EIA report

Its not Just about the trees. Its about the Environment of Aarey and Mumbai.

The EIA report prepared by MMRDA is full of flaws , with incomplete data and erroneous reporting and poor methodology.  

Please. see the attached report of Bio Diversity data of Aarey.

Here is the analysis of the same prepared by save Aarey team :-

Anyone who likes to read the full report  can find it here:



 The current critique of the EIA Report submitted by MMRDA TO JICA for Mumbai Metro Rail Corridor Line III (Colaba- Bandra-SEEPZ) (henceforth referred to as the report) focuses exclusively on Aarey, where the proposed depot and workshop (henceforth referred to as Depot) is coming up. The objective of the critique is not to stall or oppose the project as a whole, but oppose the current location of the Depot to Save Aarey, the one of the few existing green lung for Mumbai. It is an attempt to point towards the factual and fatal errors in the report.

 A.      Methodology:

1.       The major drawback of the report, is that it does not elaborate on the methodology used for the EIA. It just mentions that “standard methodology of data collection, impact assessment and formulation of the management plans is adopted(Section 1.6, Page 1.9). There are several standard methodologies and indices for all the studies mention above; each with its own merits and demerits as well as the levels of precision and complexities (ds-wmra-so-1997.pdf Chapter 3. Methodologies of EIA from EIA for developing countries). The chart of Methodology for the EIA study (Fig 1.2 Page 1.8) is very basic textbook chart and does not throw light on the methodology used. As a standard practice these methodologies need to be mentioned enumerated, if not discussed in detail. If the scaling systems have been followed they then, the value data needs to be provided.  Most important of all, the report is silent on the time duration and the season for the data collection. In case of such studies especially with respect to biodiversity, season plays a vital role in the presence or absence of species.

2.       The report mentions the Common names of the trees (Appendix 3.1 Page 3.42- 3.61), whereas such reports should mention the scientific names. The scientific names are essential from the standarisation point of view.

3.       A number of trees in the report are categorized as Wild/ others (854) in Depot area alone (Appendix 3.2 Page 3.61). The report thus mentions “none of the trees are important or rare”, without properly identifying about 50% of the trees in the Aarey area alone. Incidentally these 852 trees from Aarey are 29% of all the trees surveyed for the project.

4.       Another interesting point is the absence of the Rain Tree (Albizia saman) and Copperpod (Peltophorum pterocarpum) two common trees in the city of Mumbai as well as Aarey.

5.       Chapter 4- Negative Impacts (4.2.3 Page 4.3) points towards a short-term Heat-Island Phenomenon, which would be mitigated by afforestation after construction. However, it would be advisable to elaborate on this aspect with respect to the period of the Heat-Island Phenomenon and location of afforestation activity.  The report needs to mention the references for calculating the loss of oxygen data mentioned in Table 4.2 and the reason for choosing the said formula vis-à-vis other formulae considered, if any.

6.       (4.2.3 Page 4.3) As per the report “The proposed alignment of metro rail is in urban/ city area and not passing through any forest. Hence no loss of forest is anticipated”

This is not true as state Forest department has a pending request to reclaim this land under their jurisdiction that was transferred to state Dairy department for dairy purpose. Significant part of depot land is dense forest and has high density of full grown trees as per the census. Most part of Aarey has a forest cover, and is incorrect to say that No forest exist here.

 B.      Erroneous reporting:

 1.       Ecology 3.7 : mentions 1652 trees whereas per annexure I  2298 trees are affected and ear marked for uprooting.

2.       The depot has been planned at Aarey Milk Colony covering an area of 26.407 Ha. Where as the actual area taken is 30 plus Ha. Any on field they have marked even greater area.

3.       The Chapter 3- Environmental Baseline Data (3.7.2 Page 3.37) mentions that the nearest Protected Area (Sanjay Gandhi National Park) has an area of 19.18 sq.km. However, the official Forest Department figures of Maharashtra Government peg it at 103 sq. km. (sgnp.maharashtra.gov.in).

4.       The same section (3.7.2 Page 3.37) mentions there is no wildlife in the area. Aarey is home to leopards (Panthera pardus) and other wildlife. This can be supported by various studies and media reports (Annexure 2 and Annexure 3). Literature review alone will bring to light the existing wildlife in Aarey. The discovery of Lychas aarenensis, a species of scorpion new to science from the area points towards biodiversity of the place (Annexure 2 and Annexure 3).

5.       The section also mentions the presence of alligators (3.7.2 Page 3.37) in the National Park, where as Alligators are not found in India. The only species of alligator reported from Asia is the Chinese Alligator (Alligator sinensis) which is found in Yangtzee River and adjoining swamps.

6.       4.4.4 Muck Disposal No clear plan is mentioned about muck Disposal.

7.       “Under 6.3.1 B) Transplantation The structural component of depot should be planned in such a way that about 30% of the trees will get saved.”

This statement of intent was not followed as large number of OLD trees lined up  near the current road could be saved with some realignment of the depot structure. No thought was given to this aspect.

C.      Public consultation and Alternative sites:


1.       The MMRCL seem to have carried out the public consultation at various areas of the Metro Phase III line. However the report does not mention about public consultation being carried out at the Goregaon site (Section 7.5 Page 7.4 to 7.16). This shows the laxity on behalf of the officials to take into consideration the concerns of the stakeholders at a major component of the project i.e. Depot. Thus, it will be improper to say that all the stakeholders were consulted on the issue.

2.       In case, the authorities had conducted the public consultation at sites shortlisted for the Depot, they would have been able find more alternatives, which have now been proposed by experts and citizens in media reports and blogs (Annexure 5, and 6).

3.       In addition, the report mentions scope of further expansion as an important criteria for the selection of Aarey (Alternative III: Aarey Milk Colony Section 2.4.2 Page 2.7). However it is silent on type of expansion. It needs to clarify whether expansion merely includes infrastructure purpose or covers the real estate development (residential and commercial buildings) especially, since Aarey is a prime piece of land, with several real estate players eyeing it.

4.       The above section also mentions need for proper landscaping. This can impact the already fragile ecosystem of the existing land. In addition the manicured landscape will also damage the existing characteristic mosaic of grasslands and vegetated areas in Aarey landscape.

 Apart from the above mentioned flaws, the report is full of factual errors as well a horde of grammatical and spelling errors and lacks the scientific basis, especially from the biodiversity point of view in Aarey. In a nutshell the report is appears to be a hurriedly compiled document merely to complete the requisite paperwork formalities. Having said that it is reiterated that there is no opposition to the project as a whole but strong recommendation of relocation of the Depot to alternative location. In addition Aarey needs to be safeguarded as buffer area for the Sanjay Gandhi National Park.


 6.3.1 Talks about compensatory afforestation, where transplantation process is explained. It should be noted that the past transplantation for similar project has a near zero success rate, so what is different this time round.

EIA for metro annexure 9