A small bus load of pilgrims descended at Walen Kondh and bought the usual Prasad from a shack by the river. They crossed a suspension bridge over a deep gorge of Kal Nadi and went to the derelict temple of Vardayini Mata on the other bank.
Kal River at Walen Kondh. Photo: Author
Then a few girls among them did something unusual. Instead of offering the Prasad at the temple, they came to the ridge of the gorge and clapped a few times, peering into the river below. In a matter of seconds, there was frantic thrashing in the waters as a huge school of endangered Mahseer fish congregated swiftly. The devotees then threw in fistfuls of puffed rice to hundreds of Mahseer below. For the devotees, these fish are sacred: the children of Varadayini Mata.
Temple of Varadayini Mata . Photo: Author
Walen Kondh in Mahad Taluka of Raigad District in the Western Ghats of Maharashtra is one of the several critical community fish sanctuaries of India that protect the Mahseer fish. These sanctuaries have been successful in conserving not only the fish, but also stretches of rivers through their unique actions which find no support from the establishment and limited recognition from the conservation community.
Devotees offering puffed rice to Mahseer below. Photo : Author
Deccan Mahseer (Tor Khudree) is classified as an endangered specie by IUCN[i]. It does not feature in the schedule of species protected under the Wildlife Protection Act (1972) which is not a surprise as the Act represents freshwater diversity very poorly. However, many researchers, fisher folk and anglers have recorded that Tor Khudree and associated Mahseer species (Tor tor, Tor putitora, etc) which were once plentiful in rivers across Western Ghats, peninsular and central India, HimalayanRivers as well as floodplains, has now reduced drastically.
One of the major reasons behind the collapse of fish species like Mahseer is dam construction. Mahseer species migrate in the upstream to smaller streams for spawning (breeding). They need a flood pulse to undertake this migration. While other factors like pollution, overfishing, etc. have contributed to the decline, the multiple impacts of dams in terms of blocking migration paths, reduction of water levels in the downstream, submergence of pools in the upstream, changes in natural hydrograph and flood pulses, changes in sedimentation, etc., have been the primary reasons behind this collapse. (SANDRP’s report on Impact of Dams on Fisheries: sandrp.in/dams/Impacts_of_Dams_on_Riverine_Fisheries_in_India_ParineetaDandekar_Sept2012.pdf)
Fall of Mahseer has affected the ecology, local livelihoods, angling and recreational fishing in the rivers. While Hoshangabad on the banks of Narmada recorded 5-6 tonnes of Mahseer landings every year, it has been nearly wiped out from these places now[ii]. Mahseer used to form the majority of catch in these parts and has been severely affected by reservoirs like Tawa, Bargi, Sardar Sarovar and other Naramada projects. However, hardly any efforts are being made to reverse this situation. According to Shashank Ogale, who set up and managed Mahseer hatcheries in Tata Dams for more than 20 years, there are next to none functional Mahseer hatcheries in the country. This is despite the fact that dam proponents show an expense of crores of rupees to set up hatcheries as a part of their Environment Management Plan. After granting clearances, which are also based on these EMPs, MoEF does not bother to monitor the functioning and efficiency of these hatcheries or the impacts of dams on fish diversity and fisheries[iii].
In such a scenario, community conserved fish sanctuaries which are scattered across the country are playing a very important role in conserving various species of Mahseer as well as stretches of rivers. Unfortunately, most of these sanctuaries get no protection by the State Governments, Forest Departments or the Ministry of Environment and Forests. This is at a time when freshwater diversity is declining at the fastest rate globally[iv]. Ministry of Environment and Forests has done precious little in conserving or protecting riverine diversity, fisheries or rivers from the onslaught of dams. These sanctuaries keep getting submerged, dried up or fragmented by newly planned dams and State Fisheries Departments don’t bat an eyelid before giving a no-objection certificate (NOC) to projects which will spell doom for these sanctuaries.
Renole Pujari from Walen Kondh tells me that they have received no support or protection from the government to conserve Walen Kondh Sanctuary, however the community sanctions are so strong that not only is fishing banned across 2 kilometers from this stretch, but people are not even allowed to get down to the water, near these fish. He only hopes that this stretch of Kal nadi[v] is not destroyed by dams and chemical pollution like the neighboring Savitri River which flows through the chemical MIDC at Mahad. Fish kills are a regular feature of Savitri River.[vi]
In Maharashtra, Tilase is one more such small village in Wada Taluka of Thane district which protects Mahseer fish in Vaitarna River. The stretch is downstream of Upper Vaitarna Dam which supplies water to Mumbai. Local youths told me that fish kills occur here when water releases from Upper Vaitarna decrease. Downstream this stretch, Middle Vaitarna Dam has now come up and the sanctuary is now sandwiched between the two projects. Social sanctions here are so strict that a net cannot be put in the waters, even to check the species. Fish Sanctuaries also existed in Alandi and at Pandharpur along teh Bhima, but have been wiped out. In Vidarbha, several Dev dohs (Sacred Pools) exist in Rivers like Adan, Kathani, Wainganga, etc., where fishing is banned.
Small community fish sanctuary on Vaitarna River Photo: Author
Accoridng to Rajendra Kerkar, Goa too has community conserved fish sanctuaries protecting the Mahseer at ‘Pistyachi Kon’ nesteled between Bhimgad and Mhadei Sanctuaries. It receives no protection.
In Orissa, along the Mahanadi on the banks of the leaning temple of Huma exists the Huma Mahseer Sanctuary. On the banks is a stone statue of a lady cutting a Mahseer fish. Legend goes that the one who fishes in this stretch will meet the same fate, like King Midas! Hirakud Dam has already affected this sanctuary and the proposed Lower Suktel Dam will make things worse.
Stone Statue at a fish sanctuary on the banks on Mahanadi in Orissa Photo: Wikimedia
Karnataka possible has the highest number of community fish sanctuaries in the Western Ghats. Nakur Gaya and Yenekkal fish sanctuaries exist on the banks of Kumardhara in Dakshin Kannada. In Yenekal, local gram panchayat has built a small weir with wooden gates for maintaining water levels for the fish. The weir is so small that the fish can migrate over it in the monsoons. Both these sanctuaries are threatened by the numerous mini hydel projects coming across the region, especially the 24.75 MW Kukke Mini Hydel Project near Hosmata[vii]. Fisheries Department however has given an NOC to this and many other mini hydels coming across the region without even attempting to study their impacts on Mahseer and other fish.
Congregation of Mahseer at Yenekkal Fish Sanctuary on Kumardhara River Photo: Author
200 MW Gundia Hydel project will also affect the entire hydrograph of Kumaradhara-Gundia rivers. Here. The EIA done by KPCL (Karnataka Power Corporation Limited) says that there are no rare and endangered fish in the area. 5 new fish have been discovered in the region just in the past one year!
Child feeding fish at Shringeri fish sanctuary, Tunga River Photo: Author
Karappura Fish Sanctuary in Mysore was submerged by the Kabini reservoir while the Shimoga Agrahara Sanctuary collapsed due to dwindling water levels which resulted after construction of Tunga Anicut 12 kilometers upstream from here.[viii]
Lovely Tunga River at Chippalgudde fish Sanctuary Photo: Author
Uttarakhand and Himachal Pradesh too have temple fish sanctuaries, notably the Baijanath Temple complex on the banks on River Gomti in Uttarakhand conserves Golden Mahseer (Tor putitora) and supports a small fish sanctuary on its banks. Many isolated fish sanctuaries are also reported from the Ramganaga and Kosi area near Corbett. However, it is also reported that now these sites are used by anglers and the temples receive revenue in return. In Jogindernagar, a town in Mandi distirct of Himachal Pradesh, lies a lake known as Machchiyal, fed by River Uhl. This lake is supposed to be the abode of Machendru Devta, the Fish God. Fish are fed and worshipped here regularly and fishing is strictly prohibited in the lake. Machchiyal supports a large population of the Himalayan Mahseer. There is a Temple of Machendru Devta on the lake bank with ancient idols of fish-god.
Congregation of Mahseer at Baijnath Temple Sancatury on Gomti RIver Photo: Malvika Chauhan
In the remote Tawang in Aruncahal Pradesh in the North East corner of India flows a beautiful river Nyamjangchu. Buddhist Monpas rever the river as well as the fish in Nyamjangchu. Fish in the Nyamjangchu are not hunted. The river is threatened by the proposed 780 MW Nyamjangchu Hydel project which will divert or submerge nearly the entire length of this river flowing through India. Even premier research institutes like CIFRI (Central Inland Fisheries Research Institute) have done a shoddy study and supported the project and have not raised the issue of impact of this dam on fish diversity.[ix]
On the occasion of World Fisheries Day 2013, we urge to the MoEF to document the existing sanctuaries and grant immediate protection to all the existing fish sanctuaries in the country, protecting them from the onslaught of dams and other pressures. We had sent a similar submission to the moEF which was endorsed by several Fisheries Scientists and activists across the country in 2012, we’ve received no response from the MoEF on it till date (https://sandrp.in/rivers/MoEF_EAC_Submission_Fisheries_Nov2012.pdf, sandrp.in/rivers/World_Fisheries_Day_PR_Nov2012.pdf).
These sanctuaries stand testimony to the fact that community conservation is one of the most sustainable and effective ways of protecting ecosystems. The sanctuaries and their keepers deserve respect and recognition.
It was certainly a Conference of Party (COP) of sorts. Those present included farmers, women, academics, media persons, delegates from other states (Gujarat, Madhya Pradesh, Uttar Pradesh, Delhi), Non Government Organisations and elected representatives. It also happens to be an annual event that has been going on for 27 years. It was certainly celebrating the work that actually helped mitigation and adaptation in changing climate in both drought and flood related possibilities. It was also happening on the same dates as the COP 19 was going on far away in Warsaw, Poland.
One of the two streams of Yatra arrives at Nagar
It was an honour for me to be present at Nagar village in Malpura block in Tonk district in Rajasthan at the 27th annual Dharati Jatan conference where the Pad Yatra from two different streams that culminated. Five eco warriors were honoured at this meeting with a certificate, silver medal, shawl and other ceremonial gifts. They were being honoured for their work related to tree plantation, soil and water conservation and protection of grazing land.
As speakers at the conference on November 16, 2013 narrated, this annual festival is a remarkable achievement by the Gram Vikas Nav Yuvak Mandal at Laporiya in Dudu block in Jaipur district, led by Laxman Singh, now famous for his grazing land protection through the unique chauka system.
The Yatra prepares for the worship of the Nagar village tank
Experience of the marchers The leaders of two streams of marchers presented their experience. Rameshbhai Saini, leader of the first stream that marched through the 15 villages of Dudu block (Jaipur district) also mentioned the difficulties people are facing. For example, he mentioned how Phulsagar, one of the tanks in Laporia is encroached and communities’ efforts to remove the encroachment did not succeed as the encroacher had the support of the Rajasthan minister Babulal Nagaur who is also the member of the Legislative assembly from the local area.
Ramjilalji, the leader of the second stream that walked through Malpura block villages (Tonk district) starting from Sindolia village, also said that encroachments on tanks are increasing under political support and when volunteers try to remove such encroachments to save the water bodies, they are faced with court cases. He also said that the state government is laying long distance pipelines and building cement containers to bring the water from mega dam Bisalpur to the villages in the area. He very pertinently asked, will we allow our water harvesting culture to be destroyed since now we have this piped water supply? Reflecting unconvincingly on this dilemma, the letter from state government’s principle secretary Purushottam Agarwal (he was supposed to come for the function, but had to travel elsewhere due to some family emergency and hence sent a letter) suggested that the pipelines are only for drinking water and tanks that the GVNML has helped build are for irrigation and other purposes. The fact is that the state government made no effort to consult the people before coming up with the pipeline scheme. Kesarbhai, active in Mahoba district in Uttar Pradesh described the Apna Talab Abhiyaan through which already 70 talabs (tanks built with earthen bunds) have been built in less than a year.
Participants from other states Pankaj Shrivastava from Mahoba appreciated that communities in GVNML area have system of imposing fines when anyone is caught polluting the lakes (as reflected in the wall writing in the photo below at the Nagar village tank).
The wall writing at the tank in Nagar village explains the fine system
He also said that the communities in their area is trying to clean up Kiratsagar lake in Mahoba through a focused campaign since Oct 5, 2013. Mavjibhai from Vivekanand Research & Training Institute, Bhuj (Kutch in Gujarat) said that they plan to take up implementation of chauka system in 55 villages along the 60 km long Rukmawati river in their area.
The Awards The five awards presented on this occasion were indeed very well deserved ones. The managing committee of Akodiya village (Dist Ajmer) was recognised for the tradition of collective management of common property resources including grazing land and water harvesting systems.
Rajjak Sheikh of village Tikel (Block Dudu in Jaipur district) was honoured for planting long living trees like peepal, Banyan, neem and other local varieties along the tank embankment over the last five years through his own efforts. He also got the fisheries contract given for the village tank canceled and got some of the hunters caught at his own personal risk.
Next, Shravanlal Jaat, a shepherd of village Kalyanpura (Dudu, Jaipur) was given the Dhudhad Ratan prize for consistently planting large number of trees in grazing land and along the village tank with his own personal effort and expenses for more than five years and also taking care of the planted trees.
Efforts of Umrao Godha, a relatively rich man of village Jhirota in Ajmer district were recognised for transforming the village with institutions like school, health centre and also for planting and taking care of large number of villages. Enthused villagers elected him as village head.
Khivsingh Rajput, an old man of Bikhraniya Kalan village from relatively far off Nagaur district (Marwad area) was also honoured for his 20 year old campaign in the village to plant long living Banyan and other trees in very dry area. He also inspired people to donate money and collected Rs 5 lakhs to deepen, renovate and strengthen the village tank.
Relevance for climate change The work of GVNML in the region is remarkable in many respects. The water conservation work helps recharge the groundwater and this water is then available in years of deficit rainfall, the frequency of which is bound to increasing in warming climate. Similarly, the whole area has created such a remarkable water conservation system that even when rainfall is excessive, this area will not face any floods since the water will be stored and only slowly released. The soil here has increased carbon content which also helps hold the moisture much longer, thus helping overcome the dry spells which has also increased in recent years. Thus it is clear that the that is underway over the last over three decades under GVNML has huge implications in the climate change context. The COP 19 talks at Warsaw remains deadlocked, waiting for some façade to emerge to show progress, this different COP 27 at Nagar shows so much progress is possible when the communities are at the helm of the affairs. It is doubtful though that the lessons from COP 27 at Nagar will have any impact on COP 19 at far away Warsaw.
River Kali, before it enters Dandeli in Karnataka is a breathtaking sight..
Its waters are emerald green, flowing steadily. Its banks are thickly forested with a continuous canopy. Endemic species like Malabar Giant Squirrel, Malabar Pied Hornbills, Malabar Gray Hornbills are a common sight here. Down the river, a monitor lizard is stretched across a branch, low over the waters. Fishing eagles and several kinds of Kingfishers look for fish. Fisher folk hover along the banks in beautiful coracles, laying hooks in the riparian vegetation.
During our visit to the Kali, my six-year-old swam in the river and could not believe that the river back in his home-town was once as clear as this!
Emerald waters of the Kali Photo: Author
It’s hard to imagine that it was a touch-and-go for this stretch of Kali…
If it were not for some brave, timely advocacy and strong local action, most of this stretch would have been submerged. Rest of the river would have been diverted through a tunnel or silenced in a steady pool of a reservoir: the way many Indian rivers are silenced. There would have been no river, no riparian forests and possibly no swimming.
Malabar Pied and Malabar Gray Hornbills on the banks of Kali Photo: Author
Dams on Kali: Kali has seen far too much damming. According to Kali Bachao Andolan, a network of organizations working to protect Kali River, more than 5 dams across the river have already submerged 32,000 acres of forests in the Western Ghats. According to Karnataka Power Corporation website, “The west flowing Kalinadi has its origin at an elevation of 900 m, near the DiggiVillage in the Western Ghats of Karnataka. Its 180-km long journey ends at the Arabian Sea near Karwar.”
After its origin, it’s dammed at Supa in Joida Taluk of the Uttara Kannada District. The submergence of Supa Dam is a site to behold. Stretching endlessly like an ocean, this dam submerged more than 24 villages and hundreds of hectares of forests. One of the dam evictees, an old, frail man now tells me, “Even now in summers, when the waters recede, I can see my village and my temple. We try to go there some times. I can see all my past life there, for a brief period, before it all goes under water again”.
Extensive submergence of the Supa Dam Photo: Author
Downstream the 101 m-high Supa Dam (100 MW), the river flows down through Dandeli town, taking huge pollution from West Coast Paper Mills on the way. From here it is dammed at Bomanhalli Pick up Dam, from where it is diverted to Nagazhari Powerhouse (870 MW), then to Kodasalli Dam and powerhouse (120 MW) and then at Kadra Dam and powerhouse (150 MW). If we look at the flow chart of Kali Nadi Dams, the river seems to be flowing from one reservoir into the next, with nearly no free flowing river stretch between two dams. Its main tributaries Kaneri and Tatihalla have been dammed too.[1] The power generation performance of Kali dams for the last 27 years is shown in the graph above.
There is a stretch downstream the Supa dam to Bomanhalli Pick up dam, where the Kali still flows. This again is controlled flow, regulated by the Supa Dam. But this is the precise stretch which was also targeted to be dammed in 2000’s. An 18 MW project by Murudeshwar Power Corporation Limited (MPCL) was proposed to come up at Mavlangi village downstream Supa Dam. According to Kali Bachao Andolan, it would have meant submergence of 210 hectares of land, including 70 hectares of forest land, next to the Dandeli Sanctuary. Kali Bachao Andolan, including Parisar Samrakshana Samiti, Sirsi and Environment Support Group (ESG), Bangalore, highlighted that Uttar Kannada District only needed 17 MW electricity (in 2000) while it was producing more than 1200 MW electricity and one more dam at a huge social and ecological costs cannot be justified. More importantly, ESG exposed that the Rapid EIA (Environment Impact Assessment) report done by reputed consultancy Ernst and Young for the proponent, was in fact a copy-paste of a different EIA, done by a different agency for a different river! A strong campaign was built around this, which garnered public and media support.
Guide from one of the homestay-resorts, a resident of Dandeli Photo: Author
In 2006, the Forest Advisory Committee of the MoEF rejected Forest Clearance for this project. The project was also strongly opposed internally within the Karnataka Government by the Department of Tourism. Surprisingly, MoEF did not book the EIA agent (Ernst and Young) or the proponent (MPCL) for submitting an entirely false report! Even more shockingly, this EIA was later done by TERI (The Energy Research Institute), which also completed the study in one month and came up with a dubious report based on secondary data. However, strong opposition from local groups, ESG, and even within Karnataka Government resulted in rejection of the proposal by a number of authorities, including the Department of Industries and Collectorate of Uttar Kannada. Since then, the project has tried to raise its head again, only to be opposed strongly.[2]
Fishing along the Kali in the early morning Photo: Author
Around 10 years down the line, what does this small stretch of free flowing river mean?
I traveled in Uttara Kannada as a tourist in November 2013. A thriving tourism industry now exists on the banks of Kali and the river is now world-renowned as one of the best rivers for white-water rafting in India. There is boating, canoeing, kayaking, swimming, fishing along this stretch of the river. Pools and islands in the river provide perfect habitats for various species as well as for naturalists and bird watchers. The range of recreational activities that take place along the river are endless. Fishermen still lay their nets across this stretch and catch some fish (though I was told that fish greatly reduced after Supa Dam was commissioned in 1985). Along the banks of the river in this stretch, a thick riparian forest flourishes, providing habitat and corridor to several species.
But more importantly, this tiny stretch is a reminder of how this great river once was. A humbling reminder.
According to Lal, now a boatman and guide from Dandeli, the river stretch which could have been dammed, now provides tourism related employment to around 1000 people from around the region. The region supports around 8 resorts and several homestays. It has created multiple employment opportunities for locals like naturalists, guides, white-water trainers, etc. Some of the locals are descendants of the Supa Dam evictees. One of them says, “The relocated colony of Supa evictees is called Ramnagara, actually it is Vanvasanagara. If it were not for the tourism, I would have migrated to Goa or Belgaon. We saw the fate of Supa dam displaced and would not allow one more dam, no matter how small or big, to affect us again.”
Many ways to enjoy a flowing river: Rafting, canoeing, swimming Photo: Author
The struggle against 18 MW mini hydel has been significant in a number of ways. EIA and public hearing for the project were the two events where protests were recorded. It was through these platforms that the extent of the impacts of the projects was known and could be opposed. However, after this, a newer version of EIA Notification was adopted in Sept 2006 which excludes hydel projects below 25 MW from its ambit! This has been a ecologically senseless move as projects which have severe impacts on the ecology do not even need a public hearing and an EIA now! We, and several experts and organizations, have raised this point a number of times with the MoEF, but MoEF is yet to respond.
One more strong point of the struggle was a more than 20-year-old order by Karnataka government categorically stating that since the Kali river is so heavily dammed (five major dams on this short 186 kilometre long river, destroying most of its forests and displacing thousands of tribal and forest dwelling communities), no more dams, big or small, shall be allowed further across this river. This has been a very significant order.
Even today, when more and more bumper to bumper dams in the Himalayas and Western Ghats are killing our rivers, our Ministry of Environment and Forests does not have a clear guideline for protecting certain stretches of rivers from dams or declaring them as no-dam stretches. There exists no such order protecting over-dammed, collapsing rivers.The only report which actually recommended that 24 dams in the Upper Ganga basin should be dropped due to their impact on ecosystems, has not been complied with by the MoEF. Dams are coming up in cascades, without leaving any free-flowing riverine stretch between two projects. Nothing is being done about this. The MoEF’s Expert Appraisal Committee on River Valley Projects now has a weak norm of leaving a bare kilometer of flowing river between projects. But this norm too gets twisted and violated.
Avay Shukla committee appointed by Himachal Pradesh High Court recommended that projects should have at least 5 kilometers of free flowing river between them. But MoEF does not seem to support this. In fact, a flowing river seems to have no value in our governance system.
However, as the Kali experience shows, a flowing river is good for ecology and is good for the people too.
Let us take this opportunity to thank the Kali Bachao Andolan and the local communities for protecting the last remaining free flowing stretch of Kali… so that we can catch a glimpse of how a free-flowing river looks like!
– Parineeta Dandekar
Local children rafting along the Kali Photo: Author
The Mohanpura Project The proposed Mohanpura dam is to be constructed by the Madhya Pradesh Water Resources Deparment near the village Banskhedi of District Rajgarh, Madhya Pradesh on river Newaj in ChambalRiver Basin. The earthen dam project envisages irrigation of 97,750 ha, including the irrigable area of 62250 ha in Rabi and 35500 ha in Kharif in Rajgarh and Khilchipur Tehsils of Rajgarh district. The Environmental Impact Assessment (EIA) dated May 2013 has been done by WAPCOS, an agency under Union Water Resources Ministry.
Site of the proposed Mohanpura Dam (Source: EIA)
The EIA and the EAC We have provided below some critical comments on the EIA, these are only indicative in nature and not comprehensive. These comments were sent to the Ministry of Environment and Forests’ Expert Appraisal Committee (EAC) on River Valley Projects for its meeting in June 2013 and further comments for Sept 2013 and Nov 2013 EAC meetings. We were glad that EAC asked the project proponent to reply to our submission in detail. But we did not get any reply directly either from the project proponent or MoEF. We several times checked the relevant section of MoEF website before the Nov 11-12, 2013 EAC meeting and did not find any additional submission from the project proponent or EIA consultant except the EIA and earlier submissions. We also wrote to the EAC and MoEF officials about this absence of any response from the proponent or the EIA consultant and they did not respond to our emails.
However, while looking for something else, on Nov 13, 2013, on clicking the EIA (which we assumed was the old EIA), what we got was the Oct 2013 response from the project proponent that supposedly included the response from WAPCOS to our submission. This seems like an attempt on the part of MoEF officials to camouflage/ hide the reply so that the reply is put up, but we do no get a chance to review and respond to it. This is clearly wrong and we have written on Nov 13, 2013 to that effect to the MoEF director Mr B B Barman who is also member secretary of the EAC.
Location map of the Mohanpura Project (Source: EIA)
In any case, the WAPCOS reply of Oct 2013 does not really provide adequate response to any of the points we raised as we have discussed in the following sections. If the EAC had applied its mind, EAC too would have come to the same conclusion. However, if EAC decides to recommend clearance to the project based on this reply by WAPCOS, it will not only show lack of application of mind and bias on the part of the EAC, the project clearance would also be open to legal challenge.
In what follows we have provided main critiques of the EIA and the project.
EIA does not mention that the project is part of Inter-Linking of Rivers The Mohanpura dam is part of the Government of India’s Interlinking of Rivers scheme, specifically part of the Parbati-Kalisindh-Chambal (PKC) scheme, see for example the mention of Mohanpura dam on Newaj river in salient features of the PKC scheme at: http://nwda.gov.in/writereaddata/linkimages/7740745524.PDF, the full feasibility report of the PKC scheme can be seen at: http://nwda.gov.in/index4.asp?ssslid=36&subsubsublinkid=24&langid=1. This hiding of this crucial information by the Project Proponent is tantamount to misleading the EAC and MoEF and should invite action under EIA notification. The claim by WAPCOS (through their response in Oct 2013) that this was mentioned in DPR is clearly not tenable since this should have been mentioned in the EIA.
Much bigger Mohanpura Reservoir proposed compared to the PKC proposal It is clear from the perusal of the Feasibility of the PKC link given on the NWDA link that the project now proposed by the Govt of Madhya Pradesh is much bigger and actually an unviable scheme. The Gross and live storage of the NWDA scheme is 140 MCM and 52.5 MCM, where as the proposal now before the EAC has gross storage of 616.27 MCM and live storage of 539.42 MCM (page 1-328 mentions Live storage as 616 MCM, showing another instance of shoddy work of WAPCOS), which means the live storage proposed now is more than ten times the live storage proposed in NWDA scheme. It may be noted that there is less than 4% difference in catchment area of the two schemes, the NWDA site was slightly upstream with the catchment area of 3594 sq km, compared to catchment area of now proposed scheme being 3726 sq km, the difference between the two is only 132 sq km.
This does not warrant or justify more than ten time higher live storage. In fact the NWDA scheme had the proposal to transfer 464 MCM from the Patanpur Dam to the Mohanpura dam and yet, under the Mohanpura live storage capacity proposed under NWDA scheme was much smaller. It is clear that the proposal before NWDA is completely unviable proposal and should be rejected.
No justification for increasing the live storage capacity OVER TEN TIMES This is a very serious issue and unless this is satisfactorily resolved, EAC should not consider the proposal.
Here it should be point out that the following discussion in the 67th EAC meeting regarding the SANDRP letter is misleading: “The developers were asked to clarify doubts raised in the above letters relating to the project features that contradict with the assumptions made in the NWDA study of Parbati – Kalisindh – Chambal Scheme, a major issue is that the NWDA scheme envisaged a gross and live storage provision of 140 and 52.5 MCM respectively against the present proposal 616.27 and 539.42 MCM respectively because the NWDA proposed transferring 464 MCM from Patanpur dam to Mohanpura Reservoir to reduce the large submergence of Mohanpura Reservoir. The developers clarified that the NWDA scheme has not been accepted by the M.P. Government and is not likely to be implemented in the near future. The M. P. Government wants immediate implementation of Mohanpura Project for poverty alleviation of the backward Rajgarh District.”
The issue is not only about how NWDA plans differed from the current proposal in terms of transferring 464 MCM water to Mohanpura dam from Patanpur dam and transferring 403 MCM from Mohanpura dam to Kundaliya dam. Net effect of these two transfers is addition of less than about 61 MCM water to Mohanpura dam in NWDA proposal from outside the Newaj basin. In spite of this addition, the storage capacity of the Mohanpura dam in NWDA proposal is HUGELY LOWER than in the current GOMP proposal. There is clearly no justification for such huge storage capacity from any angle. Even the water use plan has exaggerated figures and does not change even with changed cropping pattern. The issue is the viability, desirability, need and optimality of the ten times larger reservoir than was NWDA proposed earlier.
Unfounded assumption about water availability The project assumes huge yield of 745.2 MCM, much higher than that assessed by the Chambal Master Plan, without assigning any reason. This seems to be a ploy to push for unjustifiably huge reservoir. This is clearly wrong and the proposal should be rejected. The reply by WAPCOS that “The calculated yield of dam is approved by Bureau of Design of Hydel & Irrigation Project (BODHI), M.P.” is not convincing since BODHI is government of Madhya Pradesh organisation and in any case, their approval letter and methodology details have not been attached. In any case, Newaj being in interstate Chambal river basin, it will need vetting by the interstate Chambal River Board or credible independent body.
Inadequate assessment of upstream water requirement The EIA does not do proper or adequate assessment of current and future water requirements of upstream areas and allocates almost all available water in the catchment to the project in a bid to justify unjustifiable project. The figures given in table 10.9 are not even substantiated with any basis and hence are far from adequate in the context. The PP has also not responded to the EAC query about the upstream water demand.
Unjustifiable submergence The proposal entails submergence of 7051 Ha, almost three times the submergence as per NWDA scheme of 2510 ha. The project proponent has hugely underestimated the number of affected families to 1800 against private land acquisition of 5163 ha. They have amazingly, allotted just 132 ha of land for R&R, when land for land provisions under the MP R&R policy will require much more than 5000 ha just for R&R. The social impact assessment has not been done at all. In fact the phrase Social Impact Assessment or Social Impact does not figure in the entire EIA, when the National Green Tribunal has been laying such a stress on SIA.
The whole social impact assessment of the proposal now submitted is shoddy. It is clear the huge displacement is unjustified, and the project proponent has no interest in even doing any just rehabilitation. The PP has not explained the justification for three times increasing the submergence area compared to the NWDA proposal.
Interstate aspects ignored The project is coming up on an interstate river basin and will have clear implications for the downstream state of Rajasthan, but there is no mention of this in the EIA. Several meetings have also happened between Madhya Pradesh and Rajasthan about the PKC link mentioned above. The Government of India has prioritized this link, but by taking up this project unilaterally without consent of Rajasthan or Centre (Ministry of Water Resources) the Madhya Pradesh government is violating the interstate and federal norms. The EIA does not even mention any of these issues.
Underestimation of Land required for Canal The project has command area of 97750 ha and claims that it will require just 152 ha of land for canals (table 2.6 of EIA), which is clearly a huge under estimate and is not based on any real assessment. The project will require several times more land for the canals and will have related social and environmental impacts which have not even been assessed. The response from WAPCOS that this is because most of the water conveyance system is underground is far from adequate since an assessment of land requirement should still have been done and a lot of land would still be required at the end of water conveyance system.
No Command Area Development Plan The EIA report (May 2013) mentions CAD in two sections: Section 2.8 and 10.9. However, perusal of both sections show that neither have full description of Command Area Development Plan or adverse Impacts of the project in the Command Area including drainage, health, biodiversity and other issues.
Shocking statements in Command Area Development Plan The CAD now annexed in the Additional information (dated Aug 2013) makes some shocking statements. e.g. It says: “GCA of the project is 928680 ha…” with an extra “0”. This seems to suggest that the EIA consultant is callous.
The CAD further says: “Maximum height of the spillway above the ground will be 47.90 m (measured from river bed level to top of the spillway bridge). Maximum height of spillway from expected foundation level will be 47.90 m.” So the height of the spillway above the riverbed and above the foundation is same! This means that there is no foundation of the dam below the riverbed level! This again shows the callousness and lack of understanding of basic concepts by WAPCOS.
Section 2.9 of CAD says: “The groundwater development is of the order of 6.9% to 8.7% in the command area blocks.” In reality, as the table 2-3 just below this statement shows, the groundwater draft is 69 to 89%.
Section 3.1 of CAD says: “…the catchment area intercepted upto Mohanpura dam site is 3825 sq.km.” The last sentence in the same para says: “The catchment area intercepted at the dam site is 3726 sq.km.” Such figures for the catchment area upto Mohanpura dam keeps appearing in the documents.
The CAD should start with clear statement of HOW MUCH OF THE PROPOSED COMMAND AREA IS ALREADY IRRIGATED. This is not even mentioned.
No Downstream Impact Assessment The EIA report has not done any downstream impact assessment, including the impact on biodiversity, livelihoods, draw down agriculture, water security, groundwater recharge, geo-morphological impacts, among others. The response of WAPCOS in Oct 2013 that Newaj is a monsoon fed river and hence there are no downstream impacts is completely inadequate and shows the lack of understanding of functions of the river on the part of WAPCOS.
Impact of project on National Chambal Sanctuary It may be noted that the project is to be constructed on Newaj river, a tributary of the Chambal river. The project will have significant impact of water, silt and nutrient flow pattern into the ChambalRiver, the approximate 600 km of which has been declared as National Chambal Sanctuary between 1979-1983 across three states of Madhya Pradesh, Rajasthan and Uttar Pradesh. However, the EIA does not even mention that the National Chambal Sanctuary exists down stream of the proposed project and will be impacted by the project. According to section 29 of the Wildlife Protection Act of 1972, any project that affects flow of water into or out of the protected area should be assessed for its impact on such sanctuary and necessary clearances be taken from the designated authorities including Chief Wildlife Wardens and National Wild Life Board. However, WAPCOS does not even seem aware of the existence of the sanctuary.
Another point to note is that the entire water availability in the NCS is dependent on the KaliSindh and Parbati since there is no discharge below the Kota Barrage. The response from WAPCOS (Oct 2013) that the Mohanpura catchment is about 200 km from the river and that it is just 2.5% of the Chambal catchment and hence will not have any impact is clearly untenable. Firstly, the EIA does not even mention the existence of National Chambal Sanctuary. Secondly, it is not the distance of % catchment, but the impact of the abstraction that is important and the EIA has clearly not done that.
Impact of mining of materials for the project not mentioned The EIA has some assessment of material required to be mined for the project at Table 2.7, but where will these materials come from and what will be the impacts of this is not even mentioned.
No proper Options Assessment The EIA does not do proper options assessment to arrive at the conclusion that the proposed project is the most optimum proposal. It may be noted that the area has rainfall of 972 mm (see Chapter 2 in Command Area Dev Plan in Additional Information dated Aug 2013) and there are a lot of options for local water systems. As is clear from the public hearing report, several farmers suggested that in stead of one big dam a series of smaller dams should be built and that farmers will have to commit suicide if the dam is built. The response in the EIA is most callous that this is not technically feasible is not even backed by any evidence, which again shows the shoddy nature of the EIA.
The response of WAPCOS (Oct 2013) that the project is justified for fluoride affected area is completely misleading since if that was the concern than much smaller dam and large number of rain water harvesting structures would better serve the purpose. This again shows that WAPCOS has not done any options assessment.
Public hearing in the office of the DM? Chapter 17 of the EIA says, “Public Hearing for Mohanpura Multipurpose Major Project was conducted by Madhya Pradesh State Pollution Control Board (MPPCB) on 11th March 2013 in the premises of the office of the District Magistrate, Rajgarh”. This is most shocking state of affairs. The Public hearing as per the EIA notification is supposed to be conducted at the project site and cannot be conducted in the office of the District Magistrate. The MoEF should have applied its mind on just this aspect and rejected the proposal and asked them to get the public hearing done in legal way. The public hearing report is also incomplete with several sentences not being complete. This again shows lack of application of mind on the part of the MoEF and WAPCOS. The response from WAPCOS in Oct 2013 that the DM office is just 9 km from the dam site and is convenient to all concerned is clearly wrong, the public hearing should have been conducted in the affected area and public hearing report should be full and cannot be accepted with half sentences. This public hearing will also not pass the legal scrutiny.
CUMULATIVE IMPACT ASSESSMENT FOR CHAMBAL BASIN A very large number of dams and other water use projects have been constructed, are under construction and under sanction in the ChambalRiver Basin. It is high time that a Cumulative Impact Assessment (CIA) and carrying capacity study for the ChambalBasin be done before any more projects are considered in the basin. This is also required as per the MoEF Office Memorandum (J-11013/1/2013-IA-1 dated May 28, 2013) that required states to initiate CIA in all basins within three months, that is by Aug 28, 2013.
Unacceptable EIA The whole EIA is done in most shoddy way and should be rejected for this reason and EAC should make recommendation for black listing of WAPCOS as EIA agency. Just to illustrate, the EIA says MDDL stands for Maximum Draw Down level (page 1-14), has not even mentioned the project impact on the National Chambal Sanctuary (one of the only two river sanctuaries of India also proposed as Ramsar site), for hugely inadequate R&R land and canal land requirements, for not doing impact of mining of materials for the project, for not assessing the hydrological viability of the project, for making unfounded assumptions, among other reasons mentioned above.
Issue of Conflict of Interest for WAPCOS It may be noted that WAPCOS is a Ministry of Water Resources organization, and has been in the business of doing pre-feasibility, feasibility reports and Detailed Project Reports, which are necessary for the justification of the projects. This is part of the business of the organization. Such an organization has clear conflict of interest in doing an honest EIA since an honest EIA can lead to a possible answer that the project is not viable. Hence EAC should recommend that the WAPCOS should be debarred from doing any EIAs or CIAs (Cumulative Impact Assessments).
Other Issues Besides the above, a large number of issues raised by EAC in 67th meeting remain unresolved.
Þ For example, the area to be inundated by dam break needs to be listed and shown on map, which has not been done.
Þ EAC had asked: “Details of drainage network planning be included in the report.” In response, PP has attached Annex III which is just a map!
Þ EAC had asked: “75%flow series gives a total yield of catchment as 25.77 cumec-10 days in 75% dependable year. Whereas in table-5.2 the 75% dependable yield is given as 749.71 Mcm. The same needs to be corrected. Corresponding corrections at relevant sections in Volume-II, EMP report also be done”. This has not been done except an amended table
Þ Annex XIV in Additional Info on “INCOME – EXPENDITURE DETAILS OF PAFs” leaves a lot to be desired. Here, what does the figures represent in Table 1 is also not clear.
Þ Annex XV in Additional Info volume is basically a reproduction of 10.11.6 from the EIA. Incidentally, it ends by saying: “Project planner need to understand the negative impacts with sensitivity, and formulate mitigation measures appropriately; such mitigations measures that would be acceptable to the concerned population groups and that are sustainable.” The proposed project or the R&R plan are neither acceptable to the concerned population groups, nor sustainable, in any case, there is no process to achieve this.
Þ EAC had asked for more no of villages in the sample compared to 9, but the EIA consultant has refused to do this (Annex XVI and XVII in additional Info) without any convincing reason.
CONCLUSION In view of the above, we urge EAC to:
1. Reject the proposal for environmental clearance. It will be most shocking if the project gets cleared with this kind of EIA.
2. Reject the EIA, as explained above this is most shoddy EIA.
3. Reject the Public hearing; as explained above, the public hearing has not been conducted as legally required. The public hearing also need to be conducted again since the EIA is found to be so seriously inadequate and needs to be redone. In any case, with so many additions and changes to the EIA, the public hearing clearly needs to be redone.
4. Suggest black listing of WAPCOS as EIA and CIA agency. It is high time for EAC to send a signal that such shoddy EIA would not be accepted and is in violation of law.
Submission showing how the WAPCOS EIA of Mohanpura Project is Inadequate and Plagiarised
Sep 23, 2013
To,
Chairman and members,
Expert Appraisal Committee on RiverValley Projects,
Ministry of Environment and Forests,
New Delhi Subject: Serious concerns on the Mohanpura Irrigation Project on agenda for the 68th meeting of EAC of RVP
Dear Chairman and Members of the EAC-RVP,
With reference to the Mohanpura Irrigation Project on agenda for the 68th meeting of the Expert Appraisal Committee on River Valley Projects, and WAPCOS response to EAC comments (August 2013), I believe that the concerns raised by the New Delhi based SANDRP has not been addressed. The Project Proponent has also not responded satisfactorily to the queries raised by the EAC, and I outline a few of their (WAPCOS) responses below –
EAC Comment No. 16: The source of data for faunal population is to be provided. The source of secondary information may be provided if used.
EAC Comment No. 17: The avifaunal list is good but requires a lot of typographical corrections. Also some of the species such as Golden Plover and Redshank have been shown as resident although they are migratory.
EAC Comment No. 18: The list of reptiles appears deficient for this hot and dry area of central India. This needs to be updated. The information provided by WAPCOS under-represents the faunal richness of the region and is an attempt to deceive the Expert Appraisal Committee on River Valley Projects. The sources used in the EIA are old and I would like to draw you attention to more recent work from the region (attached below).
Nair, T. & Krishna, Y. C. (2013). Vertebrate fauna of the ChambalRiver Basin, with emphasis on the National Chambal Sanctuary. Journal of Threatened Taxa, 5(2): 3620–3641; doi:10.11609/JoTT.o3238.3620-41
EAC Comment No. 19: The methodology for faunal surveys has not been provided properly. The faunal part in section 4.2.2 is too brief and fails to provide any idea about the primary effort. The source of secondary information may be provided if used. The methodology outlined in Annexure-XII by WAPCOS has simply been copied from other survey reports / studies without actually conducting them. This amounts to professional dishonesty and fraud, and is another attempt to deceive the EAC-RVP.
Eg: “Direct Count: Both terrestrial and arboreal (small and large) mammals were counted during monitoring of line transect (Burnham et al. 1980) that were walked in the early and late hours of the day, and during the night using spotlight or headlights (Duckworth 1992).” is plagiarised fromhttp://fes.org.in/studies/sitamata-report-final-july.pdf?file=ZG93bmxvYWQvd3AxOS5wZGY=
“Indirect Count: Presence and relative abundance of most of the small and large mammals was evaluated using methods that rely on indirect evidence such as animal burrows/holes, dung, pellets, scats, feeding signs, tracks, nests, digging and antler thrashing.” is also plagiarised fromhttp://fes.org.in/studies/sitamata-report-final-july.pdf?file=ZG93bmxvYWQvd3AxOS5wZGY=
“Line Transect useful in determining variation in herpetofaunal populations across continuously changing environmental gradients (Jaeger, 1994). Thus, systematic searches can be used to provide data for distribution, inventory, relative abundance, density estimates, population trends, site occupancy and territory mapping.” is plagiarised fromhttp://www.outdooralabama.com/research-mgmt/State%20Wildlife%20Grants/AL_AM_Final_Report.pdf
EAC Comment No. 20: The presence/absence of Blackbuck, a Schedule-I species, may be commented upon since it is expected in the area. WAPCOS response that ‘Blackbuck is not reported in the area’ is again not true. Please refer to the press report and scientific study which show the presence of black buck from the area. Press report: http://articles.timesofindia.indiatimes.com/2013-01-05/flora-fauna/36162066_1_blackbuck-population-stray-dogs-habitat Scientific publication: Karanth, K. K., Nichols, J. D., Hines, J. E., Karanth, K. U. and Christensen, N. L. (2009), Patterns and determinants of mammal species occurrence in India. Journal of Applied Ecology, 46: 1189–1200. doi: 10.1111/j.1365-2664.2009.01710.x I believe that such a manner of plagiarism and false claims of having used scientific methods during the Environmental Impact Assessment is reason enough to reject the project and to blacklist WAPCOS. Further, the Government must initiate civil and criminal proceedings against WAPCOS for fraud, suppressing facts and providing misleading information on an issue that has serious and negative ecological and social consequences.
It is becoming increasingly evident that ‘rivers’ do not figure anywhere in the entire e flows discourse and assessments going on at Government level in India. We have so many different types of e-flows assessments being tried out.
Multiple agencies, but where are the flows? At least 69 hydro power projects are in various stages of development in Alaknanda – Bhagirathi sub basins of the Ganga (as per IMG records). Four different e-flow regimes based on different approaches have been put forward by the four different agencies. While AHEC (Alternate Hydro Electricity Centre) has used Mean Annual Flows (MAF), WII (Wildlife Institute of India) has resorted to Mean Seasonal Runoff (MSR) for different seasons based on the needs of the fishes. CWC (Central Water Commission) has resorted to ad-hoc e flows of 20 % of daily flows. IMG (Inter-Ministerial Group) has come out with its own recommendation of percentage of daily inflows for different seasons going upto 50 % for winter season from December – March where winter flows are very low.
The beautiful Nyamjangchu River, Tawang, Arunachal Pradesh, now threatened by the 780 MW Nyamjangchu Hydel Project and very low eflows recommendation Photo courtesy: Tenzing Rab Monpa
While admitting that Building Block Methodology (BBM) is the most comprehensive holistic methodology, IMG report claims (without basis) that since it is time consuming and since it has not been tried out in any large river basin, interim e-flows recommendations be done so that hydro power development is not held up for want of environmental decisions. Mind you, this is the case with all the rivers where hydro power projects are being planned. While many of the project developers and EIA agencies claim that they follow BBM methodology, it is evident that none of these fulfill the requirements of a comprehensive BBM methodology. So who cares about the rivers here?
NIH workshop on Oct 2-3, 2013 without MoEF! The National Workshop on Environmental flows organized by the National Institute of Hydrology (NIH), Roorkee along with UK based Centre for Ecology and Hydrology (CEH) during 2-3 Oct 2013 only reinforced my conviction that what is going on in the name of e flows assessment is indeed not for any goodwill for the rivers. The workshop was conspicuous by the absence of MoEF officials whose main mandate is protecting river ecosystems and life in rivers. Were they not invited or did they decide not to participate? It was mostly dominated by technical persons and organisations who believe that rivers are for the exploitation by humans alone mostly through mega projects. The workshop agenda was set on the oft repeated dictum that e flows should be integrated into water resources development, without any will for such integration.
E-flows are for rivers In India e flows is just a formality to fulfill the requirements of the environmental clearance process. Ironically, resource persons from countries outside India with ample experience on e flows assessment pointed out that the intention was to find ways to ‘limit’ or mitigate the impacts of development. If the agenda had been set with the intention that e flows should be part of river conservation and not just to fulfill the development agenda then we would have some hope for rivers.
Developers don’t want any e-flows Project developers are clearly unhappy with even the meager allocation in the name of e flows. The dam builders like the NHPC, Uttaranchal Jal Vidyut Nigam Ltd. and Tehri Hydro Power Corporation claimed that they are actually releasing more water than they are ‘asked to’! This is indeed ridiculous. Even what they are ‘asked to’ release does not amount to e-flows and is not based on any comprehensive assessment or community validation! And there is clear evidence that they are not releasing even that (e.g. NHPC’s Teesta V or Tehri). Then where does the question of reducing e-flows allocation below dams arise? They even went to the extent of recommending that in those rivers where tributaries join the dry stretch below the dam, can’t e flows allocation be reduced and can’t the tributary contribution added as e flows? Can’t e flow releases be used for power generation by installing dam toe power houses? For them e flows is mere ‘cumecs’ (Cubic meters per second) of water to be released and nor do they understand that each tributary and the main stem of the river have their own ecological niches & functions; and social and cultural dependencies which are linked to the flows in each of these.
Dhauliganga before the June 2013 disaster, with zero water flow downstream from the dam, killing a perennial river. Source: Emmanuel Theophilus
The presentations made by NIH Roorkee, CIFRI (Central Inland Fisheries Research Institute), GBPIHED (GP Pant Institute of Himalayan Environment and Development) and AHEC for proposed hydro power projects in the Himalayas and the North East India revealed that none of the studies had carried out consultations with river dependent communities and did not follow the BBM principles either.
CIFRI-NIH’s flawed assessment of Teesta IV HEP e-flows Teesta IV HEP proposed in Sikkim is presently under the scanner since many groups have raised the genuine concern with the MoEF (Ministry of Environment and Forests), EAC (Expert Appraisal Committee), FAC (Forest Advisory Committee) and the NBWL (National Board of Wild Life) that if implemented it would mean the death of the last free flowing stretch of the main Teesta river. The ToR (Terms of Reference) of the study commissioned by MoEF says, “An estimation to be made for environmental flows downstream forsustenance of aquatic environment and for downstream uses, considering details of streams joining the river below the proposed dam site with their approximate distance from the dam site, their nature (whether perennial or seasonal) etc. A detailed environmental flows study shall be carried out through the premier institutions such as Central Inland Fisheries Research Institute (CIFRI), Barrackpore and National Institute of Hydrology (NIH), Roorkee for biological and hydrological components”.
The consultants took just 7.5 km length of the river from dam axis to the existing downstream project Teesta V which is immediately downstream. The study carried out in 2009- 2010 period has prescribed a minimum discharge of 10 cumecs (Cubic Meters per second) from the dam during the lean period and 40 cumecs for wet season for aquatic life is also prescribed. The ToR has two objectives namely e flows for the sustenance of aquatic environment and for downstream uses, but the sampling parameters in the presentation does not reflect the fulfillment of these objectives.
Teesta V HEP Photo: Tehelka
Since the Teesta V is already commissioned, the impact below the dammed and flow regulated stretch of Teesta V on the aquatic environment and downstream uses would have given useful comparisons. The study seems to have ignored the e flows for downstream uses of communities even in the 7.5 km stretch. The study though claimed to have used the BBM methodology, it is doubtful if all the relevant building blocks have been considered. The study carried out in 2009-10 does not seem to be uploaded in public domain to date.
E-flows for all projects do not make sense? Most shockingly, the chief consultant for the Ganga River Basin Management Plan now being formulated by a consortium of IITs (Indian Institutes of Technology) Dr Vinod Tare was of the opinion that all projects to release e flows does not make sense. He said it is important to seek balance and generate power as well. Now this is problematic. Let us face it that in Indian conditions we are working on e-flows under data and information deficient conditions. We are still far away from understanding a river system in its complexity along with its basin characters, eco- hydrological interactions and land use changes.
Lack of Eco-hydrological understanding Even NIH engineers and other experts agreed during discussions that we lack reliable hydrological data and have absolutely very little ecological data base on our rivers to arrive at proper recommendations for e-flows. MoEF and NGRBA (National Ganga River Basin Authority) has meanwhile accepted BBM methodology (as in the NGRBA Report; Code – 022_GBP_IIT_EFL_SOA_01_Ver 1_Dec 2011) as the most robust assessment approach to e-flows and they also say it needs to be worked upon.
The report says, ‘The BBM methodology is found to be robust with high confidence level. However, specific flow recommendations are difficult to justify at this stage, and will have to be worked out afresh. The major uncertainties centered on the hydrological and hydraulic models due to lack of availability of reliable data’. In BBM all blocks are equally important as they interact with each other. Against such a scenario, Dr Tare needs to think twice before making such statements! They can be used by dam developers to lobby for reduced or even no flows.
What about e-flows from existing dams? Another missing element from e-flows at the NIH workshop that is bothersome was the lack of interest by the experts and the various authorized institutions in allocating e flows below already dammed rivers. They say it will be a tough job and would not be possible politically. However, ultimately e-flows is a social and political choice with trade offs and negotiations inbuilt into it. Does that imply that we can leave heavily dam ravaged rivers like the Mahanadi, Krishna, Cauvery, Narmada, Tapi, Sabarmati, Godavari, Teesta, Sutlej, Ravi, Beas, Chenab, Periyar and the like to die without allowing them at least their long overdue minimum flows leave alone e flows ? It is high time the Government took interest and started engagement and studies in arriving at and allocating e flows below dammed rivers.
The same Baspa, bone dry, about 5 kms downstream Baspa Dam. Photo: SANDRP Partners
Future challenges After two days of debate and disagreements, I came out of the workshop with the following thoughts at the top of my mind.
Several institutions in this country with expertise in ecology and hydrology and with necessary infrastructure who could have made efforts to put in place comprehensive e-flows assessment process are working for dam developers and serving as experts in EIA studies giving green signals to ill conceived hydro electric projects and dams based on inadequate e-flows recommendations. The level of dilution of science and ethics this can lead to is mind-boggling and with disastrous consequences for our rivers. For example e-flows and minimum environmental flows are being used as synonyms by many institutions including CWC. An interesting and dangerous recommendation from CWC at the workshop is; ‘If feasible, a separate storage of water in the upper reaches of a river basin maybe created for environmental needs which will help in augmenting flows during lean season and satisfy the e-flows demands particularly for Himalayan rivers’. So in future all river basins with dam cascades could be recommended with e-flows reservoirs!
What about compliance, MoEF? While e-flows have become mandatory for hydro power projects in this country, it is surprising and shocking that MoEF is yet to ensure compliance and to take up comprehensive and fundamental assessment of e-flows in sample river basins on its own which is its primary mandate. It is high time MoEF develops a ToR for e-flows from its conception to implementation to monitoring. E-flows assessment presently being carried out lacks proper objectives and mostly excludes communities from its purview or assessment. There is vagueness about what constitutes downstream in e-flows assessment. Even for the e flows assessment carried out in River Ganga for the NGRBA has there been any effort to implement the same? Has the MoEF ever tried to seek inputs on e flows from outside the government organisations or from the several groups working tirelessly for conservation of rivers?
Will NIH exercise have credibility? NIH in collaboration with many institutions proposes to take up sample river basins in India and put in place eco hydrological models for e flows. The absence of MoEF and members of the Expert Appraisal Committee on River Valley Projects at this workshop organized by a MoWR institution speaks for itself how e-flows will be realized if the mandatory ministry does not take a pro active role.
Some of the gaps and challenges in e flows assessment in Indian context include: lack of reliable data, lack of understanding of eco- hydrological linkages, river aquifer interactions, pollution related aspects (how to quantify and relate to flow releases), e-flow releases for flood plains, lack of resource allocation, lack of valuation of ecosystem services and societal – cultural value of rivers, multiple institutions working against each other’s interests (MoWR vs MoEF), Peaking induced flashiness, scientific and acceptable ways to compute e-flows and lastly but most importantly, effective implementation and monitoring.
Experts from other countries pointed out that rather than numbers it is better to have distribution ranges for e flows under Indian conditions with complex dependencies. They also made an important comment that uncertainty and risk factors never get integrated into our e-flows estimations. In India land use changes are also not accounted in e flows calculations.
The EIA of the Bansujara Multipurpose Project (BMP) dated May 2013 by WAPCOS has been submitted for Environment Clearance of the project before the Expert Appraisal Committee on River Valley Projects, in Nov 2013. WAPCOS is known to do very shoddy job of Environment Impact Assessments, this one is no different. In what follows I have given a few instances of wrong facts, contradictory facts, wrong calculations or assumptions, incomplete assessments, instances that shows it is cut and paste job and lack of options assessment by the 564 page EIA document. The conclusion is inescapable that the EAC and MoEF must reject this EIA and recommend black listing and other measures against WAPCOS. The project should be asked to get a fresh EIA done by a credible agency.
Location Map of Bansujara Irrigation Project
WRONG FACTS The EIA provides several completely wrong facts, here are a few instances:
1. River description On p 1-1 the EIA says: “The Bansujara Dam Project lies in Dhasan sub-basin of Betwa basin, River Betwa is a tributary of Yamuna river, rises in district Bhopal district at an elevation of 472 m. After traversing a length of 365 km, it joins Yamuna river in Uttar Pradesh. The river runs for nearly 240 km in Madhya Pradesh, 54 km along common border of Madhya Pradesh and Uttar Pradesh and 71 Km in Uttar Pradesh state before its confluence with Yamuna river near Hamirpur town in Hamirpur district of Uttar Pradesh.” This is actually the description of River Dhasan and not Betwa! It is exactly same as the description of river Dhasan given on the next page and several other places subsequently.
2. Land required for Canals In Table 2.3 it is stated that canals will require 44 ha land, this is clearly gross under-estimate considering even 49.9 km of main canal.
3.Private land under required for project The SIA says on page 1-2, “About 935.11 ha of culturable area, 57.49 ha of forest land and 4209.118 ha of other land including road, nallah, river, etc. will be affected.” This is blatantly wrong figure. On page 1-3/4 of SIA it is stated: “About 2935.11 ha of revenue/government land and 2894.37 ha of private land is to be acquired.” This again is wrong.
As the MoEF factsheet for the Forest clearance for the project says, “Apart from the 57.495 hectares of forest land proposed to be diverted, the project involves submergence of 287.951 hectares of government land and 4,856.276 hectares of private land.” Thus the suggestion by the SIA that only 935.11 ha of culturable land is going under submergence is clearly wrong since most of the private land is under cultivation in these villages.
4.How many families will be affected The MoEF Factsheet for the project says: “The project involves submergence of 21 villages. 2628 houses, 773 wells, 5082 trees, and 2628 families with population of 13,142 are getting affected due to submergence.” These figures are at variance with the figures mentioned in the EIA. For example, the SIA (p 1-4, repeated on page 4-1) says: “Over all 748 families of 9 Abadi Villages will be affected”. This when the project will be taking away 2628 houses as per the Fact sheet, is clearly gross wrong reporting of figures. Because of use of wrong figures, their R&R plan and R&R costs are also all wrong and gross under estimates. Moreover, now the R&R plan and costs should be as per the new Land Acquisition Act Passed by the Parliament, which has not been done in the EIA-SIA. As per the new Act, land has to be provided to each losing farmer, and this must be followed.
5. Completely impossible figures of crop yields A look at table 4.3 of SIA (repeated in table 7.1 of CADP) shows that the consultants have given crop yields before project (e.g. paddy 7 t/ha, wheat 18 t/ha, groundnut 10 t/ha and gram 10 t/ha) which are much higher than the average of even Punjab crop yields and they are expecting to double that post project! These are clearly impossible figures. This shows that the consultants are plain bluffing and seem to have no clue about possible crop yields and in any case do not seem to have done any surveys, but are only cooking up data. Amazingly, they are claiming that with 211% increase in crop yield, the profits from crops will go up by 318%! All this simply shows the manipulations they are indulging in to show the project is economically viable.
CONTRADICTORY FACTS 1.Main canal length Page 2-2 says main canal length is 90 km, the salient features on next page says Main canal length is 49.9 km.
2.Command area Tehsils and villages Section 10.2 of EIA (and again section 2.7 of the CADP) says: “The Command area of the proposed Bansujara Major Irrigation project lies within the district Tikamgarh in jatur and Baldeogarh tehsil” and than goes on to give details of these tehsils, but the rest of the document (e.g. section 6.1) says: “A total of 124 villages are likely to be benefitted by the project. 80 villages are located in Tehsil Khargapur of district Tikamgarh. About 13 villages are located in tehsil Jatara of district Tikamgarh. The remaining (31) villages are located in tehsil Palera of Chattarpur district.” Chapter 6 in fact provides full list of 124 villages in the command area. The subsequent details of the command area given in chapter 10 thus does not match with what is given say in chapter 6.
Contradicting this, page 1-4 of SIA says: “The Bansujara Multipurpose Project will benefit almost 132 villages in districts Tikamgarh and Chattarpur.” Amazingly, the SIA says Palera tehsil is in Tikamgarh district and not in Chattarpur district and that additional ten villages of Badamalhera tehsil of Chattarpur district will also be in command area!
Number of beneficiary villages in Palera tehsil are given as 31 in page 44 (chapter 6) and 30 on page 141 (chapter 11), with even names differing, e.g. Banne Khurd and Bastaguwan mentioned in chapter 6 are missing in chapter 11, village Bargram mentioned in chapter 11 is missing from the list in chapter 6.
All this is most callous and shocking. This fact alone should be sufficient to REJECT this callous EIA and recommend blacklisting and other punitive measures for WAPCOS as consultant.
3.Command area population Section 10.2.1 of EIA says: “As per 2001 Census the total population of the command area is about 38,000. The male and female population is 20,181 and 17,828”. However a look at the 10.2 that follows this sentence shows that these figures are for Jatara tehsil and not command area. Another sign of callousness.
4.Submergence villages Table 11.3 of EIA gives list of Project affected families, which is at variance with the list given in tables 10.8-10.14. Firstly, chapter 10 tables say that 14 villages of Tikamgarh Tehsil are affected, but table 11.3 lists only 13 villages. More shockingly, tables in chapter 10 say 6 villages of Bada Malhera tehsil of Chhatarpur district are affected, whereas the name of this tehsil given in chapter 11 is Bijawar. All this shows shocking callousness of WAPCOS.
5.Storage Capacity Page 11-10 says: “The storage capacity of Bansujara Reservoir is 539.42 Mm3.” This is clearly wrong, the figures for gross and live storage capacity given in salient features and elsewhere are: 313.1 MCM and 272.789 MCM respectively.
6.Water Availability As per Table 5.8, water availability at the project site from MP catchment (2788 sq km) alone is 843 MCM. Strangely, this reduces to 588.68 MCM in table 11.6 for whole of catchment (3331.776 sq km) at dam site. No explanation is given for these figures.
7.Submergence area While most of the document gives submergence area as 5201.71 ha. However, in section 2.7 of EMP, it says, “The submergence area of Bansujara Irrigation Project is 7476 ha.” This is amazing kind of contradiction.
WRONG CALCULATIONS/ ASSUMPTIONS 1.Field channel length grossly underestimated The p 6-6 of EIA says: “The Bansujara Dam Project envisages irrigation over a CCA of 54000 ha. In the areas where irrigation is proposed no field drainage, land shaping of field channels exist and used to be constructed. From general experience and existing practice, it is assessed that a length of 1600 m of field channels will be required to serve a chak of 40 ha of CCA. On this basis, an approximate network of total length of 180 km of field channels will be required for 50% of CCA proposed for irrigation.” Simple calculation suggests that the field channel length for 50% of CCA would be 1080 km (54000 ha / 40 ha per 1.6 km divided by 2 for 50% CCA).
2.Drainage requirement under estimated Section 6.9 (p 6-7) of EIA says, “The command area is being traversed by a large number of nallahs and drains, therefore field drainage should not pose any problem.” This is clearly wrong assumption since additional irrigation will certainly require additional drainage and cost calculations based on such flawed assumptions are bound to be wrong.
3.Baseless assumption about waterlogging Similarly about the assumption in section 6.13 (p 6-8): “Even after construction of Bansujara Dam Project the area will not face any waterlogging problem.”
4. Wrong claims about no floods The conclusion about flood and back water impacts is completely unfounded in section 6.14 (p 6-8): “As per information gathered from the Collectorate Tikamgarh there is no village affected due to back-water of Dhasan and Ur rivers. The existing drainage system in the command is adequate. The statistics gathered from collectorate Tikamgarh show that there is no flood affected area. The command has fairly good flood disposal capacity and not special measures are called for.” This when the Maximum water level of the dam is full 1.4 m above the FRL, the back water level is found to be high. This is also particularly relevant in flood prone basin like Betwa-Dhasan.
5.Drainage characteristics of clayey soils ignored The assumption in section 7.1 (p 7-1) shows complete lack of understanding on the part of EIA consultants: “The area is sloping gently and near its outfall into Betwa river, the slope is of the order of 0% to 3%. It is traversed by small drainage channels at short distances and they help in draining excess water efficiently. Hence, no provision for drainage has been made. The soil is generally clayey.” It is well known that clayey soils are inefficiently draining soils and to make such assumption for clayey soils is clearly wrong.
6.Unrealistic assumption of irrigation efficiency System irrigation efficiency of 54% assumed in Table 11.10 is clearly wrong, no project in India has achieved such high efficiency. The water loss will surely be much higher than the assumption of 105 MCM on page 11-14. The conclusion on that page that: “The quantum of water not being utilized is quite small and is not expected to cause any significant problem of waterlogging” is clearly wrong and baseless, since water logging also depends on many other factors including drainage, soil structure, underground geology, among other factors.
7.No industries, but 19.4 MCM for industries! The CADP (page 5-7) clearly states: “At present there is no industrial requirement in the area.” And yet the project allocates 19.4 MCM water for industries. This again shows that the project is being pushed even though there is no need for it.
INCOMPLETE ASSESSMENT 1. Dependence on fisheries incomplete It is not clear what is the area from which fisheries assessment done as reported in section 9.11.6. How many people depend on fish, what is the production market and economy of the same is also not reported.
2. Hydrology figures without basis Chapter 11 (Table 11.6) assumes that “For use on u/s of Bansujara dam for environmental and ecological balance and Misc. uses by surface water” is 10 MCM and “Quantity of water reserve for d/s release for environmental and ecological balance” is 15.18 MCM and that groundwater available upstream of dam site will be 58.86 MCM (10% of surface water). No basis is given for any of these and all these (and many other) figures given in the water balance are clearly ad hoc, unfounded assumptions. The groundwater availability is typically 40% of total water availability, so around 67% of surface water availability. Why should it be 10% in case of the Dhasan basin is not explained and in any case does not seem plausible.
However, in Table 2.2 of EMP, the environment flow suggested in monsoon months is 12.8 cumecs. This would mean that the project would need to release 132 MCM of water in four monsoon months as environment flows, when they have assumed in hydrology that only 15.18 MCM water is required for this!
3.Incomplete SIA SIA says (SIA page 1-7) that it has selected certain of the 21 villages facing submergence due to the project. Actually the SIA should have done full survey of all the villages not a sample of villages.
4.Impact of loss of river not assessed It is expected that the SIA will assess the impact of loss of river for the people in submergence and downstream zone, but no such assessment has been done. Even in section 4.4 of SIA on “Impacts of Socio-Cultural Environment”, there is no mention of impact of river (or forest or other natural resources) on the people.
5.Full Canal details not given The EIA or CADP report does not provide the full lengths of main canals, distributaries, minors, field channels and field drains, including their width, land requirements, protection measures like canal like plantations etc. Without these basic details, the EIA or the CADP cannot be considered complete.
6.Command area coinciding with command area of Ken Betwa Link canal and other such projects? A perusal of the Command area of the Ken Betwa River Link Project (TOR approved by EAC in its 45th meeting in Dec 2010) shows that all the three Tehsils (namely Baldeogarh or Khargapur in Tikamgarh district, Jatara Tehsil in Tikamgarh district and Palera Tehsil in Chhattapur district) are also benefiting from Ken Betwa Link Canal. A look at the map of the command area of Ken Betwa link canal and that of the Bansujara shows that some area are certainly common. The EIA of Bansujara should have pointed this out and also if the proposed command area is to benefit from any other such projects, but it has not done that.
CUT AND PASTE JOB? Several parts of EIA raises the suspicion that they are cut and paste from other documents. This suspicion is proved correct when we see this sentence in Table 12.2 in Disaster Management Plan (Chapter 12 of EMP): “All staff from dam site, power house & TRC outlets alerted to move to safer places”, since the Bansujara project has no power house or TRC (Tail Race Channel). The consultants forgot to remove these irrelevant aspects while doing the cut and past job[1], it seems. This is just by way of illustration.
Similarly, the title of the section 2.6 of the Command Area Development Plan says it all: “2.6 FOREST TYPES IN THE MOHANPURA PROJECT AREA”. Here again it is clear that while doing cut and paste from another EIA, the consultants forgot to change the details! There is also the sentence “Tehsil Shajapur has maximum population density of 238 persons per sq.km. (2001 Census data)” on page 2-6 of CADP, but there is no mention of any such Tehsil in the area!
NO OPTIONS ASSESSMENT The EIA does not contain any options assessment. In fact section 10.2.4 shows that 19174 ha of the 48157 ha of cropped area in the command is already irrigated. This means a substantial 40% of the command area is already irrigated.
On page 3-5 of SIA it is mentioned that out of 318 land holding respondents in the SIA survey (in submergence villages), only 4 had unirrigated land. This shows that land of over 99% of respondents is already irrigated.
Very shockingly, the report does not mention what are the levels and trends of groundwater in the catchment and command of the project. When Groundwater is India’s mainstay for all water requirements, not give this full picture of groundwater makes the report fundamentally incomplete.
The area has average rainfall of around 1100 mm and thus more area can get irrigated with better use of this rainfall and such a huge dam with such huge submergence (5202 ha) and land requirement (5887 ha, gross underestimate considering that land for canals are not properly assessed), over 25000 people displacement (at least and that too only from submergence area) and other impacts is not the best option.
CONCLUSION What is listed above is not an exhaustive list. Nor are these some typographical errors, but these show serious incompetence, callousness and worse. The conclusion is inescapable that the EAC and MoEF must reject this EIA and recommend black listing and other measures against WAPCOS. The project should be asked to get a fresh EIA done by a credible agency. The EAC in the past have failed to apply its mind about such shoddy EIAs even when this was shown to EAC through such submissions. Most recent such case is that of the Mohanpura Irrigation Project in MP, in which case too the EIA was done by WAPCOS. It is hoped that EAC will apply its mind to this issue and make appropriate recommendations.
The Arunachal Pradesh government has signed a MoU with Panyor Hydro Power Private Limited, a company based in Hyderabad to construct the Panyor hydro electric project. This will be the second hydroelectric project coming up on the Panyor River which is also known as Ranganadi in the downstream. This project with 80 (2x40MW) MW installed capacity is to be considered for ToR clearance in the 69th meeting of EAC to be held on 11-12 November, 2013.
Salient Features Panyor Hydropower project will be located a Lemma, a village five km upstream of the Yazali town in Lower Subansiri district. The proposed project is 12 km upstream of the Ranganadi dam Stage II with a surface power house on the left bank of the river and a 108 m high concrete gravity dam. This reservoir will cover 7.5 km of the river length. The catchment area of this dam is 1315.50 sq km. The tail race channel will be 300 m long. Total area required for the project is 390 ha. Out of this 42 ha is river area, 25 ha is reserve forest and 323 ha is private land. The total estimated cost of this project is Rs 820 crores which imply that per megawatt cost is Rs 10.25 crores.
First Wave of Flash Flood on June 14, 2008 near N Lakhimpur town, due to excess water released from Ranganadi HEP without prior warning
Critical Issues It was surprising to see that even though the project has been on EAC agenda for ToR clearance MoEF website does not have the complete documents for this project. The PFR document of the project was not opening up in the website. Going through the Form I of the project we found several issues which need to be highlighted.
Downstream impacts In regard of the project on the Panyor river it is very important to remember that the catastrophic downstream impacts of hydropower dams in Arunachal, which has been a subject of much debate in Assam, with specific issues raised against the existing 405 MW HEP on Ranganadi. The release of water from the Ranganadi dam on June 14, 2008 had led to flash floods in a vast area and catastrophic devastation in the downstream. The Ranganadi dam is having severe downstream impacts not only in the Ranganadi valley, but also in the Dikrong valley since water from this dam is released in Dikrong or Pare River through an 8.5 km long diversion tunnel. Now construction of another dam on the same river which needs serious analysis since the Form I (p 45) states “Downstream impact on water, land, human environment due to drying up of the river at least 10 km downstream of the dam.”
The drying of the river for at least 10 km downstream of the proposed dam also need to seriously examined keeping in mind the reservoir spread of the Ranganadi stage I project.
Not a single village affected and no rehabilitation? Form I (p 33) states that not a single village would be affected and no rehabilitation needs to be done, which seems doubtful. The document at the beginning states that the project is located near Lemma village. It also suggests for socio-economic impacts where it mentioned about project affected families. These are serious contradictory issues within the same report and the developer should be asked to resolve this.
Environment Flow contradictory The Form I provides contradictory information regarding environment flow. On the last page, the document states “A scientific study shall be done to assess the downstream requirement of water to decide minimum assured release of water (Environmental Flows) for maintaining the aquatic ecology and water quality of river.” But on page 33 in the section 2.7 the document states that environment flow will be 3 cumecs.
Important aspects left out from scoping of EIA study In the scoping for EIA/EMP study there are several important aspect which the Form I has made no mention at all. These include:
1. Impacts of excavation and mining
2. Impact of the project on landslide and other disaster potential of the area and region.
3. Disaster management plan considering the previous flash flood event in June 2008.
4. Impacts of climate change and impacts of the project on local climate
5. Options assessment including potential of micro hydro (below 1 MW capacity) projects. The project will submerge a huge 312 ha of land. The PP (Project Proponent) should look into the options for run of river project rather than a dam with such huge submergence.
Wrong answers given in Form 1 In case of some of the information given in the Form 1, it seems wrong and the PP should be asked to correct it. For example (this is not exhaustive list):
1. In case of point 1.26 (p 11), in response to question “Long-term dismantling or decommissioning or restoration works?”, the Form says “No”. This is clearly wrong. After the useful life of the dam, it will need to be decommissioned and this has to be part of the EIA and TOR.
2. Similarly answer to question 1.27 (“Ongoing activity during decommissioning which could have an impact on the environment?”) is wrongly given as No.
3. In para 1.2 (p 6) there is no mention of land requirement for mining material for the project like sand, gravel, boulders, etc.
4. Para 2.2 (p 12) how much water will be used (KLD) or source is not given.
5. Para 2.3, in answer to minerals No is given, where as the project will require sand, clay, gravel, boulders, etc.
6. In response to Para 2.7, the impact of project on aquatic biodiversity, including fisheries should have been mentioned.
7. In response to Para 3.1 use of explosives is admitted. However, it should be told to PP to minimize the use of explosives considering the impact of them on increased landslides and other disasters.
8. In response to Para 3.3 the PP should have mentioned the impact of project on the people who also use the forests, rivers, get affected by other aspects including destruction of biodiversity including fisheries upstream and downstream.
9. In para 4.2 (p 16) and elsewhere, estimate of 1000 populations for “400 technical and labour staff” is clearly wrong. Also estimate of 200 labour vs 150 technical staff also do not seem correct.
10. Para 4.3 should also include the remains of explosives among hazardous waste.
11. Para 5.8 (p 19) answer (Q: Emissions from any other sources) No is clearly wrong, the reservoir covering 312 ha will certainly emit methane needs to be assessed.
12. In para 8.3 (p 22) and point 12 under environmental sensitivity (p 25-6) the vulnerability due to floods and landslides such others also need to be mentioned and response to them included.
13. The whole document keeps mentioning 25 ha forest land without inclusion of the community managed forest land in Arunachal Pradesh. This is clearly wrong information.
14. Under point 3 in on Environmental sensitivity (p 24) in response to “Areas used by protected, important or sensitive species of flora or fauna for breeding, nesting, foraging, resting, over wintering, migration”, it is not sufficient to investigate with forest dept, as the response says, since there are several aspects here (e.g. aquatic biodiversity) that are beyond the domain of forest department.
Cumulative Impact Assessment The information given in para 9.4 (p 24) is clearly wrong. There are at least eleven hydropower projects at various stages in the combined Ranganadi-Dikrong basin, including one operating, one under construction, three TOR approvals given and five additional MoA signed (in addition to the proposed project), see details below:
1. 405 MW Ranganadi HEP (Existing, transferring water from Ranganadi to Dikrong)
2. 110 MW Pare HEP (under construction)
3. 60 MW Par HEP on Dikrong (TOR approved by EAC on 8/9/2012)
4. 60 MW Dardu HEP on Dikrong (TOR approved by EAC on 8/9/2012)
5. 66 MW Turu HEP on Dikrong (TOR approved by EAC on 8/9/2012)
6. 25 MW Adum (Upper) Panyor HEP: Upfront premium and application fee of Rs 11.05 lakhs received by Arunachal Pradesh government from BSS Arunachal Energy Development Pvt. Ltd. (on 10/03/2010)[1]
7. 21 MW Panyor Lepa Middle HEP: Upfront premium nad processing fee of Rs 9.4 lakhs received by Arunachal Pradesh Government from JMD Power Solutions Pvt, New Delhi (on 27/08/2010)
8. 25 MW Papumpam HEP: allotted to: Meena Entrade and Engineering Pvt. Ltd. Naharlagun, AP. on 19/08/2008[2]
9. 15 MW Papum HEP: allotted to Patel Tours and Travels (Mumbai) on Dec 12, 2008
10. 12 MW Poma HEP: allotted to Patel Tours and Travels (Mumbai) on Dec 12, 2008
Hence a credible basin study is required BEFORE any more (including Panyor) projects are considered in Ranganadi-Dikrong basin.
Costly Project Per MW cost of this project will be Rs 10.25 crores according to current estimates. This will be costly affair considering that per MW cost of solar PV project would be lower than this.
Until the above issues are resolved, the project should not be considered for Scoping clearance.
ITANAGAR, July 11:Panchayat leaders of Pistana and Yachuli circles of Lower Subansiri district have voiced their protest against coming up of Panyor Hydro Electric Project, which they claimed was ‘kept secret’ from the public.
In a representation to the Chief Secretary yesterday, the PR leaders led by Zilla Parishad Chairperson Likha Tongum said that Panyor Hydro Electric Project came to light when M/S Raajratna Energy Holdings Private Ltd of Shimla, started surveying and investigation works in the area. They urged the Chief Secretary to cancel the MoA signed with the private company immediately in the interest of local sentiments.
To the surprise of the people of the area, MoA to this regard was already signed between the govt and the company on February 25 last for implementation of the 80 MW project on BOOT basis for which an amount of Rs 80 lakhs (at Rs 1 lakh per MW) as processing fees was already paid in the name of the Secretary Power, Govt of AP. The grass-root leaders alleged that the whole process was carried out secretly and kept under wraps.
They leaders further came down heavily on the agency for “totally undermining the project affected panchayats”.
If any agency wants to tap the natural resources available, they have to take the confidence of at least the local panchayat leaders, which is a normal procedure in a democratic setup, the leaders said.
“The local panchayats are the sole custodian and owner of natural resources in the region since time immemorial,” the leaders said and have decided to protest against the execution of the project.
47 experts and organisations from across the country have written to the Ministry of Environment and Forests, including the Minister Ms. Jayathi Natarajan to include hydel projects between 1-25 MW under the purview of EIA Notification 2006. A similar letter has been sent to the Ministry of New and Renewable Energy and Minister Dr. Farooq Abdulla, to address the impacts of these projects which are governed by the MNRE.
Those who have written include eminent personalities like Former Water Resources Secretary: Dr. Ramaswamy Iyer, Former Ambassador of India: Ms. Madhu Bhaduri, Former Secretary of Power and Principle Advisor to Planning Commission: Dr. EAS Sarma, Former member of MoEF’s Forest Advisory Committee: Dr. Ullas Karanth, Head of IISC’s Centre for Ecological Sciences: Dr. TV Ramachandran, Head of People’s Science Institute: Dr. Ravi Chopra, experts from energy field, as well as activists, fisheries experts, scientists and importantly, representatives from affected communities
Letter sent to MoEF is below:
1. Smt. Jayanthi Natarajan,
Union Minister of State (IC) of Environment and Forests,
Union Ministry of Environment and Forests, New Delhi, vrg.iyer@nic.in
3. Mr. Maninder Singh
Joint Secretary,
Ministry of Environment and Forests, New Delhi, jsicmoef@nic.in
4. Mr. Ajay Tyagi
Joint Secretary,
Union Ministry of Environment and Forests, New Delhi a.tyagi@nic.in
5. Mr. B. B. Barman
Director (IA) River Valley Projects,
Union Ministry of Environment and Forests, New Delhi, bidhu-mef@nic.in
Please include Small Hydel Projects (1-25 MW) under the purview of EIA Notification 2006, considering their serious impacts on ecosystems and communities.
Respected Madam Minister and office bearers of the MoEF,
We want to record our concern about serious impacts of small hydro projects on communities and ecosystems. Several groups from us have written to you in the past to urgently amend the EIA Notification 2006 and to include Small Hydel Projects in its ambit. Looking at the serious impacts of these projects, MoEF could have suo motto taken this initiative. But that has not happened, despite several amendments in the EIA Notification down the years.
SHPs can have and are having severe impacts on communities and ecosystems. This is significant as SHPs are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restrict itself to projects above 25 MW. The local communities are specifically affected as they do not have a platform to voice their concerns.
To highlight some of the impacts of SHPs:
Þ 70 SHPs in Karnataka under scanner following HC orders Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of SHPs on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats[1], bringing at least 70 SHPs under scanner, 40 in Hassan district, the rest in Mandya, Chamarajanagar and Uttara Kannada districts.
Gangani Small Hydro project in Uttarakhand across Yamuna which resulted in loss of lives and property during Uttarakhand floods. Photo: Yamuna Jiye Abhiyan
Þ Karnataka HC no to SHPs in W Ghats In Feb 2013, the Karnataka High Court banned SHPs in Western Ghats[2], following a petition filed by Western Ghats Forum.
Þ Uttarakhand Uttarakhand had earlier cancelled as many as 56 SHPs due to irregularities.
Þ Western Ghats reports Considering the impacts of small hydro projects, the Madhav Gadgil Panel on Western Ghats recommended that in Ecologically sensitive zone 1, only projects below 10 MW with max height of 3 m and not involving forest land be taken up. In ESZ 2, projects upto 25 MW can be taken up only if dam height is below 15 m. This shows the nuanced approach that is required for small hydro projects. The panel also recommended that WGEA should include small hydro projects under EIA notification. Even the Kasturirangan committee has recommended that hydropower projects, including SHPs be allowed only on condition that 30% eflows are released, less than 50% of the river length is destroyed and there is 3 km free flowing river between projects. It has also recommended that hydropower projects, including small hydro projects should required environment clearance in the Ecologically Sensitive Area.
Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
Þ Bhagirathi ESA In the notified Bhagirathi ESA in Uttarakhand, the MoEF itself has implied that Hydro projects only of below 2 MW installed capacity can be taken up.
Þ BWSSB asks for stoppage of SHPs In March 2013, Bangalore Water Supply and Sanitation Board (BWSSB) asked the Karnataka Power Corporation Limited (KPCL) to stop power generation from four mini hydel projects on Cauvery River as it was affecting drinking water supply to Bangalore.[3]
Most Small Hydro projects (1-25 MW) are grid connected, and local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitats and submergence.
Some examples in this regard are given here:
Þ In Himachal, communities have protested strongly against 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests.
Protesst against 4.5 MW Hul project in Himachal/ Photo: Saal Ghati Bachao Samiti
Þ Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely bio-diverse forests, plantations and houses. This is being strongly opposed by local communities.
Þ Greenko’s Perla and Shemburi Projects, Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects with a common dam. In the latter case, villagers assumed that the power canal is actually an irrigation canal for their fields. They only realised that they were alienated from their river after they were banished from approaching the canals.
Blatant violations in 24.75 MW Perla MHP and 24.75 MW Shemburi MHP across Netravathi. The common, huge barrage can be seen for two supposed seperate projects. Photo SANDRP
Þ Maruthi Gen projects, also in Karnataka, were not only clubbed together, but also hid their significant impact on forest land.
Þ Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands. 24.75 MW Thangarabalu SHP on Krishna in Karnataka entails a dam of more than 22 meters in height, but has not divulged any data of submergence to villagers or Forest Department.
Þ 3 MW Beedalli MHP in Karnataka is on the boundary of the Pushpagiri Sanctuary and will severely affect wildlife, but does not envisage eflows release, fish passage or environmental mitigation measures
Þ 15 MW Barapole MHP in Kerala is affecting reserve forests in Karnataka. An earlier such project which was affecting Brahmagiri Sanctuary was opposed and cancelled due to pressure from conservation groups in Karnataka.
Þ String of more than 98 mini hydel projects in various stages of operation, commissioning, construction and planning on the Cauvery in Karnataka has affected elephant corridors and movement.
Þ Many mini hydel projects along the Cauvery in Karnataka are adjoining the Cauvery Wildlife Sanctuary, violating the 10 km buffer zone, while also encroaching on forest land.
The lovely bharachukki falls on Cuavery, also shackeled by many mini hydel projects. Photo: SANDRP
Þ In Himachal Pradesh, several hydel projects have been built on streams that are on ‘negative list for hydel projects’. Fisheries department wanted in-situ conservation of fish in these streams.
Þ The 15 MW Om Power project near Palampur in Himachal Pradesh has caused extensive loss of forest cover and has disrupted irrigation and drinking water supply to downstream areas due to indiscriminate muck dumping.
Þ The 1.5 MW Pakhnoj Nala Power project would impact the flourishing apple economy of 19 villages in Kullu District of Himachal Pradesh by disrupting irrigation supplies. The local people have been strongly opposing the project and the matter is pending in the court.
MoEF and NCDMA: National CDM Authority is under the MoEF and has been giving Host Country Approvals to CDM applications of several small hydel projects. Many of us have been writing to NCDMA and MoEF, providing clear evidence of the sham in CDM applications of projects and their validation reports. But the MoEF has never taken a notice of this. In fact, the MoEF certifies that these projects have positive impact on sustainable development without checking the ground situation, when the impacts of some of these projects on sustainable development are negative.
World over, it is being recognised that impact of small hydel projects is in fact comparable with large hydro projects and hence has to be assessed and mitigated.[4] Countries like Vietnam have cancelled 338 small hydel projects as their assessment indicated that environmental and social impacts of these projects is not commensurate with their benefits.[5]
We would be willing to present the problems from the ground to the MoEF. A holistic and truly sustainable approach can help boost renewable energy development in our country.
We are sure MoEF is committed to protecting environmental impacts, irrespective of the installed capacities of projects and will amend the EIA Notification to this effect urgently. Till such a credible regulatory system is in place, we request the MoEF to stop providing Host Country Approvals to Small Hydel Projects.
Some links and additional information related small hydro projects and their impacts can be found at:
Dr. Ullas Karanth, Former member, Forest Advisory Committee, MoEF, Director for Science-AsiaWildlife Conservation Society and Director, Centre for Wildlife Studies, ukaranth@gmail.com
Dr. Ravi Chopra, Director, People’s Science Institute, Dehra Doon, Uttarakhand, psiddoon@gmail.com
Dr. T.V. Ramachandra, Head, Energy & Wetlands Research Group, Centre for Ecological Sciences, Indian Institute of Sciences, Bangalore
Dr. Bijukumar, Associate Professor and Head, Dept. of Aquatic Biology & Fisheries University of Kerala, Thiruvananthapuram 695 581, Kerala, abiju@rediffmail.com/ bijupuzhayoram@gmail.com
Letters have been sent by some eminent citizens and activists of Gujarat to the Union Ministry of Environment and Forests and Gujarat Environment Impact Assessment Authority that the massive Gujarat Project of setting up world’s tallest statue is being taken up by the Gujarat government without social or environmental impact assessment, without necessary public consultation process and without clearance under the Environment Protection Act 1986, Environment Impact Assessment of 2006 and also wildlife protection Act of 1972. The necessary permission from the Environment and Rehabilitation Subgroups of the Narmada Control Authority has also not been taken, nor have the party states been taken into account. The Tourism project involves massive constructions in the middle of the eco-sensitive river, just 3.2 km downstream from the Sardar Sarovar Dam and Shoolpaneshwar Sanctuary. Given below is the letter to sent to the Union Minister of State (Independent Charge) Mrs Jayanti Natarajan and secretary, Union Ministry of Environment and Forests. Similar letter has gone to Secretary, Union Ministry of Water Resources since he is the ex-officio chairman of the Narmada Control Authority. Another letter has gone to the Gujarat state EIA authority and concerned state government agencies.
Considering the importance of this issue, SANDRP is happy to share it on our blog, SANDRP Coordinator is also a signatory to the letter.
7 November 2013
To,
Dr V. Rajagopalan
The Secretary
Ministry of Environment & Forests
Government of India
Paryavaran Bhavan, CGO Complex, Lodhi Road,
New Delhi – 110 003.
Sub: To seek detailed environmental scrutiny of project called ‘Statue of Unity’ planned inside Narmada River, 3.2 Kms. downstream of Sardar Sarovar Dam and Shoolpaneshwar Sanctuary by a joint venture of Government of Gujarat and a trust – ‘Sardar Vallabhbhai Patel Rashtriya Ekta Trust’ (SVPRET) and to immediately stop all construction activity in the region.
Dear Sir,
We would like to bring to your attention that work on a project that proposes to build the world’s largest statue in the form of ‘Statue of Unity’ near Sardar Sarovar Dam in the river downstream from the dam, just 3.2 km from the Shoolpaneshwar Sanctuary, in eco-sensitive zone and involving massive infrastructure (see annexure) has started work without legally mandatory environment clearance, environment and social impact assessment or any public consultation process.
This is clearly illegal, in violation of the Environment Protection Act, 1986 and EIA notification of September 2006 and a number of NGT and Court orders about such massive kind of construction on the riverbed. On 31 October 2013, the foundation stone was laid for the project amidst huge fanfare and media attention. Tenders have also been floated. Even the work for the Garudeshwar weir, proposed about 12 km downstream of the Sardar Sarovar Dam, began without any social or environmental impact assessment, public consultation and environmental clearance from the Environmental Sub Group (ESG) of Narmada Control Authority’s (NCA).
The website http://www.statueofunity.in/ clearly state the purpose of tourism and involvement of the ‘Sardar Vallabhbhai Patel Rashtriya Ekta Trust’ (SVPRET) to build ‘Statue of Unity’, 3.2 km downstream of the Sardar Sarovar Dam inside the Narmada River on an islet called Sadhu bet.
“A 13km. long water body (pond) will create an excellent tourist spot with available infrastructure on both the banks.
The Statue of Unity is planned to be erected in the river bed on downstream of the main dam in the Garudeshwar Weir pond. A permanent standing water pool in and around the Statue of Unity will be created by Garudeshwar Weir, which will enable boating activity around the statue.” (Emphasis added.)
The estimated cost of the project is more than Rs. 2,500/- corers (Rs 2063 crores is the cost of “DESIGN, ENGINEERING, PROCUREMENT CONSTRUCTION, OPERATION AND MAINTENANCE OF THE STATUE OF UNITY D/S of Sardar Sarovar Dam, Village Kevadia Ta. Nandod, District of Narmada Gujarat State, India” as per tender notice, see: http://www.statueofunity.in/tendernotice.html). The Government of Gujarat website (http://www.statueofunity.in/) clearly state that “A monument, that will not just be a mute memorial like the rest, but a fully functional, purpose-serving tribute that will boost tourism and facilitate development in the surrounding tribal areas” and will involve huge infrastructure as described in the Annexure downloaded from the official website.
The key issues that beg immediate scrutiny is as follows:
(1) The project clearly needs environment clearance under the EIA notification of September 2006, but has not applied for or obtained the clearance at any stage.
(2) The Shoolpaneshwar Sanctuary boundary is touching the Sardar Sarovar Reservoir (as a part of the Environmental Protection measures of the Sardar Sarovar Project, the earlier Dhumkal Sloth Bear Sanctuary was extended to meet the reservoir boundaries and is called Shoolpaneshwar Sanctuary.) Since the statute is only 3.2 kms from the Sardar Sarovar Dam, it is certainly near by Shoolpaneshwar Sanctuary.
(3) The Project involves construction in the river bed and proposed reservoir, close to sanctuary in eco-sensitive zone, and hence will have serious impacts on the ecology and environment. Hence, and EIA and EC is crucial.
(4) The project will affect the downstream river, its biodiversity, people and livelihoods and other related aspects.
(5) A comprehensive assessment of the environmental and social impacts of the ‘Statue of Unity’ and its contribution to the cumulative impact of all the projects and activities in the area has not been done.
(6) The project also needs public consultation, but none has happened so far.
(7) During the construction of the Sardar Sarovar dam due to hard rock digging, the seismic area already carries the burden of artificial activity in the bed rock and added load in what is deemed geologically fault line area. Public reports on geotechnical and geological studies on the proposed site have raised issues of structural stability as well as safety. This cannot be taken casually by authorities. The seismic hazard analysis claimed to have been done by the Gujarat Government’s in-house “Institute of Seismological Research” (http://www.statueofunity.in/execution.html#sthash.jEBrofSN.dpuf) or the Geological and Geotechnical investigation commissioned to another government institute WAPCOS cannot be considered credible unless peer reviewed and put in public domain.
In view of the above facts on record, we demand that:
Direct the Government of Gujarat to submit application for environment clearance and till that is obtained, not to do any work related to the project.
Direct the Government of Gujarat to immediately stop planned project called ‘Statue of Unity’ and direct them to stop all other activities related to the ‘Statue of Unity’.
Declare the action – of the foundation stone installation on 31 October 2013 for the project called ‘Statue of Unity’ – of the Chief Minister of Gujarat State as illegal, in violation of the EIA notification of September 2006 and the Environment Protection Act, 1986.
We will look forward to your urgent action and also point wise response.
Stepping UP TO BUILD HIGH. Stepping ahead to THE FUTURE.
The Statue of Unity will be a naturalistic and historically accurate representation of Sardar wearing characteristic garments in a walking pose.
The rich bronze cladding on the Statue gives it a marvelous look
World’s fastest elevators to keep the visitor’s tour engaging
The public three-level base of the Statue – exhibit floor, mezzanine and roof – contains the Memorial Garden and a large continuous exhibit hall that will be developed as a visitor attraction focusing on the contributions of Sardar Vallabhbhai Patel
The observation deck at 500ft can accommodate 200 people at a time. The panoramic view from this level will enable visitors to see the beautiful Satpuda & Vindhyachal mountain ranges, the 256kms long Sardar Sarovar Reservoir and the 12kms long Garudeshwar Reservoir
Access to the statue is via boat ride (3.5kms)
An elaborate Gallery for a massive panoramic view of the World’s largest irrigation dam, the river and the hilly terrain, and an illustrious sight of Arabian Sea
A state-of-the-art Underwater Aquarium
A large modern canopied public plaza, overlooking the river and the Statue, will have scrumptious food stalls, ornate gift shops, retail kiosks and other visitor amenities
The project would include:
Museum & Audio Visual Gallery:
The Statue of Unity Project will also include a unique museum and audio-visual department depicting the life and times of Sardar Vallabhbai Patel.
A Laser, Light and Sound show:
A Laser, Light and Sound show on the efforts of Unification of India.
Research Centre:
A research centre dedicated to the research and development of subjects close to Sardar Vallabhbhai Patel’s heart like Good Governance and Agriculture Development. Here, subjects like Water Management and Tribal Development will also be studied and researched.
A Monumental Lift:
A heavy-load open lift with a panoramic view will be built alongside the Statue of Unity. Visitors will be able to rise up to the height of the structure’s head, walk into a viewing gallery and enjoy a panoramic view of the Sardar Sarovar Nigam project and the surrounding region from an astounding height of close to 400ft.
Hospitality & Entertainment:
Refreshment areas like restaurants and recreational spots to make the project area an attractive tourist spot, thus facilitating tourism and employment for the surrounding tribal region.
Ferry Services :
The statue and surrounding area will be accessed by special boats to avoid vehicular traffic and pollution
Sardar Patel brought the nation together and this tribute, the Statue of Unity, will bring the country national pride. Plans will be laid for convention and training centres, development and formulation of tourism plan and provision of technical and managerial assistance for bids to invite EPC contract.
The project site will be connected with modern connectivity infrastructure such as expressways, improved rail system and helipads
Through scientific area planning, clean industries will be located around the project site
Research facilities in the area of biotechnology, clean energy and ethnic crafts will generate white collar jobs in this area
Location and development of educational institutions in the areas of agriculture, animal husbandry, pisciculture will generate an educational and skill development complex to support economic activity in the region
Development of tourism infrastructure to support MICE – Meetings, Incentives, Conferences and Exhibitions; which will generate huge livelihood opportunities for the local tribal population
Ministry of New and Renewable Energy (MNRE), Government of India recently published a report on ‘Developmental Impacts and Sustainable Governance Aspects of Renewable Energy Projects’. Around the same time, Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of Small Hydro Projects (SHPs) on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats[i]. SHPs are hydel projects between 2 MW-25 MW installed capacity. Looking at the unaddressed impacts of SHPs, such a report by MNRE was sorely needed and was looked at as a welcome initiative.
Unfortunately, the MNRE Report has entirely excluded the small hydel sector from its assessment.
Agitation against 4.5 MW Hul HEP in Himachal Pradesh as it is affecting forests, irrigation channels, mills and drinking water sources of villagers. Source: Sal Ghati Bachao Andolan
SHPs can have and are having severe impacts on communities and ecosystems. They fall under the MNRE and are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restricts itself to projects above 25 MW. They get subsidies, tax rebates, tax holidays from the MNRE, apart from other benefits and preferential tariffs from states. Most of the SHP sector is crowded with private investors, wanting to make a quick buck from rivers, without any regulations. The rush is most prominent in Uttarakhand, Himachal Pradesh, Karnataka, Odisha and now Kerala, where cascades of such dams are coming across pristine rivers.
Despite MNRE’s supposed intention, most SHPs are not supplying electricity to any “remote and inaccessible areas”.[ii] Most projects are grid connected, so the local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitat loss, submergence and fraudulent practices.
Following a petition from Western Ghats Forum, Karnataka High Court has ordered a ban on SHPs in Western Ghats, Uttarakhand High Court had cancelled as many as 56 SHPs. In Himachal, communities fought a long and lonely struggle against the 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests. [iii]Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely biodiverse forests, plantations and houses.[iv] Greenko’s Perla and Shemburi Projects[v], Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects on the same river with a common dam. Maruthi Gen projects, also in Karnataka were not only clubbed together, but also hid their significant impact on forest land[vi] . Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands.
The issues are serious and have been raised by many. As the projects are outside the purview of EIA Notification, none of their impacts are studied; neither do the communities get a platform to record their protests. Hence, a study on the environmental impacts of renewable energy projects was needed to address these issues.
Considering these serious aspects, it is very surprising that MNRE Report on impacts of Renewable Energy projects has chosen not to look at this sector at all. The report does not assess impacts of any such projects, neither does it offer any recommendations for this sector under MNRE. It only makes a sketchy study of wind and solar energy projects. The report makes incorrect statements like: “All hydroelectric power projects have to get environmental clearances which under two categories: category B if capacity of projects is between 50 to 25 MW”, effectively refusing to acknowledge hundreds of SHPs, under the purview of MNRE not requiring any environmental regulation.It states incorrect facts like “There are institutions and processes governing every operational aspect of RE project development and local institutions, in the form of democratic bodies, to safeguard micro level ecological and social concerns.” This is patently untrue for SHPs, which are highly unregulated and non-participatory.
The TORs of the study stress assessment of impacts of solar and wind projects, but do not exclude hydel projects. While TORs should have stressed on impacts of SHPs, looking at the number of protests and inherent problems, that does not warrant report writers’ complete neglect of this sector. Executive Summary states that this study has been done in response to WGEEP and HLWG report recommendations. Despite the fact that WGEEP specifically banned SHPs in Ecologically Sensitive Zone I, this report has chosen to turn a Nelson’s eye to the sector.
Even with regards to solar and wind projects, the report seems inadequate. For primary data, the authors visited 6 wind energy farms and 1 solar energy site. At the solar energy site, interaction was exclusively with project management and engineers. Social and environmental impacts cannot be understood through interviews with project management alone. While the report documents the devastation around wind energy farms in Maharashtra, it is not reflected in conclusions and recommendations.
The report is entirely silent on Clean Development Mechanism applications of SHPs, which are routinely full of lies and incorrect information. CDM credits give project additional pocketable profits, while the affected communities get only unaddressed impacts. Considering the forest land submerged by Small hydel Projects, and their impacts on adaptation and mitigation potential of local communities, they are also problematic from perspective of climate change.
The report ends with unacceptable conclusions and recommendations, most surprising being: “The RE project development is regulated by environmental and social governance system. The current regulatory mechanism is strong… No new changes are required in the legal framework or the governance structure to mitigate environmental and social impacts.” It even pushes for a “fast channel for quick clearances”.
The report says that environmental impacts of RE projects “are not significant” and social impacts of are “not negative”. Report writers need to visit SHPs in Himachal, Uttarakhand and Karnataka where people have lost irrigation channels, water mills, plantations and even lives, when sudden water was released from projects like Perla-Shemburi in Bantwal[vii], Karnataka.
Sweeping conclusions and recommendations for the entire RE sector is highly problematic, especially when there are several examples of unaddressed impacts, which depend on specific site and project.
The report does include some welcome recommendations. These include: siting policy for projects including zonation and increased participation of local communities in planning and decision making about natural resources, affected by the projects. It recommends issuing clear guidelines such that community welfare is not compromised due to RE projects and about proponent’s responsibilities in the zone of influence of the RE project. The report recommends zonation of projects in go-green (no objection), go slow and no go areas for RE project development. These need to be implemented by the MNRE. If the report would have looked at the entire RE sector, it could have made some valuable observations and recommendations.
There is a very urgent need to bring projects between 1 – 25 MW under the purview of EIA Notification 2006. Several representations and evidences later, it is clear that MoEF does not have the will to do so. It was expected that MNRE will raise these issues, but if this report is an indication, MNRE too is not willing to accept the challenges of SHP development, or regulating the impacts.
Lower installed capacity does not always mean lower social or environmental impacts. Targeted efforts are needed to assess, address and mitigate impacts. For this, the first step will be to acknowledge impacts, not brush them under the carpet. World over, impacts of small hydro projects are being highlighted.
As India is looking at expanding its renewable energy sector, it needs to be truly sustainable and clean, not just an assumption. Hence, MNRE’s effort at addressing environmental and social impacts of renewable energy projects is a welcome move. But by refusing to acknowledge the impacts of Small Hydel Projects in its report, MNRE reminds one of Nero, playing his fiddle, when the forests around are being submerged or destroyed in the name of clean energy.
SANDRP 
