Comments on HLWG Report submitted to Ministry of Environment and Forests

May 20, 2013May 20, 2013 SANDRP1 Comment

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

Comments on HLWG Report with a focus on Water issues

Date: May 20, 2013

To,

Mrs. Jayanthi Natarajan

Union Minister of State (IC)

Ministry of Environment and Forests

Government of India

Email: mosefgoi@nic.in, jayanthi.n@sansad.nic.in

Dr. V Rajagopalan

Secretary

Ministry of Environment and Forests

Government of India

Email: envisect@nic.in

Dr. Amit Love,

Deputy Director,

Ministry of Environment and Forests

Email: amit.love@nic.in

Dear Mrs. Jayanthi Natarajan and Dr. Rajagopalan,

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

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

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

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

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

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

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

Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP

HLWGs recommendations about Hydropower are ad hoc, unscientific and misleading

HLWG claims that all Hydropower is “renewable and clean.”

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

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

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

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

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

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

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

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

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

Recommendation about mitigating impacts of Hydropower are extremely weak

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

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

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

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

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

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

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

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

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

Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP

The HLWG does not stress the need of Environmental Clearance (EC) for Drinking Water and Industrial supply dams

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

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

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

Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP

HLWG does not recommend eflows from existing projects

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

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

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

HLWG does not apply its mind to dam decommissioning

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

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

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

The MoEF may please recommend the same.

Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror

HLWG does not recommend free flowing rivers for WG

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

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

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

Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP

HLWG allows Inter basin transfers in Western Ghats, without any justification or studies

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

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

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

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

HLWG allows hydro projects in first and second order streams

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

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

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

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

The MoEF should follow these recommendations of the WGEEP.

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

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

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

Athirappilly Waterfalls on the Chalakudy River Photo; SANDRP

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

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

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

Thanking You,

Yours Sincerely,

Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune (ht.sandrp@gmail.com , parineeta.dandekar@gmail.com)

Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (rrckerala@gmail.com)

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, Maharashtra (manthan.shripad@gmail.com)

Dr. T.V. Ramchandra, Energy & Wetlands Research Group, Centre for Ecological Sciences, IISc, Bangalore (cestvr@ces.iisc.ernet.in)

Janak Daftari, jalbirdari, Mumbai, Maharashtra (daffy@jalsangrah.org)

Sujit Patwardhan, Parisar, Pune, Maharashtra (patwardhan.sujit@gmail.com)

Dr. Nilesh Heda, Samvardhan, Vidarbha, Maharashtra (nilheda@gmail.com)

Nisarg Prakash, Nature Conservation Foundation and Nityata Foundation, Bangalore, Karnataka (nisargprakash@gmail.com)

Mrinalinee Vanarase, Iora Consultants, Pune, Maharashtra (ioraespune@gmail.com)

Shankar Pujari, President, Nivara Bandhkam Kamgar Sangh, Sangli, Maharashtra (shankarpujari16@gmail.com)

Damodar Pujari, SANDRP, Pune, Maharashtra (damodar.sandrp@gmail.com)

Saili Palande-Datar, Kalpavriksha, Pune, Maharashtra

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

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

[1] http://www.internationalrivers.org/resources/fizzy-science-loosening-the-hydro-industry-s-grip-on-reservoir-greenhouse-gas-emissions

[2] http://www.internationalrivers.org/resources/a-bibliography-of-key-scientific-articles-and-publications-on-greenhouse-gas-emissions

[3] http://philip.inpa.gov.br/publ_livres/Preprints/2011/Fearnside-Greenhouse%20gas%20Emissions%20from%20Dams-Wiley.pdf

[4] https://sandrp.in/HEP_Performance/HEP_Performance_in_Koyna_River_Basin_Jan_2011.pdf

[5] https://sandrp.in/HEP_Performance/HEP_Performance_in_Kalinadi_River_Basin_Jan_2011.pdf

[6] https://sandrp.in/HEP_Performance/HEP_Performance_in_Sahravathi_River_Basin_Jan_2011.pdf

[7] http://www.infraline.com/Details/hc-orders-status-quo-on-maruthi-power-generation-hydel-project-168481.htm

[8] http://www.dnaindia.com/bangalore/1808037/report-damned-finally

[9] http://www.internationalrivers.org/resources/where-rivers-run-free-1670

Dams · Environment Impact Assessment · Hydropower · International Water Issues

Damocracy: “The world is killing its rivers!!”

May 15, 2013May 15, 2013 SANDRP1 Comment

http://damocracy.org/?portfolio=damocracy-the-movie

A fantastic documentary shattering the myths of Large Dams as sources of clean energy, Damocracy takes a documentary to the next level. It talks about two dams, separated by thousands of kilometers, united by people’s struggle against destructive and illegal large dams. It traces the story of the Bel Monte Dam on Xingu River in the Amazon Basin of Brazil and the Ilisu Dam on the Tigris River in Turkey.

It takes us through a maze of lies, government repression, plight of communities, strengths and struggles of local communities against these projects which have gone on for decades. While Bel Monte Dam threatens over indigenous tribes and native fish in Brazil, Ilusu Dam, under construction even without an EIA will submerge 300 archeological sites including eth entire city of Hasankeyf.

Dr. Philip Fearnside talks about the popular jingle of Hydropower being ‘clean, green source of energy’. He says “People have heard this myth so many times, that they believe it, because they’ve never heard anything else.” He talks about the impact of Methane on global warming, which is many times more than carbon di oxide.

The film ends with a diverse group of dam activists from all corners of the world actually dismantling a wall built across the Xingu… working together in the scorching Amazon sun to undo work of machines for months. In the end, the XIngu flows again..though symbolic, it a powerful message.

In the words of one of the elated activists seeing the river flow finally “If a small united group could do this, imagine what a united world can do against monster dams.”

An inspiring fim in many ways. A must watch for sure.

more on the campaign: http://damocracy.org/

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

Dams, Rivers and People Feb-March 2013 Edition

May 3, 2013 SANDRPLeave a comment

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

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

Maharashtra’s sugar shackles

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

Decommission dams as an Environmental Priority!

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

How much do we know of our dams and rivers?

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

Vertebrates of Chambal

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

Journey from Cooperation to Conflict

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

Will water released from Ujani help Solapur?

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

No New Mini hydel Projects in Karnataka Western Ghats!

Bhutan on a Hydropower Spree

Water Privatisation is not for India

Rivers changing course in Arunachal

One All verdict for India Pakistan in Kishenganga Arbitration

Bring back our Yamuna!

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

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

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

Forest Advisory Committee reconsidering clearance for Kalu Dam again!

Hydropower at the cost of Drinking water?

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

Debatable Dam in the Western Ghats

How the World Bank undermines its own development goals

Hydropower · Ministry of Environment and Forests · Ministry of Water Resources

LAKHWAR DAM PROJECT: Why the project should not go ahead

April 22, 2013April 24, 2013 SANDRP8 Comments

PRESS STATEMENT ON WORLD EARTH DAY: APRIL 22, 2013

We the signatories to this statement would like to bring some key issues to the attention of all concerned on the proposed Lakhwar Dam Project on the Yamuna River in Upper Yamuna River Basin in Dehradun district of Uttarakhand state.

The proposed dam involves a massive 204 m high dam with storage capacity of 580 Million Cubic meters, submergence area of 1385.2 ha, including 868.08 ha forest land, at least 50 villages to be affected by submergence of land in the upstream, many more in the downstream area. This site is just about 120 km downstream of the river’s origins from the holy shrine of Yamunotri. The composite project involves, in addition to the Lakhwar dam with 300 MW underground power house, another 86 m high Vyasi dam with 2.7 km long tunnel and 120 MW underground power house and a barrage at Katapathar.

As can be seen from the details below:

a) The project has not undergone basic, credible environment or social appraisal in any participatory manner.

b) It does not have legally valid environment or forest clearance.

c) There has not been any cumulative impact assessment of various existing, under construction and planned dams and hydro-projects in the Yamuna system.

d) There has not been any credible assessment about options for the project.

e) The project is to come up in an area that is seismically active, prone to flash floods and also prone to erosion and land slides.

f) The spillway capacity of the project has been awfully underestimated resulting in significant risks of dam damage / breakage with concomitant risks of unprecedented downstream flooding and destruction. It may be mentioned here that Delhi is a major city standing in the path of the river in the downstream area.

g) The religious and spiritual importance of the Yamuna River is at risk since whatever remains of the river will be completely destroyed both in the upstream and downstream of the project.

h) No agreement exists among the Upper Yamuna basin states about sharing of costs and benefits of the project, which should be a pre-condition for taking up any such project.

i) It is well known that Yamuna River is already one of the most threatened rivers in the country and the project shall further adversely affect the river system.

Recently as well as earlier last year thousands of people from Allahabad/ Vrindavan marched to Delhi, seeking a revival of their river Yamuna. The focus of the authorities should be on ways and means to restore the river Yamuna system rather than take such massive project without even basic appraisal.

We thus urge the official agencies at both the state and at the centre level to not go ahead with this project. We urge them to rather take steps to protect and preserve than destroy one of the biggest and culturally important river, without even basic appraisal at project or basin level or any options assessment carried out in a due participatory manner.

We hope that the government will not go ahead with this project until all the issues mentioned have been satisfactorily resolved.

Endorsed by:

Ramaswamy Iyer, Former Union Water Resources Secretary, Delhi, ramaswamy.iyer@gmail.com

E.A.S. Sarma, Former Union Power Secretary, Vishakhapattanam, eassarma@gmail.com

Medha Patkar, Narmada Bachao Andolan, Badwani, nba.medha@gmail.com

Ashish Kothari, Kalpavriksh, Pune, chikikothari@gmail.com

Rajendra Singh, Tarun Bharat Sangh, Rajasthan, watermantbs@yahoo.com

Prof. MK Prasad, Kerala Sastra Sahitya Parishad, Cochin, prasadmkprasad@gmail.com

Bittu Sahgal, Editor, Sanctuary Asia, Mumbai bittusahgal@gmail.com

Prashant Bhushan, Senior Supreme Court Lawyer, Delhi, prashantbhush@gmail.com

Vandana Shiva, Navdanya, Delhi, vandana.shiva@gmail.com

10. Amit Bhaduri, Prof. Emeritus, JNU, Delhi, amit.bhaduri@gmail.com

Ravi Agarwal, Toxics Link, New Delhi, ravig64@gmail.com

Madhu Bhaduri, Former Indian Ambassador & member Yamuna Jiye Abhiyaan, Delhi, madhubhaduri@rediffmail.com

Prof S. Janakarajan, Madras Institute of Development Studies, Chennai, janak@mids.ac.in

Dr Dinesh Mishra, Barh Mukti Abhiyan, Bihar, dkmishra108@gmail.com

Sharad Lele, Centre for Environment and Development, Bangalore, sharad.lele@gmail.com

S. Faizi CBD Alliance, Kerala, s.faizi111@gmail.com

Rohit Prajapati, Paryavaran Suraksha Samiti, Gujarat, rohit.prajapati@gmail.com

Bharat Jhunjhunwala, Former Professor-IIM Bengaluru, Uttarakhand, bharatjj@gmail.com

Vimalbhai, Matu Jansangthan, Uttarakhand, matujansangthan@gmail.com

20. E Theophilus, Malika Virdi, Himal Prakriti, Uttarakhand, etheophilus@gmail.com

Ramnarayan K, Save the Rivers Campaign Uttarakhand, ramnarayan.k@gmail.com

Kalyani Menon-Sen, Feminist Learning Partnerships, Gurgaon, kmenonsen@gmail.com

Dr RK Ranjan, Citizens Concern for Dams and Development, Manipur ranjanrk50@gmail.com
Jiten Yumnam, Committee on Natural Resources Protection in Manipur, jitnyumnam@yahoo.co.in

Renuka Huidrom, Centre for Research and Advocacy, Manipur, mangangmacha@gmail.com

Shweta Narayan, The Other Media, Chennai, nopvcever.new@gmail.com

Wilfred Dcosta, Indian Social Action Forum – INSAF, New Delhi insafdelhi@gmail.com

Nidhi Agarwal, Activist, Community rights on environment, Delhi, nidhi.sibia@gmail.com

Rahul Banerjee, Dhas Gramin Vikas Kendra, Indore, rahul.indauri@gmail.com
30. Subhadra Khaperde, Kansari Nu Vadavno, Khargone, subhadra.khaperde@gmail.com
Shankar Tadwal, Khedut Mazdoor Chetna Sangath, Alirajpur, shankarkmcs@rediffmail.com

Michael Mazgaonkar, Gujarat, mozdam@gmail.com

Ranjan Panda, Convenor, Water Initiatives Odisha, ranjanpanda@gmail.com

M Gopakumar, Bangalore, gopakumar.rootcause@gmail.com

Janak Daftari, Jal Biradari, Mithi Nadi Sansad, Mumbai, daffy@jalsangrah.org

Shripad Dharmadhikary, Manthan Ahdyayan Kendra, Pune, manthan.shripad@gmail.com

Prof Rohan D’Souza, Jawaharlal Nehru University, Delhi, rohanxdsouza@gmail.com

Dr Brij Gopal, Jaipur, brij44@gmail.com

Alok Agarwal, Narmada Bachao Andolan & Jan Sangharsh Morch, Madhya Pradesh, aloknba@gmail.com

40. Debi Goenka, Conservation Action Trust, Mumbai, debi1@cat.org.in

Shardul Bajikar, Editor – Natural History, Saveus Wildlife India, Mumbai shardulbajikar@gmail.com

Sankar Ray, Kolkata, sankar.ray@gmail.com

Samir Mehta, International Rivers, Mumbai, samir@internationalrivers.org

V Rukmini Rao, Gramya Resource Centre for Women, Secunderabad, vrukminirao@yahoo.com

Dr. Latha Anantha, River Research Centre, Kerala, latha.anantha9@gmail.com

Mrs Anjali Damania, Aam Admi Party, Mumbai, anjalidamania@rediffmail.com

Manshi Asher, Him Dhara, Himachal Pradesh, manshi.asher@gmail.com

Commodore (rtd) Lokesh Batra, Social and RTI activist, NOIDA, batra_lokesh@yahoo.com

Arun Tiwari, Water activist, Delhi, amethiarun@gmail.com

50. Ananda Banerjee, Writer and member, Yamuna Jiye Abhiyaan, Delhi,

Sudha Mohan, Yamuna Jiye Abhiyaan, Delhi, sudhamohan@peaceinst.org

Dr Sitaram Taigor, Yamuna Jiye Abhiyaan, Madhya Pradesh, srtchambal@gmail.com

Bhim S Rawat, Yamuna Jiye Abhiyaan, Delhi, we4earth@gmail.com

Prasad Chacko, Social activist, Ahmedabad, prasad.chacko@gmail.com

Swathi Seshadri, EQUATIONS, Bangalore, swathi.s@equitabletourism.org

Parineeta Dandekar, SANDRP, Pune, parineeta.dandekar@gmail.com,

Manoj Mishra, Yamuna Jiye Abhiyaan, Delhi (09910153601, yamunajiye@gmail.com)

58. Himanshu Thakkar, South Asia Network on Dams, Rivers & People, 86-D, AD block, Shalimar Bagh, Delhi (09968242798, ht.sandrp@gmail.com)

Annexure

DETAILED NOTES

1. No Options Assessment There has been no assessment to show that this project is the best option available for the services that it is supposed to provide, including water supply to Delhi, irrigation in Uttarakhand, hydropower generation and water storage. It was not done during the process preceding the now out-dated environmental clearance given in 1986, nor has it been done subsequently.

It is well known that Delhi has much cheaper, environment friendly and local options that has not been explored with any sense of seriousness. These include reduction in transmission & distribution losses (which stand at 35%), rainwater harvesting (as National Green Tribunal order in April 2013 exposed, even the Delhi Metro is not doing this) including groundwater recharge, demand side management, stopping non essential water use, protection of local water bodies, protection of flood plains, streams and the ridge, recycle and reuse of treated sewage, among others.

As far as irrigation in Uttarakhand is concerned, in this relatively high rainfall area, and considering the local agro-geo-climatic situation and suitable cropping patterns, better options exist. Similarly about other claimed services.

It may be added here that the EIA manual of Union Ministry of Environment & Forests, the National Water Policy and best practices around the world including the recommendations of the World Commission on Dams, require such an options assessment study, including no project scenario, before embarking on such costly and risky projects.

2. No Basin wide cumulative impact assessment or basin study: Yamuna River is already in very bad situation in many senses, including being very polluted for lack of surface water flow. The river basin also has large number of projects existing and under construction, See: http://www.sandrp.in/basin_maps/Major_Hydro_Projects_in_Yamuna_Basin.pdf, for details. Particularly, see the concentration of projects in narrow upper Yamuna Basin. However, there has been no basin wide cumulative impact assessment of projects and water use in the basin in the context of its carrying capacity on various aspects. Without such an assessment, adding more projects may not only be unsustainable, it may actually be worse than zero sum game, since the new projects will have large number of adverse impacts. That we may have already crossed the basin carrying capacity upstream of Delhi seems evident from the worsening state of Yamuna over the past decades in spite of investment of thousands of crores rupees. Adding this project with its massive impacts without such an assessment may actually be an invitation to disaster.

We learn that a Yamuna basin study has been assigned to the Indian Council for Forestry Research and Education (Dehradun). However, it should be noted that in the first place, ICFRE has had poor track record. Its EIA study for the Renuka dam in the same Yamuna basin was so poor that it was based on the poor quality of the study that the National Green Tribunal stayed the work on the project for over a year now.

3. No valid environment clearance, no valid EIA-EMP or Public consultation process

The Composite Lakhwar Vyasi project got environment clearance 27 years back in 1986 without any comprehensive environment impact assessment (EIA) or preparation of environment management plan (EMP) or any participatory process. Some preliminary work started, continued only till 1992 and stopped thereafter for lack of funds.

a) In Sept 2007, the 120 MW Vyasi HEP, part of the original composite project, sought and got environment clearance although the minutes of the Expert Appraisal Committee of MoEF notes a number of unresolved issues. In Nov 2010 EAC meeting, the EAC considered the Lakhwar Dam for Env clearance, and raised a number of questions, none of them were ever resolved. The EAC did not consider the project in any meeting after Nov 2010.

This sequence of events makes it clear that Lakhwar Dam does not have valid environment clearance. The MoEF and project proponent assumption that the Environment Clearance (EC) of 1986 is valid is not correct, since if that EC was not valid for the Vyasi HEP which has sought and received fresh EC in Sept 2007, then how could Lakhwar HEP Dam of which Vyasi HEP is a part, continue to possess a valid EC.

Thus to give investment clearance to Lakhwar dam without valid EC will be imprudent, and might invite long drawn legal challenge to the project, resulting in more delays and in turn unnecessary cost escalations.

b) The project also does not have valid EIA-EMP. What ever assessments were done before the 1986 EC cannot be considered adequate or valid today. The environment standards and also environment situation has hugely changed in the intervening 27 years.

The project did not have any public consultation process in 1986 or anytime there after. Fresh EC will require that and the project must go through that process.

4. Issues raised by EAC remain unresolved: When the 43^rd meeting of EAC considered the project for EC on Nov 12-13, 2010, the minutes of the meeting raised a large number of questions, all of them remain unresolved. These issues are fundamental in nature. Without resolving these issues, the project should not go ahead.

Just to illustrate, EAC raised questions about the need and usefulness of various project components. It is clear from the EAC minutes that the project also involves construction of Katapathar barrage downstream from Vyasi Power House at Hatiari. However, just about 10 km downstream from this barrage there is an existing barrage at Dak Pathar. It is not clear why this Katapathar barrage is required, the EAC asked. None of these issues have been resolved.

5. Project does not have valid forest clearance: The composite Lakhwar Vyasi project requires a very large area of forest land, at 868.08 ha, the diversion was originally permitted for the UP irrigation Dept, which was then transferred to Uttaranchal Irrigation Dept upon creation of the separate Uttaranchal State. However, the project has now been transferred to Uttaranchal Jal Vidyut Nigam Limited. The Vyasi Project was earlier transferred to NHPC and now stands transferred to UJVNL.

In Aug 2012 FAC (Forest Advisory Committee is a statutory body under the Forest Conservation Act 1980) meeting, there was a proposal put forward to transfer the clearance for 99.93 ha (out of total forest land of Rs 868.08 ha for composite project) forest land required only for the Vyasi Project to UJVNL from Uttaranchal Irrigation Dept. While discussing this proposal, FAC noted that the Vyasi project was earlier transferred NHPC, without getting the forest clearance transferred in favour of NHPC. In fact FAC has recommended, “State Govt shall examine the reasons for not obtaining prior approval of the Central Govt under the Forest (Conservation) Act, 1980, for change of user agency from irrigation dept to NHPC and fix responsibility”. Secondly what is apparent from the minutes of the Aug 2012 FAC meeting is that even the Catchment Area Treatment Plan for the Vyasi project has not yet been prepared. This shocking state of lack of preparation of basic management plan is the consequence of allowing the project based on outdated clearances. The FAC has now asked the user agency to fulfil all such requirements, before which the project will not be given stage II forest clearance. So the Vyasi Project also so far does not have stage II forest clearance.

Most importantly, the transfer of forest clearance for the remaining 768.15 ha of forest land required for the Lakhwar project from Uttarakhnd irrigation dept to the current project agency UJVNL has not been even sought. So the Lakhwar project does not have valid forest clearance even for first stage, and surely no stage II forest clearance. Under the circumstances, the project does not have legal sanction.

6. Inadeaquate spillway capacity The project spillway capacity is proposed to be of 8000 cumecs, as per official website, see: http://india-wris.nrsc.gov.in/wrpinfo/index.php?title=Lakhwar_D00723. However, as per the latest estimates, the location is likely to experience probable Maximum Flood of 18000 cumecs. This is as per a paper titled “The probable maximum flood at the Ukai and Lakhwar dam sites in India” by P R Rakhecha and C Clark, presented in the year 2000 at an international Symposium. Dr Rakhecha later joined Govt of India’s Indian Institute of Tropical Meteorology in Pune. The paper concludes: “For the Lakhwar dam site there would be significant flow over the dam crest after 12 h from the start of the storm hydrograph and this would be maintained for over 18 h. The maximum depth of flow over the crest would be 4 m which is large enough to cause major if not catastrophic damage to the dam structure.”

Thus the spillway capacity of the project needs to be reviewed and it would not be prudent to go ahead without the same as the new PMF could cause major damage to the dam, the paper says. Any damage to this massive structure will have far reaching consequences all along the downstream area, right upto Delhi and downstream.

In fact even for the Vyasi HEP, while discussing the project in the EAC meeting of Aug 16, 2007, the minutes notes that the clarification sought by EAC on Dam Break Analysis for the project is incomplete, inadequate and far from satisfactory and the EAC desired further concurrence of Central Water Commission. In fact, EAC should not have recommended EC to the Vyasi Project with a flawed study. For the bigger Lakhwar project, there has not even been any such appraisal.

7. No agreement among Upper Yamuna basin states, Unresolved disputes The Lakhwar storage project is part of the Upper Yamuna basin. An interstate agreement was arrived at in 1994 for sharing of water in the Upper Yamuna basin among the basin states of Himachal Pradesh, Uttar Pradesh (now also Uttarakhand), Haryana, Delhi and Rajasthan. Each project under the agreement required separate agreements. However, there has been no agreement on sharing the costs and benefits of the individual projects under the agreement.

On Renuka project also in the same Upper Yamuna basin, there was an agreement that was arrived at in 1994, but the Ministry of Law has said that the agreement is no longer valid. For several years now the Upper Yamuna River Basin Board has been holding meetings, but has failed to arrive at any agreement for sharing the costs and benefits of Renuka dam. For Lakhwar dam there has been not been any serious attempt in that direction. The current project proposal envisages to provide 50% of water (about 165 MCM) to Delhi and 50% to Uttarakhand for irrigation (see: http://www.business-standard.com/article/companies/work-on-300-mw-lakhwar-project-to-begin-by-aug-112062200178_1.html dated June 22, 2012 includes statement from project proponent UJVNL (Uttarakhand Jal Vidyut Nigam Ltd) Chairman). However, this proposal completely ignores the claims of share from the project by Uttar Pradesh, Haryana, Rajasthan and Himachal Pradesh. To go ahead with the project without an inter state agreement on sharing costs and benefits would surely not be prudent.

8. Inadequate cost estimates As per estimate as on March 1996 the cost of the project is Rs 1446 crore out of which Rs 227 crore have been spent (see: official website http://uttarakhandirrigation.com/lakhwar_vyasi_project.html). Note that this cost was for the composite project, including Vyasi HEP. As per UJVNL official webstie http://www.uttarakhandjalvidyut.com/lakhwar.php, the cost of Lakhwar Project alone is Rs 4620.48 crore on Feb 2010. The same site gives the cost of Vyasi HEP at Rs 1010.89 crores, so the cost of combined project at Feb 2010 PL is Rs 5631.37 crores. The cost has thus seen 300% escalation in 14 years between 1996 and 2010. This is a very costly project and the cost is likely to be even higher at current prices. In any case, the estimate should be for current price level and the cost benefit calculations should also be for the latest date.

9. Seismically active area, erosion prone landscape: The project area is seismically active, flash flood, land slides, cloud bursts and erosion prone. In the context of changing climate, all these factors are likely to be further accentuated. When the project was first proposed in mid 1980s, none of these issues as also the issues of biodiversity conservation, need to conserve forests for local adaptation, forest rights compliance, environment flows etc were seen as relevant or important. However, all of these issues are important today. The project clearly needs to be reappraised keeping all these issues in mind.

Hydropower

Hydropower at the Cost of Drinking Water?

March 26, 2013April 1, 2013 SANDRPLeave a comment

Even as the state faces one of the most severe droughts in recent history, the irrigation department continues to divert water from the water-deficient Krishna valley to the water-surplus region of Konkan. Around 50 thousand million cubic feet of water (TMC) is annually diverted for three private hydro electricity plants in the Bhima sub-basin, which ultimately flows into the Konkan region.

While engineers of the water resources department claim that the diversion is necessary for production of hydro electricity, water experts say drinking water should be given more importance in a drought year.

Located in the upper Krishna Basin, Koyna Dam has the largest live water reservoir (2,836 TMC) in Maharashtra. The dam also houses five powerhouses with a total capacity of 1,956 MW. Of this, 1,920 MW installed capacity takes out water from the Krishna basin that flows into the water-surplus region and only the smallest 36 MW powerhouse at the dam toe allows the water to flow into the Krishna basin in Maharashtra. Krishna basin also houses some of the worst drought-hit areas of the state, such as the taluka of Maan and districts of Sangli and Solapur.

The diversions are taking place from the dams of Shirawantha, Walwhan, Lonavala, Kundli, Thokewadi and Bhira for the three privately operated hydro-electric projects. The total power generation capacity of these three plants is around 300 MW. However, the water so used in generation of hydro-electricity flows to the westward flowing rivers, which drain ultimately in Konkan.

As per the latest available storage position of the reservoirs, Koyna dam has a live storage of 68.78 TMC, while the dams catering to the private hydro-electric stations have a live storage of around 18.75 TMC of water.

This stock, say experts, can cater to the drinking water and domestic requirements of 7 crore people for an entire year.

Water expert and South Asia Network on Dams, Rivers and People (SANDRP) founder says post the usage in the privately owned dams, the water flows into the rivers of Vashisthi, Kundalika, Patalganga and Savitri, which flow via Konkan and drain into the Arabian Sea. “The rivers pass through chemical hubs and thus get polluted and become unsuitable for human consumption,” he says.

Making a strong case for stopping this diversion, Thakkar says the water, if not diverted, would be sufficient to meet the water needs of Sangli and Satara immediately. “In neighbouring Karnataka, the government has stopped five hydro power generation stations, to preserve the water for drinking purposes for Bangalore city. In Maharashtra, we need to initiate a dialogue and take a decision to stop the diversion in the worst drought year for the state,” he adds.

Engineers associated with the project, however, point out that the proposal, though feasible, can’t be executed for technical and other reasons. To start with, they say, since the canal distribution system to carry water downstream is not ready, and due to the gradient difference, lifting water would be difficult.

D N Modak, chief engineer of the Koyna project, says it is the power generated from these projects that is required for the state. “There is sufficient water available in the Koyna dam,” he claims.

Hydropower · Ministry of Environment and Forests

Central Water Commission’s Dam Register: How much do we know about our dams and rivers?

March 14, 2013April 1, 2013 SANDRP2 Comments

Central Water Commission is India’s technical organisation under the Union Ministry of Water Resources. It publishes National Register of Large Dams (NRLD), the latest version can be seen at: http://www.cwc.nic.in/main/downloads/New%20NRLD.pdf. This is a key document that provides information about large dams in India.

The latest NRLD seems to have been uploaded only this month, since for a number of states, it claims to have been updated till January 2013. The NRLD is certainly a useful document, the only list of large dams in India and it also gives a number of salient features of the large dams in India. SANDRP has been using this document and also been doing some analysis of the information available in the NRLD.

As per the latest edition, India has 5187 large dams (height above 15 m in most cases, height of 10-15 m case of some with additional criteria). 371 of these dams are under construction and rest have been completed. In case of 194 large dams in NRLD, we do not know the year of construction, which means most of such dams must have been built before independence.

NRLD is not an exhaustive list

NRLD follows the definition of large dams given by the International Commission on Large Dams for inclusion of dams in the NRLD. However, the NRLD is far from exhaustive list of large dams in India. Very significant number of large dams built for hydropower projects in Himachal Pradesh, Uttarakhand, North East India, among other states, do not figure in the list, even though all of these would come under the definition of large dams as given in the NRLD. To illustrate from Himachal Pradesh, following dams are all under construction as per Central Electricity Authority, many of them in advance stages, but they do not figure in NRLD: Allain Duhangan, Kashang, Sainj, Swara Kuddu, Shongtong Karcham, Sorang, Tangnu Romai, Tidong. It’s a dangerous situation for safety issues, since many of them are under construction by private companies. For example, in December 2012 heavy leakage was detected in the surge shaft of the 1000 MW Karcham Wangtoo Project on Sutlej River in Kinnaur district in Himachal Pradesh. The project had to be shut down and the repairs are still going on. Had there been a serious mishap at the project the impact would be also felt by the cascade of projects downstream, including the 1500 MW Nathpa Jakhri HEP (India’s largest operating hydropower project), 412 MW Rampur HEP, 800 MW Kol Dam HEP and the Bhakra complex further downstream.

The case of missing dams

Earlier in 2010 and 2011 we filed a number of applications with the CWC under the Right to Information Act to ask them how a very large number of dams that were listed in earlier NRLD of 1990, 2002 (both printed versions) did not figure in the NRLD 2009 and many of the large dams listed in 1990 also did not figure in NRLD 2002. The CWC response in most cases was to transfer our RTI application to the relevant states, stating that CWC is not responsible for the information in the NRLD, it only compiles the information given by the respective states.

This was far from satisfactory response from India’s premier technical water resources organisation. Was CWC acting only as a post box on even such a serious issue of listing of large dams? It was not applying its mind to the information supplied by the states, not raising any questions, nor clarifying the contradictions and gaps with respect to the earlier editions of NRLD? Needless to add, this reflects very poorly on the CWC. Here it should be added that CWC is also responsible for the monitoring policies and practices related to the safety of dams in India as also a number of other aspects. What kind of diligence can we expect from CWC under these circumstances? Our analysis then also showed that many dams that should have figured in the earlier versions (considering the date of completion stated in the subsequent editions of NRLD) were not there. Again our RTI applications in such cases were transferred to respective states. We did get some response from Central Water Commission and Maharashtra, which was far from satisfactory. In case of over a hundred dams, the CWC Director, Design and Research Coordination Directorate accepted the errors in NRLD and promised that “Data entry errors/ omissions as indicated above will be rectified”.

Where are our dams located?

A quick review of the latest NRLD raises some fresh questions of the NRLD. In this exercise we just wanted to check how many dams are there in different river basins/ sub basins. This is an important question from a number of perspectives including cumulative impacts, optimisation of dam operations, hydrological carrying capacity and cumulative dam safety issues, to name a few. We through this would be simple enough exercise. But when we started looking at the 5187 large dams of India listed in NRLD, we found that in most cases, there is no name for the river on which the dam is constructed. When counted, we were shocked that in case of 2687 or 51.8% of large dams of India, the NRLD does not mention the name of the river. In most cases they just write “local river” or “local Nallah” or the box under river is left blank. Under the circumstances, it is not possible to get a clear picture of any river basin, nor about the cumulative impacts or safety aspects or possibility of optimisation of the dams in any one river basin. The absence of such basic information reflects very poorly on the quality of NRLD, and on the CWC and respective states.

Worst states

India’s largest dam builder state, namely Maharashtra, has the largest number of dams for which it does not know the name or location of the rivers or tributaries. Out of 1845 large dams in Maharashtra, in case of 1243 dams, Maharashtra does not know the name of the rivers! That means in case of 67.37% of its dams, Maharashtra does not even know the names of the rivers. It is not just for the old dams, but even for 81 of the dams completed after 2000, Maharashtra does not know the names of the rivers. Even for relatively larger 61.19 m high Berdewadi dam (completed in 2001) and 48 m high Tarandale dam (completed in 2007), the names of the rivers are now known.

Madhya Pradesh is worse than Maharashtra, it does not know the names of the rivers for 90.17% of its dams (817 dams out of total of 906). In percentage terms, Chhattisgarh is worst as it does not know names of the rivers for 227 of its 259 large dams. These three states of Maharashtra, Madhya Pradesh and Chhattisgarh collectively do not know the names of the rivers for 2287 of dams in NRLD. Some of the other states that should also share the “honours” here are Gujarat (138 dams out of 666 for which names of rivers are not known), Andhra Pradesh (124 out of total of 337) and Rajasthan (71 out of 211 large dams).

It is a disturbing situation that the agencies that are responsible for our large dams do not even know the names of the rivers (every river in India has a name, so if someone were to argue that the rivers do not have names, it won’t be acceptable excuse) on which they are located. Without the names of the rivers and locations of the various dams on specific rivers, we cannot even start looking at the crucial issues like dam safety, cumulative social and environmental impacts, hydrological carrying capacity and optimum utilisation of the storages created behind the dams. We clearly have far to go to even start knowing our dams and rivers.

Himanshu Thakkar (ht.sandrp@gmail.com)

South Asia Network on Dams, Rivers & People (www.sandrp.in, an edited version of this published at: http://indiatogether.org/2013/mar/env-dams.htm)