Chenab · Indus · Pakistan

India Pakistan resume talks on Indus Treaty: Stakes are high

When on March 20-21, 2017, on the eve of World Water Day, India and Pakistan’s Permanent Indus Commission met in Islamabad for its 113rd meeting, there was a lot at stake besides the immediate issue or even the Indus Treaty.

In many ways, the Indus Treaty remains a bright spot in relations between these two neighbors and the treaty keeps bringing them back to the talking table…This is the magic of a shared river! Continue reading “India Pakistan resume talks on Indus Treaty: Stakes are high”

Bhagirath Prayas Samman · Chenab · Dams · Himachal Pradesh · Hydropower · Sutlej

Bhagirath Prayas Samman: Himdhara Collective: Relentless Questioning and Doing

When I talk with Manshi, a friend and co-traveler from Himdhara Collective about Bhagirathh Prayas Samman that the collective received during the India Rivers Week 2016, she is modest, even slightly hesitant. She simply says, “We love the mountains, we want to protect them and help mountain communities fight the unequal battle against unplanned hydropower. That is one motivation of our work. But the other is recognition of the fact that we are privileged… privileged to be able to speak English, to work on a computer, to understand the bureaucratic procedures that alienate a tribal or forest dweller from her land. That understanding also drives us.”

Citation of Bhagirath Prayas Samman given to Himdhara Collective states: Himdhara’s strength is its engagement with communities, movements and organisations. It has created an effective discourse around issues of resource distribution and their ownership and the resultant impacts on ecological spaces of mountain communities, especially vulnerable groups like indigenous people, dalits and women. It is an honor to recognize and celebrate Himdhara Environment Research and Action Collective’s extraordinary Bhagirath efforts in maintaining the integrity of rivers in Himachal Pradesh.”

In their own words, “Himdhara is an autnomous and informal non registered environment research and action collective, extending solidarity and support, in research and action, to people and organisations asserting their rights over their natural resources and agitating against corporatisation of these resources for destructive development in the state.”

IMG_9726
Face of Hydropower in Kinnaur Photo: Himdhara

A collective of young, passionate and questioning minds, Himdhara has been working with communities in far flung areas of Himachal Pradesh include Lahaul and Spiti and Kinnaur in their fight against the onslaught of ill-planned and bumper to bumper hydropower projects in Himachal, amongst other issues. Continue reading “Bhagirath Prayas Samman: Himdhara Collective: Relentless Questioning and Doing”

Chenab · Jammu and Kashmir

Open Letter to J&KSPCB: Cancel Public Hearings for Sawalkote HEP for violations

Above: Title page of Sawalkote EIA Executive Summary

January 14, 2016

TO:

J&K State Pollution Control Board,

Parivesh Bhawan, Forest Complex, Gladni, Narwal, transport Nagar,

Jammu (J&K) Telephone Nos:- 0191-2476925, 2476927

  1. Sh. Abdul Razak, IFS

Chairman, J&K State Pollution Control Board, Mob:- +91-9419188852, chairman87jkspcb@gmail.com

  1. Sh. Vasu Yadav, IFS

Member Secretary, J&K State Pollution Control Board, Mob:- 0194-2311165, membersecretaryjkspcb@gmail.com

  1. Regional Director, Jammu,

J&K State Pollution Control Board, Jammu. Email:  regionaldirectorspcbjmu@gmail.com

Sub: Violations in public hearing for 1856 MW Sawalkote HEP

in Ramban, Udhampur and Reasi districts in J&K

Respected Chairman, Member Secretary and Regional Director,

We understand from J&K SPCB website that the pubic hearings for the proposed 1856 MW Sawalkote Hydropower project is to be held in Udhampur (Village Panchari), Reasi (Village Mahore) and Ramban (Village Tanger) districts at 10 am on January 18, 21 and 28, 2016 respectively. However, we notice a number of problems in this context, some of the key ones include: Continue reading “Open Letter to J&KSPCB: Cancel Public Hearings for Sawalkote HEP for violations”

Chenab · Floods · Jammu and Kashmir

Why does Central Water Commission have no flood forecasting for Jammu & Kashmir? Why this neglect by Central Government?

During Sept 4-6, 2014 Jammu and Kashmir in North India is facing one of the worst floods. NDTV[1] has reported that these are the worst floods in 60 years (The Times of India reported that this was worst flood of the state since independence based on number of casualties.). More than 160 people have died and some 2500 villages are affected (1615 in the valley, rest in Jammu), out of which 450 are completely submerged (390 in valley)[2]. Over 10 000 people are stranded across the state. The flood has affected almost all 10 districts in the Jammu region. J&K Chief Minister admitted that the rescuers have yet to reach the worst affected South Kashmir region. Jammu Srinagar Highway has remained blocked for over three days. Several rivers have been flowing above the danger mark and most parts of south Kashmir, including Pulwama, Anantnag and Kulgam districts have been submerged. Jhelum was flowing at 30.7 ft in South Kashmir, 7 ft above the danger mark. Chenab river was also flowing above the danger mark at several places.

 

Authorities have declared the bridge over the Chenab in Akhnoor unsafe for traffic. Source: Vinay Saraf's facebook post
Authorities have declared the bridge over the Chenab in Akhnoor unsafe for traffic. Source: Vinay Saraf’s facebook post

Unprecedented floods Landslides triggered by heavy rainfall have damaged roads, dozens of bridges, buildings and crops. As many as 40 people went missing after a landslide in Thanamandi area of Rajouri district in Jammu region. Heavy rain in the catchment areas of Jhelum river has so far submerged more than 100 villages in the south Kashmir districts of Anantnag, Kulgam, Shopian, Pulwama, where the river was still rising, as well as the north Kashmir districts of Ganderbal, Srinagar and Badgam[3]. The flood has surpassed the 1992 memories and revived the 1959 flood memories[4].

Flood Forecast map of CWC has no sites to forecast floods in J & K
Flood Forecast map of CWC has no sites to forecast floods in J & K

Vehicular traffic has been stopped on the Jammu-Pathankot highway due to incessant rain. Jammu is on red alert and Tawi bridge is also in danger.

Flood image from Vinay Saraf's Facebook post
Flood image from Vinay Saraf’s Facebook post

State Finance Minister Abdul Rahim Rather said Chenab was flowing at 38 ft at Akhnoor which is four ft above the danger mark cumulatively discharging 2.75 lakh cusecs, a quantum of discharge which equals all other rivers of the state.

The situation is very grim indeed: “According to the Army, the situation in the state is as grim as it was in Uttarakhand last year.” Union Home Minister has visited the state and the prime minister has expressed grief.

VERY HEAVY Rainfall during Sept 3-6 The state received massive 250 mm of rainfall in just three days between Sept 3-4, out of its seasonal monsoon rainfall of 568 mm till Sept 6, 2014. Rainfall just on Sept 6 was 106 mm, which is unbelievable 3116% of the normal rainfall for that date for J&K.

Rainfall Map from IMD showing that J&K received 558 mm rainfall till Sept 6, progressing to excess rainfall category in three days from deficit category on Sept 3, see the next map below
Rainfall Map from IMD showing that J&K received 558 mm rainfall till Sept 6, progressing to excess rainfall category in three days from deficit category on Sept 3, see the next map below

It can be seen from the season rainfall map see above of India Meteorology Department as on Sept 6, 2014 that J&K had received 558 mm rainfall till that date, progressing to Excess Rainfall category (blue colour code) from Deficit season rainfall of 308 mm as on Sept 3, 2014 (see IMD map below), in just three days.

IMD Map of Sept 3, 2014, showing J&K in deficit rainfall category (brown colour) with seasonal rainfall of 308 mm
IMD Map of Sept 3, 2014, showing J&K in deficit rainfall category (brown colour) with seasonal rainfall of 308 mm

CWC has no flood forecasts for J&K However, shockingly, India’s premier water resources body, Central Water Commission, responsible for flood forecasting and providing advisory to the states for tackling floods, has no flood forecast for any place in the state. The CWC’s flood forecast list[5] on Sept 6, 2014 has 18 level forecasts and 8 inflow forecasts, but NONE from J&K. CWC’s Flood forecast site has another option[6] that provides hydrographs for various rivers and location. Again for J&K it provides NO hydrographs. The options on CWC’s Flood Forecast site for list based selection[7] and map based selection[8] again has no information about Jammu & Kashmir.

J&K Flood Control Chief Engineer called the situation Alarming. Photo Source - NNIS
J&K Flood Control Chief Engineer called the situation Alarming. Photo Source – NNIS

This seems like shocking omission on the part of CWC, which functions under Union Ministry of Water Resources and reminds one that CWC completely failed to provide any flood forecast when Uttarakhand faced its worst floods in June 2013[9]. We hope CWC will urgently include the flood vulnerable sites of J&K in its flood forecasting and also explain to the people of J&K and rest of the country why these sites were not included so far.

Akhnoor flood image from Vinay Saraf's Facebook post
Akhnoor flood image from Vinay Saraf’s Facebook post

Mismanaged hydro projects increase the damage In this context, media has reported[10] that Dulhasti Hydropower project on Chenab river decided to open its flood gates DURING the worst flood period, which lead to further increase in flood levels in the downstream areas: “Release of water by NHPC dam is expected to increase the levels of the Chenab massively between Kishtwar and Ramban. Surged level can lead to submergence of the highway.” Such additional floods could have been avoided if the gates were kept opened in anticipation of floods. Such opening of gates during the floods can lead to catastrophic consequences for the downstream areas as happened in case of Srinagar Hydropower project in Uttarakhand in June 2013.

Kids crossing flooded bridge in flood hit J&K Photo Sources - NNIS
Kids crossing flooded bridge in flood hit J&K Photo Sources – NNIS

MoEF’s wrong decisions The Union Ministry of Environment and Forests have been clearing hydropower projects in the Chenab basin even without proper social and environment impact assessment as was evident in case of Sach Khas project most recently. As SANDRP pointed out in a submission to the Expert Appraisal Committee[11], the EIA and public hearing process of the Sach Khas HEP has been fundamentally inadequate and flawed and yet without even acknowledging the issues raised in this submission the EAC has recommended approval of the project. This is bound to be legally untenable decision. Such decisions by the EAC and MoEF are likely to add to the disaster potential in Chanab and other basins in J&K. There is also no cumulative impact assessment of such massive number of big hydropower projects any basins of J&K.

It is well known, as witnessed in case of Uttarakhand in 2013, that hydropower projects hugely add to the disaster potential of the vulnerable areas. We hope the J&K and central governments make this assessment on urgent basis and we hope the apex court does not have to intervene for such assessment as the Supreme Court had to do through its order of Aug 13, 2013 in case of Uttarakhand.

SANDRP

POST SCRIPT: This is one possible fall out of this, also flashed by several newspaper and following CWC questioned by media: http://www.cwc.nic.in/main/webpages/Flood%20Forecasting%20in%20uncovered%20Himalayan%20and%20interstate%20inflow%20forecasting%2011092014.pdf

Stumbled upon this on January 14, 2015. Hope the government will be now implementing this.

END NOTES:

[1] http://www.ndtv.com/article/cheat-sheet/over-100-dead-as-jammu-and-kashmir-witnesses-worst-floods-in-50-years-587572?pfrom=home-lateststories

[2] http://www.thekashmirwalla.com/2014/09/death-toll-160-jammu-kashmir-facing-worst-flood-60-years/

[3] http://www.kashmirdispatch.com/headlines/050926328-thousands-flee-homes-in-flood-ravaged-jammu-and-kashmir.htm

[4] For pictures of what people are going through, see: http://www.thekashmirwalla.com/2014/09/pictures-deadly-floods-hit-kashmir/

[5] http://180.92.171.80/ffs/current-flood-forecast/

[6] http://180.92.171.80/ffs/hydrograph/

[7] http://180.92.171.80/ffs/data-flow-list-based/

[8] http://www.india-water.gov.in/eSWIS-MapViewer/

[9] https://sandrp.wordpress.com/2013/06/25/central-water-commissions-flood-forecasting-pathetic-performance-in-uttarkhand-disaster/

[10] http://www.kashmirlife.net/kashmir-flooded-chenab-may-witness-upsurge-as-dulhasti-gates-being-opened-65126/

[11] https://sandrp.wordpress.com/2014/08/19/sach-khas-hydro-project-in-chenab-basin-another-example-of-wapcoss-shoddy-eia/

[12] http://www.hindustantimes.com/india-news/flood-situation-in-jammu-worsens-toll-mounts-to-100/article1-1260718.aspx

Chenab · Cumulative Impact Assessment · Environment Impact Assessment · Expert Appraisal Committee · Himachal Pradesh · Hydropeaking · Hydropower · Ministry of Environment and Forests

Sach Khas Hydro project in Chenab Basin: Another example of WAPCOS’s shoddy EIA

Even after multiple appeals by various experts, organizations and local people, Expert Appraisal Committee (EAC) set up by Ministry of Environment & Forest (MoEF) has once again chosen to ignore alarms of changing climate such as disaster of Uttarakhand in 2013 and has continued to consider Hydro Power Projects on Chenab Basin for Environmental Clearance (EC) before the Cumulative Impact Assessment of Chenab Basin has been accepted by MoEF. While on one hand the State Government of Himachal Pradesh has promptly appointed a committee headed by Chief Secretary to supervise and monitor all the progress and to “sort out” problems of getting various clearances “without delay in single window system”[i], on the other hand overall transparency of the Environmental Clearance Process has been steadily decreasing.

Sach Khas HEP (260 + 7 MW) (located in Chamba District of Himachal Pradesh) was considered by EAC in its 76th meeting held on August 11, 2014. Even though the project was considered for EC, no documents were uploaded on the website. Website does not even list the project under “Awaiting EC” category. This is in clear violation with MoEF norms, basic norms of transparency and Central Information Commission (CIC) orders. There are no fixed guidelines for documents to the uploaded, the time by when they should be uploaded and rules that project cannot be considered if the documents are not uploaded.

SANDRP recently sent a detailed submission to EAC pointing out several irregularities of the project. The comments were based on reading of the Environmental Impact Assessment (EIA) report available on the HP Pollution Control Board Website (which cannot be substitute for putting up the documents on EAC website). Environmental Management Plan (EMP) of the project is not accessible at all! Non availability of EMP on the HP Pollution Control Board website too is a violation of EIA notification 2006.

The EIA report which is prepared by WAPCOS is another example of a poorly conducted EIA with generic impact prediction and no detailed assessment or quantification of the impacts. Moreover since EMP is not available in the public domain, there is no way to assess how effectively the impacts have been translated into mitigation measures. Violations of Terms of Reference (TOR) issued by EAC at the time of scoping clearance is a serious concern.

Project Profile

Sach Khas HEP is a Dam-toe powerhouse scheme. The project has a Concrete Dam & Spillway with Gross storage of 25.24 MCM, Live Storage of 8.69 MCM and Reservoir Stretch at FRL of 8.2 km (approx.) Three intakes each leading to 5.8m diameter penstocks are planned to be located on three of the right bank non-overflow blocks. Three penstocks offtaking from the intakes are proposed to direct the flows to an underground powerhouse on the right bank of the Chenab river housing 3 units of 86.67 MW turbines with a total installed capacity of 260 MW. The project also proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project.

Sach Khas Dam Site

Sach Khas Hydro Electric Project was considered before completion of Cumulative Impact Assessment of Chenab Basin

Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[i]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K). 49 of these projects are planned or under construction in Chenab in HP and of which 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[ii]. MoEF sanctioned TORs for Cumulative Impact Assessment (CIA) of the HEPs on Chenab in HP in February 2012 however the project specific ECs were delinked from the CIAs[iii].

MoEFs Office Memorandum dated May 28 2013 states, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.”

We had pointed out in our submission against Kiru & Kwar projects in Jammu & Kashmir that CIA of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the Chenab River basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Looking at the fragility of the Himalayan ecosystem, considering any hydropower project in the basin without these studies will be an invitation to disaster[iv]. This fact has been repeatedly highlighted by multiple organizations and experts including SANDRP.

Sach Khas EIA Study: Gross violation of TOR

The EIA violates several stipulations of TOR issued on Feb 22, 2013, which also included the stipulations of EAC in Sept 2012 and Nov 2012 meetings where the project TOR was considered and also Annexure attached with the TOR. This has severely affected the overall quality of the EIA report.

About assessing the impacts of the project on wild life the TOR said: “Reaching conclusion about the absence of such (Rare, Endangered & Threatened) species in the study area, based on such (conventional sampling) methodology is misleading” as such “species are usually secretive in behavior”, “species specific methodologies should be adopted to ascertain their presence in the study area”, “If the need be, modern methods like camera trapping can be resorted to”. None of this is shown to be done in any credible way in EIA.

TOR also recommends intense study of available fish species in the river particularly during summer (lean) months with help of experimental fishing with the help of different types of cast and grill nets. There is no evidence in EIA of any such intensive efforts detailed here. In fact the field survey in summer moths was done in May June 2010, years before the EAC stipulation.

TOR (EAC minutes of Sept 2012) state “Chenab river in this stretch has good fish species diversity & their sustenance has to be studied by a reputed institute.” This is entirely missing. TOR (EAC minutes of Sept 2012) states “During the day, the adequacy of this discharge (12 cumecs) from aquatic biodiversity consideration needs to be substantiated”. This again is missing. TOR said 10 MW secondary station may be a more desirable option. This is not even assessed. TOR said Impacts of abrupt peaking need to be assessed. This is also not done. Site specific E-Flow studies and peaking studies stipulated by TOR are missing. TOR states that Public Hearing / consultations should be addressed & incorporated in the EIA-EMP. However there is no evidence of this in the report.

TOR also required following to be included in EIA, but many of them found to be missing: L section of ALL upstream, downstream projects; Project layout showing all components with A-3 scale of clarity and 1: 50000 scale; drainage pattern map of river upto project; critically degraded areas delineated; Demarcation of snowfed/ rainfed areas; different riverine habitats like rapids, pools, side pools, variations, etc;

Contradictions in basic project parameters

The EIA report provides contradictions in even in basic parameters of the project components: So section 2.1 on page 2.1 says, “The envisaged tail water level upstream of the Saichu Nala confluence is 2150 m.” This i s when the TWL is supposed to 2149 m as per diagram on next page from the EIA. Section 2.3 says: “River bed elevation at the proposed dam axis is 2145m.” At the same time, the tail water level is 2149 m. How can Tail water level of hydropower project be higher than the river bed level at the dam site? This means that the project is occupying the river elevation beyond what HPPCL has allocated to it. Page 23 of EIA says: “…the centerline of the machines in the powerhouse is proposed at 2138.00m…” So the Centre line o the power house is full 11 m BELOW the tail water level of 2149 m? How will the water from power house CLIMB 11 m to reach TWL level?

EIA report unacceptable on many fronts

Dam ht of 70 m was stated in TOR, however the report states it to be 74 from river bed. The submergence area, consequently has gone up from 70 ha at TOR stage to 82.16 ha, as mentioned in Table 2.2 of EIA. Total land requirement which was 102.48 ha as per TOR ha has now increased to 125.62 ha, with forest land requirement going up to 118.22 ha. This is a significant departure from TOR that should be requiring fresh scoping clearance. Part of the field study has been done for the project more than four years ago and rest too more than three years ago. There are not details as to exactly what was done in field study. EAC had noted in their meeting in Sept 2012, while considering fresh scoping clearance for the project, “EIA and EMP should be carried out afresh keeping in view the drastic changes in the features due to increase in installed capacity of the power house.” (Emphasis added.) The EIA report is thus unacceptable on multiple fronts.

No cognizance of Cumulative Impacts

CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.

On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.

The project is located between Purthi HEP upstream and Duggar HEP downstream. Elevation difference between TWL of Purthi (2220m) and FRL of Sach Khas (2219m) is barely 1 m. The horizontal distance between them is as less as 117m. This is clearly unacceptable and in violation of the minimalist EAC-MoEF norms.

Elevation difference between TWL of Sach Khas (2149m) and the FRL of Duggar (2105 m) is 44 m and the horizontal distance is 6 km. This is thus a cascade of three among many other projects in the basin.

Cascade of three projects

Purthi HEP Site

Dugar HEP Site

Even so the report does not even mention the other two projects. EIA study is project specific and no cumulative impacts are assessed along with the other two projects. The EIA does not provide a list of all the HEP projects taken up in the Chenab basin in HP state[i]. The MoEF sanctioned TORs for conducting Cumulative Impact Assessment (CIA) of Chenab In February 2012. EAC considering any further project in Chenab basin before completion of the CIA study of the basin by a credible agency (not WAPCOS) and finalised in a participatory way will be in violation of the MoEF order of May 2013.

EIA report completely misses out on the detailed analysis of cumulative impacts in terms of disaster potential of the area and how the project will increase that; impacts on flora, fauna, carrying capacity, livelihoods; cumulative downstream impact, cumulative impact of hydro peaking. impacts on springs and drainage pattern; impacts of forest diversion on environment, hydrology and society and implementation of the Forest Rights Act; changing silt flow pattern in different phases, impacts of mining, tunneling, blasting etc. Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change has not been assessed. Project makes no assessment of impact of climate change on the project even when over 60% of the catchment area of the project is snow-fed and glacier fed. Options assessment in terms of non dam options as required under EIA manual and National Water Policy are missing.

Generic impact prediction

Impact prediction is too generic with no detailed assessment, which is what EIA is supposed to do. Impacts have not been quantified at all. The EIA report merely states the likely impacts in 2 or 3 sentences. Several important impacts have gone missing. None of the serious impacts have been quantified. For an informed decision making and effective mitigation and EMP quantification of impacts is essentially a pre requisite. Following are some such incidences:

Impacts of blasting & tunneling: TOR for the impacts on “Socio-economic aspects” says, “Impacts of Blasting activity during project construction which generally destabilize the land mass and leads to landslides, damage to properties and drying up of natural springs and cause noise pollution will be studied.”(p.196 of EIA Report). The total area required for Underground Works is 2.44 Ha. The project proposes underground power house with an installed capacity of (260+7). There are three TRTs proposed of length 99.75m, 113.13m, and 132.35m. Even so the impacts of blasting for such huge construction are simply disregarded in the EIA report by stating that “The overall impact due to blasting operations will be restricted well below the surface and no major impacts are envisaged at the ground level.” (p.165). While assessing the impacts of blasting on wild life the report states that direct sighting of the animals has not been found in the study area and the possible reason could be habitation of few villages. No attempt has been made to assess impacts of blasting like damage to properties, drying up of springs etc. This is a clear violation of TOR.

Impacts of Peaking & diurnal flow fluctuation: In the lean season during peaking power generation the reservoir will be filled up to FRL. As stated in report, this will result in drying of river stretch downstream of dam site of Sach Khas hydroelectric project for a stretch of 6.0 km, i.e. upto tail end of reservoir of Dugar hydroelectric project. The drying of river stretch to fill the reservoir upto FRL for peaking power will last even upto 23.5 hours, after which there will continuous flow equivalent to rated discharge of 428.1 cumec for 0.5 to 2 hours. Such significant diurnal fluctuation with no free flowing river stretch will have serious impacts on river eco system. There is no assessment of these impacts. Instead the report projects this as a positive impact stating “In such a scenario, significant re-aeration from natural atmosphere takes place, which maintains Dissolved Oxygen in the water body.” This is absurd, not substantiated and unscientific.

International experts have clearly concluded that: “If it is peaking it is not ROR”[ii]. In this case the EIA says the project will be peaking and yet ROR project, which is clear contradiction in terms.

Impacts on wild life: EIA report lists 18 faunal species found in the study area. Out of them 8 species are Schedule I species and 8 Schedule II species. Even so while assessing the impacts of increased accessibility, Chapter 9.6.2 b(I) of the report mentions “Since significant wildlife population is not found in the region, adverse impacts of such interferences are likely to be marginal.” If the project has so many schedule I and II species, the impact of the project on them must be assessed in the EIA. Moreover, massive construction activities, the impacts of long reservoir with fluctuating levels on daily basis, high diurnal fluctuation and dry river stretch of 6km on wild life could be serious. But the report fails to attempt any assessment of the same.

Impacts on geophysical environment are missing: The project involves Underground Works of 2.44 Ha. This involves construction of underground powerhouse, three headrace tunnels and several other structures. This will have serious impacts on the geophysical environment of the region and may activate old and new landslides in the vicinity of the project. The report makes no detailed assessment of this. Generic comments like “Removal of trees on slopes and re-working of the slopes in the immediate vicinity of roads can encourage landslides, erosion gullies, etc.” (p.176) have been made throughout the report. Such generic statements can be found in every WAPCOS report. Such statements render the whole EIA exercise as a farce. Project specific, site specific impact assessment has to be done by the EIA. Considering that the project is situated between Purthi HEP upstream and Duggar HEP downstream, a detailed assessment of the geophysical environment and impact of all the project activities is necessary. Further since the EMP is not at all available in public domain, it is difficult to assess what measures are suggested and how effective measures to arrest possible landslides have been suggested.

Downstream view of Sach Khas

Right Bank Drift at Sach Khas

No assessment for Environmental Flow Releases

TOR states that the minimum environmental flow shall be 20% of the flow of four consecutive lean months of 90% dependable year, 30% of the average monsoon flow. The flow for remaining months shall be in between 20-30%, depending on the site specific requirements (p.192). Further the TOR specifically states that a site specific study shall be carried out by an expert organization (p.193).

The TOR also mandated, “A site specific study shall be carried out by an expert organisation.” However completely violating the TOR, the EIA report makes no attempt for the site specific study to establish environmental flows. Instead it proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. This completely defeats the basic purpose of the environmental flow releases. Such flows will help neither the riverine biodiversity, nor fish migration nor provide upstream downstream connectivity.

Socio-economic profile of the study area and Rehabilitation & Resettlement Plan are missing

TOR specifies a detailed assessment of socio-economic profile within 10 km of the study area including demographic profile, economic structure, developmental profile, agricultural practices, ethnographic structure etc. It also specifies documentation sensitive habitats (in terms of historical, cultural, religious and economic importance) of dependence of the local people on minor forest produce and their cattle grazing rights in the forest land. As per the TOR the EIA report is required to list details of all the project affected families.

Report however excludes assessment of socio economic impact of the study area. The total land required for the project is 125.62 ha, of which about 118.22 ha is forest land and the balance land 7.4 ha is private land. There are cursory mentions of habitations in the study area. Chapter 8.7 ‘Economically Important plant species’ states that in study area the local people are dependent on the forest produce such as fruits, timber, fuel wood, dyes and fodder for their livelihood. However the EIA report does not even estimate the population displaced due to land acquisition and impact of the various components of the project on livelihood of the people. Further detailed study is then out of question. This is again gross violation of TOR.

Indus Water Treaty

Chenab basin is international basin as per the Indus Water Treaty. A recent order of the international court has debarred India from operating any projects below MDDL and has disallowed provision for facility to achieve drawdown below MDDL in any future project[i] (for details, see: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/). The EIA described gate opening in this project for silt removal, which stands debarred by international court. The EIA thus is in violation of the verdict of international Court.

The EIA says (p. 21 bottom), “Five low level sluices with crest at 2167m of size 7.5m width and 12.3m height are proposed for flood passage. Drawdown flushing of the reservoir shall be carried out through these sluices for flushing out of the sediment entrapped in the reservoir. Detailed studies on sedimentation and reservoir flushing can be taken up at detailed planning stage.” The MDDL of the project is 2209.3 m as mentioned in the same para. This means the project envisages sediment flushing by drawdown to 2167 m (sluice crest level, the sluice bottom level wll be 12.3 m below that), about 42.3 m below the MDDL. This is clearly not allowed under PCA order cited above on Indus Treaty.

Impact of 3.5 MW Chhou Nala HEP to be constructed for the project not assessed

The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project. But the EIA does not contain any impacts of the SHP. The stream on which this is planned is extremely important for the people as drinking water schemes, irrigation Kuhls and gharats of Rai, Chhou and Thandal villages are located on this stream in the proposed project area. Thus the project will have huge impacts, but there is no assessment of these impacts. This is another glaring omission of EIA. It was shocking to read that the resident commissioner said at the public hearing that this question is not part of Environmental Public hearing, when it is very much part of it.

Public hearing report

At several places either no information is given or misleading information has been presented. For example the project representatives mis-informed the people at PH that 15-20% water will be released, when minimum water they need to release is above 20%. DFO said that soil will be spread over the muck disposal site for tree planting over it, but there is no provision of this in EIA-EMP. Many questions were provided with vague answers or no answers at all. No clear answer was given when asked if the muck dumping sites have been decided in consultation with the local people, implied answer is clearly that local people have NOT be consulted. When asked about agreements to ensure that the company implements EMP and Social Management Plan as required, there was no promise that such an agreement will be signed with the village gram sabhas. The affected people raised the issue of erosion impact of diversion tunnel, but no specific response was provided in response to this issue. When a resident of Chhou village raised the issue of vulnerability of the village to the landslides, no clear answer was given by the project developer. When the same person asked that our cremation ground is going under submergence, what is the company planning about it, the project developer replied that IF the cremation ground goes under submergence, we will think about this. This only shows that the project developer and EIA consultant have not even done an assessment of such basic aspects. The PH report accepts that close to 100 workers are already working without even basic sanitation facilities, this is clear violation of EIA notification further the EIA Agency fails to mention this.

EIA is full of cut and paste, generic statements, no actual assessments

Out of nine chapters of EIA, only the last chapter is about impacts assessments! So out of 170 pages of nine chapters, only 31 pages of chapter 9 is supposedly about impact assessment and there too mostly there is no real impact assessment, mostly only generic statements that can be included in any EIA. There are several unnecessary sections in the EIA like chapter 3 on “Construction Methodology” which is unnecessary in EIA. In most other sections too, the information is just cut and paste from DPR. By way of impact prediction, the EIA report is only listing them doing absolutely NO ASSESSMENT and no quantification of impacts is attempted. Further since the EMP is not available in the public domain, it is impossible to assess if the measures provided in the EMP are effective. Such EIA is definitely not acceptable.

No proper referencing The EIA does not provide references to the specific information, without this it is difficult to cross check which information is from which secondary sources and how credible it is and which information is from primary survey.

Conclusion

This is another most shoddy piece of EIA by WAPCOS.

Moreover, as we can see the EIA has not done several impact assessments, has violated large no of TORs on several counts, the EIA-EMP are not available on EAC website, the project parameters have undergone changes necessitating fresh scoping clearance as mentioned in TOR but that has not happened, baseline study is 3-4 years old, EAC stipulation of fresh EIA-EMP has been violated, Project is using larger riverine stretch than given by HP govt, there is no proper referencing, hydrology is weak, EMP is not available on HPPCB website in violation of EIA notification, among several other issues listed above. Every conceivable serious problem can be found in this EIA of WAPCOS.

It is full of generic statements that can be pasted in any EIA without any attempt at project specific impact assessment. SANDRP has been pointing to EAC and MoEF about such unacceptable EIA by WAPCOS for several years, but neither EAC, nor MoEF has taken any action in this regard. SANDRP has once again urged to EAC and MoEF to reject this EIA and recommend blacklisting of WAPCOS and to issue fresh scoping clearance for the project as mentioned in the TOR since the project parameters (dam height, submergence area, land requirement, etc) have gone through significant changes.

We sincerely hope the EAC will not only take serious cognition of these and not recommend clearance to the project, but also direct the project proponent and EIA consultant to implement other recommendations made above.

 Amruta Pradhan (amrutapradhan@gmail.com), Himanshu Thakkar (ht.sandrp@gmail.com)

[i] https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/

[ii] See for example https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf

[iii] https://sandrp.wordpress.com/2014/07/01/if-its-peaking-its-not-an-ror-interview-with-dr-thomas-hardy-iahr-and-texas-state-university/

[iv] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[v] https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

[vii] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[viii] Refer to SANDRP studies on Chenab

– https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

– https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

– https://sandrp.wordpress.com/2014/05/06/massive-hydropower-capacity-being-developed-by-india-himalayas-cannot-take-this-onslought/

[ix] http://northgazette.com/news/2013/04/25/special-committee-to-monitor-hydro-projects-in-hp-cm/

brahmaputra · Chenab · Ganga · Himachal Pradesh · Himalayas

How do dams affect a river?

That sounds like a rather innocent question and I was asked to write an article, addressing it. But before we go into that, let us try and understand a few things. Firstly, what is a River? Let us first try and understand that.

There is no single definition of this complex entity. For every definition, there is something more a river does.

Take the example of the one of the most complex rivers of all, the Ganga that we think we know. Before being a religious entity cultural icon, etc Ganga is, first & foremost, a River. A perennially flowing river like Ganga flows all the time. But that flow is not constant. It changes from day to night, from one day to another, from one season to another, one year to another, from one place to another.

And then, the Ganga that we know is not only a single river but a collection of rivers. So Yamuna, Bhagirathi, Alaknanda, Mandakini, Dhauliganga, Pinder, Ramganga, Kali, Tons, Gomti, Ghaghra, Sone, Gandak, Budhi Gandak, Kosi & Mahananda are some of the major tributaries that directly meet Ganga. Each of them is a river in its own right.

The Ganga Brahmaputra Basin Photo from: Wikimedia Commons
The Ganga Brahmaputra Basin Photo from: Wikimedia Commons

Take Yamuna for example. Some of its major direct tributaries include: Tons, Giri, Som, Sahibi, Hindon, Chambal, Sind, Betwa & Ken, each of them are again significantly big rivers.

Take Chambal, some of the major direct tributaries of Chambal include: Parbati, Kali Sindh (Lakhundar, Ahu, Parwan are some of the tributaries of Kali Sindh, Newaj is one of the tributaries of Parwan, Dudhi is one of the tributaries of Newaj), Banas, Ider, Retam, Sau, Kshipra, Chhoti Kali Sindh, Cham, Siwana, Kural: each of which is a river by its own right.

Take Parbati: some of the major tributaries of Parbati include: Papnaus Ajnal, Sewan Paru, Utawali, Paraparwa, Mawal, Tem, Bhader, Gochi, Gaumukh, Sunk, Negri, Chopan, Uproni, Duhral, Andheri, Beram, Kosam, Ahelil and Sukni. These are all rivers too!

We can go on like this much longer. But such is a vast network of rivers that we call Ganga.

river

Secondly what flows in a river is not just water, though most governments, official agencies & engineers see the rivers as channels of water. Flowing water is surely a major visible defining component of a river. But even a canal or a pipeline can claim that. But unlike a canal or pipeline, a river carries dissolved matter, suspended matter, bed load, microorganisms, many levels of aquatic flora and fauna.

Thirdly, a river is a connected entity. It is connected with upstream and downstream river, biodiversity & landmass, the terrestrial land & life, underground geology and groundwater aquifers and is also connected with the floodplain. Perennial rivers like Ganga meet the sea forming a delta and this connection is vital for the river and as well as the sea. The connections are so strong that a river provides a report card about what is happening upstream and downstream, if read carefully.

From: The River continuum Concept. Species in India will be different, but this represents how biological entitites in a river are linked to each other through a number of processes including nutrient spiralling Oxbowriver.com
From: The River continuum Concept. Species in India will be different, but this represents how biological entitites in a river are linked to each other through a number of processes including nutrient spiralling Oxbowriver.com

This is admittedly a partial description of a river, limited by the constraints of an article or blog. This is also a bit simplistic description of how humans deal with rivers, since there are exceptions. But this provides a broad direction of our journey with the rivers.

from : lakeconesteenaturepark.com
from : lakeconesteenaturepark.com

Apart from its many functions like ecological, hydrological, geomorphological ones, a river is also connected with the human society along the banks. The connection with human societies has been as long as the humans have existed. This connection is not really necessary for the river to survive, but we cannot say the same about human survival. Humans cannot survive without the rivers, though is doubtful if the human society understands or even acknowledges that reality.

More importantly, till about a century ago, our interaction with the rivers did not endanger the existence of the rivers themselves. But what we have been doing in last century has created existential threat for rivers. This threat comes in the form of big dams, diversions, chemical pollution from agriculture and industries, large dose of sewage pollution at major urban centers, encroachment on floodplains, deforestation, unsustainable groundwater use, riverfront developments, embankments, and climate change.

What humans have done to the rivers in last century can possibly be described as Terraforming (one of the grandest concepts in science fiction in which “advanced” societies reshape entire planets to suit their needs). Or what some geologists describe as Anthropocene, meaning a new geological age of humans to suggest that humans are now a planet transforming force.

It seems humans have stopped valuing the rivers as they exist in nature and decided that they can stop, bend, tunnel, channelise, divert, encroach, pollute the rivers. So when we build a dam, we do not put any value to the destruction of river & destruction of the services provided by a river that entails in the process of building the dam.

But let us get back to Rivers & what dams do to them. A river, by definition, must flow freely. A dam stops the free flow of river, and impacts the river in the most fundamental ways. In India when we construct a dam (e.g. Tehri), a hydropower project (e.g. 400 MW Vishnuprayag project on Alaknanda in Chamoli district in Uttarakhand) or diversion (Lower Ganga – Bhim Goda at Haridwar, Middle Ganga – Bijnor and Upper Ganga-Narora barrages), we do not have to leave any water for the downstream stretch of river. So complete drying up of the rivers for most of the dry months by these structures is the first direct impact of these structures on the river. To put it mildly, that action practically kills the river. Upstream of the dam too, the river gets killed, for immediate upstream there is stagnant water and further upstream, the river has lost its connections with the downstream river!

Dry Baspa River downstream Baspa II Dam, Himachal Pradesh
Dry Baspa River downstream Baspa II Dam, Himachal Pradesh Photo: SANDRP Partners

This is because these structures not only stop the flow of water to the downstream areas, they also stop flow of everything else that was flowing in the river: the silt, the nutrients, the sand, the organisms, the flora, fauna, and severe every one of the connections of rivers we described earlier

And imagine when a river has to face such death every few kilometers in its journey!

Density of dams in the Upper Ganga Basin Map by SANDRP
Density of dams in the Upper Ganga Basin Map by SANDRP

 

That is not all. As the river continues its journey, if the tributaries are flowing reasonably freely, there is some chance for the river to recover some of its defining characteristics. But we have dammed most major tributaries too.

To top it, we also have other elements that help kill the river, like pollution, encroachment, abstraction, etc, as described earlier.

And remember just about a century back Ganga and other rivers were not in such a bad shape. This is an achievement of less than 100 years.

Chandra Basin in Himachal Pradesh depicted by Nicholas Roerich in 1932. The same Chenab Basin now witnesses one of the highest dam densities in Himalayas. From: WikiArt
Chandra Basin in Himachal Pradesh depicted by Nicholas Roerich in 1932. The same Chenab Basin now witnesses one of the highest dam densities in Himalayas. From: WikiArt

Some people will read in this a plea to go back by those 100 years. That is not possible, and we all know that. But there are other ways to deal with the rivers. Human society can take what is needed for the society, without destroying the river.

This is true of Ganga, as any other River!

Himanshu Thakkar (ht.sandrp@gmal.com, https://sandrp.wordpress.com/)

~~~~~~~~~~~~~~~~~~~~~~

This is 200th post from SANDRP! We always look forward to your suggestions and comments for improvement.

Our 100th Blog on River Conversations: https://sandrp.wordpress.com/2013/10/08/river-conversations/

 

 

Chenab · Jammu and Kashmir

Massive Kwar and Kiru HEPs on Chenab, J and K : Poor quality & cut paste EIAs, flawed public hearing

It seems we do not want to learn any lessons from the massive Uttarakhand disaster of June 2013. Two more huge capacity hydropower projects have been submitted to the Expert Appraisal Committee (EAC) of Ministry of Environment & Forest (MoEF) for grant of Environmental Clearance (EC) with very poor quality Environmental and Social Impact Assessment (EIA) reports.

EIA reports of Kiru Hydro Electric Project (HEP) (660MW) and Kwar HEP (560 MW) proposed in Kishtwar district, Jammu and Kashmir by Chenab Valley Power Projects Ltd. (CVPP) were submitted to the EAC for River for its 74th meeting held on 5-6 May, 2014 for grant of EC. The projects are run-of-river schemes proposed on river Chenab as a part of cascade development of Chenab basin.

Vicinity Map

Vicinity Map (Source Kiru EIA Report)

 Partial map of Hydro Electric Projects on Chenab river basin

Partial Map of Commissioned and Proposed HEPs in Chenab River Basin (Map by SANDRP)

 

Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[1]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K).

While 49 of these projects are planned or under construction in Chenab in HP, 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[2]. State of J&K has 13 projects planned of total capacity 8,623 to 8,923 MW. These consist of at least four operational projects (of total 1563.8 MW), three under construction projects (of 1450.5 MW) and six proposed projects (of 5608.7 MW).

Table 1: Cascade Development of Chenab Basin

Source: EIA report of Kiru & Kwar

Sr. No. Scheme River Capacity
1 Salal (Stage- I & II) Chenab 690 MW
2 Sawalkot Chenab 1856 MW
3 Baglhar (Stage-I & II) Chenab 900 MW
4 Shamnot Chenab 370 MW
5 Ratle Chenab 850 MW
6 Dulhasti Chenab 390 MW
7 Kwar Chenab 560 MW
8 Kiru Chenab 660 MW
9 Kirthai-I Chenab 350 MW
10 Kirthai-II Chenab 990 MW
11 Barinium Chenab 240 MW

Himalayan ecosystem, of which the Chenab river basin is a part, is known to be geologically fragile. Cascade of hydel projects proposed on the river basins of this region would make the region even more vulnerable to extreme and erratic weather events, which will increase in changing climate. This has already been witnessed during Uttarakhand disaster of June 2013. Expert Body (EB) headed by Dr Ravi Chopra recently has officially acknowledged this connection in the report submitted to MoEF[3]. In light of this, a thorough impact assessment of all the proposed hydro power projects in this region is thus of critical importance. Various organizations and experts including SANDRP have repeatedly highlighted the fact that Cumulative Impact Assessment (CIA) of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the river basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Without such a study, considering any hydropower project in the basin will be an invitation to disaster[4].

Even though the MoEF sanctioned TORs for cumulative impact assessments of the HEPs on Chenab in HP in February 2012, this critical task was entrusted to the Directorate of Energy, Government of Himachal Pradesh. This is a clear case of conflict of interest. Further the project specific ECs were delinked from the CIAs[5].

More importantly, no such study has been initiated in Chenab basin in J&K or in the Chenab basin as a whole. State of Jammu and Kashmir is not even considering CIA of HEPs on Chenab in the state as MoEF has not asked for it yet. CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.

On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.

MoEF continues to give clearances to individual HEP projects despite of poor quality Project Feasibility Reports (PFRs) and EIA reports submitted for appraisal. Kiru & Kwar EIA reports are a classic example of such poorly conducted EIAs. The EIAs demonstrate several serious issues across various stages from TOR non-compliance, non assessment of impacts, cut and paste job, lack of any references, faulty public hearings, the issued raised at public hearings have not been addressed in EIAs, as statutorily required. SANDRP recently made detailed submissions to EAC highlighting these issues for both the projects. Some highlights below:

Copy paste job while preparing EIA reports Both the reports are prepared by a consortium of RS Envirolink Technologies Pvt. Ltd. (Gurgaon) and Jammu University. Kiru EIA report demonstrates a casual approach towards impact prediction and proposing mitigation measures in EMP. The report also misses out on a number of important aspects of EIA like impact of construction activities on geology, flora fauna, impact of climate change, cumulative impacts of cascade development in Chenab basin etc. While Kiru EIA is inadequate on several fronts it was utterly shocking to discover that Kwar EIA report is a complete replica of the Kiru EIA Report. Entire text, save project specific numbers, remains the same in both reports, to the extent that the Kwar EIA report mentions Kiru instead of Kwar at several places!! The impact prediction for both the cases is so vague and generic that the changes in numbers for project-specific details like proposed installed capacity, submergence of reservoir, FRL, head race tunnels etc. do not reflect at all in the reports!

Brief Project Profiles Kiru H.E. Project and Kwar H.E. Project are run-of-river schemes proposed on river Chenab located in the district Kishtwar of J&K.

Kiru HEP envisages the construction of a 193 m long and 123 m high concrete gravity dam above the river bed across river Chenab at village Kiru with four intake, four pressure shafts, an underground powerhouse of 4 units of 165 MW each. Impoundment will cover an area of 1.03 Km extending 6.5 km upstream of dam. The average river bed level at the dam site is about EL 1394 m corresponding to an FRL of 1515 m, the gross storage of the reservoir is 41.50 Mcum and area under submergence is 1.03 Km.

Proposed dam site for Kiru HEP

Proposed dam site for Kiru HEP(Source Kiru EIA Report)

 Kwar HEP envisages construction of a concrete gravity dam 101 m high from river bed across river Chenab at village Padyarna, four number intakes, four pressure shafts, an underground powerhouse to accommodate 4 units of 140 MW each and two number tail race tunnel. FRL of reservoir is proposed at EI 1385M. Gross storage of the reservoir at FRL is 27.167 Mcum. The reservoir will submerge an area of about 0.8 Sq. Km at FRL.

Proposed dam site for Kwar HEP

Proposed dam site for Kwar HEP (Source Kwar EIA Report)

 TOR non-compliance First and foremost glaring issue about the proposed projects is the non-compliance with the TORs (Terms of Reference) laid down for conducting the EIA. These TORs were granted by MoEF. We have listed here only an indicative list of non compliance below, not an exhaustive one.

Kiru HEP The TOR clearance letter was issued for Kiru project on Sept 9, 2008, the TORs are valid for a period of 3 years, but the project developer never came back for extension of the TOR on expiry of 3 year period and has come now for EC over 5.5 years after the TOR clearance. Thus the TOR clearance is no longer valid for Kiru HEP as per the law. Also originally the TOR clearance for Kiru was given for 600 MW installed capacity. The EIA however has been conducted for 660 MW capacity. No permission was sought by the PP for this increased capacity.

Kwar project has undergone several changes since the grant of TOR on 17 March 2010. Table given below compares some of these changes. First and foremost alteration has been in the proposed total power generation. While the TORs were granted for 520 MW the EIA has been conducted for 560 MW. Number of affected families goes up by 160% and project cost escalates by 29%. The TORs were granted for over four years back and the project authority never got back to EAC/MoEF for renewal of the TOR as other projects do. Thus the TORs granted originally do not remain valid in this case too.

Table 2: Changes in the scope of Kwar project after grant of TOR on 17 March 2010
Sr. No. Parameter Scope at the time of TOR clearance Current scope of the Proposed Project
1 Total power Generation 520MW 560 MW
2 Land requirement 5 Ha Government land 93.66 Ha Government land
3 Power House Units 4 x 130 MW (4 x 140MW)
4 Affected families 35 91
5 Project Cost Rs 3386.11 Cr Rs. 4375.50 Crores at Jan’2012 PL

Casual approach towards impact prediction

 Kwar EIA copy pasted from Kiru EIA report: It is evident that the EIA consultants have done nothing but copy paste job while preparing Kwar EIA report. At certain places Kwar report mentions ‘Kiru’ instead of Kwar. See for example point number 1.7 in Index of Kwar EIA mentions ‘Need of the Kiru HE project’ instead of Kwar and point number 4.4 mentions ‘Basin characteristics of free draining area of Kiru HEP’ (p.3 & p.6 of the document). Page 28 of Kwar EIA states that “The case for forest clearance of Kiru HE Project for diversion of 29.75 ha of forest land has been approved in the 81st meeting of J&K State Forest Advisory Committee (FAC) held on 09.12.2013…”

Other than very project specific figures, the entire text for both the reports is exactly the same. Impact prediction is the heart of an EIA study. However in Kwar EIA report an important chapter like Chapter 8- “Identification, Prediction and Evaluation of Environmental Impacts” is also copy pasted. The text of the chapter is same as that of Chapter 8 from Kiru EIA report save the project specific numbers and their description. The impacts predicted are vague and are conveniently kept the same in both the reports. It is clear that no real field work or application of mind is done. Such an EIA study defeats the basic purpose of conducting an EIA.

Impact of construction activities: The Kiru project involves a reservoir of live storage 10.5 MCM, a concrete dam on height (from river bed) 123.0 M & length 193 M, construction of 4 head race tunnels (of 7 m dia and 165 to 190 m length each) for discharging the water to an underground powerhouse of 4 units of 165 MW each. The project also envisages 33.4 Lakh CuM of construction material required from the project site.

The Kwar project involves construction of 101 m (above river bed)/ 109 m (above deepest foundation) high concrete gravity dam, Underground power house complex of four units of 140 MW each, Two concrete lined 9.5 m internal diameter main tailrace tunnels (having length of 2676 m and 2883 m) amongst several other features like four 5.65 m internal diameter main pressure shafts (each with a length of 108-182 m), etc. The project also envisages 38.36 Lakh CuM of construction material required from the project site.

View of Naigarh Nala Rock Quarry at Kwar Dam site

View of Naigarh Nala Rock Quarry at Kwar Dam site (Source Kwar EIA Report)

 All these activities will have significant impact on the geology and hydrology of the region. However no significant assessment or quantification of these impacts in terms of change in drainage patterns, springs in the project area, increased thereat of landslides, seismic activities has been carried out.

While talking about the impact of construction activities, the only impact of these two EIAs discussed in the chapter is ‘muck generation’. It does not mention impacts of tunneling and blasting involved in construction and also does not talk about its impact on fragile geology and hydrology of Himalayan region at all[6]. While talking about quarrying activities in the same chapter it states only two impacts viz. visual impacts and noise generation[7]. Impacts on landslides have been randomly dismissed stating that the sliding activity may not be significantly induced by project construction activities[8]. The reports trivialize the impacts on migratory fish Mahseer by stating that the upstream migration of this fish from the lower reached of the Chenab River have already been blocked by Salal and Baglihar, Dul Hasti dams. Thus they conclude that impact of this project on this fish species is not expected to be significant[9]. Option for fish ladder and fish lift has been ruled out for both the projects stating that it is not techno-economically feasible at the project site. Development of a hatchery at the project site has been proposed instead. The impact of the project on all the fish available in the river should have been assessed based on baseline assessment of the fisheries in Chenab River, which is not done. Secondly, there is no credible evidence to show that hatchery as a management option is useful or effective.

Left Bank slide for Kiru Project downstream of Ludrari Nala

Left Bank slide for Kiru Project downstream of Ludrari Nala (Source Kiru EIA Report)

 Right Bank slide for Kiru Project about 16 km downstream of Gulab Gargh

Right Bank slide for Kiru Project about 16 km downstream of Gulab Gargh (Source Kiru EIA Report)

 

The southern boundary of the Kishtwar National Park is approximately at an aerial distance of 11 km away from the proposed project, it is claimed, but this needs to be independently assessed. Also, just because it lies outside the boundary of study area which is radius of 10 KM, the EIA does not consider the impacts on this national park at all! EIA reports for both Kiru and Kwar HEPs simply state that the proposed activities shall have no impact on the National park[10].

Biodiversity at Kishwar National Park I

Biodiversity at Kishtwar National Park (Photo: Travel Places[11] & Beauty Spots of India[12])

 Several Important aspects of EIA are missing

No mention of free flowing river stretch: There is no mention of what is the flowing river stretch upstream and downstream of the project. As is clear from the EIA, the elevation difference between FRL of Kiru HEP (1515 m) and TWL of upstream Kirthan II (1526.5 m) is just 11.5 m. The elevation difference between TWL of Kiru HEP (1388 m) and FRL of downstream Kwar HEP (1385 m) is just 3 m. Similarly the elevation difference between TWL of Kwar HEP (1270 m) and FRL of downstream Hasti HEP (1264 m) is just 6 m. However, it is not clear what the flowing river lengths in all these locations are. Unless this length is assessed and is found to be adequate for river to regain its vitality, the project should not be considered and it should be asked to change the parameters.

Environmental Flows: The Kiru EIA report states that significant downstream impacts related to the water quality, fisheries, socio-economic and aquatic biodiversity are not foreseen since toe power house is proposed downstream of the dam and tail water level is EL 1388.52 m, discharge will be less only in a “very small stretch of about 800 m”. This seems to show the ignorance of the EIA consultants about how biodiversity in a flowing, lively river like Chenab survives.

Kwar EIA report states that the water entering the reservoir will be released back to river at a distance of 2.6 KM downstream. The report claims that though there in no human activity in this stretch of 2.6 KM the aquatic life will be definitely affected, as also terrestrial biodiversity, groundwater recharge, use of river and silt flow pattern.

10% of average of lean season discharge has been prescribed to be released through the dam gates as environmental flow for both the projects. This quantity has been calculated as 9.0 cumecs based on discharge data of the river. There is no mention of environmental flows in EMP. Firstly, this is even below the norms being followed by EAC and MoEF (30% in monsoon, 20% in lean season and 25% in rest, each at 90% dependability). Secondly, the amount of E-flow required needs to be arrived at based on actual assessment, but no such assessment has been done.

Impact of peaking generation not assessed: The reports talk about advantage of hydropower in terms of ability to providing peaking power. However, when a project operates as peaking station, there are severe impacts in the downstream and also upstream (rim stability). These impacts have not been assessed, nor is it assessed how the project will perform in the cascade development it is in.

Some other important aspects of impact assessment that report misses out on are:

  • Impact of the project on disaster potential in the project area as well in the downstream due to construction and also operation at various stages, say on landslides, flash floods, etc.
  • Social and Environmental Impacts of construction and operation of the coffer dams and diversion tunnels during construction phase are not included.
  • The reports do not even mention Climate Change.Impact of climate change on the project and impact of the project on the local climate has not been assessed. No mention or attempt has been made about or to assess the impact of green house gas emissions from the project.
  • Impacts on the flood characters of the river due to this dam, what will be the changes and how these will impact downstream areas.
  • Impact of changing silt flows downstream from desilting chamber and from silt flushing in monsoon on the downstream areas not analyzed. A detail account of how the silt from the dam would be flushed out annually and what would be the impact of this in the downstream as well as on the geo morphology, erosion, stability of structures etc was not done.
  • Options Assessment is missing, this is crucial part of the EIA to establish that among all options, including non project option, the given option is the least cost and best option.

Cumulative Impacts not assessed The EIA report gives list of Major hydroelectric projects executed /under execution/ under investigation so far in the basin in J&K which are a part of Cascade Development. Kirthan HE Project (990MW with proposed FRL at 1764 m and TWL at 1526.50m) which is yet to be commissioned is proposed upstream of Kiru (660 MW with FRL at 1515M). Downstream of Kiru is Kwar HE Project (560 MW with FRL at 1385 m and TWL at 1270 m) which is yet to be appraised and Dul Hasti HE Project (390 MW with FRL at 1264 m) which is commissioned.

Impoundment of Chenab at Dul Site

Impoundment of Chenab at Dul Site (Source: Kwar EIA Report)

 Moreover, the EIA does not provide the list of hydropower projects being taken up in Chenab basin in upstream Himachal Pradesh[13]. The cumulative impacts of all such projects will be huge.

The report summarizes cumulative impacts in single sentence: “The increased pressure will include uncontrolled logging, hunting of wildlife, non-timber forest product collection, livestock husbandry, the cultivation in forest areas and forest fires.”[14]

EIA report completely misses out on the detailed analysis of cumulative impacts in terms of

  • Impacts on flora, fauna, carrying capacity, livelihoods
  • Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change
  • Impacts on springs and drainage pattern
  • Disaster potential of the area
  • Tunneling and blasting
  • Geological disturbance caused
  • Seismic impacts
  • Carrying capacity

Inadequate Dam Break AnalysisThe Dam break analysis does not take into account the cumulative disaster potential including existing and proposed upstream and downstream projects. The EIA report also does not include cumulative disaster management plan.

Improper Public Hearing Public hearing conducted for both the projects were flawed. Excerpts from the speeches made by the officials from J&K State Pollution Control Board (SPCB) and CVPP that are noted in the public hearing report show that what these persons spoke was inappropriate, misleading and intimidating[15]. Also point wise responses to the issues raised by people at the Public Hearing are not provided in the EIA, as statutorily required. Hence even when people ask for Resettlement and Rehabilitation as per latest Act of 2013 (made effective from Jan 1, 2014), the EIA talks about National Resettlement and Rehabilitation Policy of 2007. The public hearing report strangely end for both projects with the officials asking those who are for the projects to raise their hands. There is no formal provision for voting for or against the project. Such public hearing should be declared null and void and fresh public hearing should be conducted.

Poor quality EIA reports that reflect pro hydro bias of the consultant EIA is the most effective tool to ensure environmental compliance in India. Needless to state that it is of critical importance. Casually predicted, unaddressed impacts and copy paste job of the Kiru and Kwar EIA reports once again highlights the poor quality of EIA reports submitted to the ministry for grant of EC. These reports decide fate of the project, of the people and environment surrounding the project site. Such quality of the report is most definitely not acceptable.

Further, an EIA report is an attempt to understand what are the adverse social and environmental impacts of a project and weather the impacts are acceptable, if the project is viable, optimal and desirable. The answer to this exercise can also include the answer that the project is not viable or desirable or acceptable. In view of this, the EIA consultant needs to be completely unbiased and should be ready to even conclude that the project is unacceptable. However, in case of the EIA consultant for the Kiru & Kwar HEP, EIA starts in very 1st chapter with a shockingly unscientific and biased statement: “Hydropower projects are dependable, renewable, economic, environmentally benign sources of energy with ability to stop and start instantaneously.” This statement is factually wrong on many counts (e.g. hydropower project is renewable or dependable or environmentally benign source of energy). It, along with whole para 1.2 also reflects the bias of the EIA consultants RS Envirolink Technologies Pvt Ltd (with Jammu University) and we urge the EAC and MoEF to reject such poor quality and biased EIAs and take other necessary steps to debar such agencies from doing any EIA or environmental studies in future.

CONCLUSION Looking at serious issues above, based on merit of the EIA reports, as well as complete cut-paste jobs, we are hopeful that the MoEF will not recommend EC for these projects. This case also highlights the importance of cumulative impact assessment in an over developed Himalayan basin. When the experience with Uttarakhand flood disaster of June 2013 is fresh, we hope that MoEF will not commit another blunder.

Amruta Pradhan, SANDRP

END NOTES:

 

[1]https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[2]https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

[3]https://sandrp.wordpress.com/2014/04/29/report-of-expert-committee-on-uttarakhand-flood-disaster-role-of-heps-welcome-recommendations/

[4] Refer to SANDRP studies on Chenab

https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

https://sandrp.wordpress.com/2014/05/06/massive-hydropower-capacity-being-developed-by-india-himalayas-cannot-take-this-onslought/

[5]https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[6]p.291 of Kiru EIA Report & p.288 of Kwar EIA report

[7]p.293 of Kiru EIA Report & p.289 of Kwar EIA report

[8]p.298 of Kiru EIA Report & p.294 of Kwar EIA report

[9]p.307 of Kiru EIA Report & p.303 of Kwar EIA report

[10]p.221 of Kiru EIA Report & p.223 of Kwar EIA report

[11]http://www.4to40.com/travel/index.asp?p=Kishtwar_National_Park&state=Jammu_and_Kashmir

[12]http://beautyspotsofindia.com/kishtwar-national-park-jammu-kashmir/

[13] See for example: https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf

[14]P. 306 of Kiru EIA

[15]The Public hearing report of Kiru says that Shri Sajjad Mufti, Regional Director of J&K SPCB said at the public hearing, “Construction of project should not deteriorate the environment….” This is a very strange, untruthful and inappropriate statement from J&K SPCB official. Why should the official be speaking at all at the public hearing and that too make such a statement that would also affect the atmosphere of the public hearing? Similarly the statement of GM of CVPP at the public hearing, “The most viable and cleanest of all (sources of power) is hydro power” was again, wrong, intimidating and inappropriate. The statement of Shri Khursheed Ahmed Butt of CVPP, “forest clearance has already been granted to the proposed project” is incorrect since the proposal for forest clearance for the project has not even come before FAC. Such public hearing should be declared null and void and fresh public hearing should be conducted.

The Public hearing report of Kwar says that the GM of CVPP said at the public hearing, “The best source of power generation is hydro power” was wrong, intimidating and inappropriate. The statement, “forest clearance has already been granted to the proposed project” is incorrect since the proposal for forest clearance for the project has not even come before FAC.

[16] See for details and link to PCA orders: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/

Chenab · Hydropower

Hydropower Generation Performance in Chenab River Basin

The Chenab River Basin is the major part of IndusRiver Basin. This river is formed by the Chandra and Bhaga, which rises in Lahul. It flows through Himachal Pradesh and Kashmir and is known as Chandra-Bhaga or Chenab. It then Traverses 330 km to Akhnur where it enters Pakistan. It flows 644 km more to Panjnad, joins the Sutlej after receiving the eaters from Jhelum at Trimmu and the Ravi lower down, its catchment area up to the Indo-akistan border is 26,155 sq km.

 The project wise generation data of large hydro with installed capacity of the basin in the latest year 2012-13.

Chenab

  • The above graph shows the trend line of power generation of Big Hydropower projects for last 25 years in the basin. the trend-line shows diminishing generation from existing hydro power projects of Chenab River Basin.
  • It shows that the per MW generation in 2012-13 (5.33) has dropped by a huge 23.09% from the highest per MW generation (6.93) achieved in the year 1990-91.
  • All generation figures have been taken from official data of Central Electricity Authority (CEA).
SN Projects

State

Inst Capacity  (MW)

Generation (MU)

MU/MW

1 Baglihar

Jammu & Kashmir

450

2839

6.31

2 Dulhasti

Jammu & Kashmir

390

2043

5.24

3 Salal

Jammu & Kashmir

690

3277

4.75

  Total

 

1530

8159

5.33

 List of other projects (up to 25 MW) under operation (for which latest generation figures not available):

SN Project

Ins Cap (MW)

State

1 Chenani-I

23.30

Jammu & Kashmir

2 Chennai-II

2

Jammu & Kashmir

3 Chenani-III

7.5

Jammu & Kashmir

4 Bhaderwah

1

Jammu & Kashmir

  Total

33.8

List of proposed and under construction projects in the basin:

  Project

Ins Cap (MW)

State

Status

  Bhaderwah Unit-III

0.5

Jammu & Kashmir Under Construction
  Pakul Dul

1000

Jammu & Kashmir Under Construction
  Baglihar-II

450

Jammu & Kashmir Under Construction
  Bardang

126

Himachal Pradesh Proposed
  Chattru

108

Himachal Pradesh Proposed
  Miyar

90

Himachal Pradesh Proposed
  Tinget

81

Himachal Pradesh Proposed
  Teling

69

Himachal Pradesh Proposed
  Tandi

104

Himachal Pradesh Proposed
  Rashil

102

Himachal Pradesh Proposed
  Gondhala

144

Himachal Pradesh Proposed
  Khoksar

90

Himachal Pradesh Proposed
  Patam

60

Himachal Pradesh Proposed
  Seli

454

Himachal Pradesh Proposed
  Dugar

236

Himachal Pradesh Proposed
  Gyspa

170

Himachal Pradesh Proposed
  Sach-Khas

149

Himachal Pradesh Proposed
  Reoli/Dugli

268

Himachal Pradesh Proposed
  Ratle

850

Jammu & Kashmir Proposed
  Bursar

1020

Jammu & Kashmir Proposed
  Kwar

520

Jammu & Kashmir Proposed
  Sawalkote I&II

1200

Jammu & Kashmir Proposed
  Lower Kalnai

50

Jammu & Kashmir Proposed
  Kirthai-I

240

Jammu & Kashmir Proposed
  Kiru

600

Jammu & Kashmir Proposed
  Ranjala Dunadi

15

Jammu & Kashmir IPP Projects
  Hanswar Paddar

6

Jammu & Kashmir IPP Projects
  Gulabgarh

6.5

Jammu & Kashmir IPP Projects
  Chenani IV

7

Jammu & Kashmir IPP Projects
  Chingus-I

3

Jammu & Kashmir IPP Projects
  Chingus-II

3

Jammu & Kashmir IPP Projects
  Upper Ans

3

Jammu & Kashmir IPP Projects
  Total

8225

EAC: Expert Appraisal Committee of MoEF; FAC: Forest Advisory Committee of MoEF

Source: http://www.hpseb.com/hydro_potential.htm; http://envfor.nic.in

http://jkspdc.nic.in/exist.htm

Map of Hydroelectric Projects in Chenab River Basin available at:

https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf

South Asia Network on Dams, Rivers & People (www.sandrp.in)                                           June 2013

ht.sandrp@gmail.com