7 Apr 2017 To Chief Engineer, (Special Projects) PWD 4th Floor, Bandhkam Bhavan Murzban Road Fort Mumbai, 400001 Sub: Relocation of Chatrapati Shivaji Maharaj Memorial to Cross Island in Mumbai Port Sir, Kindly refer to your tender notice 2016_PWSPM_163779_1 for construction of Chatrapati Shivaji Maharaj Memorial. We have seen the Detailed Project Report and we find that the project is unviable for the 25 reasons enumerated in Enclosure 1 to this letter. We are a citizens’ forum and we are placing before you only facts obtained from the Detailed Project Report, your Notice for Invitation of Tender, and information obtained from Government Departments under RTI ACT, and official web sites, etc. Copies of these documents and extracts are enclosed. In our opinion award of a contract for execution of the project will result in wasteful expenditure without achieving the aims of the project. We realise that the high level empowered committees of the Government have approved the project. However, a green signal still places the responsibility on the driver to proceed only when the road ahead is clear. In this project the road ahead has several impediments which the Government must recognise as making the project unviable. We request you to discharge your fiduciary responsibility to safeguard public funds from non productive expenditure. We are placing before you our arguments based on logic and moral force to act in the interests of the public good. We therefore request you to cancel the tender and consider an alternative location for the venerable project. With our best regards Yours faithfully sd ICRao,President APLI Mumbai Cc The Hon’ble Chief Minister & Minister for General Administration, Mantralaya,Mumbai Hon’ble Minister for PWD Mantralaya,Mumbai The Chief Secretary, Government of Maharashtra, Mantralaya, Mumbai Executive En gineer & Dy Executive Engineer Chatrapati Shivaji Maharaj Memorial Project Project Office, Cuffe Parade, Mumbai .................... Enclosure 1 to APLI Mumbai Letter to CE Spl Projects PWD, dated 7 Apr 2017 Chatrapati Shivaji Maharaj Memorial Project Tender No. 2016_PWSPM_163779_1 Reasons for declaring the Project unviable 1. Selection of the site for the Chatrapati Shivaji Maraj memorial was promulgated vide GR Smarak 3114/ Pr No. 40/29 dated 28 Feb 2014. Environment Impact Assessment procedure calls for alternative sites to be evaluated with weightage for relevant factors. This was undertaken one year later, on 20 Jan 2015 merely to inform the MCZMA that the procedure had been followed. For this project the evaluation is erroneous because one of the viable sites namely Cross Island has been rejected after mis-representing it as “Island is a host for oil refinery and has many gas holders”, “Difficult to Approach” and “the Seepages of oil is an existing issue”. All these are false statements. Please see APLI Mumbai Letter dated 16 Feb 2017 (copy at Enclosure 2) 2. The Environment Impact Assessment Procedure requires the proponent to conduct a public hearing. This was waived on the grounds that there are no affected persons. However, it must be accepted that there are affected persons, fishermen, those who place fishing stakes in the area, those who live on Marine Drive, those who visit Chowpatty Beach, etc . Therefore the decision to waive the public hearing has already been challenged and the situation requires to be rectified prior to proceeding further with the project. 3. The site selected at Lat 18 deg 55 min 33.8 secs N; and Long 72 deg 47 min 25.0 Secs E, fouls the zone marked on the Navigation chart no.2016 issued by the Chief Hydrographer to the Government of India, as “ Anchoring and Trawling Prohibited” due to submarine cables. NOC from Videsh Sanchar Nigam Ltd is not available. They may report that the submarine cables are dis-used but could still foul marine operations. See Enclosure 3 4. The site selected is not reachable by any vessels operating in Mumbai harbour registered under the Inland Vessels Act. For reasons of safety, these vessels are prohibited by the Mumbai Port Trust to cross a line joining Colaba Point to Thull Knob even during fair weather i.e 1 Sep to 25 May. See Public Works Department Bombay Government Rules Part I – General, issued by the Government of Maharashtra, copy at Enclosure 4. These limits have been shown on extract of Hydrographic chart no. 2016 at Enclosure 5. Please see also letter from Maharashtra Maritime Board dated 30 Mar 2017 at Enclosure 6. This vital factor has not even been mentioned in the Detailed Project Report. This lacuna must be rectified before re-approval and to relocate the memorial to Cross Island. 5. During the monsoon period of foul weather, 26 May to 31 Aug, these IV Vessels are further prohibited from crossing a line drawn from Colaba Point in transit Sunk Rock Light to North Brow of Great Karanja Hill. See Enclosure 5. 6. A fast passenger vessel sailing from Apollo Bunder at an average speed of 12 knots ( 22 km per hr) will take about 50 mins for the voyage of 18 km, one way, and the cycle-time will be 2 hours. If each vessel carries 100 passengers then the number of vessels required to achieve the specified peak arrivals of 6300 per hour will be: 6300 x 2 = 126 vessels !!!! 100 To transport 10,000 visitors per day the number of boats required will be over 24, full time. These issues will only be resolved if the memorial is re-located to Cross Island 7. The Government of India Gazette Notification No. S.O.1197(E) dated 11.05.2009 ( extract at Encl 7) demarcates the Maritime Base Line defining the internal waters of India. This base line defines the limit of the areas of operation of Inland Vessels.( In Mumbai the area of operation is further restricted by MbPT). Maritime Base Line relevant to Western Mumbai region is a series of lines joining Mehti Khada – Outer Reef Backbay- Prongs Reef – Kanhoji Angre Light, as shown at Enclosure 5. The memorial site is therefore not reachable by Inland vessels from harbours along the coast of Maharashtra or ports in Mumbai region e.g. Bandra, Versova, Manori and Vasai who will have to cross the base line to leave their harbours. 8. Director General Shipping Circular No.1 of 2015 permits Inland Vessels to ply 5 nautical miles beyond the base Line only between 1st Sep to 31 May provided they are certified by the Classification Society ( e.g. Indian Register of Shipping) with personnel duly certified under the model IV rules of the Inland Waterways Authority of India. A copy of the DG Shipping Circular is at Encl 8. The EIA report by NIO/NEERI shows that the wave heights in the monsoon months are 0.8m to 2.7m. The wave height tolerance for the boat design selected for the project is 0.5m. Hence the memorial site is un -approachable by any type of passenger boats at any time during the monsoon months. This is a lacuna in the Detailed Project Report to be rectified before re-approval. 9. The Project Report specifies the 100 passenger boat design as follows Length OA 22.9m; Beam 6.5m and Draught 1.9m speed 20 knots. To be permitted to cross IV limits, the boat is required to be registered under the Merchant Shipping Act. This boat with features required by the MS Act may be built at an estimated approx. cost of Rs 10 Cr and is unaffordable by the tourist trade in Mumbai region. Extract of the Boat design parameters are placed at Enclosure 9 10. The Project Report specifies landing points at H2O jetty and NCPA Jetty. The Back Bay between H2O jetty/NCPA Jetty and memorial site is rocky and the 2 m depth line is 1.6km from the jetty. The size of boats which can operate from H2O and NCPA Jetties will be too small and unable to meet the passenger capacities specified in the Detailed Project Report and Tender conditions. These boats also will require classification by IRS as they too will have to cross the base line to reach the Memorial island. The boat design specified above is unsuitable for operation from these jetties which do not have adequate depth of water. See extract of Hydrographic Chart no. 2015 at Encl 10. 11. Similarly passenger jetties at Badhwar Park, Raj Bhavan, etc have been listed in the DPR without the benefit of feasibility studies. These locations are exposed, too shallow and have no land for the marshalling / parking needed to deal with thousands of visitors to even be considered as landing points for passenger vessels. 12. The Environment Impact Assessment Report of Nov 2014, submitted jointly by N.I.O. and N.E.E.R.I has dealt with the aspect of “Routes for Boats” at Figure 1.12 of their report at page 1-19/20. Copy at Encl 11. The track shown from Gateway of India to the memorial site traverses over 4 exposed wrecks and two submerged wrecks marked, on the very same Hydrographic chart 2016 used in Fig 1.12 above, as being potentially dangerous to surface navigation. Marking the track without reference to safety of navigation is reprehensible, tantamount to negligence in a report for a project of national importance. The track shown from Nariman Point to the memorial site also traverses, for 1.5 km, over shallow water unsuitable for the 100 passenger boats selected for the project. Track which is recommended by competent seafarers is at Enclosure 12. This track takes into account • Wrecks • Lack of marker buoys • Fishing Stakes • Lack of transit marks for accurate visual navigation • 1.5 knots on shore current off Prongs Reef ( Any engine failure will lead to grounding before help can arrive) • Squat of 0.4 m at speed of 20kn • Safe Depth = Draught (1.9m) + Squat at 20kn (0.4m) + Under keel clearance (1m) Say, 3.5m 13. Considering access to 10,000 visitors per day by boat is central to the project concept, the cavalier treatment of the aspect of accessibility by boat requires postponement of the project, till feasible solutions are found, or the project relocated to Cross Island where these impediments will vanish. Cross Island is a very attractive location because: • It is terra firma, an existing island • It is unused / derelict. • In sheltered waters • Only 1 km from Ferry wharf, easily visible from the shore, reachable in just a few minutes by boat. • A memorial on the island will be an inspiring sight to all seafarers and visiting cruise ships. • This location would complement the MbPT's redevelopment of the eastern waterfront. 14. Soil Investigation is the first critical task in any civil construction project and has to be given the greatest importance. Yet, this has been entrusted by the Government to M/s Pioneer Foundation Engineers of Thane who are not known to be accredited with the leading employers of Geotechnical Survey such as E.I.L. The undated Geotechnical report ( circa Apr 2014) obtained under the RTI Act has many flaws and has apparently not been studied by any geologist, as will be clear from the following observations. • The uppermost layer, up to 6m in thickness, has been described as ‘boulders’. i.e particles of size over 256 mm, which finding is not possible while using a bore sampler of only 150mm diameter. This layer could at best be called “cobbles”, i.e. 64mm and larger. • ‘Marine soil’ is a non-technical term. The layer should have been classified as silt, or clay etc. Such a layer is not expected to be found below, weathered rock and breccias, and above a layer of basalt. Therefore such a marine layer found between these terrestrial volcanic layers needs explanation. • Slate is a metamorphic rock, virtually impossible to find below ‘marine soil’. • Therefore the nomenclature in the primary results recorded in the 11 bore logs is flawed and the location requires repeat investigation under the supervision of a competent geologist at site. The “Measurement Sheet” giving the summary of results • uses terms such as “clay rock” ( BH4,5) which are meaningless. • Marine Soil is relabelled as weathered basalt in Summary of BH1 • Fractured basalt layer thickness has been combined erroneously with compact basalt layer thickness. e.g in Borehole 1, compact basalt is shown as 11.5m thickness ( 14.5m to 26m) whereas compact basalt is recorded in the bore log as being 6m thick from 19m to 25m. The project proponent is thus being led to believe from the Summary that compact basalt at Borehole 1 was found at depth of 14.5m when it was actually found at 19m. This manipulation has been repeated for all 11 boreholes. Samples of errant pages are at Enclosure 15 All calculations of pile foundations are based on reaching bed rock. This false geotechnical survey report would have vitiated all structural planning. This situation necessitates cancellation of the current project execution schedule. 15. In the FUGRO Survey (India) Pvt Ltd Bathymetry chart J-MAR-16-048/EGIS/OFF MUMBAI/BS/B/01/7562 and accompanying report by M/s Fugro Survey (India) Pvt Ltd, the tidal reduction to arrive at depth w.r.t Chart Datum has been based on tides at Apollo Bunder, which are different from Back Bay both in timing and range. Considering that the design of the reclamation scheme for the island is dependant and highly sensitive to the maximum tides expected, the bathymetry assignment should have included tide measurements ab initio. Alternately, the tide tables issued by the Maharashtra Maritime Board for the Bandra group may be compared to determine the margin of error on the dates of survey viz May 2016. Precise dates also need to be recorded. 16. Bathymetry of the proposed site of the Memorial is contained in the report by M/s Fugro Survey (India) Ltd dated 14 Jul 2016. This provides a very narrow passageway for boats with draught of 1.9m as specified, especially at end of the Southern Breakwater. It is prudent seamanship to ensure 1m depth under the keel to allow for drift due to currents and changes in depth. i.e. navigate in waters charted with minimum 3m depth. The approach to the jetties will thus require additional navigational aids, including marker buoys to guide even experienced crews of boats with capacity of 100 passengers as they will include women, children, the elderly, physically challenged persons and non-swimmers. Furthermore, in view of the extensive use planned of the restricted boat passages, the DPR should include sweeping of the bottom to detect rock outcrops, rock dredging, and removal of boulders and construction debris hazardous to surface navigation. See Enclosure 13. 17. The proposed island layout includes construction of two breakwaters of length 228m and 382m to create a tranquil bay for the two passenger jetties. The DPR does not include any model studies to determine the siltation or erosion patterns as a consequence of the construction of 600 m of breakwater across the tidal currents prevalent in the Back Bay. The effect of siltation could make the two jetties unusable by passenger boats, negating the purpose of the project in its entirety. There is no mention of wave modelling and sediment transport modelling to assess the effect of breakwaters, which were introduced after the EIA was completed. No report is available from the Central Water and Power Research Station at Khadakvasla. Pune, which has a model of Mumbai and has conducted studies of siltation patterns in Mumbai since 1954. This is one more reason for recasting the EIA prior to proceeding with the project. 18. Approx 150,000 cu m of “granular soil with no fines”, i.e. sea sand or gravel will be required immediately at the commencement of the project, for construction of the coffer dam, which is required to be completed by LOA + 6 months. Location of the dredging site or borrow area has not been identified. Delay in identifying the source will be a cause for dispute between employer and Contractor. Therefore commencement of the project is required to be delayed till source of filler material for coffer dam cells is identified. Civil Engineering industry associated with MbPT’s Rs 1000 Cr Offshore Container Terminal project will recall that the borrow pit identified off Rewas for filling the Princes and Victoria Docks in 2007 was found to be unproductive, and affected the project adversely. (That project is now closed). 19. The construction of the breakwaters requires 1 million tons of rock as stated in the DPR. Rock median size is to be 0.75m to 1.25m.The location of the borrow area requires to be identified and requires environmental clearance and social acceptance. Commencement of the project without this essential clearance is unacceptable. 20. Requirement of rock for the Breakwaters is 4000 Tons per day, every day for nearly a year, to be transported across the city from Parsik hill or further afield by multimodal routes. Considering the logistics, tidal nature of the site, and inability to operate in the monsoon months, this requirement alone makes the project unviable. 21. Approx 100,000 Tons of silt free washed sand of specified gradation will be required for the construction of RCC structures, piles and buildings. Location of the dredging site or quarry has not been identified. Delay in identifying the source will be a cause for dispute between employer and Contractor. Therefore commencement of the project is required to be delayed till source of sand is identified. 22. Approx 40,000 Tons of laterite stone will be required for the Sea wall. The DPR mentions availability only at Talmod, Chandrapur, Satara, Ratnagiri and Kolhapur. Location of the quarrying site has not been identified. Considering that laterite quality is suitable only for a depth of 5m below the surface, the area required will be over 5ha of probably forest land. Delay in identifying the source and timely environmental clearance and administration approvals will be a cause for dispute between employer and Contractor. Commencement of the project is required to be delayed till source of laterite is identified. 23. The Detailed Project Report identifies structural design of the monument as a challenge. The first concern will be wind loads. There is also concern listed about curves and crevices which will create local factors, high suction, vortex shedding and von-karman effect. This will need the most thorough mathematical and physical modelling to determine flows and stresses, and then the internal structure has to be designed to accept the cladding. This will be akin to aircraft design, and will take time affecting the delivery programme. Yet there is no report of wind tunnel tests conducted, though reportedly offered by IIT (Delhi) in 2013. 24. The slenderness ratio of such structures is mentioned in the DPR as normally being in the range of 8 to 14. The slenderness ratio as designed for height of 192 m has already reached 16. Newspaper reports of further increase of height to 210m is therefore alarming from the point of view of safety of the structure. Times of India Article dated Sunday 24 Mar may be referred in this regard. http://timesofindia.indiatimes.com/city/mumbai/shivaji-memorial-will-now-soar-to-210m-in-bid-to-dwarf-chinese-statue/articleshow/57818769.cms 25. The DPR has identified the arm and sword of the monument as being particularly slender. Please see Enclosure 14. In such situations, mention of additional safety factor is called for. The safety factor normally assumed and the additional safety factor to be applied in this case need to be demanded and recorded in a project of this nature. Proceeding with the project without abundant caution is tantamount to abrogation of the responsibility of the Government in doubly ensuring public safety and safeguarding public funds. 26. Society and the public at large require assurance that the Detailed Project report by a Private Engineering Consultancy has been thoroughly scrutinised and shortcomings made good. (For example, is the Government aware of the stipulation that welding at site will be prohibited as a quality control measure. Has this stipulation been accepted by all concerned? What are the deviations sought by the three bidders?) A public assurance on technicalities is necessary before the project can even be considered for implementation. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx