Arunachal Pradesh · Hydropower · Lohit River

NBWL pushes Lower Demwe HEP on Lohit River in Arunachal Pradesh based on fudged WII report

The Minutes of 50th Meeting of Standing Committee (SC) of National Board of Wild Life (NBWL), held on 7th Sept 2018, were made available on 26th Sept  2018. On viewing the Minutes of Meeting, the petitioner to NGT Bimal Gogoi wrote to the Chairman and the Members of SC Of NBWL about the recommendation of the SC of NBWL on Demwe Lower Project.

Date : September 26, 2018

To: Dr. Harsh Vardhan

The Chairperson,

Standing Committee of the National Board for Wildlife,

New Delhi.

URGENT: Grant of wildlife clearance to Demwe Lower project based on faulty WII report is shocking and should be reversed

Dear Dr. Harsh Vardhan and Members of the Standing Committee of the NBWL,

Greetings from the Northeast! I have just perused the minutes of the 50th meeting of the SCNBWL and I am shocked to see that your committee has granted wildlife clearance to the 1750 MW Demwe Lower project based on a seriously flawed report of the Wildlife Institute of India (WII).

I have already made two submissions on the Demwe Lower project dated 24th February 2018 and 6th September 2018. I am now making this additional submission after going through WII DEMWE HEP report_31_08_2018

I am the appellant in the National Green Tribunal who had filed an appeal challenging the forest clearance granted to the Demwe Lower project. The Hon’ble NGT vide its judgement dated 23rd October 2017 had suspended the forest clearance and had set aside the wildlife clearance which was integrally connected with the forest clearance due to a number of reasons, including referral by the Forest Advisory Committee to the SCNBWL before grant of Stage – I forest clearance to the Demwe Lower project.

I have already highlighted in my earlier submisson that no reasons have been recorded by the SCNBWL as to how the recommendation by the three-member site visit committee (which included a representative of WII) for: “a comprehensive peer-reviewed study should be carried out on the hydrology and ecology of three seasons by a reputed and neutral scientific / technical organization(s) before according clearance” has been replaced by a rapid study by the Wildlife Institute of India (WII). As highlighted below, the detailed study is critical to take a sound decision on the project and ensure long-term ecological security of our region.

Preliminary observations on the WII report and why a rapid study cannot be the basis of a decision to grant wildlife clearance (followed by more detailed reasons):

WII is correct in acknowledging the serious inadequacy of the earlier EIA report by CISMHE and the need for prior detailed study. They propose a detailed study to be done over two years. But strangely, they say this only for the downstream and not for the areas directly affected by dam construction. They have done a selective critique of the EIA report, despite recording in the Literature Review at Annexure V:

“EIAs of hydropower projects usually include an assessment of the effects of the projects on wildlife in the surrounding areas. They usually conclude that dams have minor effects after the mitigation measures are implemented, so that the hydropower projects can go ahead with construction. (Trong Tu et al. 2013).”

They seem to have suffered the same bias which I will illustrate with concrete examples later.

Nevertheless, despite it being only a rapid field survey on foot for barely 20 days (instead of a minimum of one year), the sightings and signs of wildlife (eg. of critically endangered species such as Bengal Florican) in the affected area only vindicates the recommendations of the majority of the members of the erstwhile SCNBWL who had unanimously endorsed the report of Dr. Asad Rahmani as well the site visit report of the three-member committee  commissioned by the current SCNBWL (D.P.Bankhwal, R.D.Kamboj and Dr. Gopi) asking for comprehensive, three-season peer-reviewed studies before taking a decision on this project.

The WII report states that to ascertain the presence of mammals, they conducted surveys on foot to look for direct (sighting, vocalizations) and indirect signs (footprints, scat/dung, interviews with local people). While this was indeed important, the SCNBWL as the apex body on wildlife in the country needs to be appreciate that such surveys are required in all seasons, accompanied by camera traps and other devices to get a true,holistic picture.

The surveys were conducted in May which is the rainy season in the area. During the rains, indirect signs such as animal footprints degrade at a rate much faster than in the dry season. This means that if signs are not recording shortly after they have left by animals, a downpour can make them unrecognizable or entirely obliterate them. Much scientific literature has shown the camera traps are much better at detection low density and cryptic small-medium sized animals, especially in rugged mountain landscapes common in the project area (Zone 1 of the WII report in particular is mountainous), than sign surveys or interviews (see Silviera et al. 2003, Tobler et al. 2008). This problem is compounded in forests with a history of hunting such as those in Arunachal Pradesh where sightings are fewer given increased wariness, temporal shifting in activity patterns and evasiveness of animals (see Rovero and Mashall 2004). But this does not necessarily indicate absence of animals or even lesser densities. For example, during two years of fieldwork, Nijhawan (2018) sighted muntjac fewer than 5 times in the dense mountainous forest of Dibang Valley. In contrast, nearly 450 independent encounters were recorded with camera traps. Rovero and Marhall (2009) report a similar pattern for duikers in Central African rainforest where they were detected frequently by camera traps but never sighted.

Therefore, based on a rapid foot survey, WII cannot conclude that the wildlife affected by direct dam construction  is not critical for conservation. I will also illustrate how they have not even surveyed the full submergence area even for the rapid survey (at least 35 percent of submerged river length left out). Even though the SCNBWL has agreed with the findings of the WII report in its meeting on 7th September, I will urge the SCNBWL to re-consider this decision. I am providing detailed reasons why the current WII report cannot be the basis of giving a green signal to the Demwe Lower project.

The detailed reasons are below:

1)    WII recommendation to allow dam construction is based on factually wrong information

On page 17-18 of its report in the ‘Conclusion’ section WII states:

“In the light of the history of this dam site, wherein the submergence zone has been studied and an EIA was approved to give Environmental Clearance (corroborated by Hon’ble NGT), we feel that the creation/ construction of the dam per se would not be critical in undermining the biodiversity values of the region. The submergence zone of the dam is a habitat which is available elsewhere within the region and is not critical for the conservation of any known threatened, endangered or critically endangered species’ population.”

The SCNBWL has uncritically accepted this contention. 

There are several flaws in the report and its conclusions, including deliberate exclusion  of 35 percent of river length of Lohit river affected by ‘submergence’ as well as other areas affected due to dam construction:

  1. a) Demwe Lower reservoir will submerge 23 km length of main Lohit river in addition to stretches of some tributaries. WII says only 15 km length affected by submergence, leaves out 35 percent of river length affected by submergence in surveys and maps.

WII has defined Zone 1 for their survey as  a distance of 15 km from “Tidding village to Parshuram kund (submergence zone)”. In the description they mention the zero-point of the backwater of the reservoir. That this is not a typographical error is clear from the map on Page 9 which shows the “zero-point of reservoir” near the confluence of the Lohit river with the Tidding river. The actual zero-point of the reservoir along the Lohit river would be 23 km along the Lohit river, therefore around 8 km upstream from where WII is showing the “zero-point” of reservoir to be. This is also evident from maps provided in the original EIA report by CISMHE (which WII says it has referred to). The concerned map in the WII report  which shows submergence zone near the Tidding – Lohit confluence is attached as  Annexure 1 (see below).

annex-1-zone-1-map-wii-report-august-2018.jpgThree maps from the original EMP by CISMHE showing the submergence zone are attached as Annexure 2 – Three submergence maps from CISMHE EIA-EMP, Demwe LowerIt is evident that substantially more additional submergence will take place upstream beyond what WII has shown as the “zero-point”  of the reservoir on the Lohit river.

WII has justified allowing the dam construction and submergence by showing an affected river length which is 35 percent less than what it will be in fact. Further, the Hon’ble NGT in its judgement had asked the SCNBWL while examining the issue afresh to also consider the opinion of the majority of the members who had endorsed the report of Dr. Asad Rahmani. In their conclusion they had specifically observed that 23 km length of the river will be submerged and recommended that:

“Based on the issues raised in the ‘Site’ section above, there appears to be enough merit for rejection of a mega hydropower project at the present site of the Demwe Lower project at Parshuram Kund to protect an ecologically sensitive stretch of the lower reaches of the Lohit river and its tributaries in close proximity of Kamlang sanctuary (the only Protected Area in Lohit and Anjaw districts). Dropping the project will also help maintain a degree of longitudinal connectivity between the plains and uplands, considering the fact that a cascade of seven large hydroelectric projects proposed on the main Lohit river will lead to a serious fragmentation of the river. This will also help protect the environment in and around the cultural heritage site, Parshuram Kund.”

Thus, the majority of members of the erstwhile SCNBWL  felt that the Parshuram Kund landscape is also an extremely ecologically sensitive area which must be protected, including to protect longitudinal connectivity which is critical for  migration of aquatic fauna such as golden mahseer. WII’s recommendation is contrary to this and made after truncating the length of the riverine stretch of the Lohit river affected by 35 percent. This ground alone is enough to reject the WII report and order a probe into the fudging of data. The original EIA report of the project cited by WII mentions the submergence length of the river as 23 km.

  1. b)Selective reading of original EIA report and NGT judgements by WII to recommend construction of dam amount to misleading members of SCNBWL . Further, area directly affected by dam construction is not just submergence (Zone 1). Parts of Zone 2 of their survey, which includes hoolock gibbon habitat, is also directly affected due to construction infrastructure, colonies etc.

The SCNBWL had given the WII a straightforward mandate “to carry out hydrology / ecology study and submit the report to the Ministry in three months.”

While WII acknowledges that the rapid assessment is inadequate and it will require at least 2 years for downstream impact assessment, it chooses to do a selective reading of the original EIA report and NGT judgements to recommend for the dam construction. To re-iterate WII’s conclusion on page 17-18:

“In the light of the history of this dam site, wherein the submergence zone has been studied and an EIA was approved to give Environmental Clearance (corroborated by Hon’ble NGT), we feel that the creation/ construction of the dam per se would not be critical in undermining the biodiversity values of the region. The submergence zone of the dam is a habitat which is available elsewhere within the region and is not critical for the conservation of any known threatened, endangered or critically endangered species’ population.” 

Firstly, the Hon’ble NGT vide its judgement dated October 23, 2017 has set aside the wildlife clearance and suspended the forest clearance, asking the SCNBWL to look at the matter afresh. The SCNBWL is not required to give its recommendations referring to older judgements of the NGT (while ignoring the latest judgement of October 2017) and certainly that mandate was not given to WII which requires to do the scientific studies and not divert from that objective. The latest judgement of the Hon’ble NGT on the Demwe Lower project is dated October 23, 2017 as a result of which the matter is before the SCNBWL currently. The Hon’ble NGT observes in Paragraph 79:

“…we are of the view that in the interest of justice, the Standing Committee of NBWL, if desires, should consider all the issues afresh, taking into consideration the views expressed by the majority of the members and also to have a fresh look on the ecologically sensitive area in respect of which various points have been raised which we have elicited in our judgment and take a decision. Till such decision is taken, we consider it necessary to suspend the impugned FC both Stage I and Stage II and the consequential order of the Government of Arunachal Pradesh, so as to enable the Standing Committee of NBWL to have a fresh look on the issue based on which the 2nd respondent shall pass appropriate orders.” 

The NGT has given the space to the SCNBWL to ‘in the interest of justice’, ‘consider all the issues afresh, taking into consideration the views expressed by the majority of the members and also to have a fresh look on the ecologically sensitive area in respect of which various points have been raised which we have elicited in our judgement and take a decision.”

In light of the NGT’s observations in its latest judgement of October 2017, the very reason the project is before the SCNBWL currently, it is evident that  WII has tried to mislead members of the SCNBWL by exceeding its mandate and going into a wrong interpretation of the  ‘history of the dam site’ as well as NGT judgements to favour the developers.

Further, it is shocking that it is has done a selective reading of the earlier EIA report and come to a conclusion that the habitat is not critical for conservation – without having done a detailed study itself and also based on fudging (reducing) the extent of submergence along the length of the river.  

The same EIA report by CISMHE which WII has cited has two parts: EIA & EMP.

The EMP has a chapter on Biodiversity Conservation & Wildlife Conservation Plan  which is attached as Annexure 3 – Ch 1_Biodiversity Conservation And Wildlife management planAs an example, it is important to note that the EMP states on pages 1-28 and 1-29 that both tigers and clouded leopards are present in the project area. WII cannot selectively read the EIA-EMP to justify the dam and submergence. It will require to do a detailed three season study to put forward findings.

Further, SCNBWL members need to be reminded that the submergence zone of the Demwe Lower is within only 50 metres (0.050 km) of the Kamlang sanctuary and tiger reserve. The project submerges riverine and forest habitat contiguous with the Kamlang sanctuary as close as 50 metres to the boundary. In such a situation, WII’s confidence in condemning the habitat to destruction without even a single season survey of the full submergence zone is shocking to say the least.

WII says: “The submergence zone of the dam is a habitat which is available elsewhere within the region…” to make an argument for allowing the dam. This is an unacceptable argument to allow ecologically sensitive areas to be diverted, not in the least since WII has not even surveyed the full submergence zone in its rapid study. But even if we are to accept this line of reasoning, there is no evidence to show that WII has done a study to see what are the threats to those habitats “available elsewhere in the region”. For example, rivers of comparable size and discharge of the Lohit river in the Eastern Himalayas in Arunachal Pradesh include Dibang and Subansiri. Both these rivers have large hydroelectric projects which have been given environmental clearance in the foothills in comparable habitat (one of them in an advance stage of construction). Further, the Government of Arunachal Pradesh has signed MoAs for over 150 hydroelectric projects in the state. Therefore, it is mere conjecture that other habitats will be available for long-term conservation. It would be more beneficial if WII had stuck to the impacts of this particular project, instead of trying to show lesser impacts by using one strategy or the other (including fudging length of reservoir).

Further, WII fails to bring before the SCNBWL that it is not merely Zone 1 which is directly affected by dam construction. The entire construction facility, colonies etc. will be in Zone 2 on the left bank of the river, where even in the study team has recorded Hoolock Gibbon presence. Primatologist from Northeast India, Dr. Dilip Chetry had written to the SCNBWL on 6th March 2018 in which he had highlighted impact on hoolock gibbon habitat (attached as Annexure 4 – Dilip Chetry to NBWLSC, 6th March 2018):

“I would further like to bring to the notice of the current Standing Committee the need to be additionally concerned about the impacts on critical species such as the Eastern Hoolock Gibbon(Hoolock leuconedys). In this respect I would like to bring to the notice of the Standing Committee that I was part of an official team constituted by Government of Arunachal Pradesh which inspected the 132 KV power transmission line from Namsai to Tezu to Roing for its impact on the Eastern Hoolock Gibbon habitat during its forest clearance process. We had recommended increasing the height of the power line by 25 metres to allow movement of the gibbons in the upper canopy. As members of the site visit committee to the Demwe Lower site would have noticed, this power line passes through forest land both overlapping with and contiguous with some of the forest land being acquired for the Demwe Lower project (e.g. Kandey Community forest). This makes it apparent that the Demwe Lower project too, directly and indirectly, impacts habitat of the Eastern Hoolock Gibbon. 

Members of the NBWL SC and site visit team will be aware that small pockets of eastern Assam (Sadiya ) and Eastern Arunachal Pradesh are the only places in India that the Eastern Hoolock Gibbon (Hoolock leuconedys) is found. While the powerline had comparatively lesser impacts which could be mitigated to some extent (by extending height), construction of such a major hydropower project at this particular location is likely to seriously impact wildlife habitat directly and indirectly, including that of the Eastern Hoolock Gibbon.

The large chunk of land which will be acquired on the left bank of the river downstream of the Parshuram Kund bridge which will house construction facility, permanent colony, muck dumping and quarry areas etc. will involve felling a large amount of trees. This area also touches the road from Parshuram Kund towards Namsai which has very less traffic movement currently. But that is likely to change very substantively once construction on this project starts. Thus, in addition to the direct loss of wildlife habitat (including that of the Eastern Hoolock Gibbon) and the serious downstream impacts, the construction activites of this mega project will also cause major disturbance over a long period of time.”

The fact that this area on the south bank of the Lohit river is extremely important for conservation of the Hoolock Gibbon is also acknowledged in the literature survey by WII at Annexure 5 – EOI_21.05.2018_TOI:

“The southern bank forest of the Lohit river downstream of Parshuram Kund till Tezu has been notified as a distribution range of Eastern Hoolock Gibbon Hoolock hoolock leuconedys in India according to Das et al., (2006)”

Despite knowing that a large chunk of this will be acquired for the project and a larger area will be indirectly affected, the WII report is silent on this aspect while recommending the dam construction.

2)    Downstream studies need to done be in advance: Serious implication for techno-economics of project and forest clearance, including Forest Rights Act: 

a)The downstream study has grave implications for techno-economics of project, including dam design (e.g. height of dam). Hence needs to be done in advance. Otherwise,          SCNBWL is not only compromising ecological security, but creating a situation of increased economic risks to PSU banks

The WII report in its Conclusions section states that after three consultative meetings with developers: “Major impacts were likely to be happen in the aquatic realm of the Lohit river ecosystem, due to the peaking mechanism required for the commercial viability of the power plant.”

They add later: “..At the same time the proponents may be strictly restrained from the peaking operations and resulting flooding until the above study provides appropriate guidelines to undertake the peaking operations (if any) with minimal impact on the associated biota of the river and river-island ecosystem.”

On the one hand WII says that peaking operations are required for commercial viability of the project and on the other hand it says that one of the possible outcomes of the study is that no peaking is allowed (specific reference to ‘if any’). It is absolutely necessary that this study and prescription for dam operation is decided upfront and not later, even if we assume for a moment that it is alright to build the dam at current site at Parshuram Kund.

This is because if the conclusion of study is that no peaking should be allowed, in that case a dam of height 124 metres above river bed is not required. If it is allowed to go ahead only as a base load project, then the project can operate at Minimum Draw Down Level (MDDL) throughout the year and there is no need of a 124 metre high dam. The primary objective for building a 124 metre high dam is to allow peaking for a few hours in non-monsoon months by storing the water in non-peak hours. Further, the installed capacity of the project would have to be reduced by 20-25 percent. Basically the project would need to go back to the drawing board and seek fresh techno-economic clearance from the Central Electricity Authority (CEA) too.

If the project is allowed to go ahead currently, it will be done based on the current CEA permissions as a peaking project, rendering the recommendations of the SCNBWL irrelevant later. I will be explaining in future sections that the undertaking given by the developer is meaningless for all practical purposes.

SCNBWL needs to learn from the 2000 MW Subansiri Lower project under construction on the Assam – Arunachal Pradesh border. Downstream impact assessment studies were allowed to continue concurrent with construction and  the project is currently stuck as recommendations made by the expert group from IIT Guwahati, Dibrugarh University and Gauhati University is unacceptable to the dam builders and GoI who have already  built half the dam. Such a situation is neither in the interest of the environment nor the developers nor the public money invested in the project.

Further impact on river flow is not only a question of  patterns of release of quantities of water, but the dam structure will also impact natural sediment and nutrient flow, fish migration etc. which has a direct connection with downstream ecology. These need to be studied in advance to decide whether the dam is viable. It is naïve of WII to suggest that let the dam construction go on and we will decide release patterns later. This is a recipe to ensure that everybody loses in the long-term.

b)Implications for forest clearance and forest rights: Need for prior downstream impact assessment 

As members of the SCNBWL are aware, this is a matter in which wildlife clearance has been set aside by the Hon’ble NGT in an appeal against the forest clearance granted to this project as the grant of wildlife clearance was intricately linked with the forest clearance due to a number of reasons. The NGT has also suspended the forest clearance. Therefore, after a decision of the SCNBWL on the wildlife clearance a decision will need to be taken about the forest clearance. However, based on the preliminary findings of WII it is important that downstream impact assessment needs to be done in advance as it has serious bearings on the forest clearance. For example, if a decision is taken not to allow peaking in the project, then the project can operate at MDDL and there will be no need for a 124 metre high dam. In this case the forest land required to be diverted under the Forest (Conservation) Act, 1980 will change and therefore completion of the study is required prior and not concurrent with construction.

Further, WII findings have further bearings on impact on forest land and rights:

In the conclusions section the WII report states that the daily flooding caused by peaking operations could potentially have the following impacts on aquatic and terrestrial fauna:

“1. Possible inundation of grasslands and forested habitats in the Lohit river basin because of flooding caused due to peaking operations.

  1. Possible loss of critical habitats e.g. Small River islands which are important for nesting of birds…..”

The entire downstream riverine stretches are legally part of different categories of forest land e.g. Unclassed State Forest, Anchal Reserved Forests etc.

Therefore, the WII findings make it clear that a large area of forest land beyond which is being diverted in the forest diversion proposal is likely to be impacted by the project. Therefore, the downstream study will have to be done in advance to gauge the exact extent of impact.

The Hon’ble NGT has suspended the forest clearance. Therefore, re-issue of forest clearance at this point of time needs to be in compliance all the legal requirements of forest clearance under the FCA,1980, its rules and guidelines.

For example, the Forest (Conservation) Amendment Rules 2014 make it necessary to consider both direct and indirect impacts of diversion of forest land on forest, wildlife and environment before granting forest clearance. Therefore, the appraisal will have to be revised in light of the downstream impact findings of WII before grant of forest clearance.

Further this also has bearing on the consent to be sought from local communities under the Forest Rights Act which has to be sought prior to forest clearance. The WII study in its conclusions states:

“The project’s compensatory payment could well be well used to rehabilitate these communities from the chapories and wean them to other livelihoods. A detailed study is therefore needed to provide specific sites and options.”

This has further implications under the FRA and needs to be known prior to grant of forest clearance again. Because the consent of local communities to “ameliorative measures” under the FRA is required prior to the grant of forest clearance. This is as per the MoEFCC directive dated 3-8-2009, reiterated in the Forest (Conservation) Amendment Rules 2017.

Therefore, for the purpose of examination of the project for forest clearance (including  prior consent from communities under FRA) the downstream impact study is required in advance.

3)    Three consultative meetings with Athena Energy Ventures Pvt. Ltd. by WII to ‘find a way forward’ – Is it legal?

As I have informed members of the SCNBWL before, the developer of the Demwe Lower project, Athena Demwe Power Ltd. is undergoing insolvency since last year due to non-payment of a loan to Indian Bank.

Please find a recent advertisement inviting a resolution plan for Athena Demwe Power Ltd. issued by the appointed Resolution Professional attached as Annexure 5 – EOI_21.05.2018_TOI.

In the pendency of the insolvency process, Athena Demwe Power Ltd. can only be represented through the Resolution Professional.

WII had been mandated with a scientific study by SCNBWL and not negotiate with developers to “find a way forward”. Further, they had no business to meet the private shareholders of Athena Demwe Power Ltd. (viz. Athena Energy Ventures Pvt. Ltd.) to “find a way forward”. Ironically there was no meeting with the other JV partner, Government of Arunachal Pradesh – only the private shareholder.

During the insolvency period, the shareholders cannot be negotiating with anybody. Further the undertaking given (in the name Athena Demwe Power Ltd.) is not signed by the Resolution Professional and as such has no meaning. This is besides the fact that the undertaking itself is a vague document.

SCNBWL needs to be informed that since Athena Demwe Power Ltd. is undergoing insolvency, it has not even done the simple compliance of filing the mandatory six-monthly environmental compliance report since June 2017. If it was allowed the private shareholder would have done this task! It is shocking that WII has acted in the manner negotiating with the private shareholder (against legal norms) to push for the Demwe Lower dam.

We will be exploring our legal options to examine why the Wildlife Institute of India was hobnobbing with the private shareholders of a public company undergoing insolvency – which can be represented only through the Resolution Professional. This issue does not have implications only for the ecological security of the Northeast but how government scientific institutions could be involved in encouraging crony capitalism leading to further non-performing assets by negotiating with private parties to push unviable hydropower projects.

Even beyond the legal aspect, there was also no mandate from SCNBWL to WII to meet the developers three times to “find a way forward”.

4)    Impact on sacred natural site, Parshuram Kund, completely ignored by SCNBWL

I am beyond shocked that the SCNBWL has totally ignored the issue of Parshuram Kund.

On 22nd December 2014 the Culture Minister (currently also MoS Environment), Shri Mahesh Sharma had written to former Environment Minister Shri Prakash Javadekar expressing serious concerns regarding the Demwe Lower project coming up at Parshuram Kund. In his letter he had stated:

If this project is allowed to be constructed, it will generate 23 lakh truck loads of debris, which will destroy not only the holy site of Parashuram Kund, but also the beautiful ambience of the site, which will be converted into a dump yard.”

The letter is attached as Annexure 6 – Mahesh Sharma to Javadekar, December 22, 2014.

The issue of Parshuram Kund is not beyond the scope of the SCNBWL. It is a sacred natural site involving both biological and cultural values. WII being one of the hubs for implementation of the Convention on Biological Diversity (CBD) in India is well aware about the significance of sacred natural sites in conservation. I was surprised at them saying this area is not critical for conservation. While the site has independent merit to be conserved for its biodiversity, the reason for protecting it is even more significant since it combines biological and cultural values. That is the reason all the non-official members of the erstwhile SCNBWL had endorsed Dr. Asad Rahmani’s report and recommended:

“Based on the issues raised in the ‘Site’ section above, there appears to be enough merit for rejection of a mega hydropower project at the present site of the Demwe Lower project at Parshuram Kund to protect an ecologically sensitive stretch of the lower reaches of the Lohit river and its tributaries in close proximity of Kamlang sanctuary (the only Protected Area in Lohit and Anjaw districts). Dropping the project will also help maintain a degree of longitudinal connectivity between the plains and uplands, considering the fact that a cascade of seven large hydroelectric projects proposed on the main Lohit river will lead to a serious fragmentation of the river. This will also help protect the environment in and around the cultural heritage site, Parshuram Kund.”

Current decision-makers have also shown their hypocracy regarding how sacred sites in the Northeast are treated vis-à-vis sacred sites in other river basins such as Ganga. The ecological and cultural heritage of the Northeast is dispensable is the message sent by the current SCNBWL.

I am still hoping the SCNBWL reverses its decision based on the evidence I have provided of WII fudging data to recommend this dam.

Thanking you,

Sincerely,

Bimal Gogoi, Chandmari, Majar Ali, P.O. Golaghat, PIN 785621, Assam (bimgog@gmail.com)

References:

Silveira, L., Jacomo, A.T.A. and Diniz, J. A. F., 2003. Camera trap, line transect census and track surveys: a comparative evaluation. Biological Conservation, 114, pp. 351–355.

Rovero, F. and Marshall, A.R., 2004. Estimating the abundance of forest antelopes by line transect techniques: a case from the Udzungwa Mountains of Tanzania. Tropical Zoology, 17(2), pp.267-277.

Tobler, M. W., Carillo-Percastegui, S. E., Leite Pitman, R., Mares, R., and Powell, G., 2008. An evaluation of camera traps for inventorying large- and medium-sized terrestrial rainforest mammals. Animal Conservation 11, pp. 169–178.

Rovero, F. and Marshall, A.R., 2009. Camera trapping photographic rate as an index of density in forest ungulates. Journal of Applied Ecology46(5), pp.1011-1017.

Nijhawan, S. 2018. Human-animal relations and the role of cultural norms in tiger conservation in the Idu Mishmi of Arunachal Pradesh, India. PhD Thesis submitted to University College London (UCL), United Kingdom. 411 pp.

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