Can land, trees, structures, farms, pipes, poles, pumps etc, along a river bank several kilometers downstream collapse if water flow in the river is suddenly reduced or stopped? Yes, reduced/ stopped, not increased? This kind of river bank slump or collapse or failure is not easily understood, but it does happen. Let us see how. Continue reading “River bank failure due to sudden water flow changes”
What separated Maheshwar Ghats on the mighty Narmada from most other rivers I have seen was the sheer gaiety and joy which people were experiencing, jumping in the Narmada. The beautiful, jutting steps of the ghats were designed (and used) like diving boards by men, boys and women. For someone who had just seen a dry Godavari and drier rivers of Marathwada, this mirth was therapeutic. Ferry Boats and laidback ferrymen were relaxing on the river, bobbing up and down rhythmically. In the distance was a tiny sailboat, held together by white fluttering sails, zipping through the waters at a startling speed without the din of a diesel engine. A fisherman and his daughter were returning to their village, taking stock of their catch.. Occasional fish rose above the waters and glistened in the evening sun. Continue reading “नदी के बदले नदी दे सकते है? ..on Maheshwar, Narmada and fishing communities of India”
What does it mean when landscapes, riverscapes, ways of life are altered forever? When a mighty, flowing river is plugged and made to stop, flow in tunnel and released as per our whims? For most of us, life and environment are so fundamentally modified that we would hardly question it. But as our worldview and our politics is set to dam some of the last free flowing rivers in the North East India into Hydro-Electricity Banks, what is at stake? Continue reading “India’s Free Flowing Frontier Part I: Dibang at Nizamghat”
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.
Indus Water Treaty
Chenab basin is international basin as per the Indus Water Treaty. A recent order of the international court has debarred India from operating any projects below MDDL and has disallowed provision for facility to achieve drawdown below MDDL in any future project[i] (for details, see: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/). The EIA described gate opening in this project for silt removal, which stands debarred by international court. The EIA thus is in violation of the verdict of international Court.
The EIA says (p. 21 bottom), “Five low level sluices with crest at 2167m of size 7.5m width and 12.3m height are proposed for flood passage. Drawdown flushing of the reservoir shall be carried out through these sluices for flushing out of the sediment entrapped in the reservoir. Detailed studies on sedimentation and reservoir flushing can be taken up at detailed planning stage.” The MDDL of the project is 2209.3 m as mentioned in the same para. This means the project envisages sediment flushing by drawdown to 2167 m (sluice crest level, the sluice bottom level wll be 12.3 m below that), about 42.3 m below the MDDL. This is clearly not allowed under PCA order cited above on Indus Treaty.
Impact of 3.5 MW Chhou Nala HEP to be constructed for the project not assessed
The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project. But the EIA does not contain any impacts of the SHP. The stream on which this is planned is extremely important for the people as drinking water schemes, irrigation Kuhls and gharats of Rai, Chhou and Thandal villages are located on this stream in the proposed project area. Thus the project will have huge impacts, but there is no assessment of these impacts. This is another glaring omission of EIA. It was shocking to read that the resident commissioner said at the public hearing that this question is not part of Environmental Public hearing, when it is very much part of it.
Public hearing report
At several places either no information is given or misleading information has been presented. For example the project representatives mis-informed the people at PH that 15-20% water will be released, when minimum water they need to release is above 20%. DFO said that soil will be spread over the muck disposal site for tree planting over it, but there is no provision of this in EIA-EMP. Many questions were provided with vague answers or no answers at all. No clear answer was given when asked if the muck dumping sites have been decided in consultation with the local people, implied answer is clearly that local people have NOT be consulted. When asked about agreements to ensure that the company implements EMP and Social Management Plan as required, there was no promise that such an agreement will be signed with the village gram sabhas. The affected people raised the issue of erosion impact of diversion tunnel, but no specific response was provided in response to this issue. When a resident of Chhou village raised the issue of vulnerability of the village to the landslides, no clear answer was given by the project developer. When the same person asked that our cremation ground is going under submergence, what is the company planning about it, the project developer replied that IF the cremation ground goes under submergence, we will think about this. This only shows that the project developer and EIA consultant have not even done an assessment of such basic aspects. The PH report accepts that close to 100 workers are already working without even basic sanitation facilities, this is clear violation of EIA notification further the EIA Agency fails to mention this.
EIA is full of cut and paste, generic statements, no actual assessments
Out of nine chapters of EIA, only the last chapter is about impacts assessments! So out of 170 pages of nine chapters, only 31 pages of chapter 9 is supposedly about impact assessment and there too mostly there is no real impact assessment, mostly only generic statements that can be included in any EIA. There are several unnecessary sections in the EIA like chapter 3 on “Construction Methodology” which is unnecessary in EIA. In most other sections too, the information is just cut and paste from DPR. By way of impact prediction, the EIA report is only listing them doing absolutely NO ASSESSMENT and no quantification of impacts is attempted. Further since the EMP is not available in the public domain, it is impossible to assess if the measures provided in the EMP are effective. Such EIA is definitely not acceptable.
No proper referencing The EIA does not provide references to the specific information, without this it is difficult to cross check which information is from which secondary sources and how credible it is and which information is from primary survey.
This is another most shoddy piece of EIA by WAPCOS.
Moreover, as we can see the EIA has not done several impact assessments, has violated large no of TORs on several counts, the EIA-EMP are not available on EAC website, the project parameters have undergone changes necessitating fresh scoping clearance as mentioned in TOR but that has not happened, baseline study is 3-4 years old, EAC stipulation of fresh EIA-EMP has been violated, Project is using larger riverine stretch than given by HP govt, there is no proper referencing, hydrology is weak, EMP is not available on HPPCB website in violation of EIA notification, among several other issues listed above. Every conceivable serious problem can be found in this EIA of WAPCOS.
It is full of generic statements that can be pasted in any EIA without any attempt at project specific impact assessment. SANDRP has been pointing to EAC and MoEF about such unacceptable EIA by WAPCOS for several years, but neither EAC, nor MoEF has taken any action in this regard. SANDRP has once again urged to EAC and MoEF to reject this EIA and recommend blacklisting of WAPCOS and to issue fresh scoping clearance for the project as mentioned in the TOR since the project parameters (dam height, submergence area, land requirement, etc) have gone through significant changes.
We sincerely hope the EAC will not only take serious cognition of these and not recommend clearance to the project, but also direct the project proponent and EIA consultant to implement other recommendations made above.
Amruta Pradhan (email@example.com), Himanshu Thakkar (firstname.lastname@example.org)
[viii] Refer to SANDRP studies on Chenab
At the 10th International Symposium on Ecohydraulics in Trondheim, Norway in June 2014, SANDRP talked with Dr. Thomas Hardy, Past President of the Ecohydraulics Section of the International Association for Hydro-Environment Engineering and Research (IAHR), and The Meadows Center for Water and the Environment Endowed Professor in Environmental Flows at Texas State University.
Dr. Hardy holds advanced degrees (MS and PhD) in both aquatic ecology and civil engineer and has been at the forefront globally, for linking issues related to hydraulics and hydropower with ecosystems. Here he talks about issues like state-of-art mitigation measures being put to use across the world for mitigating impacts of hydropower, evolution of Ecohydraulics and the dangers of “Putting dams at the wrong place”
We see some significant mitigation measures, some of which include decommissioning, for addressing impacts of hydropower coming from over the world. How did this system evolve? What was the role of various actors and did this happen suo motto from the companies?
Since the last two decades, we have recognized the environmental consequences of hydropower. The cost benefits analyses of many projects is getting skewed, we have been witnessing the ecological costs of many of such projects are exceeding their economic benefits. For example, in the 5 dams in a cascade on the Klamath River, the economic value of the salmon fisheries being destroyed was more than the hydropower benefits from the dams. A lot of mitigation measures have come from countries like Norway and countries like US have also seen them, and we are always keeping our eyes open for better solutions.
While it’s accepted that there will be impacts of any intervention, we need to be honest about the scale of the impacts and who pays the price for these impacts.
About the suo motto role of companies, unfortunately, I have not seen very many companies adopting better environmental standards by themselves without consistent pressures and constant monitoring from people and the government. A lot of credit to increased performance of hydropower mitigation measures goes to NGOs, civil society groups, indigenous communities and the citizens themselves for raising these issues with the companies as well as governments to adopt better standards for their rivers. The advent of social media continues to help a lot to this end.
In the US, a lot of changes were also driven by aboriginal communities who protected their fishing rights or riverine ecosystems. For example in the Klamath River, the aboriginal tribes upheld their traditional fishing rights of salmon which were affected by the dams. This led to not only changes in dam operation, but a spurt of work on fish ladders, passes, eflows and decommissioning. Having said that, we have also committed some massive mistakes, the cost of which have been great. The mitigation measures we are trying to put in now are very costly. Making wise decisions about siting dams and including mitigation measures at the level of designing itself is not only effective, but its also comparatively cheaper. In that sense, it is encouraging to see China being more concerned about the impacts of its hydropower on the environment.
It is claimed that Run of the River projects are environmentally better than storage type HEPs. There are some such projects which undertake massive peaking. How can the impacts of massive scale of hydro-peaking be mitigated?
Firstly, if its peaking, its not an ROR. An ROR by definition cannot store water and cannot change the hydrographs of a river on a timescale. If it’s doing that, it’s not an ROR and should not be labelled as such. Period. If anyone is doing that, I would question their motives in being less than truthful. It’s also a matter of wrong green labels to these projects. So we need to remember that RORs do not change the downstream hydrograph and hence cannot peak.
How about the contention that ramping up and down reduces peaking capabilities of the project?
Well, there is no free lunch. There is a cost to doing business, cost of doing good business, and only this will keep it running in the long term. No one would deny that all developmental activities entail environmental costs, but we to understand the range of environmental and social costs, put them on table and then take a wise decision, taking everyone on board.
As for ramping rates affecting peaking operations, power demands do not fluctuate hugely from established patterns on a daily, weekly, or seasonal basis and the companies have a pretty good forecast idea of the range of demand. Based on this, if the peaking is supposedly for 3 hours, up ramping can be started an hour earlier, so that we get the benefits of 3 hours peaking. Same goes for down ramping, you need to coordinate it that way. Of course this will mean some change of efficiency, but like I said, there is no free lunch and surely government and companies are concerned about safety of their people downstream these projects.
Safety concerns of peaking opeartions, apart from the ecological concerns, are very important to consider. In case of the Milner Dam on the Snake River in the US, I actually had a group of students and fishermen stand and then wade in a river and we then worked on the releases from the dam which gave sufficient time for these people to get out of the river. There is no option to safety measures. They are of paramount importance.
When we develop rivers in a cascade, would it help if we maintain free flowing stretches between projects?
Well it’s a relative question, which is all about siting your projects. In the first place, don’t put a dam in the wrong place! That’s most important. After that, placing of other dams will be specific to the ecological uniqueness of that river. But we need guidelines which say at least some percentage of the upper watershed should be conserved and not exposed to impacts like peaking. It may be better to entirely protect the tributaries of a heavily dammed basin, rather than adopting a cut and stitch approach. FERC (Federal Energy Regulatory Commission) is now routinely including impacts of hydropeaking on fish and other organisms like benthic macroinvertebrates while relicensing and also licensing.
How is the monitoring mechanism around mitigation measures developed in the US? Do communities have a role to play here?
Monitoring is well developed and an important part of the licensing process. The company can do annual monitoring themselves, or they can outsource this to an external entity. Monitoring advisory Committees are mandatory for projects and this committee includes representatives from the company, wildlife groups, aboriginal groups, regulators, etc. The membership to this committee is pretty flexible. If a group has significant reasons and wants to be a part of the monitoring committee, it can do so. This committee monitors environmental management plans and also guides the company in this process.The issue is about making the companies and government accountable to the society.
There has been a flood of eflows methodologies, Which one would you describe as the state of art methodology at this moment?
ELOHA is robust and well developed for this moment, but there is no one size fits all method, the assessment method depends on the data, time and resources available. The main point is that even eflows entail consensus generation and equitable sharing of resources and here too, the community should be playing a main role.
When the dam building pressures are too high, there is little point in hurrying through studies. In extreme cases, it is wise to put a moratorium on on-going development, try and fathom what we have lost and will be losing, look at the environmental and social consequences of this loss and then decide on the way forward. These things cannot be hurried into.
At places like Columbia River systems, we realize that we have changed the entire river basin, but the mitigation measures have been developed, put in place and are working. So, that’s good. But in other places, we realize that the social, ecological and even economic costs we are paying for developing dams are just not worth the costs. In those cases, we need to bring them down. This has happened too.
Interviewed by Parineeta Dandekar, SANDRP
(The trip was possible due to generous support from Both ENDS)
 Text book definition of ROR: ““Run-of-river” refers to a mode of operation in which the hydro plant uses only the water that is available in the natural flow of the river, “Run-of-river” implies that there is no water storage and that power fluctuates with the stream flow.”
NOTE: Contrast this with the Indian Bureau of Standards definition of ROR, which allows pondage for even weekly fluctuations of demands and then claiming that this “does not alter the river course materially”. This is a blunder as that sort of pondage and resultant peaking hydrograph changes the downstream character of the river completely. even weekly storage and then peaking as ROR!
 http://www.northfieldrelicensing.com/NorthfieldRelicensing/Lists/Documents/Attachments/47/20130228-5329(28100604).pdf: The Turners Falls Project is currently operated with a minimum flow release that was not based on biological criteria or field study. Further, the project generates power in a peaking mode resulting in significant with-in day flow fluctuations between the minimum and project capacity on hourly or daily basis. The large and rapid changes in flow releases from hydropower dams are known to cause adverse effects on habitat and biota downstream of the project. Effects on spawning behavior could include suspension of spawning activity, poor fertilization, flushing of eggs into unsuitable habitat due to higher peaking discharges, eggs dropping out into unsuitable substrate and being covered by sediment deposition and/or eggs becoming stranded on de-watered shoal areas as peak flows subside.
In a classical Thumri rendition, Ustad Rashid Khan sings about how a river, which was once a friend, has turned into a foe…Nadiya Bairi Bhayi.. Something similar is happening at a number of places in India, where the river, a life giving friend, is turning into a deadly force.
Drowning of 25 students following sudden water releases from the 126 MW Larji Dam in Mandi, Himachal Pradesh is one more saddening and shocking incidence in the long list of hydropower-release related disasters in India where rivers are turned into death traps.
On the 18th April 2014, 11 year old Radhika Gurung studying in standard fourth was accompanying her sisters Chandra and Maya along the river Teesta near Bardang, Sikkim. Suddenly, without having any time to respond, all three school girls were washed away by a forceful water released by upstream 510 MW Teesta V Hydropower project in Sikkim. While Maya and Chandra were lucky to be saved, Radhika was not so lucky. She lost her life. Residents here say that NHPC, the dam operator, does not sound any sirens or alarms while releasing water in the downstream for producing hydroelectricity and villagers live in constant fear of the river. Residents demanded strict action against NHPC, but no action has been taken.
On the 28th March 2013, 5 people, including two small children aged 2 and 3 drowned in the Bhawani River near Mettupalayna when 100 MW Kundah IV HEP (Tamil Nadu) on the Pillur Dam suddenly released discharge of about 6000 cusecs water. The family was sitting on the rocks in the riverbed when water levels started rising, and they did not get enough time even to scramble out of the river with the two children, says the sole survivor. Tangedco officials stated that although alarm is sounded at the nearest hamlets, it does not reach the downstream regions. Local villagers say no alarm is sounded. No action has been taken against Tangedco.
On 8th January 2012, a family of seven people, including a child, drowned in the Cauvery River when water was released from the 30 MW Bhavani Kattalai Barrage-II (BKBII in Tamil Nadu). The same day, two youths were also swept off and drowned in the same river due to this release. There are no reports of any responsibility fixed or any action taken against the Barrage authorities or Tangedco, although it was found that there was not even a siren installed to alert people in the downstream about water releases.
Uttarakhand has a history of deaths due to sudden releases from its several hydropower dams. In April 2011, three pilgrims were washed away due to sudden release of water from Maneri Bhali-1 Dam on the Bhagirathi in Uttarakhand. In 2006 too, three women were washed away by such releases by Maneri Bhali. The district magistrate of Uttarkashi district ordered filing a case against the Executive Engineer of the dam after a number of organisations demanded action against the guilty. Again in November 2007, Uttarakhand Jal VIdyut Nigam Limited was testing the opening and closing of gates of Maneri Bhali Stage II, when two youths were washed away by these releases.  Following a protest by locals and Matu Jan Sangathan, the Executive Engineer and District Magistrate simply issued a notice which said that “Maneri Bhali Hydropower Projects exists in the upstream of Joshiyada Barrage and water can be released at any time, without prior notice from here”.
Similar notice is also given by NEEPCO, which operates the Ranganadi Dam and 405 MW Dikrong Power House in Arunachal Pradesh, on the Assam border. “The gates of Ranganadi diversion dam may be opened at any time. NEEPCO will not take any responsibility for any loss of life of humans, animals or damage to property”.
Similar notice sits on the banks of the Chalakudy River near the Athirappilly falls in Kerala and the Kadar tribes, which traditionally stay close to the river and are skilled fisher folk too, are fearful of entering the river.
Chamera HEP in Himachal Pradesh has been held responsible for sudden water releases and resultant deaths in the downstream. As per retired IAS Officer Avay Shukla who resides in Himachal, similar incidences which resulted in loss of lives have also happened due to Nathpa Jhakri and other dams in the state.
In December 2011, three youth were drowned in the Netravathi River when water was released by the fraudulently combined 48.50 MW AMR project (Karnataka) now owned by Greenko. Villagers protested at the site, but this has not been the first instance of drowning because of this project. Villagers accuse the dam for the deaths of as many as 7 unsuspecting people in the downstream. This dam is now increasing its height and one more project is being added to it.
On October 1, 2006, at least 39 people were killed in Datia district in Madhya Pradesh when suddenly large amount of water was released from the upstream Manikheda dam on Sind River in Shivpuri district. There was no warning prior to these sudden releases and hence unsuspecting people crossing the river were washed away. Chief Minister Shivraj Chauvan ordered a judicial probe into this incidence in 2006, however, and a report was submitted by retired High Court Judge in 2007. Since then, the report has been buried and several attempts of RTI activists to access the report have been in vain. The government has not released the report, forget acting upon it or fixing responsibility after 8 years.
In April 2005, at least 70 people were killed at Dharaji in Dewas district of Madhya Pradesh due to sudden release of huge quantity of water from the upstream Indira Sagar Dam on Narmada river. Principal Secretary Water Resources Madhya Pradesh inquired into the incident and found that “there was no coordination between agencies”. No accountability was fixed and no one was held responsible. NHPC, who operated 1000 MW Indira Sagar Project, simply claimed that it was a case of miscommunication and that it was not aware of the religious mela in the downstream of the river. As SANDRP observed then, “ It just shows how far removed is the dam operator from the welfare of the people in Narmada as the fair annually gathers more than 100,000 people of the banks of the river. It is a scandal that no one was held responsible for the manmade flood which resulted in the mishap.”
Above incidents make it clear that incident at Larji is not the first and will not be the last, if we continue non transparency and non accountability in hydropower dam operations.
Some Questions that arise from these events:
Do sanctioning authorities and dam operators reaslise that each of these projects convert an entire river ( not limited to the hydropower project) in the downstream area into a potential death trap? Do they assess the impacts of the various possible operations of the projects in the downstream area and envisage, plan and implement measures to avoid death and destruction in the downstream areas?
Can cordoning off and alienating a river, indicating that it is dangerous, be a solution to this? Are measures like alarms, sirens, lights enough when a river experiences order of magnitude sudden change in its flow due to dam and hydropower releases?
Is it ok to have hundreds of dam-related deaths in the recent years due to irresponsible and non-transparent dam operations and not have any responsibility fixed?
The obvious answer to the above seems NO.
Some Recommendations: As we have seen above, many man made disasters have happened in India over the last decade and governments and dam operators have learnt no lessons. The avoidable tragedies are repeating without any change. India is possibly the only country in the world where such events have been happening in such large numbers. Here we are recommending some basic steps if we want to avoid or minimise occurrence of such tragedies in future.
MEASURES FOR TRANSPARENT, INCLUSIVE MANAGEMENT NORMS IN OPERATION OF ALL EXISTING DAMS AND HYDROPOWER PROJECTS:
For every operating Dam and Hydropower project in India there should be clearly defined operating procedure in public domain. This operating procedure will include the steps taken before release of water from dam or power house, how the releases will be increases (the increase should be in steps and not suddenly releasing huge quantity) or decreased, how these will be planned in advance, who all will need to be informed about such plans in what manner and what safety measures will be taken. This will also include who all will be responsible for designing, monitoring and implementing these measures. There should be boards at regular intervals in the downstream area in language and manner that local people and outsiders can understand and the boards should also indicate the danger zone and what kind of sirens and hooters may blow before the releases.
The operating procedure will take into account where there are upstream projects and how the upstream projects are going to influence the inflow into the project and how information will be shared with upstream and downstream projects and in public domain. The Power Load Dispatch Centres should also remember that when any hydropower project is asked to shut on or off, there are consequences in the river and they should be asked to keep such consequences in mind and time required to alert the regions in risk.
For every dam there should be a legally empowered official management committee for the project management, in which 50% people should be from govt and 50% should be non govt persons, including local community representatives and this committee should be in charge of providing oversight over management, including operation of the project and should have right to get all the information about the project.
Hourly water levels and release data of hydropower dams be made available in public domain on daily bases. Water levels corresponding to discharges (and possible timings where applicable) should be physically marked on the river banks, local communities should be involved in this, evacuation methods and mock drills should be organised by dam proponent from time to time in all places along the river where the impacts reach.
THE EXISTING DAMS AND HYDROPOWER PROJECTS SHOULD BE MANDATED TO PUT ALL THIS IN PLACE WITHIN A PERIOD OF NEXT THREE MONTHS THROUGH A LEGALLY EMPOWERED STEP IN ALL STATES.
SANCTIONING PROCESS FOR NEW PROJECTS, INCLUDING FOR UNDER CONSTRUCTION PROJECTS:
Safety measures related to, including water releases for all kind of eventualities and their downstream impacts and management plan should be an integral part of EIA and EMP. The aspect should be thoroughly discussed while appraising the project, and clear cut roles and responsibilities fixed. Mitigation measures should include proper siting of the project, gradual upramping & Downramping of releases in a clearly defined way and where planning is mandatory, safe operation of discharges through dams, etc.
Entire clearance mechanism for cascade hydropower projects in the Himalayas and elsewhere needs to be revisited to include the operational safety measures considering the cumulative operation of the projects. Projects where operational safety measures alone will not be sufficient due to massive fluctuations/location/upstream projects, etc., should be urgently dropped.
Peaking power projects should be restricted to certain locations like deep mountain gorges, after proper studies. Such projects should not be permitted as rivers enter into floodplains, due to their significant impact on the downstream and also in biodiversity rich river stretches.
SAFETY MEASURES BEFORE AND DURING WATER RELEASES:
Primary safety measures like informing the administration well in advance before release, sirens, hoots, alarms, lights, buoys should be strictly enforced and a clear responsibility of these measures should be adopted, for the entire zone in risk, sign boards at every 50 mts interval in such zones in languages and manner that local people and outsiders can understand, and which also show the specific risk zone. Where sudden unseasonal releases are likely, include police surveillance of the risk zone during danger period.
WHEN THERE IS DEATH AND DESTRUCTION IN THE DOWNSTREAM AREA:
Exemplary punishments should be fixed not only for dam operators,but also engineers and dam companies in case of negligence. Independent inquiry will be required since departmental or inquiries by District administration or government officials are not likely to be credible.
Since the designed safety measures in case of Larji were clearly inadequate, not just the operational staff but all those responsible for such shoddy safety plan should be held accountable.
It is unacceptable that a life giving and beautiful entity like a river should be converted into a dangerous and deadly force for our energy needs, without even the most basic precautions in place.
-Parineeta Dandekar, Himanshu Thakkar
In 1999, 39 people and hundreds of animals and livestock in Cambodia was washed away and drowned by the release from Yali Falls Dam on Sesan in Vietnam. Mekong River Commission took a strong view on this. http://www.threegorgesprobe.org/pi/Mekong/index.cfm?DSP=content&ContentID=8946
 http://www.daijiworld.com/news/news_disp.asp?n_id=124216, http://www.indiawaterportal.org/articles/1-dam-2-projects-many-fools
7 Students Get Justice 16 Yrs after Meeting Watery Grave
By Express News Service Published: 18th September 2014 06:03 AM
BHUBANESWAR: In a significant judgment, a civil court on Wednesday awarded a compensation of `25 lakh each to the families of seven students of University College of Engineering (UCE) of Burla __ now VSS University of Technology __ who were swept away by unannounced and untimely release of water from Hirakud dam 16 years ago.
Civil Judge (Senior Division), Bhubaneswar, Sangram Keshari Patnaik, who pronounced the verdict in his 31-page judgement, ordered that the compensation be paid with 6 per cent interest effective from 2001, the year when the case was filed before the court.
The tragic incident had occurred on January 30, 1998 when eight students of the UCE of Burla were taking pictures on a sand bar of Mahanadi as part of the Spring Festival activity. The water flow of the river rose menacingly and barring Soubhagya Barik, the rest seven second-year engineering students were swept away and met their watery grave.
The Hirakud Dam authorities had allegedly opened nine gates during the non-monsoon season which led to the tragic incident as no caution was sounded before the release of the water.
The State Government ordered a Revenue Divisional Commissioner-level inquiry into the incident and the then RDC Hrushikesh Panda submitted the report to the Government on March 29, 1998. The Government accepted it on May 19.
The RDC, in his report, had examined 77 witnesses and 31 affidavits were filed. Panda, in his report, had highlighted the irresponsibility of the engineers and stated that even the Sambalpur Collector and the Superintendent of Police were not intimated about the release of water, let alone the public.
Basing on the report, the State Government had announced a compensation of `3 lakh each to the family of seven students. However, considering the compensation inadequate, a petition was filed before the Orissa High Court. In 2001, the HC directed that the case must be filed before a civil court since it pertained to compensation.
According to Madhumadhab Jena and Sidharth Das, counsels for the deceased’s families, the Civil Judge Court took into account various aspects, including the academic background of the students of UCE.