Cumulative Impact Assessment · Ministry of Environment and Forests

Uttarakhand Deluge: How human actions and neglect converted a natural phenomenon into a massive disaster

Analysing a natural disaster is a complex task. Many a times, a natural disaster and its human impacts are a result of multiple things occurring together. At the same time, disasters like the one being faced by Uttarakhand currently highlight the stark anthropogenic reasons which contribute towards causing the disaster as well as increasing its impacts manyfold.

SANDRP has been trying to analyse the situation, and looking at number of causes which precipitated in the current tragedy. These include the absence of early warning system, absence of responsible and active disaster management of monitoring system. While the calamity is natural in the sense that the region did receive extreme heavy rainfall and cloud burst, the root causes which increased the human tragedy include unchecked and unplanned infrastructure development along the rivers and development of  hundreds of hydel projects in the fragile zone without proper checks and balances, transparent studies and decision-making processes.

A brief update on SANDRPs work on this issue as well a compilation of the numerous ways in which hydel projects in Uttarakhand are flouting norms of sustainability, transparency, participation or safety and what has been the response to this from the highest quarters: Prime Minister, Minster and Ministry of Environment and Forests as well as the state administration.

The first thing that strikes you when you analyse this disaster is that there was no specific and timely warning of impending disaster from the IMD or any other body (their claim to the contrary not withstanding). In fact we do not have a system in place to forecast cloud burst events, when technology is available to achieve that at approximate cost of Rs 15 crores, as informed to me by formed Director General of IMD, Dr S K Srivastava.

Secondly, even after the event of rainfall started and occurred, till date, six days after the event started on 15th, there is no account of how much rainfall occurred at what specific locations, and what was done to alert the populations that were at risk. This is again a failure of IMD and local administration. In fact it transpired that Kedarnath, one of the most affected area, has no raingauge, says Indian Express.

This shows how agencies like IMD, CWC, NDMA and SDMA have failed to put in place basic systems of warning, forecasting, monitoring and information dissemination that can greatly reduce disaster potential of any area.

In April 2013, a CAG report said that Uttarakhand state disaster management authority, which was formed in Oct 2007, has never met till date. Nor has it mandatory “rules, regulations, polices or guidelines”, first step for the authority to have functional existence. (for elaborate excellent information on this CAG report, see:, for CAG report, see:



From all accounts it is clear that areas around all four Pilgrimage centres (Gangotri, Yamunotri, Kedarnath and Badrinath) and the fifth one of Hemkunt Sahib have faced some serious floods this season. In addition, areas of Pithoragarh (Goriganga basin) and Himachal Pradesh (Kinnaur district, mainly Kashang area, a tributary of Sutlej) basin also faced floods during the same period. The rainfall event that lead to these floods started on June 15 and went on till June 16-17.  It seems strange to see such vast area facing simultaneous high intensity rainfall. IMD officials tried to explain this ( as collision of western disturbance with the upcoming monsoon clouds. It is also true, as Anupam Mishra ji explained to me that the catchments of all these basins in their uppermost ranges are not too far from each other. Incidentally, Tibetan area is also not very far from these region, it would be interesting to know if that area also faced cloud burst events in this period.

In an interview with Rediff Editor Sheela Bhatt, NDMA Vice Chair M Shashidhar Reddy accepted that there are no rain-gauges at Kedarnath and Badri nath and hence we may never know how much rainfall feel at those sites and we will never have full scientific explanation of what happened on June 16-17.

The best we have is weekly district wise rainfall in Uttarakhand districts for the week June 13-19, from India Meteorological Department:


13.06.2013 TO 19.06.2013




    % DEP



































































Events of June 16-17 at Kedar Nath Based on Media information, it seems Kedarnath shrine saw two massive flood events, one starting around 8.15 pm on June 16 and second at 6.55 am on June 17. The flood witnessed at the shrine (located at 3584 m above msl) originated from catchment that includes two mountain peaks: Kedarnath and Kedarnath Dome (6831 m elevation). Following torrential rains possibly triggered by cloude burst, huge boulders broke away from Kedar Dome and ruptured the downstream charbari lake reservoir, about 6 km upstream from the temple along the Mandakini river. This description seems to suggest that this was also an event of GLOF (Glacial Lake Outburst Flood), though no one seems to have used that term so far.

Another instance of GLOF in this Uttarakhand flood disaster could have happened at Hemkunt Sahib pilgrim centre (elevation 4632 m), where report suggest, the level of water in the lake surrounding the shrine suddenly “increased as glacier from the uphill came down.”

However, from all accounts, the massive rainfall and cloud burst events were happening at multiple places, including in Bhagirathi basin, Assiganga basin, Mandakini Basin, Badrinath region, other places in Alaknanda region, among others. The high rainfall started sometime on June 15 and went on till at least June 18. When I talked with Prof Bharat Jhunjhunwala staying at Devprayag along the confluence of Bhagirathi and Alaknanda, he said that the peak of the floods happened on the morning of June 17 (The Hindu reported this happened at 3 am on 17th), though massive flood event there in Alaknanda started the previous evening. He also mentioned that the massive amount of muck deposited on the Alaknanda riverbed by the under construction 330 MW GVK Srinagar Alaknanda Hydropower Prooject (the project has had no credible environmental impact assessment) accentuated the flood disaster in the downstream area. The Hindu reported ( that sudden release of water from the dam along with the illegally dumped muck in the river bed lead to disaster in downstream Srinagar town.

A Sphere India report said that in Rudraprayag (this is likely to be one of the Mandakini hydropower projects, either Phata Byuang or Singoli Bhatwari), “The local are saying the muck of the dam was deposited along the river which has diverted the course of water.” (

It is interesting to note that if these accounts are correct, the peak of flood event at Devprayag and Kedarnath (separated by about 150 km) happened on the morning of June 17, which possibly indicates that there were multiple could burst or very high intensity rainfall events in Alaknanda valley alone.

However, I had already received a detailed report from Uttarkashi Apda Prabanthan Jan Manch with photos of unfolding disaster on the evening of June 16, 2013, so the high rainfall event and beginning of flood  disaster at Uttarkashi began much earlier. The news channels were already showing live footage of the event unfolding in downstream Rishikesh and Haridwar on June 17, again indicating that the flood event in the upstream mountains must have started at least two days earlier.

Unfortunately we still do not have an accurate account of this whole episode from any of the official agency. When Vice Chairman of National Disaster Management Authority M Shashidhar Reddy was asked about this by me on NDTV INDIA badi khabar programme on June 21 evening (see:, he accepted we still do not have that account six days after the event. This shows the poor monitoring situation from all concerned.

UTTARAKHAND AND GLOFS The mention of GLOFs in the context of current Uttarakhand floods above should trigger other thoughts. In fact not many observers are mentioning GLOFs in current context. However, Climate scientists including ICIMOD has been mentioning increasing risks of GLOFs all across Himalayas.

This blog ( provides satellite images from Indian Space Research Organisation to explain the occurrence of GLOF in the current disaster at disaster and its consequences in the downstream Rambara area. Its Author Dave Petley, dean of research and global engagement, Wilson Professor of Hazard and Risk at DurhamUniversity in the United Kingdom, tries to explain the events around Kedarnath in an interview to Rediff editor Sheela Bhatt:

Similar images are also available on Down to Earth article ( and NRSC website (

Anupam Mishra ji in fact mentioned in NDTV INDIA discussion ( mentioned is 1977 article (see in Hindi: where he describes the 1970 floods and also the 1893 glacial dam burst, flood due to bursting of which was monitored and local people alerted by the then British government in collaboration with local people.

Chorbari Glacier The Chorabari glacier that played a role in current floods in Kedarnath lies between latitudes 30°44′50″N and 30°45′30″N, and longitudes 79°1′16″E and 79°5′20″E, from an altitude of approximately 6,000 m (20,000 ft) at the slopes of Kedarnath peak, to 3,800 m (12,500 ft). The glacier is around 7 km in length, while the basin area of the glacier is approximately 38 sq km and the glacier ice cover is 5.9 sq km. The glacier slope is around 11 degrees and faces south. The glacier has two snouts. It is hypothesized by R. K. Chaujar that an original single glacier covered the area, which while receding, split into two snouts. One of the snouts is the source of the Mandakini River at 3,865 m (12,680 ft). The other snout, at 3,835 m (12,582 ft), drains into the Chorabari Tal. (

DAMAGED HYDRO PROJECTS A large number of hydropower projects are likely to have suffered damage due to the flood disaster in Uttarakhand and Himachal Pradesh. Some of the projects that have suffered damage include:

  • According to the update from on June 27, 2013, the 520 MW under construction Tapovan Vishnugad HEP has suffered damaged by rains on June 16, 2013: “While construction of diversion tunnel was completed in April this year, the same was washed away due to heavy rains on June 16. Diversion dyke has washed away and damages have been observed in chormi adit approach road. In August last year, the flash floods had caused serious damages in the coffer dam of the project.”
  • 400 MW Vishnuprayag HEP of JP Associates has suffered serious, but as yet unassessed damage (–as-plant-shuts-down-in-uttarakhand/1133083/). As per MATU PR (, the project has also been cause of damage in Lambagad village, which was also flahsed on front page of TOI on June 25, 2013, though without mentioning the project.
  • 76 MW Phata Byung HEP of Lanco in Mandakini Valley in Uttarakhand
  • 99 MW Singoli Bhatwari HEP of L&T in Mandakini Valley in Uttarakhand NDTV India reported that the water level of the river has gone up due to the silt dumped by dams. This is likely to be due to the Phata Byung and Singholi Bhatwari HEPs.
  • Kali Ganga I, Kali Ganga II and Madhyamaheshwar HEP, all in Mandakini Valley, all of UJVNL, all hit by mudslides (
  • Assiganga I-IV projects on Assiganga river in Bhagirathi basin in Uttarakhand
  • Small HEP in Goriganga basin in Pithoragarh (name not known)
  • 65 MW Kashang HEP in Sutlej basin in Himachal Pradesh
  • 280 Dhauliganga Project of NHPC in Pithoragarh district of Uttarakhand (reports said the power house was submerged, but is now working, part of the township was submerged.)

It has been now reported in Business Standard ( that the 330 MW Srinagar project, a cause for downstream destruction, has itself suffered massive damages on June 17, 2013, with breach of its protective embankment. The report also mentions the damage to the L&T’s Singoli Bhatwari HEP on Mandakini river.

Down to Earth ( has given some details of damage to some of the hydropower projects, quoting UJVNL sources. It says: 19 small hydropower projects have been completely destroyed, while others have been damaged by the raging waters (see BOX)

Estimated losses from damage to hydropower projects on the Ganga
Project Location Capacity Estimated Loss
Dhauli Ganga Pithoragarh  280 MW Rs 30 crore (project completely submerged)
Kaliganga I Rudraprayag 4 MW Rs 18-19 crore (power house and 4 houses washed away)
Kaliganga II Rudraprayag 6 MW Rs 16 crore (power house and 4 houses washed away)
Sobla Pithoragarh 8 MW Rs 14 crore (completely washed away)
Kanchauti Pithoragarh 2 MW Rs 12 crore (totally washed away)
Chirkila Pithoragarh 1.5 MW Rs 20 crore (part of the project washed away)
Maneri Bhali I&II Uttarkashi 304+90 MW Rs 2 crore + Rs 5 crore (walls collapsed, silt in barrages)

In addition, a large  number of projects had to stop generation temporarily due to high silt content, including Maneri Bhali I and II, Tehri, Tanakpur, Nathpa Jakhri, Karcham Wangtoo, among others.

NO LESSONS LEARNT FROM PAST DISASTERS In fact in August 2012, Uttarkashi district saw similar tragedy that left 29 dead, many more missing and collapse of houses like card board boxes. The Uttarakhand State Diaster Mitigation and Management Centre report of this disaster in Oct 2012 concluded, “It is therefore highly important to strictly regulate developmental initiatives in close vicinity of streams and rivers. Appropriate legislative interventions would be required for formulating a policy in this regard and firm executive action in accordance with letter and spirit of this policy would be required to ensure compliance of the same.”


Similarly in Sept 2012, Okhimath in Rudraprayag  district (one of the epicentres of current tragedy) saw monsoon induced landslides killing 69 people among other damages. That state DMMC report of this tragedy in Oct 2012 made made recommendations to reduce the risks of landslides in landslide prone state, one of them read, “Use of explosives in the fragile Himalayan terrain for infrastructure developmental works introduces instability in the rocks and therefore use of explosives should necessarily be banned.” And “This provision would automatically ban habitation in the close proximity of seasonal streams and rivers. In case people are already residing in such areas provision has to be made for their timely relocation.”


In fact Rudraprayag has faced monsoon related major disasters SEVEN times in last 34 years, including in 1979, 1986, 1998, 2001, 2005, 2006 and 2012, each involving death and destruction.

If implemented, these recommendations could have saved many lives. Each of the hydropower project in the state involves MASSIVE blasting of MASSIVE scale, but there is no regulation in place about this even after clear warning from state DMMC.

Uttarakhand Floods and Climate Change That the vulnerability of already disaster prone Uttarakhand to such events is increasing is well known.  Secretary of Government of India Ministry of Earth Sciences Shailesh Nayak has now said that  the cloudburst that triggered flash floods in Uttarakhand read like a weather phenomenon brought about by warming. He also narrated how the high intensity rainfall is increasing while low and medium intensity events are decreasing. (See:

In this context, all developmental activities in such areas will need to factor in this increased vulnerability and how any intervention is going to affect the disaster vulnerability of the region. We have been writing to the Union Environment Ministry and its expert Appraisal Committee on River Valley Projects that the Environmental Impact Assessments of the hydropower and other projects need to include an assessment as to how the projects would affect the adaptation capacity of the local people in changing climate and how climate change would affect performance of such projects. There has been no change in the working of the ministry on this so far, but we hope this disaster will provide a wake up call to change that urgently.

Recommendation of National Himalayan Mission ignored National Mission of Sustainable Himalayas, one of the nine missions under National Action Plan on Climate Change, had made a recommendation for protection of areas around the four pilgrimage sites of Gangotri, Yamunotri, Kedarnath and Badrinath by creation of spiritual and ecological buffer zones around pilgrim places in the ecologically-sensitive region. The mission noted that construction of roads should be prohibited beyond at least 10 kms from protected pilgrim sites, which could have reduced the number of casualties. These areas, like national parks and sanctuaries, were to be maintained as special areas, where there would be minimal human interference. These measures could have lessened the extent of damage in these area suffered during current floods. However, the recommendations have been completely ignored and rampant construction were carried out at char dham, as tourist inflow boomed over the years. From 2.15 lakh in 2000, the number of Kedarnath pilgrims increased to 5.75 lakh last year. (

Geological fault lines ignored Prof KS Valdiya, an honorary professor at Bangalore’s Jawaharlal Nehru Centre for Advanced Scientific Research, said the heavy loss of life and property in the deluge was a result of “criminal oversight” over the decades of the state’s geological features and water channels by various authorities. These features are well-mapped and documented. But engineers and builders choose to overlook them, said Valdiya. The geologist identified four major ways in which constructions flouted scientific norms. First, he said, the seismic fault-lines of this earthquake-prone state were not kept in mind while building roads (and other infrastructure). “These tectonic fault-lines, which are active and see back-and-forth movements, have been cut in many places by roads. More dangerously, roads are built along the fault-lines at many places. As a result, tiny seismic movements in the fault-lines weaken the rocks at the base of the roads, making these stretches susceptible to cave-ins and slides,” Valdiya said.

The second area of rampant neglect, he pointed out, was drainage. “I have never seen road engineers provisioning for draining out all rainwater that can possibly enter the stretch. Where one to two metre bridges are required, they build small culverts. At places where drains have been provided for, these are usually filled with debris.” Buildings have been constructed over old drains and streams, blocking the natural pathways of rainwater, he said. “One of the reasons for the devastation at Kedarnath was that people had constructed houses on the west stream of the Mandakini river that had been dry for decades. When the river returned to its old course following the deluge, these constructions were washed away,” he added.

Valdiya said another type of transgression, similar to the previous one, was construction taking place on river flood ways. A flood way is the area covered by the river at the time of its biggest flooding in the past 100 years. “In places along Alakananda/ Ganga such as Karnaprayag and Rishikesh, constructions have taken place on the lower terraces which are part of the flood way. Sooner or later, water would get to these places,” the expert said.

Lastly, Valdiya said roads have been built over the debris of previous landslides because it’s costlier to build paths higher up on the hills where the rock is firmer. “Sadly, the department geologists are often no more than rubber stamps, okaying everything the engineers say. Independent geologists are never consulted,” he said. “Scientific engineering has very low priority in the state,” he lamented. Unfortunately, the state pays with human lives and huge property losses because authorities do not pay attention to basic scientific principles. (

SANDRP’s On-ongoing analysis of the Hydel Power Development in Uttarakhand

Flash Flood of Hydel Projects in Uttarakhand: Uttarakhand is witnessing unprecedented development of Hydel Projects along its rivers: mainly Alaknanda, Bhagirathi and their tributaries as well as Ganga, Gori Ganga, Kali Ganga etc. Though exact estimates are not available, activists like Ravi Chopra have said that there are close to 680 dams in various stages of commissioning, construction, planning in the hill state.

Some maps on the Uttarakhand river basins that contain location and details of the hydropower projects (as in 2011, the maps do not have all the projects, but only those for which we could find details when they were made):

Throughout their lifecycle, from construction, deforestation, blasting, mining, obtaining materials from river bed for construction, muck disposal, debris dumping, damming, altering hydrological cycle to allied activities like colonies, roads, infrastructure deevlopment, Hydel power plants have a profound impact on geology and hydrology of the region.

Dams in various stages in Alaknanda and Bhagirathi Basins in Upper Ganga, also affecting prtected areas. Map by SANDRP

In response to this unprecedented development ( most of these are private hydel projects), Central Empowered Committee (appointed by the Supreme Court) referred the Kotlibhel IA, 1B &  II projects back to the Forest Advisory Committee for reconsideration of Forest clearances issued under the Forest Conservation Act (1980). A sub-committee of FAC after visiting the area, recommended that a “thorough study of the carrying capacity of Ganga tributaries has to be undertaken.” MoEF hired The Alternate Hydro Energy Center of IIT Roorkee (AHEC IITR), without undertaking any bidding process.

MOEF commissioned two studies: Assessment of Cumulative Impact of Hydropower Projects in Alaknanda and Bhagirathi Basins which was given to AHEC, IITR &Assessment of Cumulative Impacts of Hydroelectric Projects on aquatic and terrestrial biodiversity in Alaknanda and Bhagirathi Basins, Uttarakhand, which was given to Wildlife Institute of India, Dehra Dun.

The supposed ‘Cumulative Impact Assessment Report’ conducted by IIT Roorkee is so pro dam, biased and unscientific that even the Expert Appraisal Committee of the MoEF (not known for any high standards) found plenty of faults in it.

SANDRPs analysis of the IIT R Report:

At that time too, organisations like SANDRP, Himal Prakriti and others had raised the issue that this study is not looking at cumulative impacts due to muck disposal, bad management practises, seismicity, etc.

Parallelly Wildlife Institute of India submitted its report in 2012 which clearly suggested that 24 projects from the 70 projects in Upper Ganga should be shelved due to their high impact on ecology. The report said that these projects are, together, affecting nearly 10,000 hectares of land in this small state, with more than 3,600 hectares of forests going under submergence. There were some limitations to this report too, but it was a huge improvement on the IIT R Report.

SANDRPs analysis of the WII Report:

It may be added here that the World Bank and Asian Development Banks are guilty of funding hydropower projects in Uttarakhand without adequate impact assessment in place.

Interministerial Group’s Report on Upper Ganga Projects: Continuing its modus operandi of appointing  a committee when one committee’s decisions are unpalatable, MoEF appointed the Interministerial Group on Upper Ganga Projects, to study reports of IIT R and WII under the chairpersonship of B. K. Chaturvedi. The Committee was overshadowed with bureaucrats with three non governmental members: Rajendra Singh, Dr.  Veerbhadra Mishra (who passed away) and Sunita Narain.

The report is largely biased towards hydro projects in Uttarakhand and does not say a word about WIIs recommendation of dropping 24 projects, without giving any explanations. The IMG report does not go at all into the issues of environmental destruction that such projects would cause and how they will increase the disaster vulnerability of the region, already prone to multiple disasters. IMG report did not even mention that the state is vulnerable to disaster in so many ways and how the projects would influence that.

IMG report also did not mention the increased vulnerability of the region to climate change and how the projects would affect the adaptation capacity and increase the disaster potential. CSE Director General Sunita Narian, member of the IMG, filed what she called “An alternate view” but closer scrutiny reveals that it is not much of an alternate view. It says adoption of three principles would make hydropower development in Ganga basin sound, but does not bother to apply two of the principles to the projects under review. She also does not mention the numerous environmental destruction this projects would cause, how it will impact the disaster potential, nor the increased vulnerability of the region to climate change. She is the member of the Prime Minister’s advisory committee on climate change and in that context, this is most glaring. She was also a member of the High Level Working Group Chaired by Dr Kasturirangan on Western Ghats and she signed on a report that certified all hydro projects as green and renewable. Something that most other countries wont do.


SANDRPs critique of the IMG Report:

Is MoEF truly assessing Hydel Projects in the Upper Ganga?

Despite all these reports, several represenattions from affected population, PILs in National Green Tribunal, submissions from various organisations, the Expert Appraisal Committee of the MoEF did not deny granting Environmental Clearance to ANY projects in the Upper Ganga. This was depsite the fact that for projects like 300 MW Alaknanda HEP by GMR, the Forest Advisory Committee had actually rejected Forest Clearance TWICE and WII had also written strongly against the project. Not only did the project get Environmental Clearance, the EAC (Expert Appraisal Committee) haggled with the private proponent (GMR) about eflows release in the river. It did not keep to its mandate or the powers it has been given to deny EC in case the impacts of the projects are severe. SANDRP and partner organisations had also raised this point with the EAC, to no avail.

More on this issue:

When it comes to granting TORs and Environmental Clearance to Hydropower and Irrigation Projects, EACs track record is so exceedingly poor that since its conception six years ago, it has not rejected a SINGLE project for Environmental Clearance. From an Expert Appraisal Committee, its seems to be an Expert APPROVAL Committee.

Report on EACs performance:

Consistent advocacy about impacts of dams on hydrology, communities: Numerous organisations, notably the Matu Jan Sangathan, Ganga Avhan, individuals like Bharat Jhunjhunwala, and even CAG has been raising questions about the impact of unbridled hydel power development in Uttarakhand. Their concerns have gone largely unaddressed till now. In 2009, CAG performed an audit of Hydel Projects in Uttarakhand and concluded that:

  • “Audit scrutiny of project records revealed that no specific measures had been planned/ designed in any project to cope with the risk of flash floods The adverse consequences of such floods are acute as they can not only damage the project structures but can cause loss of live in low-lying down stream areas. Civil construction in projects is required to factor in this natural threat. Also the bigger the project, the greater should be the efficacy of the preventive measures.”
  • “Given the current policy of the State Government of pursuing hydro-power projects indiscriminately, the potential cumulative effect of multiple run-of-river power projects can turn out to be environmentally damaging.[Paragraph 5.3.2]”
  • “Negligence of environmental concerns was obvious as the muck generated from excavation and construction activities was being openly dumped into the rivers contributing to increase in the turbidity of water. The projects seemed oblivious of the gross negligence of environmental concerns”
  • “The plantation activity was highly deficient, as 38 per cent of projects reported hardly any plantation; posing severe hazards both for natural ecology and stabilization of hill slopes”
  • “Audit analysis revealed that, negligence in applying appropriate construction norms and structuring the project without appropriate technical counter measures may expose projects to enhanced seismic vulnerability”

“In conclusion, the above also shows inadequate construction practices being followed by project developers who failed to cater for such eventualities which are common place in the region. Additionally, it also highlights the ineffective monitoring by the GoU and the nodal agency as a result of which the slapdash approach of the project authorities towards project execution has gone on unchecked”

CAG report on Uttarakhand Hydro power projects in 2011 again repeats many of these warnings, but none of them were heeded.

Some recent comments:

Himanshu Thakkar on Karan Thapar’s Last Word:

Himanshu Thakkar on The Last Word

“In a state like Uttarakhand, which is prone to disasters like cloud bursts, flash floods, land slides, the indiscriminate building of hundreds of hydropower projects in this state, each project entailing dam, tunnels that need to be blasted through, the roads, townships and deforestation, the disaster and damage potential goes up multi fold, particularly when there are no credible environment of social impact assessments at project or basin leve, nor any carrying capacity study, nor any credible compliance mechanisms. Even the wrong operation of projects can add to the disaster potential.”

“The South Asia Network on Dams, Rivers and People (SANDRP) says too many hydropower projects, underground tunnels, roads, encroachments of riverbeds by buildings coupled with deforestation could have worsened the impact of the flash floods.

“We do not have credible environmental-impact assessment of infrastructure projects on these highly ecologically sensitive areas,” says Himanshu Thakkar of SANDRP. “Neither is there any credible mechanism to assure compliance with environmental regulations. These are places where there is a heavy tourist influx. The collapse of buildings like a set of playing cards shows these were encroachments on the riverbed and floodplains.”

Thakkar says there have been seven similar flood-related disasters in Rudraprayag in the last 34 years. “The administration should have learnt,” he says. “This is not the first time such a disaster has hit us. Both Uttarkashi and the Chamoli-Rudraprayag-Kedarnath area faced monsoon disasters last year, killing several people. There are a few hundred hydropower projects, for instance, in the various tributaries of the Ganga here. These may all be legal projects approved by the environment and forests ministry but have a serious bearing on the flow of the river.”

In conclusion:

Managing disasters after they occur is at a huge human, ecological and economic cost. Predicting and controlling disasters transparently and swiftly is a crucial factor.It is clear that numerous organisations, groups, individuals, even government institutions had raised the issue of impacts of cascade hydel dams on Upper Ganga on Hydrology, Ecology and Communities in this fragile region. Most of the suggestions have been ignored.

Even gazette notification of 135 kms of Bhagirathi as an Eco sensitive Zone came in pretty late from the MoEF and is being opposed by the Uttarakhand Government.

The responsibility of the current calamity does not rest alone with Uttarakhand Government or Disaster Management unit. It lies squarely also with the MoWR, Ministry of Environment and Forests and the Prime Minister, who is the chairperson of the National Ganga River Basin Authority. Incidentally, the MoEF has been sitting on Draft River Regulation Zone Notification for more than 3 years now. The RRZ Notification could have helped in controlling infrastructure development like hotels and homes along the river.

At the cost of hundreds of lives, the current disaster is a bitter lesson for us. It is not a time to engage in a blame game of whether or not this is a man made disaster. The contributing reasons like Dams, tunnelling, blasting, mining are well known; History of projects on Assiganga and Dhauliganga is well know and so is the topographical, seismological, geological fargility of the region. It is now a time to act and actually implement recommendations given by so many committees and organisations since past many years.

Climate Change is no longer a distant, obscure event, it is in front of us now.

In keeping with all these factors, there is an urgent need to immediately stop the ongoing hydel projects in Uttarakhand, address pending issues raised by communities and groups, undertake transparent and true carrying capacity study of the region, scrap 24 projects mentioned by WII and more, considering geological impacts, monitor commissioned projects closely for compliance, decommission commissioned projects whihc flout environmental norms or have a severe downstream impact, manage 135 kms Ecosenstive zone on bhagirathi, have a similar one for Alaknanda and near all river origins in Uttarakhand.

When faced with a human toll that is feared to be close to a thousand, hydel power does not seem so bright or clean, green and sustainable like it is touted. It is not something for which India can risk the lives and well-being of its population or environment.

Himanshu Thakkar, Parineeta Dandekar

Useful Links:

1. For an account of Floods in Pithoragarh district of Uttarakhand, see:; images of the Goriganga floods:; Before and after images of 5 Motighat hydropower project:

2. For a photo feature on damage to Vishnuprayag HEP, see:

3. For an excellent account of how Uttarakhand is a model of disaster, see:

4. Uttarakhand Disaster Mitigation and Management Centre:

5. National Disaster Management Authority:

6. National Institute of Disaster Management:

7. India Meteorological Department:

8. Flood forecasting site of Central Water Commission:

9. Sphere India website, coordinating disaster management from non govt agencies:

10. People Science Institute:…html

11. Action Aid:

Cumulative Impact Assessment · Dams · Hydropower · Ministry of Environment and Forests

Upper Ganga Report with Pro Hydro Bias does not do justice to its terms or to Ganga, people or environment

Summary A month after its submission to the Union Ministry of Environment and Forests, the Inter Ministerial Group on Upper Ganga basin Hydropower projects and Ganga river in general is yet to be put in public domain. A detailed perusal of the report shows that the report is hugely biased in favour of large hydropower projects, and has not done justice to the task given to it or to the Ganga river, people or environment. Out of the three non government members (out of total 15 members) on the Group, Dr Veer Bhadra Mishra expired during the working of the group. Rajendra Singh has given a dissent note, not agreeing with the report in its totality. The “alternative view” note from Sunita Narain, the third non-government member, is not much of an alternative and is not in the interest of the river, people or the environment. However, the fact that none of the non-government members have endorsed the report speaks volumes about the credibility of the report.


The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations.

A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. The report gives a list of positive aspects of the IMG report on which there is a lot of scope for positive action, which the MoEF should initiate, while rejecting the report.


1. The Inter Ministerial Group (constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012) report has been submitted around April 22, 2013, but it is still not in public domain a month later. The report should have been promptly put in public domain as in the case of the HLWG report on WGEEP panel recommendation on the Western Ghats, which was made public the day after the submission of the report to MoEF. These comments[1] are based on the hard copy of the final report made available by a colleague[2].

2. The IMG final report has been endorsed by all members, except the dissent note by Rajendra Singh attached at Annexure X and a note on “alternate approach” from Sunita Narain, attached at Annexure XI. Shri Veer Bhadra Mishra, who was the third non-government member, expired during the period of functioning of the IMG group. The committee constitution was heavily loaded in favour of the government officers (ten of the fifteen members were government officials), so its independence was already in doubt. With none of the non-government members endorsing the report, the report has little credibility. This review tries to look at the report with an open mind.

3. While SANDRP as a group is critical of large, destructive and non participatory hydropower projects, it does not mean the group is against all hydropower projects. For example, if the projects were to be set up through a participatory and informed, decentralized, bottom up decision making process or if projects were to follow the recommendations of World Commission on Dams, such projects would certainly have greater public acceptance. That is not the case for any of the projects today.

4. The main TOR given to the IMG was to decide the quantum of environment flows for the upper Ganga basin rivers, keeping in mind the IIT (Indian Institute of Technology Roorkee, the report was basically from some individual of Alternate Hydro Electric Centre of IIT-R) and WII (Wildlife Institute of India) reports on cumulative impact assessment of the projects in these river basins. However, IIT (Roorkee) report has been found to be so flawed and compromised (for details see: that it should have been rejected by the MoEF and the NGRBA. Even the MoEF’s Expert Appraisal Committee on River Valley Projects has been critical of the IIT-R report. However, since a member of the IIT-R was present on the IMG, it may not have been possible for the IMG to take an objective view of the merits of IIT-R report. It is however, welcome that IMG has relied on WII rather than IIT-R report while accepting recommendations on e-flows. WII report was better in some respects, though still suffering from some basic infirmities. Moreover, to set up an IMG to decide on the course of action considering these two reports (and any other relevant reports) was compromised at the outset and was an invitation for further dilution of the environment norms, considering the track record of the most of the members of IMG.


Ganga river flowing through a channel, diverted for the 144 MW Chilla hydropower project

5. The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even

where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations. All of these points are further elaborated in this note.

6. Cancelled projects  & those on Bhagirathi Eco Sensitive Zone shown as under development Shockingly, even the projects like the Loharinag Pala, Pala Maneri and Bhairon Ghati that have been officially dropped are shown as under development by the IMG, see Annex VID! In fact in Table 12 and 13 IMG even calculates the reduction in power generation and increase in tariff at Loharinag Pala (among others) if the IMG recommended e-flows are implemented! The 140 MW Karmoli HEP on Bhagirathi, on a stretch that the MoEF has been declared as Eco Sensitive Zone, and on which the GOI has said no large hydro will be taken up, the IMG has actually suggested that the project can be taken up! The 50 MW Jadhganga project, very close to the Gangotri, is shown to be project under development by the IMG! These examples show how the IMG has played a role of supporter of the hydropower lobby.

7. Wrong classification of projects as under construction and under clearance projects IMG has divided the 69 hydropower projects in Upper Ganga basin (leaving our the Kotli Bhel 2, since it is on Ganga river and not on Bhagirathi or Alaknanda) in four categorie

s: Operating projects, under construction projects, under clearance projects and under development projects. It is here that IMG has done its biggest manipulation by classifying a number of projects as under construction when they are not and cannot be under construction. IMG classification of projects under clearances is equally problematic. IMG and even the “alternative View” by Sunita Narian says all these projects in first three categories can go ahead without any change, except the e-flows recommendations. This manipulation shows the stark pro hydro-bias of the IMG.


Dry Ganga river after the river is diverted for Chilla HEP. Photos by SANDRP

8. Manipulations about percentage length of river that the projects can destroy On the one hand, the IMG has recommended that “projects may be implemented so that not more then 60% of the length (of the river) may be affected.” There is no mention how they have arrived at this magic figure of 60%, what is the basis or science behind that magic figure. At the same time the IMG has said that if all the 69 projects were to be implemented than 81% of Bhagirathi and 65% of Alaknanda will be affected. Firstly these numbers are not correct if we taken into account the full length of the reservoirs and the bypassed river lengths by the hydro projects, in many cases the length of the submerged reservoir behind the dam has not been counted. Here we need to add the fact that the reservoir of the 70th Project on its list, the Kotlibhel 2 project will submerge parts of both Bhagirathi and Alaknanda rivers, which has also not been counted by the IMG. WII had to recommend 24 projects to be dropped, and even after that, WII assessed that 62.7% of the rivers would still be affected. However, the IMG has made no recommendation as to which of the projects need to be dropped (except vague review of the projects in Annex VI-D) to achieve that magic figure of 60%. This again shows how non serious IMG is, making this recommendation meaningless.

9. IMG double talk on distance criteria The IMG has said that “There is a clear need to ensure that adequate river length is available to meet the societal needs and River gets adequate time during its flow to regenerate itself” (emphasis added). This sounds good. But IMG has shown no will or interest in ensuring that this happens. In fact IMG exposes its understanding on this matter when it says, “the distance between two hydro projects should generally be such as to ensure that over-crowding is avoided”. What is over-crowding, how do you define it? This is a funny word IMG has used, not even bothering to define it. However, when it comes to implementation, dumping all these requirements, IMG has justified smaller distance (read zero distance) between projects where gradient is high. Now let us understand this: where gradient is high, if the distance left between the projects is less, will the time the river flows between projects be smaller or greater than if the gradient is low? Clearly, if gradient is high, for the same distance, the river will have less time to travel then if the gradient were low. It is in fact the time of free flow that is a crucial driving parameter for river to regenerate itself. So if the river were to have the same amount of time to flow between two points, with higher gradient, river will require more distance, not less. This again exposes the poor understanding of IMG members about science of the rivers.

The IMG even goes on to say that “distance will have to be smaller in view of technical requirement of the hydro power. This could result in continuity in some cases.” Firstly it is clear here again that IMG is basically catering to the hydropower lobby, it is completely non serious about the environmental issues. That is why after all those great sentences, it goes on to say that it is the technical requirement of the hydropower project that will be the decider! If technical requirements means no distance between two projects, then river can disappear, environmental issues do not matter! In case of many projects where the distance of free flowing river between projects is very little or nil and where the construction has not started or has not progressed much, there is today scope for change. For example in case of Vishnudgad Pipalkoti HEP on Alaknanda: the Full Reservoir Level of the VPHEP is same as the Tail Water Level of the upstream Tapovan Vishnugad HEP. This means that there is zero length of free flowing river between the projects. VPHEP does not have all the clearances and its construction has not started. Even for the upstream Tapovan Vishnugad HEP, the construction has not gone far enough and there is scope for change in both projects to ensure that there is sufficient length of free flowing river between the projects. IMG should have recommended change in parameters in this and other such cases, but it has done no such thing, it has shown no interest in any such matter! Even the “alternative approach” note in Annexure XI has not bothered to recommend such changes even while recommending 3-5 km free flowing river between two projects.

The IMG makes another unscientific statement in this context when it says, “With the recommendation of IMG for environment flow which will be available and which would have traveled throughout the diverted stretch, any significant gaps and large distance may not be required.” This is an unscientific, unfounded statement. Firstly where is the evidence that the environment flows that IMG has suggested would take care of the need for river to flow on stretches between the projects? Secondly, the need for river to flow between the projects to rejuvenate itself will also depend on the length of the rivers submerged by the reservoirs, and also depend on the biodiversity, the social, cultural and religious needs in addition to the ecological needs. By making such ad hoc unfounded statements devoid of scientific merit, the IMG has exposed itself.

While the IMG talks about the rich diversity of fish species and other aquatic diversity of the river, it has no qualms in saying that e-flows alone will address all the problems caused by bumper to bumper projects. As many including Government of India’s CIFRI (Central Inland Fisheries Research Institute) have concluded, Dams have been the primary reason for the collapse of aquatic diversity in India, not only because of the hydrological modifications and lack of e-flows, but also because of the obstruction to migration they cause, destruction of habitat during construction, muck disposal, trapping of sediments, destruction of terrestrial (especially riparian) habitats. But these concerns are not even considered by the IMG while saying that recommended e-flows will be able to solve all problems caused by bumper to bumper projects.

Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute
Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute

10. WII recommendation of dropping 24 HEPs rejected by IMG without any reason The IMG notes that WII has recommended that 24 hydropower projects of 2608 MW installed capacity should be dropped in view of the high aquatic and terrestrial biodiversity. However, IMG decides to dump this WII recommendation without assigning any reasons. This again shows the strong pro hydro bias of the IMG. WII report says that even after dropping these 24 projects, at least 62% of the river will be destroyed.

It is shocking that projects like Kotlibhel 1B and Alaknanda HEP, which have been rejected by WII and Forest Advisory Committee, is considered as “under development” by IMG, when they should have been rejected. While the IMG Report talks of unique biodiversity of the Ganga Basin, Valley of Flowers and Nanda Devi National Parks, it still supports projects which will be affecting these National Parks like the 300 MW Alakananda GMR HEP, which was also rejected by the WII and FAC (twice).

As a matter of fact, of the 24 projects that WII report recommended to be dropped, the IMG has shown 8 as under construction and 4 as “projects with EC/FC clearances”. This is sheer manipulation, in an attempt to make them a fait accomplice. Strangely, the “alternative approach” note in Annexure XI does not say anything about this manipulations and in fact says the projects in Annexure VI-B and VI-C can go ahead!

11. Non serious recommendation about keeping six tributaries in pristine state IMG (Para 3.70) “recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, Assi Ganga, Dhauli Ganga (upper reaches), Birahi Ganga and Bhyunder Ganga should be kept in pristine form and developments along with measures for environment up gradation should be taken up. No new power projects should be taken up in these River Basins.” This sounds good, but turns out to be like a joke, since firstly, IMG recommends construction of projects on these rivers that yet to be constructed! If these rivers are to be kept in pristine state then IMG should have asked for immediate stoppage of under construction projects and also time bound decommissioning of the operating projects on each of these rivers. In stead, the IMG report shows that projects are under construction on rivers like Assi Ganga (stage I and stage II projects each of 4.5 MW), Birahi Ganga (24 MW stage I project), Bal Ganga (7 MW stage II project listed in Annex VI B of IMG report, in addition to the 1 MW Balganga and 5 MW Balganga I project are also under construction as per IIT Roorkee report) and Bhyunder Ganga (24.3 MW stage II project) and IMG has (implicitly) recommended that these projects be allowed to continue, on rivers that IMG says it wants to remain pristine! Moreover, Rishi Ganga (13.2 MW project) and Birahi Ganga (7.2 MW) have operating projects on these rivers to be kept pristine! In addition, on Assi Ganga the 9 MW stage III project, is considered by the IMG as ready for development since it has some of the clearances.

Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu
Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu

The IMG has noted that 70 MW Rishi Ganga Stage-1 and 35 MW Stage II Project are under development on Rishi Ganga (IIT-R report mentioned another project on Rishi Ganga, namely the 60 MW Deodi project, it is called Dewali project by WII report; WII report also mentions 1.25 MW Badrinath II existing project on Rishi Ganga) and 24 MW Birahi Ganga-II project is under development. But the IMG does not recommend dropping of these projects.

So at least five of the six rivers that the IMG claims it wants to stay in pristine state are no longer pristine! They have multiple projects, most of them under construction or yet to be developed and the IMG has not said that any or all of these projects should be stopped, cancelled and those under operation be decommissioned in time bound manner. Even on Nayar, the sixth small tributary that IMG said should be kept in pristine condition has a 1.5 MW Dunao project under development by UJVNL, as per the UJVNL website. It’s clear how non serious IMG is about its own recommendation. IMG has included Dhauli Ganga (upper reaches) in this recommendation, but has not even bothered to define which stretch of the Dhauli Ganga this applies to, again showing the non-seriousness of IMG.

In para 4.22 IMG says, “Specifically, it is proposed that (a) Nayar River and the Ganges stretch between Devprayag and Rishikesh and (b)… may be declared as Fish Conservation Reserve as these two stretches are comparatively less disturbed and have critically important habitats for long-term survival of Himalayan fishes basin.” If IMG were serious about this, they would have also said that Kotli Bhel II project should be cancelled since it is to come in this very stretch.

IMG’s claim that not having any more projects on these six streams will mean loss of generating capacity 400 MW is also not backed by any sort of information or list of projects to be dropped, it seems IMG is in the habit of making such claims and does not feel the need to back them.

12. IMG on environmental impacts of Hydropower projects One of the key TORs given to IMG was “to make a review of the environmental impacts of projects that are proposed on Bhagirathi, Alaknanda and other tributaries of river Ganga and recommend necessary remedial action.” What has the IMG done about this TOR? IMG wrongly claims (Para 4.18), “The environment impact of proposed 69 hydropower projects has been considered by IMG.” It has done absolutely no justice to this very crucial TOR. First thing IMG has done in this regard is to dump the WII recommendation to cancel 24 hydropower projects, without giving any justifiable reasons. The IMG has produced a set of guidelines for the hydropower projects, which have almost nothing new, they are certainly not comprehensive or legally binding. They miss the most important issues of inadequate environment impact assessment, inadequate public consultation process, inadequate appraisal, lack of accountable governance and compliance.

What is required is certainly not new set of guidelines. MoEF already has a long list of environment and forest clearance conditions, environment management plans and manuals. But there is no interest, will or willingness to achieve compliance in MoEF. IMG is obviously aware of this state of affairs. Yet they have happily prepared a new set of five page guidelines just to show they have done something about this TOR. The “alternative approach” in Annex XI also has nothing to offer on this score.

Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan
Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan

13. Unwarranted conclusion about BBM methodology The IMG has said, “Considering environment, societal, religious needs of the community and also taking into account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirement”. This is good and needs immediate and credible implementation.

However, IMG says this will be applicable only “in situation where the required conditions are satisfied and resources, time and data are available.” The only basis for this conclusion by IMG is the fact that WWF took three years to do a study of environment flow requirements of three sites along Ganga involving large number of experts. This is clearly an unwarranted conclusion since WWF was only doing it first time and has much less resources at its disposal than the government have. By arriving at this unjustified conclusion that has no basis, the IMG implies is that BBM methodology is required and is justified, but Indian rivers including the Ganga won’t get it since IMG (wrongly) thinks that “required conditions” are not satisfied. This is clearly wrong and unwarranted conclusion. The BBM can and must be applied in all cases immediately, including for all existing and under construction projects and cumulative impact assessments.

Also, while stating multiple times that BBM for three locations for Ganga took three years, the IMG does not go into the details of what caused this delay. One of the important reasons stated by WWF itself is that required data was not made available to them, which contributed to the delay. So it is the government itself that was part of the reason for the delay in WWF study, and now IMG uses that delay to suggest that BBM is not practicable for Ganga! If the Government has the will to implement a more holistic methodology like BBM, it can be done and IMG conclusion is unwarranted and wrong.

14. Unjustified pro hydro bias of the IMG The IMG has shown its pro hydro bias at several places. At one place it says that a balanced approach needs to be taken as “It is important to see that the flows do not result in exorbitant cost of power which the people of the region may not be able to afford. This would make these power projects uneconomic and un-implementable”. Firstly, as far as people in immediate neighbourhood of the projects are concerned, history of grid connected hydropower projects in India shows that local and particularly the affected people almost never get power benefits from projects but they surely suffer all the negative impacts. IMG is wrong as far as this section of the people is concerned.

Secondly as far as the people of Uttarakhand in general are concerned, where all the projects in Upper Ganga basin are situated, the state would get 12+1 % of free power. Since most of the projects are in central or private sectors, the rest of the electricity would mostly go outside the state. As far as this 13% free power is concerned, since it is supposed to be free, there will be no impact of e-flows on the tariff of such projects, except some marginal reduction in quantum of power.

Lastly, is it the bottom line of the IMG that projects must be economic and implemented at all costs, by hook or by crook, as is apparent from the above quoted sentence? How can that be the bottom line of IMG considering its TORs? Moreover, by making the projects economic and implementable by hook or by crook, the IMG seems to be saying that irrespective of the social, environmental, cultural, religious and even economic costs, the projects must go on. Thus what IMG is suggesting is that artificially low cost electricity must be produced for the cities and industries irrespective of any concerns of costs and impacts on people, environment, future generations and rivers including the national river! This is clearly a plea to export the water, livelihood and environment security of the people for the short term economic prosperity of far off city dwellers and industrialists. Is this acceptable?

15. What is environment flow? IMG should have provided a definition of what is meant by river and environment flow. Since it is linked with enabling the river to perform its various roles and services in the downstream area, it cannot be just limited to water flow downstream. The downstream river also needs silt and nutrition from the upstream and the biodiversity and geomorphology in the river crucially depends on such flows of nutrition and silt. However, IMG has said nothing on this count.

Dry River at Uttarkashi Photo: Open Magazine
Dry River at Uttarkashi Photo: Open Magazine

16. Environment flows = aviraldhara? The IMG has said, “Environment flows in the river must lead to a continuous availability of water (aviraldhara) in the river for societal and religious needs.” This equation of aviral river with continuous flow of water is clearly flawed, since by that token even a pipeline has aviraldhara, but a pipeline is not the same as aviral River. For a river to be flowing aviral, continuous flow of water is a necessary but not a sufficient condition. A river means so much more.

17. No attempt at assessment of social, religious, cultural needs The IMG keeps talking about social, religious and cultural perspective and needs of the society from the river and so on. However, there has been no attempt to assess what exactly this means in terms of river flow, quality, content of flow across the time and space. More importantly, how is all this to be decided and who all are to be involved in the process. IMG just assumed that this has already been done by IITR and WII, which is flawed assumption, since WII or IIT-R has clearly not done any such assessment. So in stead of giving standard monthly flow release percentage across the rivers (releases to vary based on daily flow variations, this recommendation of daily changing flow is certainly an improvement from IMG), IMG should have asked for actual assessment of such needs across the rivers and IMG should also have given the process for arriving at such decisions. But while deciding social, religious or cultural needs, the IMG sees no role for the society, religious groups or cultural institutions.

In this context it may be added that the IMG has also not taken note of the legal stipulations like the order of the Allahabad High Court that says that no project can divert more than 50% of river flows existing at the point of diversion.

DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia
DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia

18. IMG recommendation during High Flow Season (May-Sept) The IMG has recommended 25% of daily uninterrupted (no clear definition is given how this will be arrived at) flow, with the stipulation that the total inflow in the river would not be less than 30% of the season flows. This is same as 30% of mean seasonal releases recommended by WII (para 8.3 of WII report, para 4.11 of IMG report) and also used by even Expert Appraisal Committee on River Valley Projects currently. The recommendation of releases based on daily flow is an improvement compared to the earlier situation, but its implementation is in serious doubt considering the weak compliance requirements from IMG.

It should be added here that IMG has not mentioned how the environment flow will be released. Just dropping it from the top of the dam won’t help, the flow must be allowed to flow downstream in an environmentally sound manner that is as close as possible to the flow of the river and helpful for the biodiversity in the river to link up from downstream to upstream and vice versa. Moreover, while deciding flows, IMG has largely followed the recommendations of the WII. However, WII conclusion of classifying Upper Ganga basin under EMC class C itself is flawed. IMG should have corrected this flaw, before concluding on environment flows.

19. IMG recommendation during Lean Flow season (Dec-March) The IMG has recommended (Para 3.48) release of 30% of daily uninterrupted river flows, this will go up to 50% where the average monthly river flows during lean season (Dec-March) is less than 10% of average monthly river inflows of the high flow season (May-Sept) and to 40% (however, Para 3.51 does not mention this 40% norm) where this ratio is 10-15%. While this is an improvement in the current regime, this remains weak considering that IMG has not done project wise calculations where 30, 40 and 50% stipulation is applicable, which it could have easily done at least for the existing and genuinely under construction projects.

20. IMG recommends lower flow for India’s national river compared to what India promises Pakistan in Jhelum basin The IMG has recommended 30-50% winter flows for all projects as described above. This in case of a river everyone recognizes as the heart and soul of India, a river that has such an important social, religious, spiritual significance and it has been declared as the national river. Let us compare this with what e-flows Indian government has promised to Pakistan downstream of the Kishanganga Project in Jhelum river basin in Kashmir. In a case before the Permanent (International) Court of Arbitration (PCA), Indian government has assured that India will release more than 100% of the observed minimum flow from the dam all round the year, and now in fact the government is considering even higher than 100% of the observed minimum flow all round the year. The PCA is yet to decide if what India has proposed will be sufficient or more water flow is required. So, as against the assurance of more than 100% of minimum flow at all times on another river, for the river flowing into another country; for the national river Ganga, for India’s own people and environment, all that the IMG recommends is 30-50%. On most winter days, KishengangaRiver downstream of the hydropower project, flowing into Pakistan, thus will have higher proportion of its daily flows than what Bhagirathi or Alaknanda will have.

Dry Ganga at Haridwar in August 2012 Photo: SANDRP
Dry Ganga at Haridwar in August 2012 Photo: SANDRP

21. Monitoring and compliance of Environment Flows The IMG has said that effective implementation is cardinal part of its recommendations. This is good intention. However, by asking the power developer to be responsible for the implementation, the IMG has made the recommendations ineffective. IMG has chosen to ignore the fact that there is clear conflict of interest for the power developer in assuring e-flows, since the e-flows would reduce the power generation and profits of the developer. Its faith in IT based monitoring is also completely untested and there is no evidence to show that such monitoring will be free of manipulation. Secondly, to ask the MoEF to do annual review, that too only for first five years ignores the track record of MoEF in such matters where MoEF has shown no will, capacity or interest in achieving post-clearance compliance of the environment laws of the country. Thirdly, to require this only for projects above 25 MW shows the lack of understanding of IMG as to how important the smaller streams are for the water, ecology and livelihood security of the community in hills. Its recommendation of monitoring by an independent group is welcome, but lacks credibility in the absence of sufficient involvement of local community groups in such a mechanism.

22. Baseless assumption of low water requirement for fish in the Himalayan region The IMG has assumed that in the Himalayan region, the water requirement for fish in the river is less and hence the rivers here will not require as much water as the rivers do in the plains. This is completely unscientific, flawed and baseless assumption. The amount of e-flows needed has to be assessed not only based on the requirement of fish (IMG has not done even that assessment), but entire aquatic and connected terrestrial biodiversity across the seasons, in addition to the water needs of a river for providing the social and environmental services.

23. Suggestions that are bad in Law The IMG report shows several projects as “Under Construction” (Annex VI B) category, when they do not even have statutory clearances and hence cannot even legally start the work. This is a ploy to make these projects a fait accomplice when these projects are perfectly amenable to review and rejection since the project work has not started. In fact to categorise such projects without having all the statutory clearances (e.g. Vishnugad Pipalkoti does not have forest clearance) as under construction project is plain illegal.

24. Wrong representations The IMG has shown several projects in Annex VI C, as “Hydropower projects with EC/FC Clearances and others”, basically a ploy to push the projects that do not even have all the statutory clearances. None of these projects have all the statutory clearances and are certainly not in position to start construction and hence these projects are the ones where dropping of the projects or modifications in dam location, dam height, FRL, HRT length, e-flows, capacities etc are still possible. But IMG did not do it for any of the projects. As mentioned above, four of these projects have been recommended by WII to be dropped, and IMG should have recommended dropping these or should have categorized them as ‘to be reviewed’.

25. No mention of impact of peaking operation of hydropower projects The IMG has missed many crucial environmental impacts. One crucial one that it has missed is the issue of peaking operation of hydropower projects on the downstream people, environment, flood plains, geo morphology, biodiversity and other aspects of the river. This is very important since one of the Unique Selling Proposition (USP) of hydropower projects is supposed to be that they can provide peaking power. However, peaking operation means sudden changes of huge magnitude of flows in downstream river, having far reaching impacts including those on safety of people, flood plain cultivation, impacts on cattle and property, impact on ecology, amongst many others. The IMG has completely missed this, which is very strange since this is a huge issue being taken up by people and campaigns in the North East against large hydropower projects there.

26. IMG cannot see through poor work of IIT-R It is well known that IIT-R report on Ganga basin study is of poor quality. In the IMG report there is an attempt to respond to only a couple of the criticism of IIT-R report, but IMG could not even see through the wrong facts presented by IIT-R report. For example, IMG report says, “The requirement of flushing during monsoon is not required in both rivers as all hydro projects except Tehri reservoir are run of river types where silt is not stored.” This is completely wrong. All the projects, even if run of the river, have storage behind the dam where the coarser silt will settle down and will need to be flushed out periodically. The dams are being provided with bottom sluices to facilitate this. A quick perusal of the EIA reports of some of the hydropower projects in the region shows that Vishnugad Pipalkoti, Srinagar, Kotli Bhel 1-A, Kotli Bheal 1-B, to name only a few all have proposed to provide bottom sluices for periodic release of silt accumulated behind the dam. Thus the contention that most projects do not need flushing is wrong. In any case, for all projects, the de-silting chambers would be releasing silt laden water and there is no attempt to assess the cumulative impacts of such actions. IMG’s attempt to provide scope for some defense for the IIT-R has clearly back fired on IMG! Moreover, even in case of Tehri, the biggest project in the region under review, IMG report has nothing at all, about it social, environmental impacts and performance, about its power generation, irrigation, water supply, flood control performance or even its silt management performance.

The contention that all projects except Tehri are ROR is entirely wrong and misleading. Even as per the WII report, out of the 69 projects, a whopping 13 projects are storage projects. This includes the biggest and most problematic projects like Srinagar, KotliBhel IB, KotlibhelIA, Koteshwar, Vishnugad Pipalkoti, Devsari, etc.

27. IMG on Srinagar HEP and Dharidevi Temple The IMG was also asked to “review the impacts of the Alaknanda (GVK) Hydro Power Project on flow of the River and the issues related to the temple relocation.” The IMG gave an interim report on this issue, which was so disappointing that Rajendra Singh and Late Shri Veer Bhadra Mishra both members of the IMG, gave a dissenting note, Rajendra Singh also suggested shelving the project. The IMG rejected the suggestion of its own members without giving any justifiable reasons.

DhariDevi Temple threatened by submergence
DhariDevi Temple threatened by submergence

28. Time bound action plan for E-flows from existing projects The IMG says that the existing projects should also follow the suggested e-flows and this should be achieved in three years (Para 3.52). However, IMG should have been more clear about the role of different agencies (MoEF, state government, developers, state electricity regulatory commissions and power purchases) and what is the legal backing such a step will have.

29. Lack of understanding of conflicting projects and public protests The IMG report, Annex VI B shows 12.5 MW Jhalakoti (wrongly) as under construction project. In fact the Jhalakoti project has been recommended by WII to be dropped. The IMG seems to have no clue that Jhalakoti project is being strongly opposed by the local communities and no work has started on the project. The under construction status given by IMG for this project is clearly wrong. If the Jhalakoti HEP comes up then the existing 40 KW Agunda micro HEP will no longer be able to function. Many of the other projects including the Devsari and Vishnugad Pipalkoti HEP are also facing strong opposition, but the IMG has not taken note of these or any of the social impacts of the projects in the Upper Ganga basin.

Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan
Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan

30. IMG on TOR on pollution abatement in Ganga It is good to see that IMG has suggested that “all users must be forced to plan for water needs based on what the river can spare, not what they can snatch.” However this should not mean an advocacy for more big dams and storages on the rivers. This seems to be the case when we read the IMG recommendation that says, “The government then has a choice to build storages to collect monsoon water for dilution within its territory or to ‘release’ water to rivers and make other choices for use in agriculture, drinking or industry”. Storages can come in many forms and sizes and IMG should be careful not to recommend more big storages on the rivers. The suggestion that “there will be a clear conditionality in Central government funding, which is matched to the quantum of ecological flow released by the state in the river” is welcome. Linking of JNNURM-II and National Mission for Clean Ganga to the above norm, incentivisation of use of innovative bioremediation and in-situ drain treatment are also welcome. However, IMG has shown no interest in understanding or tackling the real problem in river pollution: Lack of participatory, democratic governance in urban water and pollution control regime.

IMG has recommended in Para 6.7(i), “Ecological flow will be mandatory in all stretches of the river.” This is welcome. IMG goes on to suggest some norm for the urbanized stretches of rivers, but no norms are suggested for the non urbanized stretches of river in the lower river basin.

31. Report does not reflect the discussions in IMG? The dissent note by Shri Rajendra Singh, a member of IMG says that on several aspects, IMG report does not reflect what transpired in the IMG meetings. This is a very serious charge that puts a big question mark on the IMG report and its recommendations, particularly since Rajendra Singh is the lone independent voice in the IMG after the sad demise of Shri Veer Bhadra Mishra[3].

32. Incomplete project list The IMG does not seem to have full information about the existing, under construction and planned hydropower projects in the Upper Ganga basin in Uttarakhand. Some of the projects not listed in the IMG report include:

A. Operating projects under 1 MW: According to the website of UJVNL (Uttarakhand Jal Vidhyut Nigam), the state has 12 such projects with total capacity of 5.45 MW, see for details: Most of these projects are in Upper Ganga basin, though it is not clear how many.

B. UJVNL has larger list of schemes under development by UJVNL including in the Upper Ganga basin, not all of them are included in the IMG list, see:

C. Private sector has been given license for a large number of hydropower projects, not all the projects of Upper Ganga basin here are on IMG list, see for full list of projects being developed by IPPs in Uttarakhand:

D. There is another “full list” of hydropower under development in Uttarakhand including sub-MW size projects, see: Some of the projects here in Upper Ganga basin do not figure on IMG list.

One would expect better information base of the IMG than what they have shown.

33. No specific recommendation to save the prayags There are five holy prayags (confluence of rivers) along Alaknanda river in Uttarkhand, including Deoprayag, Vishnuprayag, Karnaprayag, Rudraprayag and Nandprayag.

Vishnuprayag has already been destroyed by the 400 MW existing Vinshnuprayag HEP of Jaiprakash Associates, rest would be destroyed by the projects listed by IMG. The IMG keeps talking about cultural importance of the rivers, but has not said a word about how it plans to save these culturally important confluences and how it plans to rejuvenate the Vishnuprayag already destroyed.

34. “Alternative View” in Annexure 21: How much of an alternative is it? In Annexure XI of IMG report, a note authored by one of the IMG members, Sunita Narian of Centre for Science is given, it is titled: “TOR (ii): Alternative View: Environment flow”. The Annexure opens with the line “The recommendations of this IMG report are not acceptable.” It is not clear if this sentence applies to all the recommendations of the IMG or about environment flows mentioned in the title or it applies to TOR (ii) that applies to all environmental aspects, not just environmental flows. The Annexure also deals with some issues besides environment flows, so one assumes this “alternative view” is about environmental aspects of hydropower projects.

The Annexure XI seems to give an impression that, principles of distance between dams, ecological flow and limit on % of river than can be “affected” will lead to “sound hydropower development, balanced for energy and environment”.

One of the three principles listed in the note says: “Distance between projects: 3-5 km”. The note does not say how this distance has been arrived at or how this distance is to be measured, the least the note should have mentioned was that this is not distance between projects but distances of flowing river between the Tailwater level of upstream and full reservoir level of downstream project.  No elaboration is given about this criterion at all. Most importantly, there is not even any attempt to apply this criterion to the projects that IMG is supposed to look into. On the contrary, the note says that “The projects under construction can be built” (point 7(ii)) and “projects with EC and FC clearances can be taken up for construction” (point 7(v)). So in fact there is absolutely no application of the criterion to the projects on hand. The conclusion that this is half baked and non serious criterion is inescapable.

Another of the three principles listed in Annexure XI is: “Maximum intervention allowed in river length: 50-60 per cent”. Again there is no elaboration as to how these figures are arrived at, why there is a range, what is meant by “intervention”, which lengths it will apply and so on. Again, the note does not bother to apply this criterion to the rivers under review and actually says in point 7(ii) and 7(v) described above, that projects in Annexure VI (B) and VI(C) can go ahead without even checking if in that case this criterion will be violated or not. Again the conclusion that this is also a half baked and non serious criterion is inescapable.

The whole of the Annexure XI is basically devoted to application of the third principle: “Ecological flow regime: 30/50 per cent (high and lean period)”. About this, the annexure says: “The engineering design of the uninterrupted flow would take into account the need for sediment and fish transfer”, not clear how this will be achieved. The Annexure does not suggest any new measure of achieving compliance with its recommendations. The note mentions “design changes incorporated to maximize energy generation during high discharge season” but does not elaborate what these would mean.

Annexure XI says that IIT-R tried to suggest that e-flows must be low and in this effort did “big and large manipulation of data”. This is good. However, it would have been better if the full data and notes from IIT-R were annexed here to illustrate how the manipulation was done.

Bullet point 3 in Annexure XI reads, “It is important to consider that water of a river is similar to the coal or gas as raw materials used in thermal plants”. This statement needed to be qualified that the impact of taking out coal or gas from its source is not comparable to taking out water from the river, the latter’s impact is much more severe, since river is not equal to just water flowing in it.

Since Annexure XI does not raise objection to any other conclusions and recommendations of the IMG except the three principles mentioned above, it would not be incorrect to assume that author agrees to the rest of the IMG report. This, when taken together with the fact that at least two of the three principles in the alternative view note have not been applied to the projects under review, leads to the conclusion that there is not much of an alternative in “alternative view”  note and this won’t help the cause of the river, people, environment or even sustainable and sound development.

35. Conclusion A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. One of the positive aspect of this report is that possibly for the first time heads of central organizations like CWC and CEA have sat with some non government members to discuss some important subjects that have remained contentious for these official agencies.

However, as noted above, on most positive aspects, while IMG has been less than sincere, there is a huge potential to take the environment flow movement forward.

The MoEF and NGBRA should, considering all the above points, take some positive aspects forward. Some of the positive retrievable aspects of the IMG report include the following, on each of which there is a lot of scope for serious action:

  • Ensuring at least 50% E-flows in non monsoon months in all rivers.
  • Keeping some rivers in pristine form, stopping all ongoing and planned projects on suggested rivers and time bound decommissioning of existing projects on such rivers that are to be in pristine form. This should be immediately implemented on the rivers recommended by IMG and also in other selected rivers in all river basins.
  • Rejecting planned and under construction projects which have high impact on terrestrial and aquatic biodiversity, as per score developed by WII Report as well as projects which irreversibly impact spiritual and religious places like rivers, prayags, places of worship and ghats.
  • Give deadline of one year and maximum of two years for all the existing dams, diversions and hydropower projects across the Ganga basin (& other rivers) to achieve the suggested e-flows with clear inbuilt mechanisms for monitoring and compliance with participation of river basin communities, as a first step.
  • Accepting BBM as the standard methodology for E-flows assessment, e-flows to mimic the river flows and involving communities as an important stakeholder in this methodology.
  • Ensuring Aviraldhara.
  • Ensuring rivers have adequate free flow time between projects to regenerate itself. Mandating at least 5 km free flowing river between any two projects as an immediate measure pending site specific studies and reviewing all under construction, under clearance and under development projects in the basin keeping this in mind.
  • Releases based on daily flows rather than monthly or seasonal averages in all rivers. Define uninterrupted flows to arrive at uninterrupted daily flows.
  • Monitoring of e-flows and other environmental compliance by independent group involving at least 50% of the monitoring group from local communities.
  • Assuring that e-flows through well designed fish passages (taking consideration of Guideline 7, Annex IX).
  • The IMG has recommended that a technical group may be made to study alternatives including the alternative suggested by Prof Bharat Jhunjhunwala that only partial dams across rivers may be allowed. This should happen expeditiously. The proposed projects should be stopped till this is done.

Himanshu Thakkar (

South Asia Network on Dams, Rivers & People (

Endorsed by:
EAS Sarma, Former Union Power Minister, Visakhapattanam,

Vimal Bhai, Matu Jansangathan, Uttarakhand,

Malika Virdi, Himal Prakriti, Uttarakhand,

E Theophilus, Himal Prakriti, Uttarakhand,

Ramnarayan K,  Save the Rivers Campaign Uttarakhand,

Dr Latha Anantha, River Research Centre, Kerala,

Parineeta Dandekar, SANDRP, Pune,

Samir Mehta, International Rivers, Mumbai,

Tarini Manchanda, Independent film maker, Delhi,


Current state of our National River at Haridwar  Photo: SANDRP
Current state of our National River at Haridwar Photo: SANDRP

[1] The author is thankful to Parineeta Dandekar, Shripad Dharmadhikary and Samir Mehta among others for providing comments on earlier drafts.

[2] Prof Bharat Jhunjhunwala provided the copy.

[3] One of the members of the IMG started discussing the report in public domain through her writings even before the report was in public domain, see: and This can create misleading impression about the report, when the readers do not have benefit of cross checking what the report is actually saying. The articles in any case are full of serious errors, for example it said: “Most of the proposed projects are run-of-the-river schemes, which are seemingly benevolent as compared to large dams”, not understanding that EACH of the so called run of the river schemes ALSO involves a dam, most of them are large dams as per international definition. It incorrectly said, “Run-of-the-river projects, which used flowing water as the raw material for energy”, in reality NONE of the so-called ROR projects generate power from flow of the water in the river, they all dam and divert the water away from the river to produce power. It also tried to dilute the impact of the projects on rivers (akin to killing of rivers) by saying projects “affect” rivers. It misleadingly wrote, “The hydropower engineers argued for 10 per cent e-flow” without mentioning that the EAC of MoEF is prescribing 20-30% of mean season flows. The article claimed that figures of water flow and tariffs were modified by IIT-Roorkee, but in the entire IMG report, (except the Annexure XI written by author of the articles), there is no mention of any of these. The article talks about engineers’ claims that “this source provides power during peak demand hours”, but as we noted above the IMG has not even looked at the impact of peaking generation. There is not even an attempt to understand how much of the current generation from hydropower projects is happening during peaking hours, or what is the generation performance of hydropower projects, issues that SANDRP has been raising for many years.

Cumulative Impact Assessment · Dams · Environment Impact Assessment · Hydropower · Ministry of Environment and Forests · Western Ghats

Comments on HLWG Report submitted to Ministry of Environment and Forests

This post is based on a submission made by SANDRP and our colleagues on the HLWG Report on Western Ghats. 20th May 2013 is the last date to submit comments on this. Comments need to be sent to: We request groups and individuals to make as many submissions as possible.

Comments on HLWG Report with a focus on Water issues

Date: May 20, 2013



Mrs. Jayanthi Natarajan

Union Minister of State (IC)

Ministry of Environment and Forests

Government of India



Dr. V Rajagopalan


Ministry of Environment and Forests

Government of India



Dr. Amit Love,

Deputy Director,

Ministry of Environment and Forests



Dear Mrs. Jayanthi Natarajan and Dr. Rajagopalan,


SUB: Comments on the High Level Working Group Report with respect to water sector

This is in response to announcement posted on MoEF website about submitting comments on the HLWG report under the Chairpersonship of Dr. Kasturirangan. These comments mainly deal with water in Western Ghats: One of the most critical issues for Western Ghats States.

A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP
A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP

Unfortunately, we have to note that recommendations of the HLWG Committee in response to WGEEP Report as well as some of HLWGs omissions and commissions are detrimental to the well-being of rivers, wetlands and dependent communities in the Western Ghats and hence, for related sectors like ecology, water supply, irrigation, hydropower, etc. This is elucidated in the following points:

  1. HLWG does not comment on any other issue related to water except hydropower:

While the Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamilnadu are facing multiple issues with respect to rivers, drinking water, irrigation, loss of biodiversity and livelihoods, dam-induced displacement, etc., the only issue HLWG report has commented upon is Hydropower. The WGEEP report has dealt with a number of issues related to the water sector from democratic community driven bottom up governance, watershed development, opposition to large dams in ESZ I and II, drinking water, fisheries, etc. However, the HLWG does not comment on any of these recommendations of the WGEEP, nor does it offer its own position on these. This is a serious lacuna in the HLWG Report.

In the absence of such recommendations, we request that MoEF adheres to WGEEP recommendations.

Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP
Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP
  1. HLWGs recommendations about Hydropower are ad hoc, unscientific and misleading
  1. HLWG claims that all Hydropower is “renewable and clean.”

This is a completely incorrect statement and it’s surprising to see that it comes from HLWG. The world over, the myth of Hydropower as clean source of energy has been busted.[1],[2] Hydropower projects have huge impacts on environment, ecology, forests, rivers, biodiversity and livelihood security of the people. Studies have proved that methane emissions from reservoirs formed by hydropower dams in tropical countries can have significant global warming potential, methane being about 21 times more potent global warming gas than CO2. Dams emit methane at every draw down.[3] With tropical forests in the Western Ghats (WG) under submergence and otherwise destruction by such projects, this threat is even more serious. Already WG has some of the biggest hydropower plants in the country including the Koyna, Bhandardara, Ghatghat HEPs and three Tata HEPs in Maharashtra, Linganmakki, Gerisouppa, Bhadra, Tungabhadra, Upper Tunga, Talakalale, Kabini, Harangi, Chakra, Supa, Varahi, HEPs in Karnataka, Idukki, ldamalayar, Lower Periyar, Poringalkuttu, Sholayar HEPs in Kerala and Bhavani HEPs in Tamil Nadu. All these projects have not only contributed to greenhouse gas emissions, but have also adversely affected communities, forests, rivers and ecosystems in Western Ghats. There are numerous pending cases of rehabilitation from these dams (for example Koyna in Maharashtra) till date involving tens of thousands of people and communities in many areas are still suffering from erratic water releases from these projects (downstream communities near Jog Falls d/s Linganmakki).

Hydropower dams in WG are in many cases transferring water across the basin for power generation, making it unavailable of the original basin and its inhabitants (For example:  Interbasin transfers from Koyna and Tata Hydropower dams in Maharashtra). Every hydropower project has finite life. Thus, for the basin dwellers and everyone else, Hydropower not much renewable either.

 HLWG is not justified in giving a ‘clean and renewable’ certificate to hydropower.

Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP
Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP


  1. HLWG allows Hydropower projects in ESAs while not looking at performance of existing projects

While the WGEEP did not allow large dams and hydropower projects in ESZ I and II, HLWG has allowed hydropower projects in its demarcated ESAs. This is unacceptable. Western Ghats are already ravaged by dams and at least the areas of high biodiversity value should now be protected from the same onslaught. But the HLWG has rejected WGEEP recommendations about this. While doing so, they have not looked at the performance of the existing HEPs in WG. SANDRP has been studying performance of HEPS in India for some time now based on generation data from Central Electricity Authority. The performance of existing hydropower plants in WG is dismal as can be seen below:

  • In Koyna Basin, the per MW generation in 2010-11 has dropped by a huge 56.79% from the highest per MW generation achieved in the year 1994-95.[4]
  • In Kali Nadi projects, the per MW generation has dropped by 46.65% from the highest per MW generation achieved in 1994-95[5]
  • In Sharavathi Basin projects, per MW generation in 2010-11 has dropped by 37.60% from the highest per MW generation achieved in the year 1994-95[6]
  • Same situation is true for most other hydropower projects.
  • Most of these projects are performing far below the level at which the projects were given techno-economic clearances.
  • There is no assessment as to how much of the generation from such hydropower projects is during peaking hours. Nor is there any attempt at optimising the peaking power from these projects.

It is clear that there is huge scope to make the existing projects more efficient, rather than destroying ESAs in WG with more projects.

We request that in line with WGEEP report, large dams should not be permitted in ESAs of Western Ghats.

  1. Recommendation about mitigating impacts of Hydropower are extremely weak
  • The HLWG has recommended 30 % of lean season flow as the minimum flow throughout the year as a conditionality for allowing hydro power projects in the ESA. This is contradictory to the recommendation for ecological flows by the HLWG.  Ecological flows means trying to mimic the natural flow regime in the river as far as possible and that would include arriving at different seasonal flows based on studies and consultation with the river communities and other stakeholders, using the Building Block Methodology which even the Inter Ministerial Group on Ganga Basin has said is the most appropriate for India. Moreover, the IMG has recommended 50% releases in lean season flows, applicable for all existing projects. MoEF should accept these norms immediately for all existing projects.

The MoEF should be recommending ecological flows / environmental flows as in the WGEEP report and not minimum environmental flows and this should be determined through holistic methodologies like Building Block Methodology and local participation.

  • The HLWG recommendation of 3 km minimum distance between dams is totally ad hoc, arbitrary and hence unacceptable. Firstly, the HLWG should have mentioned min 3 km of flowing river between projects. The minimum distance is river specific and would depend upon a basin level study of the river including the altitudinal profile of the river, the riparian forest status, the aquatic habitats and biodiversity, the present dependability and many such criteria. More significantly, the cascade hydropower dam menace which is destroying rives in Himalayas need not be replicated in western ghats. We would like to reiterate that no large dams should be allowed in the ESA of WG.

The MoEF should recommend for arriving at river specific studies while accepting 5 km of free flowing river between projects as minimum distance of free flowing river between projects. The best case is not to allow any further large dams in Western Ghats.


No flows in Sharavathy downstream Linganmakki  Dam and Jog Falls. Photo: SANDRP
No flows in Sharavathy downstream Linganmakki Dam and Jog Falls. Photo: SANDRP


  1. The HLWG does not stress the need for Environmental Clearance for Mini hydel Projects

Hydro projects less than 25 MW are currently exempt from Environmental Clearance due to a dangerous omission in the EIA Notification 2006. WG is currently facing a severe threat due to a flood of these unplanned cascades of Mini Hydel Projects. Ecosystems and communities in rivers like Netravathi, Kumaradhara, Krishna and Cauvery are facing impacts of these projects, many of which are fraudulent.[7] Netravathi has more than 44 mini hydel projects planned and under operation. Kerala has plans to set up  around 100 mini Hydel projects on its rivers. The threat of these projects on river systems in Western Ghats is so high that in March 2013, the Karnataka High Court, has banned any new mini hydel projects in Karnataka Western Ghats[8].

WGEEP had recommended no mini hydel projects in ESZ I and II. HLWG has not done this. While the HLWG makes a rather vague statementThere is a need to redesign and reevaluate small hydropower projects – below 25 mw as these often have limited impact on energy generation and can lead to huge impacts on ecology’, it has not recommended that these projects should need an EIA and EC process, like it has said for Wind Energy. This is a very serious omission. SANDRP and many organizations have written about this to the MoEF several times.

The MoEF should amend the EIA Notification 2006 and include all hydel projects above 1 MW in its purview.


Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
  1. The HLWG does not stress the need of Environmental Clearance (EC) for Drinking Water and Industrial supply dams

HLWG has not looked at water as a sector, but has only confined itself to hydropower. This has resulted in several loopholes. Many dams are being constructed in Western Ghats for Drinking Water and Industrial water supply. These are also exempt from EC process as per the EIA Notification 2006. Dams like Kalu, Shai, Balganga, Khargihill, Pinjal, Gargai are set to submerge more than 6000 hectares of forest in ESAs and Protected Areas in Northern Western Ghats in Maharashtra.

WGEEP Report had recommended no large dams in ESZ I and II, but the HLWG does not talk about these dams at all. Their impacts on WG forests and communities are entirely ignored. This is another serious lapse of the HLWG report.

The MOEF should amend the EIA Notification 2006 to include all large dams, irrespective of the purpose, including drinking and industrial water supply dams in its purview. No large dams should be planned in ESA of Western Ghats.


Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP
Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP
  1. HLWG does not recommend eflows from existing projects

Several hundreds of Irrigation, water supply, hydropower dams have transformed the nature of rivers and dependent communities in Western Ghats. While the WGEEP Report mentioned maintaining eflows from existing projects, the HLWG does not make any recommendation for eflows from existing projects.

Hydropower projects in Karnataka like Kali, Linganmakki have affected communities and ecosystems in the region, have driven some species to extinction. There is an urgent need to restore eflows in all WG rivers.

The MoEF should recommend that eflows should be assessed with holistic and participatory methodology like BBM and recommend e-flows for all dammed rivers in Western Ghats with time limit of one year.

  1. HLWG does not apply its mind to dam decommissioning

The HLWG has chosen to ignore the recommendations on dam decommissioning. While the states have rejected the recommendation the MoP (Ministry of Power) and Central Electricity Authority has noted that dam decommissioning in a phased manner is worth considering.

There are several irrigation and hydropower dams in the Western Ghats which are severely underperforming or incomplete after two decades, or more than 100 years old, and/or unsafe. For example, several experts have opined than large irrigation projects in Konkan region of Maharashtra are severely underutilized. Tillari Interstate Project between Maharshatra and Goa which has come up affecting a wildlife corridor and which has still not rehabilitated its affected population, has a created irrigation potential of 7,295 hectares in Maharashtra of which farmers are utilizing just 162 hectares, according to the Govt Of Maharashtra’s 2012 White Paper on Irrigation Projects in Maharashtra. This underlines the redundancy of large irrigation projects in the WG.

The HLWG had an opportunity to relook at such projects, which it has not done. The HLWG could have noted that the state governments and the MoEF and MoP should start the process of evolving parameters / criteria towards the process of dam decommissioning.

The MoEF may please recommend the same.

Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror
Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror


  1. HLWG does not recommend free flowing rivers for WG

Rivers in Western Ghats are repositories of biological, ecological and cultural diversity. Rivers in WG harbor high endemism and diversity in freshwater fish. They also house several Sacred groves at river origins, river fish sanctuaries, etc., protecting rivers and fish. The freshwater biodiversity remains the most fragmented among all biodiversity and HLWG has taken no note of this state and further risks that freshwater biodiversity faces. The WGEEP had wisely followed a graded approach in tune with the ecological connectivity of river ecosystems. ln the HLWG approach, stretches of rivers would flow out of the natural landscape into the cultural landscape which is open to indiscriminate development and the chance for their restoration or protection would be completely lost out. A river cannot be protected in pieces like this.

Looking at the pressures from dams and water abstractions, there in an urgent need to conserve ecologically, culturally and socially important rivers in their free-flowing condition. This approach is well accepted globally and several countries have created specific legislations for protecting free flowing rivers[9]. It seems that the IMG Committee on Upper Ganga, in which Ms. Sunita Narain (Member of Kasturirangan Committee), was also a member has recommended that some six tributaries of Upper Ganga basin should be kept in pristine state. While rejecting WGEEPs recommendation about dam decommissioning or dam free rivers in the ESZs, HLWG has not recommended keeping even a single river in Western Ghats in its free flowing condition.

MoEF should identify ecologically, culturally and socially important rivers, based on community and ecological knowledge and conserve Heritage Rivers of Western Ghats in their free flowing condition for the current and future generations.


Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP
Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP
  1. HLWG allows Inter basin transfers in Western Ghats, without any justification or studies

The HLWG has agreed to inter basin transfers toeing the claims of some of the states. There are ample instances of failed interstate – inter basin transfers in the Western Ghats rivers which have turned into permanent scenes of conflicts like the famous Mullaperiyar,  Parambikulam Aliyar, Siruvani interstate inter basin transfers between Kerala and Tamil Nadu. The HLWG while acknowledging the need for ‘ecological flows assessment’ in rivers has failed to note that in all these inter basin transfers, the river / tributary has been completely diverted and has lost its ‘ecological flows’. The HLWG could have recommended a cumulative impact assessment of the existing inter basin transfers which would reveal the ground reality.

HLWG seems to have accepted the contention of states like Maharashtra: “This (stopping IBT) would be a problem, they explained, as many regions of the Western Ghats lie in the rain shadow area and need water to be diverted for irrigation and drinking.”

Reality is that, ALL the interbasin transfers happening in Maharashtra currently (through Koyna and Tata Hydro power projects, an amount more than 4 Billion Cubic Meters Annually) are transferring water FROM the rain shadow area of Krishna and Bhima basins TO water surplus regions in Konkan. If HLWG was concerned about water supply for rain shadow regions, it would have at least recommended that this transfer from deficit area to high rainfall area be immediately reviewed and reversed in a time bound manner. It has chosen not to, showing its complete ignorance of ground reality or its completely pro government and pro vested interests bias.

The MoEF should retain the recommendation for no more inter basin transfers as in the WGEEP report and ask for immediate review of transfer of water from deficit basins to high rainfall areas. 


  1. HLWG allows hydro projects in first and second order streams

The HLWG has not said no to hydro power projects in first and second order streams in ESA. Meanwhile the MoP, CEA and WAPCOS all agree that hydro power projects should not be permitted in these highly ecologically sensitive areas which are the ‘origin’ of Western Ghats Rivers.

The MoEF should retain the recommendation for no run of the river schemes in first and second order streams as in the WGEEP report.

  1. HLWG offers no comments of on several water sector recommendations of WGEEP which have been supported by State Governments

Kerala and Maharashtra have accepted many of the recommendations of the WGEEP in water sector (page 14 section 2.3 – point 9) like catchment area treatment plan, protection of high altitude valley swamps, water conservation measures, rehabilitation of mined areas, improved river flows etc. It is surprising to note that the HLWG is silent on these very important measures and has not even endorsed these acceptable recommendations which can significantly contribute towards improving water availability in the Western Ghats.

The MoEF should follow these recommendations of the WGEEP.

  1. HLWG takes an extremely biased stand about Athirappilly and Gundia Hydropower projects, rejected by the WGEEP

The WGEEP had categorically stated that the Athirappilly and Gundia Hydropower project should not come up in Western Ghats, looking at their huge impacts on biodiversity, several studies by local organisations and local opposition. However, ignoring all these, the HLWG has taken a very pro project stand on these projects, stating that they can be considered with some vaguely due process, which the state government would be happy to show they have followed it on paper. This is entirely unacceptable.

The MoEF should not allow Athirappilly and Gundia HEPs looking their impact on ecology and communities and in face of the strong local opposition that they are facing.

Athirappilly Waterfalls on the Chalakudy River Photo; SANDRP

The WGEEP process and report initiated a robust discussion about the paradigm of development and conservation in Western Ghats. Water and Rivers is a cross cutting issue connecting ecosystems and communities, rural areas and urban centers, providing goods and services and supporting freshwater biodiversity, which is most threatened currently.

A proactive position on conserving rivers in Western Ghats will go a long way in protecting and conserving myriad livelihoods and ecosystems that thus depend of them.

We hope the MoEF considers the recommendations made above about the WGEEP and HLWG Reports and helps conserving rivers of the Western Ghats for people and ecosystems urgently. The HLWG Report cannot be accepted the way it stands presently. As a step in this direction, we also suggest that WGEEP should get a formal chance to respond to the points raised about it in the HLWG.

Thanking You,


Yours Sincerely,

Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune ( ,

Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, Maharashtra (

Dr. T.V. Ramchandra, Energy & Wetlands Research Group, Centre for Ecological Sciences, IISc, Bangalore (

Janak Daftari, jalbirdari, Mumbai, Maharashtra (

Sujit Patwardhan, Parisar, Pune, Maharashtra (

Dr. Nilesh Heda, Samvardhan, Vidarbha, Maharashtra (

Nisarg Prakash, Nature Conservation Foundation and Nityata Foundation, Bangalore, Karnataka (

Mrinalinee Vanarase, Iora Consultants, Pune, Maharashtra (

Shankar Pujari, President, Nivara Bandhkam Kamgar Sangh, Sangli, Maharashtra (

Damodar Pujari, SANDRP, Pune, Maharashtra (

Saili Palande-Datar, Kalpavriksha, Pune, Maharashtra

Following Members from Energy and Wetlands Research Group, Centre for ecological Science, Indian Institute of Sciences: 

  • Dr. M.D. Subash Chandran
  • Dr. Prakash Mesta
  • Dr. Uttam Kumar
  • G R Rao
  • Mahima Bhat
  • Vishnu Mukri
  • Sreekanth Naik
  • Balachandran C
  • Boominathan M
  • Bharath H Aithal
  • Bharath Settur
  • Vinay S
  • Ganesh Hegde
  • Anindita Dasgupta
  • Arun D T
  • Vishnu Bajpai
  • Gouri Kulkarni
  • Sudarshan Bhat
  • Durga Madhab Mahapatra
  • Ashwath Naik
  • Sowmya Rao
  • Shwetmala



Cumulative Impact Assessment · Environment Impact Assessment · Expert Appraisal Committee · Forest Advisory Committee · Hydropower · International Water Issues · Ministry of Environment and Forests · Western Ghats

Dams, Rivers and People Feb-March 2013 Edition

How is the 2012-13 drought worse than the one in 1972?

The present drought in Maharashtra is dubbed as being worse than the one in 1972. This article conclusively proves that these critical conditions are not due to the rainfall, but due to poor water management decisions. The rainfall in 2011-12 has been more than 1971-72 in most of the worst drought-affected districts.  Mismanagement of water in the dams, and irrational promotion of water-intensive sugarcane, unjustifiable west ward water diversions for hydro power generation have all led to the dearth of water to a much larger extent than the quantum of rainfall.

sugar farmers

Maharashtra’s sugar shackles

Maharashtra has 209 sugar factories, the highest in any state in India. most of them in worst drought-affected districts. Of its 30 cabinet Ministers, 13 either own sugar factories or have considerable shares in them. This article examines the impact of this hegemony on the state’s farmers and it’s water.

Free flow after dam removal

Decommission dams as an Environmental Priority!

Some of the oldest dams in the world exist in India with around 100 large dams are more than 100 years old. These are increasingly unsafe. MoEF needs to consider dam decommissioning as a viable option for restoring the ecology of rivers

Our missing dams

How much do we know of our dams and rivers?

This article analyses the National Register of Large Dams. It is a disturbing situation that the agencies that are responsible for our large dams do not even know for majority of our large dams the names of the rivers on which they are located!

Gharial on the river bank

Vertebrates of Chambal

National Chambal Santuary is one of the very few protected river sanctuaries in India.This article describes a project to provide a peer-reviewed and  open-access compilation of vertebrate fauna of the Chambal River basin, which highlights the regions ecological significance as also the threats it faces

Protesting against dams

Journey from Cooperation to Conflict

This article discusses the various conflicts developing in the Indian Sub-continent. International, inter-state, and inter-sectoral conflicts are discussed. The article also discusses the steps that need to be taken to achieve greater water cooperation across the world

Ujani Dam

Will water released from Ujani help Solapur?

The HC order to release water from upstream dams to  Ujani dam for mitigating drought in Solapur is examined. Unfortunately, the Maharashtra water resources department is unable to curb unathorised water use, let alone promote equitable usage of water from canals, dams and rivers

Related News: 

Impact of nearly 100 mini hydel projects on Bangalore’s Water Supply: SANDRP Report

No New Mini hydel Projects in Karnataka Western Ghats!       

Bhutan on a Hydropower Spree

Water Privatisation is not for India

Rivers changing course in Arunachal

One All verdict for India Pakistan in Kishenganga Arbitration

Bring back our Yamuna! 

Huge Anti Dam Protests in Tawang, Arunachal Pradesh headed by monks   

Traditional Fisherfolk evicted from Loktak in blatant disregard to human rights as well as law

India Water Week 2013: MoWR again working as a big dam lobby?

Forest Advisory Committee reconsidering clearance for Kalu Dam again!

Hydropower at the cost of Drinking water?

Good News. HC stays a sugar factory that was coming up (again) in drought affected Solapur District 

Debatable Dam in the Western Ghats

How the World Bank undermines its own development goals

Cumulative Impact Assessment · Environment Impact Assessment · Forest Advisory Committee · Ministry of Environment and Forests · Western Ghats

Kalu Dam in Western Ghats: FAC goes back on its word without any justification

Through an unfortunate and short sighted decision, the Forest Advisory Committee of the Ministry of Environment and Forests has gone back on its decision of rejecting Forest Clearance to Kalu Dam that it took on 2nd April 2012. It reconsidered the project and in its last meeting on 3rd-4th April 2013, and has actually recommended the Kalu Dam project for FC, involving 1000 hecatres of Forests in the Western Ghats. It has done this when all the illegalities and irregularities from the proponent still stand today, entirely unaddressed.

We have sent a submission condemning this decision on behalf of Shramik Mukti Sangathana as well as villagers to be affected by Kalu Dam to the Forest Advisory Committee and Minister of Env and Forests Ms. Jayanthi Natarajan. (see below)
You can support the communities and Forests in Kalu by sending similar letters to MoEF Minister and Forest Advisory Commitee.

Illegal Work on Kalu Dam Site by FA Constructions Photo: SANDRP, May 2011
Illegal Work on Kalu Dam Site by FA Constructions Photo: SANDRP, May 2011



Ms. Jayanthi Natarajan,

Minister of State (IC) for Environment and Forests,

Ministry of Environment and Forests, New Delhi


Subject: Request not to grant Forest Clearance to Kalu Dam in Maharashtra due to several procedural and legal irregularities on the part of the Project Proponent and also the Forest Advisory Committee.


Respected Madame Minister,

This is to express our utter shock and dismay at FAC’s decision of recommending Forest Clearance to Kalu Dam falling in Western Ghats area in Murbad, Thane District, Maharashtra as seen in the minutes of the FAC meeting of April 3-4, 2013.

Just one year ago on the 2nd of April 2012, the Forest Advisory Committee had rejected this proposal, raising substantial points against the proposal and closed the file. This was a respite for the communities facing displacement, community groups working on the issue, for the Western Ghats ecology and the forests. We had then thanked FAC for this decision of April 2012.

On 4th of April 2013, the same Forest Advisory Committee (now with a changed constitution) went back on its decision and recommended Forest Clearance (FC) to Kalu Dam even when nothing has changed on ground and all of the objections based on which FC was rejected in the first place still stand todayThe Project Proponent (PP): KIDC, Maharashtra Water Resource Department, has not been able to respond in credible way to any of the points raised by the FAC, Chief Conservator of Forests (Central), State Forest Department, affected villagers or civil society organisations.

We strongly condemn this decision by the FAC of recommending Forest Clearance for diverting nearly 1000 hectares of Forests in the Western Ghats. We urge you (i) not to recommend FC for Kalu Dam; (ii) request you to take steps to make Forest Advisory Committee more transparent, responsive and accountable to issues of communities and forests; specifically, all the documents from the project proponent, including all the annexures of the Form A and gram sabha resolutions for the projects on FAC agenda must be on FAC website at least ten days in advance as per CIC orders and as also assured by you in public; (iii) We also urge you to direct action against those responsible for illegal construction of the Kalu dam as noted by the FAC minutes; (iv) urge you ask FAC to hence forth recommend strict action against such violations.

 Major issues about recommending FC to Kalu Dam:

Non-transparent decision making in violation of CIC Orders: None of the documents submitted by the project proponent about the Kalu Project were available in full with all the annexures on the MoEF website even a week before FAC meeting on the 3rd and 4th of April. This is a blatant violation of the CIC orders and we had pointed this out to the FAC through our letter dated March 25, 2013, but the FAC chose to ignore this. As a Minister, you had taken a strong stand against this and had said in October 2012 “These actions and decisions of the officials are unacceptable to me. The forthcoming meeting of the FAC will be postponed, and I shall resolve these (violation of CIC orders and non-compliance of FRA) issues.”[1]

Considering that the lives and livelihoods of about 18000 people will be affected by this project, and when they have the first and foremost right to have all the information on decision making around this project, such irresponsibility on the part of FAC is unacceptable and it is also bad in law. Petition against Kalu Dam is in the High Court of Bombay currently and this point will be raised there.

Complete reliance on Project Proponent’s (PP) claims While recommending FC, the FAC has relied entirely on claims of the proponent, without checking the veracity of the claims or applying its mind. FAC has not even mentioned the numerous submissions made by communities and community-based organisations raising pertinent points against PP’s claims. The FAC needed to keep in mind that the same proponent has gone against its word many times earlier and each time, it has been pointed out to the FAC. It has wilfully violated the Forest Act by starting construction of the project in the absence of FC when the project is to submerge nearly 1000 hectares of land in a biodiversity hotspot, it has gone against its written word when it said that ‘no new project will be required for Mumbai until 2031”, in the process of seeking Stage I Forest Clearance for Shai Project, barely 20 kilometres from Kalu Project.

But the FAC, instead of taking any strict action against the proponent in this regard, has simply accepted its claims, which are again misleading and false.

Grounds for rejection of Kalu Project in 2nd April 2012 by FAC: The FAC minutes state:

·                    Submergence of 18 villages and their connectivity,

·                    Initiation of construction without Forest Clearance,

·                    Breach of commitment given by the Project Proponent during Stage I clearance of Shai Dam,

·                    Location of the dam within 7 kms of Protected Area

·                    Location of the project in eco sensitive Western Ghats

·         Non-furnishing of:  Rehabilitation Plan, Environment Impact Assessment report, Technical Report on Wildlife Status, Gram Sabha resolutions about compliance of Forest Rights Act


NONE of the issues stated above are resolved through the PP’s responses as clarified below:


·                    No Gram Sabha Resolutions Passed supporting the project:  Misleading the Forest Advisory Committee:  PP has claimed that it has secured Gram Sabha Resolutions from 8 villages out of the 11 villages that will be fully or partially submerged by the dam. In fact, Shramik Mukti Sangathana has letters from 10 Gram Panchayats out of these 11 that they have not issued any such resolutions at any stage. The last resolution in this regard that they passed was AGAINST the project. These were sent to the FAC on 16.11.11.

If the Project Proponent has the resolutions as claimed, why have they not put these up on the FAC website with the necessary documentation from the PP?

Why did the FAC not see the need to ascertain this even when it was pointed out by us in our letter dated 29.10.12 and again in 25.03.13 that no such resolutions exist?

·                    Clear violation of the Forest Conservation Act (1980): The proponent accepts that it violated the Forest Conservation Act (1980) by starting work before an FC, but states that it stopped AFTER High Court Orders. High Court Orders were in response of a PIL filed by Shramik Mukti Sangathana against the illegal nature of the work. So, stopping AFTER HC orders is no justification for committing the illegality. Before the High Court orders, Shramik Mukti Sangathana had written several letters about this violation to the Collector, Chief Secretary and Forest Department and had also served a notice to the PP. It did not stop work then.


Considering this, the Forest Advisory Committee ought to have penalised the project proponent for violation of Forest Conservation Act (1980), not recommend the same project for clearance.This only gives out a signal that no action will be taken by the MoEF even after it knows that violation of Forest Act is happening, that too by a state agency.

·                    Continued violation of the Forest Rights Act (2006) It has been pointed out several times to the FAC that Kalu Project is violating the Forest Rights Act (2006) as community and individual claims are yet to be settled. The Forest Rights Act was passed to safeguard historical injustice on Forest-dependent communities, but the FAC itself is encouraging the PP to violate FRA, PESA, Rehabilitation Policy and Forest Conservation Act. You, as a Minister, had reasserted MoEF’s commitment to implementation of Forest Rights Act.

·                    No Rehabilitation Plan has been submitted at the time of recommending Forest Clearance There is no such plan available in public domain, nor has there been any participatory process of approval of the plan with the affected people. A claim of a rehabilitation package of Rs 68.75 Crore does not constitute a Rehabilitation Plan. This point was raised several times by community organisations, State Forest Department, Chief Conservator of Forests as well as the FAC.  Villages to be affected by Kalu Dam fall in Tribal Subplan and attract PESA. Without any legally mandatory process, just the claim of rehabilitation package of Rs 68.75 crore seems good enough for FAC. It was clearly wrong on the part of the FAC to recommend FC based on such claims.

·                    Konkan Irrigation Development Corporations letter that “it is not necessary to construct any new water source till 2031”:  This was submitted to the MoEF while seeking Stage I Forest Clearance for Shai Dam, less than  25 kms from proposed Kalu dam in 2010-11. FAC recommended Stage I Clearance to Shai Dam based on that assurance. In less than 3 years, the proponent feels that Shai dam, whose clearance was obtained on such a claim, will not be sufficient till 2031. This is unjustifiable and tantamount to misleading the FAC with false assurances.

·                    No Environment Impact Assessment (EIA) Conducted The Kalu Dam falls in ecologically sensitive Western Ghats. The Western Ghats Expert Ecology Panel had categorised the region in ESZ I where no large dams should be permitted. Even as per the Kasturirangan Committee Report, more than 5 villages affected by Kalu Dam are falling in the ESA.

The State forest Department, Chief Conservator of Forests (Central), community groups have all urged that EIA as well as a Cumulative Impact Assessment of the Project has to be done before granting Forest Clearance. In fact, this was one of the conditions laid by the State Forest Department. Looking at the ecologically sensitive location of Kalu Dam and submergence of nearly 1000 hectares of Western Ghats Forest Land, this was a reasonable expectation.

Despite these clear conditions, the PP argues that EIA is not required. And despite this, the FAC recommends FC to this project!

In this context, Section 2.3 (ii) of FCA (1980) read, “Notwithstanding the above, if in the opinion of the Ministry or the Advisory Committee, any proposal should be examined from the environmental angle, it may be required that the project proponent refer the case to the Environment Wing of the MOEF.” So irrespective of the requirement of EIA notification, the FAC has been provided powers to refer to an such project to the environment wing of MoEF or EAC for examination of the project from the environment angle, but FAC failed to do this just under the claim of the PP that EIA is not required under EIA notification.

FAC recommendation that Cumulative Impact Assessment has to be undertaken for drinking water projects around Mumbai is welcome but again, it could have been done before considering this project for clearance and not after recommending clearance. Similarly their recommendation to the MoEF to amend the EIA notification to ensure that such dams are included for environmental impact assessment is welcome, but they could have waited for MEF response rather than recommending Forest Clearance.

In this regard we urge you: (i) immediately change the EIA notification to include Kalu and all such large dams under the ambit of the EIA notification, irrespective of the purpose of the project; (ii) Direct specifically that Kalu Dam require EIA and Env clearance, using the above mentioned part of the Forest Conservation Act, 1980 and EPA, 1986; (iii) Order a cumulative impact assessment of all the projects in the western ghats region around Kalu dam, as recommended by FAC and (iv) direct that FC for Kalu will NOT be considered till all these requirements are fulfilled.

·                    Forest Conservation Act requires Gram Sabha clearance Moreover, section 2.1(vii)(4) of the Forest Conservation Act, 1980 clearly states: “Therefore, whenever any proposal for diversion of forest land is  submitted,  it should be accompanied by a resolution of the ‘Aam Sabha’ of Gram Panchayat/Local Body of the area endorsing the proposal that the project is in the interest of people living in and around the proposed forest land except in cases wherever consent of the local people in one form or  another has been obtained by the State or the project proponents and the same is indicated in the proposal explicitly.  However, it would be required where the project activity on forest land is affecting quality of life of the people residing in nearby areas of the site of diversion; like mining projects, displacement of people in submergence area, etc.” This provision is particularly applicable to a project like Kalu that has not had EIA or public hearing as stated in the same section in FCA, 1980. Recommending FC for Kalu Dam project without fulfilling this requirement is clearly a violation of the FCA, 1980 by the FAC.

We urge you to direct the project proponent to get gram sabha resolutions on the lines mentioned above in FCA Section 2.1(vii)(4) and direct FAC consider the project only after these have been received.

·                    Distance from Protected Area: The submergence of the project is less than 10 kms from Kalsubai Sanctuary. Considering the fact that no EIA is conducted, no report on Wildlife Status exists, this makes ecological impacts of Kalu Dam on Western Ghats ecosystem even more serious. Considering all these issues, FC should have been rejected on this ground alone. In fact the PP goes ahead to say: “No rare or endangered flora or fauna has been reported from this site” How can this be stated when no EIA has been conducted and no wildlife report exists?

·                    The PP states that only “44566” and “44611” that is ‘only’  89177 tress will be felled during and the rest ‘may be’ saved. Ninety thousand trees in Western Ghats is a huge number. But it seems FAC does not see any objection in this. The claim that the rest of the 60 000 trees can be saved is of doubtful credibility. Similarly the claim in the FAC meeting minutes that “No rare or endangered species of flora and fauna has been reported in the area” is also without any credible basis.


·                    We would like to reiterate that no options assessment about water supply options to Mumbai has been done. No consideration of rainwater harvesting, using saline water for some uses, grey water recycling, demand management, water use efficiency, and conjunctive groundwater use has been done. The FAC minutes notes this, but from the minutes it seems it has not applied its mind to these issues and recommended FC as a matter of blind support for the project. The mention of the letter from the Chief Minister in the minutes only adds to the suspicion that the FAC has cleared the project without looking into merits of the issue.

·                    Contradictions in FAC conditions? The FAC has recommended FC to the project, with some additional conditions, one of the additional conditions states: “The User agency will abide by all conditions by Regional Office, Bhopal and State Government during inspection of the project.” So the PP has to adhere to all the conditions imposed by the Regional Office, Bhopal and the State forest Department while inspecting the project.

One of the conditions imposed by the Regional office, Bhopal included: “…the State Govt. may be directed to stop all the construction related activities till all the legal formalities and forest, wildlife and environment related studies are completed and a well-considered decision regarding forest diversion is taken based on proper scientific documentation and studies.”

We seem to be in a funny situation now. The FAC, while recommending FC, put a condition that says that decision of FC should not be taken without “proper scientific documentation and studies”, but FAC has done just that! In any case, one implication of this is that the project should not get even first stage FC without the studies recommended by Regional Office, Bhopal, including EIA has been done.

Similarly the State forest department too has asked for (i) Rehabilitation Plan (ii) EIA (iii) technical report from WII on impact of project on wildlife in and around the project area (iv) gram sabha resolutions from all affected villages under FRA. The project should not thus be given even stage I clearance without satisfaction of all these conditions.

Most of these issues have been brought to the attention of the FAC time and again by us, Shramik Mukti Sangathana and other community groups. However, the FAC still went ahead with the incomprehensible decision. Hence, we are writing to you with the hope that after looking at all the points raised above, you will definitely not recommended Forest Clearance to Kalu Dam. We also hope that MoEF will punish violators of FC and FRA Acts to send a strong signal and will take steps to make the present Forest Advisory Committee more transparent, accountable and responsive to issues ailing our forests and forest-dependent communities.

We will look forward to detailed response on this from you. Thanking you for your attention,

Yours Sincerely,


Indavi Tulpule: Shramik Mukti Sangathana, Murbad, Thane


Affected Villagers of the Kalu Dam:

Anil Kantaram Kawate: Parchonde (Upsarpanch)

Ganpat Deu Mengal: Zadghar (Gram Panchayat Member)

Navsu Shiva Wagh: Shisewadi

Mrs. Sonibai Shiva Wagh

Nama Shankar Shida: Banachi wadi

Maloji Alo Mengal: Bhoirwadi

 Mrs. Tulibai Wakh: Diwanpada

Bhagawan Bhala: Dighephal

Budjhaji Songwan: Wakalwadi

Anil Waman Wakh: Tejwadi  (Phangane)

Shivram Lakhu Hilam: Talegaon

Harbhau Raut: Kasole

Popatrao deshmukh: Jadai

Devram Darwade: Khutal

Ashok Pathare: Khutal

Tulshi Bhau Wagh: Zadghar

Moreshwar Bhala: Zadghar


Brian Lobo, Shramik Kashtakari Sanagthana: Dahanu

Surekha Dalawi, Shramik Kranti Sangathana: Raigad

                                                                                                                                                                                                Neema Pathak, Kalpavriksha: Pune 

Parineeta Dandekar, Himanshu Thakkar, South Asia Network on Dams and People: Pune and Delhi


Cumulative Impact Assessment

The End of The River

The Video site says this about the video: Published on Nov 6, 2012
European rivers are negatively impacted by thousands of hydropower installations and barrages, with many more to come if the power industry has it their way. Energy produced by hydropower installations is per definition “renewable” energy – but “green” or “clean” it is certainly not. This film is produced to inform about the hydropowers devastating impact on our rivers and the life in them.

Length: 29 min 6 secs
Language versions available: EN, DE, FR. Film produced for: the European Anglers Alliance, and the European Fishing Tackle Trade Association. Directed and written by: James G. Beaulieu
Produced by: Dr. Stefan Spahn and James G. Beaulieu”

COMMENT: This is an excellent video indeed, visuals showing the devastating impact that hydropower projects can do to the river, the fish and the biodiversity across the river and also in turn on the people (though it does not have as much about the social impacts as one would like and as would be applicable in a country like India). It also shows the adverse impacts of the peaking mode of generation and also shows that even in a temperate country like Germany,the hydropower reservoirs can be a source of methane, a gas having 21 times more impact on global warming compared to carbon dioxide. It mentions how fish ladders and fish passages are hardly effective.

HOWEVER, it seems to privilege big hydro project as against small hydro and even micro hydro projects (the commentary mentions projects as small as 20 Kilo watts) over large hydro, seeming to say that the impact of smaller projects on fish (impact hydropower projects on fish seems to be focal point of the video, not the river as the title says) compared to large hydro and actually advocates moratorium on small hydro and also decommissioning of small hydro (as Denmark seems to have done, as shown in the video).

That message may not be as much relevant for a country like India where such micro projects are the only ones that can provide electricity to the communities that do not have them and when such micro projects are the only ones that can be taken up in a participatory way for the benefit of the local communities and where impacts are easier to understand and accept.

Otherwise this is an educative video for all those concerned about the impact of hydropower projects on the river and its biodiversity, particularly fish. This is particularly relevant for India in the context of the social angle and hence is particularly important with reference to larger hydropower projects.

Comments welcome.