affect urban aesthetics due to the loss of green cover and public spaces. In the particular case of elevated rail corridors, it is also a globally documented impact that expected depression of economy on streets where such corridors pass through can lead to an increase in crime rates. In addition, there would be significant increase in noise pollution, and the congestion on road surface below will result in air pollution rise due to a tunnelling effect. A review of currently implemented MRPs reveal that they significantly compromise walking and cycling spaces on roads, especially given our indulgence to prioritise the motor vehicle over every other mode of travel. This is likely to increase accidents and casualties of pedestrians and cyclists. In effect, therefore, MRPs as presently implemented are largely violative of various progressive features of the National Urban Transport Policy. Applicability of EIA Notification to Metro Rail Projects: In light of irreversible its impacts on urban habitats, MRPs need to be implemented after due and careful consideration of its environmental and social impacts. On this basis MRPs were included in the list of projects requiring prior environmental clearance in the Draft Environment Impact Assessment Notification dated 15 September 2005 (for inviting suggestions/objections from the public) issued by the Ministry of Environment and Forests (MoEF), Government of India. There was widespread support and agreement that this was a correct approach. However, based on the mere opinion of Mr. E. Sreedharan, MD of Delhi Metro and a prime consultant to MRPs across India, who claimed in his letter to the Prime Minister's Office that these megaprojects do not have significant environmental and social impacts, the final EIA Notification issued on 14 September 2006 omitted MRPs from the list of projects requiring environmental clearance. Such omission of MRPs from the EIA Notification, 2006 is arbitrary and discriminatory, and the beneficiaries clearly are metro rail lobbies (lobbies of the construction companies and international coach manufacturers). This issue has now come up in a PIL (WP 18483/2008) in the High Court of Andhra Pradesh. However, MoEF has not yet filed the counter on the question whether environmental and social impacts are a core concern that ought to be addressed prior to implementation of MRPs, this even a year after issuance of notice. This silence of the Ministry must be viewed in the context of the EIA Notification, 2006 requirement for huge construction activities such as 'Building and Construction' and 'Townships and Area Development' to undergo a comprehensive environmental clearance procedure. MRPs involve massive construction activity for stations, piers, parking lots, commercial zones, elevated corridors, railway yards, power stations, etc., which impact heavily built up densely populated core city areas. Yet such megaprojects with very high environmental and social impacts have been exempted from environmental clearance. All these instances suggest that the Metro systems as they are planned and implemented today have overlooked a wide range of significant environmental and social concerns. This unnecessarily urgency in implementation of MRPs is causing a variety of disturbances resulting in protests, litigations, and campaigns, that are affecting the pace and implementation of these mega projects. Principles 10 and 11 of the Rio Declaration, to which India is a signatory, mandate that public must be involved in decisions that relate to their environment. In India, not only are MRPs exempted from EIA Notification, but proponents are blatantly flouting Town and Country Planning Rules and Regulations in planning and implementing such projects. Keeping all this in view, we urge you to immediately issue an amendment to the EIA Notification 2006 including the Metro Rail Projects in the Schedule so that they undergo a full review of their environmental and social impacts based on public hearings and consultations. This should apply to all the Metro Rail Projects, both planned and implemented. C. Ramachandraiah, Citizens for a Better Public Transport, Hyderabad. Leo F. Saldanha, Environment Support Group, Bengaluru. Medha Patkar, National Alliance for Peoples Movements.