Submission to the Forest Advisory Committee, Ministry of Environment and Forests urging them not to grant Forest Clearance to Kikvi Drinking water supply Dam coming up in Trimbakeshwar, Nashik,  in the absence of relevant studies and justifications. The project  will submerge  nearly 1000 heactres of agricultural and forest land in Western Ghats, and there is no justification provided that Nashik needs a new source. The city already takes water from 4 dams, is building a fifth weir and is allegedly supplying more drinking water to help  India Bulls Thermal Power Project.

 

To,

Chairperson and members,

Forest Advisory Committee

Ministry of Environment and Forests

Delhi

 Subject: Concerns about Kikvi Drinking Water Supply Project, Brahmanwade, Nashik

 Respected Chairperson and Members,

We see from the agenda uploaded on MoEF Website that the FAC will be considering proposal of Kikvi Drinking Water Supply Dam in BrahmanwadeVillage in Nashik, Maharashtra diverting 172.46 hectares of Forest in its upcoming meeting on 11^th and 12^th July 2013. The entire submergence of the project is a massive 933.98 hectares in the Northern Western Ghats. Partners from SANDRP visited the site on the 7^th July 2013, studied the ecology and talked with the local farmers to be affected by the project. Based on the visit and analysis of Site Inspection report (SIR), FormIA and Factsheet uploaded on MoEF Website, we would like to highlight some strong concerns about this proposal:

1. No evidence that Nashik needs a new source of drinking water: The Site Inspection Report of the Additional Principal Chief Secretary of Forest Department in June 2013 simply says “The project should be encouraged as it is a drinking water project”.

This is a strange statement coming from Forest Department, entrusted with protecting the dwindling forests of the country. There has been no supporting evidence provided by the Additional PCCF, Western Zone that Nashik actually needs this project for its drinking water supply needs.

In fact, there is no information provided in the Site Inspection Report, FormIA or the Fact sheet justifying the need for this project.

There is no estimation of Nashik’s current water demand, existing drinking water sources, future water demand, options assessment, demand management explored, etc.

In the absence of any such studies, how can Forest Department simply “encourage” a project to divert 172.47 hectares of forest (it will also submerge 776.52 hectares of agricultural land) only because it is a drinking water supply project? This is unacceptable and FAC should ask all the concerned officials to apply their mind before accepting to such proposals, including looking at the justifiability of the proposal and assessment that given project is the best option. This is important for all projects, but particularly so for a project that does even have environmental and social impact assessment.

2. Nashik has a number of existing drinking water supply projects There are already three dams in the upstream of Nashik city on the river Godavari and its tributaries. Nashik Municipal Corporation has a reservation for drinking water in each of these dams. These include the Gangapur Dam, Kashyapi Dam and Gautami Dam. Kashyapi and Gautami Dams were built to supplement Gangapur Dams water storage because it was silting up[1]. Kikvi project is also being pushed stating the same reason that Gangapur dam is silting up.

In addition, Nashik Municipal Corporation has a reservation of 350 million cubic feet on the Darna Dam, 28 kms downstream Nashik.

Nashik Municipal Corporation (NMC) is also building one more weir on DarnaRiver with a capacity of 144 million cubic feet. [2] There is no study to show that Nashik has been using all these available resources efficiently and that it is taking necessary steps to reduce the siltation of the Gangapur dam effectively and also considering the desilting of the reservoir.

It is clear that NMC already has many sources to supply drinking water. With efficient water supply, demand management, effective use of rainwater harvesting and gray water recycling (which have been compulsory since 2009, but which are yet not implemented effectively) the water demand of NMC may come down. These options should be explored first rather than a new dam project that is ecological, economically and socially costly. Forest Clearance to such projects should not be given in the absence of supportive studies.

3. The City Development Plan prepared by Nashik Municipal Corporation (NMC) under the JNNURM does not consider a new drinking water source in its Phase I work till 2016. Why then is there a hurry to divert forests and submerge agricultural lands? (http://nashikcorporation.gov.in/pagedetail.aspx?id=22&mid=69). Even for the phase beyond 2016, unless there is credible study that shows that Nashik is using its current resources efficiently and has exhausted all available options, there should not be any consideration for the current project.

4. No exploration of desilting Gangapur Dam While the Form IA and Factsheet claim that the project is needed as capacity of Gangapur Dam is decreasing due to siltation, it logically follows that the first attempt should be to arrest siltation and desilting of the reservoir. Gangapur Dam also provides irrigation water. Hence, desilting should be explored seriously. During the current 2012-13 drought, Government had undertaken desilting of some reservoirs in Maharashtra. In fact, the Chief Minister himself said that a capacity of 8 TMC has been added in Pune division due to desilting projects.[3] Thus, desilting should be carried out even before discussing new costly sources.

5. Wrong representation in Form IA FormIA states that there is no dependence on forests of the communities and the project does not involve any rehabilitation. This is incorrect.

The entire project involves submergence of 933.98 hectares of land, with 761.52 hectares of agricultural land. This also includes farm shelters and temporary houses of farmers. Farmers and tribals in this region depend heavily on the forests for a number of produce. Hence, the claim in FormIA that there is no dependence on forests is incorrect and should not be accepted.

In fact, there is a strong opposition to the project by villagers of nine villages which are losing agricultural lands to this project.

6. Fact sheet claims lands under submergence and not irrigated: As our partners witnesses this is a misleading statement. Large proportion of land under submergence is irrigated by groundwater through private shallow wells sunk by farmers. This irrigated area will also be submerged, along with the wells.

7. Over developed region The SIR, Form I and Fact sheet mention that there is no alternative alignment of Kikvi project possible due to existing projects in the upstream and downstream. This gives an idea of the overdeveloped region in terms of projects. One more project in this area will add to the cumulative impacts of the existing projects on ecology as well as sociology, but there is no cumulative impact assessment available.

8. Violation of Forest Rights Act: While it is clearly stated by the State Government in the Fact Sheet that: “10. The project authority has partially fulfilled the compliance under the Schedule Tribes and Other Traditional Forest Dwellers (Recognition of Right) Act, 2006.  The compliance is not in proper format.” (emphasis added), it is surprising to see that the Form IA mentions that the project authority has fulfilled the compliance under Forest Rights Act 2006!

Thus, Forest Clearance should not be recommended unless the status of FRA compliance is known clearly.

9. Restoration of Forests needed, not further diversion The SIR by the Additional PCCF, Western Zone, notes that submergence of 1960 trees “ will have no ill effect on the area, in fact it will have positive impact due to water body”. This is a shocking statement to be coming from the Forest Department. How can loss of 1960 trees have no ill effect? As for the positive impact due to water bodies, this is a baseless claim for a region that has many water bodies and receives 2600-3000 mm rainfall annually.

The further justification given to divert forests is that the forest is pruned and lopped with low density. When partners of SANDRP visited the site on the 7^th of July 2013, they found that the region is poorly managed by the Forest Department, with no security. This has encouraged encroachment and lopping. Instead of addressing these problems and restoring the forests under their control, Forest Department is using this as a justification to further divert forests. This argument is not acceptable.

10. No Environment Impact Assessment, Public Hearing or Environmental Clearance process: Due to an unsound and arbitrary exclusion in the EIA Notification 2006, drinking water supply projects are excluded from the ambit of EIA, Public hearing, Environmental Clearance and hence, Environment Management Plan and environment monitoring. The current project will submerge a total of 933.98 hectares of land without these checks and balances and hence, the FAC needs to consider this project very seriously. Not only will this affect the forest, it will also affect the agrarian economy of the region. FAC should first demand a project specific EIA, SIA and also cumulative impact assessment before even considering this project.

11. No mention of environmental flows: The proposed project will be entirely diverting the water of River Kikvi for drinking water use through Gangapur Dam in Nashik. Such a complete diversion of river has a profound ecological and social impact on the downstream. The issue is serious here as this region forms part of the Western Ghats. Hence, there has to be a study of the environmental flows that should be released from the project in the downstream for social and ecological needs.

As the project will not be applying for an Environmental Clearance, FAC needs to pay serious attention to these aspects.

We hope that the Forest Advisory Committee considers this project seriously and not simply as a drinking water supply project. Nashik Municipal Corporation has been reported to be supplying more drinking water to Nashik city than its need. This is allegedly to benefit the India Bulls Thermal Power plant which is based on the treated sewage water from Nashik Municipal Corporation.[4]

In this scenario, FAC should not recommend a forest clearance to this project, with no justification. The points becoming more pertinent considering that this is a project which has a potential to drown nearly 1000 hectares land in the Northern Western Ghats without any project specific EIA, SIA or cumulative impact assessment without any options assessment or study to show that Nashik is using its current resources efficiently.

Looking forward to a point-wise response to the issues raised above.

Thanking You,

Yours sincerely,

Parineeta Dandekar, SANDRP, Pune

Jui Pethe, Independent Botanist and Agriculturist, Trimbak, Nashik

Amit Tillu , Independent Wildlife Researcher and Agriculturist, Trimbak, Nashik