New Grounds Why Pancheshwar Dam Is Unviable Project

Date 3.12.2017

To,

The Chairman and members,     

The Expert Appraisal Committee,                                                                    

River Valley Projects,

Ministry of Environment, Forests and Climate Change, Govt of India,

Jor Bagh, New Delhi 110 003

Sub: Urgent submission regarding the Environmental Clearance for the proposed 5040 MW Pancheshwar Multipurpose Project in Uttarakhand and Nepal.

Dear Chairman & Members of the Expert Appraisal Committee,

This is to bring to your notice, and to place on record, some serious concerns related to the Environmental Clearance of the proposed 5040 MW Pancheshwar Multipurpose Project. The concerns are both, on Points of Order, as well as observations on and serious flaws in the Environmental Impact Assessment report submitted by WAPCOS.

First, the Points of Order:

1. Unscientific delimitation of Scope of the EIA study: The Expert Committee on River Valley Projects is well aware that a radical alteration of a river, in terms of flow volumes, seasonal rhythms and connectivity, such as proposed under the Pancheshwar Multipurpose Project (the highest impoundment anywhere in the Himalaya) has serious upstream and downstream environmental impacts far beyond the impoundment, or a 10 km terrestrial periphery of it. Such a limited scope for the study of impacts, as has been done in the EIA submitted by WAPCOS for approval is unscientific, grossly misleading and unacceptable. Further elaboration is detailed in this note.
2. Legal requirement for the National Tiger Conservation Authority (NTCA) and the National Board for Wildlife (NBWL), to be involved in the approvals process. As a consequence of regulation of monsoon flows by the Project in the name of flood control, a large complex of connected Tiger Reserves and Protected Areas in the proximate Terai, both in India and Nepal, sustaining populations of the most endangered and valued fauna of India and Nepal, will be doomed to collapse due to loss of critical habitats. The Terai-Duar Savanna and Grasslands Ecosystems are characterized by swamps, marshes and grasslands that are created and maintained by annual inundation and renewal by the Mahakali-Sharda river during monsoon floods and spates. These include the Pilibhit Tiger Reserve, the Kishanpur Wild Life Sanctuary, the Katarniaghat Wild Life Sanctuary, and the Dudhwa Tiger Reserve in India, and their proximate PAs in Nepal namely the Shuklaphanta Wildlife Reserve and the Bardia National Park. The two statutory bodies concerned in India, and their counterparts in Nepal, must necessarily be involved in any such approvals process. Further elaboration in this note.
3. Incomplete Assessment on critical seismological aspects: While the proposed dam-site is less than 3 km away from a seismologically active fault, the overburden of the greatest volume of impounded water is proposed to be exactly over the North Almora Thrust, that follows the Sarju triburary and cuts across the Mahakali river just above their confluence. This has been a) underplayed in the EIA, b) the details are equivocal and are those provided by the Project Proponent in the DPR, and c) the matter has been dismissed by recommending further studies. The process is incomplete on one of the most important security and feasibility aspects. Until such studies are conducted, or the many studies already existing on the matter are examined by designated and independent geologists, any approval granted would be a serious dereliction of duty. Further elaboration follows.
4. Non-implementation of the Indo-Nepal Joint Mechanism for the EIA. As per the spirit and the letter of the Mahakali Treaty between India and Nepal, under which this project is proposed, the appraisal of any EIA report for approval is required to be  undertaken by a joint mechanism involving representatives of both countries, since the environmental impacts will be borne by both countries. Side-stepping this is neither appropriate nor will it stand legal scrutiny.

Second, observations on the EIA, for your consideration:

1. This addresses points 1 and 2 of the Points of Order. Apart from the proposed generation of hydropower and the augmentation of irrigation through existing networks, one of the aims of the Pancheshwar Multipurpose Project, is flood-control. Floods are cast as undesirable phenomena, bringing temporary displacement and economic losses to populations settled along the floodplain. Monsoon flows are proposed to be impounded and released in a ‘regulated’ manner, and the costs of the project offset by the projected gains in terms of crops saved from flood waters. The tables on planned releases for irrigation show that zero compulsory monsoon flows are provided for, other than those already required for irrigation in the Lower Sharda Command Area. Even if this ongoing release for irrigation requirements constitutes 30% of the monsoon flows, all of it to be used up in the downstream Command Area, it will not provide the renewing inundation and lateral connectivity that this river in spate does. It hardly bears mention to an Expert Committee, that the casting of floods as an undesirable phenomenon to be controlled, is an obsolete and tired ontology. As an intervention, it is amply demonstrated by experience to be environmentally disastrous. We know that in essence, seasonal flow variations are what constitute and characterize a river. All life in and around aquatic and riparian ecosystems have evolved their life-cycles and survival strategies in anticipation of these variations. Drastic modifications in natural flow variations will have drastic impacts.

Some of the obvious and drastic consequences to be anticipated in this context are the following. Immediately downstream of the Rupaligad Re-routing dam, as soon as the Mahakali reaches the plain, is the beginning of a complex of Protected Areas, both in India and in Nepal, that have been designed and set aside as a most valuable conservation unit by both Governments of India and Nepal. They work as a unit because they provide sufficient habitat only when put together, are contiguous and provide connectivity, they are a mosaic of complementary habitat types, and they are longstanding corridors for seasonal movement and dispersal of the valuable wildlife being protected. They contain wildlife and habitats that have been accorded the highest protection categories in both the countries, namely Tiger Reserves and National Parks. On the Indian territory there are the Pilibhit Tiger Reserve, the Kishanpur WLS, the Katarniaghat WLS and the Dudhwa Tiger Reserve. The Expert Committee is probably aware that the Dudhwa Tiger Reserve constitutes the amalgamation of the Dudhwa National Park, the Katarniaghat WLS and the Kishanpur WLS under a unified Tiger Reserve. On the Nepal side there is the Shuklaphanta Wild Life Reserve, and contiguous to the Dudhwa Tiger Reserve in the North, is the Bardia National Park.

It is important to see clearly what is at stake here. The proposed regulation and alteration of the existing natural flow variation in the Mahakali-Sharda river during the monsoon for so-called flood-control, is going to lead to a drastic degradation of the unique habitats, its trophic productivity, and therefore a collapse of the populations of all the protected wildlife that are uniquely evolved to depend on flood-plain habitats. All the Protected Areas mentioned in India, and the Shuklaphanta WLR in Nepal are located on either side of the Mahakali-Sharda river, interlaced with minor tributaries. They form a mosaic of marshlands, swamps and grasslands as well as moist deciduous forests that are completely dependent on the seasonal spates in the Mahakali river during the monsoon for their creation, and for annual renewal of productivity and the maintenance of trophic levels. In addition to critically providing lateral hydrological connectivity, it also provides seasonal isolation for the breeding of many of the protected species. This habitat is unique and valuable, and as a part of the global strategy to conserve biodiversity aiming to protect representative example of all the world’s ecosystems, has been designated as the Terai Ecosystem, and the particular habitat as the Terai-Duar Savanna and Grasslands.

The Expert Committee is probably aware that these Protected Areas contain wildlife that have been accorded the highest protection Scehdules in India under the Wildlife Protection Act (Schedules I and II). They include the Tiger- Endangered (IUCN Threat Status), Bengal Florican- Critically Endangered, Lesser Florican- Endangered, Hispid Hare- Endangered, the last of the northern populations of the Swamp Deer- Vulnerable, the western-most population of the Indian Rhinoceros- Vulnerable, Gharial- Critically Endangered, Marsh Crocodile- Vulnerable and the Ganga Dolphin- Endangered. Shuklaphanta also has an elephant population-Endangered, that ranges across  forest areas in India and Nepal. Habitat loss and degradation are known to be the single largest cause of wildlife extinctions and population decline. Floods and seasonal inundation is precisely what creates and sustains these Protected Areas and all the life therein. Changing those  critical conditions for survival, is a very serious matter for both the nations involved and must not be treated lightly or be ignored by this approvals process, as is presently the case. The Expert Committee is requested to give this matter due consideration, and to not take any decision on this matter in isolation from the relevant statutory bodies, such as the National Tiger Conservation Authority, Uttarakhand & UP’s state Boards of Wildlife and the India’s National Board of Wildlife, and their counterparts in Nepal.

2. Addressing point 3 of the Points of Order. Incomplete and inconclusive study on geological and seismological aspects. For a project that is going to cost over INR 331 Billion (in reality likely to be above Rs 500 Billion for just the hydropower component even at current prices), and inter alia displace over 31,000 people in 134 villages, submerge the very best agriculture land in Kumaon and Far Western Nepal, apart from some of the downstream impacts already mentioned, any approval prior to sufficient consideration of the seismological aspects would be, to say the least, irresponsible. The chapter on Geology in the EIA presented by WAPCOS is equivocal and inconclusive. There are clear indications that the site chosen for the highest dam in India is geologically unsuitable. Here, to put it mildly, is the rub.

Both the dam-sites are located on the Almora Klippe which is a shallow layer of low grade metamorphics, predominantly mica schist (rock soft enough to flake off with your fingernail) and fractured quartzite underlain with alluvial sediments. The Almora Klippe is bounded on the North by the North Almora Thrust, and in the south by the South Almora Thrust that co-incides with the deeper Main Boundary Thrust. The limits of this shallow remnant Nappe itself is an indication of geologically recent and serious tectonic movements. The North Almora Thrust runs right along the Sarju river, and actually cuts across the Mahakali just north of the confluence of the Sarju with the Mahakali, and many studies have shown that it is a currently active Thrust, and these will be quoted soon. The Pancheshwar dam-site is less than 3 km south of this geological fault, and the greatest mass and weight of impounded water will be precisely over the North Almora Thrust at the confluence, where the combined impoundment volume will be the greatest. First, let us look at some aspects from Chapter 6 of the EIA that require your attention.

On reservoir competence: When impounded by this 315 meter high dam, the reservoir will cover an area of 116 sq km, set across a series of currently active Thrusts. While this is quoted (from the DPR) and mentioned in the EIA, the significance of this has been downplayed. The reservoir area consists of litho-units that are predominantly carbonaceous (dolomitic limestone) in the arms of the Mahakali, the Sarju and the Chamelia. Probability of leakage and losses due to karst formations have been dismissed in one sentence referring to the limestone being argillaceaous (clayey). Anyone travelling down this section of the Mahakali will notice that the limestone units here are not homogenous, and this is an unfounded generalization to make. The reservoir area is also interspersed with units of shale and slates, and this has been mentioned as an area of concern, but only for rim stability. Further on rim stability, the report mentions in Chapter 6 page 11, last para: “The main issues pertain to reservoir rim stability especially considering the large sections of the reservoir slopes exposing vulnerable argillaceous units.” Surprisingly, here argillaceous is inversely quoted in an instability context. They recommend that “The reservoir rim stability of northern limb in the arms trending along strike should be critically examined” and mention that GSI studies in the reservoir area are underway and that on availability of the result, reservoir competency regarding landslide potential will have to be further evaluated.

Further, on the competence of the actual dam structure, the following is brought to your notice. Regarding fracture permeability owing to foliation joints at the location, the report mentions on page 18 “The joint openings possibly tend to remain open even in the considerable depth in drill holes, resulting permeability values above the permissible limits, persisting to deeper depth. This could be possibly due to lateral stress due to movement along the thrust planes.” Further, in page 20 they mention that the bed-rock “at the dam foundation is not homogenous as competent quartzite is often associated with mica schist bands upto 10 meters thick. This intercalatory association of alternating foundation media of differing strength parameters renders the foundation heterogeneous”. Even the recommended stripping to a depth of 35 meters and designing a foundation for the strength of the weaker schist is still not assuring in the face of the “two shear/fracture zones that have been encountered in drill hole DH-3 from 38.0 m to 38.20 m and 41.0 m to 42.0 m depths. The affected portion of the lower zone seems to be extending upto 44 m depth. Since this shear/fracture zone is foliation parallel, dipping upstream at moderate angle, it may not pose any serious threat to sliding stability of dam and seepage control from reservoir. But it is likely to extend along the dam body for considerable length. As such elaborate dental treatment evolved by designer will be necessary.” Concluding this, in the last para on page 21, the report recommends that rock mechanic testing of different litho-units to characterize rock mechanic parameters, especially shear strength and deformation be carried out to ascertain rock mass attributes and to further characterize the rock mass.

Our submission to the Expert Committee is that it is clear that proper investigations as to dam feasibility and rim stability are incomplete and inconclusive. There are serious questions that need to be addressed, and the recommended and ongoing investigations need to be completed before any approvals can be granted. It is certainly not enough to say that even though the two shear/fracture zones encountered below the proposed dam that extend at least upto 44 m depth, that since the fracture is foliation parallel and dipping upstream at a moderate angle, that it “may” not pose a serious threat to sliding stability of the dam, or seepage control from the reservoir. Or to put the matter away by saying that “elaborate dental treatment evolved by designer will be necessary”.

The equivocation and downplaying of great risk in a cavalier manner by the WAPCOS report is amply clear. References to a few other studies regarding the serious and recent nature of tectonic activity specifically in the area are mentioned below for your reference. While a) and c) deal, among other things, with the NAT fault along the Saryu river, b) deals with the geologically recent seismic activity that not only formed, but also drained the paleolakes, the beds of which Vadda and Pithoragah are presently located on, and the active fault along the Thuligadh, that drains into the Mahakali, very close to and just north of the proposed Dam site. The names of the authors speak for themselves.

a) Geomorphological and Geological Investigation of Neotectonic Activity of Saryu River fault (SRF), a part of North Almora Thrust (NAT) in Seraghat-basoli Area in Central Kumaon, Uttaranchal. P.D. Pant, GC Kothyari, Khayingshing Luirei. Journal of Geological Society of India. Volume 70, Issue 5 Volume, November 2007.

b) Quaternary Paleolakes in Kumaon Lesser Himalaya: Findings of Neotectonic and Paleoclimatic significance. KS Valdiya, BS Kotlyia, PD Pant, Manik Shah, Nidhi Mungali, Sunita Tewari, Nalin Shah, Moulishree Upreti.  Current Science Vol 70, No 2, 25 Jan 1996.

c) Evidences of Active Deformation in the Northwest part of Almora in Kumaon Lesser Himalaya: A Geomorphic Perspective. GC Kothyari and PD Pant. Journal Geological Society of India, Vol 72, Sept 2008.

3. Other areas of concern regarding the EIA by WAPCOS. This EIA presented to the Expert Committee for environmental clearance is extremely poor and clearly unacceptable. The problem is not just that it is shoddy and incomplete work, which it is, but even more importantly, it completely misrepresents the ecological scenario, as well as the environmental impacts of the project. And this is deliberate, which should actually render it a criminal misrepresentation. The flaws and inadequacies are too many to go into in detail, but we shall list some of them here briefly, to bring them to your notice, and for the record.

a) Is it a serious matter that the agency conducting an Environmental Impact Assessment does not know where the river they are studying originates from? That they make up names of non-existent glaciers, and cite locations and heights of peaks that do not exist? That they call the Mahakali an antecedent river, which it is not, and they randomly quote stream order numbers that do not conform to any known system of stream classification? Like the Saryu being a first order stream for example. These are not typographical errors. This is work that you would fail a class 10 student for. On page 8 while introducing the Mahakali river basin the report states that “The Mahakali river originates from the Lipu Lekh glacier at an elevation of about 7,820 m in the Himalayas”. For the information of the Committee, there is no glacier on either North or South slope of Lipu Lekh, and no glacier in the world is located at 7,820 meters altitude. And neither is there any peak of that height in the location mentioned. Is an EIA report that stems from such levels of incompetence acceptable to the Expert Committee?

b) WAPCOS have called their report a CEIA, which is remarkable, since there is nothing comprehensive or cumulative about it. Unless C is for something that the reader is yet to discover. Two aspects bear pointing out here. One, that while spelling out the method adopted for the EIA in Chapter 4, they mention that in addition to the submergence area, 10 km periphery of the project area, the area for appurtenances and 10 km of the appurtenances, that they have studied the “Catchment Area intercepted at the Dam site”. This, as you will see, has not been done. Apart from their animal species list, with fictitious inclusions, they have done no any work in the huge catchment area upstream. Two, the only other hydropower project in the entire catchment mentioned by them in Fig. 2.1 on upstream and downstream developments, is the Dhauliganga HEP. This is misleading because it makes no mention of 41 other large, medium and small hydropower projects planned and under way in the various tributaries of the Mahakali upstream, just on the Indian side.

c) The projections for utilizing the flows downstream of the Rupaligad dam to augment irrigation potential in command areas below the Tanakpur, Banbassa and Lower Sharda Barrage, and on which they have based their economic justification is flimsy. The hunkering gorilla in the room that everyone is ignoring, is the Interlinking of Rivers Project of which the Sharda Yamuna Link is the longest of them all, and will drain into the Arabian Sea instead of the Bay of Bengal. If the Pancheshwar Project has the heft (most conservatively) of INR 331 Billion, then the ILRP has the heft of US$ 120 Billion. If and when that comes through, is there any doubt where the water will be prioritized for? This is quoted here only in the context of their cost projections, put together for justification. The fact that no additional irrigation infrastructure is planned under this project, is also indicative. And is it not obvious, that for all the benefits from augmented irrigation calculated, that while staying within the existing infrastructure, there is no way that the same volume of irrigation will be required (even if available) in the Rabi crop (wheat, oilseeds, potatoes and vegetables), as compared to the Kharif crop (paddy, sugarcane and maize). And only another small detail that their calculations for increased food production counter-pose rain-fed agriculture production with their augmented irrigated production, both in the command area. That farmers currently augment any existing deficit with ground water irrigation does not even figure in their calculations.

d) A related matter of concern is their calculations of increased food production through augmented irrigation in the distant plains, in a context where the very best and largest fields for agriculture in all of Kumaon, and in Far West Nepal, are planned to be submerged and lost by the Pancheshwar dam. This is a repeat of the very best floodplain agricultural land in Himachal Pradesh being lost to the Pong Dam, and in Garhwal being lost to the Tehri dam. Apart from counter-posing hypothetical food production with actual food production, what value is ascribed at all to aspects such as regional food reliance and self-sufficiency of hill regions? NIL. What will be the fate of people left in these valleys, in the not-inconceivable event of any crisis leading to the disruption or breakdown of centralized or distant food supply?

e) The WAPCOS report’s analysis of the biological aspects is not just poor, but it is grossly misleading. This is not surprising coming from WAPCOS, who in an EIA for a hydropower project in the Gori river, a major tributary of the Mahakali, found species of fish where no fish existed, and after a whole year of study, listed eight birds (at one place I EIA), three of which were two crows and a myna. And this, in a valley that is designated an Important Bird Area (IBA) of India, harbouring over 330 bird species. Coming to their present lists however, it needs to be pointed out that they have not adhered to the methodology they have described in their EIA methodology i.e. evaluated catchment area intercepted at dam-site, but for most evaluations (other than mention a few high altitude animals randomly, including fictitious ones) stayed within the 10 km periphery of the dam and submergence area. A baseline of the entire catchment area, as mandated, is absolutely necessary to predict, measure and monitor impact. To list just a few aspects for the Committee’s attention.

Their plant list for the area includes just 193 species. Just the Gori basin, where the submergence area extends way into, has a list of 2,359 species of 963 genera from 199 families. There are over 120 species of orchids in the Gori valley, especially in the area that is proposed to be submerged.  The floral aspects have been studied only for what they call the ‘Influence Zone’, which is within the 10 km periphery of the dam and submergence area, in which they have gone into many pages of seasonal data and supposed detail on density, frequency and basal cover. They have even gone into the weighted geometric mean of the proportional abundances in impressive looking algebraic equations, but only to conclude that there are a few useful timber  trees, a few useful medicinal plants, and no listed rare and threatened plants. There is no analysis of or any usable correlation of plant communities with patterns of human settlement or governance regimes, or a correlation with faunal associations and dependence, or of  refugia that will be destroyed by submergence.

While WAPCOS says that there was no available literature on fish species, there are published lists of fish species in the Mahakali, such as those by SP Badola and TK Shreshtha, to mention just two, whose combined listing includes 124 species of fish in this river; the WAPCOS report lists just 30 species. It is notable that in every EIA WAPCOS seems to do a detailed analysis of microscopic life such as diatoms and plankton in their laboratories (which are difficult to cross-check without access to expensive equipment), but the larger verifiable indicators such as a proper listing of fish species in a river, and an analysis of their species assemblages, or importantly, addressing questions such as where these populations stand in relation to meta-populations, now that most Himalayan rivers have already been dammed, is always absent. Neither is there any analysis about what the diatom species assemblage or relative abundance tells us about the current state of the river. Under impacts of the proposed project, while they acknowledge that connectivity will be greatly compromised and that migratory fish species will be affected, it is completely disingenuous of WAPCOS to say that the positive impact of submergence of a large area will lead to greater fish production and availability though fisheries. The experience of such fisheries at the Bhakra, Pong and Tehri dams does not bear this out in the long term. If anything, fish production and harvest is commercialized on a contract basis, and local people are excluded from the harvest, and at best, reduced to labour in harvesting operations. There is sufficient literature on this experience.

Their bird-list (at another place in EIA) for the area is just 70 species, whereas just one tributary valley upstream, the Gori, has over 330 bird species listed. In this context again, WAPCOS has suggested  that bird populations and diversity will boom after the area is inundated. This is deliberate misinformation. It is only in instances where the inundation is either in a very wide valley, or in a plains area, where there is a large area of shallow waters with marshy conditions for waders and for protective habitat, is there a boom in migratory bird populations. The Pong and Ropar dams are examples of this, and on the other hand, the Bhakra and Tehri dams are examples of steep banks with deeper waters, and no boom in bird populations whatsoever. Like the Tehri dam, the Pancheshwar reservoir is similarly proposed in an area where the waters will be deep and no boom in bird populations can be expected.

 Their reptile list has no mention of species such as the King Cobra Ophiophagus hannah and the Indian Rock python Python molurus, or the White lipped Pit-viper Trimeresurus septentrionalis that are reasonably abundant in the proposed submergence area. Mis-identifying a female Agama tuberculata as a Japalura Kumaonensis in a photograph or a Naja naja as a Naja kaouthia as they have done, is somewhat understandable, but the Himalayan Brown Bear on their list is hallucination. There is no mention of the Tiger using the Mahakali river course as a corridor and found by WII to range as high as Cold Temperate forests in the Gori basin upstream. Very importantly, there is no mention of the very high concentration of leopards and ungulates such as the Ghoral, all along the river course, and especially on the steep cliffs that serve as refugia on either side. In the multiple journeys down the Mahakali, we have observed leopard tracks on every single sand beach along the river course downstream of Jauljibi. This is despite the fact that such evidence on sand beaches along the river are obliterated by strong winds every day. These sand beaches and the valuable refugia are now proposed to be submerged.

f) On air-qualtiy: Here again, there are many pages of tables bearing measurements on air-quality, five of ten selected sites being from close to the dam-site, and five from distant Hardoi district in Uttar Pradesh. Comparison with locations in Hardoi can hardly present a useful comparison even at a synoptic scale, since pressure gradients, diurnal anabatic and catabatic flows in mountain valleys is radically different from a location deep in the Gangetic plain. Neither can it be representative of regional background air quality.

4. Final observations: The Expert Committee is requested to consider the above.

a) Can such an EIA be acceptable for approval at all? Both because it is incomplete and because it is misleading.

b) It is requested to bear in mind the risk-factor, both economically and for national security in a seismically uncertain context. The risk that is being referred to is one, of building such a large impoundment over a series of active thrusts and faults, and two, of the great potential hazard of this dam being bombed in the event of war with neighbours. Pancheshwar is barely 150 km from the Chinese border, and history is replete with dams being prime targets during wartime.

c) Considering that the energy scenario is rapidly transforming, and that hydropower is emerging as one of the more expensive and environmentally damaging alternatives today, and that many nations are dismantling their large dams, should we be proceeding in this direction?

d) Finally, please consider the fact that the Mahakali-Sharda-Ghaghra river is the largest and oldest tributary of the Ganga, larger than even the Ganga mainstem at their confluence. The Mahakali-Sharda is now the only large river that is undammed on its mainstem in the Himalayan reaches. In the same way that we set aside terrestrial areas for conservation as Protected Areas, and other countries set aside entire rivers to flow free of dams, the Mahakali should be left free of any further dams, not just for the Himalayan sections, but for the numerous Protected Areas in the Terai, whose existence and health is dependent on the Mahakali river flowing free.

In view of the very serious nature of issues raised here and in earlier submissions by SANDRP, Himdhara, MATU jansangathan and others, which remain unaddressed, including those related to public hearing, we request EAC not to clear the Pancheshwar project till all these concerns including those raised here are adequately addressed.

Thanking you, looking forward to your responses,

1. E. Theophilus, resident of Mahakali basin, etheophilus@gmail.com, Munsiari, Pithoragarh, Uttarajhand
2. Malika Virdi, resident of Mahakali basin, malika.virdi@gmail.com, Munsiari, Pithoragarh, Uttarajhand
3. Ramnarayan K, resident of Mahakali basin, ramnarayan.k@gmail.com, Munsiari, Pithoragarh, Uttarajhand
4. Himanshu Thakkar, ht.sandrp@gmail.com, SANDRP, Delhi