Minutes of Government of India meeting on Lower Subansiri HEP in Dec 2014 rejected by movement:
Shoddy Cumulative impact assessments, lack of public consultations won’t help
On Dec 10-11, 2014, on completion of three years of stoppage of work on Lower Subansiri hydropower project, Union Power Ministry called a meeting of “Stakeholders of Subansiri Lower Project”. The minutes of the meeting (chaired by Union Power Minister Piyush Goyal), issued on Dec 30, 2014 suggests that the government is basically going through the motions of showing that something is being done to address the issues raised by the mass based movement in Assam, but in essence it has no will to address any of the issues with any seriousness.
The sketchy minutes of the meeting provides sufficient evidence to reach such a conclusion. Let us take just two examples.
Movement demands As mentioned in the minutes, one of the key issues that the movement leaders raised at the meeting was (strangely listed at no 15 of the 17 issues listed): Cumulative downstream impact study of big dams. Issue no 14 (cumulative impact of dams in Subansiri basin), issue no 11 (downstream Assam be considered project affected and public hearings should be conducted in downstream Assam for projects in upstream Arunachal Pradesh), issue no 12 (impact of changing silt flow pattern in downstream areas), issue no 13 (impact of peaking operation of hydropower projects on downstream area), issue no 8 (impact of projects on biodiversity including dolphins), issue no 7 (adequate environmental flows in downstream areas) among others are related to cumulative impact assessments, besides being relevant for specific project in question.
Ministry of Power Response on CIA Considering the linkage of so many issues with the cumulative impact assessment and proper public consultation process for the same, and considering the gravity of the situation, one would have expected the government to provide some serious response. However, the minutes show how non serious the government response was, it says: “On the issue of cumulative basin wise downstream studies, it was clarified that the same are already being carried out for all the basins of Brahmaputra under the guidance of Ministry of Environment and Forests itself. Some of the studies are at final stages.”
Shoddy, unacceptable CIA What is the reality? So far, four Cumulative Impact Assessment (CIA) studies from the North East Region have been put out in pubic domain, for following sub basins of Brahmaputra basin: Siang, Subansiri, Lohit and Bichom (a sub basin of Kameng Basin). We have gone through all these studies and have provided detailed submissions on each to the Ministry of Environment, Forests & Climate Change (MoEF&CC) and its Expert Appraisal Committee (EAC) on River Valley Projects that is supposed to appraise such studies from Terms of Reference stage to the final approval. None of these studies can be considered complete; in fact they are so shoddy that they would not pass any independent scrutiny.
For Subansiri basin, the cumulative impact assessment study has been done by IRG Systems South Asia Private Limited (http://www.irgssa.com/, a subsidiary of US based IRG Systems). A total of 19 projects are proposed in this basin. In our detailed submission in Sept 2013 to EAC on this study[i], we noted at the outset: “In fact, one of the key conditions of environmental clearance to the 2000 MW Lower Subansiri HEP was that no more projects will be taken up in the basin upstream of the Lower Subansiri HEP, which essentially would mean no more projects in the basin, since LSHEP is the last project on Subansiri River before its confluence with Brahmaputra River. That condition was also part of the Supreme Court order in 2004. The need for a carrying capacity study was also stressed in the National Board of Wild Life discussions. We still do not have one. In a sense, the Subansiri basin is seeing the consequences of that subversion.” Going against prudent decision making, the condition of no upstream project was diluted after construction started, even over-ruling the objection of non-official expert members that cumulative impact assessment and carrying capacity be done before modifying the condition. We still do not have those studies.
Our letter to EAC also highlighted large number of reasons why the Subansiri Basin study should be rejected, some of them being: No mention of social impacts, no knowledge of clearance situation of the projects in the basin, large number of cumulative impacts not assessed, large number of wrong and misleading statements, Environment flow assessment without use of acceptable method like the Building Block Method, no environment flows recommended in monsoon, no study of impacts of peaking operation, no mention of key fish species like the Gangetic Dolphin and no lessons learnt from experience of the Lower Subansiri HEP. For details of this critique, see SANDRP blog. The Minutes of the EAC meeting in Sept 2013[ii] noted large number of shortcomings of the report and also asked the consultant to respond to SANDRP comments.
In case of Siang Basin, the Final report of the Cumulative Impact Assessment study done by RS Envirolink Technologies Ltd was discussed by the EAC in its meeting in Feb 2014[iii]. SANDRP had sent a detailed critique of the 2 volume 1500 page Siang Basin CIA[iv], about which the EAC asked the consultant to provide point wise response. Some of the key shortcomings of the study were: No mention of social and cultural impacts, Downstream impacts on Assam not studied in detail, Cumulative Disaster vulnerability, impact of projects on such vulnerabilities, Dam Safety Assessment, risk assessment not done, “Cumulative” Impacts not assessed on several aspects, Non-compliance with critical recommendations by the EAC, No actual assessment of environment flows as required by the Terms of Reference, No mention of Climate Change, reservoir emissions vis-à-vis cumulative impacts of such massive scale, how the projects would affect the adaptation capacity of the communities and region in the context of climate change, No stand taken on three mega projects on Siang Main Stem and other big hydro projects, No conclusion about how much length of the river is to be compromised, Source of information not given, Inconsistency, contradictions in listing of flora-fauna, Unsubstantiated advocacy: going beyond the TOR & mandate, no Public consultation across the basin, including Assam.
The consultants have conveniently and deliberately decided to do no impact assessment and flow fluctuation modeling between Assam – Arunachal Pradesh border and Dibrugarh. This is fraudulent as it leaves out the entire Jonai sub-division in the Dhemaji district of Assam as well as the Dibru-Saikhowa National Park and Biosphere Reserve from the purview of impact assessment. Worryingly, flow fluctuations in this region due to cumulative peaking operation of Siang Basin Projects is going to be tremendous, raising serious questions of human and animal safety. At D’Erring Sanctuary (in E Siang district of Arunachal Pradesh), close to Dhemaji district, water level fluctuation in winter months can be as high as 22 feet in a day, but the consultant has tried to hide this fact by studying level fluctuations only at Dibrugarh, Bokaghat and Guwahati, leaving this most-impacted region of Assam out of the study. SANDRP had specifically raised this issue of impacts on Assam when the EAC was discussing the study, but no attention was paid to this issue. The details of each of these points can be found on SANDRP blog.
The study was again discussed by the EAC in its meeting in July 2014, which also included the consultant response[v] to only a small proportion of the SANDRP submission and in most cases the consultant (wrongly) claimed that these issues were not part of the mandate of the study, thus accepting that they have NOT studied those aspects. This by itself shows that the Siang Basin study is incomplete and unacceptable. As is usually the case, EAC did not even apply its mind to the shortcomings pointed out by SANDRP and the shoddy response of the consultant.
The maximum number of basin studies have happened for Lohit Basin, but almost all the studies having been done by the controversial agency WAPCOS, there has been no satisfactory conclusion of the studies. SANDRP has sent a number of submissions to EAC in this regard, the earliest one was sent in Nov 2011[vi], where the following shortcomings of the study were highlighted: no assessment of impacts of projects on tributaries of Lohit (the Terms of Reference for this are now issued in 2014), no assessment of environment flows, Not a word on social and cultural impacts in Arunachal Pradesh or Assam, no proper biodiversity impacts, large number of cumulative impacts not assessed, impact of peaking operation not assessed, the impact of climate change and impact of projects on adaptation capacity of people not assessed, impact of project on culturally important places like Parsuram Kund not assessed, to name only a few. These short comings remain unaddressed and hence the study is yet to reach acceptable level.
Water level fluctuations at Parshuram Kund due to peaking operation of Lower Demwe Project will be more than 5 feet in a single day in winter. When question was asked about the safety of pilgrims due to this huge and sudden level changes 4 times a day, the consultant WAPCOS only said that an alarm system will be in place. The Larji Dam Release mishap on Beas River in June 2014 which claimed 25 lives and many such hydropower release related tragedies in India have highlighted the uselessness and ineffectiveness of having only an alarm as a warning system, this is also regressive in the global hydropower risk management scenario. But EAC did not raise any questions on this issue and accepted WAPCOS’ weak claim.
SANDRP had specifically suggested that there should be exploration of reducing the rate of water release during peaking, making it gradual for the sake of safety (up-ramping and down-ramping rates. This is a global norm). However, WAPCOS responded to this saying that any changing in ramping rates would affect the peaking power production of the project and should not be explored further. EAC also accepted this explanation. This shows that basin studies place more importance to power production than safety concerns.
Further, WAPCOS has specifically not accepted including impacts of Lohit Basin projects on Dibru Saikhowa a part of the Lohit Basin Study, although it was specifically asked for by EAC and other groups from Assam and India. EAC has meekly accepted WAPCOS claim and has not increased the scope of the Lohit Basin Study to Dibru Saikhowa National Park, although the Park and its population will be specifically affected by all Lohit Basin Projects.
Bichom is a sub basin of Kameng Basin and the cumulative impact assessment of 11 projects proposed in this basin was done by the same problematic agency WAPCOS and this was discussed by the EAC in their meetings in Oct 2010, July 2011 and March 2012. In our submission on this in March 2012[vii] we highlighted that the studies does not even have a word about the social, cultural and livelihood impacts of the projects on the basin population. As recorded in the minutes of EAC meeting of July 2011, WAPCOS did not even know about one of the 11 projects, namely Khuitam HEP, which was already cleared and hence it did not include any impact assessment of this project.
It is clear from above that cumulative impact assessment for none of the sub basins of Brahmaputra is available, and the total cumulative impacts of all the sub basin projects together has not even been attempted. Under the circumstances, the Ministry of Power Response is clearly not going to have any credibility.
An acceptable Cumulative Impact Assessment would have to be done by a multi disciplinary consortium of credible groups/institutions both national and regional (not WAPCOS which did so many the shoddy studies including the Environmental Impact Assessment of Lower Subansiri, which is a key reason for unending issues that plague the project), public consultation at every stage (ToR, draft studies) with local people etc after making the documents available in local language and facilitating their informed participation and also seeking their inputs.
Ministry of Power Response on Need for Public consultation & impacts in Assam On this issue, this is what the minutes of the Dec 10-11 2014 meeting state about MoP response: “… the areas under submergence and areas affected by land acquisition are declared as Project Affected Area as per policy.” This most bureaucratic reply is straight on the face denial of any consideration of Assam for the downstream impacts; leave aside the issue of compensating those affected. This is most shocking.
The minutes further says about the demand of public hearings to be held in Assam: “Regarding public hearing to be held in such areas of Assam, it was clarified that the same is conducted after wide publicity in the designated areas as per extant law and policy”. But extant law and policy has no provision for public consultations in downstream Assam, which in effect is again a straight on the face denial by the government, that Assam will have no right to public hearing, even though it is affected region!
The government could have surely adopted a more sincere approach and agreed to these minimum demands of conducting confidence inspiring Cumulative Impact Assessments, agreeing to hold public consultations in Assam and agreeing to compensate those that are going to be adversely affected in Assam, among other justified demands of the movement.
Movement rejects the Minutes The minutes end with the declaration of constitution of “Project Oversight Committee” (it “will be an on-going committee”) with eight members, four each from the Expert Group of Assam and Govt of India. It is not clear if this committee has been set up and who will chair the committee. However, going by the non serious responses from the Ministry of Power, a doubt arises if the government is at all serious about resolving the issues.
It was not surprising hence to see media reports that say the movement has rejected the inaccurate and manipulated account of the meeting in the minutes and demanded scrapping of the project itself and asking all concerned to take a clear stand[viii].
Himanshu Thakkar, SANDRP, firstname.lastname@example.org
[vi] Our earliest submission on Lohit basin study was in Nov 2011: https://sandrp.in/rivers/Lohit_Basin_Study_by_WAPCOS_A_mockery_of_e-flows_and_cumulative_impacts.pdf
[vii] This submission dated March 30, 2012 has not been uploaded on our website, but is available with SANDRP.