Even as the Expert Appraisal Committee on River Valley and Hydropower Projects sits to decide about Environment Clearance to Ken Betwa River Link Proposal on Feb 8-9, 2016, a number of people have written to the committee against recommending clearance to the project. We are publishing here some of them:
PROF BRIJ GOPAL TO EAC ON JANUARY 17, 2016:
GREETINGS and very best wishes for a Happy, Healthy and Fruitful New Year 2016.
I, Dr Brij Gopal, wish to submit the following in the above noted subject for your kind and immediate attention.
1. I write to you in continuation of my earlier submissions in August and October last year on the EIA/EMP of the K-B Link project.
2. I have noted that your EAC (vide Minutes of the meeting held on 26 October 2015) has taken note of various representations and passed them to the project proponent for a response. I also note with satisfaction that the EAC has asked for several otjer clarifications related to the impacts of the project, including the Conservation Management Plan for Ken Gharial sanctuary, mechanism for ensuring a longitudinal connectivity for non-disruptive biota movement and sediment transport, and the impact of the reservoir on the microclimate. I have also noted that
the EAC will consider the proposal after taking into account the LSMP to be prepared by the WII and a second independent opinion on it.,
3. I wish to reiterate and emphasize for the EAC’s specific consideration (beside points in my earlier submission) before it takes any decision on the EC to the project in any form:
A. Foundation of the Project: the proposal for K-B linking is based on the assumption than River Ken basin is water surplus that is not supported by any hydrological data, is erroneous and farthest possible from the reality on the ground. The proposal is rooted in the desire to construct four projects in upper Betwa basin for growing rice and sugarcane in place of pulses and millets while Panna district gets no water from the project. Social implications need to be examined.
B. Incomplete TOR: As stressed earlier, the EIA has to consider the impacts on the entire downstream river and the entire upstream stretch to be affected by submergence. The TOR for the EIA has to be revised. The impacts on the groundwater must be included. Banda- the only major city on the river banks is suffering from water shortage.
C. Cumulative EIA: The River linking projects CN NOT be divided into parts and treated separately. The impacts of diverted water on River Betwa downstream and the impacts of four upper Betwa projects have to be considered together with the impacts in Ken basin. The EAC should not ignore earlier circulars and decisions with respect to cumulative EIA and Environmental Flows. EAC members will be aware of the MOWR’s directive to the CWC about withholding all projects until the issue of environmental flows is fully settled.
D. Landscape Management Plan: I welcome the proposal and opportunity for preparing Landscape level management plan which should become the norm. But I am unable to understand how can there be a LSMP without a cumulative EIA and that too on a landscape level. The proposed LSMP cannot be and should not be wildlife-specific and will have to necessarily conduct a detailed EIA for the two sub-basins – present, proposed and future planned projects for water and land, and extend its spatial scope to the areas beyond the two sub-basins into entire “tiger landscape” in the region. The humongous task cannot be completed even in a few years.
While we continue to debate these modalities, the alternatives to the proposed project continue to be ignored and the people of Bundelkhand remain unprepared to meet the challenges of rising temperatures and frequent droughts in the region. Far more effective alternatives based ontradition al practices of tanks and farm ponds coul be implemented within 2-3 years at a nominal cost relative to the costs of the K-B Link project that totally ignores the warnings of climate change.
Respectfully submitted for due consideration of the EAC whenever it meets next..
with best regards,
SANCTUARY ASIA EDITOR BITTU SEHGAL TO EAC on FEB 6, 2016:
I wish to officially record my strong opposition to the above project.
I have served on several Expert Committees of the MoEF for over a decade. I am therefore well aware of the political and contractor-driven dimensions to the environmental clearances issued by your committee. I am also aware that most often far too many projects are presented to the committee and clearances are therefore rushed.
I would, however, like to suggest to each one of you that you contemplate your own personal roles in the tragedy that would befall India in the event that you endorse this proposal, which threatens to destroy one of India’s finest forests, the Panna Tiger Reserve.
In an era of climate change, forests are going to be not only the primary source of water, but also our insurance against the worst impacts of floods and droughts. Drowning such large forest parcels is akin to burning lifeboats on a sinking Titanic to stay warm.
I searched for, but was unable to locate any link that provided the DPA, DMP or EIA for the above project. Nor has the river-flow, ground water mapping and basin hydrology data been made known. I would therefore be grateful to the Chairman and Members of the Committee if these documents be made available to me at the earliest.
Kindly do not rush into taking any decision on this project without much fuller national consultation and debate.
I have personal experience of the forests of Panna as I have also served in the past as a member of the Project Tiger Steering Committee. History will not forgive us if we sacrifice such survival assets for short term gains.
I would like an opportunity to present my objections to this project in person and look forward to receiving an invitation from your committee for the same.
Bittu Sahgal ,Editor, Sanctuary Asia
FORMER NBWL STANDING COMMITTEE MEMBER PRERNA BINDRA TO EAC ON FEB 7, 2016
I wish to express my concern and officially record my opposition to the Ken-Betwa river linking project which threatens to destroy one of India’s most pristine forests. The project is entirely located in one of India’s finest tiger reserves, Panna, and will submerge a large chunk of the core area of the park, which has half of the reserve’s tigers, and also nesting sites of the critically endangered white-backed and long-billed vulture.
I have served previously as a member of the Standing Committee of the National Board of Wildlife’s and also served on various committees of the National Tiger Conservation Authority.
Sirs, I will greatly appreciate if you would read the following note (published previously in an online site) which details some of the concerns regarding the Ken-Betwa river-linking project.
I am grateful for your time, and kind consideration.
Former Member, Standing Committee, National Board for Wildlife
NOTE: 7th February, 2016
Ken-Betwa river-linking to drown Panna tigers
The pristine forests of Panna, and its tigers, are earmarked to be submerged by the first of India’s ambitious–estimated to cost Rs 560,000 crore at 2002 prices–-river linking project, the Ken-Betwa link. The project was scheduled to be initiated in December 2015. After being bulldozed through the State Board for Wildlife, the proposal will now be put up in the next meeting of the Standing Committee of the National Board for Wildlife. According to sources, that the project will pass through is a given, with the government intent on proceeding with it .
The entire project is located within the reserve, directly submerging 89 sq km. Over 58 sq km is in the core/critical tiger habitat, deemed to be inviolate and sacrosanct as per law. The impact area will be far greater–construction, quarrying, mining, blasting, staff colonies, power houses, etc–will disturb, dissect, disembowel, obliterate over 200 sq km of the tiger reserve, and all the wildlife within it. This includes over a dozen tigers, including breeding tigresses. In fact, nearly half of Panna’s breeding tigresses reside in the submergence area.
We know tigers are rare, critically endangered and hence precious. The tigers of Panna are, in a way, even more special. After Panna’s tiger extinction debacle in 2009 (mainly due to poaching, compounded by the management’s denial of the crisis), the population was rebuilt. In an unprecedented exercise, tigers were translocated from other reserves in Madhya Pradesh. The Panna team (which also includes its elephants!) worked 24×7 to protect and monitor the tigers, and keep them safe.
Their dedication was rewarded when the tigers bred, raising cubs–and the next generation of Panna’s ”new“ tigers. From zero, there are 32 tigers in the reserve now, and they are charting new territory, dispersing outside and populating the landscape. There is no such parallel in the world. Panna’s success has won it international fame, and is cited as a model for conservation success.
There has been a similar effort in Sariska (Rajasthan) after tigers went extinct in 2005, but due to extreme disturbance and pressures in the park, progress has been slower.
The Panna project cost the public exchequer Rs 4.78 crore over five years. It will all go to dust—the expense, the effort, and the pride of this extraordinary achievement.
It is not just tigers that the project will sink. The reserve has other rare wildlife—including critically endangered vultures, caracal, wolves, chausingha, sloth bears, leopards, pangolins—who now face an equal risk.
The proposed reservoir, the canals—a network of 221 km—and the ongoing construction will wreck crucial wildlife corridors towards the south and south-west. Tigers regularly use these corridors. One example is ”T3”, who travelled about 450 km through three districts towards Pench Tiger Reserve, which was his original home, thus showing us that tigers have a homing instinct. Meanwhile, at least four tigers traversed the south-west corridor through the patchy forests of Gwalior-Jhansi-Lailtpur. Among them was tigress “P222”, who eventually had her cubs on the park’s south-western tip, reiterating the critical importance of the connectivity this corridors provide.
If you think drowning tigers is of little concern, then consider the fact that its forest is the catchment of the perennial river Ken, which feeds three districts downstream. This Yamuna tributary harbours the gharial, mahseer fish (called the tiger of the river) and other endangered aquatic fauna. Ken is the lifeline of the tiger reserve’s ecosystem, and also of millions of people of Panna and its adjoining districts. It will affect the livelihood of fisherfolk and farmers. Experts opine that the river Ken falls short in meeting the water requirements of the people along its course. How then is it expected to have excess water to feed another river?
On a recent visit to the region, I found a palpable anger among the people that the project will seek to transfer the Ken’s water to irrigate Bundelkhand districts in MP and Uttar Pradesh, even as they themselves are water-starved. This unrest has the local leaders worried, even as the project is backed by the Chief Minister Shivraj Singh Chauhan and the Union Minister of Water Resources Uma Bharati. At a function in Panna on 1, November 2015 (Madhya Pradesh State Foundation Day), state cabinet minister Kusum Singh Mahdele said that Panna Tiger Reserve could not be compromised at any cost, echoing the sentiment of the local BJP leader Sadannand Gautam who questioned the wisdom of the river linking, and its fatal impact on the reserve.
Backing them were the children of Panna, who rallied for their tigers, whose forests ”gave them water and fresh air, and had made their town famous!”
Regardless, the river link project is on a fast track. The state pushed to denotify 90 sq km of the Panna National Park through the State Board for Wildlife in its September 12, 2015 meeting, in spite of stiff opposition from non-official members, who warn that the project will mean the end of Panna. In a strongly worded dissenting note, two non-official board members, including India’s former environment and forest secretary, said, ”The state and the nation will have to decide whether to have the project or the park, we cannot not have both.”
The irony is that such monumental decisions which lay waste our natural heritage and destroy livelihoods, is based on shoddy environment impact assessments. This project’s EIA is a ”shining“ example. It omits to mention endangered species in the Ken river basin, noting that ”the submergence area is neither home nor important habitat for wildlife or birds“. The tigers, leopards, vultures, gharials, etc, obviously do not matter. Instead, the EIA report discovers new species in the park–the slow loris (residents of evergreen forests in the north-east), Manipur brow-antlered deer (very obvious where it is found, except to the ‘learned’ EIA consultants!), and describes Panna as a sal forest (it isn’t). The EIA report also finds that the project will be beneficial to fish, as it will give them a ”shortcut“ to migrate through the canal!
If it weren’t so tragic, it would be funny.
It is also proposed to ”mitigate“ and ”compensate“ Panna’s loss by adding Nauradehi, Rani Durgawati, Ranipur and Mahavir Swami wildlife sanctuaries as ”satellite cores“ of the reserve. But these are already sanctuaries—no new area is getting protective cover. How will these satellites survive if the main forest—Panna—and connecting corridors are pillaged? Rani Durgawati, for instance, is a tiny 25 sq km park, and about 150 km away from Panna, with increasingly fragile connectivity.
And how does one ”compensate“ for pristine forests, gorges and grasslands that will be submerged and destroyed? Consolidating tiger habitats is the need of the hour, but no amount of ”compensation“ can alleviate the damage of drowning Panna’s heart.
As we well know, it will simply mean the end.
Source: Prerna Singh Bindra, DailyO, 25, November 2015
SANCTUARY ASIA ASSISTANT EDITOR CARA TEJPAL TO EAC ON FEB 8 2016:
Respected Chairman and Members,
In continuation of my earlier submissions (the last one dated Oct 24, 2015, see below), I have gone through the NWDA response dated January 5, 2016 where in annexure 2 they have also claimed to respond to submissions including ours. Our quick response on key issues:
- Firstly, a bare reading of the issues I have raised and the NWDA response shows that in most cases NWDA has failed to properly respond to almost any of the issues I have raised. I have tried to show that in detail a couple of times, but NWDA does not seem to be sincere and I would like to urge EAC to invite some of us to the EAC meeting so that both sides have fair chance to counter and question face to face.
- Kay issue is the gross inadequacy of the EIA-EMP of the project and EAC needs to take a clear stand that the whole EIA-EMP is so grossly incomplete, wrong, inadequate and misleading that it is not acceptable and the whole EIA-EMP must be asked to be redone by a more credible and competent organisation. EAC needs to take this decision urgently. It is unfortunate that even after confronted with such flawed EIAs in every project, EAC has refused to conclude about the quality of the EIA-EMP. We hope EAC takes a decision in this case.
- That brings to the key issue of LMP that WII has been asked to do. The EMP is essentially going to redo the EIA and EMP, since without full assessment of the impacts, no management plan can be formulated and it is clearly evident to any independent observer that current impact assessment is not serving that purpose. In such a situation, to propose a so called conceptual plan of LMP to to suggest that this can go on with the implementation of the project is to suggest that let us to Environment and social impact assessment even as we implement the project and we will come up with the EMP also during implementation. This is clearly unacceptable. Unless full LMP is available, it will not even be known if the impacts are mitigable at all. No decision about the viability of the project can be taken without full LMP is available and is reviewed by independent experts as suggested by EAC repeatedly.
- Similarly on the question of viability, there can be no conclusion about the same till NWDA makes available: (i) all hydrology figures used in the design of the project, including the study done by NIH. (ii) water balance used to show that Ken is surplus and Betwa is deficit. Such water balance will be required at basin level as well as at project level. NWDA has so far not made this available and without that the viability of the project, e-flows and downstream river ecology cannot be ascertained.
- The contention of NWDA that “…Alternatives like ground recharge, rain water harvesting, water shed management measures are not the alternatives of the project of this magnitude…” is unacceptable since it is totally speculative. NWDA has done no such assessment. If they have done any Ken Or Betwa basin level or Panna or Chhattarput or Tikamgarh or Mahoba district level assessment, let them put share them to prove that indeed that is the situation. EAC should not accept such baseless responses.
- We have given specific quote from the DPR about how the poject components will affect the Ken Ghariyal sanctuary, but NWDA has not responded to that. Most of their responses are in terms of contentions and not based on reality, this is just one illustration.
- If NWDA is accepting that Hindi Exec summary was not really a summary of the EIA-EMP ans that the new EIA now on MOEF website is corrected, improved and better, that is their acceptance that the EIA-EMP used for the PH was flawed. In any case, the EIA on the MoEF website continues to remain grossly inadequate and of unacceptable quality.
- The NWDA response dated 05.01.2016 says on page 3 that SBWL has approved the project on conditions, which include: “The study of mitigation impact on vulture habitat at project cost by BNHS”. Firstly, this statement does not make any sense, their translation of the Hindi is so callous and wrong, it should have read: “The study of mitigation of impact on….” Secondly, this again is an admission that firstly, there is not even study of impact of the project on vulture habitat, nor the mitigation has been planned, these should have been part of the EIA-EMP and cannot be done post approval/ launching of construction.
- Similarly, NWDA has rejected the dissent note of the then PTR Project director as “invalid” and also the dissent notes submitted by independent experts at the SWLB meeting, without addressing any of the issues or facts raised in the submissions. This is not the way to treat dissent notes.
We will look forward to EAC applying its mind to the various issues we have raised and NWDA responses, on their merits and arriving at a judgement. We would be happy to come to EAC meeting to explain this further if necessary.
Himanshu Thakkar (firstname.lastname@example.org), SANDRP