If as critics point out, the environmental impact assessment study was commissioned only after the auction process got underway with not all the stakeholders getting to know of it, then the government has already compromised the trust it could have enjoyed with Kerala's public including its coastal communities, points out Shyam G Menon.
On March 4, 2025, the Kerala assembly passed a resolution urging the central government to withdraw its decision allowing deep sea mining off the state's coast.
According to The New Indian Express dated March 5, the resolution moved by Chief Minister Pinarayi Vijayan, 'expressed concerns about the potential harm to marine wealth, ecology, and the livelihoods of fishermen.'
Four days later, N K Premachandran, the Lok Sabha MP from Kollam, told me, "It is a unanimous resolution. It reflects the will of the people of Kerala. So, the Government of India will have to take it into consideration."
Premachandran belongs to the Revolutionary Socialist Party which is part of the United Democratic Front (UDF), at present the political Opposition in Kerala.
The passage of the assembly resolution was two days ahead of the state conference of the Communist Party of India-Marxist -- it anchors the Left Democratic Front (LDF) -- currently in power in Kerala.
The conference was scheduled to be held in Kollam, the sea bordering which, was location for the main thrust of the mining project.
Earlier in late February, there was a 24-hour strike in the state's fisheries sector over the mining issue.
In Kerala's districts enjoying a seashore, the fisher community has lived on the periphery of the majority's awareness.
Enduring an unsteady life owing to the very nature of the fishing economy and periodically displaced by natural calamity and infrastructure projects, they stay wary of schemes that fail to take stakeholders into consideration.
This and the absence of a formal in-depth study of the consequences of sea mining in Kollam, formed the gist of what Father Eugene Pereira, a priest long associated with issues concerning fisherfolk, told me in Thiruvananthapuram, late February 2025.
Hailing from the Latin Catholic denomination, to which most of the Christian fishers on Kerala's coast belong, Fr Pereira was previously among the activists seeking greater transparency and engagement with stakeholders in the now up and running Vizhinjam container transhipment terminal in southern Kerala.
Those like him, worried about fishers' livelihood and the marine environment, had stayed watchful ever since the Centre announced intentions of a Blue Economy policy, with deep sea mining mentioned among the activities planned.
Kollam's importance on India's mineral map has been known for long; onshore deposits of rare earths and minerals strategic to India's atomic energy establishment exist here along with extraction and processing.
But that is onshore. When it comes to the sea, Kollam is home to one of Kerala's biggest fisheries harbours.
It also has a sizable number of artisanal fishers. And most important of all, it is close to one of the most productive fishing grounds of the state -- the Kollam (Quilon) bank.
Any offshore mining activity here must be therefore properly studied for what impact it may have on the local fishing grounds as well as the fisher community dependent on the sea for sustenance.
A meeting in Kochi and the uncertainty about an environment impact study
In India, the law governing offshore mining is The Offshore Areas Mineral (Development and Regulation) Act, 2002.
In early August 2023, the Press Information Bureau (PIB), on behalf of the ministry of mines, posted a statement on amendments to this Act passed by Parliament.
The statement specifically mentioned the following resources delineated by the Geological Survey of India (GSI): 1,53,996 million tons of lime mud within the EEZ off Gujarat and Maharashtra coasts; 745 million tons of construction-grade sand off Kerala coast; 79 million tons of heavy mineral placers in the inner-shelf and mid-shelf off Odisha, Andhra Pradesh, Kerala, Tamil Nadu and Maharashtra; phosphorite in the eastern and western continental margins and polymetallic ferromanganese (Fe-Mn) nodules and crusts in Andaman Sea and Lakshadweep Sea.
The people I spoke to regarding the Kollam controversy, were latched on to these changes -- the introduction of an auction regime for the blocks identified for mineral exploitation and the installation of state-owned public-sector units as the sole agency for mining, restricted to mineral deposits relevant to atomic energy.
They saw the private sector as welcome to extract other minerals.
On top of this, two other angles aggravated their concerns.
Although the potential for mining off Kerala and Kollam were known, the actual steps in this regard -- critics argue -- happened without all the stakeholders involved, being properly informed.
In early January 2025, a meeting took place at a hotel in Kochi as prelude to setting the auction process rolling.
"Some people from the fishing community came to know of this and they staged a protest at the venue," Fr Pereira said.
The PIB website has a statement (issued on behalf of the ministry of mines), dated January 11, 2025, about this meeting.
According to it, senior officials from the central and state governments attended the meeting.
It said the official representing the state government, 'delivered a key address underlining Kerala's strategic importance in the offshore mining sector. He showcased the state's vast deposits of construction sand and reaffirmed Kerala's commitment to promoting investor-friendly and sustainable mining practices.'
The statement added, 'Participants expressed keen interest in the identified blocks, particularly the three offshore blocks in Kerala, which hold immense promise for the state's construction and infrastructure industries.'
Another grievance, Fr Periera and some others unhappy with the government's approach to sea mining, highlighted, was the apparent absence of a detailed environment impact assessment report (those tracking the mining plan in southern Kerala, had not heard of one) even as the government held meetings anticipating auction.
After protests staged, there is now talk that an environment impact study has been commissioned.
Premachandran, the member of Parliament, also said this appears to have been the case.
Both the confirmation of such a study ordered and the ethical correctness in such a study commissioned after steps related to the auction process had been initiated (if that was the sequence followed), are crucial to form an opinion about its aptness.
None of these points could be cross checked with government officials.
I visited the office of the directorate of mining and geology in Thiruvananthapuram, hoping to speak to a senior official.
The official concerned was not available; he was gone to the state assembly likely because the mining issue was live there.
I also tried speaking to the senior official on the phone and left text messages requesting for an opportunity to speak.
There was no response. By then, the earlier mentioned assembly resolution stood passed.
The state had called upon the central government to withdraw its decision to mine in the seas off Kerala.
For critics of mining, the environment impact assessment report is as important a demand as discussions being held with all stakeholders.
They cited past instances in coastal projects, when environment related studies were done late, leading to suspicions around how reliable and impartial those studies had been.
Caught in the middle: fishers and a rich fishery environment
Given little information forthcoming from the government, much of the media reporting so far about the proposed sea mining project at Kollam has used an overview by a senior academic as valuable reference point.
The lay of the continental shelf off Kerala, the underwater environment and the wealth of fish resources in the seas here have been the subject of scientific study since at least the late nineteenth century.
Dr A Biju Kumar, who heads the department of aquatic biology and fisheries at the University of Kerala, is among those continuing that tradition now.
For the past few years, he has explored and studied the fisheries resource in the waters off Kollam.
He has dived in the area and seen first-hand, the underwater marine ecosystem of the region.
The marine biologist had no difficulty realising what mining could do to the place.
He authored a small report, easy to comprehend, titled: Report on the Possible Impacts of Offshore Sea Sand Mining Off Kollam on Marine Biodiversity and Coastal Livelihoods.
For now, this is the go-to reference material for anyone wishing to comprehend the proposed sea mining project off Kollam and its potential consequences.
The commodity at the core of the Kollam-sea mining issue is sand.
'Driven by industrialization, population growth, and rapid urbanization, global demand for sand has surged. Aggregates -- comprising sand and gravel -- are now the world's second most consumed natural resource after water and the most extracted material,' Dr Biju Kumar's report said.
Over the past two decades, aggregate consumption has tripled, reaching an estimated 40 to 50 billion tons annually, a rate of extraction far exceeding natural replenishment.
The demand for sand in India has risen sharply thanks to urbanisation and infrastructure development.
Sand deposits are found within Indian territorial waters, extending up to 12 nautical miles from the coast and beyond in the country's Exclusive Economic Zone (EEZ).
Surveys by the Geological Survey of India (GSI) have revealed substantial deposits of construction-grade sand at various locations including Ponnani, Chavakkad, Kochi, Alappuzha and Kollam (all in Kerala).
These are at depths ranging from 22 to 45 metres. As mentioned earlier from the PIB statement, the GSI has identified over 745 million tons of construction-grade sand off the Kerala coast and 79 million tons of heavy mineral placers in the inner-shelf and mid-shelf regions off Odisha, Andhra Pradesh, Kerala, Tamil Nadu and Maharashtra.
These deposits contain sand with purity levels ranging from 80 to 96 per cent and clay content between 4 to 20 per cent.
Originally sourced from rivers, the sand has undergone marine processes, making it suitable for use in construction after desalination.
According to Dr Biju Kumar's report, in the first phase of mining sand, extraction was to be carried out in Ponnani, Chavakkad, Alappuzha, Kollam North and Kollam South with interested mining companies required to submit expressions of interest by February 18 and the tender process completed by February 27, 2025.
There are two major problems here. The first is the long-known rich biodiversity of the Kollam (Quilon) Bank aka Kollam Paaru.
It is one of the most productive fishing zones on India's southwest coast. It is the seabed between 08'N and 09'N latitudes, within a depth range of 275 to 375 metres.
Falling between Kollam and Alappuzha, this region hosts deep sea prawns, shrimps, lobsters, sardines, mackerel and export-oriented squid varieties.
The Kollam bank is also significant for its submerged deep water coral reefs.
All corals are included in the Schedule 1 of the Wildlife (Protection) Act of India.
Surveys by the Fishery Survey of India have shown that the deeper offshore waters of Kollam are also rich fishing grounds.
The region's high productivity may be linked to the extended effects of upwelling, driven by drift currents extending towards the Wadge Bank further south (Wadge Bank is close to Kanyakumari).
Additionally, the shallow waters off Kollam have rocky reefs that serve as both feeding grounds and nurseries for juvenile fish.
Traditional fishers depend heavily on the rich fish stocks associated with these rocky reefs, for their economic survival.
The second major problem has two subsets. The first subset is linked to the ecological impact of mining for sea-sand.
Mining disturbs sediments in the region (at sea, such disturbance is not limited to where the mining is happening; it spills over into the neighbourhood) causing high turbidity and reduced light penetration.
'Light is crucial for phytoplankton, the primary producers in marine ecosystems, which support a large biomass of zooplankton and in turn, higher trophic levels. The disruption of this process negatively impacts the marine food web and species distribution,' the report said.
Mining also directly disturbs the sediments that serve as habitat for various marine organisms facilitating interactions that sustain seafloor biodiversity.
The disturbance caused by mining can disrupt the feeding and breeding of marine species in the deeper waters off Kollam; it can also upset the migration of species like 'karikkadi' shrimp affecting the livelihood of local fishers.
Further, mining can interfere with sea-current patterns, trigger water pollution, affect nutrient availability, cause decline in dissolved oxygen, potentially produce harmful algal blooms (caused when there is high nutrient loads in disturbed waters), increase the vulnerability of shoreline communities to storm damage and potentially impact the creation of mudbanks that sustain high fish populations (potentially because the impact of sand mining on mudbank formation is scientifically unclear still).
'The long-term impact of deep-sea and offshore mining on the global carbon cycle are still not fully understood but could be significant,' the report added.
The crux of the problem
The second subset captures the crux of this mining controversy in Kollam.
While I could not get an idea of how far from shore the mining location is (whether it is well beyond the 12 nautical miles limit of territorial [state jurisdiction] waters or close to it) courtesy, senior officials at the directorate of mining and geology staying unreachable; Dr Biju Kumar said that the location despite distance from shore, lay in relatively shallow waters.
As the portrait of the region from the scientist's report would show, depth (both shallow and deep) is important for the rich marine life ecosystem off Kollam and the fishers dependent on it.
Fishers go wherever they can access potential catch with the equipment at their disposal.
Artisanal fishers typically work in shallow waters.
Viewed so, mining in shallow waters (with potential damage to marine ecosystem), even if it be beyond the 12 nautical miles territorial limit will interfere with the livelihood of artisanal fishers because of the tendency of fishers to go wherever the depth is manageable for their fishing crafts and fishing equipment.
The exact location of mining also matters when it comes to deciding whether the nearest state is eligible for mining royalties or not.
Typically, a state gets royalty if the mining is in territorial waters.
Beyond, the 12 nautical miles limit, royalties accrue to the Centre.
The PIB statement on the 2023 amendments to the offshore mining Act says clearly: 'Royalty, auction premium and other revenues from the production of minerals from offshore areas shall accrue to the Government of India.'
The feeling among those I spoke to, was that Kerala may get some royalty if the location is not far beyond the limit of territorial waters, or maybe, it will get nothing.
Here too, clarity could not be officially had.
Another angle here is that given over-fishing and the impact of climate change on the movement of fish stock, states would like to see their offshore jurisdiction limit extended.
Royalty matters because in addition to being income for a state, it is also part of potential financial resources to compensate those affected by big projects.
A state that gets no royalty would look like a complete loser.
All the above is without mentioning something else that has been puzzling observers.
The desalination process of so many tons of sand excavated from the seabed typically requires fresh water.
How is that proposed to be done and from where would the fresh water needed be sourced in times of Kerala's climate gone haywire with scorching summers also now around to cope with?
Premachandran said that although the Kerala assembly has passed a unanimous resolution and the central government has to take note of it, the resolution does not put a stop to the tender process currently underway.
According to him, its completion is now set for April.
Speaking to me at the archbishop's house at Vellayambalam in Thiruvananthapuram, Fr Pereira was clear that sea mining has its share of detrimental effects.
It is best avoided in environmentally sensitive areas.
His minimum demand was to see a comprehensive study on the impact of sea mining in Kollam done by a reputed and trustworthy agency along with the government speaking to all stakeholders concerned and listening to what they have to say.
If as critics point out, the environmental impact assessment study was commissioned only after the auction process got underway with not all the stakeholders getting to know of it, then the government has already compromised the trust it could have enjoyed with Kerala's public including its coastal communities.
These are very real worries because although there has been the push for a Blue Economy internationally and some countries have gone in for sea mining, it is an evolving area as regards proper understanding of impact and consequences.
In some instances, consequences have been reportedly serious.
In direct proportion to how rapacious industrial consumption becomes, the more wary becomes other stakeholders in the larger ecosystem.
Besides the question of whether sand should be mined at all in the seas off Kollam, what we are seeing is a picture of poor trust between the government and other stakeholders.
Shyam G Menon is a freelance journalist based in Mumbai.
Feature Presentation: Aslam Hunani/Rediff.com