Guest Blog by Manoj Misra
Apropos Sri Pravir Pandey (Vice Chairman, IWAI) article (https://www.hindustantimes.com/analysis/the-inland-waterways-project-won-t-choke-rivers/story-3CTflDhyTxijS5AAqlQeqO.html) in HT (The Hindustan Times) dated 24 Jan 2019 rejecting our serious reservations (https://www.hindustantimes.com/analysis/the-inland-waterways-project-will-destroy-india-s-rivers/story-8TDyHX1UuzQzKwWhHXQVPJ.html) expressed earlier (HT, 4 Jan 2019) on the claimed merits of the Inland Waterways Transportation (IWT) project. While welcoming IWAI’s presumed willingness to debate the matter, we reject Sri Pandey’s contentions in their entirety as having been made on rhetoric and ‘confidential’ assessments rather than on sound and convincing facts.
There are two key considerations which require attention before merit, if any, could be found in a potentially impactful project like the IWT. First are of course its financial viability and the second and much more critical are its environmental impacts.
Financial viability of any project is based on whether its benefits outweigh all its costs. Here the word ‘all’ is material since by undermining several key costs any project could be shown to be viable.
Sri Pandey, Vice Chairman, Inland Waterways Authority of India (IWAI) claims that the Internal Rate of Return (IRR) of Jal Marg Vikaas Project (JMVP) – Varanasi to Haldia on Waterway (WW I) is 21.1%. Unfortunately Sri Pandey fails to reveal that this claim is based on a report (Detailed Feasibility and Engineering Studies) which is not public. The project’s Detailed Project Report (DPR) which should carry the said IRR was also denied to to Manthan Adhyayan Kendra in a RTI query. Obviously a ‘confidential’ assessment is beyond debate and its very nature of confidentiality colors its merit, if any. If all is well as claimed then why hide behind a cloak of confidentiality?
There are various other reports (which fortunately are in the public domain) that have raised valid queries on the financial viability of the project.
The NTPC, which is the foremost user of National Waterway 1 (NW – 1) to transport coal for its power plant at Farakka, told the Parliamentary Standing Committee:
“…the transport cost through waterway is only slightly lesser compared to the railways right now, since the cargo is transported one way only.”
In fact, whether the IWT is cheaper than other modes depends on many factors, including whether the movement is downstream or upstream, the costs of the terminals and handling. A study by RITES points out:
“The level of advantage offered by IWT is much higher when compared with road than that of rail, but corresponding advantage goes adverse when terminal costs involved in the case of IWT also forms cost of comparison.
“Although IWT seems to be the cheapest mode of transport as far as operation costs are concerned, it fails to attract traffic when local or terminal costs are involved. …commodity wise level of diversion on proposed IWT services is strongly guided by the terminal costs that reduce the waver margin of benefits to very large extent”.
A study on Sector Development Strategy and Business Development Study for Capacity Augmentation of National Waterway 1 states:
“Often times a price advantage of NW-1 shipments is leveled out by additional costs, as inland-waterway transport cannot offer door-to-door services where producers and/or users are not located directly on the waterway. Instead, pre- and onward carriage is usually required to cover for the ‘last mile’ with cost implications arising from additional cargo handling.”
When comparing operational costs the relative distance from point A to B by different modes also becomes critical with very little flexibility in it available in case of IWT as compared to both road and rail transport (new roads and railways could be laid but new rivers cannot be created). As an example it is well known that the riverine distance from Varanasi to Haldia is 1600 km as against only 900 km by road[i].
Clearly the claims on financial viability of IWT are misleading and half-truths at best and untrue at worst.
Even if for a moment, the financial viability of IWT is accepted as given, much more critical matter is its environmental viability since once in place it could play havoc with the integrity of the identified river stretches in the country beginning with the WW-I (aka NW-1).
You Tube video dredging in river Ghaghra
And to claim that IWT is a standard practice in rivers of several countries in the west and the east is to ignore, possibly deliberately, the vast difference between those rivers and our rivers in south Asia. Most of those rivers are more in the nature of regulated canals, whence erstwhile rivers having been canalized, ruthlessly exploited and hence are devoid of the diverse biodiversity which Indian rivers, fortunately, still carry. Also the corresponding hydrology and resulting biodiversity in them are significantly different. Most importantly, millions of people directly depend on our rivers for their livelihoods, unlike the situation in the west. And yet, it is also a fact that those rivers too suffer adverse impacts from heavy duty inland transportation.
Environmental Impact Assessment (EIA)
There exists a well established legal instrument in EIA Notification under the Environment Protection Act, 1986 where various projects with potentially large environmental footprint are assessed and evaluated through a legally established process before a project is found eligible (with or without conditions) to receive an environmental clearance (EC).
Often a project like the IWT with several environmentally impactful components would undergo environmental impact assessment even if the project by itself might not be listed (presently) within the EIA Notification schedules. So it was but natural that the IWT would undergo EIA process and seek an EC.
Regretfully documents pertaining to correspondence and meetings between MOEFCC, IWAI and Ministry of Shipping (MoS) on the issue of EC for Ganga waterways (WWI) and the Varanasi terminal accessed through RTI reveal that the Ministry of Shipping has gone out of its way to somehow wriggle out of the ambit of EIA Notification with MOEFCC unfortunately succumbing to such pressures. This is despite clear provisions of the relevant regulations and MOEFCC expert committee being on record to have recommended a need of EIA and EC for IWT.
Ironically on the other hand the IWAI authorities have actually carried out, as rightly claimed by Sri Pandey, an EIA and prepared an EMP (Environmental Management Plan) for IWT in deference to such a requirement to access funds from the World Bank (WB). But that is clearly not good enough since the EIA has not gone through any process of appraisal, public consultation-cum-public hearing, environment management plan, monitoring and compliance under statutory law.
This double faced action on the part of IWAI authorities is perplexing and most unacceptable. While MoS and IWAI has issues with observing a statutory process (EIA/EC) under a national law, it readily is open to conducting a similar exercise to meet WB needs; though the latter has no validity in law for it is not subject to expert appraisal, public scrutiny or statutory monitoring. Nation would be helpless if the WB EIA / EMP are not implemented.
On biodiversity front lesser said the better! For WWI, the Kashi Turtle Sanctuary at Varanasi is sought to be denotified. While no official permission exists for passage through the Vikramshila Dolphin Sanctuary at Bhagalpur, barges and vessels of IWT continue to move illegally through it. This is when expert scientific studies suggest existential threats to Dolphins from dredging and the sounds produced by the movement of large sized vessels.
Clearly there is a lot more that the IWAI needs to explain!
Coming to the specifics of Sri Pandey’s article:
Width of Ganga
It is claimed that, “The Inland Waterways Authority of India (IWAI) is developing standardised vessels for the National Waterway 1 that have a shallow draft and high carrying capacity of (up to 2000 tonnes). These vessels will need a depth of 2.2 to 3 metres and a channel width of 45 metres only even though the Ganga is almost 2.5 kilometres wide at some stretches.”
The statement made as above by Sri Pandey is misleading being true only in stretches.
Just because the Ganga is almost 2.5 km wide at some stretches does not mean that there are no issues due to waterways in these stretches or in other stretches. There are certain stretches where the river meanders, where the width is critical. Movement of large barges over these stretches will further aggravate the problem of bank erosion.
The CIFRI report mentions: “Some of the critical, curved areas of the river stretch studied are lying between the channel chainage from 256 to 274 km; 310 to 324 km; 400 to 410 km; 448 to 462 km; 474 to 492 km from the Sagar Island (origin). Some of the critical narrow zones with Latitude/Longitude (width in metre) are : Rudrapara, P (Nadia) 23.417822/88.382964 (154 m) and 23.428905/88.370694 (145 m); Nadia 23.755396/ 88.214249 (147 m); Burdwan 23.520073/ 88.376256 (131 m); Kashiadanga (Burdwan) 23.547377/ 88.356404 (153 m); Majida (Burdwan) 23.541266/ 88.330699 (133 m); Murshidabad 23.776894/ 88.230486 (145 m) and 23.791747/ 88.233179 (146 m) and Chowrigacha (Murshidabad) 23.967821/ 88.187946 (153 m)” (CIFRI report, Page 133 (143 in PDF))
Moreover, “About 185 km are vulnerable to erosion due to barge movement which is indicating the sub critical to super critical speed zone along the meanders and narrow regions of the channel.” (CIFRI report, Page 133 (143 in PDF))
It is also claimed by Sri Pandey that “the physical interventions have been kept to a minimum and construction of barrages, diversion structures and groins have been avoided. According to the dredging (desilting) management plan for JMVP, dredged material will not be deposited outside the river. The bed of the river is not being disturbed. Only maintenance dredging will be done to desilt 20 % bed load silt even as 80% of silt is in suspension.”
This is an extremely objectionable claim. The term “minimum” is a relative term, and the actual extent of interventions would be clear only when the detailed project report is made public. The key issue is, what is the impact of whatever “minimum” they are doing and who is going to ensure that it is indeed “minimum”? Even when barrages, diversion structures, groins are avoided, water and sediments will be diverted through the river conservancy measures such as dredging and bandalling. The EAC meeting held on 18.05.2017 noted that dumping of dredged material will have ‘additional burden’ on the river ecosystem.
The claim that “the bed of the river is not being disturbed” is contradicted by the author when he says dredging is being done to shift the silt from one part of the river bed to another. How can that be achieved without disturbing riverbed? It also needs to be substantiated by making the DPR public and by having full environmental appraisal as a statutory requirement. It is difficult to believe that with the level of dredging planned, habitats of river flora and fauna will not be disturbed. In fact all available evidence and common sense tells us that the habitats are already getting adversely affected.
Moreover, this 20% of the ‘desilting’ is huge in quantity (and in terms of expenditure involved). For example, the estimated quantity of dredging required is 2.865 million Cum in the Farakka-Kahalgaon stretch (146 Kms). Maintenance dredging of this stretch alone, where the work has already commenced, will lead to the expenditure of Rs 150 crore. (Major Project status, October 2018, Pdf Page 10). We need to bear in mind that NW-1 (WWI) is 1620 km long (JMVP FAQs).
If the dredged material is dumped back into the river, it will further accumulate elsewhere in the channel and some of it will come back after sometime. This means that maintenance dredging or ‘mere desilting’ will have to take place on a continuous basis, implying continuous impacts, which itself raises serious questions on the financial viability and environmental sustainability of the project.
Moreover, as mentioned later in the HT article, MoEFCC has exempted maintenance dredging from environmental clearance subject to certain safety measures. One of the safety measures to be implemented is avoiding cutter suction dredger for maintenance dredging. However, the Major Status Report updated on the IWAI on monthly basis reveals procurement of cutter suction dredgers for maintenance dredging in NW-1 (S.No. 2.13, Page 14, Major Project status, October 2018). This proves the dishonest and insincere attitude of IWAI and MoEFCC towards the environmental impacts of this project.
Further, the JMVP FAQs list mentions “Disposal of dredged material and its uses for other infrastructure works as per State Support Agreement are also being formulated. (JMVP FAQ Point 9, Page 4).” This shows the contradictions in the publicly put out FAQs and the assertion made by Sri Pandey.
EIA and EC Requirement
Sri Pandey further claims that “In December 2017, the Union ministry of environment, forest and climate change (MoEF&CC), has confirmed that under JMVP, prior Environmental Clearance for Maintenance Dredging, construction of terminals, jetties etc are not required.”
Sri Pandey should have mentioned the fact that the abovementioned MOEFCC order is under scrutiny at the NGT. It is more than clear that the MoEFCC has been pressurized to grant this exemption, as the entire correspondence between Shipping Ministry and MoEFCC shows. Particularly, this exemption has been granted by MoEFCC against the recommendation of its own expert committee, and in gross violation of extant law. Moreover, this exemption is granted subject to the implementation of several safety conditions, of which no mention is made by Sri Pandey. An example of the violation of a condition has already been provided above. What is the guarantee that other conditions are not being violated and would not be violated.
Interestingly Sri Pandey goes onto claim that “thanks to a thoroughly scrutinised Environment Management Plan, IWAI has got wildlife clearance for navigation through the Kashi Turtle Sanctuary, Varanasi, from the National Board for Wildlife (NBWL) and the Coastal Regulation Zone clearance for Multi-Modal Terminal at Haldia from the MoEF&CC on November 6, 2017.”
The case of wildlife clearance through Kashi Turtle Sanctuary is telling in more ways than one. Firstly the NBWL under section 29 of the Wildlife Protection Act, 1972 has no authority to permit any activity within a sanctuary which is not specifically in the interest of wildlife in that Sanctuary. Clearly the so called clearance is ultra vires. But the tale has become much more insidious. IWT authorities finding wildlife clearance conditions difficult to meet within the Kashi Turtle Sanctuary, we understand, now there is a move is now afoot to denotify the entire sanctuary.
Sri Pandey conveniently fails to mention that no such wildlife clearance exists for the Vikramshila Dolphin Sanctuary in another stretch of WWI. Fact is that in a brazen violation of the Wildlife Protection Act, movement of barges & vessels continues through the Sanctuary?
On Vikramshila Dolphin Sanctuary, Sri Pandey claims that “Dredging is not being carried out in the entire stretch of Vikramshila Gangetic Dolphin Sanctuary (VGDS).”
But the fact is that dredging is proposed upstream and downstream of the Sanctuary, hence the sanctuary is bound to get affected. Dolphins are not only found in the VGDS, but in several stretches of Ganga. Nachiket Kelkar, a scientist at the Bangalore based ATREE with long term scientific study in Ganga writes: “Unprotected’ reaches of the Ganga and its tributaries also hold viable dolphin populations, but environmental impact assessments for the NW-1 wrongly assume that mitigation measures apply only to Protected Areas such as Vikramshila.[ii] (“Turning Blind Eyes: Do we care for river dolphins or their habitat?”, SANDRP, 2016, ‘A River Dolphin’s ear-view of India’s Waterways Development Plans, Sanctuary Asia, 2017’).
Recent studies by Nachiket Kelkar and others prove that the sound created by large vessels within their habitat tend to impact Dolphins adversely since the latter being effectively sightless depend on use of high-frequency ultrasound clicks for navigation, communication and foraging. Due to its almost constant reliance on sound for survival, underwater noise that will be generated by ships, vessels and dredging activities will spell doom for them.
On the issue of impact on water quality Sri Pandey cites a study by ICAR-CIFRI, Barrackpore that it has revealed no significant changes in water quality parameters.
This is a classic case of moral hazard of providing selective information. The CIFRI report actually mentions that “Results of the study revealed no significant changes in water quality parameters in the river due to the current movement of barges in this short period of time, except increase in turbidity up to 5% in the shallow channel stretches and near the bank areas immediately after barge movement. (Page 11 PDF) ” And, “Further, that it is suggested that long term continuous studies may be required to assess the impact of barge movement on ecology of the river, fish assemblage and stock.” (Page 12 (PDF)
Another CIFRI study, “Impact Analysis on “Ecology, Flora and Fauna including Fish and Fisheries due to Movement of Barges Carrying Coal through National Waterway No.1 (Sagar to Farakka) Final Report to Jindal ITF” say:
“The study revealed that the movement of barges increases water turbidity and alters river flow. About 10% increase in turbidity has been recorded in shallower areas and bank areas due to movement of barges. Increased water turbidity will reduce primary production and will ultimately reduce the energy flow through the aquatic food chain.” (Page 145, 155 (PDF))
Both the studies have been done by CIFRI on the same stretch. Really shows the lack of credibility of Sri Pandey’s assertions. The report also mentions considerable impact on the livelihood of fishermen.
Waterways in other countries
Sri Pandey claims that “Has anyone ever wondered why the waterways of the USA, Canada, the European Union, China, Vietnam, Thailand, Brazil, Argentina, Russia, Bangladesh etc are so alive with millions of tonnes of cargo transported on them, and why Indian waterways are dying without any cargo transportation as yet”?
First of all, it is not correct to imply, as Sri Pandey tries, that rivers in these countries are not affected adversely by water transport. Secondly, characteristics of Indian rivers are so diverse and unique that one would think twice about comparing the rivers of one region to that of the other in India itself. Indeed, there is small but growing number of waterways in some countries which have been modeled to create ‘win-win’ solutions for environment, transport and other river uses. However, they have recognised that “Navigation requirements can result in a stabilized, single thread, ecologically uniform river channel (i.e. a waterway or canal), lacking both natural in-stream structures with their gentle gradients and connectivity with the adjacent floodplains, which leads in the long run to ecosystem degradation (such as for the main river channel and the floodplain) and a loss of species.” (Page 42, Platina Manual on good practices on sustainable waterways planning, ICDPR, 2010). These guidelines also recognise that integrated planning, including prior understanding of wider environmental context, proper respect and contribution towards the legal environmental requirements, and early integration of all the stakeholders including those representing environmental interests, public, and NGOs leads to the management of ecologically-oriented waterways which give measurable benefits.
Room for River, model
Strangely Sri Pandey cites a model from Netherlands to claim that “JMVP will help rejuvenate the river Ganga by creating a Room for River, a model that has proved to be an effective flood mitigating and river conservancy measure internationally especially in low lying Netherlands.”
Sri Pandey provides not details as to how the transport and navigation plan in the Ganga is being compared with the Room for River model. From all available information, the assertion seems to be without basis and more like the use of Orwellian language.
These Scheldts Projects in the Netherlands (Page 88-90 of the Platina Manual) were created with a ‘long term vision.’ In addition to safety to flood and accessibility, ecosystem was an important component which was given proper attention. Not only was an international EIA process followed, new disposal strategies were devised which were monitored by six professors from different disciplines. It emphasised on the habitat and bird directive and compliance of flood risk directive. Overall the project was a product of years of integrated planning and revisions where all the environmental, economical, societal and agricultural evaluations were based on detailed technical analyses of the effectiveness and feasibility of measures. This is clearly not the case with JMVP as yet, nor does it show any intention or preparation to carry out such a process.
Clearly a project with poor understanding of India’s rivers, which IWAI authorities are in a mighty hurry to implement, with proven reluctance to follow the laws of the land & utilizing opaque processes, reports and studies to back it up is sought to be thrust on the nation? The Ganga will certainly be WORSE OFF with such projects, decisions, processes and organisations.
Manoj Misra (firstname.lastname@example.org) Convener of Yamuna Jiye Abhiyaan.
Acknowledgement: I am thankful to Sri Shripad Dharamadhikary and Ms Avli of Manthan for their inputs.
 Para 19.3 of the report of the Parliamentary Standing Committee.
 RITES Study, Final Report, Page 12 and 30
 IWT Sector Development Strategy and Business Development Study for Capacity Augmentation of National Waterway 1 from Haldia to Allahabad Volume I: Report Part A, HPC Hamburg Port Consulting GmbH, Germany and UNICONSULT, Germany, IWAI. June 2016 Page 15
 Minutes available with Manthan, obtained through RTI