Above: A fabulous view of Ken river. Nesting sites of Long-billed vultures are to the right. All will go under water if Ken-Betwa linkup is carried out (Photo by AJT Johnsingh)
PREFACE: Following is a submission by the authors to the Ministry of Environment and Forests’ Expert Appraisal Committee on River Valley Projects, sent on Oct 25, 2015, as the EAC was to consider the Ken Betwa River Link Project for Environment Clearance on Oct 27, 2015. The authors had sent a submission to EAC in Aug 2015, when the EAC considered this project for the first time. In response to the various submissions that EAC received on this proposal, including one by the authors and another by SANDRP, among others, the EAC had asked the project proponent, NWDA (National Water Development Agency, an organisation under Union Water Resources Ministry) to provide a point wise reply. The NWDA response can be seen here: http://environmentclearance.nic.in/writereaddata/Online/EDS/0_0_15_Oct_2015_1405329601eac.pdf
One has to wonder that if the Ken-Betwa is such a worthwhile project, why is it necessary for the proponents to lie and obfuscate facts in order to promote it. We are not unreasonable individuals and have no reason not to want people to be benefited by appropriate development. If the project had more overall benefit than detriment, why would everyone not support it. However we find that it is prejudiced, not argued on reason, much is being obscured and alternate views have not been taken into consideration. The project is being undertaken in an area that has been evaluated as important enough to set aside for the tigers’ welfare. High priority must therefore be given to this species; but throughout totally inadequate consideration has been given to this.
We would like to highlight the fact that the proposed Daudhan dam will be the first dam in India ever to be built inside the core area of a National Park. It is the first dam whose proposed submergence area mostly lies within a Tiger Reserve. The proponents fail to mention clearly this fact and appear not to recognise that the legal definition of a Tiger Reserve includes not only the core area but the buffer areas also. When this is recognised the amount of area within the Panna Tiger Reserve is a great deal more than 41 sq km. Indeed much of the – on their own admittance – “very large” submergence area of 90 sq km would fall within the Reserve. In view of this and the precedent this will set, we feel that the EAC should consider the project with the utmost care. Since independent studies have shown that the cost benefit ratio is next to par, given what will be lost, it is hard to see arguments in its favour.
Statements such as “the project will provide improved living conditions for the tigers” and will “provide better breeding area for tigress” (sic) reveals ecological illiteracy. If this were the case why would the MOEF/NTCA not be pushing for such projects in all the tiger reserves of the country. To claim that Panna Tiger Reserve has “acute shortage of water and pastureland” confirms their lack of ecological understanding. Research shows that Panna Tiger Reserve has high herbivore density (46 tiger prey per square kilometre which is as high as some of the world’s best parks), more than enough to support its tiger and other large carnivore populations. This is not an issue for the Reserve.
The limiting factors of a dry forest area like Panna lie in more complex issues, two of the most critical of which are PA size and connectivity. Both of these will be negatively impacted by the proposed project. For the NWDA to claim that there will “not be any loss of corridor or migratory path” and to claim that the project will have “positive impact” on the tiger population is extraordinary to say the least (see image below). Decisions should be taken in the light of truth not fallacies so such remarks cannot be allowed to pass unchallenged. The reality of what will be lost must be taken into account when deciding whether or not the project is worthy.
To cite Pench as a comparable example is disingenuous. The Tiger Reserve was created after the dam was built so the submergence area could therefore be taken into consideration. Furthermore the major difference between Pench and Panna is that Pench still has a functioning corridor linking it to other tiger areas (like Kanha). A large part of the reason parks such as Sariska and Panna are at such risk of extinction is their isolation. Panna’s only viable connection is through forests to the west. This is the direction dispersing animals have been seen to take and is the only direction likely to lead them to further tiger habitat or from which tigers may come. It is exactly this path that the Daudhan dam and reservoir will block. As stated earlier, the reservoir will effectively bifurcate the park, cutting off core areas as well as the corridor to reserve forests outside.
The above diagram is self explanatory. It shows the present corridor width – approximately 26 kms. This will go under submergence and the small mount remaining will be only a kilometre or two either end; even this would be hardly usable for tigers due to human habitation and poor tiger habitat. Due to the proposed reservoir blocking all paths to the west, tigers will be forced to move in other directions that will escalate the human-wildlife conflict and hugely increase their likelihood of being poached.
A fuller understanding of tiger ecology and the larger Panna landscape would appreciate that the addition of areas elsewhere cannot compensate for this obstruction. Even now the Panna National Park is too small to hold a viable tiger population without connection to other areas; the post-project truncated park would be even less able to do so and without connection to the western forest areas, the tigers’ future in the Bundelkhand area would be doomed to extinction over time. Panna Tiger Reserve is the only hope for restoring a tiger population in the vast Bundelkhand landscape.
The NWDA continues to insist that their various sister and related organisations have assessed and examined the flow and found all the information they provide “in order”. Since all attempts to access information of the figures are met with refusal and the flow information seems to be a closely guarded secret, it is impossible to properly appraise their contentions. But in view of other inaccurate information presented, there seems little reason to be confidant that we can trust this. This may be the first dam in the world to have no impact downstream as has been claimed! Also importantly the whole basis of the project rests on these figures that they claim show the Ken to have surplus water. Since so many question this and their calculation, we feel it is certainly an issue that needs to be checked and assessed. For this the figures and data need to be made public. In a democracy it really is somewhat startling to be told that a river’s flow data is not something that can be given in the public domain.
It is also extraordinary that independently so many are complaining that the public hearings were not properly conducted, yet the NWDA still contend that all was as it should be. There is no doubt that proper information was not readily available to the local community and those attending the meeting. We ourselves were present and witnessed that those who tried to speak their queries and criticisms of the project were shouted down and prevented from speaking. Indeed there is film footage to prove this so their version of events can be easily disproved.
As part of our argument to show the lack of rigour and appropriate knowledge we had mentioned that the EIA claimed existence of brow-antlered deer in the area. The NWDA defend this by saying it was only in the annexure (they say annexure VII.15 although in fact it is VII.14) and was included “inadvertently”. We reiterate here that of the 49 species they list as present, as many as 20-25% are not found in the area, some are even species endemic to other countries and not found in India at all. The brow-antlered deer was mentioned as but one example. Does this sound like an organisation competent to assess the impact of a project on the environment and wildlife. There are many more arguments that can be given to show that it is not.
The EIA’s first assessment also claims the very specific number of 3260 sal trees (Shorea robusta) in the submergence area. This is in the report not annexure – is this also “inadvertently”? They cover this incompetence by claiming as defence that this was done “in the presence of Officers of the Forest Department, Govt of MP.” This sounds like a great insult to the Forest Department since it seems highly unlikely that there would be a single Forest Officer in MP who could not recognise a Sal tree and know that there are none within a 100km of the proposed submergence area of the Ken river. It is clear that the EIA was not done by competent experts, nor have they taken the advice and knowledge of such experts. It would be a travesty to clear a project on the basis of such a document.
The State Board for Wildlife passed the project at the last meeting in the face of strong opposition from several independent members who were present but completely over ruled (“Brushing aside the objections of the environmentalists..”). Apparently the Chief Minister was considering the project more in the light of concern for people than for the wildlife that the Board was constituted to consider.
When a drought prone, river-less area such as Dewas can resuscitate their agriculture and water availability with no big dam or destructive project, should not an EIA at very least look at the possibility of this for the command areas of the Ken-Betwa project. To say that smaller scale, less damaging suggestions “are not the alternatives of the project of this magnitude” (sic) is not an argument. It merely shows their disinclination to consider any alternative.
We continue to contend that a fresh EIA is required, done by an appropriately expert and credible agency, before this project can be considered in any meaningful way. Kindly do not make a decision on such inadequate documentation.
J Van Gruisen (email@example.com), R.S. Chundawat (firstname.lastname@example.org) Baavan – bagh aap aur van