This post is based on a submission made by SANDRP and our colleagues on the HLWG Report on Western Ghats. 20th May 2013 is the last date to submit comments on this. Comments need to be sent to: email@example.com. We request groups and individuals to make as many submissions as possible.
Comments on HLWG Report with a focus on Water issues
Date: May 20, 2013
Mrs. Jayanthi Natarajan
Union Minister of State (IC)
Ministry of Environment and Forests
Government of India
Email: firstname.lastname@example.org, email@example.com
Dr. V Rajagopalan
Ministry of Environment and Forests
Government of India
Dr. Amit Love,
Ministry of Environment and Forests
Dear Mrs. Jayanthi Natarajan and Dr. Rajagopalan,
SUB: Comments on the High Level Working Group Report with respect to water sector
This is in response to announcement posted on MoEF website about submitting comments on the HLWG report under the Chairpersonship of Dr. Kasturirangan. These comments mainly deal with water in Western Ghats: One of the most critical issues for Western Ghats States.
Unfortunately, we have to note that recommendations of the HLWG Committee in response to WGEEP Report as well as some of HLWGs omissions and commissions are detrimental to the well-being of rivers, wetlands and dependent communities in the Western Ghats and hence, for related sectors like ecology, water supply, irrigation, hydropower, etc. This is elucidated in the following points:
- HLWG does not comment on any other issue related to water except hydropower:
While the Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamilnadu are facing multiple issues with respect to rivers, drinking water, irrigation, loss of biodiversity and livelihoods, dam-induced displacement, etc., the only issue HLWG report has commented upon is Hydropower. The WGEEP report has dealt with a number of issues related to the water sector from democratic community driven bottom up governance, watershed development, opposition to large dams in ESZ I and II, drinking water, fisheries, etc. However, the HLWG does not comment on any of these recommendations of the WGEEP, nor does it offer its own position on these. This is a serious lacuna in the HLWG Report.
In the absence of such recommendations, we request that MoEF adheres to WGEEP recommendations.
- HLWGs recommendations about Hydropower are ad hoc, unscientific and misleading
- HLWG claims that all Hydropower is “renewable and clean.”
This is a completely incorrect statement and it’s surprising to see that it comes from HLWG. The world over, the myth of Hydropower as clean source of energy has been busted., Hydropower projects have huge impacts on environment, ecology, forests, rivers, biodiversity and livelihood security of the people. Studies have proved that methane emissions from reservoirs formed by hydropower dams in tropical countries can have significant global warming potential, methane being about 21 times more potent global warming gas than CO2. Dams emit methane at every draw down. With tropical forests in the Western Ghats (WG) under submergence and otherwise destruction by such projects, this threat is even more serious. Already WG has some of the biggest hydropower plants in the country including the Koyna, Bhandardara, Ghatghat HEPs and three Tata HEPs in Maharashtra, Linganmakki, Gerisouppa, Bhadra, Tungabhadra, Upper Tunga, Talakalale, Kabini, Harangi, Chakra, Supa, Varahi, HEPs in Karnataka, Idukki, ldamalayar, Lower Periyar, Poringalkuttu, Sholayar HEPs in Kerala and Bhavani HEPs in Tamil Nadu. All these projects have not only contributed to greenhouse gas emissions, but have also adversely affected communities, forests, rivers and ecosystems in Western Ghats. There are numerous pending cases of rehabilitation from these dams (for example Koyna in Maharashtra) till date involving tens of thousands of people and communities in many areas are still suffering from erratic water releases from these projects (downstream communities near Jog Falls d/s Linganmakki).
Hydropower dams in WG are in many cases transferring water across the basin for power generation, making it unavailable of the original basin and its inhabitants (For example: Interbasin transfers from Koyna and Tata Hydropower dams in Maharashtra). Every hydropower project has finite life. Thus, for the basin dwellers and everyone else, Hydropower not much renewable either.
HLWG is not justified in giving a ‘clean and renewable’ certificate to hydropower.
- HLWG allows Hydropower projects in ESAs while not looking at performance of existing projects
While the WGEEP did not allow large dams and hydropower projects in ESZ I and II, HLWG has allowed hydropower projects in its demarcated ESAs. This is unacceptable. Western Ghats are already ravaged by dams and at least the areas of high biodiversity value should now be protected from the same onslaught. But the HLWG has rejected WGEEP recommendations about this. While doing so, they have not looked at the performance of the existing HEPs in WG. SANDRP has been studying performance of HEPS in India for some time now based on generation data from Central Electricity Authority. The performance of existing hydropower plants in WG is dismal as can be seen below:
- In Koyna Basin, the per MW generation in 2010-11 has dropped by a huge 56.79% from the highest per MW generation achieved in the year 1994-95.
- In Kali Nadi projects, the per MW generation has dropped by 46.65% from the highest per MW generation achieved in 1994-95
- In Sharavathi Basin projects, per MW generation in 2010-11 has dropped by 37.60% from the highest per MW generation achieved in the year 1994-95
- Same situation is true for most other hydropower projects.
- Most of these projects are performing far below the level at which the projects were given techno-economic clearances.
- There is no assessment as to how much of the generation from such hydropower projects is during peaking hours. Nor is there any attempt at optimising the peaking power from these projects.
It is clear that there is huge scope to make the existing projects more efficient, rather than destroying ESAs in WG with more projects.
We request that in line with WGEEP report, large dams should not be permitted in ESAs of Western Ghats.
- Recommendation about mitigating impacts of Hydropower are extremely weak
- The HLWG has recommended 30 % of lean season flow as the minimum flow throughout the year as a conditionality for allowing hydro power projects in the ESA. This is contradictory to the recommendation for ecological flows by the HLWG. Ecological flows means trying to mimic the natural flow regime in the river as far as possible and that would include arriving at different seasonal flows based on studies and consultation with the river communities and other stakeholders, using the Building Block Methodology which even the Inter Ministerial Group on Ganga Basin has said is the most appropriate for India. Moreover, the IMG has recommended 50% releases in lean season flows, applicable for all existing projects. MoEF should accept these norms immediately for all existing projects.
The MoEF should be recommending ecological flows / environmental flows as in the WGEEP report and not minimum environmental flows and this should be determined through holistic methodologies like Building Block Methodology and local participation.
- The HLWG recommendation of 3 km minimum distance between dams is totally ad hoc, arbitrary and hence unacceptable. Firstly, the HLWG should have mentioned min 3 km of flowing river between projects. The minimum distance is river specific and would depend upon a basin level study of the river including the altitudinal profile of the river, the riparian forest status, the aquatic habitats and biodiversity, the present dependability and many such criteria. More significantly, the cascade hydropower dam menace which is destroying rives in Himalayas need not be replicated in western ghats. We would like to reiterate that no large dams should be allowed in the ESA of WG.
The MoEF should recommend for arriving at river specific studies while accepting 5 km of free flowing river between projects as minimum distance of free flowing river between projects. The best case is not to allow any further large dams in Western Ghats.
- The HLWG does not stress the need for Environmental Clearance for Mini hydel Projects
Hydro projects less than 25 MW are currently exempt from Environmental Clearance due to a dangerous omission in the EIA Notification 2006. WG is currently facing a severe threat due to a flood of these unplanned cascades of Mini Hydel Projects. Ecosystems and communities in rivers like Netravathi, Kumaradhara, Krishna and Cauvery are facing impacts of these projects, many of which are fraudulent. Netravathi has more than 44 mini hydel projects planned and under operation. Kerala has plans to set up around 100 mini Hydel projects on its rivers. The threat of these projects on river systems in Western Ghats is so high that in March 2013, the Karnataka High Court, has banned any new mini hydel projects in Karnataka Western Ghats.
WGEEP had recommended no mini hydel projects in ESZ I and II. HLWG has not done this. While the HLWG makes a rather vague statement “There is a need to redesign and reevaluate small hydropower projects – below 25 mw as these often have limited impact on energy generation and can lead to huge impacts on ecology’, it has not recommended that these projects should need an EIA and EC process, like it has said for Wind Energy. This is a very serious omission. SANDRP and many organizations have written about this to the MoEF several times.
The MoEF should amend the EIA Notification 2006 and include all hydel projects above 1 MW in its purview.
- The HLWG does not stress the need of Environmental Clearance (EC) for Drinking Water and Industrial supply dams
HLWG has not looked at water as a sector, but has only confined itself to hydropower. This has resulted in several loopholes. Many dams are being constructed in Western Ghats for Drinking Water and Industrial water supply. These are also exempt from EC process as per the EIA Notification 2006. Dams like Kalu, Shai, Balganga, Khargihill, Pinjal, Gargai are set to submerge more than 6000 hectares of forest in ESAs and Protected Areas in Northern Western Ghats in Maharashtra.
WGEEP Report had recommended no large dams in ESZ I and II, but the HLWG does not talk about these dams at all. Their impacts on WG forests and communities are entirely ignored. This is another serious lapse of the HLWG report.
The MOEF should amend the EIA Notification 2006 to include all large dams, irrespective of the purpose, including drinking and industrial water supply dams in its purview. No large dams should be planned in ESA of Western Ghats.
- HLWG does not recommend eflows from existing projects
Several hundreds of Irrigation, water supply, hydropower dams have transformed the nature of rivers and dependent communities in Western Ghats. While the WGEEP Report mentioned maintaining eflows from existing projects, the HLWG does not make any recommendation for eflows from existing projects.
Hydropower projects in Karnataka like Kali, Linganmakki have affected communities and ecosystems in the region, have driven some species to extinction. There is an urgent need to restore eflows in all WG rivers.
The MoEF should recommend that eflows should be assessed with holistic and participatory methodology like BBM and recommend e-flows for all dammed rivers in Western Ghats with time limit of one year.
- HLWG does not apply its mind to dam decommissioning
The HLWG has chosen to ignore the recommendations on dam decommissioning. While the states have rejected the recommendation the MoP (Ministry of Power) and Central Electricity Authority has noted that dam decommissioning in a phased manner is worth considering.
There are several irrigation and hydropower dams in the Western Ghats which are severely underperforming or incomplete after two decades, or more than 100 years old, and/or unsafe. For example, several experts have opined than large irrigation projects in Konkan region of Maharashtra are severely underutilized. Tillari Interstate Project between Maharshatra and Goa which has come up affecting a wildlife corridor and which has still not rehabilitated its affected population, has a created irrigation potential of 7,295 hectares in Maharashtra of which farmers are utilizing just 162 hectares, according to the Govt Of Maharashtra’s 2012 White Paper on Irrigation Projects in Maharashtra. This underlines the redundancy of large irrigation projects in the WG.
The HLWG had an opportunity to relook at such projects, which it has not done. The HLWG could have noted that the state governments and the MoEF and MoP should start the process of evolving parameters / criteria towards the process of dam decommissioning.
The MoEF may please recommend the same.
- HLWG does not recommend free flowing rivers for WG
Rivers in Western Ghats are repositories of biological, ecological and cultural diversity. Rivers in WG harbor high endemism and diversity in freshwater fish. They also house several Sacred groves at river origins, river fish sanctuaries, etc., protecting rivers and fish. The freshwater biodiversity remains the most fragmented among all biodiversity and HLWG has taken no note of this state and further risks that freshwater biodiversity faces. The WGEEP had wisely followed a graded approach in tune with the ecological connectivity of river ecosystems. ln the HLWG approach, stretches of rivers would flow out of the natural landscape into the cultural landscape which is open to indiscriminate development and the chance for their restoration or protection would be completely lost out. A river cannot be protected in pieces like this.
Looking at the pressures from dams and water abstractions, there in an urgent need to conserve ecologically, culturally and socially important rivers in their free-flowing condition. This approach is well accepted globally and several countries have created specific legislations for protecting free flowing rivers. It seems that the IMG Committee on Upper Ganga, in which Ms. Sunita Narain (Member of Kasturirangan Committee), was also a member has recommended that some six tributaries of Upper Ganga basin should be kept in pristine state. While rejecting WGEEPs recommendation about dam decommissioning or dam free rivers in the ESZs, HLWG has not recommended keeping even a single river in Western Ghats in its free flowing condition.
MoEF should identify ecologically, culturally and socially important rivers, based on community and ecological knowledge and conserve Heritage Rivers of Western Ghats in their free flowing condition for the current and future generations.
- HLWG allows Inter basin transfers in Western Ghats, without any justification or studies
The HLWG has agreed to inter basin transfers toeing the claims of some of the states. There are ample instances of failed interstate – inter basin transfers in the Western Ghats rivers which have turned into permanent scenes of conflicts like the famous Mullaperiyar, Parambikulam Aliyar, Siruvani interstate inter basin transfers between Kerala and Tamil Nadu. The HLWG while acknowledging the need for ‘ecological flows assessment’ in rivers has failed to note that in all these inter basin transfers, the river / tributary has been completely diverted and has lost its ‘ecological flows’. The HLWG could have recommended a cumulative impact assessment of the existing inter basin transfers which would reveal the ground reality.
HLWG seems to have accepted the contention of states like Maharashtra: “This (stopping IBT) would be a problem, they explained, as many regions of the Western Ghats lie in the rain shadow area and need water to be diverted for irrigation and drinking.”
Reality is that, ALL the interbasin transfers happening in Maharashtra currently (through Koyna and Tata Hydro power projects, an amount more than 4 Billion Cubic Meters Annually) are transferring water FROM the rain shadow area of Krishna and Bhima basins TO water surplus regions in Konkan. If HLWG was concerned about water supply for rain shadow regions, it would have at least recommended that this transfer from deficit area to high rainfall area be immediately reviewed and reversed in a time bound manner. It has chosen not to, showing its complete ignorance of ground reality or its completely pro government and pro vested interests bias.
The MoEF should retain the recommendation for no more inter basin transfers as in the WGEEP report and ask for immediate review of transfer of water from deficit basins to high rainfall areas.
- HLWG allows hydro projects in first and second order streams
The HLWG has not said no to hydro power projects in first and second order streams in ESA. Meanwhile the MoP, CEA and WAPCOS all agree that hydro power projects should not be permitted in these highly ecologically sensitive areas which are the ‘origin’ of Western Ghats Rivers.
The MoEF should retain the recommendation for no run of the river schemes in first and second order streams as in the WGEEP report.
- HLWG offers no comments of on several water sector recommendations of WGEEP which have been supported by State Governments
Kerala and Maharashtra have accepted many of the recommendations of the WGEEP in water sector (page 14 section 2.3 – point 9) like catchment area treatment plan, protection of high altitude valley swamps, water conservation measures, rehabilitation of mined areas, improved river flows etc. It is surprising to note that the HLWG is silent on these very important measures and has not even endorsed these acceptable recommendations which can significantly contribute towards improving water availability in the Western Ghats.
The MoEF should follow these recommendations of the WGEEP.
- HLWG takes an extremely biased stand about Athirappilly and Gundia Hydropower projects, rejected by the WGEEP
The WGEEP had categorically stated that the Athirappilly and Gundia Hydropower project should not come up in Western Ghats, looking at their huge impacts on biodiversity, several studies by local organisations and local opposition. However, ignoring all these, the HLWG has taken a very pro project stand on these projects, stating that they can be considered with some vaguely due process, which the state government would be happy to show they have followed it on paper. This is entirely unacceptable.
The MoEF should not allow Athirappilly and Gundia HEPs looking their impact on ecology and communities and in face of the strong local opposition that they are facing.
The WGEEP process and report initiated a robust discussion about the paradigm of development and conservation in Western Ghats. Water and Rivers is a cross cutting issue connecting ecosystems and communities, rural areas and urban centers, providing goods and services and supporting freshwater biodiversity, which is most threatened currently.
A proactive position on conserving rivers in Western Ghats will go a long way in protecting and conserving myriad livelihoods and ecosystems that thus depend of them.
We hope the MoEF considers the recommendations made above about the WGEEP and HLWG Reports and helps conserving rivers of the Western Ghats for people and ecosystems urgently. The HLWG Report cannot be accepted the way it stands presently. As a step in this direction, we also suggest that WGEEP should get a formal chance to respond to the points raised about it in the HLWG.
Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune (firstname.lastname@example.org , email@example.com)
Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (firstname.lastname@example.org)
Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, Maharashtra (email@example.com)
Dr. T.V. Ramchandra, Energy & Wetlands Research Group, Centre for Ecological Sciences, IISc, Bangalore (firstname.lastname@example.org)
Janak Daftari, jalbirdari, Mumbai, Maharashtra (email@example.com)
Sujit Patwardhan, Parisar, Pune, Maharashtra (firstname.lastname@example.org)
Dr. Nilesh Heda, Samvardhan, Vidarbha, Maharashtra (email@example.com)
Nisarg Prakash, Nature Conservation Foundation and Nityata Foundation, Bangalore, Karnataka (firstname.lastname@example.org)
Mrinalinee Vanarase, Iora Consultants, Pune, Maharashtra (email@example.com)
Shankar Pujari, President, Nivara Bandhkam Kamgar Sangh, Sangli, Maharashtra (firstname.lastname@example.org)
Damodar Pujari, SANDRP, Pune, Maharashtra (email@example.com)
Saili Palande-Datar, Kalpavriksha, Pune, Maharashtra
Following Members from Energy and Wetlands Research Group, Centre for ecological Science, Indian Institute of Sciences:
- Dr. M.D. Subash Chandran
- Dr. Prakash Mesta
- Dr. Uttam Kumar
- G R Rao
- Mahima Bhat
- Vishnu Mukri
- Sreekanth Naik
- Balachandran C
- Boominathan M
- Bharath H Aithal
- Bharath Settur
- Vinay S
- Ganesh Hegde
- Anindita Dasgupta
- Arun D T
- Vishnu Bajpai
- Gouri Kulkarni
- Sudarshan Bhat
- Durga Madhab Mahapatra
- Ashwath Naik
- Sowmya Rao
One thought on “Comments on HLWG Report submitted to Ministry of Environment and Forests”
Excellent work SANDRP, more power to you :).