Open letter to MoEF & River Valley EAC: Review Recommendation to grant EC to Etalin HEP

The MoEF’s Expert Appraisal Committee (EAC) on River Valley Projects in its meeting in January 2017 recommended Environmental Clearance (EC) to the controversial 3097 MW Etalin Hydropower project in Dibang River Valley in Arunachal Pradesh. However, since the stage I forest clearance to Etalin HEP has not yet been accorded, the EC letter has not yet been issued. Hence there is an opportunity to stop EC to the project till the EAC reviews its decision.

It may be noted that Forest Advisory Committee (FAC) in its meeting on April 23, 2020, has decided in the context of Etalin Project: “As this is a large sized project in the Himalayas, inputs of IA (Impact Assessment) Division of the Ministry on whether environmental impacts of the proposed project and mitigating measures have been considered, will be obtained.” This provides an opportunity for the MoEF to direct the IA Division and EAC to review its decision to recommend EC to the Etalin Project.

A review of the minutes of the six meetings of the EAC where this project was considered, the EIA and related documents and subsequent documents show that EAC’s decision to approve the Etalin project was based on inadequate information, incomplete impact assessment and a horde of misleading and wrong information. The EAC failed to look at these gross inconsistencies and inadequacies in EIA, its own minutes and information base.

We are highlighting major reasons here why the EAC needs to reconsider and review this decision to approve Environment Clearance (EC) to Etalin HEP.

1. MoEF agency: EIA “is completely inadequate” The Forest Advisory Committee (FAC) of the Ministry of Environment, Forests and Climate Change (MoEF for short) noted in its official meeting on Feb 28, 2017[i], that the Environment Impact Assessment of the Etalin project is completely inadequate. Many of us have been saying this, and the EAC ignored this, but how can they now ignore this conclusion from the official agency? In fact, the FAC recommended, “multiple seasonal replicate studies on biodiversity assessment by an internationally credible institute as the current study (EIA) is completely inadequate in this regard.” As we all know EIA is the key document based on which EAC considers any project for EC and when the EIA is declared “completely inadequate” by an official agency, it also implies that the decision to grant EC based on such a document cannot be acceptable.

2. EAC did not have approved CAT plan, R&R plan, CA land details and yet approved the project? A perusal of the FAC minutes of Feb 2017 and subsequent documents show that the approved Catchment Area Treatment (CAT) Plan, the Resettlement and Rehabilitation (R&R) Plan, the details of the land for Compensatory Afforestation, were all approved, finalized and submitted after Feb 2017. That means that the members of the EAC till January 2017, when EAC approved EC for the Etalin project, did not have these basic ingredients of the EIA and EMP (Environment Management Plan). This again shows the gross inadequacy of the information base available with EAC to approve EC for the project.
3. Gross inadequacies of EIA: Only 5 mammalian species? Let us consider some gross inadequacies of the EIA as highlighted in the minutes of the EAC meetings. So for example, the Feb 2015 EAC meeting[ii] noted: “During the surveys, only 5 mammalian species belonging to 5 orders were sighted”. The Etalin Project Fact sheet[iii] accompanying the agenda for the FAC meeting on Apr 23, 2020 says that the WII (Wildlife Institute of India) study[iv] (“Wildlife Conservation Plan for the impact zone of Etalin HEP”, which itself has been found to be making underestimates in this regard) found there were 21 mammalian species, 3 of which are endangered and 3 are vulnerable category. The list of mammals in the Dibang Valley as per the peer review of the WII study is much larger at 53.
4. Gross inadequacies of EIA: Only 33 bird species? The minutes of the EAC meeting dated Feb 2015, quoting EIA says: “Similarly 33 species of birds belonging to 22 families were recorded during the surveys.” As per the FAC Factsheet dated Apr 21, 2020, the project area has 230 bird species. In fact, the WII study that FAC quotes itself underestimates the bird number, but even if we take WII study, will it not be shameful to approve such a huge project based on a study that says there were just 33 species of birds? The list of bird species in Dibang Valley as per peer review of the WII study is much larger at 433 and BNHS has in fact even larger list at 680 species.
5. Gross inadequacies of EIA: other biodiversity As per the Feb 2015 minutes of EAC meeting: “In all 11 species of reptiles and lizards belonging to 9 families are reported from the study area. In addition, 5 species of amphibians are also reported from the area.” The FAC Factsheet quoted above says WII found 31 species of reptiles (against 11 by EIA), 14 species of amphibians (against 5 by EIA) and 413 species of plants (370 by EIA), 159 species of butterflies (against 45 by EIA). The EIA found just one spider, “House spider” among the 18 insects it found in the study area, when WII found 113 species of spiders alone in the study area! Can any one with even basic exposure to science accept such an EIA for approval of a mega hydropower project?

The EIA found 12 species of fish, whereas the peer review of WII report reports 32 species, many of them recorded in last decade. The WII study notes the presence of RET fish species Schizothorax richardsonii (p 23).

6. EAC raised conflict of interest issue, never satisfactorily resolved The EIA for Etalin project was done by the same agency (M/s R. S. Envirolink Technologies Pvt Ltd) that did the Cumulative Impact Assessment for the Dibang Valley, where Etalin project is situated. The minutes of the June 2015 EAC meeting records: “The committee was apprised about the Dibang sub-basin study awarded to M/s R.S. Envirolink Technologies Pvt Ltd on 25th March, 2015 by the Central Water Commission. Incidentally, the same consulting firm has been engaged by the project developer for preparation of EIA/EMP reports. As such, there seems to be conflict of interest, and the Ministry may take cognizance of the same for a holistic decision by the EAC.” That issue was discussed as additional agenda item in Aug 2015 EAC meeting when discussing the Dibang and Kameng Basin studies and EAC concluded that since the studies are TOR driven and has to support its conclusions with data and analysis, there is no conflict of interest! If we go by this conclusion, since all studies that are TOR driven and also have to support them with data and analysis, the conflict of interest does not exist! This is clearly totally unsatisfactory and callous.
7. The missing EAC discussion on representations The minutes of the EAC meeting in Feb 2015 on Etalin project end with EAC asking PP (Project Proponent) to provide a number of information, including: “The project proponent must submit response to the various issues raised by SANDRP in their representation submitted to this Ministry.” The same gets repeated in minutes of April[v] and June[vi] 2015 EAC meetings.

In none of the minutes of the four EAC meetings from Feb to Aug 2015 where Etalin was discussed, was there any discussion about the issues raised in the representations, response from PP/ EIA consultant. This whole conundrum is another reason to review the EAC decision to recommend EC to Etalin Project.

8. The irreplaceable, unique, bio-divers forest The EIA submitted to the MoEF in early 2015 throughout says that the project will need 1143.09 ha forest land. The minutes of the EAC for the meeting in Dec 2016 says the project needs 1149.65 has forest land. However, the Arunachal Pradesh state government had already in 2014 applied for use of 1165.66 ha of forest land. So the EIA consultant, PP and the EAC seems to be unaware of even how much forest land the project needs. Through the minutes of the six EAC meetings where Etalin is discussed, there is not even a mention of the kind of forest that the project proposes to deforest, including its amazing unique biodiversity, the number and size of trees that the Etalin Project required to be cut.

The forests to be submerged by 3097 MW Etalin HEP are priceless. The Forest Department itself has admitted that they are “irreplaceable” in their values. We urge the EAC and MoEF to consider this project with extreme caution. The Ministry has Climate Change in its name. It cannot ignore the impact of affecting 1165.6 hectares of forest land and two free flowing rivers. At a time when a global pandemic has highlighted the importance of old growth forests and conserved biodiversity & wildlife, pushing for a project which furthers the destruction of most bio-diverse with such flawed process should not be acceptable. Hence we urge the EAC and MoEF to review the decision to grant EC to the Etalin Project.

9. Flawed E-flow study There are major flaws in the Assessment of E-flows Study[vii], done by CIFRI (Central Inland Fisheries Research Institute) in August 2014 at the behest of the developer.

• The report does not mention the duration or dates of field visits or sampling studies,
• One of its objectives was (Section 1.2) “To assess the present status of aquatic habitat in terms of fishes and fish food organisms.” However, the section Fish Diversity (3.4) does not mention a single fish specie except Snow Trout! There are no lists of species, no discussion on the aquatic ecosystem. Just one fish is supposed to drive all the eflows work.
• The methodology used, a strange combination of EMC and FDC curves, is without any merit or established precedence. The calculations of width, depth and velocity needed for Snow Trouts do not even mention a single impact of the flows on the food of the fish.
• The final e-flows recommended are significantly less than the EAC norm of 20% lean season, 20-25% non Lean, non monsoon months and 30% monsoon flows of a 75% dependable year. It does not even consider a 75% dependable year, but a 90% dependable year, further bringing down the e-flows requirement.
• The study claims in the Executive Summary, “Dependency of the local population on river for other needs e.g. domestic requirement, irrigation, navigation, commercial fisheries, etc. is not there.” This is clearly contradicted by the WII study (Para 6.10.1) when it says: “Social survey, reported that more than 50% of the PAFs depend on natural resource for income generation. Within the natural resource collection 86.0% depend on NTFP, 39.77% hunting, 99% fish collection and 35.75% collect timber for their requirements.” (Emphasis added.)
• In whole of the CIFRI report, there is no mention of any other fish species, except Snow trout (Schizothorax richardsonii, Family: Cyprinidae), and this is the only species mentioned in section 3.4 titled “Fish Diversity”. Only in concluding chapter the report actually mentions name of another fish species: “Although none of the Mahseer species (Tor progeneius and T. putitora) could be observed during experimental fishing but their occurrence downstream of confluence of Dri and Tangon could not be ruled out.”
• The CIFRI report does not mention how the project components like road construction or muck dumping or sediment trapping in upstream can impact the fish, contrast to the WII report.
• The first objective of the CIFRI report (para 1.2) is stated as: “To assess the present status of aquatic habitat in terms of fishes and fish food organisms.” But the CIFRI report does not even mention the diversity of fish it found in different seasons in the project rivers.

The Jan 2017 EAC meeting which recommended EC to the project did not record any discussions around the merits or acceptability of this e-flows report. It did not raise any objections to the CIFRI report, but accepted eflows values given by Cumulative Impact and Carrying Capacity Study of the Dibang sub Basin of Brahmaputra Basin Study conducted by RS Envirolinks, 2016 for MoEF&CC, which are even lower than CIFRI recommendations! The CIFRI recommendations were even lower than the normal EAC thumb rule recommendations.

10. Poor quality CIA-CCS The EAC relied on the CIA – CCS (Cumulative Impact Assessment – Carrying Capacity Study) or Dibang Basin Study of Dibang sub-Basin conducted by RS Envirolinks in their discussions, but the EAC never critically reviewed the study or raised pertinent questions about the CIA-CCS Study. The Study had a number of significant flaws. For example, the minutes of Jan 2017 EAC meeting simply state that Dibang Basin Study (or Cumulative Impact Assessment (CIA) – Carrying Capacity Study (CCS)) has been accepted by the Ministry. There is no application of mind by the EAC about the Basin Study and its recommendations for 3097 MW Etalin Project. Some key flaws of the Dibang Basin study:

• The Dibang Basin study was never made publicly available before its approval. There has been no public hearing or public consultation process on the draft of the basin study.
• There was basic conflict of interest in RS Envirolinks doing the basin study since they also did the Etalin EIA study.
• We have already seen the pathetic quality of the EIA study that this consultant did for Etalin Project. All the same flawed approach is also reflected in the Dibang Basin Study.
• The study says it was initiated in May 2015 and final report was already done before July 2016!
• And yet in the whole report, the word “Climate Change” does not occur, except when mentioning the name of the Ministry of Environment, Forests and Climate Change!
• There is no discussion in the report about how climate change is impacting the various aspects of Dibang Basin, how the adaptation capacity of the basin will be affected by the proposed projects or if the proposed projects are the most appropriate or optimal options in the Dibang Basin.
• The report does not assess the impact of operation of various hydropower projects in peaking mode within Arunachal Pradesh. It only makes some rather inadequate assessment of impacts in downstream Assam. Even for the Dibang Project, the downstream impact of whose peaking release of 1441 cumec is attempted to be assessed in Assam, there is no assessment of the same within Arunachal Pradesh, the 45 km stretch before river enters Assam.
• Nor does the study assess to extent the projects can operate in peaking mode, since the projects are planned in almost bumper to bumper mode with little distance between the TWL of upstream and FRL of the downstream project. This is important since hydropower projects are sold in the name of peaking power.
• Just one sentence in section 7.2 titled “Fish and Fisheries” exposes the pathetic character of the CIA-CCS study: “Due to fast flow of river during the survey no fish could be landed.” The consultants could not catch a single fish and their whole study on fish and fisheries is based on secondary sources! Even here, there are contradictions. So Table 7.10 lists Fish Species in Dibang basin has listed 74 species, but next page (PP 7.21) mentions 76 species.
• The study recommends Eflows for Dri and Talo Rivers based on the requirements of only one fish species that is the Snow Trout, no consideration of other fish, zoo plankton and phytoplankton which are essential for fish survival. No mention of other social uses of the river.
• The e-flows recommended, based on these misleading and myopic assumptions do not meet the norms laid by the EAC. EAC recommends 20% of average Lean season flow, 25% of average non-lean non-monsoon flows and 30% of average monsoon flows for a 75% dependable year as Eflows. However, the CIA CCS study recommends flows which are 18.4% of average non lean, non monsoon months and 14.5% of average monsoon months. This is also for the 90% dependable year, and not 75% dependable year as EAC norms state.
• Reading Table 8.19, where the % environment flows recommended for all the projects in Dibang Valley by CIA-CCS are tabulated, we find that the % are the lowest for both Dri and Talo limbs of Etalin project, for both monsoon and non-lean non-monsoon seasons. This when the Etalin project is the highest capacity project, diverting the longest stretches of rivers compared to any other projects! Even for Dibang project, which is has comparable installed capacity with Etalin, the % are higher in monsoon and non-lean non-monsoon seasons, in addition to the releases happening through ungated opening and one turbine running all round the year. If ungated opening were possible in Dibang project, with much higher storage capacity dam, why can it not be possible for Etalin Project? These inconsistencies and contradictions are possible since the calculations are hidden behind cross sections and modelling which is not shared in public domain.

Conclusion Considering all the facts and issues highlighted above, it would be the most prudent decision on the part of the MoEF and EAC to review the Environment Clearance for the Etalin Project. It should reject the EIA-EMP for the Etalin Project and also the CIFRI E flows study and also the CIA-CCS. These studies should be freshly initiated through a more credible process involving institutes of repute, credible track record and no conflict of interest.

Himanshu Thakkar (ht.sandrp@gmail.com),
Parineeta Dandekar (parineeta.dandekar@gmail.com), SANDRP

END NOTES:

[i] http://forestsclearance.nic.in/writereaddata/FAC_Minutes/3111712012121FAC-MINUTES_001.pdf

[ii] http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/0_0_31120124612111FinalMinutesof82ndEACMeetingminutes.pdf

[iii] http://forestsclearance.nic.in/writereaddata/AdditionalInformation/AddInfoSought/0_0_411211210121318-20-2014.pdf

[iv] https://wii.gov.in/images/images/documents/publications/rr_2019_etalin_hep.pdf

[v] http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/0_0_511121211216183EAC-Minutes.pdf

[vi] http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/0_0_611251211218184EACminutes.pdf

[vii] Assessment of Environmental Flows for Etalin Hydro-Electric Project in the River Dri and Tangon, Dibang Valley District, Arunachal Pradesh: FINAL REPORT by CENTRAL INLAND FISHERIES RESEARCH INSTITUTE (Indian Council of Agricultural Research) BARRACKPORE, KOLKATA