PROJECT UNABLE TO SUBMIT SATISFACTORY PROPOSAL EVEN SIX YEARS AFTER PM LAID FOUNDATION STONE!
In a remarkable decision, the Forest Advisory Committee (FAC) of MoEF has rejected the forest clearance to 3000 MW Dibang multipurpose project for the second time in its meeting held on 29 -30 April 2014. In that meeting FAC considered the Dibang multipurpose project for diversion of massive 4577.84 ha of biodiversity rich forest land which would lead to cutting down of huge 3.24 lac trees.
The project was previously considered in the FAC meeting of 11-12 July, 2013 for diversion for 5056 ha of forest land which would have led to cutting down of 3.55 lac trees. In that meeting too, FAC had rejected forest clearance to the project. It is important to note that the foundation stone of this project was laid way back on 31st January 2008 by the Prime Minister of India (to know more on this, read our earlier blog on Dibang). At that time the project had neither the environment clearance nor the forest clearance even though these two are most essential for a project to legally have foundation stone.
Over six years later, continuous rejection of forest clearance to this project reflects how government gives little importance to environment while planning for mega development projects such as Dibang. This kind of callous environmental governance, disregarding environmental concerns of large number of people was one of the major reasons for decimation of the UPA government, provided NDA government wants to learn anything from it.
Rejecting the forest clearance to this project, the latest FAC meeting proceedings stated, “In view of the above the committee has recommended for rejection of the proposal and felt that the proposed area is very rich in Bio-diversity aqua sensitive ecosystem being at the edge of hills and flood plains and having large number of endemic and endangered flora and fauna. Moreover, such project is most likely to have considerable downstream impact on the Dibru-Saikhowa NP in Assam which is not yet studied.”
SANDRP has been making submissions to the FAC & other authorities on this project at various points of time. Brief timeline regarding Dibang HEP is given in Annexure 1. Excerpts of our last submission dated 28th April 2014 are given in Annexure 2. The project also does not have environment clearance.
FAC Rejected CCI Recommendation to Give Clearance to Dibang Project While considering the forest clearance to Dibang project, the statutory body FAC was under pressure from the Cabinet Committee on Investment (CCI) headed by the Prime Minister of India. In its recommendation to FAC the CCI had stated – “The Committee considered the note dated 25.10.2013 from the Ministry of Power (Vidyut Mantralaya) and in the light of all relevant facts, decided that Ministry of Environment and Forests may grant the requisite clearance for diversion of forest land expeditiously. The Committee further directed that appropriate measures for increasing the environment flow in the 1.2 Km along stretch between the dam and Tail Water Level (TWL) of the dam to Power House be taken and if required, adjustments in the project parameter be made at a later stage keeping in view the report of Water and Power Consultancy Services (India) Ltd.”
The project proponent NHPC Ltd had approached CCI after FAC meeting of 11-12 July, 2013 where the forest clearance to the project was rejected for the first time. It is important to remember here that while rejecting the forest clearance to Dibang the FAC had clearly stated that “ecological, environmental and social costs of diversion of such a vast track of forest land, which is a major source of livelihood of the tribal population of the State, will far outweigh the benefits likely to accrue from the project.” CCI’s intervention in this matter, to push for the forest clearance for the project, was not at all based on merits of the issue. This also reflected a total disregard for the FAC clearance process. The FAC has taken a positive step towards conservation of the rich biodiversity of the Dibang valley, disregarding the CCI suggestion.
Rational for Rejection: FAC’s Observation Regarding Dibang project The FAC has made several significant observations in regard to this project and on the basis of which it has rejected the forest clearance to this project. Some of these observations in order of importance are listed here.
- “The revised proposal envisages reduction in dam height by 10 meter which will bring down the submergence of the forest area by only 445 ha, a reduction by less than 9%. The number of affected trees is marginally coming down to 3.24 lakhs from 3.5 lakh. Such a marginal reduction in requirement of the forest land may not be able to reduce the adverse impact of project on such a biodiversity rich mature forest ecosystem to the extent which could make the project environmentally as well as socio-economically viable in forest dependent tribal society of Arunachal Pradesh. The revised proposal, therefore, does not address the concerns raised by the FAC in its last meeting where too the project was rejected.”
- The reduction in power generation due to reduction of the Dam height by 10m it is to the tune of 2.3%. The User Agency has not given any convincing justification for their stand of not reducing the Dam height by more than 10 meter. Impact of reduction of the Dam height on the economic feasibility of the project has not been put forth before the committee.
- The proposed forest land for Dibang Multipurpose Project is the major habitat of schedule I flora and Fauna. The major Schedule–I species like Elephant, Hollock Gibbon, Mishmi Takin, Clouded Leopard, Tiger, Leopard cat, Fishing cat, Mithun, Slow Loris, Snow Leopard and Himalayan Black Bear etc are found in the area.
- As per the SIR (Site Inspection Report) of RO (Range Officer) Shillong, there will be significant effect on removal of trees in the general ecosystem of the area. As the proposed diversion site is having a steep slope with patches of Jhum cultivated area, removal of the trees will affect the micro climate of the area and the Wildlife and Flora endemic in the proposed sub-mergence area. The trees and shrubs all along the submergence are to be removed so that they will not be left submerged thereby causing decomposition and lead to the accumulation of the methane gas causing Green House effect. The construction of the dam itself may lead to the increase in the temperature in the submergence area which may also effect the micro aqua habitat.
- Earlier NHPC had submitted three alternatives directly to the ministry reducing dam height by 10, 30 and 40m. However, these proposals have not been mentioned in the revised proposal of the state government.
- The FAC also made some observations regarding the revised proposal submitted by the Government of Arunachal Pradesh (vide letter no FOR.10/Cor./2003/VolIV/287) on 13.02.2014. Corresponding details pertaining to the revised proposal such as suitable map (Survey of India topo-sheet, Digital GPS map, forest cover map, etc) have not been submitted by the State Government.
- Compliance of Schedule Tribe and Other Traditional Forest Dwellers (Recognition of Forest Rights) Act, 2006 has also not been submitted by the State Government.
- No clarification about the non-suitability of the land identified for Compensatory Afforestation, as per observation of the Regional Office Shillong made in the site Inspection Report, has been furnished by the state government.
- CAT plan has not been submitted.
- Earlier decision of FAC also noted, “Including Dibang HEP, there are several other HEP proposed in the same river valley. However there is no study conducted in to assess the cumulative impact of all these reservoir and it upstream and downstream impacts.”
Welcome decision It is indeed amazing that over six years after the Prime Minister laid foundation stone, the project is unable to submit a satisfactory proposal complete in basic details. How can the cabinet ask that such a proposal be cleared? This is also a fitting answer to all those who have been blaming MoEF for not clearing projects. How can projects be cleared if the project authorities are not able to provide even basic details as required under the law?
This categorical rejection of the Dibang HEP by FAC on merits is indeed a remarkable decision of the FAC and we hope the new government at the centre with strengthen this decision and learn lessons for the hydropower projects in North East India.
Parag Jyoti Saikia (email@example.com)
Brief Timeline of the Dibang Project
|Dates||Matters Discussed||Recommendations/ issues of concern|
|31 Jan 2008||Prime Minister Dr Manmohan Singh lays foundation stone for Dibang HEP||No clearances, not even public consultations or impact assessments.|
|18 Aug 2011||State government submits proposal to MoEF||MoEF asks Regional office to do site inspection through letter dated Sept 14, 2011. However, the proposal did not have sufficient information. Regional office informed on Aug 1, 2012 that due to lack of sufficient information from state government about the proposal and poor connectivity, site inspection could not happen. Significant part of the project also falls within 10 km radius of the Mehao Wildlife Sanctuary.|
|11- 12 July 2013||Diversion of 5056.50 ha of forest land in favour of NHPC for Dibang project on Dibang river in Lower Dibang valley of Lower Dibang district of Arunachal Pradesh, after site inspection||The committee noted that the project involves huge forest area, having very good forest cover. Felling of more than 3.5 lakh trees most likely to have adverse impact on general eco-system of the area, recovery of which may be very difficult through any type of mitigative measures. Including Dibang HEP, there are several other HEP proposed in the same river valley. However there is no study conducted in to assess the cumulative impact of all these reservoir and it upstream and downstream impacts. The committee is of the opinion that ecological, environmental and social costs of diversion of such a vast tract of forest land, which is a major source of livelihood of the tribal population of the State, will far outweigh the benefits likely to accrue from the project/ The committee, therefore, recommended that approval for diversion of said land may not be accorded.|
|13 Aug 2013||Meeting between Secretary, MoEF & Secretary, Ministry of Power||User agency to explore the possibilities of reducing the forest land requirement and send revised proposal to MoEF.|
|25 Oct 2013||Ministry of Power note to Cabinet Com on Investment||Asks CCI to intervene to reverse the FAC decision|
|9 Dec 2013||Meeting of Cabinet Committee on Investment||Cabinet secretariat, through OM dated 13 Dec 2013 sends the minutes to MoEF asking MoEF to clear the project expeditiously|
|13 Feb 2014||State government sends revised proposal to MoEF for FAC||Marginal reduction in forest land required to 4577.84 ha through reduction in dam height by 10m, claiming further reduction is not possible as it will affect power generation of the project.|
|29 – 30 April 2014||Revised proposal regarding diversion of 4577.84 ha of forest land in favour of NHPC for Dibang project||….the committee has recommended for rejection of the proposal and felt that the proposed area is very rich in Bio-diversity aqua sensitive ecosystem being at the edge of hills and flood plains and having large number of endemic and endangered flora and fauna. Moreover, such project is most likely to have considerable downstream impact on the Dibru-Saikhowa NP in Assam which is not yet studied.|
Submission made by SANDRP to the FAC on Dibang Project
SANDRP’s submission of 28th April 2014 which was also endorsed by Keshav Krishna Chatradhara of Peoples’ Movement for Subansiri and Brahmaputra Valley (PMSBV), had mentioned several pressing concerns regarding Dibang project. Some of these mentioned below:
1. Revised Proposal for Dibang HEP is incomplete, FAC cannot Consider on the basis of incomplete proposal – In our submission we had clearly mentioned that the revised proposal which is submitted by Government of Arunachal Pradesh on 13.02.2014 was incomplete which was very clear from the factsheet that was made available on the forest clearance website dated 21st April 2014.
o The revised proposal does not provide the details regarding Compensatory Afforestation (CA). Details such as the non-forest area/degraded forest area identified for CA, its distance from adjoining forest, maps showing the area identified for CA and adjoining forest boundaries, details of CA scheme, total financial outlay for CA have not been provided along with the revised proposal.
o The number of families which needs to be rehabilitated have increased to 115families in the in the revised proposal. In the previous factsheet of July 4th 2013 this was 68 families. The revised proposal also does not have the details of the rehabilitation plan.
o The recommendations from DFO, CCF, Nodal Officer and SG were not available.
o The revised proposal submitted by government of Arunachal Pradesh on 13.02.2014 was clearly incomplete since in the Form A submitted by the state government, the Part-II of the form was not been enclosed.
2. No Details about the Reduction in Land required for the project The proposal stated that the land requirement has been reduced to 4577.84 ha from the 5056.5 ha which implies that 478.56 ha of land has been reduced. But the factsheet mentioned about the reduction of 33.658 ha of area falling under the 10 km radius of Mehao Wildlife Sanctuary. But it has no information about the rest 445 ha of land. The revised proposal should provide detailed breakup of forestland, river bed and non-forest land coming under the revised submergence.
3. FAC concerns remain unresolved While rejecting the forest clearance to Dibang the FAC had clearly stated that “ecological, environmental and social costs of diversion of such a vast track of forest land, which is a major source of livelihood of the tribal population of the State, will far outweigh the benefits likely to accrue from the project.” There is nothing in the fresh proposal to resolve these issues.
4. Huge opposition to the project in Arunachal Pradesh and from downstream Assam: The project faces stiff opposition from Arunachal Pradesh and even more so in downstream Assam and any effort at pushing the project is likely to spark conflicts in this conflict prone region, like we are witnessing in Lower Subansiri HEP. FAC should not go ahead with the project without assessments, studies and participation to save future complications and wastage of resources. A video titled “Dibang Resistance (Arunachal Pradesh)” depicts the protest and blockade by local people against the Dibang dam. The video can be viewed here – https://www.youtube.com/watch?v=m8TCUKh2hQY
5. Impacts of Climate Change: North East is one of the 4 most vulnerable regions to Climate Change Impacts as identified by the Climate Change and India 4X4 Assessment Report of the MoEF. Detailed studies about the impact of the loss of 4577.84 hectares of forests needs to be conducted on various aspects, including adaptive capacity of the people, biodiversity and so on. Ironically, the Site Inspection Report only mentions that to decrease Green House Gas Emissions, trees surrounding the reservoir should be cut, which highlights the unscientific, misleading and myopic perspective on climate change and its impacts. There should also be assessment of impact of the loss of carbon sink, green house gas emission from the reservoir and local climate impacts. We are already experiencing the effects and impacts of climate change. It should now be obligatory for the FAC to consider climate change in its functioning.
6. Incomplete and Shoddy Downstream Impact Assessment The downstream impact assessment done for the Dibang multipurpose does not take into account impacts of the dam in Assam and hence it is incomplete and shoddy. The downstream impact assessment study does no assessment except the impact on Dibru-Saikhowa and whatever has been done is also very much inadequate. It is important to note that lack of adequate downstream impacts assessment of the 2000 MW Lower Subansiri HEP of the same developer NHPC Ltd is one of main reasons behind the ongoing anti dam protests in Assam. Due to these protests the work in the said project has been stalled for last 28 months since Dec 2011 after spending over Rs 5000 crores. Dibang multipurpose may also meet the same fate if project is pushed ahead without proper downstream impact assessment, which is also important for the downstream forest and protected areas.
7. No Public Hearing Held in Assam Even though the Dibang multipurpose will have severe impacts in downstream Assam, there was no public hearing held for the project in Assam. This is a clear violation of norms and this should be taken seriously by the FAC.
Similar concerns were resonated in the submission made by Shri Chow Rajib Gogoi, Secretary, All Tai Ahom Student Union, Jorhat on this project to the 68th meeting of Expert Appraisal Committee held on September 23rd-24th, 2013. In that submission it was said “The Dibang project will cause regular havoc in the downstream Assam, not just in terms of forest but also agriculture and livelihood. The EAC / MoEF is also aware of the widespread concerns in Assam about the downstream impact of dams and has respectfully repeatedly received petition on the same. We are disturbed that concerns still remain unaddressed.” But the reply to this by the project proponent reflects lack of seriousness on the part of the proponent. The project proponent stated, “The memorandum has not given the detail as to how Dibang project would cause havoc in the downstream in terms of forest, agriculture and livelihood.” It is surprising to read such a reply since it is the responsibility of the project proponent to get these studies done. But in stead, to cover up, it is asking a local student group to give all these details!
8. Severe Impacts of Migration of Outsider on Local Tribal Community and Fear of Demographic Imbalance Influx of migrant worker for construction of Dibang multipurpose will have severe impacts on the communities living there. The primary inhabitants of Dibang valley are Mishmi (Idu) which is a very small community with a population of 11,023 according to 2001 census. Due to this, they fear that influx of outsiders for dam building will lead to a demographic imbalance in the Dibang valley. According to NHPC estimates a workforce of 5800 people (labour and technical staff) would be needed for the Dibang multipurpose project. But All Idu Mishmi Students Union (AIMSU) has contested this figure and opined that a single project would bring about 15,000 people into the region. It is also reported that NHPC claim that the project will cause ‘negligible human displacement’ grossly undermines its harmful impacts on smaller ethnic community such as Idu Mishmis. This is a serious concern regarding Dibang multipurpose project and severe demographic impacts which can be deduced from the figures above cannot be undermined.
Influx of labour at such a massive scale will increase the conflict potential of the region. As it is, the region is scarred with many conflicts and unrest surrounding water. MoEF needs to be sensitive about growing discontent and increasing conflicts in this region.
9. No Cumulative Impacts Assessment study undertaken: 3000 MW Dibang HEP is one of the 17 cascade of hydel projects coming up in the Dibang valley. When this is known, the FAC cannot consider Forest Clearance to 3000 MW Dibang Project in isolation. The FAC should first ask for a cumulative impact assessment study and Basin Study of the Dibang River, to be done by an independent consortium of experts (not agencies with conflict of interest and poor track record like WAPCOS), the study should include carrying capacity assessment and only based on such a study consider individual projects in this region.
 Mimi, R., “The Dibang Multipurpose Project, Resistance of the Idu Mishmi” published in “Water Conflicts in Northeast India – A Compendium of Case Studies” edited by Das, Partha J. et. all, 2013