Above: Protest against Lower Subansiri Project in Assam. Basin Study of Lower Subansiri is also a part of intense debate in Assam. Now these studies are under wraps by the MoEF and CC
Non-transparent Environment Governance does not help anyone, neither is it legal. In the upcoming Expert Meeting of the MoEF and CC on River Valley Projects (read dams), documents pertaining to 6 of the 8 projects being considered are not available!
We have appealed to the new Minister to take swift action against this non-transparent and non-democratic governance in the MoEF and CC. Please feel free to send similar letters to the email addresses mentioned below.
Shri Anil Madhav Dave,
Union Minister of State (Independent Charge)
Ministry of Environment, Forest and Climate Change, New Delhi. email@example.com
Copy to: Secretary, MoEF. firstname.lastname@example.org;
Additional Secretary, MoEF; email@example.com
Chairman and members of EAC on River Valley Projects (firstname.lastname@example.org, “Mr. Hardip S Kingra” <email@example.com>, “Dr. Surendra Kumar Mishra” <firstname.lastname@example.org>, “Chief Engineer (Hydrology), CWC” <email@example.com>, <firstname.lastname@example.org>, <email@example.com>, <firstname.lastname@example.org>, <email@example.com>, “Mr. C Achalender Reddy” <firstname.lastname@example.org>, <email@example.com>, <firstname.lastname@example.org>, Pabitra Chaudhuri <email@example.com>, “firstname.lastname@example.org” <email@example.com>, <firstname.lastname@example.org>, KD Joshi <email@example.com>, “Dr. Dhananjai Mohan” <firstname.lastname@example.org>, email@example.com, Panchagnula Subba Rao <firstname.lastname@example.org>)
Subject: Transparency in Environment Governance: Case of upcoming 95th EAC Meeting on River Valley Projects does not have documents in open domain.
Let us first take this opportunity to congratulate you on your appointment as the Environment Minister of the country. We are heartened that a River Conservationist is at the helm of the affairs even as the condition of India’s rivers is precocious and strong, transparent, accountable and democratic environmental governance was never as badly needed as now.
Having said this, it is unfortunate to note that Governance in MoEF is far from this objective. Take the case of the forthcoming meeting of the MoEF’s Expert Appraisal Committee on River Valley Projects, to be held on July 11-12, 2016. Of the 8 projects on agenda (see: http://environmentclearance.nic.in/writereaddata/Form-1A/Agenda/0407201650Q7BVEC95thAgendaforHEP.pdf as accessed at 5 pm on July 7, 2016) for the meeting, full documents are available in public domain only for two projects!
- No Documents available on MoEF and CC Website:
In case of projects, which include:
Kundaliya Major Multipurpose Project in Rajgarh District, Madhya Pradesh by M/s EEWRD Kundalia – for Environmental Clearance
Savanur Integrated Micro Irrigation Project in Haveri District of Karnataka by M/s. Karnataka Neeravari Nigam Ltd, Government of Karnataka – for Environmental Clearance
And Four Cumulative Impact Assessment Studies of far-reaching importance:
- Cumulative Impact Assessment & Carrying capacity study (CIS & CCS) of Lohit River Basin in Arunachal Pradesh – Discussion on the draft Final Report.
- Cumulative Impact Assessment & Carrying capacity study (CIS & CCS) of Beas River Basin in Himachal Pradesh – Discussion on the Inception Report.
- Cumulative Impact Assessment & Carrying capacity study (CIS & CCS) of Dibang River Basin in Arunachal Pradesh – Discussion on the draft Final Report.
- Cumulative Impact Assessment & Carrying capacity study (CIS & CCS) of Chenab River Basin in Himachal Pradesh – Discussion on the draft Final Report.
NO Information or documents are available on the Ministry website, where these documents are supposed to there (http://environmentclearance.nic.in/default.aspx)!
This is clearly against all the basic norms of transparent, accountable and participatory governance and also in violation of the orders of the Central Information Commission.
- Agenda uploaded late:
The agenda of the meeting to be held on 11th and 12th of July 2016 was made available less than a week before the meeting. This again is against the CIC orders and we request the Ministry and the concerned officials to kindly ensure that Agenda and ALL documents related to the agenda item are uploaded on the website at least two weeks before the meeting. Considering the remoteness of several locales from where communities wish to voice their concerns, two weeks is the minimum time needed.
We hence request the Ministry to kindly cancel the upcoming EAC meeting as the agenda was uploaded very late.
- Deliberate non transparency about Cumulative Impact Assessment studies:
We are constrained to point out that since February 2016, no documents related to Cumulative Impact Assessment studies have been uploaded on the Ministry Website, despite the fact that several crucial studies have been discussed in the EAC meetings since January 2016.
We had specifically written about this to the Minister and the Secretaries on 5th February 2016, but received no answer to the letter. Please find the submission here: https://sandrp.wordpress.com/2016/02/05/cumulative-impact-assessment-documents-not-in-public-domain-letter-to-moef-and-cc/
The upcoming EAC will be discussing four crucial river basin studies, including one for the Lohit Basin in which the EAC has referred to submission made by communities and organizations several times in the past. In case of the Beas Basin Study, the suggestions made by SANDRP on the TORs were accepted by the EAC. Similarly, Chenab Basin Study has seen simmering conflicts in Himachal Pradesh. However, abruptly, MoEF has decided not to make available any of the river basin studies for Cumulative Impact Assessment and Carrying Capacity Assessment. As we have pointed out in our submission, Cumulative Impacts are clearly mentioned in the EIA Notification 2006 and are an integral part of the Environmental Clearance Process and hence, legally too all documents pertaining to CIA discussion have to be made available in public domain. Not doing so will make all related decisions untenable in law.
Cumulative Impacts of projects have significant bearing on whole river basins, including downstream communities. In fact, Public Hearing must be conducted about the CIA & CCA Studies in all the districts of the relevant basins. Not doing so will not help at all, as can be seen through worrying and persistent conflicts in Subansiri, Tawang, Chenab basins, etc. The decisions taken in such non-transparent, non-participatory and unaccountable manner will have no public acceptance.
We therefore request you as the the new Minister to kindly ensure that all documents related to CIA-CCA studies are made available in the open domain as soon as possible. No CIAs should be discussed in the EAC meetings in the meantime.
We are sure the Minister appreciates the gravity of these issues, which have far reaching implications for environment governance and also harmony in far flung regions.
We request the Minister to kindly take swift and appropriate actions on the same. We would be happy to discuss these issues in person, if the Minister or officials so wish.
Looking forward to hearing from you,
Himanshu Thakkar and Parineeta Dandekar
South Asia Network on Dams, Rivers & People, Pune/ Delhi