Those who have written include eminent personalities like Former Water Resources Secretary: Dr. Ramaswamy Iyer, Former Ambassador of India: Ms. Madhu Bhaduri, Former Secretary of Power and Principle Advisor to Planning Commission: Dr. EAS Sarma, Former member of MoEF’s Forest Advisory Committee: Dr. Ullas Karanth, Head of IISC’s Centre for Ecological Sciences: Dr. TV Ramachandran, Head of People’s Science Institute: Dr. Ravi Chopra, experts from energy field, as well as activists, fisheries experts, scientists and importantly, representatives from affected communities
Letter sent to MoEF is below:
1. Smt. Jayanthi Natarajan,
Union Minister of State (IC) of Environment and Forests,
Paryavaran Bhawan, Lodhi Road, New Delhi, email@example.com
2. Dr. V Rajagopalan,
Union Ministry of Environment and Forests, New Delhi, firstname.lastname@example.org
3. Mr. Maninder Singh
Ministry of Environment and Forests, New Delhi, email@example.com
4. Mr. Ajay Tyagi
Union Ministry of Environment and Forests, New Delhi firstname.lastname@example.org
5. Mr. B. B. Barman
Director (IA) River Valley Projects,
Union Ministry of Environment and Forests, New Delhi, email@example.com
Please include Small Hydel Projects (1-25 MW) under the purview of EIA Notification 2006, considering their serious impacts on ecosystems and communities.
Respected Madam Minister and office bearers of the MoEF,
We want to record our concern about serious impacts of small hydro projects on communities and ecosystems. Several groups from us have written to you in the past to urgently amend the EIA Notification 2006 and to include Small Hydel Projects in its ambit. Looking at the serious impacts of these projects, MoEF could have suo motto taken this initiative. But that has not happened, despite several amendments in the EIA Notification down the years.
SHPs can have and are having severe impacts on communities and ecosystems. This is significant as SHPs are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restrict itself to projects above 25 MW. The local communities are specifically affected as they do not have a platform to voice their concerns.
To highlight some of the impacts of SHPs:
Þ 70 SHPs in Karnataka under scanner following HC orders Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of SHPs on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats, bringing at least 70 SHPs under scanner, 40 in Hassan district, the rest in Mandya, Chamarajanagar and Uttara Kannada districts.
Þ Karnataka HC no to SHPs in W Ghats In Feb 2013, the Karnataka High Court banned SHPs in Western Ghats, following a petition filed by Western Ghats Forum.
Þ Uttarakhand Uttarakhand had earlier cancelled as many as 56 SHPs due to irregularities.
Þ Western Ghats reports Considering the impacts of small hydro projects, the Madhav Gadgil Panel on Western Ghats recommended that in Ecologically sensitive zone 1, only projects below 10 MW with max height of 3 m and not involving forest land be taken up. In ESZ 2, projects upto 25 MW can be taken up only if dam height is below 15 m. This shows the nuanced approach that is required for small hydro projects. The panel also recommended that WGEA should include small hydro projects under EIA notification. Even the Kasturirangan committee has recommended that hydropower projects, including SHPs be allowed only on condition that 30% eflows are released, less than 50% of the river length is destroyed and there is 3 km free flowing river between projects. It has also recommended that hydropower projects, including small hydro projects should required environment clearance in the Ecologically Sensitive Area.
Þ Bhagirathi ESA In the notified Bhagirathi ESA in Uttarakhand, the MoEF itself has implied that Hydro projects only of below 2 MW installed capacity can be taken up.
Þ BWSSB asks for stoppage of SHPs In March 2013, Bangalore Water Supply and Sanitation Board (BWSSB) asked the Karnataka Power Corporation Limited (KPCL) to stop power generation from four mini hydel projects on Cauvery River as it was affecting drinking water supply to Bangalore.
Most Small Hydro projects (1-25 MW) are grid connected, and local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitats and submergence.
Some examples in this regard are given here:
Þ In Himachal, communities have protested strongly against 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests.
Þ Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely bio-diverse forests, plantations and houses. This is being strongly opposed by local communities.
Þ Greenko’s Perla and Shemburi Projects, Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects with a common dam. In the latter case, villagers assumed that the power canal is actually an irrigation canal for their fields. They only realised that they were alienated from their river after they were banished from approaching the canals.
Þ Maruthi Gen projects, also in Karnataka, were not only clubbed together, but also hid their significant impact on forest land.
Þ Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands. 24.75 MW Thangarabalu SHP on Krishna in Karnataka entails a dam of more than 22 meters in height, but has not divulged any data of submergence to villagers or Forest Department.
Þ 3 MW Beedalli MHP in Karnataka is on the boundary of the Pushpagiri Sanctuary and will severely affect wildlife, but does not envisage eflows release, fish passage or environmental mitigation measures
Þ 15 MW Barapole MHP in Kerala is affecting reserve forests in Karnataka. An earlier such project which was affecting Brahmagiri Sanctuary was opposed and cancelled due to pressure from conservation groups in Karnataka.
Þ String of more than 98 mini hydel projects in various stages of operation, commissioning, construction and planning on the Cauvery in Karnataka has affected elephant corridors and movement.
Þ Many mini hydel projects along the Cauvery in Karnataka are adjoining the Cauvery Wildlife Sanctuary, violating the 10 km buffer zone, while also encroaching on forest land.
Þ In Himachal Pradesh, several hydel projects have been built on streams that are on ‘negative list for hydel projects’. Fisheries department wanted in-situ conservation of fish in these streams.
Þ The 15 MW Om Power project near Palampur in Himachal Pradesh has caused extensive loss of forest cover and has disrupted irrigation and drinking water supply to downstream areas due to indiscriminate muck dumping.
Þ The 1.5 MW Pakhnoj Nala Power project would impact the flourishing apple economy of 19 villages in Kullu District of Himachal Pradesh by disrupting irrigation supplies. The local people have been strongly opposing the project and the matter is pending in the court.
MoEF and NCDMA: National CDM Authority is under the MoEF and has been giving Host Country Approvals to CDM applications of several small hydel projects. Many of us have been writing to NCDMA and MoEF, providing clear evidence of the sham in CDM applications of projects and their validation reports. But the MoEF has never taken a notice of this. In fact, the MoEF certifies that these projects have positive impact on sustainable development without checking the ground situation, when the impacts of some of these projects on sustainable development are negative.
World over, it is being recognised that impact of small hydel projects is in fact comparable with large hydro projects and hence has to be assessed and mitigated. Countries like Vietnam have cancelled 338 small hydel projects as their assessment indicated that environmental and social impacts of these projects is not commensurate with their benefits.
We would be willing to present the problems from the ground to the MoEF. A holistic and truly sustainable approach can help boost renewable energy development in our country.
We are sure MoEF is committed to protecting environmental impacts, irrespective of the installed capacities of projects and will amend the EIA Notification to this effect urgently. Till such a credible regulatory system is in place, we request the MoEF to stop providing Host Country Approvals to Small Hydel Projects.
Some links and additional information related small hydro projects and their impacts can be found at:
Þ Himdhara’s Report on Mini Hydel Projects in Himachal Pradesh: http://www.himdhara.org/2012/09/09/small-hydropower-big-impact-a-discussion-on-issues-facing-local-communities-in-himachal-pradesh/
Þ Meeting on Mini hydel projects in Karnataka: https://sandrp.in/hydropower/PR_Halt_Mini_Hydel_Projects_in_Karnatka_pending_regulation_and_review_080812.pdf
Þ Comments on some of the CDM proposals for SHPs: https://sandrp.in/hydropower/
Looking forward to your response to the issues raised above.
- Ramaswamy Iyer, Former Secretary, Ministry of Water Resources, New Delhiramaswamy.firstname.lastname@example.org
- EAS Sarma, Former Secretary, Ministry of Power, email@example.com
- Madhu Bhaduri, Ambassador of India, ( Retd), firstname.lastname@example.org
- Dr. Ullas Karanth, Former member, Forest Advisory Committee, MoEF, Director for Science-AsiaWildlife Conservation Society and Director, Centre for Wildlife Studies, email@example.com
- Dr. Ravi Chopra, Director, People’s Science Institute, Dehra Doon, Uttarakhand, firstname.lastname@example.org
- Dr.Bharat Jhunjhunwala, Uttarakhand, email@example.com
- Manoj Misra, Convener, Yamuna Jiye Abhiyaan, Delhi, firstname.lastname@example.org
- Sharadcchandra Lele, Member, Elephant Task Force, Bangalore, Karnataka, email@example.com
- Dr. T.V. Ramachandra, Head, Energy & Wetlands Research Group, Centre for Ecological Sciences, Indian Institute of Sciences, Bangalore
- Dr. Bijukumar, Associate Professor and Head, Dept. of Aquatic Biology & Fisheries University of Kerala, Thiruvananthapuram 695 581, Kerala, firstname.lastname@example.org/ email@example.com
- Neeraj Vagholikar, Kalpavriksh, Pune, firstname.lastname@example.org
- Emmanuel Theophilus, Himal Prakriti, Pithoragarh, Uttarakhand,email@example.com
- Ramnarayan K, Himal Prakriti, Pithoragarh, Uttarakhandramnarayan.firstname.lastname@example.org,
- Malika Virdi, Himal Prakriti, Pithoragarh, Uttarakhand email@example.com
- Dr. Latha Anantha, River Research Centre, Kerala, firstname.lastname@example.org
- Samir Mehta, River Basin Friends, Guwahati International Rivers, Mumbai, email@example.com
- Dr. Jagdish Krishnaswamy, Eco hydrologist, Bangalore, firstname.lastname@example.org
- Dr. Shrinivas Badiger, Fellow, ATREE-Bengaluru, email@example.com
- Dr. Bhaskar Acharya, ATREE, Bangalore, firstname.lastname@example.org
- Dunu Roy, Hazards centre, Delhi, email@example.com
- Sankar Ray, Journalist with specialisation in environmental issues, Kolkata firstname.lastname@example.org
- Meher Engineer, email@example.com
- Manshi Asher, Himdhara Collective, Himachal Pradesh, firstname.lastname@example.org
- Rahul Saxena, Himdhara Collective, Himachal Pradesh, email@example.com
- Prasad Chacko, Human Development and Research Centre, Ahmedabad, firstname.lastname@example.org
- Girin Chetia, North-East Affected Area Development Society (NEADS), Village & P.O.- DhekiakhowaDist.- Jorhat (Assam), email@example.com; firstname.lastname@example.org
- Ashwin Gambhir, Prayas Energy Group, Pune, email@example.com
- Falguni Joshi, Gujarat Forum for CDM, Ahmedabad, firstname.lastname@example.org
- Madhusoodhanan C.G., Research Scholar, IIT Bombay, email@example.com
- Neethi Mahesh- Independent researcher, International collaborator- Mahseer Trust.firstname.lastname@example.org
- Kedar Nadolli Gogate, Urumbi Ankattu Pratirodh Samiti, Hosmata, Karanataka, email@example.com
- Karunakar Gogate, President, Urumbi Ankattu Pratirodh Samiti, Hosmata, Karanataka
- Dr. Beerathadaka Rajesh, Kutrupady, Hosmata, Dakshin Kannada, firstname.lastname@example.org
- Beni Prasad (Chairperson) Jan Jagaran evam Vikas Sanstha, Village Sarsei, PO Haripur, Tehsil and District Kullu, Himachal Pradesh.
- Dr. Pushpal Thakur (General Secretary), Jan Jagaran evam Vikas Sanstha, Village Sarsei, PO Haripur, Tehsil and District Kullu, Himachal Pradesh.
- Lal Chand Katoch, Sanyojak, Jal Jangal Jameen Bachao Sangharsh Samiti (Majhat), Village Batahar, PO Haripur, Tehsil and District Kullu, Himachal Pradesh.
- Rahul Banerjee, Dhas Gramin Vikas Kendra, Indore. email@example.com
- Subhadra Khaperde, Kansari nu Vadavno, Khargone firstname.lastname@example.org
- Shankar Tadwal, Khedut Mazdoor Chetna Sangath, Alirajpur email@example.com,
- Dr. AK Malhotra – Trustee, SAI (Save Animals Initiative) Sanctuary Trust, Kodagu District, Karnataka, firstname.lastname@example.org
- Gopakumar Menon, Nityata Foundation, Bangalore, email@example.com
- Nisarg Prakash, Nityata Foundation,Bangalore, firstname.lastname@example.org
- Tarun Nair, Researchers for Wildlife Conservation, email@example.com
- Dr Shambu Prasad, Chebrolu, Bhubaneshwar, firstname.lastname@example.org
- Anush Shetty, Bangalore, email@example.com
- Himanshu Thakkar, SANDRP, New Delhi, firstname.lastname@example.org
- Parineeta Dandekar, SANDRP, Pune, email@example.com