Written submission by the Conservation Action Trust & Others dated 18/11/2020. Conservation Action Trust had filed the appeal before the National Green Tribunal (NGT) challenging the Environment Clearance of November 2, 2016 granted for the proposed expansion of Alang-Sosiya Ship Recycling Yard (SRY) from the present ship breaking capacity of 400 ships per year to 600 ships per year at Alang and Sosiya villages, Bhavnagar district, Gujarat.

The highly polluting method of beaching has been selected to expand the existing ship breaking yard by granting permission for an additional 15 number of plots each admeasuring 100x90 meters. This is in addition to the existing 167 plots which are already using beaching methods for the purpose of carrying out ship- breaking activities.

The Appellant (Conservation Action Trust) has placed on record several studies and documents to show that the beaching method is the worst method of ship breaking, both from the perspective of environment as well as health of the thousands of migrant workers who are engaged in this activity. The beaching method of ship breaking can never be environmentally safe and protective of human health.

The report also raised faults in the EIA report. It said that the EIA report is completely lacking with regard to the baseline monitoring of several hazardous pollutants which are associated with the ship-breaking industry. These include asbestos, polychlorinated biphenyls (PCBs), VOCs manganese, nickel, chromium, iron, aluminium, lead, carbon dioxide, carbon monoxide, PM, sulphur dioxide and oxides of nitrogen (NOx). However, the Project Proponent has only conducted baseline studies regarding PM, SO2 and NOx. None of the other hazardous pollutants have been monitored.

Baseline monitoring of sediment pollution as well as study on incremental the load of the same is critical when the project in question is ship breaking using the beaching method. In such a case, there is a huge ecological stress on the sediments and sea water. However, the Project Proponent failed to conduct baseline studies as well as study the impact of incremental load due to the project in question on existing pollution levels.

These were some of the points raised by the Conservation Action Trust against the proposed expansion of Alang-Sosiya Ship Recycling Yard in its report to the NGT.