It seems we do not want to learn any lessons from the massive Uttarakhand disaster of June 2013. Two more huge capacity hydropower projects have been submitted to the Expert Appraisal Committee (EAC) of Ministry of Environment & Forest (MoEF) for grant of Environmental Clearance (EC) with very poor quality Environmental and Social Impact Assessment (EIA) reports.
EIA reports of Kiru Hydro Electric Project (HEP) (660MW) and Kwar HEP (560 MW) proposed in Kishtwar district, Jammu and Kashmir by Chenab Valley Power Projects Ltd. (CVPP) were submitted to the EAC for River for its 74th meeting held on 5-6 May, 2014 for grant of EC. The projects are run-of-river schemes proposed on river Chenab as a part of cascade development of Chenab basin.
Vicinity Map (Source Kiru EIA Report)
Partial Map of Commissioned and Proposed HEPs in Chenab River Basin (Map by SANDRP)
Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K).
While 49 of these projects are planned or under construction in Chenab in HP, 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances. State of J&K has 13 projects planned of total capacity 8,623 to 8,923 MW. These consist of at least four operational projects (of total 1563.8 MW), three under construction projects (of 1450.5 MW) and six proposed projects (of 5608.7 MW).
Table 1: Cascade Development of Chenab Basin
Source: EIA report of Kiru & Kwar
|1||Salal (Stage- I & II)||Chenab||690 MW|
|3||Baglhar (Stage-I & II)||Chenab||900 MW|
Himalayan ecosystem, of which the Chenab river basin is a part, is known to be geologically fragile. Cascade of hydel projects proposed on the river basins of this region would make the region even more vulnerable to extreme and erratic weather events, which will increase in changing climate. This has already been witnessed during Uttarakhand disaster of June 2013. Expert Body (EB) headed by Dr Ravi Chopra recently has officially acknowledged this connection in the report submitted to MoEF. In light of this, a thorough impact assessment of all the proposed hydro power projects in this region is thus of critical importance. Various organizations and experts including SANDRP have repeatedly highlighted the fact that Cumulative Impact Assessment (CIA) of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the river basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Without such a study, considering any hydropower project in the basin will be an invitation to disaster.
Even though the MoEF sanctioned TORs for cumulative impact assessments of the HEPs on Chenab in HP in February 2012, this critical task was entrusted to the Directorate of Energy, Government of Himachal Pradesh. This is a clear case of conflict of interest. Further the project specific ECs were delinked from the CIAs.
More importantly, no such study has been initiated in Chenab basin in J&K or in the Chenab basin as a whole. State of Jammu and Kashmir is not even considering CIA of HEPs on Chenab in the state as MoEF has not asked for it yet. CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.
On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.
MoEF continues to give clearances to individual HEP projects despite of poor quality Project Feasibility Reports (PFRs) and EIA reports submitted for appraisal. Kiru & Kwar EIA reports are a classic example of such poorly conducted EIAs. The EIAs demonstrate several serious issues across various stages from TOR non-compliance, non assessment of impacts, cut and paste job, lack of any references, faulty public hearings, the issued raised at public hearings have not been addressed in EIAs, as statutorily required. SANDRP recently made detailed submissions to EAC highlighting these issues for both the projects. Some highlights below:
Copy paste job while preparing EIA reports Both the reports are prepared by a consortium of RS Envirolink Technologies Pvt. Ltd. (Gurgaon) and Jammu University. Kiru EIA report demonstrates a casual approach towards impact prediction and proposing mitigation measures in EMP. The report also misses out on a number of important aspects of EIA like impact of construction activities on geology, flora fauna, impact of climate change, cumulative impacts of cascade development in Chenab basin etc. While Kiru EIA is inadequate on several fronts it was utterly shocking to discover that Kwar EIA report is a complete replica of the Kiru EIA Report. Entire text, save project specific numbers, remains the same in both reports, to the extent that the Kwar EIA report mentions Kiru instead of Kwar at several places!! The impact prediction for both the cases is so vague and generic that the changes in numbers for project-specific details like proposed installed capacity, submergence of reservoir, FRL, head race tunnels etc. do not reflect at all in the reports!
Brief Project Profiles Kiru H.E. Project and Kwar H.E. Project are run-of-river schemes proposed on river Chenab located in the district Kishtwar of J&K.
Kiru HEP envisages the construction of a 193 m long and 123 m high concrete gravity dam above the river bed across river Chenab at village Kiru with four intake, four pressure shafts, an underground powerhouse of 4 units of 165 MW each. Impoundment will cover an area of 1.03 Km extending 6.5 km upstream of dam. The average river bed level at the dam site is about EL 1394 m corresponding to an FRL of 1515 m, the gross storage of the reservoir is 41.50 Mcum and area under submergence is 1.03 Km.
Proposed dam site for Kiru HEP(Source Kiru EIA Report)
Kwar HEP envisages construction of a concrete gravity dam 101 m high from river bed across river Chenab at village Padyarna, four number intakes, four pressure shafts, an underground powerhouse to accommodate 4 units of 140 MW each and two number tail race tunnel. FRL of reservoir is proposed at EI 1385M. Gross storage of the reservoir at FRL is 27.167 Mcum. The reservoir will submerge an area of about 0.8 Sq. Km at FRL.
Proposed dam site for Kwar HEP (Source Kwar EIA Report)
TOR non-compliance First and foremost glaring issue about the proposed projects is the non-compliance with the TORs (Terms of Reference) laid down for conducting the EIA. These TORs were granted by MoEF. We have listed here only an indicative list of non compliance below, not an exhaustive one.
Kiru HEP The TOR clearance letter was issued for Kiru project on Sept 9, 2008, the TORs are valid for a period of 3 years, but the project developer never came back for extension of the TOR on expiry of 3 year period and has come now for EC over 5.5 years after the TOR clearance. Thus the TOR clearance is no longer valid for Kiru HEP as per the law. Also originally the TOR clearance for Kiru was given for 600 MW installed capacity. The EIA however has been conducted for 660 MW capacity. No permission was sought by the PP for this increased capacity.
Kwar project has undergone several changes since the grant of TOR on 17 March 2010. Table given below compares some of these changes. First and foremost alteration has been in the proposed total power generation. While the TORs were granted for 520 MW the EIA has been conducted for 560 MW. Number of affected families goes up by 160% and project cost escalates by 29%. The TORs were granted for over four years back and the project authority never got back to EAC/MoEF for renewal of the TOR as other projects do. Thus the TORs granted originally do not remain valid in this case too.
|Table 2: Changes in the scope of Kwar project after grant of TOR on 17 March 2010|
|Sr. No.||Parameter||Scope at the time of TOR clearance||Current scope of the Proposed Project|
|1||Total power Generation||520MW||560 MW|
|2||Land requirement||5 Ha Government land||93.66 Ha Government land|
|3||Power House Units||4 x 130 MW||(4 x 140MW)|
|5||Project Cost||Rs 3386.11 Cr||Rs. 4375.50 Crores at Jan’2012 PL|
Casual approach towards impact prediction
Kwar EIA copy pasted from Kiru EIA report: It is evident that the EIA consultants have done nothing but copy paste job while preparing Kwar EIA report. At certain places Kwar report mentions ‘Kiru’ instead of Kwar. See for example point number 1.7 in Index of Kwar EIA mentions ‘Need of the Kiru HE project’ instead of Kwar and point number 4.4 mentions ‘Basin characteristics of free draining area of Kiru HEP’ (p.3 & p.6 of the document). Page 28 of Kwar EIA states that “The case for forest clearance of Kiru HE Project for diversion of 29.75 ha of forest land has been approved in the 81st meeting of J&K State Forest Advisory Committee (FAC) held on 09.12.2013…”
Other than very project specific figures, the entire text for both the reports is exactly the same. Impact prediction is the heart of an EIA study. However in Kwar EIA report an important chapter like Chapter 8- “Identification, Prediction and Evaluation of Environmental Impacts” is also copy pasted. The text of the chapter is same as that of Chapter 8 from Kiru EIA report save the project specific numbers and their description. The impacts predicted are vague and are conveniently kept the same in both the reports. It is clear that no real field work or application of mind is done. Such an EIA study defeats the basic purpose of conducting an EIA.
Impact of construction activities: The Kiru project involves a reservoir of live storage 10.5 MCM, a concrete dam on height (from river bed) 123.0 M & length 193 M, construction of 4 head race tunnels (of 7 m dia and 165 to 190 m length each) for discharging the water to an underground powerhouse of 4 units of 165 MW each. The project also envisages 33.4 Lakh CuM of construction material required from the project site.
The Kwar project involves construction of 101 m (above river bed)/ 109 m (above deepest foundation) high concrete gravity dam, Underground power house complex of four units of 140 MW each, Two concrete lined 9.5 m internal diameter main tailrace tunnels (having length of 2676 m and 2883 m) amongst several other features like four 5.65 m internal diameter main pressure shafts (each with a length of 108-182 m), etc. The project also envisages 38.36 Lakh CuM of construction material required from the project site.
View of Naigarh Nala Rock Quarry at Kwar Dam site (Source Kwar EIA Report)
All these activities will have significant impact on the geology and hydrology of the region. However no significant assessment or quantification of these impacts in terms of change in drainage patterns, springs in the project area, increased thereat of landslides, seismic activities has been carried out.
While talking about the impact of construction activities, the only impact of these two EIAs discussed in the chapter is ‘muck generation’. It does not mention impacts of tunneling and blasting involved in construction and also does not talk about its impact on fragile geology and hydrology of Himalayan region at all. While talking about quarrying activities in the same chapter it states only two impacts viz. visual impacts and noise generation. Impacts on landslides have been randomly dismissed stating that the sliding activity may not be significantly induced by project construction activities. The reports trivialize the impacts on migratory fish Mahseer by stating that the upstream migration of this fish from the lower reached of the Chenab River have already been blocked by Salal and Baglihar, Dul Hasti dams. Thus they conclude that impact of this project on this fish species is not expected to be significant. Option for fish ladder and fish lift has been ruled out for both the projects stating that it is not techno-economically feasible at the project site. Development of a hatchery at the project site has been proposed instead. The impact of the project on all the fish available in the river should have been assessed based on baseline assessment of the fisheries in Chenab River, which is not done. Secondly, there is no credible evidence to show that hatchery as a management option is useful or effective.
Left Bank slide for Kiru Project downstream of Ludrari Nala (Source Kiru EIA Report)
Right Bank slide for Kiru Project about 16 km downstream of Gulab Gargh (Source Kiru EIA Report)
The southern boundary of the Kishtwar National Park is approximately at an aerial distance of 11 km away from the proposed project, it is claimed, but this needs to be independently assessed. Also, just because it lies outside the boundary of study area which is radius of 10 KM, the EIA does not consider the impacts on this national park at all! EIA reports for both Kiru and Kwar HEPs simply state that the proposed activities shall have no impact on the National park.
Biodiversity at Kishtwar National Park (Photo: Travel Places & Beauty Spots of India)
Several Important aspects of EIA are missing
No mention of free flowing river stretch: There is no mention of what is the flowing river stretch upstream and downstream of the project. As is clear from the EIA, the elevation difference between FRL of Kiru HEP (1515 m) and TWL of upstream Kirthan II (1526.5 m) is just 11.5 m. The elevation difference between TWL of Kiru HEP (1388 m) and FRL of downstream Kwar HEP (1385 m) is just 3 m. Similarly the elevation difference between TWL of Kwar HEP (1270 m) and FRL of downstream Hasti HEP (1264 m) is just 6 m. However, it is not clear what the flowing river lengths in all these locations are. Unless this length is assessed and is found to be adequate for river to regain its vitality, the project should not be considered and it should be asked to change the parameters.
Environmental Flows: The Kiru EIA report states that significant downstream impacts related to the water quality, fisheries, socio-economic and aquatic biodiversity are not foreseen since toe power house is proposed downstream of the dam and tail water level is EL 1388.52 m, discharge will be less only in a “very small stretch of about 800 m”. This seems to show the ignorance of the EIA consultants about how biodiversity in a flowing, lively river like Chenab survives.
Kwar EIA report states that the water entering the reservoir will be released back to river at a distance of 2.6 KM downstream. The report claims that though there in no human activity in this stretch of 2.6 KM the aquatic life will be definitely affected, as also terrestrial biodiversity, groundwater recharge, use of river and silt flow pattern.
10% of average of lean season discharge has been prescribed to be released through the dam gates as environmental flow for both the projects. This quantity has been calculated as 9.0 cumecs based on discharge data of the river. There is no mention of environmental flows in EMP. Firstly, this is even below the norms being followed by EAC and MoEF (30% in monsoon, 20% in lean season and 25% in rest, each at 90% dependability). Secondly, the amount of E-flow required needs to be arrived at based on actual assessment, but no such assessment has been done.
Impact of peaking generation not assessed: The reports talk about advantage of hydropower in terms of ability to providing peaking power. However, when a project operates as peaking station, there are severe impacts in the downstream and also upstream (rim stability). These impacts have not been assessed, nor is it assessed how the project will perform in the cascade development it is in.
Some other important aspects of impact assessment that report misses out on are:
- Impact of the project on disaster potential in the project area as well in the downstream due to construction and also operation at various stages, say on landslides, flash floods, etc.
- Social and Environmental Impacts of construction and operation of the coffer dams and diversion tunnels during construction phase are not included.
- The reports do not even mention Climate Change.Impact of climate change on the project and impact of the project on the local climate has not been assessed. No mention or attempt has been made about or to assess the impact of green house gas emissions from the project.
- Impacts on the flood characters of the river due to this dam, what will be the changes and how these will impact downstream areas.
- Impact of changing silt flows downstream from desilting chamber and from silt flushing in monsoon on the downstream areas not analyzed. A detail account of how the silt from the dam would be flushed out annually and what would be the impact of this in the downstream as well as on the geo morphology, erosion, stability of structures etc was not done.
- Options Assessment is missing, this is crucial part of the EIA to establish that among all options, including non project option, the given option is the least cost and best option.
Cumulative Impacts not assessed The EIA report gives list of Major hydroelectric projects executed /under execution/ under investigation so far in the basin in J&K which are a part of Cascade Development. Kirthan HE Project (990MW with proposed FRL at 1764 m and TWL at 1526.50m) which is yet to be commissioned is proposed upstream of Kiru (660 MW with FRL at 1515M). Downstream of Kiru is Kwar HE Project (560 MW with FRL at 1385 m and TWL at 1270 m) which is yet to be appraised and Dul Hasti HE Project (390 MW with FRL at 1264 m) which is commissioned.
Impoundment of Chenab at Dul Site (Source: Kwar EIA Report)
Moreover, the EIA does not provide the list of hydropower projects being taken up in Chenab basin in upstream Himachal Pradesh. The cumulative impacts of all such projects will be huge.
The report summarizes cumulative impacts in single sentence: “The increased pressure will include uncontrolled logging, hunting of wildlife, non-timber forest product collection, livestock husbandry, the cultivation in forest areas and forest fires.”
EIA report completely misses out on the detailed analysis of cumulative impacts in terms of
- Impacts on flora, fauna, carrying capacity, livelihoods
- Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change
- Impacts on springs and drainage pattern
- Disaster potential of the area
- Tunneling and blasting
- Geological disturbance caused
- Seismic impacts
- Carrying capacity
Inadequate Dam Break AnalysisThe Dam break analysis does not take into account the cumulative disaster potential including existing and proposed upstream and downstream projects. The EIA report also does not include cumulative disaster management plan.
Improper Public Hearing Public hearing conducted for both the projects were flawed. Excerpts from the speeches made by the officials from J&K State Pollution Control Board (SPCB) and CVPP that are noted in the public hearing report show that what these persons spoke was inappropriate, misleading and intimidating. Also point wise responses to the issues raised by people at the Public Hearing are not provided in the EIA, as statutorily required. Hence even when people ask for Resettlement and Rehabilitation as per latest Act of 2013 (made effective from Jan 1, 2014), the EIA talks about National Resettlement and Rehabilitation Policy of 2007. The public hearing report strangely end for both projects with the officials asking those who are for the projects to raise their hands. There is no formal provision for voting for or against the project. Such public hearing should be declared null and void and fresh public hearing should be conducted.
Poor quality EIA reports that reflect pro hydro bias of the consultant EIA is the most effective tool to ensure environmental compliance in India. Needless to state that it is of critical importance. Casually predicted, unaddressed impacts and copy paste job of the Kiru and Kwar EIA reports once again highlights the poor quality of EIA reports submitted to the ministry for grant of EC. These reports decide fate of the project, of the people and environment surrounding the project site. Such quality of the report is most definitely not acceptable.
Further, an EIA report is an attempt to understand what are the adverse social and environmental impacts of a project and weather the impacts are acceptable, if the project is viable, optimal and desirable. The answer to this exercise can also include the answer that the project is not viable or desirable or acceptable. In view of this, the EIA consultant needs to be completely unbiased and should be ready to even conclude that the project is unacceptable. However, in case of the EIA consultant for the Kiru & Kwar HEP, EIA starts in very 1st chapter with a shockingly unscientific and biased statement: “Hydropower projects are dependable, renewable, economic, environmentally benign sources of energy with ability to stop and start instantaneously.” This statement is factually wrong on many counts (e.g. hydropower project is renewable or dependable or environmentally benign source of energy). It, along with whole para 1.2 also reflects the bias of the EIA consultants RS Envirolink Technologies Pvt Ltd (with Jammu University) and we urge the EAC and MoEF to reject such poor quality and biased EIAs and take other necessary steps to debar such agencies from doing any EIA or environmental studies in future.
CONCLUSION Looking at serious issues above, based on merit of the EIA reports, as well as complete cut-paste jobs, we are hopeful that the MoEF will not recommend EC for these projects. This case also highlights the importance of cumulative impact assessment in an over developed Himalayan basin. When the experience with Uttarakhand flood disaster of June 2013 is fresh, we hope that MoEF will not commit another blunder.
Amruta Pradhan, SANDRP
 Refer to SANDRP studies on Chenab
p.291 of Kiru EIA Report & p.288 of Kwar EIA report
p.293 of Kiru EIA Report & p.289 of Kwar EIA report
p.298 of Kiru EIA Report & p.294 of Kwar EIA report
p.307 of Kiru EIA Report & p.303 of Kwar EIA report
p.221 of Kiru EIA Report & p.223 of Kwar EIA report
 See for example: https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf
P. 306 of Kiru EIA
The Public hearing report of Kiru says that Shri Sajjad Mufti, Regional Director of J&K SPCB said at the public hearing, “Construction of project should not deteriorate the environment….” This is a very strange, untruthful and inappropriate statement from J&K SPCB official. Why should the official be speaking at all at the public hearing and that too make such a statement that would also affect the atmosphere of the public hearing? Similarly the statement of GM of CVPP at the public hearing, “The most viable and cleanest of all (sources of power) is hydro power” was again, wrong, intimidating and inappropriate. The statement of Shri Khursheed Ahmed Butt of CVPP, “forest clearance has already been granted to the proposed project” is incorrect since the proposal for forest clearance for the project has not even come before FAC. Such public hearing should be declared null and void and fresh public hearing should be conducted.
The Public hearing report of Kwar says that the GM of CVPP said at the public hearing, “The best source of power generation is hydro power” was wrong, intimidating and inappropriate. The statement, “forest clearance has already been granted to the proposed project” is incorrect since the proposal for forest clearance for the project has not even come before FAC.
 See for details and link to PCA orders: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/