Tunneling for hydropower project using the blasting technique can have massive impacts. It has a series of direct and indirect impacts which have already been documented. Among the most serious impacts is drying up of the natural drinking water springs and the reduction in sub-soil moisture. This directly impacts the drinking water availability for the local villagers as well as agriculture and horticultural productivity, which is critically dependent upon the presence of sub-soil moisture. Blasting for tunnels and other underground components of hydroelectricity projects creates vibrations that have resulted in cracks in houses situated near these components.
Importance of impacts of tunneling and blasting becomes very important since all run of the river (ROR) projects involve tunneling and blasting. Proponents claim that ROR hydropower projects are environment friendly, but most people do not know that the tunneling and blasting adds an additional dimension to the impacts due to ROR hydropower projects and these can be very serious. Most environmental and social impact assessments or cumulative impact assessments do not even assess these impacts. Many times the proponent get away claiming that the impacts are not due to the projects, when in reality all evidence shows that these are very much caused by the tunneling and blasting being done as part of the construction of these projects.
This photo essay documents the impacts of tunneling and blasting for hydropower projects mainly in Chamba (part II of photo essay does the same for projects in Kinnaur district) of Himachal Pradesh. In Chamba, the photo essay includes such impacts of Chamera III, Chanju, Ginni, A.T. hydropower projects. It is noteworthy that impacts are not only limited to large hydropower projects, but also to what is defined as small hydropower projects (projects below 25 MW installed capacity). This should also help puncture the misconceived notion that small hydropower projects are environmental benign and they do not need environmental and social impact assessment, public consultations, appraisal, monitoring or compliance.
These photo essays are indicative of the kind of impacts tunneling and blasting can have in the process of building hydropower projects in the Himalayas. What they indicate is relevant not only for Himachal Pradesh, but entire Himalayas and all projects that involve such tunneling and blasting. We hope these photo essays open the eyes of state governments, Union Ministry of Environment, Forests & Climate Change, Union Ministry of Power, Union Ministry of Water Resources, Central Electricity Authority, state environment departments, hydropower developers, EIA consultants, chairman and members of Expert Appraisal Committee on River Valley Projects, media, judiciary, civil society and all others concerned.
People of Dhalanjan village show their destroyed and dilapidated structures
A.T. Hydro Power Project, Chamba
Ravi (Tarela Nallah)
Pictures taken on
Ginni Hydro Power Project, Chamba
Ravi (Tarela Nallah)
Picture was taken on
Landslide due to the construction activities and then subsequent destruction of the penstock of the Ginni project further led to soil erosion. The village above the slides, Junas has 20 houses and now stand threatened
For Part 2 of the photo essay related to tunneling impacts of hydropower projects in Kinnaur district, see: https://sandrp.wordpress.com/2014/10/02/photo-essay-on-the-impacts-of-blasting-and-tunneling-for-hydropower-projects-in-kinnaur-district-in-himachal-pradesh-2/
The Union Ministry of Environment, Forests and Climate Change (MEFCC) in the BJP led new government at the centre has, through Office Memorandum (OM no 22-15/2014-IA.III) dated Aug 29, 2014 constituted High Level Committee (HLC) under the chairpersonship of former cabinet secretary TSR Subramanian, “to review various acts administered by Ministry of Environment, Forests and Climate Change”. Let us try and look at this proposal on its merits.
Firstly, it should be noted that the HLC has a far-reaching mandate to review the core legislations that are supposed to protect India’s environment, including the Environment Protection Act (1986), the Forest Conservation Act (1980), the Wildlife Protection Act (1972), the Water (Prevention and Control of Pollution) Act (1974) and the Air (Prevention and Control of Pollution) Act (1981). Considering that these acts are the back bone of MEFCC’s environmental governance, the recommendations of this committee can have far reaching impact on India’s environmental governance.
Secondly, there are no doubts that India’s environmental laws and governance needs to be reviewed and strengthened. While the industry and vested interest lobbies have been claiming that MEFCC’s work is a hindrance to India’s development and growth, the reality is quite the opposite. MEFCC provides environment clearance (for projects covered under EIA notification of Sept 2006, which is the current notification and which excludes large number of projects from requirement of environment clearance), forest clearance, wildlife clearance, coastal zone clearance and also certifies if the projects applying for CDM (Clean Development Mechanism under the United National Frame Convention on Climate Change) are sustainable development projects.
The committee has been explicitly constituted for reviewing the five environmental laws. These laws need to be strengthened so that there is inclusive, democratic, bottom up process in which people have a decisive role. The governance related to the laws thus needs to be changed in this context so that there is greater transparency, accountability and participation and better compliance is achieved. This is what we mean when we say we need to improve the environmental governance.
MEFCC’s zero rejection rate With respect to giving any of these clearances, the MEFCC has almost zero rejection rate in most crucial sectors. For example a review of the functioning of the Expert Appraisal Committee on River Valley and Hydropower project shows that the committee has not rejected almost any of the proposals that came its way in last seven years. The MEFCC has not rejected any of the proposals that applied for CDM status. Even in other sectors, the MEFCC has rejection rate below 3%, if at all and projects for which clearances have already been given like coal mining, are far from being implemented.
States already have enormous powers Some people have been claiming that states do not have sufficient powers in environmental decision making and hence the powers need to be delegated to the states. The fact is that the states already have enormous powers in environmental governance, including in all clearances. The pollution control regime is completely under the states. The states are empowered to clear several categories of projects in the context of all the clearances. The state pollution boards are supposed to give consent to establish and operate, before which no project can operate, they are also supposed to conduct public consultations even for projects requiring central clearances. Before National Wildlife Board clears a project, State Wildlife Boards need to clear the projects. Consent of Forest Officials from the states is mandatory before Forest Clearance application is processed to higher levels. Which state in India has shown exemplary conduct to inspire confidence that they are in a position to achieve necessary environmental governance? We do not know of any. Unless the capacity of states in this regard is increased, we cannot improve environmental governance in India only in the name of entrusting it in the hands of the states.
Is MEFCC responsible for delays? This is another bogey raised against the MEFCC. The fact is that the EIA notification has clearly defined timelines that says that if MEFCC fails to respond within the timeline, the project can be deemed to have secured the clearance. The fact of the matter is that no project has claimed or gotten such deemed clearance, since most project developers are uninterested in fulfilling even the minimalist demands of MEFCC. On the other hand, most dams and hydropower projects get delayed beyond the promised time frame even after getting the clearances! For any objective person, the claim that MEFCC is responsible for delays and lengthy procedures is clearly a bogey.
Do projects need too many clearances? Another argument made by some is that MEFCC needs too many separate clearances for the same project, which leads to delays. This is again not borne out by facts and clearances that are required now are bare minimum. Except environmental clearance, rest of the clearances do not need public consultation process. Even in case of environment clearance, except the projects covered under EIA notification, rest of them do not need public consultations. The five clearances that MEF gives as listed above are required under each specific law and it is completely justified that separate appraisal process is required for each of them as the issues considered and sectors affected are specific in each case, which cannot be clubbed. We need to strengthen each one of these appraisals, rather than weakening them or clubbing them together.
EAC lacks credible independent members or chairpersons It is public knowledge that most of the people who are appointed on the various committees that appraise the projects for clearances are those who are ready to toe the official line without raising too many uncomfortable questions. There are known cases when the chairman of the EAC or member of FAC were found to have direct conflict of interest with their involvement in companies whose projects they were to consider for clearance. Recently, NGT has ordered that the chairs of the EAC cannot be generalist administrators but must have domain knowledge and experience. The lack of credible independent members in these committees is a major reason why the Ministry manages to clear almost anything that comes its way.
Poor quality impact assessments It is also well documented how most of the environment & social impact assessments, environment management plans or the cumulative impact assessments are shoddy, inadequate, incomplete, cut paste or dishonest efforts. Even media has reported several cases, environment groups have repeatedly sent detailed analysis and critiques of these assessments, but the ministry and its committees have the distinction of not rejecting any of such assessments or recommending punitive action against the agencies that are submitting such dishonest or problematic reports.
Public consultations in name sake Under the EIA notification of Sept 2006, the projects are supposed to have public consultations which include public hearing at each of the affected project districts. Here again there have been several documented cases how the public hearings are hijacked by the project developers, they are conducted by partisan government officers and there is no application of mind from the MEFCC to ensure that the issues raised at the consultations are addressed. Several observers, including a former environment minister has accepted that these consultations are largely for namesake only, a box to be ticked. Even when all the people present at the public hearings have said that they do not want the project, it has no impact on the decision of giving clearance to the project.
Non-existent compliance All the clearances given are conditional, and the project developer is supposed to follow these conditions and implement environment management plan. However, how is compliance to these conditions and management plans, a very crucial aspect, to be achieved? The project developer is supposed to submit six monthly compliance reports, but there are no consequences if they do not do that for years! The officials at MEFCC or their regional offices do not have the time to go through these reports and check if these indicate adherence to the required measures and norms prescribed. Neither do these agencies take steps when the compliance reports do not follow the norms. They are never known to have taken any steps in this regard. The monitoring visits from regional offices of the MEFCC are always preplanned and the project developers get away with window dressing at best. There are no surprise visits. Even after monitoring visits, the MEFCC has never taken any steps when MEFCC finds lack of compliance.
We have narrated this list of known problems to show how lax is our environmental governance and how necessary it is to strengthen it rather weakening it. If the review is being done with a view to strengthen the environment governance, it would be welcome.
Review of functioning of institutional set up in environmental governance The review of functioning of institutional set up responsible for environmental governance also becomes imperative after such a long period since these institutions were set up. For example, state and central pollution control boards were set up under the Water Act of 1974, but we do not have experience of a single river or even a tributary of a river having been cleaned up because of the efforts of the pollution control institutions. This failure is a major reason for the state of our rivers today, including the Ganga.
New Issues In addition to the need for strengthening the environmental governance, the review of environmental laws and institutional architecture connecting with their implementation is also necessary in view of the emerging new issues. For example issues like climate change, need for cumulative impact assessments, need for environmental flows in the river, need to protect, preserve and rejuvenate rivers (a proclaimed priority of the current government) or assessment of impact of projects on disaster potential of the area were not as important and urgent as they were when these laws were formulated.
CURRENT REVIEW What I have written above provides sufficient ground for need for review of laws and institutional set up for environmental governance in India. For this we need a credible independent team with clearly defined terms of reference and transparent, participatory and confidence inspiring process. Let us see if the review set up under the HLC qualifies to achieve such a review.
Sinisterly ambiguous TOR Firstly, if we read the four Terms of Reference (TOR) given to this committee under the above mentioned OM, the first TOR says the review will assess status of implementation of the act vis a vis “the objectives”. But the TOR does not define what is meant by “the objectives”. The second TOR is not problematic as it says the review will “examine and take into account the various court orders and judicial pronouncements relating to these acts”. The Third TOR is the most sinister. It says the HLC will recommend specific amendments in the acts, “so as to bring them in line with current requirements and to meet objectives”. The trouble is, neither “current requirements” nor “objectives” have been defined. Without defining them, these are open to any interpretation that is suitable to the committee! Such ambiguous TORs which are open to manipulation are completely unacceptable and do not inspire any confidence in this exercise.
Constitution of HLC The committee chaired by former cabinet secretary T.S.R. Subramanian has four members (including the chair) and two secretaries (both government officials). The constitution of the committee and criteria for selection of the members has remained completely non transparent, which itself raises many questions.
Among the four members, two are former bureaucrats and two are with legal backgrounds. None of the members are either expert in environmental issues or environmental governance. None of the members (including the chair and the secretaries) are known to have fought for or campaigned for or worked for improving environmental governance in India. There are no credible, independent non-governmental members or independent experts here.
Viswanath Anand, one of the two former bureaucrat members of the HLC and former environment secretary, does not inspire confidence due to his track record either as environment secretary (1997-2000) or as Vice Chair of National Environment Appellate Authority (2002-2005). His tenure at NEAA was described by the Delhi High Court as “a one-man show” in the absence of a chairman and three technical members of the authority. Media further reports: “Very few appeals were admitted by Anand during his three-and-a-half-year stint at NEAA. In the Loharinag Pala case, he drew sharp criticism from the Delhi High Court for “adopting a very hyper-technical approach in rejecting the petitions” and overlooking “that these petitioners deserve to be heard on merits”. The court quashed Anand’s order and reinstated the appeal.” That says a lot. There are several other narrations about the role played by Mr Anand at NEAA. Mr Anand is also on Coca Cola India’s Advisory Council on Environment and Sustainability, which seems to be in conflict with his role in HLC.
Appointment of Mr Hardik Shah (one of the two secretaries) as the Member Secretary of Gujarat Pollution Control Board was challenged in Gujarat High Court by RTI activist Amit Jethwa before he was killed, as per Indian Express report, see link in End Note 2 bleow.
Considering the non-transparency in its appointment and known background of some of the members, the constitution of the committee too does not inspire any confidence that it will help improve environmental governance in India.
Process of participation The MEFCC has said that within a month, that is by Sept 27, 2014, people can send submission to the committee in less than 1000 characters (or an email)! This is completely ridiculous and shows how non-serious the government and the HLC is about the submissions. This article, with already more than 13000 characters would clearly disqualify for submission to the HLC! Besides the issue of length, there is not even a clearly defined process that tells the people what will happen to their submissions and how are they sure to know that their submissions will be even acknowledged and responded to or even read. The process of participation is completely unacceptable. The whole process limits the participation to only English speaking and writing people who have access to internet, leaving out vast majority of the people out of the review process.
Conclusion It is clear from all accounts that the HLC does not carry any credibility or inspire in any confidence for any objective person. The best course for the MEFCC is to dissolve the HLC and restart the process keeping in mind the comments from groups and individuals without vested interests. The government should in the first place institute a credible independent review of the experience with environment laws, institutions and governance in India. This has also been highlighted by organisations like ESG. The report of this exercise should then be made available to all the gram sabhas in local languages. It is only based on such a report that a review of the environmental laws, institutions and governance be taken up, in which then the people and groups on ground can participate. At least 50% members of the review process should be women, when today there are none.
We have looked at this process purely on its merit, without looking at what the new BJP led government at the centre has done over the last four months. The government has been very busy diluting and dismantling whatever little exists in terms of environmental governance in India. If we add that track record to this analysis, then the conclusion is loud and clear: The formulation of HLC is aimed at completely dismantling the laws and institutions related to environmental governance in India. This is not a good sign for the future of this country and her people.
Himanshu Thakkar, SANDRP
Another blog on this issue: https://sandrp.wordpress.com/2014/10/10/strengthen-and-not-dilute-environment-laws-submission-to-the-mefs-hlc-to-review-environment-laws/
POST SCRIPT 1:
Those who agree may send this to firstname.lastname@example.org, Sept 27, 2014 is the last date for sending submissions, but we need to keep sending submissions on these lines even after that deadline.
Post Script 2: Press Release from Environment Support Group, Bangalore after the meeting with HLC in Bangalore on Sept 27, 2014:
Press Release : Bangalore : 27th September 2014
(Attached PDF with pictures)
High Level Committee of Ministry of Environment and Forests and Climate Change walks out of Public Consultation in Bangalore
The High Level Committee headed by Mr. T. S. R. Subramanian, former Union Cabinet Secretary, constituted by the Union Ministry of Environment and Forests and Climate Change to review environment, pollution control and forest conservation laws, invited the public at large for a consultation between 12 and 1.30 pm today (27th September) at Vikas Soudha, the high security office complex of the Government of Karnataka. Advertisements to this effect had been issued by the Karnataka Department of Forest, Ecology and Environment in various newspapers on 21st September 2014, followed up by various press releases inviting the public to interact with the Committee.
When various individuals and representatives of public interest environmental and social action groups turned up for the meeting, the police prevented their entry at the gates. It was only following a spot protest that the police consented to allow them to participate in the consultation. Despite this indignifying experience, all who gathered proceeded to the meeting hall with the intent of engaging with the High Level Committee.
The meeting commenced with introductory remarks by the Chairperson Mr. Subramanian. Broadly, he shared that the intent of the Committee was to hear views from across India on the type and nature of changes that were required in the environmental and forest protection laws. He stated that the Committee had the mandate of the Government to propose necessary changes that would help improve the quality of life and environment. But he said the need to ensure develop was primary, as the country was very poor (over 80% were poor he claimed) and thereby it is found essential to streamline environmental clearance processes that thwarted growth. Mr. Subramanian also shared that it was a matter of concern to the Government that several development projects were getting mired in litigation on environmental grounds, leading to needless delays. Concluding his introductory remarks he shared that the Committee is not in any manner guided by the Ministry and their recommendatory report would be submitted to the Union Government. The Committee’s proceeding, he clarified, were not open to the public, unless the committee decided to engage with the public. Responding to a question, Mr. Subramanian said that nothing that was submitted to the Committee would be shared with anybody, and that only the report would be submitted to the Government. Mr. Subramanian also said that the Ministry never proposed a public consultation exercise, but he had suggested this should take place.
Mr. K. N. Bhat, Senior Advocate and a member of the Committee, shared that there were a variety of submissions the Committee had received and each of this would be considered. He aired that environment and development should go side by side and the objectives of the laws if not found sufficient to address current needs, need for their review exists. The industry in particular, he said, had raised concerns over delays in environmental and forest clearances when the Committee met with them.
On these introductory notes Mr. Subramanian asked the members of the public to suggest changes to the existing environmental law framework. Officials assisting the Committee did not provide any rationale for the Ministry proposing changes to existing laws. The Committee also did not have any procedure, excepting online submissions of opinions on the Ministry’s website (limited to 1000 words).
When the turn of the public came, a submission was made by the Karnataka Planters Association about procedural difficulties in securing forest clearance and conforming with pollution control norms, and sought amendments for the benefit of plantations. Thereafter, Mr. A. C. F. Anand, an RTI Activist, suggested that all environmental laws must be translated so that it would be understood by all and thus the compliance rates improved.
Speaking next, Mr. Leo F. Saldanha of Environment Support Group requested the Committee to address the basis for its functioning, and whethere the TOR constituting the Committee was sufficient for such a massive and onerous task that involved fundamentally reviewing all environmental laws that were intricately linked to Right to Life, Clean Environment and Livelihoods. He sought to know what it meant, as is main TOR, ““(t)o recomment specific amendments needed in each of these Acts so as to bring them in line with current requirements to meet objectives”.
Mr. Subramanian responded that neither he nor any other members of the Committee were influenced by the TOR in any manner and that they worked per their own understanding of the mandate given to them by the Government. But when Saldanha pressed to know how a Committee consisting of high ranking former civil servants, a former Judge and a Senior Advocate could at all have agreed to such vague terms, Mr. Subramanian reacted dismissively. He claimed that this was a non-substantive issue and sought to move on to hear others. Saldanha argued that it is disturbing that Mr. Subramanian unilaterally rules a legitimate concern over vague and weak TORs as being of trivial concern, when, in fact, it would have been fit and proper for the Committee to have first explained in the interest of public accountability and transparency how they found the terms rationale and acceptable to them. And in case the terms were acceptable, then the High Level Committee, unshackled as it were by the bureaucratic norms of the Ministry, could have provided a clear note on the nature of the reforms being considered and also explicated on the procedure of consulting and receiving criticisms from various sectors, peoples, regions, geographies, etc.
Mr. Vinay Sreenivasa of Alternative Law Forum submitted that the process by which the Committee was conducting the consultation was rather opaque. The vague TOR and the fact that the Committee was constituted by a Government that sought to belittle the importance of the National Wildlife Board and rush pet projects through the clearance mechanism, seemed to suggest the entire exercise appeared to be merely ritualistic. Ms. Aruna Chandrasekhar of Amnesty International – India sought to know what specific amendments were being proposed or demanded by industry/corporate sectors, and requested the Committee put it all out. But Mr. Subramanian waved away this request too.
Prof. Puttuswamy wanted to know how a High Level Committee sought to improve environmental laws when notifications of Ministry were being issued to dilute the laws. To which Mr. Subramanian responded saying he is not a “Postman” for the Ministry. Ms. Priti Rao, meanwhile, asked for decentralised solid waste management. Mr. Vijayan Menon shared that even though he was not an official, he had walked into the Committee’s immediately preceding engagement with Government officials where a clear set of amendments were being proposed. He expressed surprise that this presentation was not being made for the benefit of the general public.
Ms. Bhargavi Rao of Environment Support Group wanted to know how law could be reformed when forest officials are unaware of biodiversity protection laws that had been passed over two decades ago and asserted that this rushed exercise in reviewing environmental laws had all the trappings of making light of people’s fundamental rights and concerns. Justice A. K. Srivatsav (Retd. Judge of the Delhi High Court) and a Member of the High Level Committee stated at this juncture that the public must have confidence in a Committee in which a senior retired Judge is a member. By which time Mr. Subramanian had remarked several times that the public was wasting the Committee’s time and there was no point continuing with this procedure. Several who had gathered protested such an assessment by the Chairman of the High Level Committee. Mr. Srinivas of Mavallipura sought to speak, saying he represents a community impacted by mal-development and waste dumping in his village, and he too was brushed aside.
At this point, Mr. Subramanian got up and said “We will end the joke here!” and walked out. He was followed by the rest of the Committee.
When Mr. Subramanian walked out, it was 1 pm. Members of the common public who had travelled great distances to engage with the Committee protested Mr. Subramanian taking them for granted and dismissing their views as of trivial concern. They demanded that the Committee return to hear the public and as advertised remained in the Hall till 1.30 pm. Neither did the High Level Committee return, nor did any official of the Ministry of Environment and Forests or Karnataka Environment Department come back to explain to the public why the High Level Committee had behaved in this manner. In fact, throughout the engagement with the public, not one Karnataka Government official was present in the Hall.
The undersigned are deeply disturbed by the manner in which the T. S. R. Subramanian headed High Level Committee has treated this public consultation process. The undersigned demand that the Ministry of Environment and Forests and Climate Change call off this exercise as it has all the markings of being a ritual exercise. In its place the undersigned demand that the Ministry must constitute a Committee that has a clear rationale for reform and Terms of Reference that are democratic, consultative and transparent. In particular, the following demands are made:
Environment Ministry must first come out with a White Paper discussing the nature of the reforms that it proposes in environmental, forest conservation and pollution control laws.
On the basis of such a Paper, an accessible Committee must be constituted that would hear peoples responses across the biologically, culturally and linguistically diverse country and also from various sectors equally.
The membership of the Committee should be so constituted that it would reflect diverse concerns and sectos, and in particular ensure that members conversant with tribal and human rights, environmental management, conservation biologists, biodiversity, risk assessment, planning, etc., and not merely ex-bureaucrats or members of the legal fraternity were included Particularly important is the need to ensure there is adequate representation of women on the High Level Committee, which presently is constituted only of men.
The process of the consultation to be followed has to be meaningful and conform with Principle of Prior and Informed Consent, even if this is not a consenting process.
The timeline for the Consultation mechanism for such a critical review has to be reasonable as laws sought to amended, or tweaked, fundamentally affect theRight to Life and Livelihoods, and Right to Clean Environment.
The entire process has to be transparent, all meetings must be recorded publicly, none of the deliberations must be in camera (as it appears to be the case now), and all proceedings, submissions, minutes and reports must be in the public domain.
Adequate facilities must be made to ensure that anyone interested can participated with dignity and without being inhibited by language or geographical location. To ensure this, the process must be devolved by enlisting the support of State and Local Governments.
I hold you in high regard and was pleased when you were appointed Chairman of the High Level Committee to review the enviromental laws. I hoped that you would save the environmental laws from decimation. I am beginning to lose that hope.
It is amply clear why the HLC has been set up. This government and in particular Minister Javadekar (who is Minister not for environment butagainst environment) are firmly convinced that environmental laws are playing havoc with ‘development’. What is needed in their view is quick clearance. Both those words are important. The clearance must be quick in all cases, and it must be a clearance in all cases, not a rejection in any instance. In other words, the whole exercise should be reduced to a formality or a ritual. Of course a simpler way of achieveing the objective would be to scrap the clearance procedure altogether, and repeal all the environmental laws. However, that is not easy, and such a move may have a political cost. The next best thing to do is to extract all the teeth from the laws and weaken and dilute them to the point of virtual repeal. It is for such an exercise in emasculation that the MoEF has set up the HLC. I thought that you would not be a party to such an exercise in disingenuousness. I believed that you shared the environmental and ecological concerns of many of us to some extent, if not wholly, and that the environmental laws of the country were safe in your hands. I am not so sure now, after reading reports of what happened at the ‘Public Hearing’ at Bengaluru. It appears that your views on ‘Environment vs Development’ are the same as those of Minister Javadekar. I deeply fear that the report of your HLC will do immense harm to the country. Are you prepared to live with that possibility?
I can only hope that I am wrong. If I have misjudged your position, I am ready to aplogise without reservation.
MANGALORE: Activists in Dakshina Kannada urged that the review of environmental laws must never be done in haste.
Activists expressed their views before the High Level Committee of Union ministry of environment and forests (MoEF) headed by former Union Cabinet Secretary TSR Subramanian during its meet to receive suggestions and objections at deputy commissioner’s office here on Sunday.
The Acts to be reviewed by the centre include Environment Protection Act, 1986, Forest Conservation Act, 1980, Wildlife (Protection) Act, 1972, Water (Prevention and Control of Pollution) Act, 1974 and Air (Prevention and Control of Pollution) Act, 1981.
Karavali Karnataka Janabhivriddi Vedike members said that they are deeply concerned about the haste with which the TSR Subramanian Committee has been set up by the Union Ministry to review five of India’s most important environmental laws.
In a memorandum, Vedike members urged the committee to undertake a study of the effectiveness of the existing laws and their proper implementation, not just from the perspective of obtaining speedy clearances for industrial projects, but from that of protecting the environment and the rights of the poor.
“As concerned citizens, we would like to assert that review of environmental laws must never be done in haste. Protection of the environment concerns is our very survival and must not be seen as an impediment in the drive for industrialisation. Any review must be done in a transparent manner, involving all the stakeholders. The MoEF has a duty to uphold the constitutional right of every individual to livelihood and a clean environment. Economic growth benefiting the rich at the cost of life-sustaining ecosystems must not be seen as development. In view of such concerns, we urge the Government to revamp the review process,” members stated in the memorandum.
Vedike coordinator Shreekumar said seeking to make changes in environmental laws, which are meant to protect important rights enshrined in the Constitution such as Right to Life, Clean Environment and Livelihoods in such haste under vague terms of reference is indeed disturbing. “Recent statements emanating from the Union Government as well as the MoEF have been displaying a dangerous haste with respect to granting environmental clearances for industrial projects with scant respect for environmental protection. Expediting clearances is serving only the interests of corporate powers. The haste and thoughtlessness with which the current review is being undertaken raises the apprehension that it is meant to facilitate such policies,” Shreekumar said urging reconstitution of the committee by including experts in the fields of environmental science, social sciences, natural sciences and environmental law, also giving adequate representation to various stakeholders such as farmers, fishers and tribals.
Even after multiple appeals by various experts, organizations and local people, Expert Appraisal Committee (EAC) set up by Ministry of Environment & Forest (MoEF) has once again chosen to ignore alarms of changing climate such as disaster of Uttarakhand in 2013 and has continued to consider Hydro Power Projects on Chenab Basin for Environmental Clearance (EC) before the Cumulative Impact Assessment of Chenab Basin has been accepted by MoEF. While on one hand the State Government of Himachal Pradesh has promptly appointed a committee headed by Chief Secretary to supervise and monitor all the progress and to “sort out” problems of getting various clearances “without delay in single window system”[i], on the other hand overall transparency of the Environmental Clearance Process has been steadily decreasing.
Sach Khas HEP (260 + 7 MW) (located in Chamba District of Himachal Pradesh) was considered by EAC in its 76th meeting held on August 11, 2014. Even though the project was considered for EC, no documents were uploaded on the website. Website does not even list the project under “Awaiting EC” category. This is in clear violation with MoEF norms, basic norms of transparency and Central Information Commission (CIC) orders. There are no fixed guidelines for documents to the uploaded, the time by when they should be uploaded and rules that project cannot be considered if the documents are not uploaded.
SANDRP recently sent a detailed submission to EAC pointing out several irregularities of the project. The comments were based on reading of the Environmental Impact Assessment (EIA) report available on the HP Pollution Control Board Website (which cannot be substitute for putting up the documents on EAC website). Environmental Management Plan (EMP) of the project is not accessible at all! Non availability of EMP on the HP Pollution Control Board website too is a violation of EIA notification 2006.
The EIA report which is prepared by WAPCOS is another example of a poorly conducted EIA with generic impact prediction and no detailed assessment or quantification of the impacts. Moreover since EMP is not available in the public domain, there is no way to assess how effectively the impacts have been translated into mitigation measures. Violations of Terms of Reference (TOR) issued by EAC at the time of scoping clearance is a serious concern.
Sach Khas HEP is a Dam-toe powerhouse scheme. The project has a Concrete Dam & Spillway with Gross storage of 25.24 MCM, Live Storage of 8.69 MCM and Reservoir Stretch at FRL of 8.2 km (approx.) Three intakes each leading to 5.8m diameter penstocks are planned to be located on three of the right bank non-overflow blocks. Three penstocks offtaking from the intakes are proposed to direct the flows to an underground powerhouse on the right bank of the Chenab river housing 3 units of 86.67 MW turbines with a total installed capacity of 260 MW. The project also proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project.
Sach Khas Hydro Electric Project was considered before completion of Cumulative Impact Assessment of Chenab Basin
Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[i]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K). 49 of these projects are planned or under construction in Chenab in HP and of which 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[ii]. MoEF sanctioned TORs for Cumulative Impact Assessment (CIA) of the HEPs on Chenab in HP in February 2012 however the project specific ECs were delinked from the CIAs[iii].
MoEFs Office Memorandum dated May 28 2013 states, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.”
We had pointed out in our submission against Kiru & Kwar projects in Jammu & Kashmir that CIA of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the Chenab River basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Looking at the fragility of the Himalayan ecosystem, considering any hydropower project in the basin without these studies will be an invitation to disaster[iv]. This fact has been repeatedly highlighted by multiple organizations and experts including SANDRP.
Sach Khas EIA Study: Gross violation of TOR
The EIA violates several stipulations of TOR issued on Feb 22, 2013, which also included the stipulations of EAC in Sept 2012 and Nov 2012 meetings where the project TOR was considered and also Annexure attached with the TOR. This has severely affected the overall quality of the EIA report.
About assessing the impacts of the project on wild life the TOR said: “Reaching conclusion about the absence of such (Rare, Endangered & Threatened) species in the study area, based on such (conventional sampling) methodology is misleading” as such “species are usually secretive in behavior”, “species specific methodologies should be adopted to ascertain their presence in the study area”, “If the need be, modern methods like camera trapping can be resorted to”. None of this is shown to be done in any credible way in EIA.
TOR also recommends intense study of available fish species in the river particularly during summer (lean) months with help of experimental fishing with the help of different types of cast and grill nets. There is no evidence in EIA of any such intensive efforts detailed here. In fact the field survey in summer moths was done in May June 2010, years before the EAC stipulation.
TOR (EAC minutes of Sept 2012) state “Chenab river in this stretch has good fish species diversity & their sustenance has to be studied by a reputed institute.” This is entirely missing. TOR (EAC minutes of Sept 2012) states “During the day, the adequacy of this discharge (12 cumecs) from aquatic biodiversity consideration needs to be substantiated”. This again is missing. TOR said 10 MW secondary station may be a more desirable option. This is not even assessed. TOR said Impacts of abrupt peaking need to be assessed. This is also not done. Site specific E-Flow studies and peaking studies stipulated by TOR are missing. TOR states that Public Hearing / consultations should be addressed & incorporated in the EIA-EMP. However there is no evidence of this in the report.
TOR also required following to be included in EIA, but many of them found to be missing: L section of ALL upstream, downstream projects; Project layout showing all components with A-3 scale of clarity and 1: 50000 scale; drainage pattern map of river upto project; critically degraded areas delineated; Demarcation of snowfed/ rainfed areas; different riverine habitats like rapids, pools, side pools, variations, etc;
Contradictions in basic project parameters
The EIA report provides contradictions in even in basic parameters of the project components: So section 2.1 on page 2.1 says, “The envisaged tail water level upstream of the Saichu Nala confluence is 2150 m.” This i s when the TWL is supposed to 2149 m as per diagram on next page from the EIA. Section 2.3 says: “River bed elevation at the proposed dam axis is 2145m.” At the same time, the tail water level is 2149 m. How can Tail water level of hydropower project be higher than the river bed level at the dam site? This means that the project is occupying the river elevation beyond what HPPCL has allocated to it. Page 23 of EIA says: “…the centerline of the machines in the powerhouse is proposed at 2138.00m…” So the Centre line o the power house is full 11 m BELOW the tail water level of 2149 m? How will the water from power house CLIMB 11 m to reach TWL level?
EIA report unacceptable on many fronts
Dam ht of 70 m was stated in TOR, however the report states it to be 74 from river bed. The submergence area, consequently has gone up from 70 ha at TOR stage to 82.16 ha, as mentioned in Table 2.2 of EIA. Total land requirement which was 102.48 ha as per TOR ha has now increased to 125.62 ha, with forest land requirement going up to 118.22 ha. This is a significant departure from TOR that should be requiring fresh scoping clearance. Part of the field study has been done for the project more than four years ago and rest too more than three years ago. There are not details as to exactly what was done in field study. EAC had noted in their meeting in Sept 2012, while considering fresh scoping clearance for the project, “EIA and EMP should be carried out afresh keeping in view the drastic changes in the features due to increase in installed capacity of the power house.” (Emphasis added.) The EIA report is thus unacceptable on multiple fronts.
No cognizance of Cumulative Impacts
CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.
On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.
The project is located between Purthi HEP upstream and Duggar HEP downstream. Elevation difference between TWL of Purthi (2220m) and FRL of Sach Khas (2219m) is barely 1 m. The horizontal distance between them is as less as 117m. This is clearly unacceptable and in violation of the minimalist EAC-MoEF norms.
Elevation difference between TWL of Sach Khas (2149m) and the FRL of Duggar (2105 m) is 44 m and the horizontal distance is 6 km. This is thus a cascade of three among many other projects in the basin.
Even so the report does not even mention the other two projects. EIA study is project specific and no cumulative impacts are assessed along with the other two projects. The EIA does not provide a list of all the HEP projects taken up in the Chenab basin in HP state[i]. The MoEF sanctioned TORs for conducting Cumulative Impact Assessment (CIA) of Chenab In February 2012. EAC considering any further project in Chenab basin before completion of the CIA study of the basin by a credible agency (not WAPCOS) and finalised in a participatory way will be in violation of the MoEF order of May 2013.
EIA report completely misses out on the detailed analysis of cumulative impacts in terms of disaster potential of the area and how the project will increase that; impacts on flora, fauna, carrying capacity, livelihoods; cumulative downstream impact, cumulative impact of hydro peaking. impacts on springs and drainage pattern; impacts of forest diversion on environment, hydrology and society and implementation of the Forest Rights Act; changing silt flow pattern in different phases, impacts of mining, tunneling, blasting etc. Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change has not been assessed. Project makes no assessment of impact of climate change on the project even when over 60% of the catchment area of the project is snow-fed and glacier fed. Options assessment in terms of non dam options as required under EIA manual and National Water Policy are missing.
Generic impact prediction
Impact prediction is too generic with no detailed assessment, which is what EIA is supposed to do. Impacts have not been quantified at all. The EIA report merely states the likely impacts in 2 or 3 sentences. Several important impacts have gone missing. None of the serious impacts have been quantified. For an informed decision making and effective mitigation and EMP quantification of impacts is essentially a pre requisite. Following are some such incidences:
Impacts of blasting & tunneling: TOR for the impacts on “Socio-economic aspects” says, “Impacts of Blasting activity during project construction which generally destabilize the land mass and leads to landslides, damage to properties and drying up of natural springs and cause noise pollution will be studied.”(p.196 of EIA Report). The total area required for Underground Works is 2.44 Ha. The project proposes underground power house with an installed capacity of (260+7). There are three TRTs proposed of length 99.75m, 113.13m, and 132.35m. Even so the impacts of blasting for such huge construction are simply disregarded in the EIA report by stating that “The overall impact due to blasting operations will be restricted well below the surface and no major impacts are envisaged at the ground level.” (p.165). While assessing the impacts of blasting on wild life the report states that direct sighting of the animals has not been found in the study area and the possible reason could be habitation of few villages. No attempt has been made to assess impacts of blasting like damage to properties, drying up of springs etc. This is a clear violation of TOR.
Impacts of Peaking & diurnal flow fluctuation: In the lean season during peaking power generation the reservoir will be filled up to FRL. As stated in report, this will result in drying of river stretch downstream of dam site of Sach Khas hydroelectric project for a stretch of 6.0 km, i.e. upto tail end of reservoir of Dugar hydroelectric project. The drying of river stretch to fill the reservoir upto FRL for peaking power will last even upto 23.5 hours, after which there will continuous flow equivalent to rated discharge of 428.1 cumec for 0.5 to 2 hours. Such significant diurnal fluctuation with no free flowing river stretch will have serious impacts on river eco system. There is no assessment of these impacts. Instead the report projects this as a positive impact stating “In such a scenario, significant re-aeration from natural atmosphere takes place, which maintains Dissolved Oxygen in the water body.” This is absurd, not substantiated and unscientific.
International experts have clearly concluded that: “If it is peaking it is not ROR”[ii]. In this case the EIA says the project will be peaking and yet ROR project, which is clear contradiction in terms.
Impacts on wild life: EIA report lists 18 faunal species found in the study area. Out of them 8 species are Schedule I species and 8 Schedule II species. Even so while assessing the impacts of increased accessibility, Chapter 9.6.2 b(I) of the report mentions “Since significant wildlife population is not found in the region, adverse impacts of such interferences are likely to be marginal.” If the project has so many schedule I and II species, the impact of the project on them must be assessed in the EIA. Moreover, massive construction activities, the impacts of long reservoir with fluctuating levels on daily basis, high diurnal fluctuation and dry river stretch of 6km on wild life could be serious. But the report fails to attempt any assessment of the same.
Impacts on geophysical environment are missing: The project involves Underground Works of 2.44 Ha. This involves construction of underground powerhouse, three headrace tunnels and several other structures. This will have serious impacts on the geophysical environment of the region and may activate old and new landslides in the vicinity of the project. The report makes no detailed assessment of this. Generic comments like “Removal of trees on slopes and re-working of the slopes in the immediate vicinity of roads can encourage landslides, erosion gullies, etc.” (p.176) have been made throughout the report. Such generic statements can be found in every WAPCOS report. Such statements render the whole EIA exercise as a farce. Project specific, site specific impact assessment has to be done by the EIA. Considering that the project is situated between Purthi HEP upstream and Duggar HEP downstream, a detailed assessment of the geophysical environment and impact of all the project activities is necessary. Further since the EMP is not at all available in public domain, it is difficult to assess what measures are suggested and how effective measures to arrest possible landslides have been suggested.
No assessment for Environmental Flow Releases
TOR states that the minimum environmental flow shall be 20% of the flow of four consecutive lean months of 90% dependable year, 30% of the average monsoon flow. The flow for remaining months shall be in between 20-30%, depending on the site specific requirements (p.192). Further the TOR specifically states that a site specific study shall be carried out by an expert organization (p.193).
The TOR also mandated, “A site specific study shall be carried out by an expert organisation.” However completely violating the TOR, the EIA report makes no attempt for the site specific study to establish environmental flows. Instead it proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. This completely defeats the basic purpose of the environmental flow releases. Such flows will help neither the riverine biodiversity, nor fish migration nor provide upstream downstream connectivity.
Socio-economic profile of the study area and Rehabilitation & Resettlement Plan are missing
TOR specifies a detailed assessment of socio-economic profile within 10 km of the study area including demographic profile, economic structure, developmental profile, agricultural practices, ethnographic structure etc. It also specifies documentation sensitive habitats (in terms of historical, cultural, religious and economic importance) of dependence of the local people on minor forest produce and their cattle grazing rights in the forest land. As per the TOR the EIA report is required to list details of all the project affected families.
Report however excludes assessment of socio economic impact of the study area. The total land required for the project is 125.62 ha, of which about 118.22 ha is forest land and the balance land 7.4 ha is private land. There are cursory mentions of habitations in the study area. Chapter 8.7 ‘Economically Important plant species’ states that in study area the local people are dependent on the forest produce such as fruits, timber, fuel wood, dyes and fodder for their livelihood. However the EIA report does not even estimate the population displaced due to land acquisition and impact of the various components of the project on livelihood of the people. Further detailed study is then out of question. This is again gross violation of TOR.
The EIA says (p. 21 bottom), “Five low level sluices with crest at 2167m of size 7.5m width and 12.3m height are proposed for flood passage. Drawdown flushing of the reservoir shall be carried out through these sluices for flushing out of the sediment entrapped in the reservoir. Detailed studies on sedimentation and reservoir flushing can be taken up at detailed planning stage.” The MDDL of the project is 2209.3 m as mentioned in the same para. This means the project envisages sediment flushing by drawdown to 2167 m (sluice crest level, the sluice bottom level wll be 12.3 m below that), about 42.3 m below the MDDL. This is clearly not allowed under PCA order cited above on Indus Treaty.
Impact of 3.5 MW Chhou Nala HEP to be constructed for the project not assessed
The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project. But the EIA does not contain any impacts of the SHP. The stream on which this is planned is extremely important for the people as drinking water schemes, irrigation Kuhls and gharats of Rai, Chhou and Thandal villages are located on this stream in the proposed project area. Thus the project will have huge impacts, but there is no assessment of these impacts. This is another glaring omission of EIA. It was shocking to read that the resident commissioner said at the public hearing that this question is not part of Environmental Public hearing, when it is very much part of it.
Public hearing report
At several places either no information is given or misleading information has been presented. For example the project representatives mis-informed the people at PH that 15-20% water will be released, when minimum water they need to release is above 20%. DFO said that soil will be spread over the muck disposal site for tree planting over it, but there is no provision of this in EIA-EMP. Many questions were provided with vague answers or no answers at all. No clear answer was given when asked if the muck dumping sites have been decided in consultation with the local people, implied answer is clearly that local people have NOT be consulted. When asked about agreements to ensure that the company implements EMP and Social Management Plan as required, there was no promise that such an agreement will be signed with the village gram sabhas. The affected people raised the issue of erosion impact of diversion tunnel, but no specific response was provided in response to this issue. When a resident of Chhou village raised the issue of vulnerability of the village to the landslides, no clear answer was given by the project developer. When the same person asked that our cremation ground is going under submergence, what is the company planning about it, the project developer replied that IF the cremation ground goes under submergence, we will think about this. This only shows that the project developer and EIA consultant have not even done an assessment of such basic aspects. The PH report accepts that close to 100 workers are already working without even basic sanitation facilities, this is clear violation of EIA notification further the EIA Agency fails to mention this.
EIA is full of cut and paste, generic statements, no actual assessments
Out of nine chapters of EIA, only the last chapter is about impacts assessments! So out of 170 pages of nine chapters, only 31 pages of chapter 9 is supposedly about impact assessment and there too mostly there is no real impact assessment, mostly only generic statements that can be included in any EIA. There are several unnecessary sections in the EIA like chapter 3 on “Construction Methodology” which is unnecessary in EIA. In most other sections too, the information is just cut and paste from DPR. By way of impact prediction, the EIA report is only listing them doing absolutely NO ASSESSMENT and no quantification of impacts is attempted. Further since the EMP is not available in the public domain, it is impossible to assess if the measures provided in the EMP are effective. Such EIA is definitely not acceptable.
No proper referencing The EIA does not provide references to the specific information, without this it is difficult to cross check which information is from which secondary sources and how credible it is and which information is from primary survey.
This is another most shoddy piece of EIA by WAPCOS.
Moreover, as we can see the EIA has not done several impact assessments, has violated large no of TORs on several counts, the EIA-EMP are not available on EAC website, the project parameters have undergone changes necessitating fresh scoping clearance as mentioned in TOR but that has not happened, baseline study is 3-4 years old, EAC stipulation of fresh EIA-EMP has been violated, Project is using larger riverine stretch than given by HP govt, there is no proper referencing, hydrology is weak, EMP is not available on HPPCB website in violation of EIA notification, among several other issues listed above. Every conceivable serious problem can be found in this EIA of WAPCOS.
It is full of generic statements that can be pasted in any EIA without any attempt at project specific impact assessment. SANDRP has been pointing to EAC and MoEF about such unacceptable EIA by WAPCOS for several years, but neither EAC, nor MoEF has taken any action in this regard. SANDRP has once again urged to EAC and MoEF to reject this EIA and recommend blacklisting of WAPCOS and to issue fresh scoping clearance for the project as mentioned in the TOR since the project parameters (dam height, submergence area, land requirement, etc) have gone through significant changes.
We sincerely hope the EAC will not only take serious cognition of these and not recommend clearance to the project, but also direct the project proponent and EIA consultant to implement other recommendations made above.
“We enjoy Pushing Rivers Around” –An early Hydraulic engineer in California (from Patrick McCully’s Silenced Rivers, 1996)
“We can tame the mighty rivers. We are an example of human will and endeavor”
-Sutlej Jal Viduyt Nigam Limited, damming the entire Satluj Basin in India.
“A river flowing to the sea is a waste”- a view held by several water resource developers in India
Welcome to Anthropocene ,says James Syvitski, a leading oceanographer, geologist and hydrologist from Colorado University who has been studying subsidence of deltas.
Some scientists are now placing Anthropocene, an era marked with human interference with natural systems, at par with geological epochs like Pleistocene and Holocene. It is manifested in many ways. Rivers and associated systems like deltas and floodplains possibly have had to face the maximum brunt of the Anthropocene.
Cutting edge scientists like Prof. Syvitski who study the changes in our deltaic systems seem to reach to a common conclusion: Delta subsidence is now the main driving force for effective sea level rise for many coastal environments. This subsidence is more influential than sea level rise related to global warming and any deltas are sinking much faster than the sea level is rising.
But why are deltas sinking? What is the main reason behind this subsidence which is eating away land and making millions of people more vulnerable?
It has been established that the main reason behind delta subsidence is drastically reducing sediments reaching the delta.Studies estimate that during the past century, there has been a 94% reduction in Krishna’s sediment reaching the delta, 95% reduction from historic load in Narmada, 80% reduction in Indus, 80% reduction in Cauvery, 96% reduction in Sabarmati, 74% reduction in Mahanadi, 74% reduction in Godavari, 50% reduction Brahmani, etc.,
But why are sediments not reaching the delta?
Almost unanimous agreement between scientists indicates that the reason behind this drastic decline in sediments is sediment retention by dams and reservoirs in the upstream.(Walling and Fang (2003), Vörösmarty et al., 2003; Syvitski et al.,(2005), Erisson et al, (2005), Walling (2008), K Rao et al (2010), H Gupta et al (2012) ). This has been reiterated in IPCC WG II Report, April 2014.
Prof. Syvitski wrote a few words on the issue for SANDRP. He says, “A delta can form only where the sediment volume supplied from a river can overwhelm the local ocean energy (waves, tides, currents). Ocean energy is ceaseless. Engineering of our river systems, largely through the construction of upstream dams and barrages, has reduced this sediment supply. Consequently ocean energy has begun to reduce the size of our deltas, and coastal retreat is presently widespread. Deltas, once the cradle of modern civilizations, are now under threat — some deltas are in peril of lasting only the next 100 years. Sea level is rising due to ocean warming and glacier melting. Incessant mining of groundwater from below a delta’s surface, along with oil and gas extraction, further contribute to our disappearing deltas. At risk are the residences of more than 500 million people, the loss of biodiversity hotspots, major infrastructure (e.g. megacities, ports), and the rice and protein bowls of the world. Every year thousands of people drown due to storm surges and other coastal flooding. Sinking deltas are evidence of the magnitude of the human footprint on our planetary environment. We must learn to do better.” Professor J P Syvitski (U Colorado, Boulder, USA), Chair — International Geosphere-Biosphere Programme (ICSU), Executive Director, the Community Surface Dynamics Modeling System
Large reservoirs trap as much as 80% of the upstream silt. As a result, most rivers are carrying much less sediment, and some rivers (like Krishna, Indus, Nile, and Colorado) transport virtually no sediment! In the last 50 years, the combined annual sediment flux of the large Chinese rivers has been reduced from 1800 million tons (Mt) to about 370 Mtmainly due to frenzied dam building. The impact of dams and reservoirs on sediment retention has been so significant that the resultant reduced sediment load represents a volume of about 730 km3, equivalent to an area of 7300 km2 assuming a 10 m thick bed. Waling (2008) states that about 25 Gt/year of sediment are trapped by large dams each year. IPCC Report (Assessment Report 5, 2014) refers that 34 rivers with drainage basins of 19 million km2 in total show a 75% reduction in sediment discharge over the past 50 years due to reservoir trapping.
Delta Subsidence and Effective Sea Level Rise (ESLR)
While this delta subsidence and sediment retention has several impacts on dense delta population and coastal ecosystems which offer important services, one of the most serious impacts is its direct role in Effective Sea Level Rise. Ericsson and Vorosmarty et al, 2012, concluded that decreased accretion of fluvial sediment resulting from sediment retention and consumptive losses of runoff from irrigation (also due to dams) are the primary determinants of ESLR in nearly 70% of studied deltas.
More and more scientists are concluding that climate related sea level rise has a ‘relatively minor influence on delta conditions’, as compared to anthropogenic reasons. As seen above, there is an almost unanimous agreement that dams are the most important factor influencing contemporary land-ocean sediment fluxes. Globally, greater than 50% of basin-scale sediment flux in regulated basins is potentially trapped in artificial impoundments of approximately 45,000 reservoirs (with dams 15 m high) (Vörösmarty et al., 2003; Syvitski etal., 2005) and sediment delivery to deltas has been reduced or eliminated at all scales.Other reasons for delta subsidence include flow diversion by dams, sediment compaction due to groundwater abstraction, oil and gas exploration and mining, etc,.
Deltas, formed by centuries of accretion of rich sediment, are one of the most fertile and densest populated regions across the world. It is estimated that close to half a billion people live on or near deltas, often in megacities. Although constituting a mere 5% of the total landmass, coastal regions sustain almost three-quarters of the world’s population and yield more than half of global gross domestic product (Vorosmarty et al.,2009).
The direct impacts of ESLR and delta subsidence include inundation of coastal areas, saltwater intrusion into coastal aquifers, increased rates of coastal erosion, an increased exposure to storm surges, etc. These threats have implications for hundreds of millions of people who inhabit the deltaic as well as the ecologically sensitive and important coastal wetland and mangrove forests.
Already, some studies are ringing alarm bells. It is estimated that if no mitigation measures are undertaken and sediment retention continues, then by 2050, more than 8.7 million people and 28,000 km2 of deltaic area in 33 deltas studied including Ganga-Brahmaputra, Indus, Krishna and Godavari could suffer from enhanced inundation and increased coastal erosion. In addition, a larger population and area will be affected due to increased flood risk due to storm surges. Conservative estimates state that delta area vulnerable to flooding could increase by 50% under the current projected values for sea-level rise in the 21st century and this could increase if the capture of sediment upstream persists and continues to prevent the growth of the deltas.
The Intergovernmental Panel on Climate Change (IPCC) projects that sea level will rise by another 21 to 71 cm by 2070, with a best estimate of 44 cm averaged globally. This will further compound impacts of delta subsidence and sediment trapping.
It has been estimated that even in the case of debilitating floods, sediment has not reached rivers in the deltas.In 2007–08 alone Ganges, Mekong, Irrawaddy, Chao Phraya, Brahmani, Mahanadi, Krishna and Godavari flooded with more than 100,000 lives lost and more than a million habitants displaced. Most of the deltas that suffered from floods did not receive a significant input of sediment, and this lack of sediment can be attributed to upstream damming. Some studies demonstrate that storage of sediment-laden water of major flood events leads to huge sediment trapping behind mega dams.
Above: Global distribution of ESLR under baseline for each of the 40 deltas studied by Ericsson et al, 2006.From Ericsson et al, 2006
Fluvial Sediments and Deltas in India
Rivers are not only conduits of water. They are a complex, moving systems carrying sediment, nutrients, organisms, ecosystems, energy, material and cultures in their wake.
There are three kinds of sediments: suspended, bed load and wash load. Here we are referring to mainly the suspended sediments in the rivers. Sediments play a significant role in the river geomorphology, defining the river channel, its shape and structure. Sediment deposits form alluvial floodplains, deltas, levees, beaches, ox bow lakes and lagoons and creeks. The sediment load and composition changes according to the river, the geological landscape it flows in, its length, flow, structure, etc. While much of the sediment is deposited by the river on its banks, the delta of the river is primarily formed of rich sediments. Through this deposition, the river may form distributaries at its mouth, like in case of Ganga, Brahmaputra or Mahanadi systems. Ganga-Brahmaputra Delta, shared by India and Bangladesh is one of the largest delta systems in the world, spanning more than 100,000 km2carrying more than one billion tonnes of sediments annually.
Deltaic populations in shared rivers of India, Bangladesh and Pakistan: Population of Ganga-Brahmaputra-Meghana Delta is more than 147 million people with a population density of more than 200 people per km2 (520 people per square mile), making it one of the most densely populated regions in the world . The Krishna Godavari twin deltas supports 9·26 million people inhabiting the 12,700 km2 area at 729 persons per km2, which is more than double the country’s average. Cauvery delta supports 4.4 million people while the Mahanadi Delta too supports millions. Only two districts of Cuttack and Jagatsinghpur have a population more than 3.7 million. (Census 2011) in addition, the contribution of deltas to economics, food production, transport, ecosystem services etc., is immense, making it a very valuable ecosystem which deserves protection. Indus Delta in Pakistan supports more than 900,000 people.
Deltas in Peril: Impact of damming on deltas in India
1. Krishna-Godavari Delta: In 2010, a team led by K Nageswar Rao of Dept of Geo Engineering, Andhra University, carried out an assessment of the impacts of impoundments on delta shoreline recession in Krishna and Godavari Delta. The study revealed a net erosion of 76 km2 of area along the entire 336-km-long twin delta coast during the 43 years between 1965–2008 with a progressively increasing rate from 1·39 km2 per year 1965 and 1990, to 2·32 km2 per year during 1990–2000 and more or less sustained at 2·25 km2 per year during 2000–2008.
For Krishna, flows as well as suspended sediments in the delta have nearly reached zero. Suspended sediment loads decreased from 9 million tons during 1966–1969 to negligible 0·4 million tons by 2000–2005. Syvitski et al in their 2009 assessment place Krishna in the category of “Deltas in Greater Peril: Virtually no aggradation and/or very high accelerated compaction.”
In the case of the Godavari delta, there has been almost a three-fold reduction in suspended sediment loads from 150·2 million tons during 1970–1979 to 57·2 million tons by 2000–2006. Syvistki et al classify Godavari delta as “Deltas in greater risk: reduction in aggradation where rates no longer exceed relative sea-level rise”. H Gupta et al (2012) suggest that decline in historic sediments of Godavari post damming has been as high as 74%.
Above: Graph indicating decadal sediment and water flow trends at Prakassam Barrage, across Krishna. Dam building also marked. From Rao et al, 2010
According to Dr. Rao, a comparison of data on annual sediment loads recorded along the Krishna and Godavari Rivers shows consistently lower sediment quantities at the locations downstream of dams than at their upstream counterparts, holding dams responsible for sediment retention. Reports based on bathymetric surveys reveal considerable reduction in the storage capacities of reservoirs behind such dams. Authors say: “Sediment retention at the dams is the main reason for the pronounced coastal erosion along the Krishna and Godavari deltas during the past four decades, which is coeval to the hectic dam construction activity in these river basins.”
Impacts of this can be seen in destroyed villages like Uppada in Godavari delta, destruction of Mangrove forests and shoreline. Similarly Krishna delta is losing land at the rate of 82·5 ha per year, leading to destruction of mangrove forests and loss of land.
The study concludes: “If the situation continues, these deltaic regions, which presently sustain large populations might turn out to be even uninhabitable in future, considering conditions elsewhere, such as in southern Iraq, where the farmers downstream of dams across Tigris River in Iraq, Syria and Turkey are being forced to migrate to urban centres as the reduced river flows become overwhelmed by seawater.”
I talked with Dr. Rao and asked him, if his disturbing study had any impacts. He said, no one from the administration has contacted him ever about this issue.
Above: Sediments measured at Sir. Arthur Cotton Barrage across Godavari near the Delta from Rao et al, 2010
A similar study by IWMI concludes: “Coastal erosion in the Krishna Delta progressed over the last 25 years (is) at the average rate of 77.6 ha/ yr, dominating the entire delta coastline and exceeding the deposition rate threefold. The retreat of the Krishna Delta may be explained primarily by the reduced river inflow to the delta (which is three times less at present than 50 years ago) and the associated reduction of sediment load. Both are invariably related to upstream reservoir storage development.”
Krishna Basin Water Disputes Tribunal Award, though mentions dam siltation (it mentions that in 5 decades, Tungabhadra Dam has silted up to 22% of its capacity), does not say anything about flow for flushing sediments or its importance to the delta in Andhra Pradesh, or if the “minimum instream flow” recommended by the Tribunal will address this issue. This is a major limitation of the tribunal, when advanced studies have been conducted on the Krishna River delta condition and its relation to upstream dams has been established beyond doubt. Only at one place does it mention that to reduce siltation of the Almatti Dam, sluice gates should be opened when water is flowing above the crest.
However, the Award states that issues like minimum in stream flows are not decided once for all and it is an evolving process. Let us hope that there is some space to address the issue of shrinking deltas through this.
Above:Decreasing Sediments of Krishna down the years from K Rao et al, 2010
In the upstream Maharashtra, more and more dams are under construction in the Krishna Godavari Basin. One of the proposed dams called Kikvi, at the headwaters of Godavari in Trimbakeshwar was cleared by the Forest Advisory Committee recently. Ironically, the proponent (Water Resources Department, Maharashtra and Nashik Municipal Corporation) justified this dam which will submerge more than 1000 hectares of land, by stating that one more large dam close to Kikvi: Gangapur Dam is heavily silted up. Rather than desilting Gangapur Dam, the administration wants to build one more dam.
Above: Trends in Sediments in Godavari and dam building activity. From K Rao et al
Many dams in Krishna Godavari Basin in Maharashtra have been criticised for not contributing to increasing irrigation.These dams are not only obstructing river flow, but are also acting as sediment traps. Unfortunately, the MoEF is not even considering impacts of sediments while appraising dams. In Karnataka, major projects are being undertaken by fraud, without environmental appraisal, violating Environment laws, similarly in Andhra Pradesh, many projects are being pushed illegally without environmental appraisal and which involve huge corruption.
2. Cauvery Delta: Although detailed studies have not been carried out, there is a clear indication of salt water intrusion and delta erosion in this over developed basin, due to upstream dams. The saline-freshwater boundary map indicates a steady migration inland.
A study by Gupta et al, 2012, indicates that historical sediment flux of Cauvery was 1.59 million tonnes, which is now 0.32 million tonnes (average of 10 years) and hence, there is a whopping 80% reduction in sediment flux of the river.
Unfortunately, the Cauvery Water Disputes Award Tribunal between Karnataka and Tamilnadu does not even mention the word ‘sediment’ in its award. There has been no justification for 10 TMC feet (Thousand Million Cubic feet) water recommended by the Tribunal for Environmental purposes and its possible impact on sediment carrying (or even environment for that matter).
Pennar showed 77% reduction and Mahanadi showed 67% reduction in amount of silt reaching the delta in recent years. (Gupta et al, 2012)
3. Narmada Delta: The west flowing rivers like Narmada and Tapi do not form extensive deltas like the east flowing rivers. Nonetheless, sediments from a huge river like Narmada play an important part in the stability of Narmada delta and villages and ecosystems around it.
Above: From: H. Gupta et al, 2007 and 2012
Gupta et al (2012 and 2007) assessed daily water discharge and suspended sediment load data measured by CWC at two gauging stations, one upstream of the Sardar Sarovar dam (Rajghat), and another downstream of the dam (Garudeshwar).
Historical sediment discharge of Narmada was found to be 61 million tonnes and the current sediment discharge (average of last ten years of the study) was found to be 3.23 million tonnes, indicating a reduction of 95% sediment discharge. The presence of dam reduces 70–90% of coarse and approximately 50% of medium-sized particles on their way downstream, allowing them to settle in the reservoir Comparative studies of average suspended sediment load at various locations on the Narmada River for more than two decades, show overall reduction in suspended sediment load in the river.
The study indicated 96% reduction in suspended silt flux in Sabarmati, 41% reduction in Tapi and 68% in Mahi.
4. Ganga- Brahmaputra Delta: Different studies put different values for individual and combined sediment load of the Ganga Brahmaputra system, which carries one of the highest sediment loads in the world. According to Islam (1999) Ganges and Brahmaputra rivers in Bangladesh transport 316 and 721 million tonnes of sediment annually. Of the total suspended sediment load (i.e. 1037 million tonnes) transported by these rivers, only 525 million tonnes (c. 51% of the total load) is delivered to the coastal area of Bangladesh and the remaining 512 million tonnes are deposited within the lower basin, offsetting the subsidence. Of the deposited load, about 289 million tonnes (about 28% of the total load) is deposited on the floodplains of these rivers. The remaining 223 million tonnes (about 21% of the total load) is deposited within the river channels, resulting in aggradation of the channel bed at an average rate of about 3.9 cm/yr sediment.
Across the 20th Century, Syvitski et al suggest about 30% reduction of silt load in the river system. Gupta et al  suggest that the observed decrease in sediment load could be due to construction of several mega dams in the Ganga basin, closure of Farakka barrage (1974) and diversion of sediments laden water into the Hooghly distributary. They also caution that dams in Ganga and Brahmaputra can worsen the situation.
5. Indus Delta: Inam et al (2007) assessed annual sediment loads of the Indus river at Kotri Barrage (270 km upstream from river mouth) during the last 73 years. The study indicates that annual sediment load of the Indus river has reduced drastically from 193 Mt (between 1931 and 1954) to 13 Mt (between 1993 and 2003). According to them, construction of three large dams on the Indus river, namely Kotri Barrage, Mangla and Terbela led to this situation causing annual water discharge to reduce from 110 km3 to 37 km3, with disastrous impacts on the delta ecosystem and population.
Above: Variation of water and sediment discharge below Kotri Barrage in Indus basin: Inam et al
Inam states : “Currently the Indus river hardly contributes any sediment to the delta or Arabian Sea.The active delta is reduced from 6200 km2 before construction of dams to 1200 km2. The sea water has travelled upstream upto 75 kms, combined loss of freshwater and sediment has resulted in loss of large areas of prime delta agricultural land and submergence of several villages in the coast. This has caused desertification and displacement of several hundred of thousands of local residents. Study of records and bathymetric maps from 1950 indicate widespread coastal retreat…The life on the delta is dependent on availability of freshwater and sediment. Severe reduction of both as a result of dams and barrages and associated structures in the upstream has resulted in pronounced erosion in parts of the delta and reduction in mangroves. Environmental studies to be extended to the entire Indus ecosystem from the mountains to the Arabian sea.”
It is clear that deltas and dependent populations and ecosystems have suffered due to near total ignorance about the impact of dams on sediment and deltas and if immediate action is not taken then, this will impact a huge population and a large eco-region in Indian subcontinent, as elsewhere.
The impacts of nutrient rich sediment retention and flow reduction is not limited to teh delta, but has also affected marine fish production
The issue of impact of a dam on the sediment regime of the river is not being studied or considered at all while conducting Environmental Impact Assessments of projects, appraising the project for options assessment, environmental clearance, cost benefit analysis or through post clearance monitoring and compliance.
Sediment release and sediment transport through rivers is not being raised in trans-boundary river negotiations.
Looking at the severity of the issue and its far reaching impacts on millions of people in India and across the world, there is a need for adopting urgent and strong mitigation measures against sediment trapping in dams.
It has to be remembered that for older dams, older hydropower projects and most irrigation projects, there is no mechanism available to flush the accumulated silt.
Sediment retention also reduces the life of the dam, while starving the river and delta in the downstream of sediment. As per a study by SANDRP in 2006, India may be losing 1.95 Billion Cubic Meters of Storage capacity of its reservoirs annually. This implies that the rivers are losing at least that quantity of sediment annually.
The frantic dam activity in Indian Himalayas at this moment will have a serious impact on Ganga Brahmaputra Delta in India and Bangladesh and Indus Delta in Pakistan. There is an urgent need to, firstly, acknowledge these links, assess the impacts, include them in cost benefit and options assessment, address the issues and implement mitigation measures, where relevant, abandon the projects where impacts are unacceptable projects unviable.
In case of the Ganga Brahmaputra delta, recent studies have indicated that the main source of sediment in the river is the Himalayas. Of the entire sediment load of Ganga catchment (This study assumed it to be 794 million tonnes/year), 80+/-10 % comes from High Himalayas and 20+/-10 % comes from Lesser Himalayas.
Bumper to bumper dam/ hydropower project building is occurring in almost all of the Himalayan states in India, which is poised to make Indian Himalayas most densely dammed region in the world. All of these dams are located in the downstream of the Greater and straddling Lesser Himalayas and can together have a tremendous impact on Ganga’s sediment load. Uttarakhand is planning and building nearly 336 Hydroelectric projects,while Sikkim and Himachal Pradesh too are building hundreds of hydro projects. Arunachal Pradesh intends to dam most of its rives to produce hydropower.
No studies on impact of these projects on sediment regime of the rivers are being carried out for; neither does the MoEF insist that projects will not be cleared unless such studies are carried out. Even Cumulative impact assessments are not assessing this aspect.
Some stark examples:
The Cumulative Impact Assessment Report of the Upper Ganga Basin in Uttarakhand (where more than one hundred dams are planned and under construction back to back) was doen by IIT Roorkee. This cumulative impact assessment did not study any cumulative impacts due to reduced silt load of the river following major dam push.
The Lohit Basin Study done by WAPCOSwhich involves more than 12 dams across the Lohit River, one of the three main segments that form Brahmaputra, does not mention anything about impacts of dams on sediments. The only thing it states is very worrying : “Due to substantial storage capacity, the Demwe Upper reservoir will have high sediment retention capacity and a large proportion of sediments carried by the Lohit River will get settled in the reservoir.”
Siang Basin Study (by RS Envirolinks Pvt Limited), which involves three mega dams across the main stem Siang, completely obliterating free flowing stretches in the river,in addition to 42 hydropower dams, does not mention anything about sediment regime, although being specifically asked to address this issue by the Expert Appraisal Committee, Union Ministry of Environment & Forests (MoEF).
1500 MW Tipaimukh Mega Dam near Bangladesh Border, which has received Environmental Clearance from MoEF does not study the impacts of sediment retention on downstream Bangladesh, and this concern has been raised by the groups in that country. The Environment Management Plan of this project which can submerge 25000 hectares of forests does not even mention the word “sediment”.
The bumper to bumper dam building activity in Himachal Pradesh in Satluj, Beas, Chenab and Ravi rivers will have a major impact on silt load reaching the Indus river Basin and the Indus Delta in Pakistan. However, none of the EIAs or EMPs mention any impact of the dams on the sediment regime of the river.
In conclusion, although the risks of delta subsidence, effective sea level rise and its impact on a huge population and ecosystems has been established, these risks are being entirely ignored in the current governance surrounding rivers and deltas.
National Centre for Sustainable Coastal Management It is unfortunate to see that MoEF’s National Centre for Sustainable Coastal Management, supported by MoEF and World Bank does not allude to this issue or raise it through any publications. In conversation with SANDRP, Director R. Ramesh said that the center may look at these issues in the future. However, its publications on National Assessment of Shoreline Changes on Tamilnadu and Odisha do not mention upstream dams, although robust evidence exist that Cauvery delta and Mahanadi, Brahmani and Baitarni deltas are eroding due to sediment retention. Let us hope this institute will try to highlight the impact of dams on deltas with the seriousness it deserves.
1. Urgently study impacts of sediment retention by dams on delta population and ecosystems: MoEF, Ministry of Rural Development and Urban Development should conduct an in-depth study to understand the scale of the problems and the extent of affected people and ecosystems due to sediment impoundment by upstream dams.
2.Urgently study the optimal level of sediments (and water regime) needed for stabilising deltas and reducing subsidence.
3. Urgently institute a study to assess the extent of sediment and flows needed to be released from upstream dams and feasibility of such releases on regular basis, mimicking the river’s hydrograph. Where dams have sluice gates, these should be opened in monsoons where feasible, to allow sediment flushing. Even in dry and stressed river basins like Colorado in the United States, such high releases for redistributing sediments have been conducted in the 1990s and again in 2013 with proper planning and impact assessment.
4. In Krishna and such other basins, where delta subsidence, coastal erosion and related impacts like salinity intrusion and storm surges has reached serious proportions, specifically problematic dams should be considered for decommissioning.
Environmental Appraisal Process
Study of impact on sedimentation and siltation should be a part of the environmental impact assessment, environmental appraisal and clearance process.
There should be a separate section in EIA for e-flows and sedimentation studies. Similarly such studies should be mandatory part of cumulative impacts, carrying capacity and basin studies.
More dams in basins which support large deltaic populations and those having significant impacts of sediment retention by reservoirs should not be cleared.Let us hope that this chronically neglected issue receives the attention it deserves. Delta subsidence and ESLR due to upstream damming again highlights the complex and interconnected nature of the riverine ecosystem. The environmental governance in India ( as also South Asia) surrounding rivers has been treating rivers with an extremely piecemeal approach. It is clear that with the herculean challeneges we face now, such an approach is no longer affordable.
…especially in the part called Delta, it seems to me that if the Nile no longer floods it, then, for all time to come, the Egyptians will suffer – Herodotus, History, c 442 BC (stated in Patrick McCully’s Silenced Rivers)
The Mohanpura Project The proposed Mohanpura dam is to be constructed by the Madhya Pradesh Water Resources Deparment near the village Banskhedi of District Rajgarh, Madhya Pradesh on river Newaj in ChambalRiver Basin. The earthen dam project envisages irrigation of 97,750 ha, including the irrigable area of 62250 ha in Rabi and 35500 ha in Kharif in Rajgarh and Khilchipur Tehsils of Rajgarh district. The Environmental Impact Assessment (EIA) dated May 2013 has been done by WAPCOS, an agency under Union Water Resources Ministry.
The EIA and the EAC We have provided below some critical comments on the EIA, these are only indicative in nature and not comprehensive. These comments were sent to the Ministry of Environment and Forests’ Expert Appraisal Committee (EAC) on River Valley Projects for its meeting in June 2013 and further comments for Sept 2013 and Nov 2013 EAC meetings. We were glad that EAC asked the project proponent to reply to our submission in detail. But we did not get any reply directly either from the project proponent or MoEF. We several times checked the relevant section of MoEF website before the Nov 11-12, 2013 EAC meeting and did not find any additional submission from the project proponent or EIA consultant except the EIA and earlier submissions. We also wrote to the EAC and MoEF officials about this absence of any response from the proponent or the EIA consultant and they did not respond to our emails.
However, while looking for something else, on Nov 13, 2013, on clicking the EIA (which we assumed was the old EIA), what we got was the Oct 2013 response from the project proponent that supposedly included the response from WAPCOS to our submission. This seems like an attempt on the part of MoEF officials to camouflage/ hide the reply so that the reply is put up, but we do no get a chance to review and respond to it. This is clearly wrong and we have written on Nov 13, 2013 to that effect to the MoEF director Mr B B Barman who is also member secretary of the EAC.
In any case, the WAPCOS reply of Oct 2013 does not really provide adequate response to any of the points we raised as we have discussed in the following sections. If the EAC had applied its mind, EAC too would have come to the same conclusion. However, if EAC decides to recommend clearance to the project based on this reply by WAPCOS, it will not only show lack of application of mind and bias on the part of the EAC, the project clearance would also be open to legal challenge.
In what follows we have provided main critiques of the EIA and the project.
EIA does not mention that the project is part of Inter-Linking of Rivers The Mohanpura dam is part of the Government of India’s Interlinking of Rivers scheme, specifically part of the Parbati-Kalisindh-Chambal (PKC) scheme, see for example the mention of Mohanpura dam on Newaj river in salient features of the PKC scheme at: http://nwda.gov.in/writereaddata/linkimages/7740745524.PDF, the full feasibility report of the PKC scheme can be seen at: http://nwda.gov.in/index4.asp?ssslid=36&subsubsublinkid=24&langid=1. This hiding of this crucial information by the Project Proponent is tantamount to misleading the EAC and MoEF and should invite action under EIA notification. The claim by WAPCOS (through their response in Oct 2013) that this was mentioned in DPR is clearly not tenable since this should have been mentioned in the EIA.
Much bigger Mohanpura Reservoir proposed compared to the PKC proposal It is clear from the perusal of the Feasibility of the PKC link given on the NWDA link that the project now proposed by the Govt of Madhya Pradesh is much bigger and actually an unviable scheme. The Gross and live storage of the NWDA scheme is 140 MCM and 52.5 MCM, where as the proposal now before the EAC has gross storage of 616.27 MCM and live storage of 539.42 MCM (page 1-328 mentions Live storage as 616 MCM, showing another instance of shoddy work of WAPCOS), which means the live storage proposed now is more than ten times the live storage proposed in NWDA scheme. It may be noted that there is less than 4% difference in catchment area of the two schemes, the NWDA site was slightly upstream with the catchment area of 3594 sq km, compared to catchment area of now proposed scheme being 3726 sq km, the difference between the two is only 132 sq km.
This does not warrant or justify more than ten time higher live storage. In fact the NWDA scheme had the proposal to transfer 464 MCM from the Patanpur Dam to the Mohanpura dam and yet, under the Mohanpura live storage capacity proposed under NWDA scheme was much smaller. It is clear that the proposal before NWDA is completely unviable proposal and should be rejected.
No justification for increasing the live storage capacity OVER TEN TIMES This is a very serious issue and unless this is satisfactorily resolved, EAC should not consider the proposal.
Here it should be point out that the following discussion in the 67th EAC meeting regarding the SANDRP letter is misleading: “The developers were asked to clarify doubts raised in the above letters relating to the project features that contradict with the assumptions made in the NWDA study of Parbati – Kalisindh – Chambal Scheme, a major issue is that the NWDA scheme envisaged a gross and live storage provision of 140 and 52.5 MCM respectively against the present proposal 616.27 and 539.42 MCM respectively because the NWDA proposed transferring 464 MCM from Patanpur dam to Mohanpura Reservoir to reduce the large submergence of Mohanpura Reservoir. The developers clarified that the NWDA scheme has not been accepted by the M.P. Government and is not likely to be implemented in the near future. The M. P. Government wants immediate implementation of Mohanpura Project for poverty alleviation of the backward Rajgarh District.”
The issue is not only about how NWDA plans differed from the current proposal in terms of transferring 464 MCM water to Mohanpura dam from Patanpur dam and transferring 403 MCM from Mohanpura dam to Kundaliya dam. Net effect of these two transfers is addition of less than about 61 MCM water to Mohanpura dam in NWDA proposal from outside the Newaj basin. In spite of this addition, the storage capacity of the Mohanpura dam in NWDA proposal is HUGELY LOWER than in the current GOMP proposal. There is clearly no justification for such huge storage capacity from any angle. Even the water use plan has exaggerated figures and does not change even with changed cropping pattern. The issue is the viability, desirability, need and optimality of the ten times larger reservoir than was NWDA proposed earlier.
Unfounded assumption about water availability The project assumes huge yield of 745.2 MCM, much higher than that assessed by the Chambal Master Plan, without assigning any reason. This seems to be a ploy to push for unjustifiably huge reservoir. This is clearly wrong and the proposal should be rejected. The reply by WAPCOS that “The calculated yield of dam is approved by Bureau of Design of Hydel & Irrigation Project (BODHI), M.P.” is not convincing since BODHI is government of Madhya Pradesh organisation and in any case, their approval letter and methodology details have not been attached. In any case, Newaj being in interstate Chambal river basin, it will need vetting by the interstate Chambal River Board or credible independent body.
Inadequate assessment of upstream water requirement The EIA does not do proper or adequate assessment of current and future water requirements of upstream areas and allocates almost all available water in the catchment to the project in a bid to justify unjustifiable project. The figures given in table 10.9 are not even substantiated with any basis and hence are far from adequate in the context. The PP has also not responded to the EAC query about the upstream water demand.
Unjustifiable submergence The proposal entails submergence of 7051 Ha, almost three times the submergence as per NWDA scheme of 2510 ha. The project proponent has hugely underestimated the number of affected families to 1800 against private land acquisition of 5163 ha. They have amazingly, allotted just 132 ha of land for R&R, when land for land provisions under the MP R&R policy will require much more than 5000 ha just for R&R. The social impact assessment has not been done at all. In fact the phrase Social Impact Assessment or Social Impact does not figure in the entire EIA, when the National Green Tribunal has been laying such a stress on SIA.
The whole social impact assessment of the proposal now submitted is shoddy. It is clear the huge displacement is unjustified, and the project proponent has no interest in even doing any just rehabilitation. The PP has not explained the justification for three times increasing the submergence area compared to the NWDA proposal.
Interstate aspects ignored The project is coming up on an interstate river basin and will have clear implications for the downstream state of Rajasthan, but there is no mention of this in the EIA. Several meetings have also happened between Madhya Pradesh and Rajasthan about the PKC link mentioned above. The Government of India has prioritized this link, but by taking up this project unilaterally without consent of Rajasthan or Centre (Ministry of Water Resources) the Madhya Pradesh government is violating the interstate and federal norms. The EIA does not even mention any of these issues.
Underestimation of Land required for Canal The project has command area of 97750 ha and claims that it will require just 152 ha of land for canals (table 2.6 of EIA), which is clearly a huge under estimate and is not based on any real assessment. The project will require several times more land for the canals and will have related social and environmental impacts which have not even been assessed. The response from WAPCOS that this is because most of the water conveyance system is underground is far from adequate since an assessment of land requirement should still have been done and a lot of land would still be required at the end of water conveyance system.
No Command Area Development Plan The EIA report (May 2013) mentions CAD in two sections: Section 2.8 and 10.9. However, perusal of both sections show that neither have full description of Command Area Development Plan or adverse Impacts of the project in the Command Area including drainage, health, biodiversity and other issues.
Shocking statements in Command Area Development Plan The CAD now annexed in the Additional information (dated Aug 2013) makes some shocking statements. e.g. It says: “GCA of the project is 928680 ha…” with an extra “0”. This seems to suggest that the EIA consultant is callous.
The CAD further says: “Maximum height of the spillway above the ground will be 47.90 m (measured from river bed level to top of the spillway bridge). Maximum height of spillway from expected foundation level will be 47.90 m.” So the height of the spillway above the riverbed and above the foundation is same! This means that there is no foundation of the dam below the riverbed level! This again shows the callousness and lack of understanding of basic concepts by WAPCOS.
Section 2.9 of CAD says: “The groundwater development is of the order of 6.9% to 8.7% in the command area blocks.” In reality, as the table 2-3 just below this statement shows, the groundwater draft is 69 to 89%.
Section 3.1 of CAD says: “…the catchment area intercepted upto Mohanpura dam site is 3825 sq.km.” The last sentence in the same para says: “The catchment area intercepted at the dam site is 3726 sq.km.” Such figures for the catchment area upto Mohanpura dam keeps appearing in the documents.
The CAD should start with clear statement of HOW MUCH OF THE PROPOSED COMMAND AREA IS ALREADY IRRIGATED. This is not even mentioned.
No Downstream Impact Assessment The EIA report has not done any downstream impact assessment, including the impact on biodiversity, livelihoods, draw down agriculture, water security, groundwater recharge, geo-morphological impacts, among others. The response of WAPCOS in Oct 2013 that Newaj is a monsoon fed river and hence there are no downstream impacts is completely inadequate and shows the lack of understanding of functions of the river on the part of WAPCOS.
Impact of project on National Chambal Sanctuary It may be noted that the project is to be constructed on Newaj river, a tributary of the Chambal river. The project will have significant impact of water, silt and nutrient flow pattern into the ChambalRiver, the approximate 600 km of which has been declared as National Chambal Sanctuary between 1979-1983 across three states of Madhya Pradesh, Rajasthan and Uttar Pradesh. However, the EIA does not even mention that the National Chambal Sanctuary exists down stream of the proposed project and will be impacted by the project. According to section 29 of the Wildlife Protection Act of 1972, any project that affects flow of water into or out of the protected area should be assessed for its impact on such sanctuary and necessary clearances be taken from the designated authorities including Chief Wildlife Wardens and National Wild Life Board. However, WAPCOS does not even seem aware of the existence of the sanctuary.
Another point to note is that the entire water availability in the NCS is dependent on the KaliSindh and Parbati since there is no discharge below the Kota Barrage. The response from WAPCOS (Oct 2013) that the Mohanpura catchment is about 200 km from the river and that it is just 2.5% of the Chambal catchment and hence will not have any impact is clearly untenable. Firstly, the EIA does not even mention the existence of National Chambal Sanctuary. Secondly, it is not the distance of % catchment, but the impact of the abstraction that is important and the EIA has clearly not done that.
Impact of mining of materials for the project not mentioned The EIA has some assessment of material required to be mined for the project at Table 2.7, but where will these materials come from and what will be the impacts of this is not even mentioned.
No proper Options Assessment The EIA does not do proper options assessment to arrive at the conclusion that the proposed project is the most optimum proposal. It may be noted that the area has rainfall of 972 mm (see Chapter 2 in Command Area Dev Plan in Additional Information dated Aug 2013) and there are a lot of options for local water systems. As is clear from the public hearing report, several farmers suggested that in stead of one big dam a series of smaller dams should be built and that farmers will have to commit suicide if the dam is built. The response in the EIA is most callous that this is not technically feasible is not even backed by any evidence, which again shows the shoddy nature of the EIA.
The response of WAPCOS (Oct 2013) that the project is justified for fluoride affected area is completely misleading since if that was the concern than much smaller dam and large number of rain water harvesting structures would better serve the purpose. This again shows that WAPCOS has not done any options assessment.
Public hearing in the office of the DM? Chapter 17 of the EIA says, “Public Hearing for Mohanpura Multipurpose Major Project was conducted by Madhya Pradesh State Pollution Control Board (MPPCB) on 11th March 2013 in the premises of the office of the District Magistrate, Rajgarh”. This is most shocking state of affairs. The Public hearing as per the EIA notification is supposed to be conducted at the project site and cannot be conducted in the office of the District Magistrate. The MoEF should have applied its mind on just this aspect and rejected the proposal and asked them to get the public hearing done in legal way. The public hearing report is also incomplete with several sentences not being complete. This again shows lack of application of mind on the part of the MoEF and WAPCOS. The response from WAPCOS in Oct 2013 that the DM office is just 9 km from the dam site and is convenient to all concerned is clearly wrong, the public hearing should have been conducted in the affected area and public hearing report should be full and cannot be accepted with half sentences. This public hearing will also not pass the legal scrutiny.
CUMULATIVE IMPACT ASSESSMENT FOR CHAMBAL BASIN A very large number of dams and other water use projects have been constructed, are under construction and under sanction in the ChambalRiver Basin. It is high time that a Cumulative Impact Assessment (CIA) and carrying capacity study for the ChambalBasin be done before any more projects are considered in the basin. This is also required as per the MoEF Office Memorandum (J-11013/1/2013-IA-1 dated May 28, 2013) that required states to initiate CIA in all basins within three months, that is by Aug 28, 2013.
Unacceptable EIA The whole EIA is done in most shoddy way and should be rejected for this reason and EAC should make recommendation for black listing of WAPCOS as EIA agency. Just to illustrate, the EIA says MDDL stands for Maximum Draw Down level (page 1-14), has not even mentioned the project impact on the National Chambal Sanctuary (one of the only two river sanctuaries of India also proposed as Ramsar site), for hugely inadequate R&R land and canal land requirements, for not doing impact of mining of materials for the project, for not assessing the hydrological viability of the project, for making unfounded assumptions, among other reasons mentioned above.
Issue of Conflict of Interest for WAPCOS It may be noted that WAPCOS is a Ministry of Water Resources organization, and has been in the business of doing pre-feasibility, feasibility reports and Detailed Project Reports, which are necessary for the justification of the projects. This is part of the business of the organization. Such an organization has clear conflict of interest in doing an honest EIA since an honest EIA can lead to a possible answer that the project is not viable. Hence EAC should recommend that the WAPCOS should be debarred from doing any EIAs or CIAs (Cumulative Impact Assessments).
Other Issues Besides the above, a large number of issues raised by EAC in 67th meeting remain unresolved.
Þ For example, the area to be inundated by dam break needs to be listed and shown on map, which has not been done.
Þ EAC had asked: “Details of drainage network planning be included in the report.” In response, PP has attached Annex III which is just a map!
Þ EAC had asked: “75%flow series gives a total yield of catchment as 25.77 cumec-10 days in 75% dependable year. Whereas in table-5.2 the 75% dependable yield is given as 749.71 Mcm. The same needs to be corrected. Corresponding corrections at relevant sections in Volume-II, EMP report also be done”. This has not been done except an amended table
Þ Annex XIV in Additional Info on “INCOME – EXPENDITURE DETAILS OF PAFs” leaves a lot to be desired. Here, what does the figures represent in Table 1 is also not clear.
Þ Annex XV in Additional Info volume is basically a reproduction of 10.11.6 from the EIA. Incidentally, it ends by saying: “Project planner need to understand the negative impacts with sensitivity, and formulate mitigation measures appropriately; such mitigations measures that would be acceptable to the concerned population groups and that are sustainable.” The proposed project or the R&R plan are neither acceptable to the concerned population groups, nor sustainable, in any case, there is no process to achieve this.
Þ EAC had asked for more no of villages in the sample compared to 9, but the EIA consultant has refused to do this (Annex XVI and XVII in additional Info) without any convincing reason.
CONCLUSION In view of the above, we urge EAC to:
1. Reject the proposal for environmental clearance. It will be most shocking if the project gets cleared with this kind of EIA.
2. Reject the EIA, as explained above this is most shoddy EIA.
3. Reject the Public hearing; as explained above, the public hearing has not been conducted as legally required. The public hearing also need to be conducted again since the EIA is found to be so seriously inadequate and needs to be redone. In any case, with so many additions and changes to the EIA, the public hearing clearly needs to be redone.
4. Suggest black listing of WAPCOS as EIA and CIA agency. It is high time for EAC to send a signal that such shoddy EIA would not be accepted and is in violation of law.
Submission showing how the WAPCOS EIA of Mohanpura Project is Inadequate and Plagiarised
Sep 23, 2013
Chairman and members,
Expert Appraisal Committee on RiverValley Projects,
Ministry of Environment and Forests,
New Delhi Subject: Serious concerns on the Mohanpura Irrigation Project on agenda for the 68th meeting of EAC of RVP
Dear Chairman and Members of the EAC-RVP,
With reference to the Mohanpura Irrigation Project on agenda for the 68th meeting of the Expert Appraisal Committee on River Valley Projects, and WAPCOS response to EAC comments (August 2013), I believe that the concerns raised by the New Delhi based SANDRP has not been addressed. The Project Proponent has also not responded satisfactorily to the queries raised by the EAC, and I outline a few of their (WAPCOS) responses below –
EAC Comment No. 16: The source of data for faunal population is to be provided. The source of secondary information may be provided if used.
EAC Comment No. 17: The avifaunal list is good but requires a lot of typographical corrections. Also some of the species such as Golden Plover and Redshank have been shown as resident although they are migratory.
EAC Comment No. 18: The list of reptiles appears deficient for this hot and dry area of central India. This needs to be updated. The information provided by WAPCOS under-represents the faunal richness of the region and is an attempt to deceive the Expert Appraisal Committee on River Valley Projects. The sources used in the EIA are old and I would like to draw you attention to more recent work from the region (attached below).
Nair, T. & Krishna, Y. C. (2013). Vertebrate fauna of the ChambalRiver Basin, with emphasis on the National Chambal Sanctuary. Journal of Threatened Taxa, 5(2): 3620–3641; doi:10.11609/JoTT.o3238.3620-41
EAC Comment No. 19: The methodology for faunal surveys has not been provided properly. The faunal part in section 4.2.2 is too brief and fails to provide any idea about the primary effort. The source of secondary information may be provided if used. The methodology outlined in Annexure-XII by WAPCOS has simply been copied from other survey reports / studies without actually conducting them. This amounts to professional dishonesty and fraud, and is another attempt to deceive the EAC-RVP.
EAC Comment No. 20: The presence/absence of Blackbuck, a Schedule-I species, may be commented upon since it is expected in the area. WAPCOS response that ‘Blackbuck is not reported in the area’ is again not true. Please refer to the press report and scientific study which show the presence of black buck from the area. Press report: http://articles.timesofindia.indiatimes.com/2013-01-05/flora-fauna/36162066_1_blackbuck-population-stray-dogs-habitat Scientific publication: Karanth, K. K., Nichols, J. D., Hines, J. E., Karanth, K. U. and Christensen, N. L. (2009), Patterns and determinants of mammal species occurrence in India. Journal of Applied Ecology, 46: 1189–1200. doi: 10.1111/j.1365-2664.2009.01710.x I believe that such a manner of plagiarism and false claims of having used scientific methods during the Environmental Impact Assessment is reason enough to reject the project and to blacklist WAPCOS. Further, the Government must initiate civil and criminal proceedings against WAPCOS for fraud, suppressing facts and providing misleading information on an issue that has serious and negative ecological and social consequences.
The EIA of the Bansujara Multipurpose Project (BMP) dated May 2013 by WAPCOS has been submitted for Environment Clearance of the project before the Expert Appraisal Committee on River Valley Projects, in Nov 2013. WAPCOS is known to do very shoddy job of Environment Impact Assessments, this one is no different. In what follows I have given a few instances of wrong facts, contradictory facts, wrong calculations or assumptions, incomplete assessments, instances that shows it is cut and paste job and lack of options assessment by the 564 page EIA document. The conclusion is inescapable that the EAC and MoEF must reject this EIA and recommend black listing and other measures against WAPCOS. The project should be asked to get a fresh EIA done by a credible agency.
WRONG FACTS The EIA provides several completely wrong facts, here are a few instances:
1. River description On p 1-1 the EIA says: “The Bansujara Dam Project lies in Dhasan sub-basin of Betwa basin, River Betwa is a tributary of Yamuna river, rises in district Bhopal district at an elevation of 472 m. After traversing a length of 365 km, it joins Yamuna river in Uttar Pradesh. The river runs for nearly 240 km in Madhya Pradesh, 54 km along common border of Madhya Pradesh and Uttar Pradesh and 71 Km in Uttar Pradesh state before its confluence with Yamuna river near Hamirpur town in Hamirpur district of Uttar Pradesh.” This is actually the description of River Dhasan and not Betwa! It is exactly same as the description of river Dhasan given on the next page and several other places subsequently.
2. Land required for Canals In Table 2.3 it is stated that canals will require 44 ha land, this is clearly gross under-estimate considering even 49.9 km of main canal.
3.Private land under required for project The SIA says on page 1-2, “About 935.11 ha of culturable area, 57.49 ha of forest land and 4209.118 ha of other land including road, nallah, river, etc. will be affected.” This is blatantly wrong figure. On page 1-3/4 of SIA it is stated: “About 2935.11 ha of revenue/government land and 2894.37 ha of private land is to be acquired.” This again is wrong.
As the MoEF factsheet for the Forest clearance for the project says, “Apart from the 57.495 hectares of forest land proposed to be diverted, the project involves submergence of 287.951 hectares of government land and 4,856.276 hectares of private land.” Thus the suggestion by the SIA that only 935.11 ha of culturable land is going under submergence is clearly wrong since most of the private land is under cultivation in these villages.
4.How many families will be affected The MoEF Factsheet for the project says: “The project involves submergence of 21 villages. 2628 houses, 773 wells, 5082 trees, and 2628 families with population of 13,142 are getting affected due to submergence.” These figures are at variance with the figures mentioned in the EIA. For example, the SIA (p 1-4, repeated on page 4-1) says: “Over all 748 families of 9 Abadi Villages will be affected”. This when the project will be taking away 2628 houses as per the Fact sheet, is clearly gross wrong reporting of figures. Because of use of wrong figures, their R&R plan and R&R costs are also all wrong and gross under estimates. Moreover, now the R&R plan and costs should be as per the new Land Acquisition Act Passed by the Parliament, which has not been done in the EIA-SIA. As per the new Act, land has to be provided to each losing farmer, and this must be followed.
5. Completely impossible figures of crop yields A look at table 4.3 of SIA (repeated in table 7.1 of CADP) shows that the consultants have given crop yields before project (e.g. paddy 7 t/ha, wheat 18 t/ha, groundnut 10 t/ha and gram 10 t/ha) which are much higher than the average of even Punjab crop yields and they are expecting to double that post project! These are clearly impossible figures. This shows that the consultants are plain bluffing and seem to have no clue about possible crop yields and in any case do not seem to have done any surveys, but are only cooking up data. Amazingly, they are claiming that with 211% increase in crop yield, the profits from crops will go up by 318%! All this simply shows the manipulations they are indulging in to show the project is economically viable.
CONTRADICTORY FACTS 1.Main canal length Page 2-2 says main canal length is 90 km, the salient features on next page says Main canal length is 49.9 km.
2.Command area Tehsils and villages Section 10.2 of EIA (and again section 2.7 of the CADP) says: “The Command area of the proposed Bansujara Major Irrigation project lies within the district Tikamgarh in jatur and Baldeogarh tehsil” and than goes on to give details of these tehsils, but the rest of the document (e.g. section 6.1) says: “A total of 124 villages are likely to be benefitted by the project. 80 villages are located in Tehsil Khargapur of district Tikamgarh. About 13 villages are located in tehsil Jatara of district Tikamgarh. The remaining (31) villages are located in tehsil Palera of Chattarpur district.” Chapter 6 in fact provides full list of 124 villages in the command area. The subsequent details of the command area given in chapter 10 thus does not match with what is given say in chapter 6.
Contradicting this, page 1-4 of SIA says: “The Bansujara Multipurpose Project will benefit almost 132 villages in districts Tikamgarh and Chattarpur.” Amazingly, the SIA says Palera tehsil is in Tikamgarh district and not in Chattarpur district and that additional ten villages of Badamalhera tehsil of Chattarpur district will also be in command area!
Number of beneficiary villages in Palera tehsil are given as 31 in page 44 (chapter 6) and 30 on page 141 (chapter 11), with even names differing, e.g. Banne Khurd and Bastaguwan mentioned in chapter 6 are missing in chapter 11, village Bargram mentioned in chapter 11 is missing from the list in chapter 6.
All this is most callous and shocking. This fact alone should be sufficient to REJECT this callous EIA and recommend blacklisting and other punitive measures for WAPCOS as consultant.
3.Command area population Section 10.2.1 of EIA says: “As per 2001 Census the total population of the command area is about 38,000. The male and female population is 20,181 and 17,828”. However a look at the 10.2 that follows this sentence shows that these figures are for Jatara tehsil and not command area. Another sign of callousness.
4.Submergence villages Table 11.3 of EIA gives list of Project affected families, which is at variance with the list given in tables 10.8-10.14. Firstly, chapter 10 tables say that 14 villages of Tikamgarh Tehsil are affected, but table 11.3 lists only 13 villages. More shockingly, tables in chapter 10 say 6 villages of Bada Malhera tehsil of Chhatarpur district are affected, whereas the name of this tehsil given in chapter 11 is Bijawar. All this shows shocking callousness of WAPCOS.
5.Storage Capacity Page 11-10 says: “The storage capacity of Bansujara Reservoir is 539.42 Mm3.” This is clearly wrong, the figures for gross and live storage capacity given in salient features and elsewhere are: 313.1 MCM and 272.789 MCM respectively.
6.Water Availability As per Table 5.8, water availability at the project site from MP catchment (2788 sq km) alone is 843 MCM. Strangely, this reduces to 588.68 MCM in table 11.6 for whole of catchment (3331.776 sq km) at dam site. No explanation is given for these figures.
7.Submergence area While most of the document gives submergence area as 5201.71 ha. However, in section 2.7 of EMP, it says, “The submergence area of Bansujara Irrigation Project is 7476 ha.” This is amazing kind of contradiction.
WRONG CALCULATIONS/ ASSUMPTIONS 1.Field channel length grossly underestimated The p 6-6 of EIA says: “The Bansujara Dam Project envisages irrigation over a CCA of 54000 ha. In the areas where irrigation is proposed no field drainage, land shaping of field channels exist and used to be constructed. From general experience and existing practice, it is assessed that a length of 1600 m of field channels will be required to serve a chak of 40 ha of CCA. On this basis, an approximate network of total length of 180 km of field channels will be required for 50% of CCA proposed for irrigation.” Simple calculation suggests that the field channel length for 50% of CCA would be 1080 km (54000 ha / 40 ha per 1.6 km divided by 2 for 50% CCA).
2.Drainage requirement under estimated Section 6.9 (p 6-7) of EIA says, “The command area is being traversed by a large number of nallahs and drains, therefore field drainage should not pose any problem.” This is clearly wrong assumption since additional irrigation will certainly require additional drainage and cost calculations based on such flawed assumptions are bound to be wrong.
3.Baseless assumption about waterlogging Similarly about the assumption in section 6.13 (p 6-8): “Even after construction of Bansujara Dam Project the area will not face any waterlogging problem.”
4. Wrong claims about no floods The conclusion about flood and back water impacts is completely unfounded in section 6.14 (p 6-8): “As per information gathered from the Collectorate Tikamgarh there is no village affected due to back-water of Dhasan and Ur rivers. The existing drainage system in the command is adequate. The statistics gathered from collectorate Tikamgarh show that there is no flood affected area. The command has fairly good flood disposal capacity and not special measures are called for.” This when the Maximum water level of the dam is full 1.4 m above the FRL, the back water level is found to be high. This is also particularly relevant in flood prone basin like Betwa-Dhasan.
5.Drainage characteristics of clayey soils ignored The assumption in section 7.1 (p 7-1) shows complete lack of understanding on the part of EIA consultants: “The area is sloping gently and near its outfall into Betwa river, the slope is of the order of 0% to 3%. It is traversed by small drainage channels at short distances and they help in draining excess water efficiently. Hence, no provision for drainage has been made. The soil is generally clayey.” It is well known that clayey soils are inefficiently draining soils and to make such assumption for clayey soils is clearly wrong.
6.Unrealistic assumption of irrigation efficiency System irrigation efficiency of 54% assumed in Table 11.10 is clearly wrong, no project in India has achieved such high efficiency. The water loss will surely be much higher than the assumption of 105 MCM on page 11-14. The conclusion on that page that: “The quantum of water not being utilized is quite small and is not expected to cause any significant problem of waterlogging” is clearly wrong and baseless, since water logging also depends on many other factors including drainage, soil structure, underground geology, among other factors.
7.No industries, but 19.4 MCM for industries! The CADP (page 5-7) clearly states: “At present there is no industrial requirement in the area.” And yet the project allocates 19.4 MCM water for industries. This again shows that the project is being pushed even though there is no need for it.
INCOMPLETE ASSESSMENT 1. Dependence on fisheries incomplete It is not clear what is the area from which fisheries assessment done as reported in section 9.11.6. How many people depend on fish, what is the production market and economy of the same is also not reported.
2. Hydrology figures without basis Chapter 11 (Table 11.6) assumes that “For use on u/s of Bansujara dam for environmental and ecological balance and Misc. uses by surface water” is 10 MCM and “Quantity of water reserve for d/s release for environmental and ecological balance” is 15.18 MCM and that groundwater available upstream of dam site will be 58.86 MCM (10% of surface water). No basis is given for any of these and all these (and many other) figures given in the water balance are clearly ad hoc, unfounded assumptions. The groundwater availability is typically 40% of total water availability, so around 67% of surface water availability. Why should it be 10% in case of the Dhasan basin is not explained and in any case does not seem plausible.
However, in Table 2.2 of EMP, the environment flow suggested in monsoon months is 12.8 cumecs. This would mean that the project would need to release 132 MCM of water in four monsoon months as environment flows, when they have assumed in hydrology that only 15.18 MCM water is required for this!
3.Incomplete SIA SIA says (SIA page 1-7) that it has selected certain of the 21 villages facing submergence due to the project. Actually the SIA should have done full survey of all the villages not a sample of villages.
4.Impact of loss of river not assessed It is expected that the SIA will assess the impact of loss of river for the people in submergence and downstream zone, but no such assessment has been done. Even in section 4.4 of SIA on “Impacts of Socio-Cultural Environment”, there is no mention of impact of river (or forest or other natural resources) on the people.
5.Full Canal details not given The EIA or CADP report does not provide the full lengths of main canals, distributaries, minors, field channels and field drains, including their width, land requirements, protection measures like canal like plantations etc. Without these basic details, the EIA or the CADP cannot be considered complete.
6.Command area coinciding with command area of Ken Betwa Link canal and other such projects? A perusal of the Command area of the Ken Betwa River Link Project (TOR approved by EAC in its 45th meeting in Dec 2010) shows that all the three Tehsils (namely Baldeogarh or Khargapur in Tikamgarh district, Jatara Tehsil in Tikamgarh district and Palera Tehsil in Chhattapur district) are also benefiting from Ken Betwa Link Canal. A look at the map of the command area of Ken Betwa link canal and that of the Bansujara shows that some area are certainly common. The EIA of Bansujara should have pointed this out and also if the proposed command area is to benefit from any other such projects, but it has not done that.
CUT AND PASTE JOB? Several parts of EIA raises the suspicion that they are cut and paste from other documents. This suspicion is proved correct when we see this sentence in Table 12.2 in Disaster Management Plan (Chapter 12 of EMP): “All staff from dam site, power house & TRC outlets alerted to move to safer places”, since the Bansujara project has no power house or TRC (Tail Race Channel). The consultants forgot to remove these irrelevant aspects while doing the cut and past job, it seems. This is just by way of illustration.
Similarly, the title of the section 2.6 of the Command Area Development Plan says it all: “2.6 FOREST TYPES IN THE MOHANPURA PROJECT AREA”. Here again it is clear that while doing cut and paste from another EIA, the consultants forgot to change the details! There is also the sentence “Tehsil Shajapur has maximum population density of 238 persons per sq.km. (2001 Census data)” on page 2-6 of CADP, but there is no mention of any such Tehsil in the area!
NO OPTIONS ASSESSMENT The EIA does not contain any options assessment. In fact section 10.2.4 shows that 19174 ha of the 48157 ha of cropped area in the command is already irrigated. This means a substantial 40% of the command area is already irrigated.
On page 3-5 of SIA it is mentioned that out of 318 land holding respondents in the SIA survey (in submergence villages), only 4 had unirrigated land. This shows that land of over 99% of respondents is already irrigated.
Very shockingly, the report does not mention what are the levels and trends of groundwater in the catchment and command of the project. When Groundwater is India’s mainstay for all water requirements, not give this full picture of groundwater makes the report fundamentally incomplete.
The area has average rainfall of around 1100 mm and thus more area can get irrigated with better use of this rainfall and such a huge dam with such huge submergence (5202 ha) and land requirement (5887 ha, gross underestimate considering that land for canals are not properly assessed), over 25000 people displacement (at least and that too only from submergence area) and other impacts is not the best option.
CONCLUSION What is listed above is not an exhaustive list. Nor are these some typographical errors, but these show serious incompetence, callousness and worse. The conclusion is inescapable that the EAC and MoEF must reject this EIA and recommend black listing and other measures against WAPCOS. The project should be asked to get a fresh EIA done by a credible agency. The EAC in the past have failed to apply its mind about such shoddy EIAs even when this was shown to EAC through such submissions. Most recent such case is that of the Mohanpura Irrigation Project in MP, in which case too the EIA was done by WAPCOS. It is hoped that EAC will apply its mind to this issue and make appropriate recommendations.
The Simang River is a tributary of the Siang River which originates at an elevation of 2950 m. The river is 44 km long (as mentioned in the EIA/EMP reports done by consultant R S Environ Link). Total catchment area of Simang River is 554 sq km. There are two projects proposed on the Simang River. The first one is Simang I with an installed capacity of 67 MW (3 x 22.33 MW) and catchment area of 494 sq km. The second one is the upstream project Simang II with an installed capacity of 66 MW (3 x 22 MW) and catchment area of 422 sq km. These two projects were jointly discussed in the 19th meeting of EAC in October 2008 for the first time. Then these projects were subsequently discussed in the 21st, 36th, 66th and 67th meeting of EAC. A diagram of the two projects on the Simang River is given below.
Troubled Figures of EIA/EMP
In order to prepare the above diagram EIA/EMP reports of both Simang I and Simang II has been consulted. A detailed analysis of the numbers and figures mentioned in the EIA/EMPs for the river shows serious inadequacies in both the EIAs and raises questions on the authenticity of the EIA studies being done on the river.
1. EIA Wrong about Length of Simang River: It is surprising to find that the EIA studies for the two projects cannot give the correct the length of Simang River and contradicts each other (e.g. paragrapgh 4 page 1.14 of EIA of Simang I). Even though the total length of the river has been mentioned as 44 km in EIA studies of both the projects, lengths of the river over different parts do not add upto that.
The EIA report of Simang I in map of ‘Figure 1.3: Project in Simang Basin’ of page 1.16 shows that the distance between the origin of the river and reservoir of Simang II HEP is 22.27 km. The EIA report of Simang II states that the distance between barrage axis of Simang II and Simang-Siang confluence is 19.66 km (paragraph 1 page 5.2). The stretch of the Simang River used by Simang II barrage is 1.05km (from page 4.6 paragraph 1 & 2 of Simang II EIA report). If we take the total of these three parts of the Simang River, the total length of the river will be 42.98km and not 44 km.
On the other hand if we take some other figures given for different parts of the river, then we get another length for the Simang River. The Simang I EIA shows that the distance between the barrage axis of Simang II and TWL of Simang I is 15.75 km (Figure 1.3). The distance between the TWL of Simang I and it’s confluence with Siang river is given as 3.29 km. From this the total length of the river comes out as 41.31 km excluding the Simang II reservoir area. The stretch of the Simang River used by Simang II reservoir is 1.05 km. So including this total length of the Simang River is 42.36 km, not 44 km.
This is a serious inadequacy on the part of the EIA studies since the studies are not clear even about the river length across different parts of the projects. Either the EIA consultants do not know the rivers or they are fudging figures. In either case, these EIA reports should not be accepted.
2. Incorrect Assessment of River Use for the Projects The EIA reports of both Simang I and II projects gives incorrect figures for stretch of river used for the projects. The stretch of the Simang River submerged by Simang II barrage is 1.05 km (from page 4.6 paragraph 1 & 2 of Simang II EIA report), stretch of river bypassed between Simang II barrage and TWL is 7.75 km. The EIA report of Simang I states that the stretch of river submerged by Simang I barrage is 1.48 km and stretch of river bypassed between Simang I barrage and TWL is 7 km. This concludes that the total length of the river used by the two projects is 17.28 km and not 15.75 km as claimed in the EIA reports. Not giving the correct information about the stretch of the river used for projects is a major lacunae on the part of the EIAs and hence these EIA should be rejected.
3. Incorrect Assessment Distance between Simang-Siang Confluence and Power House of Simang I: It seems the EIA/EMP consultant has no knowledge of the area since the distance stated between the Simang-Siang confluence and Power House also seems to be incorrect. The Simang I EIA in states that distance between barrage axis of dam and Simang-Siang confluence is 9.34 km. It also stated that the distance between barrage axis and power house is 7 km. This leaves the distance between the Simang-Siang confluence and Simang I power house as 2.34 and not 3.29 as shown in Figure 1.3 in page 1.16 of the EIA. This again proves that the EIA report prepared by the consultant is inadequate and it should not be accepted.
4. Assessment of river length for diversion is doubtful The diverted river length for Simang II HEP given as 7.75 km in the EIA seems to be doubtful. But tunnel lengths mentioned in the same document for Simang II are as follows:
In fact the bypassed length of the river is likely to be longer than this length of the various tunnel components since rivers do not flow in straight lines, unlike the tunnels.
Critical Issues Not Addressed by EIA/EMP The projects on the Simang River were first considered for TOR in 2008 in the 19th EAC meeting. The proposal that time was to construct three hydro electric projects (HEPs) on the river. In reply to this the EAC had asked, “Secretary (Power) and Secretary (Environment) of Government of Arunachal Pradesh should attend the next meeting to clarify the reason for allotting a series of hydroelectric projects on a river which subsequently flows only through tunnels and damage the aquatic ecology.” The Power secretary and Environment secretary attended the 21st meeting of EAC. Going through the minutes of that meeting, it becomes very obvious that Arunachal with its aim to generate more revenue was ready to dam every river or stream in the state. This strengthens the impression that the Simang I or Simang II HEPs are not going to be much beneficial for the local people, environment or the state.
After going through the EIA/EMP of both the projects we have found that there are several critical issues with these studies. There are several issues which are common in both the studies and several others which are particular to each project. Reading these documents thoroughly gives a feeling that the documents don’t have much of a difference from each other and lot of ‘copy-pasting’ has been done. Some of them are also mere replications (e.g. section 4.2 page 4.7 of Simang I EIA and section 4.1.8 in page 4.6 Simang II EIA). There are also many instances where names and words have been confused, e.g. in page 1.15 of Simang II EIA, in the title of the Table 1.1 “Simang I” has been mentioned instead of “Simang II’. This kind of issues raises question on the validity and authenticity of the EIA/EMP studies done. Some of the critical issues are listed below as an example, this is not exhaustive list.
1. EAC Recommendations not Followed: The EIA/EMP studies of these projects have not followed several of the EAC recommendations. EAC in its meetings had recommended the project proponent to address several important concerns but those were no followed.
“To maintain the aquatic life, a study to be conducted by National Institute of Hydrology, Roorkee. Methodology followed for measurement of water flow to be given.” (19th EAC Meeting) – There is no mention of any study done on environment flows. The EIA/EMP report of both the projects does not give any details of how the environment flow was measured except mentioning what will be the environmental flow.
Between dam and power house how many streams/ tributaries join and what is their contribution in turn of water in the lean season and monsoon? (19th EAC meeting) – The EIA/EMP of none of the two projects responded to this. There are no accurate details about number the flow contribution of different streams or river joining Simang.
Seismic Studies, Slope Stabilization measures, Reservoir Rim Treatment should be included in the EIA/EMP studies. (36th EAC meeting) – The EIA/EMP studies of the two projects do not have any details ofseismic studies done in the project area.
Disaster Management Plan should be included in the EIA/EMP studies. (36th EAC meeting) – This is very surprising because none of the two projects in Simang River has any disaster management plan in their respective EIA/EMP documents.
2.Impact of Migration of Outside Workers on Local Communities not Assessed The EIA/EMP reports estimates that there will be migration of nearly 1000 persons for each project during the peak construction period to this very sparsely populated area. People who live in this area belong to several ethnic tribal groups with unique social, economic, political and cultural values. The EIA/EMP reports do not discuss what will be the impact of such migration on the social, political, economic and cultural lives of the people. Influx of such migration will also have impacts on their human rights as well on women. The EIA/EMPs make no mention of these impacts of migration and that is why the EIA/EMP report is incomplete. Besides, even though the projects had been considered together by EAC, no cumulative impact assessment of migration was done.
3. Shoddy Socio-economic Impact Study: The property surveys which the consultant claim to have done for both these projects are inadequate and shoddy socio-economic impact assessment studies. For Simang I a property survey of project affected families in 5 villages was done but it was found incomplete since it does not take into account two of the project affected villages. On page 6A-10 of the EIA report, these 5 villages are stated as Dosing, Lileng, Pareng, Rengo and Boleng. But out of these villages, there are only three villages mentioned in the property survey – Pareng, Rengo and Boleng. The two villages Dosing and Lileng were not found in the list and instead there were two different villages mentioned in the list – Yingku and Sine.
But after reading through the EIA study of Simang II, it becomes clear that project consultant had done only one survey for both the projects. The two villages Yingku and Sine are also found in the property survey list for Simang II EIA with the same number of affected families (page 6A-16).
It is also surprising to see how the opinions can be exactly similar for both the projects when the affected families are different for each project (See page 16A-15 of Simang I HEP EIA and page 16A-17 of Simang II HEP EIA). Besides, in the list mentioned in page 6A-17 of Simang II EIA, village named Yingku is mentioned twice but there is no justification provided for that.
This brings to light how recklessly these EIAs had been prepared. In fact, the whole concept of property survey is questionable. It takes into account very limited concerns related with the projects ignoring many serious issues. One important aspect of what is the value of the river and other common property resources for the people of the area finds no mention in the property survey. Such property survey cannot be taken as a full proof socio-economic impact assessment and hence EIA/EMP is incomplete and cannot be accepted.
4. Options Assessment not Done The EIA/EMPs of the proposed projects have not done any options assessment study. For example, the option of sub megawatt micro hydro project for a sparsely populated and pristine area like this has not been assessed. For ethnic tribal communities with small population micro hydro project is a better option. The option of solar power generation has also not been assessed by the EIA/EMPs of the projects. Options assessment is an important part of the EIA/EMP document and since this is not done the EIA/EMP reports are incomplete and cannot be accepted.
5. Environmental Flows Assessment not Done: The EIA/EMP reports of the two projects do not give any detail of how environment flow was calculated and how environment flow will be released. We have already mentioned that in the 19th EAC meeting, EAC had suggested that in order to maintain the aquatic life, a study should be conducted by National Institute of Hydrology, Roorkee and the methodology followed for measurement of water flow should be made available in the EIA. But there is no mention about any such study in any of the documents.
EIA reports of both projects mentioned about the environment flow release exercise but that should have been done already and should have been a part of the EIA. Since the EIA reports do not mention about any study done on environment flow as asked by the EAC this EIAs cannot be taken as a complete impact assessment.
6. Socio-Economic Impacts of Reduced Flow Ignored: None of EIA/EMP reports mention about the socio economic impacts of reduced flow in the intermediate stretch between the barrage axis and power house. Besides, in questionnaire of the primary survey/property survey which the EIA consultants claim to have done, there is no question on impacts of the reduce flow of water in the river. Besides, the EIA/EMP studies do not discuss the importance of the river for the local people. This proves that EIA report is inadequate and cannot be accepted.
7.Impacts of Non-monsoon Peaking Power Generation not Assessed: EIA/EMP reports of the two projects do not assess how peaking power generation during non-monsoon period will impact the flow in the river downstream from power house. Peaking power generation will have significant impact in the downstream since there will be sudden flow of water in the river for a short period of the day and rest of times it will remain almost dry. This sudden release of water holds threat for the people living downstream as well as their livestock. There are many instances where large number of people and livestock dying due to sudden release of water from upstream dam. Most recently, on Oct 7, 2013, one person was washed away in Arunachal Pradesh due to sudden release of water from the Ranganadi HEP. Besides, this fluctuation in river water on everyday basis will have severe impacts on aquatic bio diversity of the river and use of the river by the people. EIA study ignores all these issues and that is why this study cannot be accepted as a complete study.
8. Impact Assessment of changing sediment releases not Done The EIA/EMP reports do not talk about how sedimentation will impact the reservoir. The EIAs should have included detail analysis of two main impacts – 1.Impact of changing silt flows downstream from desilting chamber and 2. Impacts of silt flushing in monsoon season on the downstream areas. The EIA/EMP report should also do a cumulative study of reservoir sedimentation because the sediment released from the upstream reservoir will affect the reservoir downstream.
9. Socio-economic Impact Assessment of Quarrying not Done: EIA/EMP of any of the two projects on Simang does not talk about the socio economic impact of quarrying on the local people and environment. EIA/EMP reports also have not assessed how the quarrying in a fragile hill range like Eastern Himalayas will increase the risk of landslide and disaster. Ignoring the disaster risk of quarrying in the hills can have disastrous impacts and the recent Uttarakhand disaster is a proof of that. Since EIA/EMP studies ignore all these issues, they cannot be accepted as complete and that is why EIA/EMPs of Simang I and II should be rejected.
10. False Claim about Height of the Dam: The claim made by the EIA/EMP of both the projects that 18 m high dam reservoir is “very low height” is misleading and false. In the 2nd paragraph of page 10.2, the EMP report of Simang I states “Because it is a run of the river hydro project with a small barrage with very low height (18 m), the inundation will be minimized during reservoir filling.” The same claim has been made in the same page of Simang II EMP. This claim is baseless because according to international standards any dam with a wall height of 15 m or above is a big dam.
11. Climate Change Assessment Not Done EIA/EMP studies of both the projects have not done any climate change impact assessment for the proposed projects. Today when climate change impact risks are increasing day by day, it is very essential for studies like these to do an assessment of possible climate change impacts on the project as well as impacts of the projects on local climate. In fact the word “climate change” is nowhere to be found in the EIA or EMP of the two projects. Without climate change risk assessment, an environment impact assessment cannot complete and that is why this report is unacceptable.
The EIA/EMP studies should also have done an assessment of methane release from the reservoir of the project. Since these important issues are not addressed by the impact assessment study, it cannot be accepted as a complete study.
12. False Claims about Flora and Fauna The EIA/EMP of the two projects makes a completely baseless claim that “There will be no negative impact on flora of region during the operation phase.” This cannot be accepted as truth since during the construction phase of Simang I and II, the forest area diverted will be 29.86 ha and 22.02 ha respectively. After such a diversion forest, the impact on flora and fauna is inevitable because the area is covered by dense forest. The EIA report of Simang I states that forests constitute the predominant land use in the 10 km area which was studied for this project and 67.66% of this area is covered by dense forests. Besides, none of the two EIA studies provide any data on how many trees will be cut down for the project. These are serious lacunas on the part of EIA/EMP of these two projects and that is why this report cannot be accepted as a comprehensive study.
14. Barrage Location not Clearly Stated for Simang I The EIA report of Simang I is not clear about where the barrage of proposed Simang I HEP will be located. In page 1.5 the EIA report states “The reservoir created by the barrage located near Boleng town will operate between FRL 339 m and MDDL 334 m.” But the same report in page 5.2 says “The proposed Barrage axis is situated about 9.34 Km upstream of confluence of Simang river with Siang river. The river Simang joins the SiangRiver near Boleng township.” Besides, the maps show that Boleng area is located near the confluence of two rivers not near the barrage site. This is a significant error of the EIA study and hence this study is inadequate and cannot be accepted.
15. Simang II does not assess the project impact on Protected Area EIA states that the distance between Mouling National Park and the reservoir tail at Subbung Nala and Simang River are 5.6 and 5.7 km respectively (page 1.2, paragraph 2). Being in so close proximity of a protected area there should have been impact assessment of the project on the protected area but the EIA/EMP does not mention any such assessment.
16. Threat to Nearly Threatened Mammals The Simang II HEP is a threat to some of the endangered mammal species listed in IUCN Red List. Common leopard (Panthera pardus) and Assamese macaque (Macaca assamensis) which falls in the “Near Threatened” and Gaur (Bos frontalis) falling in “Vulnerable” category of IUCN Red List are found in the project area of Simang II. There are 13 more species of mammals falling under the “Least concern” category of IUCN which are also found in the area. This has been stated in the EIA study of Simang II.
On the other hand, the EIA study of Simang I ignores some the species falling under IUCN Red List. Rhesus macaque, Indian Porcupine and Asiatic Brush Tailed Porcupine which are found in the area fall under the “Least concern” category of IUCN Red List but the EIA report completely ignores this.
The EIA/EMP reports of the two proposed HEP projects on Simang River have significant lacunas and those cannot be ignored. The EIA consultant also had not consulted the local people in preparing the EIA report. This is another significant lacuna on the part of the EIA because it is the local people who are more aware of the local environment and river as they have lived in that place for generations. It is shameful that on the basis of such studies and reports, public hearing for the two HEPs was held without even announcing the Public hearing dates on the AP Pollution Control Board website. If these dams are constructed on the basis of such shoddy reports and flawed public hearings then it will invite an uncertain future for the people of the area and people have to live at the risk of disaster. The EAC should consider these issues seriously and must not accept these reports. The EAC should also consider recommending the black list of the consultants for the serious lacunae in the reports.
The Study The study has been done by IRG Systems South Asia Private Limited (http://www.irgssa.com/, a subsidiary of US based IRG Systems) and http://www.eqmsindia.com/[i]. It is supposed to be a Cumulative Impact Assessment of 19 HEPs planned in the basin, out of which PFRs of 7 are available, DPR of two, and one of which, the 2000 MW Subansiri Lower HEP is under construction.
Subversion of Environment Governance in the Subansiri basin While looking at this basin study, the subversion of environment governance in Subansiri basin this very millennia should be kept in mind. A glimpse of it is provided in Annexure 1. In fact, one of the key conditions of environmental clearance to the 2000 MW Lower Subansiri HEP was that no more projects will be taken up in the basin upstream of the Lower Subansiri HEP, which essentially would mean no more projects in the basin, since LSHEP is close to the confluence of the Subansiri River with Brahmaputra River. That condition was also part of the Supreme Court order in 2004. The need for a carrying capacity study was also stressed in the National Board of Wild Life discussions. We still do not have one. In a sense, the Subansiri basin is seeing the consequences of that subversion.
Information in public domain not known to consultants The report does not even state that Middle Subansiri dam have also been recommended TOR in 41st EAC meeting in Sept 2010. This project will require 3180 ha of land, including 1333 Ha forest land, and 2867 ha area under submergence. Even about Upper Subansiri, the consultants do not know the area of forest land required (2170 ha). So the consultants have not used even the information available in public domain in EAC meetings.
Study based on flawed and incomplete Lohit Basin Study The Study claims that it is based on Lohit Basin Study done by WAPCOS. Lohit Basin Study is an extremely flawed attempt and does not assess cumulative impacts of the cascade projects. Civil society has written about this to the EAC and the EAC itself has considered the study twice (53rd and 65th EAC Meetings), and has not accepted the study, but has raised several doubts. Any study based on a flawed model like Lohit Basin Study should not be acceptable.
No mention of Social impacts Major limitation of the study has been absolutely no discussion on the severe social impacts due to cumulative forest felling, flux of population, submergence, livelihoods like riparian farming and fishing, etc. Though this has been pointed out by the TAC in its meeting and field visit, the report does not reflect this.
Some key Impacts Some of the impacts highlighted by the study based on incomplete information about HEPs are:
Þ The length of the river Subansiri is 375 km up to its outfall in the Brahamaputra River. Approximately 212.51 km total length of Subansiri will be affected due to only 8 of the proposed 19 HEPs in Subansiri River basin.
Þ Total area brought under submergence for dam and other project requirements is approx. 10, 032 ha of eight proposed HEPs. The extent of loss of forest in rest of the 9 projects is not available.
Þ 62 species belonging to Mammals (out of 105 reported species), 50 Aves (out of 175 reported species) and 2 amphibians (out of 6 reported species) in Subansiri Basin are listed in Schedules of Wildlife Protection Act, 1972 (as amended till date).
Þ 99 species belonging to Mammals (out of 105 reported species), 57 species belonging to Aves (out of 175 reported species), 1 Reptilian (out of 19 reported species), 2 Amphibians (out of 6 reported species), 28 fishes (out of 32 reported species), 25 species belonging to Odonata of Insecta fauna group (out of 28 reported species) are reported to be assessed as per IUCN’s threatened categories.
Even this incomplete and partial list of impacts should give an idea of the massive impacts that are in store for the basin.
Cumulative impacts NOT ASSESSED Specifically, some of the cumulative impacts that the report has not assessed at all or not adequately include:
1. Cumulative impact of blasting of so many tunnels on various aspects as also blasting for other project components.
2. Cumulative impact of mining of various materials required for the projects (sand, boulders, coarse and fine granules, etc.)
3. Cumulative impact of muck dumping into rivers (the normal practice of project developers) and also of also muck dumping done properly, if at all.
4. Changes in sedimentation at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof.
5. Cumulative impact on aquatic and terrestrial flora and fauna across the basin due to all the proposed projects.
6. Cumulative impact of the projects on disaster potential in the river basin, due to construction and also operation at various stages, say on landslides, flash floods, etc.
7. Cumulative dam safety issue due to cascade of projects.
8. Cumulative change in flood characteristics of the river due to so many projects.
9. Cumulative impacts due to peaking power generation due to so many projects.
10. Cumulative sociological impact of so many projects on local communities and society.
11. Cumulative impact on hydrological flows, at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof. This will include impacts on various hydrological elements including springs, tributaries, groundwater aquifers, etc. This will include accessing documents to see what the situation BEFORE project and would be after. The report has failed to do ALL THIS.
12. Impact of silt laden water into the river channel downstream from the dam, and how this gets accumulated across the non-monsoon months and what happens to it. This again needs to be assessed singly and cumulatively for all projects.
13. Impact of release of silt free water into the river downstream from the power house and impact thereof on the geo morphology, erosion, stability of structures etc, singly and cumulatively.
14. Impact on Green House Gas emissions, project wise and cumulatively. No attempt is made for this.
15. Impact of differential water flow downstream from power house in non-monsoon months, with sudden release of heavy flows during peaking/ power generation hours and no releases during other times.
16. Cumulative impact of all the project components (dam, tunnels, blasting, power house, muck dumping, mining, road building, township building, deforestation, transmission lines, etc.,) for a project and then adding for various projects. Same should also be done for the periods during construction, operation and decommissioning phases of the projects.
17. Cumulative impact of deforestation due to various projects.
18. Cumulative impact of non compliance of the environment norms, laws, Environment clearance and forest clearance conditions and environment management plans. Such an assessment should also have analysed the quality of EIA report done for the Subansiri Lower hydropower project.
Wrong, misleading statements in Report There are a very large number of wrong and misleading statements in the report. Below we have given some, along with comment on each of them, this list is only for illustrative purposes.
Statement in CIA
“During the monsoon period there will be significant discharge in Brahmaputra River. The peaking discharge of these hydroelectric projects which are quite less in comparison to Brahmaputra discharge will hardly have any impact on Brahmaputra.”
This is a misleading statement. It also needs to be assessed what will be the impact on specific stretches of Subansiri river. Secondly, the projects are not likely to operate in peaking mode in monsoon.
“However, some impact in form of flow regulation can be expected during the non-monsoon peaking from these projects.”
This is not correct statement as the impact of non-monsoon peaking is likely to be of many different kinds, besides “flow regulation” as the document describes.
“Further, during the non-monsoon period the peaking discharge release of the projects in upper reaches of Subansiri basin will be utilized by the project at lower reaches of the basin and net peaking discharge from the lower most project of the basin in general will be the governing one for any impact study.”
This is again wrong. What about the impact of such peaking on rivers between the projects?
“The construction of the proposed cascade development of HEPs in Subansiri basin will reduce water flow, especially during dry months, in the intervening stretch between the Head Race Tunnel (HRT) site and the discharge point of Tail Race Tunnel (TRT).”
This statement seems to indicate that the consultants have poor knowledge or understanding of the functioning of the hydropower projects. HRT is not one location, it is a length. So it does not make sense to say “between HRT and the discharge point of TRT”.
“For mature fish, upstream migration would not be feasible. This is going to be the major adverse impact of the project. Therefore, provision of fish ladder can be made in the proposed dams.”
This is simplistic statement without considering the height of the various dams (124 m high Nalo HEP dam, 237 m high Upper Subansiri HEP dam, 222 m high Middle Subansiri HEP dam), feasibility of fish ladders what can be optimum design, for which fish species, etc.
“…water release in lean season for fishes may be kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20% water flow in lean season may be maintained at Hiya and Nyepin HEP for fish migration.”
This conclusion seems unfounded, the water release suggested is even lower than the minimum norms that EAC of MoEF follows.
Viability not assessed The report concludes: “The next steps include overall assessment of the impacts on account of hydropower development in the basin, which will be described in draft final report.”
One of the key objective of the Cumulative Impact assessment is to assess how many of the planned projects are viable considering the impacts, hydrology, geology, forests, biodiversity, carrying capacity and society. The consultants have not even applied their mind to key objective in this study. They seem to assume that all the proposed projects can and should come up and are all viable. It seems the consultant has not understood the basic objectives of CIA. The least the consultant could have said is that further projects should not be taken up for consideration till all the information is available and full and proper Cumulative impact assessment is done.
The consultants have also not looked at the need for free flowing stretches of rivers between the projects.
Section on Environmental Flows (Chapter 4 and 9): The section on Environmental flows is one of the weakest and most problematic sections of the report, despite the fact that the Executive summary talks about it as being one of the most crucial aspects.
The study does not use any globally accepted methodology for calculating eflows, but uses HEC RAS model, without any justification. The study has not been able to do even a literature review of methodologies of eflows used in India and concludes that “No information/criteria are available for India regarding requirement of minimum flow from various angles such as ecology, environment, human needs such as washing and bathing, fisheries etc.”
This is unacceptable as EAC itself has been recommending Building Block Methodology for calculating eflows which has been used (very faultily, but nonetheless) by basin studies even like Lohit, on which this study is supposedly based. EAC has also been following certain norms about E flow stipulations. CWC itself has said that minimum 20% flow is required in all seasons in all rivers. BK Chaturvedi committee has recently stipulated 50% e-flows in lean season and 30% in monsoon on daily changing basis.
The assumption of the study in its chapter on Environmental Flows that ‘most critical reach is till the time first tributary meets the river” is completely wrong. The study should concentrate at releasing optimum eflows from the barrage, without considering tributary contribution as an excuse.
First step of any robust eflows exercise is to set objectives. But the study does not even refer to this and generates huge tables for water depths, flow velocity, etc., for releases ranging from 10% lean season flow to 100% lean season flow.
After this extensive analysis without any objective setting, the study, without any justification (the justification for snow trout used is extremely flawed. Trouts migrate twice in a year and when they migrate in post monsoon months, the depth and velocity needed is much higher than the recommended 10% lean season flow) recommends “In view of the above-said modeling results, water release in lean season for fishes maybe kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at all HEP for fish migration and ecological balance.”
The study does not recommend any monsoon flows. Neither does it study impact of hydro peaking on downstream ecosystems.
Shockingly, the study does not even stick with this 20-25% lean season flow recommendation (20-25% of what? Average lean season flow? Three consecutive leanest months? The study does not explain this). In fact in Chapter 9 on Environmental Flows, the final recommendation is: “Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at Hiya and Nyepin HEP or all other locations for fish migration.” (emphasis added)
So it is unclear if the study recommends 20-25% lean season flows or 10-15% lean season flows. This is a very flawed approach to a critical topic like eflows.
The study keeps mentioning ‘minimum flows’ nomenclature, which shows the flawed understanding of the consultants about e-flows.
The entire eflows section has to be reworked, objectives have to be set, methodology like Building Block Methodology has to be used with wide participation, including from Assam. Such exercises have been performed in the past and members of the current EAC like Dr. K.D. Joshi from CIFRI have been a part of this. In this case, EAC cannot accept flawed eflows studies like this. (DR. K D. Joshi has been a part of a study done by WWF to arrive at eflows through BBM methodology for Ganga in Allahabad during Kumbh: Environmental Flows for Kumbh 2013 at Triveni Sangam, Allahabad and has been a co author of this report)
Mockery of rich Subansiri Fisheries Subansiri has some of the richest riverine fisheries in India. The river has over 171 fish species, including some species new to science, and forms an important component of livelihood and nutritional security in the downstream stretches in Assam.
But the study makes a mockery of this saying that the livelihoods dependence on fisheries is negligible. The entire Chapter on Fisheries needs to be reworked to include impacts on fisheries in the downstream upto Majuli Islands in Assam at least.
No mention of National Aquatic Animal! Subansiri is one of the only tributaries of Brahmaputra with a resident population of the endangered Gangetic Dolphin, which is also the National aquatic animal of India (Baruah et al, 2012, Grave Danger for the Ganges Dolphin (Platanista ganegtica) in the Subansiri River due to large Hydroelectric Project. http://link.springer.com/article/10.1007/s10669-011-9375-0#).
Shockingly, the Basin Study does not even mention Gangetic Dolphin once in the entire study, let alone making recommendations to protect this specie!
Gangetic Dolphin is important not only from the ecological perspective, but also socio cultural perspective. Many fisher folk in Assam co-fish with the Gangetic River Dolphin. These intricate socio ecological links do not find any mention in the Basin study, which is unacceptable.
Lessons from Lower Subansiri Project not learnt A massive agitation is ongoing in Assam against the under construction 2000 MW Subansiri Lower HEP. The people had to resort to this agitation since the Lower Subansiri HEP was going ahead without studying or resolving basic downstream, flood and safety issues. The work on the project has been stopped since December 2011, for 22 months now. In the meantime several committee have been set up, several changes in the project has been accepted. However, looking at this shoddy CIA, it seems no lessons have been learnt from this ongoing episode. This study does not even acknowledge the reality of this agitation and the issues that the agitation has thrown up. There is no reflection of the issues here in this study that is agitating the people who are stood up against the Lower Subansiri HEP. The same people will also face adverse impacts of the large number of additional projects planned in the Subansiri basin. If the issues raised by these agitating people are not resolved in credible way, the events now unfolding in Assam will continue to plague the other planned projects too.
Conclusion From the above it is clear that this is far from satisfactory report. The report has not done proper cumulative assessment on most aspects. It has not even used information available in public domain on a number of projects. It does not seem to the aware of the history of the environmental mis-governance in the SubansiriBasin as narrated in brief in Annexure 1. For most projects basic information is lacking. Considering the track record of Central Water Commission functioning as lobby FOR big dams, such a study should have never been given to CWC. One of the reasons the study was assigned by the EAC to the Central Water Commission was that the CWC is supposed to have expertise in hydrological issues, and also can take care of the interstate issues. However, the study has NOT been done by CWC, but by consultants hired by CWC, so CWC seems to have no role in this except hiring consultant. So the basic purpose of giving the study to CWC by EAC has not been served. Secondly the choice of consultants done by the CWC seems to be improper. Hence we have a shoddy piece of work. This study cannot be useful as CIA and it may be better for EAC to ask MoEF for a more appropriate body to do such a study. In any case, the current study is not of acceptable quality.
Set Conditions to be waived Later – The MoEF way of Environmental Governance
In 2002, the 2,000 MW Lower Subansiri hydroelectric project on the Assam-Arunachal Pradesh border came for approval to the Standing Committee of the Indian Board for Wildlife (now called the National Board for Wildlife) as a part of the Tale Valley Sanctuary in AP was getting submerged in the project. The total area to be impacted was 3,739.9 ha which also included notified reserved forests in Arunachal Pradesh and Assam. The Standing Committee observed that important wildlife habitats and species well beyond the Tale Valley Sanctuary, both in the upstream and downstream areas, would be affected (e.g. a crucial elephant corridor, Gangetic river dolphins) and that the Environmental Impact Assessment studies were of a very poor quality. However, despite serious objections raised by non-official members including Bittu Sahgal, Editor, Sanctuary, Valmik Thapar, M.K. Ranjitsinh and the BNHS, the Ministry of Environment & Forests (MoEF) bulldozed the clearance through in a May 2003 meeting of the IBWL Standing Committee. Thus a project, which did not deserve to receive clearance, was pushed through with certain stringent conditions imposed (Neeraj Vagholikar, Sanctuary Asia, April 2009).
The EC given to the project was challenged in Supreme Court (SC) by Dr L.M Nath, a former member of the Indian Board for Wildlife. Nath pleaded, these pristine rich and dense forests classified as tropical moist evergreen forest, are among the finest in the country. Further the surveys conducted by the Botanical Survey of India and the Zoological Survey of India were found to be extremely poor quality. The Application mentions that the Additional DG of Forests (Wildlife) was of the view that the survey reports of the BSI and ZSI reports were not acceptable to him because these organisations had merely spent five days in the field and produced a report of no significance.
The SC gave its final verdict on 19-4-2004, in which the Court upheld the EC given by MoEF to NHPC but with direction to fulfill some important conditions. Out these conditions there were two conditions which were very significant – “The Reserve Forest area that forms part of the catchment of the Lower Subansri including the reservoir should be declared as a National Park/ Sanctuary. NHPC will provide funds for the survey and demarcation of the same.”, and “There would be no construction of dam upstream of the Subansri River in future.” These conditions were also mentioned in the original EC given to the project in 2003.
In May 2005, two years after the EC was given the Arunachal Pradesh govt and NHPC approached the SC to waive or modify the above two conditions. The state government calimed that following these conditions would imply loss of opportunity to develop 16 mega dams in the upstream of Lower Subansiri (this including 1,600 MW Middle Subansiri and 2,000 MW Upper Subansiri to be developed by NHPC). The SC sent it back to National Board for Wildlife to review the conditions.
The petition was done strategically. “The strategy of the dam proponents is simple. They raised no objection to the terms until the construction of the Lower Subansiri project had proceeded beyond a point when it could have been cancelled. Armed with this fait accompli, they asked for a review of the clauses on the very basis on which the original clearance – laid down by members who were subsequently dropped from the wildlife board – was granted.”[ii]
Then nonofficial members of NBWL expressed their dissent to the proposal. In a May 2008 communication to the Chairman of the NBWL Standing Committee, member Dr. Bibhab Talukdar observed: “If the Standing Committee agrees to waive the conditions, we would be setting a dangerous precedent and sending a wrong signal regarding the credibility of decision-making by us. This would mean that projects impacting rich wildlife habitats can receive clearances based on stringent conditions, only to be up for review later. Such an approach is undesirable both from a perspective of good governance as well as the long-term interest of wildlife in the country.”
Dr. Asad Rahmani of the BNHS, who was part of a sub-committee of the NBWL Standing Committee conducting a site visit to the project area, stated in his report: “Under no circumstances should new projects be allowed in the Subansiri river basin until an advance cumulative assessment of proposed projects and a carrying capacity study of the Subansiri river basin are completed.”
In the December 12 2008 meeting of NBWL Standing Committee, even after these dissenting opinions from nonofficial members MoEF managed to do a dilution of the above two conditions. Assam that time was witnessing a major protest concerning the downstream impacts of Lower Subansiri HEP but it was not even consulted. Shockingly the “no dam upstream” condition was removed and it was decided that “any proposal in the upstream of the SubansiriRiver would be considered independently on its merit by the Standing Committee as and when submitted by the proponents”.
Now the Arunachal Pradesh government needs to declare a smaller area of 168 sq. km. as a sanctuary and “make serious efforts” to bring an additional 332 sq. km. reserved forest under the category of Conservation Reserve (CR) in consultation with the MoEF. The latter part of the condition (declaration of CR) is non-enforceable because of the choice of words. Even the demand to at least conduct an advanced cumulative impact assessment of proposed projects and a carrying capacity study of the Subansiri river basin has been ignored[iii].
As Bittu Sahgal, Editor, Sanctuary Asia says, “The Lower Subansiri is one such, where the PMO has placed a very dubious role in forcing clearances, agreeing to clearance conditions and then starting the project, only to loosen the environmental conditions. In this whole scam the Zoological Survey of India and the Botanical Survey of India have been co-conspirators that have suppressed the ecological value of the forests to facilitate the building of the dam, which will drown pristine elephant, tiger and clouded leopard forests and cause havoc downstream as well.”
The above sequence of events are very pertinent to remember as we see the Subansiri basin study.
[i] Website says: “More than 200 successful environmental Impact Assessment Clearance from Ministry of Environment & Forests, Government of India for Industry, Infrastructure & Construction projects” Sounds strange from an EIA consultant.
Yettinahole Diversion Project is being planned in the Western Ghats and Eastern Plains of Karnataka, by the Karnataka Neeravari Nigam Limited (KNNL) purportedly as a drinking water supply scheme to supply 24 TMC water to Kolar and Chikkaballapur Districts. The scheme involves 8 dams in Western Ghat forests, 250 kms long canals, 80 and 50 kms long raising mains, a reservoir that will submerge 1200 hectares of land and 2 villages. A closer look at the Project Report of the scheme indicates that of the 24 TMC to be diverted, assured drinking water to Kolar and Chikkabalapur is just 2.81 TMC! Rest is planned to be allocated for uses like river and tank rejuvenation, irrigation, industries, urban supply etc.
The Project has escaped appraisal by the Expert Appraisal Committee of the MoEF, claiming that it is a drinking water scheme ( as per the EIA Notification 2006, Drinking Water Supply Schemes are exempt from Appraisal and Environmental Clearance process.)
But analysis of the Project report indicates a different picture.
More than 14 individuals, mainly from Karnataka have written to the Union Environment Minister, Secretary, MoEF and Director, Impact Assessment, River Valley Projects Division to appraise the Yettinahole Diversion Scheme entirely. Signatories include Dr. Ullas Karanth, former non-official member of the Forest Advisory Committee, MoEF, Praveen Bhargava from Wildlife First, Dr. T.V. Ramchandra from Indian Institute of Sciences, noted rainwater harvesting expert Vishwanath Srikataiah, Niren Jain of Kudremukh Wildlife Foundation, amongst others. While the signatories support long term and sustainable solutions to legitimate drinking water demands of drought affected regions in Karnataka, as the letter clarifies, Yettinahole Diversion Project does not seem to be an answer to that.
Smt. Jayanthi Natarajan,
Union Minister of State (IC) of Environment and Forests,
Subject: Appeal for fresh Appraisal of the Yettinahole Diversion Project in Karnataka and withdrawal of the Letter/NOC which has been issued by the MoEF on the basis on inaccurate/insufficient information.
Respected Madame and Sirs,
In the 63rd meeting of the EAC for River Valley and Hydropower projects, the committee considered Yettinahole Diversion Project by Karnataka Neeravari Nigam Limited, Government of Karnataka (Agenda Item: 2.11 (b) “Clarification on Drinking Water Supply Scheme to Tumkur, Bangalore (Rural), Kolar & Chikaballapur Districts by M/s. Karnataka Neeravari Nigam Ltd, Government of Karnataka for applicability of EIA Notification, 2006.)
The EAC concluded (emphasis added): “In view of the above, the EAC expressed its inability to consider the project for the purpose of TOR/EIA/EMP etc as this does not fall within the preview and mandate of the EAC although, there appear to be some environmental and R&R issues involved which may be appropriately addressed. Outcome of the WGEEP report may also have to be factored. The drinking water schemes, in fact, do not attract the provisions of EIA Notification, 2006 and its subsequent amendment, 2009… The project neither proposes any hydro-electric power generation component nor comprises of any irrigation component and thus has no command area.”
The EAC also recommended: “The Ministry of Environment & Forests may write to Karnataka Neeravari Nigam Ltd (KNNL), Government of Karnataka that the instant project does not attract the provisions of EIA Notification, 2006 and its subsequent amendment, 2009.” We understand the MoEF sent a letter to KNNL on these lines.
This recommendation of the EAC and MoEF decision are both incorrect. Looking at the facts mentioned below, the scheme is Category A project and needs to be appraised by the EAC not only because it falls under the purview of the EIA Notification 2006, but also due to serious ecological and social impacts. This letter is based on a site visit to the region, discussions with local communities, perusal of the Project Report of the scheme as well as the minutes of 63rd EAC Meeting.
EAC considered the project only on the basis of the proponent’s statements, without studying the Project Report.
An analysis of the Project Report (Version June 2012, prior to EAC Meeting) it is clear that:
1. Irrigation Component: The project aims to supply water to 337 minor irrigation tanks and Zilla Parishad Tanks in Kolar and Chikkaballapur. The command areas of these 337 minor irrigation tanks, as mentioned in the Project Report (Voulme I, Annex 3) come to 29,182 hectares. This is higher than command area of 10,000 hectares; hence this is a Category A project which comes under the purview of EIA Notification 2006 and will have to be considered for Environmental Clearance by Expert Appraisal Committee of the MoEF.
2. Hydropower Generation: The Project Report claims that it can generate 125-150 MW of power through gravity canals. Location details are also made available in the Project erport (Page 59, Volume I). As this is higher than 25 MW, the project comes under the purview of EIA Notification 2006 and will have to be considered for Environmental Clearance by the Expert Appraisal Committee of the MoEF.
Thus, the Project comes under the purview of EIA Notification 2006 and should be considered by the EAC, urgently taking back any letter sent to Karnataka Government to the effect that the project does not require an EC as per EIA notification 2006.
In addition to technicalities about qualifying under the EIA Notification 2006, the project has severe socio ecological impact, which cannot be sidelined by the EAC and the MoEF.
Majority of the project falls in Ecologically Sensitive Zone I as per the WGEEP, where any large infrastructure project is banned. In addition, WGEEP bans any inter-basin transfer of water. MoEF has as yet not decided on WGEEP recommendations. In the absence of this, the MoEF cannot provide any letter to the state about not requiring an Environmental Clearance. MoEF will need to consider the WGEEP Report while making its recommendations, as also directed by NGT, which MoEF has not done.
The project plans to divert 24.01 TMC water from 4 streams in Western Ghats, without making any study of eflows for the downstream Eco Sensitive Zone.
The project does not divulge forest land required. Only by estimating heads under ‘cutting thick forests’ in its estimates, it will require 107.27 hectares land with thick forest cover only for laying raising mains. The Hon’ble Supreme Court has formulated Guidelines in the Lafarge Judgment which mandate that projects that require both forest and environment clearance must first secure forest clearance. This has not been complied with.
Gravity Canal from Harvanahalli (Sakaleshpur) to Tumkur will require a minmum of 400 hectares land
Reservoir at Devarnyadurga will require 1200 hectares of land, including 50% forest land and will submerge at least 2 villages.
Though the project claims to be a scheme for drinking water of Kolar and Chikkaballapur Districts, actual dedicated drinking water allocation of these districts is only 2.81 TMC of the 24.01 TMC diverted which works out to less than 10%. Rest will go for irrigation, river rejuvenation, urban areas, industrial areas, etc. Signatories support long term and sustainable solutions to drinking water crisis. While provision of drinking water to the said districts is a legitimate necessity that we do not object to, what we are questioning is the justification of this ill conceived project whose cost-benefit analysis is extremely skewed and the ecological and social impacts are horrendous.
Alternative and feasible proposals that will provide the 2.81 TMC feet of water for the said districts have, in our considered view, not been explored. Furthermore, the feasibility of large-scale land acquisition required for the project must be considered in the context of the amendments to the Land Acquisition Bill that has just been passed by Parliament.
Considering all these serious issues, the EAC’s appraisal of this project has been incorrect technically as well as wrong on facts and law.
We urgently request the MoEF to:
1. Withdraw any letter/NOC etc., that it may have sent to Karnataka Government in this regard as the current decision of the EAC and MoEF may not stand the test of legal scrutiny and may lead to some wholly un-necessary litigation.
2. Direct the State of Karnataka to present a detailed project report that includes the plans for phase II and III that are sure to follow.
3. Ensure that the EAC considers the DPR and appraises project for Environmental Clearance in its entirety.
Looking forward to your response and appropriate action to points raised above.
Maharashtra’s Chief Minister Prithviraj Chavan was the Chief Guest for one day symposium regarding water management in Maharashtra organised by the Gokhale Institute of Politics and Economics in Pune on the 2nd of July 2013.
In his address, the CM raised a number of important topics about water management in Maharashtra. Some of his thoughts were encouraging. He talked about the problems and expense of large irrigation projects, their underperformance and underlined the need for decentralised water management systems. He mentioned that the 2000 crores spent on tankers and animal shelters during 2013 drought was an avoidable expense, if we had developed decentralised water sources. He highlighted the problems of water regulatory authorities like MWRRA. He also mentioned that improper dam operation is a reason behind many disasters like the floods in Surat in 2006 due to Ukai Dam, Sangli floods due to mismanagement of Almatti Dam and stressed that Maharashtra should be concerned about this.
Significantly, he mentioned that while we are assessing the economic costs and efficiency of large dams, we are not looking at their social and ecological and that such assessments should take place. He also said that there should be an in-depth study on the ecological costs of these projects. This is a very welcome statement.
In reality, there has been a huge gap on what he said and what is happening on the ground.
The most blatant example of this is the Kalu Dam where work has stopped currently due to a stay order by the Hon. Bombay High Court. This dam is coming up in the Murbad block of Thane District and falls entirely in the tribal sub plan area and ecologically sensitive region of the Western Ghats. It is set to submerge 1000 hectares of Western Ghats forests and will affect more than 18000 primarily tribal population. The dam, being built by the Konkan Irrigation Development Corporation (KIDC,) has not done any Social Impact Assessment as per the National Rehabilitation Policy. Nor has it undertaken an Environmental Impact Assessment or Cumulative Impacts Assessment of its impact on the Forests. The individual and community Forest Rights have not been settled, in violation of the Forest Rights Act, 2006. Despite all this, the construction started illegally, without a Forest Clearance and is halted only because of a petition filed in the High Court by Shramik Mukti Sangathana.
The Forest Clearance of this dam was rightfully rejected in 2012 by the Forest Advisory Committee (FAC) of the Ministry of Environment and Forests (MoEF). But exactly a year later the Forest Advisory Committee went back on its decision and gave Forest Clearance to this project unjustifiably.
One of the important reasons as, stated by the FAC in in its minutes is that
“(The FAC) also noted that Hon’ble Chief Minister of Maharshtra has specifically requested for a review of the decision of the Forest Advisory Committee” (FAC Minutes 3-4th April 2013)
How is it that the CM actually pushed for a Forest Clearance which would destroy over one lakh trees in Western Ghats, without any studies or options assessment?
When we asked this to the CM after this meeting, he replied that there is no law which says that EIA study for a drinking water supply dam is needed. While this is true and attributed to the erroneous omission in the EIA notification 2006, there is no law which says that such studies should not be conducted! Especially for a dam which is going to submerge 1000 hectares of forests and affect 18000 tribals! A Chief Minister with vision would in fact ask for such studies suo motto.
Dams around Mumbai which are mainly for drinking and industrial water supply can together submerge more than 6000 hectares of Forest. Even the State Forest Department under the Chief Minister himself has said that EIA of Kalu Dam is necessary. Chief Conservator of Forests, Central Circle has said that Cumulative impact Assessment of Dams coming up around Mumbai is necessary.
In this scenario, rather than urgently demanding for such a study the CM has in fact pressurised the FAC into giving a Forest Clearance to Kalu Project, WITHOUT any assessments.
During his speech, the CM said how important afforestation is. He said that he has asked all departments to undertake afforestation. “The issue is so important that even tanker water should be given for afforestation”. When afforestation is so important, why are we submerging last remaining forests of Western Ghats without any studies?
Misrepresentation of Western Ghats Expert Ecology Panel (WGEEP) Report: The CM also said that WGEEP Report has banned all development from Gujarat to Kerala and that the on-going laterite stone mining in Sindhudurga-Ratnagiri districts is a result of WGEEP which will hamper development in these places. It has laid a blanket ban on development.
CM seems to be entirely misinformed on this count. Firstly the laterite stone mining ban has nothing to do with WGEEP Report, but is in place due to a Supreme Court Order. This point has been reiterated several times and it is surprising to see the CM still claiming this. Secondly the WGEEP has not banned developmental activities, but has said that local communities should be in the driving seat while taking decisions affecting their regions. This is also upheld by several laws including the Forest Rights Act. So CMs statement about the WGEEP is clearly ill informed.
It was great to see the CM mention Climate Change, its impacts, need for advanced weather monitoring, etc. It was also good to hear from him about ecological importance for rivers and their flow. It will be good if environmental flows are released from dams of Maharashtra, as also upheld by the Krishna Water Disputes Tribunal. This is currently not happening.
The CM seems to have progressive opinions about water and natural resource management. Hence, we are sure that the CM will demand for an Environment Impact Assessment, Social Impact Assessment and Cumulative Impact Assessment of dams coming up around Mumbai, especially Kalu Dam and will take a critical look at dams coming up across Western Ghats in Konkan being undertaken by KIDC, breaking laws like Forest Conservation Act, Forest Rights Act, Environment Protection Act, National Rehabilitation Policy with impunity. In fact he should see that KIDC and contractors which started work illegally are brought to the books.
We hope that the CM walks his talk about decentralised water management and valuing ecology.