Arunachal Pradesh · Assam · brahmaputra

Is government at all serious in addressing the issues raised by Movement against the Lower Subansiri Hydropower Project?

Minutes of Government of India meeting on Lower Subansiri HEP in Dec 2014 rejected by movement:

Shoddy Cumulative impact assessments, lack of public consultations won’t help

Map of Subansiri RIver Basin  Source: https://sandrp.in/basin_maps/Subansiri_River_Basin.pdf
Map of Subansiri RIver Basin
Source: https://sandrp.in/basin_maps/Subansiri_River_Basin.pdf

Continue reading “Is government at all serious in addressing the issues raised by Movement against the Lower Subansiri Hydropower Project?”

Arunachal Pradesh · Environment Impact Assessment · Expert Appraisal Committee

Submerged – what to expect if the Dibang river is dammed

Guest Blog by: : Karthik Teegalapalli (kartix@gmail.com) a researcher with the Nature Conservation Foundation

In April 2014, the Forest Advisory Committee (FAC) decided to deny clearance to the 3000 MW Dibang Multipurpose Hydro-electric Project, the largest capacity hydro project in the country proposed to be developed by the National Hydropower Power Corporation (NHPC) in the biodiversity-rich Arunachal Pradesh State (Saikia 2014). The project was also denied clearance in July 2013. More recently though, the project has been recommended forest clearance by the FAC and Environment Clearance by the Expert Appraisal Committee. Therefore it is pertinent to look at the impacts the project may have in some detail.

Ecological impacts The project, in its earlier version involved diversion of more than 5000 hectares of relatively undisturbed grassland and tropical forest habitat. These and the adjoining forests harbour endangered species such as tiger, leopard, serow as well as the critically endangered takin, all of which are protected under Schedule I of the Wildlife (Protection) Act, 1972 (these species are also listed as present in the area in the Environmental Impact Assessment report of the project, undertaken by National Productivity Council, Guwahati). The grasslands in the area harbour the critically endangered Bengal Florican, a grassland habitat specialist (Sinha et al. 2014). Other species recorded from the area include the critically endangered white-rumped vulture, the slender-billed vulture and the white-winged wood duck. The project site lies in an area identified by the Bombay Natural History Society as a Ramsar site and an Important Bird Area (Islam & Rahmani 2004). The habitat of six endangered plants (Aconitum ferox, Coelogyne mossiae, Dendrobium aurantiacum, Paphiopedilum fairieanum, Paphiopedilum venustum and Vanda coerulea) will be submerged by the reservoir (Chernaik 2007).

The project will also affect aquatic species; the dam will block the breeding migration of four species of fish: the Vulnerable snow trout Schizothorax richardsonii, Endangered golden mahseer Tor putitora, Near-Threatened mahseer Tor tor, and chaguni Chagunius chagunio. The recommendation of the Environmental Management Plan of the Project to establish fish hatcheries for these species is impractical and can have further damaging effects on the species due to collection of eggs and spawn from the wild population.

The project will have other collateral damages such as through Compensatory Afforestation (CA) that often involves converting an area with diverse native species into monocultures, as has been shown for other dams such as the Sardar Sarovar Dam on the Narmada river (Bhatnagar 2004). The project involves CA of a relatively large area of over 100 sq. km (double the area of forest being affected by the project). The ill-effects of this conversion particularly for the project can be expected to be higher if tree-less natural grassland habitats in Dibang Forest Division, Namsai Forest Division and Anini Social Forestry that harbour grassland habitat specialists are planted with undesired native or non-native tree species. Perhaps the irreversible loss of biodiversity in the forests and grasslands that will be diverted for the project could never be ‘compensated’.

During the construction phase of the project, an estimated 32 lakh truckloads of boulders and 16 lakh truckloads of sand is to be extracted from the Dibang river basin. Unsustainable extraction of sand and boulders has significant negative effects on geomorphology, bank stability, flood character of the river, water quality, river flow, and the biodiversity in the river basin (Padmalal et al. 2008). The project during the construction is to generate 198 lakh cubic meters of muck which will be disposed in the river bank which will cause further loss of 120 ha of river habitat. Construction of new roads (64 km) and widening of existing roads (19.5 km) will also lead to removal of trees and increase the vulnerability of the region to landslides and erosion (Chernaik 2007).

Social impacts The Lower Dibang valley is currently a region of relatively low human population density (~14/km2); the entire population of the Idu-Mishmi tribe is about 12,000. The influx of approximately 6,000 project staff (which is very likely an underestimate) for a period of 8 years or more will affect their way of life, their culture and their tradition as well as open up access to relatively moderately disturbed habitat and biodiversity in the region.

Downstream effects include those on fisheries, agricultural lands and wetlands (beels) and the dam will also increase the vulnerability of the region to flash floods. For instance, in the year 2007, flash floods caused due to sudden release of water from the relatively smaller 405 MW Ranganadi project in the Lower Subansiri district in Arunachal Pradesh swamped 83 villages and caused huge loss of lives and property in the Assam State. The project will have a considerable impact on the Dibru-Saikhowa National Park in Assam which has not been studied in detail in the EIA.

On shaky grounds A critical issue with the project is that the site lies close to an active Fault Line in the Mishmi Thrust of the Mayudia Group in Eastern Arunachal Pradesh with a history of several seismic activities including the Great Assam earthquake of 8.6 magnitude in 1950 (Figure 1, Misra 2009). In the event of an earthquake, the project poses a risk of catastrophic submergence of several villages and vast areas of forests downstream. The recommendations of the Environmental Impact Assessment (EIA) report of the project are cursory and suggest further research on the natural seismicity of the region as well as reservoir-induced seismicity, which should be the basis for the decision about the project.

Figure 1 (reproduced from Misra, 2009) showing the location of the fault lines around the proposed project site. 1 is the location of the Fault line and 2 is the location of the proposed site.
Figure 1 (Modified from Misra, 2009) showing the location of the fault lines around the proposed project site. 1 is the location of the Fault line and 2 is the location of the proposed site.

Notwithstanding these, in Oct 2014 the project was cleared by the FAC constituted by the new Government, although the committee still had four of the six members who had earlier twice recommended rejection of clearance. Is this decision driven by changes made by NHPC in their project plan? Clearly not. Diversion of forests has now been reduced by a mere 9% to about 4600 hectares; instead of 3.55 lakh trees, the felling has been reduced to 3.24 lakh trees, the power generation capacity has been reduced by 2.3% and the height of the proposed dam reduced by 10 m. In fact, the FAC rejection of April 2014 was for this 10 m rejection proposal!

The beautiful Dibang valley, that faces the threat of submergence due to the Dibang Multipurpose Project (Photography by Soumya Dasgupta).
The beautiful Dibang valley, that faces the threat of submergence due to the Dibang Multipurpose Project (Photography by Soumya Dasgupta).

NHPC misleadingly and baselessly claimed that they ‘were not in a position to reduce the height of the dam any further, as it would significantly affect the power generation’. The decision to provide clearance to the project seems like a hasty one driven by the blinders of development and the consequences of such projects is evident from the fate of the Lower Subansiri Hydropower Project in the same State, also by NHPC. After 12 years since the LSHP was initiated and after an expenditure of over Rs. 5000 crores, the work has been on a standstill for the last 35 months as a result of India’s biggest anti-dam people’s movement (Dandekar & Thakkar 2014). Considering the economic, ecological, environmental and social costs of the project as well as the geophysical risk it poses, it would be prudent to withdraw the project till a credible, detailed cumulative study covering these aspects is undertaken in a transparent and participatory way. While the rest of the world is recognising the ill-effects of dams, with the largest dam removal project on the Elwha river in the United States completed just three months back, it is paradoxical that we are heading in the other direction; of building the highest dam in the country and largest capacity reservoir of the North East India without even basic studies, credible impact assessment and democratic decision making process.

References:

Bhatnagar, D. (2004) Uprooting Forests, Planting Trees: Success of Compensatory Afforestation Measures Mitigating the Deforestation for the Sardar Sarovar Dam, India. University of California at Berkeley.

Chernaik, M. (2007) Evaluation of the Environmental Impact Assessment Report & Environmental Management Plan for the Dibang Multipurpose Project (3000 MW) https://www.elaw.org/system/files/Evaluation+of+the+EIA+report+for+the+proposed+Dibang+dam.doc

Dandekar, P. & Thakkar, H. (2014). Manipulating Environment & Forest Clearances for Dibang Project: Déjà vu: LSHP History repeated: Will it be tragedy or comedy https://sandrp.wordpress.com/2014/10/06/manipulating-environment-forest-clearances-for-dibang-project-deja-vu-lshp-history-repeated-will-it-be-tragedy-or-comedy/

Islam, M. Z. & Rahmani, A. R. (2004) Important bird areas in India: priority sites for conservation. Indian Bird Conservation Network, Bombay Natural History Society and BirdLife International (UK).

Misra, D. K. (2009) Litho-tectonic sequence and their regional correlation along the Lohit and Dibang Valleys, Eastern Arunachal Pradesh. Journal of the Geological Society of India, 73: 213-219.

Padmalal, D., Maya, K., Sreebha, S. & Sreeja, R. (2008) Environmental effects of river sand mining: a case from the river catchments of Vembanad lake, Southwest coast of India. Environmental Geology, 54(4): 879-889.

Saikia, P. J. (2014). Six years after PM laying the foundation ston: No clearance, no work for 3000 MW Dibang Dam.

https://sandrp.wordpress.com/2014/01/31/six-years-after-pm-laying-foundation-stone-no-clearance-no-work-for-3000-mw-dibang-dam/

Sinha, A., Hoque, J., Pradhan, T., Bakshi, M. K., Pulu, J., Singh, A. K. & Ahmed, F. (2012) Sighting record of Bengal Florican Houbaropsis bengalensis (Gmelin, 1789) (Aves: Gruiformes: Otididae) in Lower Dibang Valley District, Arunachal Pradesh, India. Journal of Threatened Taxa, 4(14): 3375-3376.

Also see:
https://sandrp.wordpress.com/2014/10/23/insensitivity-analysis-of-dibang-multipurpose-project-fac-recommends-dibang-at-10-mt-height-reduction-will-destroy-4577-hectares-forest/

https://sandrp.wordpress.com/2014/05/17/dibang-project-rejected-forest-clearance-for-the-second-time/

Arunachal Pradesh · Environment Impact Assessment · Expert Appraisal Committee · Forest Advisory Committee · Himalayas

Dibang Insensitivity Analysis : FAC recommendation can destroy 4577 ha rich Forests

Reaching exasperating lows of environment decision making, the Forest Advisory Committee (FAC is a statutory body of the Ministry of Environment Forests and Climate Change (MoEFCC) formed under the Forest Conservation Act of 1980. FAC appraises Forest diversion proposals) has recommended Forest Clearance to the 3000 MW Dibang Project on Dibang river in Arunachal Pradesh.

While we had already written against this recommendation, what is nearly unbelievable is that this recommendation has come at just 10 meters height reduction of the dam from the proposed 288 meters.

This was the very same NHPC proposal which was rejected twice by the FAC in the past,[1] despite this token 10 meter height reduction. In fact in April 2014, the FAC said that 10 mt reduction does not take care of any pertinent impacts for which the proposal was rejected in the first place in July 2013! A 10 m reduction would still mean destruction of 3.24 lakh trees and submergence of 4577.84 hectares, nearly 12000 acres, of rich bio-diverse forest.

Dibang River Photo with thanks from Global Post, Scot Ligare
Dibang River.  Photo with thanks from Global Post, Scot Ligare

The usually reticent MoEFCC (Ministry of Environment, Forests and Climate Change, MoEF earlier) too had issued a strong-worded rejection to this scheme in August 2014, stating that 10 meters reduction is nothing in the face of what is being lost. The rejection letter stated: “Such a marginal reduction in requirement of the forest land (445 hectares reduction, reducing forest requirement from 5056 hectares to 4577 hectares) for the project may not be able to reduce the adverse impact of project on such a biodiversity-rich mature forest ecosystem to the extent which could make the project environmentally as well as socio-economically viable in forest dependent tribal society of Arunachal Pradesh”.

This letter from the same ministry certified that the 10 m reduction proposal still leaves the project environmentally, socio-economically unviable. So an environmentally and socio-economically unviable project has been recommended clearance by the statutory FAC (and also the separate recommendation a week earlier by the same MEFCC’s Expert Appraisal Committee on River Valley Projects)!

This shows that the decision of FAC is devoid of merits, will invite huge opposition from Arunachal Pradesh, Downstream Assam, North East India, and even beyond and will not pass legal scrutiny. The decision seems to have been taken under pressure from the political masters. Union Power Minister Piyush Goyal has been dreaming of clearance to this project, as is clear from his road map published on completion of 100 days of office for the new NDA government[2]. He has also been pressurizing the MoEFCC to clear the project by hook or by crook. The FAC was reconstituted and the reconstituted FAC has obliged the minister in its very first meeting. In the process, the entire FAC has violated its mandate and should be held accountable for this.

Regrettably, MoEFCC seems to have become the willing punching bag of not only above-mentioned ministries, but even unrelated ministries like Ministry of Mines and Minerals, Ministry of Steel ,etc., whose ministers and Secretaries were present for the meeting: “to Expedite Clearances”. (Incidentally, when was the last time we heard MEFCC resisting such arm-twisting, or forthrightly suggesting any pro-environment measures to other ministries?)

Before the minutes of the September FAC meeting were out on Oct 22, 2014 (there was an inordinate delay this time, raising suspicion of negotiated minutes and again breaking all norms of conduct), there was discussion in media that Dibang was cleared, but even the hard-core skeptics believed that this recommendation must have come after a 20 meter or 40 meter height reduction, for obvious reasons.

But the FAC seems to have outdone itself. As stated above, the recommendation has come at 10 mts height decrease, for which the FAC had rejected the project and MoEF had issued a rejection letter in the past.

As we discussed in detail in our last blog on Dibang project, the twice-rejected project was up for discussions again in Sept 2014 only after considerable arm-twisting of the MEFCC by the Cabinet Committee of Investment, Ministry of Power, Project Developer NHPC and Arunachal State Government. This time it was for a supposed sensitivity analysis (done by the developer!) for studying the feasibility of reducing the height of the project upto 40 meters from its original height of 288 meters.

This sensitivity analysis was not shared with anyone, not even the FAC members till the day of the FAC meeting, breaking all codes of conduct of transparency, participation and informed decision making in governance. SANDRP wrote about this to the Minister and Secretary of MoEFCC as well as the Member of the FAC, but received no response.

Looking at the minutes, it is clear that the FAC members have lapped up the logic presented by the developer and the Ministry of Power which in a nutshell says that “10 meters reduction is sufficient as the ratio of forest land required per MW is lowest at 10 meters reduction.” This twisted logic reduces all decision making related to forests, even biodiversity-rich forests supporting endemic, unstudied species, local protests, downstream impacts etc., to mere number crunching of forest per MW. This criteria alone cannot  be the basis for decision for forest appraisal committee.

Dibang Valley Forests Photo: The Telegraph
Dibang Valley Forests Photo: The Telegraph

As per the sensitivity analysis by NHPC, the ratio forest land required per MW for 40 meters reduction is 1.67 MW/ hectare, which is same as no height reduction and 1.78 MW/ hectare in case of 20 meter reduction. In terms of tariff, for 40 meters reduction, the power tariff will be 6.24 Rs./unit while it is 5.66 Rs/unit 10 meters reduction, 5.94 Rs./unit 20 meters reduction and 5.64 Rs. at zero reduction. The installed capacity will reduce by 120 MW (4%) MW for 10 meters reduction, 600 MW (20%) for 20 mt reduction and 780 MW (26%) for a 40 meter reduction.

Height Reduction Forest land required MW capacity per ha Forest lost First Year Tariff: Rs per unit Reduction in installed capacity
Nil (288 m) 5056 Ha 1.67 5.64 None
10 m 4578 Ha 1.59 5.66 120 (2880 MW)
20 m 4284 Ha 1.78 5.94 600 (2400 MW)
40 m 3703 Ha 1.67 6.24 780 (2200 MW)

The proponent said: “Decrease in dam height and consequent sacrifice of power generation beyond 10 mt is not commensurate with saving forest land.”

How did NHPC reach this conclusion? What is the value of the mature, old growth forest land considered by NHPC? Without knowing this, how can this conclusion be acceptable to the FAC? It has to be remembered that Dibang is not an exclusive hydropower project, but a multipurpose project with a flood moderation component and costs have to be borne for this.

While the proponent and Ministry of Power did their best for pushing the project, the FAC did not do its duty of stating that the sensitivity analysis put forth by NHPC is a sham as it does not consider the worth of the forest being lost.

In this sabji-mandi haggling, when FAC had all the watertight justifications for rejecting the project, it did not bat for even a 40 meter reduction, which could have saved nearly 1355 hectares of forests and would have had a marginal impact on other factors. Its unclear why this happened.

Only one of the FAC members tried to battle the case saying that 10-40 meter reduction still does not address the upstream and downstream impacts, especially considering the biodiversity rich area. The minutes do not disclose the name of this member, but it seems the brute majority (majority of FAC members are govt officials) took the official line, alleging “subjectivity” and said that “To reduce subjectivity, it is important to analyse the issue objectively on objective parameters”. Forgetting that this is Forest Appraisal committee, not Power Developer Committee.

This is ironical. It was indeed the duty of the FAC to appraise the project “objectively” based on issues like destruction of 3.24 lakh trees, invaluable forests, unstudied biodiversity, rich wildlife and several Schedule I species, community dependence, traditional rights, downstream impacts, climate change impacts, options assessment, etc. But it did nothing of that and has in fact recommended the project “subjectively”, bowing to pressures outside their ambit.

Clearly, per MW forest land required and per Unit Tariff from a project are anything but objective criteria for FAC. FAC is supposed to apply its mind to a number of issues like the ones above.  If FAC was not supposed to apply its mind to these aspects and its judgment, there was no need for an FAC, Power ministry and developer could have taken the decision independently.

The FAC decision does not address any pertinent issues raised by the same FAC while rejecting the project, it also does not address downstream impacts on Assam or assume any value for a rich forest. There is no discussion why 20 meters or 40 meters reduction is not seriously considered by FAC. Decision-making based on such biased, proponent-driven criteria is bound to be open to legal challenge and public protests.

Sham consideration of Downstream Impacts About Impact of the project on Dibru-Saikhowa National Park, the User Agency said that the issue was considered by EAC in its meeting on the 16th September (Please note this is just 6 days and 5 working days back from FAC meeting. There is no chance of minutes being firmed up by then. They were not in open domain in any case) and the EAC has recommended clearance based on the fact that there is less than 1 meter level fluctuation at DSNP.

This claim in any case is patently incorrect, again a case of project-friendly, anti-environment decision-making. The level fluctuation at DSNP can go way higher than a meter, anywhere from 7-8 feet every day in lean season, according to the studies considered by the EAC of the MEFCC itself. This has been pointed out by SANDRP to the EAC as well. There has been no study of the impacts of this project on downstream Arunachal Pradesh or Assam. The developer seems to assume that Dibru-Saikhowa is the only part of Assam worth considering.

Dibang Valley tribes Photo from go ibibo/dibangvalley
Dibang Valley tribes Photo from go ibibo/dibangvalley

There is no compliance under Forest Rights Act (2006) for such a massive project and despite this, FAC under some supposedly progressive members working on tribal issues, does not bat an eyelid before recommending clearance!

To conclude, pricing mature, biodiversity-rich forests in terms of per MW terms is an insult of those forests, the communities that depend on them and to the mandate of  FAC. Downstream impacts of Dibang project are not studied, the impacts on Dibru-Saikhowa are based on compromised studies.

There is no merit in this decision from the newly appointed FAC which includes members also from reputed environment protection organizations in North East and from Tribal Welfare groups like Friends of Baripada. It is also sad to see that there is no dissenting note from a single member. The unnamed member who expressed dissent in the meeting has not written anything about this in public domain.

Decisions like Dibang lay further foundations for poor, pro-developer, anti-people, anti-environment decisions taken due to pressure from proponent and other ministries. Such decisions will not be legally tenable, nor acceptable to affected communities, nor good for sustainability and equity. In fact, by such reversals, FAC decisions are losing their sanctity. FAC has done this in the past too in case of Kalu Dam in Western Ghats which would submerge 18 villages and 1000 hectares forest.

Isn’t it ironical that the new government changed the name of the MoEF to MoEFCC but is sanctioning massive projects like Dibang which will have far reaching impacts on Climate Change as well as adaption and mitigation abilities of the affected communities? Without even considering these aspects or even mentioning them?

Parineeta Dandekar, parineeta.dandekar@gmail.com

[1] For details see: https://sandrp.wordpress.com/2014/10/06/manipulating-environment-forest-clearances-for-dibang-project-deja-vu-lshp-history-repeated-will-it-be-tragedy-or-comedy/, https://sandrp.wordpress.com/2014/05/17/dibang-project-rejected-forest-clearance-for-the-second-time/

[2] http://www.piyushgoyal.in/uploadedfiles/views/ministry_english_booklet.pdf

[3] http://www.theguardian.com/environment/india-untamed/2014/oct/22/indias-largest-dam-given-clearance-but-still-faces-flood-of-opposition

[4] https://sandrp.wordpress.com/2013/04/25/kalu-dam-in-western-ghats-fac-goes-back-on-its-word-without-any-justification/

Arunachal Pradesh · Environment Impact Assessment · Expert Appraisal Committee · Forest Advisory Committee · Himalayas · Hydropower

Manipulating Environment & Forest Clearances for Dibang Project: Déjà vu: LSHP History repeated: Will it be tragedy or comedy?

Dibang River (Source - EMP)
Dibang River (Source – EMP)

Every possible violation of norms, procedures, law and democratic governance is being committed in pushing clearances for the India’s largest capacity hydropower project, which involves India’s highest dam proposed so far & North East India’s Largest capacity reservoir: the 3000 MW Dibang Multi Purpose Project in Arunachal Pradesh. The players involved in these violations include the Union government of NDA led by BJP (UPA earlier), including its cabinet and Union Ministry of Environment, Forests and Climate Change (MEFCC), Ministry of Power, State government, the project developer company NHPC Ltd, the Expert Appraisal Committee (EAC) and Forest Advisory Committee (FAC).

The project will need more than 4700 hectares of biodiversity rich Forest area with several Schedule I species in Arunachal Pradesh. It will also have significant downstream impacts on the people & environment of Arunachal and Assam and Dibru Saikhowa National Park. Most of its impacts have not been either properly assessed or considered by the developer, EIA agency or the EAC & MEFCC.

Déjà vu: We did the same for Lower Subansiri HEP! It seems the government is indulging in the same blunders that the previous NDA government[1] indulged in over a decade ago while clearing the then-largest capacity hydropower project: the 2000 MW Lower Subansiri Hydropower Project (LSHP), also in Arunachal Pradesh. Environment clearance for LSHP came on July 16, 2003 and stage I forest clearance came on June 10, 2003. Exactly the same set of players were involved in manipulating LSHP clearances over a decade ago. The developer is also the same: NHPC. The government at centre is again led by NDA.

Aaranyak environmental group of Assam, in a letter dated May 16, 2002 to the then-Chief Justice of India had highlighted the violations involved at various stages in the decision making of LSHP including during public hearings, in conducting EIA, in giving environment, forests and wildlife clearances. Almost all the issues that Aranayak letter raised then are applicable in case of Dibang with even greater force. But it seems in the twelve years since 2002 when that letter was written, our environmental governance has only degenerated.

The fate of the LSHP is a lesson in itself. After spending over Rs 5000 crores (Rs 50 Billion), the work on the project came to a standstill in December 2011. It has remained stalled for 34 months since then, following India’s biggest Anti dam People’s movement so far. This is unprecedented in India’s hydropower history. NHPC Ltd has been trying every possible trick to resume the construction work on LSHP, without genuinely trying to address the issues people’s movement has been raising.

Dr Mite Linggi, Representative of Kere A Initiative for Cultural and Ecological Security said exactly that at the public hearing of Dibang Project on March 13, 2013: “It is evident that the 2000 MW Lower Subansiri Project is stalled since Dec 2011 because the technical, environmental and social concerns of the people of Assam were not considered earlier… Ignoring downstream concerns will only ensure that this project to will meet the same fate as Subansiri Lower Project (2000 MW and get stalled by people of Assam.”

It seems none of the players have learnt any lessons from the blunders committed in LSHP’s decision making. If this is how Dibang Project is being pushed down the throat of the people of Dibang Valley, Arunachal Pradesh and the North East India, they will have no option but to oppose the project and the Dibang Project may have the same fate as that of LSHP. Those who have been involved in the decision making now will then be held accountable for the wrong decisions and manipulations.

Dam site and the Dibang River Basin (Source - EMP)
Dam site and the Dibang River Basin (Source – EMP)

THE DIBANG PROJECT

The foundation stone of 3000 MW Dibang Multipurpose Project on Dibang River was laid on 31st January 2008, by Prime Minister Manmohan Singh[2] when the project had no clearances, showing utter disregard the former PM had for statutory clearances or environment or affected people. The project affects Lower Dibang Valley and Dibang Valley districts of Arunachal Pradesh, and significantly, several districts in downstream Assam.

Considering the fact that Dibang has the largest installed capacity for a project in India, involving highest dam in India and biggest reservoir in North East India so far, one expected the EAC to be much more diligent while considering the project and even more so considering the experience of the LSHP. But that, it seems, was expecting too much.

The first thing that would strike any one who goes through the EAC and FAC documents is that the basic parameters of the project are yet unclear even as the EAC and FAC have recommended clearances, within the span of a week, under pressure from their political masters. Unbelievably, these two committees functioning under the same Ministry have recommended clearance for differing capacities, differing heights, differing submergence areas and so on!

This is because the NHPC knowingly misled the EAC in its meetings by presenting the 288 m height (above the deepest foundation level) dam with 545 m elevation at Full Reservoir Level (FRL) and 3.75 Billion Cubic Meters (BCM) of storage capacity at FRL. The same NHPC, in FAC meeting on Sept 22, 2014 provided sensitive analysis with dam height reduced upto 40 m, but this was not even mentioned before the EAC!

Let us review the how the EAC and FAC dealt with the project.

A. ENVIRONMENTAL CLEARNACE FOR THE DIBANG PROJECT:

The Expert Appraisal Committee (EAC) of the MoEF, which holds the distinction of having a zero rejection rate for the projects it appraises, recommended Environment Clearance to 3000 MW Dibang Multipurpose Project in its 77th meeting on 16th Sept, 2014.

The Project was given TOR (Terms of Refence) clearance on 17.8.2009. Public hearings in Lower Dibang and Dibang Valley districts were held on 11.3.2013 and 13.3.2013 respectively, with huge protests from affected people. The EAC earlier considered the project in 68th meeting in Sept 2013, in 73rd meeting in March 2014, in 74th meeting in May 2014 and now in 77th meeting in Sept 2014.

Some key questions that arise as to how the EAC arrived at the positive recommendation:

1. Was there any Public Hearing in downstream Assam? Was there proper public hearing in Aruunachal Pradesh?

Although Dibang Multipurpose project will have impacts in the downstream Assam, as accepted by NHPC Ltd, WAPCOS and recorded in EAC minutes, no public hearing has been conducted in Assam, in complete violation of the EIA notification which clearly states that in all affected districts public hearings must be held. The submissions from Assam were not discussed during EAC minutes. The people of Assam have been completely ignored in the decision-making about a project that will affect them. Several people who spoke at the Dibang Public Hearing in Arunachal Pradesh in March 2013 raised this issue, but MEFCC and EAC failed to do anything about this even after SANDRP submissions to EAC also raised this issue.

Even in Arunachal, the public hearing process has seen several violations, leading people to oppose the project and the public hearings, see the quotes from the public hearings given below. Consequently, the public hearings were disrupted by the local people and had to be cancelled several times. The MEFCC, unfortunately, has no concern for the quality of the whole consultation process and sees it as only a box to be tick marked. The EAC does not even look at issues related to public hearings.

View of One of the affected villages show the rich forest that the project will destroy (Source - EIA)
View of One of the affected villages show the rich forest that the project will destroy (Source – EIA)

2. Were the issues raised at public hearing in March 2013 addressed?

No. As is clear from the report of the public hearing for the project held at Roing and New Anaya on March 11 and 13, 2014 respectively, the affected people raised a lot of critical issues about the project, EIA, EMP and Public hearing.

In the Minutes of the 68th meeting of EAC held in Sept 2013 and the 73rd EAC meeting held in March 2014, there is one paragraph (same para in both minutes) on public hearings: “Concerns Raised During Public Hearings It was explained that in general, the people were satisfied with the EIA and EMP reports and proposed R&R plan and community and social development plan. R&R plan has been formulated in line with the State R&R Policy, 2008. They took keen interest in knowing the R&R package and community and social development (CSD) plan. However, during public consultation prior to public hearing and during public hearings of Dibang Multipurpose Project, in addition to community and social development plan more infrastructural development in both Lower Dibang Valley and Dibang Valley Districts were sought viz., up gradation of District Hospitals in both districts, financial assistance for schools, colleges and polytechnic, and construction of cultural museum at Roing and ITI at Anini etc. Besides this for downstream people, the main concern was protection of downstream area in case of dam break / high flood. Keeping this in view, a lump sum provision of Rs. 17100 lakhs has been proposed for consideration of MoEF for mitigative measures at downstream and other infrastructural facilities as raised during public hearings in addition to R&R and CSD plan.”

The claim that “in general, the people were satisfied with the EIA and EMP reports and proposed R&R plan and community and social development plan” is a complete lie, as we see from the quotes from the official public hearing minutes below.

It seems the EAC members have not bothered to read the public hearing report, and they have willingly or unwillingly been misled by the NHPC and EIA agencies. To illustrate the critical issues raised at the public hearings, we are giving below some quotes from the official public hearing report. Most of these reports remain unaddressed in the EIA-EMP submitted to the MEFCC, but MEFCC and EAC has not bothered to check this.

Shri Lokha Elapra, President, All Idu Mshmi Students Union: “Poor planning of mitigation from impacts during construction phase. Mitigation measures fail to address issues of demographic impacts, socio-cultural concerns and preservation of traditional land and livelihood… EMP does not have any provision to address this. EIA and EMP does not have any mitigation measures to preserve nor compeansation for permanent loss of mithun grazing areas, fishing grounds and medicinal plants thus endangering the loss of Mishmi Takin (rare Animal), Mishmi Monal (rare Bird) and Mishmi  Teeta (rare medicinal plant)… Flood control of Eze (Deopani River to protect Roing Township… A cumulative impact study in the Dibang river basin must be undertaken.”

Shri Raju Mimi, Member, Mishmi Scholar’s Association: “NHPC had undermined the seismic design parameters as recommended by the experts of IIT Guwahati, Guwahati University and Dibrugarh University in respect of the Subansiri Dam. In this regard can the community members of the affected  areas be certain that such careless disregard for dam safety be not repeated by NHPC in this case?  All the documents related to dam design and safety be made public. Also, the documents should be peer reviewed by independent group of scientists. Ecological concerns like extraction of boulders from ecologically sensitive Important Bird Area (IBA). No impact assessment made regarding this in the EIA report… Hence a cumulative impact study in the Dibang river basin must be commissioned. Socio-economic concerns like the catchment area treatment (CAT) plan will restrict land use resulting in loss of land and livelihood. NHPC must ascertain such losses and compensate the people affected by CAT… There is possibility of loss of land by destabilization of soil due to the huge reservoir. What mechanisms will be implemented to address these losses? ”

Shri Kelo Pulu, President IMCLS: “Environment Monitoring Cell to assess and review the various mitigation measures as mentioned in the EMP is not convincing. Therefore, the Government of Arunachal Pradesh should immediately notify the formation of an independent Committee consisting of less than 5 members of local Idu Mishmi people.”

Shri Moba Riba: “Conduct Public hearing at Dambuk Sub division.”

Shri Jibi Pulu: “Additional EIA-EMP must be undertaken to ensure the minimum impacts to the ecology of Dibang area. The Community people will lose an area of 10390 ha that will be required for CAT plan. This area being grazing area of Mithun will be lost. The EIA does not have any data or estimate/ valuation of this resource. Without any compensation the livelihood rights cannot be taken away from the community. EIA studies about wildlife conservation is inadequate. EIA studies carried out regarding assessment of economic and medicinal plants is not project specific nor community focused. It does not have any reference, assessment and compensation of economically valuable plants like Piper mellusa and Paris polyphylla. The impact of 1950 earthquake of 8.7 magnitude.. Is the dam axis and reservoir standing along the seismic fault line? The impoundment of the drainage system by building dam will have major effect.. Hence, EIA studies on downstream impact particularly study of Deopani drainage and its siltation status is absolutely necessary.”

Dr Mite Linggi: “As recommended by the Planning Commission Committee we demand for a Dam safety design panel for an independent assessment of safety of Dibang Dam. There are lacunae in EIA-EMP reports. This must be rectified.”

Shri MartinLego: “Resistance capacity of the mountains which fall in the reservoir is not studied. Dam should be able to withstand flashflood. Construction of flood protection works with RCC wall supported by vegetative cover on both banks of Dibang River… Our demands must be fulfilled then only we will support.”

Shri Mibom Pertin, President Adi Bane Kebang (ABK): “Till date no initiative has been taken by the State Government, the district administration or the NHPC to educate the people… the EIA EMP must be modified/ rectified wherein safety measures and actions to be taken in case of dam break… Until and unless the above points are fulfilled the holding of this public hearing is strongly opposed by ABK.”

Shri Jowar Moyang: “Demand to establish a family dossier of the entire downstream people… Downstream not reflected in the EIA/EMP and DRP therefore, a separate guideline be made to include the downstream within the defined local area. The demands placed above must be addressed to within three months of this hearing or else will protest against the  construction of the project.”

Shri Nun Pertin, President, Dibang Adi Students’ Union (DASU): “Downstream people are unaware of the project benefits, impacts and other issues which are mandatory to be known before the commencement of the project. Therefore, public hearing in this regard must be conducted within blocks and subdivision of Lower Dibang Valley. This must be furnished in written assurance form within one week’s time. ”

Shri Anjite Menjo, Zilla Parishad Member, Iduli Anchal Block and Shri Chiliko Meto, ZillaParishad Chairperson: “Environment Monitoring Cell to assess and review the various mitigation measures as mentioned in the EMP is not convincing. Therefore, the Government of Arunachal Pradesh  should immediately notify the formation of an independent Committee consisting of less than 5 members of local Idu Mishmi people… Hence a cumulative impact study in the Dibang river basin must be commissioned.”

Dr Mite Linggi, Representative of Kere A Initiative for Cultural and Ecological Security (KICES): “It is evident that the 2000 MW Lower Subansiri Project is stalled since Dec 2011 because the technical, environmental and social concerns of the people of Assam were not considered earlier. Report of the Planning Commission appointed Committee of Dr C D Thatte and M S Reddy has raised several serious concerns about the downstream impacts of the 2000 MW Subansiri Lower Project. Therefore, keeping this in mind, it is absolutely important that public consultation in Assam is carried out before the Dibang project gets environment clearance. Public consultation in Assam is not only necessary to address the concern of the people, but it is a pre-requisite for the people of Dibang Valley in the upstream… Ignoring downstream concerns will only ensure that this project to will meet the same fate as Subansiri Lower Project (2000 MW and get stalled by people of Assam. Rights of the people to use Catchment Area will be denied. Will compensation be included for them? Is it possible for NHPC Ltd to formulate new criteria for all those villages perched atop to include within affected families?”

Shri Lokha Elapra, President, All Idu Mishmi Students’ Union (AIMSU): Raises most of the critical issues raised above including need for Cumulative Impact Asessment, inadequate EIA-EMP, Impacts of demographic changes, lack of assessment of loss of grazing land, fishing right. “We do not want to be refugees in our land.. We the Idu Mishmi have a way of living where we live independently. Past history is proof of it.  We had never been ruled and can never be ruled under any circumstance or vice versa. The plot which the NHPC Ltd claim giving free of cost is by virtue forcefully asking us to live in that piece of land where the PAFs are not satisfied.”

Shri Athupi Melo, Ex-ZPM, Anelih-Arju Block and Representing New Endoli village: “Public hearing on Dibang Multipurpose Project (3000 MW) was postponed 10-14 times earlier as the consent of the public was not taken before preparing EIA and EMP reports. The NHPC Ltd had cheated the entire affected people by concealing information and letting the awareness remain within the high reach people only. The NHPC Ltd as per their survey has shown 5 villages, 72 families, 243 persons, 938.8 ha of agriculture land as to be affected by the project. Do they know that the storage reservoir will submerge the land mass which belongs to another 34 villages of the valley?”

Shri Kupu Miku-ASM Arzoo and Representative of Apako village: “Had been resisting NHPC Ltd for the last ten years. Nothing was made known as to how much land would go and how much compensation would be provided.”

Shri Rezina Mihu, General Secretary, All Idu Mishmi Students Union (AIMSU): “It has been six yeas of resistance till this morning. The former President of AIMSU sacrificed his life fighting against the Dibang Project… the EIA-EMP is still not upto the mark.”

This selection of quotes from the Public hearing and reading of NHPC response, EIA-EMP and EAC minutes show that not only NHPC has failed to satisfactorily respond to most of these issues, the EAC and MEFCC has not even bothered to check the veracity of the claims of NHPC and uncritically accepted the NHPC claims. Inadequate response to the issues raised at the public hearing means that environmental clearance given to the project is legally untenable.

Anxious afffected people outside the public hearing Hall in March 2013 (Source - PH Report)
Anxious afffected people outside the public hearing Hall in March 2013 (Source – PH Report)

3. Has there been proper Environmental Impact Assessment of the project? Kalpavriksh, SANDRP, affected groups from Assam and Arunachal have made several independent submissions to EAC on the inadequacies of the EIA (Environmental Impact Assessment). SANDRP itself sent four different submissions (dated Sept 20, 2013, April 2014, May 2014 and Sept 12, 2014) highlighting various inadequacies of the EIA including:

  • Lack of compliance with the Terms of Reference of the EIA
  • Lack of basin wide cumulative impact assessment
  • Impact of mining of materials for the project not assessed
  • Lack of downstream impact assessment (more details below)
  • Lack of assessment of how climate change will affect the project and how the project will worsen the climate change impacts.
  • Lack of options assessment
  • Severe Impacts of Migration of Outsider on Local Tribal Community not assessed
  • Impact of the project on disaster potential in the project area as well in the downstream including Assam not assessed
  • Impact of changing silt flows downstream not assessed

As noted above, large number of speakers at the public hearing also pointed out the inadequacies of the EIA-EMP.

4. Are downstream impacts on Assam & Arunachal Pradesh Studied?

No credible study of the impact of the dam, dam break and peaking on Assam and Arunachal Pradesh in the downstream has been done.

Several speakers at the public hearing raised this issue of inadequate downstream impact assessment, as can be seen from the quotes from the public hearing listed above.

It may be mentioned here that the biggest issue plaguing the LSHP is lack of downstream impact assessment, and the EAC, MEFCC, NHPC or the EIA agencies (WAPCOS, which by now is notorious for doing substandard studies and National Productivity Council). Even Assam and Arunachal Pradesh state governments also seem least bothered. Also, it seems no lessons have been learnt after Larji mishap when 25 students were washed away due to demand-driven water releases by upstream hydropower project.

5. Has the impact of Peaking on Downstream Assam & Arunachal Pradesh studied?

NO

This is despite the fact that submissions were sent to the EAC from several organizations and individual also from Assam, drawing their attention to impact of peaking in downstream Assam, especially in lean season (winter) when flow fluctuations will range from 111 cumecs (Cubic meters per second) to about 13 time rise in volume at 1441 cumecs in a single day. Fluctuations can happen twice or thrice in a single day.

6. Has the impact on Dibru Saikhowa National Park in the downstream Assam studied?

NO

The EAC has shown zero application of mid in this respect. There are several hydropower projects being constructed on the three main tributaries of Brahmaputra upstream of Dibru Saikhowa National Park in Assam. All these hydropower projects will undertake peaking operations. EAC has considered these projects separately, as a part of basin studies and as a part of downstream impact studies on Dibru Saikhowa National Park.

In all these studies, the level fluctuation at the National Park when the three major projects in the upstream undertake peaking operations is different, as per the convenience of the project proponent! EAC has considered all these studies without raising any questions about this convenient difference in figures even when the contradictions were brought to EAC’s attention by SANDRP.

The EAC has recommended Clearance to Dibang Multipurpose Project accepting the contention of the NHPC that “water level fluctuation in Dibru Saikhowa National Park (DSNP) will be less than one meter.”

  • However, the same EAC has considered EIA of Lower Siang HEP (by WAPCOS) where the fluctuation at Dibru Saikhowa when all projects are peaking is said to be 8 feet (2.38 meters)
  • The Report on “Effect of Peaking power generation by Siang Lower HEP, Demwe Lower HEP and Dibang Multipurpose HEP on Dibru Saikhowa National Park” also by WAPCOS states that level difference when all three projects are peaking is estimated to be 34 mts i.e. 7.67 feet. (Page 26)

EAC did not question these glaring differences in these models even when a submission highlighting these points was sent to the EAC on 13.09.14, before the 77th EAC meeting. The submission is not mentioned in the minutes, neither discussed, also violating Hon. Delhi High Court Orders (Utkarsh Mandal Case).

7. EAC decision violates its mandate; MEFCC & NHPC guilty of misleading EAC.

During the entire appraisal process, the EAC has failed to pose any difficult questions to NHPC, has not taken a stand supporting Assam, has not even initiated discussion in that direction, has turned blind eye towards submissions it received raising critical concerns, has overlooked contradictions, has overlooked precautionary principle and welfare of people in the downstream Assam and has refused to learn any lessons from the LSHP experience or the Larji Mishap.

While discussion about height reduction of Dibang upto 40 meters were initiated in MEFCC/ NHPC since Feb 2014, the MEFCC or the NHPC has not brought this proposal to the attention of the EAC and the EAC has taken absolutely no notice of this and has not even asked for this 40 m height reduction. The only reference we can find to the height reduction proposal is in the minutes of the 73rd EAC meeting, where too there is reference to only 10 m ht reduction. And yet, there is no mention of this in the minutes of the 77th EAC meeting where the EAC recommended clearance to the project.

This alone is sufficient to make the EAC decision legally untenable and make both MEFCC and NHPC guilty of not informing the EAC about these developments more than six months after they were initiated.

The EAC on its part has not shown the will to ask for a realignment of the project to minimize its downstream impacts, peaking impacts and submergence impacts. Such biased conduct and the decisions of the EAC, sidelining genuine concerns are in complete violation of the mandate given to EAC and extremely damaging to environmental governance of the country and are a reason for increasing conflicts, delays, protests and strife underlining its callousness towards environmental impacts and local resistance.

The issues that FAC raised while rejecting the Forest clearance are the very issues that EAC should be concerned about since they are under their mandate. But not only EAC did not raise them on their own, but even after they were brought to the EAC’s attention by SANDRP, the EAC failed to even discuss those issues.

8. Issues on Dibang raised in earlier EAC meeting remains unanswered

The decision making paragraph of the minutes of the EAC meeting of Sept 16-17, 2014 on Dibang Project reads: “After critically examining the proposal and considering the response to various issues raised in the earlier EAC meetings, the project was recommended by EAC for accord of Environmental Clearance to Dibang Multipurpose Project. However, EAC suggested that 20 cumec flow may be released towards e-flow in the 1.2 km diverted stretch as 15 cumec gives just sufficient quantity. EAC noted that beyond this 1.2 km, adequate flow will be available from TRT which will be minimum in the order of 85 cumec at 80% rated discharge of one turbine.”

It is clear that this paragraph does not reflect any application of mind by EAC if the response provided by NHPC to the various issues raised by EAC and others’ submissions to EAC are adequate. Even in this paragraph, it is not clear what is the basis of EAC decision to recommend 20 cumecs flow downstream of the dam and not the norm that EAC is following for other projects (30% in monsoon, 20% in lean season and 20-25% in non monsoon non lean season). Nor is it clear what is the basis and impact of operation of one of the (there are 12 turbines, each of 250 MW installed capacity in this project) turbine at minimum 80% capacity round the clock. This non application of mind on the part of the EAC is the norm of EAC and not an isolated incident.

In fact, reading through the minutes of all the EAC meetings since Sept 2013 where Dibang EC (Environment Clearance) was discussed, it is clear that while EAC has raised a large no of questions and reported some of the information submitted by NHPC, no where can we find application of mind of the EAC where it is stated that the information/ responses provided by NHPC is adequate or not. The uncritical acceptance by the EAC about the information/ responses provided by the developer is another noteworthy feature of EAC decision.

Let us illustrate this. The minutes of the 73rd EAC meeting held in March 2014 says: “A detailed fisheries (also flora and fauna) survey was conducted by Centre for Inter-Disciplinary Studies for Mountain and Hill Environment (CISMHE), Delhi University in the month of December 2013.” Immediate question than arises is, why were the fisheries and other surveys done only in one month and not across the year as is the normal practice? What were the outcomes of the study? You will find neither critical questions, nor any answers in the EAC proceedings.

Here is another example. The minutes of the 74th EAC meeting held in May 2014 says: “It was informed that fluctuation in the water level at upstream of Dibang-Lohit confluence due to peaking operation will be about 17 cm which is almost negligible considering the size of the river.” Shockingly, the EAC does not even ask: A. If this estimate is sound and if it is consistent with conclusions of other studies; B. What will be the level fluctuation at different points along 60 km stretch of the river upstream from this point to the project site and what will be the impact there of. EAC’s such uncritical acceptance of apparently contradictory and inadequate responses from the developer is the norm and not an isolated incident. Considering that EAC was considering the largest installed capacity project of India, highest dam of India and biggest reservoir in North East India so far, one expected the EAC to be more diligent. This was even more so considering the experience of the LSHP.

To further illustrate, the minutes of the 74th EAC held in May 2014 says: “The point-wise reply to the two representations submitted by Kalpavriksh was submitted to MoEF and EAC members and the same was also presented before EAC during the meeting.” Similarly, the minutes of the 73rd EAC meeting held in March 2014 says: “point-wise replies to the issues raised by Shri Chow Rajib Gogoi, Secretary, All Tai Ahom Student Union, Jorhat and Shri Pushp Jain, Director, EIA Resource and Response Centre (ERC), New Delhi were also given”. But in both cases, there is not even a word as to whether EAC discussed the NHPC response and if they did what was their conclusion about adequacy or acceptability of the NHPC responses.

As far as four separate submissions sent by SANDRP to EAC on Dibang Project are concerned, EAC neither mentioned them, nor did it seek NHPC’s response on them.

Considering all this, the decision of the EAC to recommend EC to the Dibang Project is clearly wrong, based on inadequate appraisal, in the absence of application of mind and legally untenable.

Active Lanslide  zone in submergence area of Dibang Project (Source - EIA)
Active Lanslide zone in submergence area of Dibang Project (Source – EIA)

B. FAC DECISIONS ON DIBANG PROECT

It has been reported[3] that the Forest Advisory Committee of the MoEF has recommended clearance to 3000 MW Dibang Multipurpose project in its meeting on Sept 22, 2014, though the minutes of the FAC meeting are as yet unavailable. This decision is reversal of FAC’s clear rejection to the project twice in past 2 years[4] in addition to MEFCC’s rejection letter to the project as late as on the 28th August 2014.

  • MEFCC was pressurized by the Cabinet Committee on Investment, Ministry of Power and even unrelated Ministries like Ministry of Mine, Ministry of Steel and Ministry of Coal into clearing the Dibang project. FAC itself was under pressure of the MEFCC minister and its highest officials to clear Dibang at any cost.
  • Relevant papers regarding height reduction proposal by NHPC were not uploaded on FAC Website in advance of the Sept 22, 2014 Meeting.
  • It is unclear if even the FAC Members had these documents, which form the basis of project consideration.
  • The height reduction proposal was not available to the EAC members a week earlier before EAC recommended clearance to the project.
  • FAC’s recommendation on Dibang project is clearly an undemocratic and illegal decision in the absence of prior information in public domain for all concerned, and when all the original objections raised by FAC while rejecting the project twice remain unaddressed.

Let us look at the timeline of FAC decision making on Dibang Project:

12.06.13: FAC rejects Dibang FC (Forest Clearance) Proposal. Reasons: “huge forest area with very good forest cover, irreparable and adverse impact on general eco-system of the area by felling of more than 3.5 lakhs of trees, several other HEP have been proposed in the same river valley apart from Dibang HEP, unavailability of study on cumulative impact of all the HEP, etc. The Committee is also of the opinion that ecological, environmental and social costs of diversion of such a vast track of forest land, which is a major source of livelihood of the tribal population of the State, will far outweigh the benefits likely to accrue from the project.”

13.08.2013: Meeting of Secretary, Ministry of Environment and Forests and the Secretary, Ministry of Power held and it was decided that proposal will be considered again after exploring the possibility to reduce the requirement of forest land for the project.

9.12.2013: Project discussed by the Cabinet Committee of Investment which nearly ordered fast clearance for Dibang Project. It stated: “Ministry of Environment and Forests may grant the requisite clearance for diversion of forest land expeditiously.” Such direction from CCI was clearly in violation of the Forest Conservation Act 1980 which clearly defines the process for forest clearance and where CCI has no role.

10.02.14: NHPC revises proposal and submits two alternatives, reducing height by 5 m and 10 meters respectively. Marginal decrease in submerge of forest land due to 10 meters reduction. NHPC Officials say any further reduction will not be possible.

Revised Diversion proposal with reduction of 10 mts height and 445 hectares forest area submitted to MoEF with new proposal for total diversion of 4577.84 hectares.

29th-30th April 2014: Revised proposal discussed in FAC with 10 meters reduction. The revised proposal was incomplete in many basic respects like absence of maps, CAT Pan, FRA compliance, identified land for Compensatory afforestation, etc. In addition, the FAC noted that the region is home to Schedule I species, the reduction in forest loss due to decrease in height in minimal and will not have substantial ameliorative impact, It said “Such a marginal reduction in requirement of the forest land for the project may not be able to reduce the adverse impact of project on such a biodiversity rich mature forest ecosystem to the extent which could make the project environmentally as well as socio-economically viable in forest dependent tribal society of Arunachal Pradesh”. FAC also noted that impact of reduction of dam height on its economic feasibility was not put before the committee.

16.06.2014: Secretary Power writes to Secretary, MEFCC on 16.06.2014 to review the decision of FAC and accord the Stage-I forest clearance. Such direction from letter was clearly in violation of the Forest Conservation Act 1980 which clearly defines the process for forest clearance and where Power Ministry secretary has no role.

19.06.2014: Joint meeting held between Ministry of Mine, Ministry of Steel, Ministry of Environment Forests and Climate Change and Ministry of Coal, attended by the Ministers and Secretaries of the respective Ministries, as well as Secy, Ministry of Power wherein it was decided that a report on sensitivity analysis of dam height reduction by 40 meters shall be submitted to MoEF and action will be taken only after that.

24.06.2014: Secy, Ministry of Power writes to MEFCC & submitted a report on the sensitivity analysis on the dam height reduction upto 20 meters. However, MEFCC maintained that that as decided in the meeting the sensitivity analysis report was not submitted by the project proponent.

28.08.14: MEFCC sends letter rejecting Forest Diversion Proposal of Dibang Multipurpose Project on the basis of 10 meters height reduction, rich forest, social impacts and also downstream impacts on Assam, including Dibru Saikhowa.

5.09.2014: MEFCC writes to (NHPC/ Min of Power) to submit sensitivity analysis of reduction by 40 meters.

08.09.14 (This letter of 08.09.14 was uploaded on MEFCC FAC website on the day of the FAC meeting, 22.09.14): NHPC submits letter to MEFCC about sensitivity analysis for height reduction from 5m-40 meters. While it highlights the loss in installed capacity (780 MW) and loss in revenue due to 40 m reduction, it downplays the fact that 40 mts reduction will bring down forest land requirement by 26%. It concludes, without substantiation that “Decrease in dam height and consequent sacrifice in power generation beyond 10 mts reduction is not commensurate with saving forest land” and further recommends only 10 mts height reduction, which proposal the MEFCC had rejected in its Apr 29-30, 2014 meeting.

21.09.14: No sensitivity Analysis uploaded on MoEF FAC Website. SANDRP sends a submission urging FAC not to consider the project in the absence of this analysis in public domain as it violates CIC orders. People affected by the project have no idea of this analysis which is the basis of decision making in the next day’s meeting.

22.09.14: Day of the Meeting: Suddenly Additional Information document accessed (and downloaded) on 21.09.14 changes, with two additional pages and letter from NHPC about sensitivity analysis is uploaded ON THE DAY OF THE MEETING.

23.09.14: News that FAC has recommended clearance to Dibang was already public.

The affected people stopping the public hearing in 2008. Source: http://www.roingcorrespondent.in/this-circus-should-stop-no-public-hearing/
The affected people stopping the public hearing in 2008. Source: http://www.roingcorrespondent.in/this-circus-should-stop-no-public-hearing/

CONCLUSION As noted earlier, the Dibang Project is the largest capacity hydropower project, the highest proposed dam and largest proposed reservoir of North East India. One expected all concerned to be diligent in taking decisions on such a project. However, it is clear from this narrative that the process of environment and forest clearance for the Dibang Project is fundamentally flawed, inadequate and in violation of all norms of democratic and informed governance. Significantly, it is also illegal and untenable. Such manipulative decision-making has led to flawed decisions of environmental and forest clearances in case of LSHP in 2003, with the project stalled by people’s agitation since 34 months now. If the Dibang Project, which is bigger than LSHP in every respect and with much greater impacts, is pushed in such a manner, it is likely to face the same fate as that of the LSHP. We hope that the final decisions related to Dibang Project will be more informed, diligent, democratic, unbiased and objective. Admittedly, such hope seems rather farfetched at this moment.

Parineeta Dandekar (parineeta.dandekar@gmail.com) & Himanshu Thakkar (ht.sandrp@gmail.com), SANDRP

END NOTES:

[1] This is not to state that the UPA government that ruled India during the 2004-2014 decade was in anyway more sensitive to environment or democratic concerns. In fact part of the EC and FC time line and some of the manipulations happened before May 2014 when the current government took over. However, it is apparent that the current government has indulged in much more  violations and manipulations and pressurized the statutory bodies (including FAC & NBWL reconstitution).

[2] https://sandrp.wordpress.com/2014/01/31/six-years-after-pm-laying-foundation-stone-no-clearance-no-work-for-3000-mw-dibang-dam/

[3] http://indianexpress.com/article/india/india-others/6-years-2-rejections-later-indias-largest-hydro-project-cleared/99/#sthash.vNJo2nAs.dpuf

[4] For details, see: https://sandrp.wordpress.com/2014/05/17/dibang-project-rejected-forest-clearance-for-the-second-time/

[5] A video titled “Dibang Resistance (Arunachal Pradesh)” depicts the protest and blockade by local people against the Dibang dam. The video can be viewed here: https://www.youtube.com/watch?v=m8TCUKh2hQY 

[6] Mimi, R., “The Dibang Multipurpose Project, Resistance of the Idu Mishmi” published in “Water Conflicts in Northeast India – A Compendium of Case Studies” edited by Das, Partha J. et. all, 2013

Arunachal Pradesh · Dams

Dibang Project Rejected Forest Clearance for the Second Time

PROJECT UNABLE TO SUBMIT SATISFACTORY PROPOSAL EVEN SIX YEARS AFTER PM LAID FOUNDATION STONE!

In a remarkable decision, the Forest Advisory Committee (FAC) of MoEF has rejected the forest clearance to 3000 MW Dibang multipurpose project for the second time in its meeting held on 29 -30 April 2014. In that meeting FAC considered the Dibang multipurpose project for diversion of massive 4577.84 ha of biodiversity rich forest land which would lead to cutting down of huge 3.24 lac trees.

Continue reading “Dibang Project Rejected Forest Clearance for the Second Time”

Arunachal Pradesh · Assam · brahmaputra · Embankments · Ministry of Water Resources

Analysis MoWR’s Advisory Committee’s Decisions for Northeast – January 2009 to Dec 2013

This is analysis of the decisions of the Advisory Committee in the Union Ministry of Water Resources for consideration of techno-economic viability of Irrigation, Flood Control and Multi Purpose Project Proposals (TAC in short) for North East India[1] from 95th meeting of January 2009 to 122nd meeting held in December 2013. In our last analysis of TAC minutes we have covered the decision taken for NE states from July 2011 to December 2013 which  is available at – https://sandrp.wordpress.com/2014/03/19/lack-of-transparency-and-accountability-remains-the-norm-of-functioning-for-mowrs-advisory-committee/. In this analysis, we have covered the same for an extended period. In these five years TAC has accepted project proposals worth of 5515.46 crores. In calculating the total cost of the projects considered we have considered only the projects whose proposals were given clearance by TAC. In these five years, some of the projects also made two appearances with revised costs. In such cases the higher revised cost has been taken into consideration, e.g. Khuga Multipurpose Project and Dolaithabi Barrage Project, both located in Manipur were accepted by the committee in its 100th meeting (held on 9th October 2009) with revised cost of Rs 381.28 crore and 251.52 crore respectively. In the 115th meeting (held on 24th July 2012) of the TAC, these two projects were considered again where the cost for Khuga Project was Rs. 433.91 cr and for Dolaithabi Project it was Rs. 360.05 Cr. The same is the case for the Thoubal Multipurpose Project which appeared in 101st and 115th meeting of the TAC.

Within these five years, TAC has given financial clearance to 26 flood and erosion control projects and majority of these projects are from Assam. The committee gave the clearance to 6 irrigation projects, 3 barrage projects and 3 multipurpose projects.[2] The committee also gave clearance to a strom water drainage improvement project below Greenfield Airport at Pakyong in Sikkim within this period.

In this period, largest no of considered (25) and approved (20) projects were from Assam. Assam also has the maximum cost of projects among all states (Rs. 2631.99 Cr). Highest number of projects were considered (16) and approved (14) in the year 2009, with total cost of Rs 2321 Crores, which too was highest among all the years.

As found in our previous analysis, in the last five year from 2009 to 2013 TAC has not rejected a single project. Five projects had been deferred but were approved in the subsequent meetings within the same period. In the 108th meeting (held on 4th January 2011), the TAC did not discuss two projects on the Brahmaputra river stating “It was observed that the flood control and anti erosion scheme of Brahmaputra Board are implemented through Central Fund, which do not require investment clearance from the Planning Commission. Therefore, these schemes need not be put up to the Advisory Committee. However, the technical aspect of such project may be looked into by Central Water Commission as per past practice.”  But both these projects were reconsidered in the 110th meeting of TAC (held on 20th July 2011) and were cleared by the committee.

So this seems like a rubber stamping committee, clearing everything that comes to it. Reading of the minutes of the meetings also reveals that there are hardly any critical questions asked on merits of the questions for the massive delay and cost escalations that most of the projects suffer. Nor is there an discussion about the performance of the projects.

As we noted earlier, this committee functions in most non transparent, non participatory and unaccountable way. Neither the minutes nor the agenda notes of the meetings are in public domain. Following our letters along with TAC analysis in April 2011, addressed to Planning Commission, Union Ministry of Water Resources, Central Water Commission and members of the National Advisory Council, for the first time, TAC minutes were put up on CWC website (see: http://www.cwc.gov.in/main/webpages/TAC%20minutes.html). However, the last uploaded minutes were for the 115th meeting held in July 2012, after which minutes have stopped being uploaded. Secondly, some of the links are not working and all the files are unnecessarily large PDF files since only scanned pages of the minutes are put up, in place of the PDFs of normal word files, which would be of much smaller size. The TAC also has no independent, non government members, all the members are government officials. As we wrote to MoWR and Planning Commission in April 2011 and again in March 2014, there is urgent need for TAC to have  such members so that they provide objective perspective about the projects that come up before TAC.

The importance of functioning of this committee cannot be over emphasised. As we  wrote  in our letter to MoWR and Planning Commission, TAC “considers dozens of such projects with huge economic, social, environmental and other implications for the country in every one of its meetings. All of these projects are supposed to be public purpose projects, and are taken up using public resources. The Planning Commission accords investment clearance to the projects only after the TAC clearance. This Committee’s decisions are perhaps the ones which impact on India as a whole the most – as they relate to land and water – which are the basic life sustaining and livelihood providing resources for the people.”

It is high time that first effective steps are taken to ensure that the functioning of this committee becomes more transparent, participatory and accountable.

State-wise list of projects cleared by TAC

State No of Projects Considered No of projects approved Total cost of the projects
Arunachal Pradesh 4 4 106.6
Assam 25 20 2631.99
Manipur 10 10 2268.99
Meghalaya 1 1 5.63
Sikkim 1 1 48.55
Tripura 6 6 453.7

Note: No projects from Mizoram and Nagaland have come to TAC in this 5 years period.

Year-wise List of Projects Cleared by TAC

Year No of Projects Considered No of projects approved Total cost of the projects
2009 16 14 2321
2010 5 5 663.67
2011 12 9 497.33
2012 5 5 2208.81
2013 9 9 1439.45

Meeting-wise List Projects Cleared by TAC January 2009 to December 2013

Sl. No Meeting no Date of meeting No of projects considered No projects approved No of projects deferred No of projects rejected Total cost of the accepted projects, Rs Crore
95th 20.01.2009 4 3 1 0 196.07
96th 16.02.2009 2 2 0 0 168.14
100th 09.10.2009 6 5 1 0 264.73
101st 30.11.2009 4 4 0 0 77.26
102nd 28.01.2010 1 1 0 0 59.91
103rd 11.03.2010 1 1 0 0 302.22
106th 16.09.2010 3 3 0 0 301.54
108th 04.01.2011 2 0 2 0 0
109th 04.03.2011 3 3 0 0 70.13
110th 20.07.2011 5 4 1 0 211.56
111th 17.08.2011 1 1 0 0 167.09
112th 14.09.2011 1 1 0 0 48.55
115th 24.07.2012 5 5 0 0 2208.81
117th 21.03.2013 1 1 0 0 155.87
118th 30.07.2013 2 2 0 0 467.38
119th 29.08.2013 2 2 0 0 601.67
120th 13.09.2013 1 1 0 0 42.96
121st 08.10.2013 2 2 0 0 146.01
122nd 20.12.2013 1 1 0 0 25.56
Total   47 42 5 0 5515.46

95th meeting (20.01.2009): Accepted TOTAL – Rs 196.07 crores (revised costs have been taken into consideration)

SN Project Dist/ State Appr. year River/ Basin Original (revised) Cost-CrRs Decision
1 Protection of Sialmari Area Morigaon/ AS 2002 B’putra 14.29 (25.73) Accepted
2 Protection of Bhojaikhati, Doligaon and Ulubari AS 2002 B’putra 14.52 (27.92) Accepted
3 Protection of Majuli Island Ph II-III AS New B’putra 116.02 Deferred the proposal with suggestion to prepare the cost at current prices.
4 Raising & strengthening Dyke from from Sissikalghar to Tekeliphuta including closing of breach by retirement and anti erosion measures AS New B’putra 142.42 Accepted

96th meeting (16.02.2009): Accepted Total – Rs 168.14 crores

SN Project Dist/ State Appr. year River/ Basin Original (revised) Cost-CrRs Decision
1 Flood protection of Majuli Island Ph-II & III AS New B’putra 115.03 Accepted
2 Restoration of Dibang & Lohit rivers to their original courses at Dholla Hattiguli AS New B’putra 23.32(53.11) Accepted partially & suggested that proposal of coffer dam, pilot channel, etc. may be put up to the Standing Committee for expert opinion

100th meeting (09.10.2009): Accepted: TOTAL – Rs 897.53 crores

SN Project Dist/ State Appr. year River/ Basin L of Dam Original (revised) Cost-CrRs Benefit Irri CCA Annual Irrigation Decision
1 Borolia Irrigation Project AS 1980 Brahmaputra 92 m 6.775 (135.93) 9717 15,000 Ha Deferred due to non-submission of State Finance Concurrence
2 Khuga Multipurpose (Major- Revised) Manipur 1980 Khuga/ Imphal 230 m 15 (381.28) 9575 14,755 Ha Accepted
3 Dolaithabi Barrage Project (Med Revised) Manipur 1992 Iril/ Manipur 79 m 18.86 (251.52) 5,500 7,545 Ha
4 Gumti Irrigation Project (Revised) Tripura 1979 Gumti 96 m 5.88 (83.01) 4,486 9,800 ha Accepted
5 Khowai Irrigation Project (Revised) Tripura 1980 Khowai 96 m 7.10 (83.01) 4,515 9,320 Ha Accepted
6 Manu Irrigation Project Tripura 1981 Manu 82 m 8.18 (98.71) 4,198 7,600 Ha Accepted

101st meeting (30.11.2009): Accepted TOTAL – Rs 1059.26 crores

SN Project State Appr. year River/ Basin L of Dam Original (revised) Cost-CrRs Benefit Irri CCA/ flood prot. Annual Irrigation Decision
1 Raising & strengthening to Puthimari embankment Assam New B’putra NA 30.23 15000 Ha NA Accepted
2 Anti Erosion measures to protect left B’putra Dyke Assam New B’putra NA 27.97 5000 Ha NA Accepted
3 Protection of Gakhirkhitee and its adjoining areas Assam New B’putra NA 19.06 20,000 Ha NA Accepted
4 Thoubal Multipurpose Project (revised) Manipur 1980 Thoubal/ Imphal 1074 m 47.25 (982) 21,862 ha 33,449 Ha Accepted

102nd meeting (28.01.2010): Accepted TOTAL – Rs 59.91 crores

SN Project Dist/ State Appr. year River/ Basin Original Cost-CrRs Benefit-flood protsn Decision
1 Emergent measures for protection of Rohmoria in Dibrugarh Dist Assam New Brahmaputra 59.91 18,000 Ha Accepted

103rd meeting (11.03.2010): Accepted: TOTAL Cost of approved projects: Rs 302.22 crores

Project Dist/ State Appr. year River/ Basin L of Dam Original (revised) Cost-CrRs CCA (Ha) Annual Irrigation (Ha) Decision
Champamati Irrigation Project Chirag/AS 1980 Champamati/B’putra 258.5 m 15.32 (309.22) 17,414 24,994 Accepted

106th meeting (16.09.2010): Accepted TOTAL – Rs 301.54 crores

SN Project Dist/ State Appr. year River/ Basin Original (revised) Cost-CrRs Decision
1 Raising & strengthening of tributary dyke on both banks of Kopili River Assam New Kopilli/ B’putra 110.72 Accepted
2 Assam Integrated Flood River Bank Erosion Risk Management Project Dibrugarh/ Assam New Brahmaputra 61.33 Accepted
3 Assam Integrated Flood River Bank Erosion Risk Management Project Palasbari/ Assam New Brahmaputra 129.49 Accepted

108th meeting (04.01.2011): Accepted TOTAL- Rs 0

SN Project Dist/ State Appr. year River/ Basin Original (revised) Cost-CrRs Decision
1 Restoration of Dibang & Lohit rivers to their original courses at Dholla Hattiguli AS New Brahmaputra 23.32(53.11) The technical aspect pf this type of project may be looked in to by CWC as per past Practices.
2 Protection of Majuli Island from flood & erosion, Ph II-III AS New Brahmaputra 116.02 The technical aspect pf this type of project may be looked in to by CWC as per past Practices.

109th meeting (04.03.2011): Accepted TOTAL – Rs 70.13crores

SN Project Dist/ State Appr. year River/ Basin Original (revised) Cost-CrRs Decision
1 Anti Erosion & Flood Protection work in Dikrong Basin Arunachal Pradesh New Dikrong 23.68 Accepted
2 Anti Erosion & Flood Protection work in Bhareli sub Basin Arunachal Pradesh New Bhareli 16.81 Accepted
3 Anti Erosion & Flood Protection work in Siyom Basin Arunachal Pradesh New Siyom 29.64 Accepted

110th meeting (20.07.2011): Accepted: TOTAL: Rs 211.56 crores

Sl No Project Dist/State Appr. year basin original cost (Rs. Cr) decision
1 Anti Erosion & Flood protection in Tawangchu basin ArP New Tawangchu 36.47 Accepted
2 Protection of Majuli from Flood & Erosion Ph II & III Assam 2011 Brahmaputra 115.03 Accepted
3 Restoration of rivers Dibang and Lohit to their original courses at Dholla Hatighuli Assam 2011 Brahmaputra 54.43 Accepted
4 Protection of Balat village from flood and erosion of river Umngi in W Khasi hill district West Khasi hill/Meghalaya New Brahmaputra 5.63 Accepted

111th meeting (17.08.2011): Accepted: TOTAL: Rs 167.09 crores

Project Dist/State Appr. year basin original cost decision
Protection of Biswanath Panpur including areas of upstream Silamari and Far downstream Bhumuraguri to Borgaon Sonitpur/Assam New Brahmaputra Rs 167.09 Cr Accepted

112th meeting (14.09.2011): Accepted: TOTAL: Rs 48.55 crores

Sl No Project Dist/ State Appr. year original cost (Rs. Cr) decision
1 Improvement of Strom Water Drainage below Greenfield Airport at Pakyong Sikkim  New 48.55 Accepted

115th meeting (24.07.2012): Accepted: TOTAL: Rs 2208.81 crores

Sl No Project Dist/State Appr. year basin original cost (Rs. Cr) decision
1 Thoubal Multipurpose project Manipur 1980 Brahmaputra 1387.85 Accepted
2 Khuga Multipurpose project Manipur 1980 Brahmaputra 433.91 Accepted
3 Dolathabi Barrage Project Manipur 1992 Brahmaputra 360.05 Accepted
4 ERM of Imphal Barrage Project Manipur New Brahmaputra 16.8 Accepted
5 ERM of Sekmai Barrage Project Manipur New Brahmaputra 10.2 Accepted

 

117th meeting (21.03.2013): Accepted: TOTAL: Rs 155.87 crores

Sl No Project Dist/ State Appr. year basin Ht / L of Dam/Embnk. original cost (Rs. Cr) Benefit flood prot. (Ha) decision
Protection of Sissi-Tekeliphuta dyke from erosion – Lotasur to Tekeliphuta Assam New Brahmaputra 153 km 155.87 10117 Accepted

1188h meeting (30.07.2013): Accepted: TOTAL: Rs 467.38 crores

Sl No Project Dist/ State Appr. year River/ basin original cost (Rs. Cr) Benefit flood prot. (Ha) decision
Flood management of Dikrong and river training works on both banks embankment Lakhimpur/ Assam New Dikrong/ Brahmaputra 105.96 9998 Accepted
Flood management of Ranganadi and river training works on both bank embankments Lakhimpur/ Assam  New Ranganadi/ Brahmaputra 361.42  21056 Accepted

119th meeting (29.08.2013): Accepted: TOTAL: Rs 601.67 crores

Sl No Project Dist/ State Appr. year River/ basin original cost (Rs. Cr) annual irrigation decision
Dhansiri Irrigation project Assam 1975 Dhansiri/ B’putra 567.05 Accepted
ERM of Singda multipurpose project Manipur  New Brahmaputra 34.62 3000 Accepted

 

120th meeting (29.08.2013): Accepted: TOTAL: Rs 42.96 crores

Project Dist/State River original cost (Rs. Cr) decision
Anti erosion work along river Haora from Champakpur to Baldakhal W Tripura Haora 42.96 Accepted

121st meeting (08.10.2013): Accepted: TOTAL: Rs 146.01 crores

Sl No Project Dist/ State River original cost (Rs. Cr) Benefit flood prot. (Ha) decision
Anti erosion work along river Gumti from Dlak Samatal Para to Durgapur under Amarpur, Udaipur & Sonamura subdivision S & West Tripura Gumti 54.99 2209 Accepted
Anti erosion work along river Khowaii from Netajinagar to Banglahour under Telimura subdivision and from south L. N. Pur to Paharmura bridge under Khowai subvision West Tripura Khowaii 91.02  4256 Accepted

122nd meeting (20.12.2013): Accepted: TOTAL: Rs 25.56 crores

Sl No Project Dist/State River original cost (Rs. Cr) decision
Loktak Lift Irrigation Project Manipur 25.56 Accepted

 Parag Jyoti Saikia and Himanshu Thakkar

————————————–

[1]While this article only contains the details of the North East India Projects considered in TAC for the five years, we hope to soon provide details of the projects considered by TAC from all over India.

[2] Sicne Khuga Multipurpose, Thoubal Multipurpose and Dolaithabi barrage project, all from Manipur appears twice in this period, they have calculated only for once here.

[3] Feature image – Khuga Mutipurpose project. Image courtesy – http://manipuronline.com/

Arunachal Pradesh · Assam · brahmaputra · Embankments · Ministry of Water Resources · Sikkim

Lack of Transparency and Accountability Remains the Norm of Functioning for MoWR’s Advisory Committee

The Advisory Committee in the Union Ministry of Water Resources (MoWR) for consideration of techno-economic viability of Irrigation, Flood Control and Multi Purpose Project Proposals (TAC in short) is a very important committee. It accords the financial clearance for any irrigation, flood control and multipurpose project. TAC is supposed to discuss the techno-economic viability of projects as per the resolution published in the Union of India Gazette Notification No. 12/5/86-P-II dated Nov 27, 1987. This committee came into being replacing a similar committee that existed earlier in the planning commission. Even now, the guidelines for functioning of the committee are issued by the Planning Commission.

The Gazette notification cited above also said, “The committee may also invite representatives of any other Government organizations, scientific body of experts in the relevant fields to participate in its deliberations.” This seems like a window to appoint credible, independent, non-government persons in the committee, but this window does not seem to have been used. Among the functions of the committee listed in this notification include, “The functions of the Committee will be to examine projects proposed by State Governments, Central Government or other organizations and satisfy itself that the schemes have been prepared after adequate investigations” and “the need of environment conservation and proper rehabilitation of project-affected persons have been taken into account.” However, our perusal of the functioning of the TAC shows that TAC has failed to fulfill both these mandates.

As noted in the Guidelines for Submission, Appraisal and Clearance of Irrigation and Multipurpose Projects, 2010 available on the CWC website (see: http://www.cwc.nic.in/main/webpages/publications.html), “The project proposal, thereafter, is put up to the Advisory Committee for clearance, which is, by and large, like single window clearance.” The importance of such a single window clearance becomes all the more important. The guidelines further note, “On the basis of examination conducted by the Advisory Committee, decision on techno-economic viability of the projects is taken in the meeting of this Committee. The projects found acceptable by the Advisory Committee shall be recommended for investment clearance by the Planning Commission and inclusion in the Five Year Plan/Annual Plan.” This shows how important is the role of the TAC in judging techno-economic viability of projects and also from the point of view of prudent planning.

No Transparency, independent participation or accountability of TAC Considering the above, there is strong case for clearly defined norms for transparency, participation and accountability in (1) functioning of TAC; (2) The screening process of the projects at initial stages that also happen under these guidelines in the Central Water Commission, based on which approval for DPR preparation is given.

In view of the significance of TAC, this is SANDRP’s third analysis of the decisions taken in TAC meetings. The present analysis covers decisions taken for North East India from 110th to 122nd TAC meeting. In the two previous analysis done by SANDRP, TAC meeting decisions taken from 95th meeting to 109th meeting has been covered. Here it is important to note that lack of transparency has been observed right from the agenda and minutes of the TAC meetings. The agenda and minutes of the TAC meetings should be uploaded on CWC website but CWC website has minutes only till the 115th meeting held on 24th July 2012 and the website has been last updated on 31/08/2012.

In this analysis we have covered 13 TAC meetings held from July 2011 to December 2013. In these 13 meeting, 21 projects from 6 northeastern states have been considered. But out of the 13 meetings held, projects from northeast were considered only in 10 meetings. TAC has accepted the proposals for projects with a total cost of rupees 4075.46 crore. Majority of the projects were given clearance at the first time of consideration. Thus, on an average TAC  had cleared projects worth of 407.55 crores from the North East in each of these 10 meetings. Number of the projects considered by TAC in each meeting along with their total cost is given below. A state-wise and a project-wise list is also provided.

Total Cost of Projects Cleared by TAC July 2012 to December 2013

Sl No Meeting no Date of meeting No of projects considered from NE No projects approved No of projects deferred No of projects rejected Total cost of the accepted projects, Rs Crore
1 110th 20-07-11 5 4 1 0 211.56
2 111th 17-08-11 1 1 0 0 167.09
3 112th 14-09-11 1 1 0 0 48.55
4 115th 24-07-12 5 5 0 0 2208.81
5 117th 21-03-13 1 1 0 0 155.87
6 118th 30-07-13 2 2 0 0 467.38
7 119th 29-08-13 2 2 0 0 601.67
8 120th 13-09-13 1 1 0 0 42.96
9 121st 08-10-13 2 2 0 0 146.01
10 122nd 20-12-13 1 1 0 0 25.56
  Total     20     4075.46

State-wise list of projects cleared by TAC

Sl. No State No of projects approved Total cost of the approved projects, Rs Crore
1 Arunachal 1 36.47
2 Assam 7 1526.85
3 Manipur 7 2268.99
4 Meghalaya 1 5.63
5 Sikkim 1 48.55
6 Tripura 3 188.97

Note: No projects from Mizoram and Nagaland have come to TAC in this 30 month period.

Some observations regarding TAC meetings

1. Zero Rejections The TAC did not reject a single project. There was only one project which was deferred in the 110th meeting but it was approved in the next meeting. Rest of the new projects were were approved in the very first meeting of their consideration.

2. Lack of information The TAC minutes provide little information about projects. Specially in case of newer projects, detailed discussions should have happened. The minutes of TAC meetings do not give much of an idea about size, location, benefits of a particular project. In the project- wise list provided towards the end of this analysis, we have provided limited information available in the minutes. Some of the noteworthy missing information is listed below:

– In the 115th meeting, 5 projects from Manipur were considered. Out of these five projects, 2 were multipurpose projects and 3 were barrage projects. Surprisingly, there was no information about where these projects are located, on which river, what the size of these projects. None of the minutes mentioned about whom these projects will actually benefit. Only two projects mentioned about increase in annually irrigated land but no more detail was provided.

– In the 118th meeting, construction of embankments on both banks of river Ranganadi for flood management and river training was considered. But the cost of the project was on the higher side compared to the embankment construction work to be done on the river Dikrong, considered in the same meeting. This cost escalation may be due to the difference in the length of the projects. But this cannot be confirmed since minutes do not mention the length of the proposed embankments.

India's First Geo-tube embankment in Matmora in Dhakuakhana sub-division of Lakhimpur district in Assam.  Photo: Parag Jyoti Saikia
India’s First Geo-tube embankment in Matmora in Dhakuakhana sub-division of Lakhimpur district in Assam. Photo: Parag Jyoti Saikia

But the increased costs may also be due to the use of Geo bag technology for construction of Ranganadi embankments. Use of Geo-bag technology is a costly affair but nothing has been mentioned about the use of this technology in the minutes of 118th meeting. This is stated in the annexure (Annex VI as mentioned in the document) of the meeting. Interestingly this annexure too has been mentioned only as a corrigendum.

3. No Detailed Discussion on Projects Considered This was very evident in the two previous analysis done by SANDRP and situation remains the same this time as well. In case of all the projects, including the ones considered for the first time, there was no detailed information or any detailed discussion. There is no discussion on technical viability of the project. Reading through the minutes gives an impression that approval for any project considered by TAC is fait accompli. There is no discussion about whether the project is a desirable project, if there are other options available, if this is the best option and so on. Under the mandate given to it, TAC is supposed to discuss all these issues. TAC accepted projects proposals with huge cost and time overruns but little enquiry has been made why such escalation happened.

Dhansiri irrigation project This is a glaring example of cost escalation. The project was discussed in the 119th meeting on 29.08.2013 for consideration of cost of Rs 567.05 crores. But, it was surprising to find that original cost of the project in 1975 was Rs 15.83 crores as according to the information available in Assam State Irrigation Department website.[1] The same website states that project started in 1975 and supposed to be completed 35 years later in 2010. In the TAC meeting a new time schedule of March 2015 was stated. The cost of the project has increased by 35.82 times over a period of 40 years but the advisory committee accepts proposal without much scrutiny or enquiry. There was no detailed assessment of the reasons for time and cost over runs (there is no question of delay due to clearances or agitations here) or whether this project which will take 40 years just to complete will be viable or not. On the contrary, the planning commission representatives said, “the benefit cost ratio of the project was 1.2 and any further escalation in cost would result in the project becoming techno-economic unviable.”

The TAC should have done a detailed assessment why the project took so long time to complete. But it seemed to be contended with the rational that the project authorities provided which was that due land acquisition and law and order problem the project has not been completed. But in the meantime minutes of the meeting also showed that that major components of the project are in advanced stages of construction with 93% of barrage work, 99% of the canal works and about 83% of works in the distribution system were reported to have been completed. There has been no detailed assessment in to any of these aspects.

Imphal Barrage project In this project, the cost of the project mentioned in the minutes of the 115th meeting contradicted with the cost provided in the annexure. The cost of Extension, Renovation and Modernization (ERM) of the Imphal barrage project as mentioned in the minutes is Rs 16.80 crores. But a letter from the Under Secretary, Govt. of Manipur to the Chief Engineer of Irrigation and Flood Control Department, Manipur dated 21.07.2012 stated the cost of the project as 23.41 crores. This reflects the lack of serious discussion over projects in TAC. It is also surprising that TAC, being the committee which gives the techno economic clearance to projects, does not have clarity about even the cost of the project.

4. No Discussion over Social, Environmental and Other impacts of the Projects The projects cleared by TAC have serious social, environmental and other impacts but the committee never discussed these impacts. TAC does not at all take into account the impacts a project would have on the environment.

In the 118th meeting (30.07.2013), while considering the proposal for flood management of Dikrong along with river training works on both banks, the minutes stated “Effectiveness of existing embankments of river Dikrong has been deteriorating due to lack of repair, siltation of river bed and consequential change in river behaviour, change in flow pattern due to release of Ranga Nadi hydel project etc.” But this is one of the rare instances when TAC mentioned about the environmental impacts on embankments. But rather than asking for more details on these impacts or to see whether embankment would really be a viable option or not, the TAC accepted the proposal. On the other hand nowhere the committee discussed what impacts an embankment has on river bed, siltation or downstream stretches of a river.

Dikrong Power Station at Hoz where water from Ranganadi HEP is released in Dikrong. Photo: Parag Jyoti Saikia
Dikrong Power Station at Hoz where water from Ranganadi HEP is released in Dikrong/Pare. Photo: Parag Jyoti Saikia
Dikrong at Dikronghat in Lakhimpur district of Assam where it erodes rapidly. The impacts of change is water flow is clearly visible. Due to release of water in upstream water at night covers the lower portion of the bank. This photo was taken around 8am in the morning when the water receded. The lower bank portion was wet in the morning. According to the local the water further recedes by the evening and again increases at night. Photo: Parag Jyoti Saikia
River Dikrong at Dikronghat in Lakhimpur district of Assam where it erodes rapidly. The impacts of change is water flow is clearly visible. Due to release of water in upstream water at night covers the lower portion of the bank. This photo was taken around 8am in the morning when the water receded. The lower bank portion was wet in the morning. According to the local the water further recedes by the evening and again increases at night. Photo: Parag Jyoti Saikia

It is also important to note here TAC also does not take into consideration impacts of the hydropower projects on the embankments in the downstream of the river. In the above mentioned case, the increased costs of Dikrong embankment should have been charged on the Ranga Nadi HEP, but there is no discussion on this. The Pare hydropower project (110 MW) in Papumpare district of Arunachal Pradesh is currently under construction on Dikong / PareRiver. Moreover there are at least 10 hydropower projects at various stages in the combined Ranganadi-Dikrong basin in Arunachal Pradesh, including one operating, three TOR approvals given and five additional MoA signed (in addition to a proposed project). There is no provision to assess the impacts of these projects on the embankments downstream of DikrongRiver in Assam. In fact there is no provision for any impact assessment study for embankments even though studies show the disastrous impacts of embankments on environment, floods and on the lives of the people living close to the river.

5. Clearing Same Embankment Projects over Years In terms of embankments, it is observed that the TAC had cleared same projects over the years. Not emphasizing on the environmental impacts of embankment projects is one of the major reasons for this. In the 117th TAC meeting held on 21.03.2013 the proposal for “Protection of Brahmaputra dyke from Sissikalghar to Tekeliphuta at different reaches from Lotasur to Tekeliphuta from the erosion of river Brahmaputra Assam” was considered. The estimated cost of the project was Rs 155.87 crore. But on the same embankment, a project titled “Raising and Strengthening to Brahmaputra dyke from Sissikalghar to Tekeliphuta including closing of breach by retirement and anti-erosion measures (to protect Majuli and Dhakukhana areas against flood devastation by the Brahmaputra, Lakhimpur district, Assam) was accepted in the 95th TAC meeting held on 20.01.2009. The estimated cost of the earlier project was 142.42 crore.

A Hoarding on the way to Geo-tube embankment in Matmora, describing the project.  Photo: Parag Jyoti Saikia
A Hoarding on the way to Geo-tube embankment in Matmora, describing the project.
Photo: Parag Jyoti Saikia

The minutes of the 117th meeting, about the previous scheme said that it “was taken up primarily for closure of breach in the then existing embankment including raising of embankment around the breach area only.” But the minutes of the 95th TAC meeting had said something totally different about the project. The minutes stated that project proposal envisaged – (i) Raising and strengthening of embankment for a length of 13.9 km, (ii) Construction of retirement bund with geo-textile tubes of length 5000 m. This shows how the discussion on the Brahmaputra dyke Sissikalghar to Tekeliphuta is 117th meeting is completely misleading. TAC does on even take into account its previous meeting discussions before clearing a project. This possibly gives a hint of a scam.

The Brahmaputra dyke from Sissikalghar to Tekeliphuta has a long history of facing severe erosions. The first geo-tube embankment was constructed on this dyke in Dec 2010. Crores have been spent for the protection of this embankment. But even after that the Dhakukhana sub-division always remained in the headlines during the flood season in Assam. There is need for area specific detailed study assessing the impact on and of the embankment, but little has been done in this regard. Besides, the Bogibeel Bridge, the fourth one on the BrahmaputraRiver, is coming up in the upstream of this embankment. Construction of this bridge would make this dyke even more prone to erosion since the length of this bridge will be 4.94 km, shrinking the wide river to great extent. In a personal visit to the area, one of the government officials informed that as a result of this “funneling action”, the force of water will increase and it will directly hit the embankment leading to more erosion. But TAC has never dealt with these issues in its meetings but cleared all the proposals that it considered.
Short History Brahmaputra Dyke from Sissikalghae to Tekeliphuta[2]

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6. There is no independent, critical voice in the meetings. The agenda, proceedings, or decisions of the meetings are not even in public domain.
7. There is no mechanism to hold the TAC accountable for any wrong decisions taken.
8. The TAC is clearly not fulfilling the mandate given to it in the guidelines for TAC meetings. The guidelines themselves need revision from several points.
9. There is no attempt to assess the justifiability of the kinds of projects that are being accepted and if they are indeed delivering the promised benefits.

Parag Jyoti Saikia (meandering1800@gmail.com)

Project-wise Detailed List of TAC decisions

110th meeting (20.07.2011): Accepted: TOTAL: Rs 211.56 crores

Sl No Project Dist/State Appr. year basin original cost (Rs. Cr) decision
1 Anti Erosion & Flood protection work Arunachal Pradesh New Tawangchu 36.47 Accepted
2 Protection of Majuli from Flood and Erosion Phase II & III Assam 2011 Brahmaputra 115.03 Accepted
3 Restoration fo rivers Dibang and Lohit to their original courses at Dholla Hatighuli Assam 2011 Brahmaputra 54.43 Accepted
4 Protection of Balat village from flood and erosion of river Umngi in West Khasi hill district West Khasi hill/Meghalaya  New Brahmaputra 5.63 Accepted

111th meeting (17.08.2011): Accepted: TOTAL: Rs 167.09 crores

Sl No Project Dist/State Appr. year basin original cost (Rs. Cr) decision
1 Protection of Biswanath Panpur including areas of upstream Silamari and Far downstream Bhumuraguri to Borgaon against erosion of the river Brahmaputra Sonitpur/Assam  New Brahmaputra 167.09 Accepted

112th meeting (14.09.2011): Accepted: TOTAL: Rs 48.55 crores

Sl No Project Dist/ State Appr. year original cost (Rs. Cr) decision
1 Improvement of Strom Water Drainage below GreenfieldAirport at Pakyong Sikkim  New 48.55 Accepted

115th meeting (24.07.2012): Accepted: TOTAL: Rs 2208.81 crores

Sl No Project Dist/State Appr. year basin original cost (Rs. Cr) decision
1 Thoubal Multipurpose project Manipur 1980 Brahmaputra 1387.85 Accepted
2 Khuga Multipurpose project Manipur 1980 Brahmaputra 433.91 Accepted
3 Dolathabi Barrage Project Manipur 1992 Brahmaputra 360.05 Accepted
4 ERM of Imphal Barrage Project Manipur New Brahmaputra 16.8 Accepted
5 ERM of Sekmai Barrage Project Manipur  New Brahmaputra 10.2 Accepted

117th meeting (21.03.2013): Accepted: TOTAL: Rs 623.25 crores

Sl No Project Dist/ State Appr. year basin Ht / L of Dam/Embnk. original cost (Rs. Cr) Benefit flood prot. (Ha) decision
1 Protecion of Sissi-Tekeliphuta dyke from erosion – Lotasur to Tekeliphuta Assam New Brahmaputra 153 km 155.87 10117 Accepted

1188h meeting (30.07.2013): Accepted: TOTAL: Rs 623.25 crores

Sl No Project Dist/ State Appr. year River/ basin original cost (Rs. Cr) Benefit flood prot. (Ha) decision
1 Flood management of Dikrong and river training works on both banks embankment Lakhimpur/ Assam New Dikrong/ Brahmaputra 105.96 9998 Accepted
2 Flood management of Ranganadi and river training works on both bank embankments Lakhimpur/ Assam  New Ranganadi/ Brahmaputra 361.42  21056 Accepted

119th meeting (29.08.2013): Accepted: TOTAL: Rs 601.67 crores

Sl No Project Dist/ State Appr. year River/ basin original cost (Rs. Cr) annual irrigation decision
1 Dhansiri Irrigation project Assam 1975 Dhansiri/ B’putra 567.05 Accepted
2 ERM of Singda multipurpose project Manipur  New Brahmaputra 34.62 3000 Accepted

120th meeting (29.08.2013): Accepted: TOTAL: Rs 42.96 crores

Sl No Project Dist/State River original cost (Rs. Cr) decision
1 Anti erosion work along river Haora from Champakpur to Baldakhal West Tripura Haora 42.96 Accepted

121st meeting (08.10.2013): Accepted: TOTAL: Rs 146.01 crores

Sl No Project Dist/ State River original cost (Rs. Cr) Benefit flood prot. (Ha) decision
1 Anti erosion work along river Gumti from Dlak Samatal Para to Durgapur under Amarpur, Udaipur & Sonamura subdivision S & West Tripura Gumti 54.99 2209 Accepted
2 Anti erosion work along river Khowaii from Netajinagar to Banglahour under Telimura subdivision and from south L. N. Pur to Paharmura bridge under Khowai subvision West Tripura Khowaii 91.02  4256 Accepted

122nd meeting (20.12.2013): Accepted: TOTAL: Rs 25.56 crores

Sl No Project Dist/State River original cost (Rs. Cr) decision
1 Loktak Lift Irrigation Project Manipur 25.56 Accepted

[2] From the brochure published by WRD, Assam at the time of commissioning the geo-tube embankment in Matmora

Arunachal Pradesh · Expert Appraisal Committee

Hydromania in Arunachal Pradesh: Massive 1850 MW Dam Planned Without Any Basic Data, Not even Water Flow Data…

‘MoU Virus’ was the term used by former environment minister Jairam Ramesh in May 2008 to describe the speed at which the Memorandum of Understanding or MoUs for hydropower projects were signed by Arunachal Pradesh government. Five years after that virus attack, the ill-effects are clearly visible. The construction of Lower Subansiri hydropower project has been stopped for 26 months now. Environment and Forest clearances are yet to be accorded to 3000 MW Dibang Multipurpose dam, even though the foundation stone for this dam was laid by none other than the Prime Minister Dr. Manmohan Singh on 31st January 2008. Lower Siang hydropower project public hearing was vehemently opposed by people. But learning no lesson from these, the government of Arunachal Pradesh and the center is going ahead with its gigantic plan to make Arunachal Pradesh the ‘future powerhouse’ of the country. In doing so scientific studies and ground realities have been blatantly neglected.

Oju hydropower project in the Subansiri river basin with a proposed installed capacity of 1850 MW is the latest example of the hydromania, which has gripped the government of Arunachal Pradesh and the center. Oju HEP is the upper most project proposed on the Subansiri river in the Upper Subansiri district with a catchment area of 9827 sq. km. up to the dam site. The project was considered for Terms of Reference (TOR) or first stage of environmental clearance by the Expert Appraisal Committee on River Valley and Hydroelectric projects (EAC) in its 72nd meeting held on 20th and 21st February this year. But there is little information available about the actual situation of the project area.  Before going any further, consider the following situations –

Any scientific study is yet to be done at the dam site. Water flow data which is a prerequisite for construction of a hydropower dam is not available for the proposed dam site. No gauge and discharge measurement site at the project site or anywhere in the catchment of the dam.

The project area is totally under forest cover. It holds rich biodiversity which is yet to be explored.

* There is no road to reach the project area. The distance between the dam site of Oju hydropower project and Limeking town, the last point of motarable road is 60 km. From Daporijo, the headquarters of Upper Subansiri district, the dam site is 210 km away. 

Tentative Road Network to Project Site Source: Oju PFR
Tentative Road Network to Project Site
Source: Oju PFR

A small hydropower project is proposed to be constructed in a nearby stream in order to fulfill the electricity requirement during the construction of the project.  

SNC-Lavalin, the consultants hired for preparation of detailed project report, is known to be one of most corrupt engineering firms in the world.

All the situations mentioned above are drawn from the project documents submitted to MoEF. It was shocking to find that without any environmental baseline assessment, the Pre Feasibility Report and Form I made all kinds of sweeping assertions. This hydromania is leading to nothing but ignorant, unscientific and corrupt decision making. 

SANDRP after reviewing the project documents, made a detailed submission to EAC on February 13th pointing out the critical issues related with Oju HEP. We asked the EAC not to consider the project for TOR clearance. We also demanded that the project proponent should  be  asked  to  get  at  least  five  years’  daily  water  flow, gauge, rainfall and sediment data at the project site before applying for TOR clearance. The critical issues mentioned in SANDRP’s submission on Oju HEP to EAC are listed below.

Critical Issues of Oju HEP

No More Projects Should be Cleared in Subansiri basin before Completion of Basin Study From 20007 to 2013, four projects in Subansiri basin has been considered by EAC along with one sub-basin study. All the four projects have been given TOR clearance. Subansiri Upper HEP has been given TOR extension on 6th June 2013. The total installed capacity of these projects are 4960 MW. It is also important to note that 2000 MW Lower Subansiri project is in under construction phase. This implies that nearly 6960 MW of capacity has already been given clearance by EAC without any cumulative impacts assessment study of Subansiri basin being completed through a participatory process. This capacity is in addition to the small hydropower projects in the basin.

The Subansiri sub-basin study was discussed for the first time in 68th EAC meeting in 2013. In that meeting the EAC had stated that “optimal number and locations of HEPs and similar projects to be planned in the basin conforming strictly to ecological and environmental sustainability is to be clearly delineated.” This can only be known once the basin study is completed.

In this situation, no more projects in Subansiri basin should be given any clearance till the cumulative study is being completed. Besides, the EAC must take into account the fact that cumulative impact assessment study of the basin is major demand of the organizations whose agitation has stopped the construction work of Lower Subansiri with the support of the people of Assam. Therefore it is very essential that a through and detailed cumulative impact assessment study is done for Subansiri in participation with all the people of the basin. Without this, clearances given to projects would face the same fate as the Lower Subansiri project is now facing: Work stopped for 26 months till now.

A list of projects cleared by EAC in Subansiri basin is given below.

Sl. No Project State Sub-Basin Ins Cap Status Meeting date Total Area Req. ha Forest Land, ha
1. Subansiri Lower AP Subansiri 2000 Under construction EC on 16-07-03 4111 4039.9
2. Subansiri Middle AP Kamla 1600 TOR Approved 25-09-10 3180 1333
3. Nalo HEP AP Subansiri 360 TOR Approved 11-12-11 662.94
4. Naba AP Subansiri 1000 TOR Approved 03-05-13 658
5. Subansiri Upper AP Subansiri 2000 TOR Ext Granted 06-06-13 3155 2170

Premature application Reading the PFR and Form I on the EAC website shows that project has come rather prematurely for TOR clearance. There is no gauge and discharge measurement site at the project site or anywhere in the catchment, the nearest site is at Upper Subansiri dam site with catchment area about 50% higher than that of Oju HEP. Even for this site, the flow measurement observations are available only for 6 years. How can optimum parameters of a massive project with 1850 MW capacity be formulated without any flow measurements, which is the most important parameter for hydropower project. Even now the flow measurements do not seem to have begun. There are no roads to the project area. It should be remembered that this is a virgin site, and there have been no environmental baseline assessments and yet the PFR and Form I are making all kind of sweeping assertions. The PP should be asked to get back with such an application only after they have at least five years of observation data of water flow and other parameters. That the application is premature is also apparent from the drastic changes the project capacity has gone through so far, as described in PFR. 

Oju HEP's nearest gauge is located in Menga, also the site for Subansiri Upper HEP. But there are four hydropower projects planned between Oju and Subansiri Upper.  Source: Form I of Oju HEP
Oju HEP’s nearest gauge station is located at Menga which the site for Subansiri Upper HEP. But there are four hydropower projects planned between Oju and Subansiri Upper. Source: Form I of Oju HEP

This premature-ness of the proposal is further confirmed when we see contradictory figures in the submitted documents about basic project parameters. For example dam height is given as 110 m (sec 8) at one place and 115 m at another place. Live Storage capacity is given as 2.065 MCM at some place, 3.3 MCM elsewhere (e.g. sec 4.4 of PFR). Power intake design discharge is given as 327.4 cumecs at some places and 333.39 cumecs elsewhere (e.g. sec 2.2 of Form 1).

Proposal in contradiction with Cumulative Impact Assessment This proposal before EAC for a 1850 MW Oju project is in contradiction with what is given in the Cumulative Impact Assessment (CIA) commissioned by the CWC and which was discussed in the 68th meeting of  EAC. The CIA says (see para 3 of Ex Summary) that there are two Oju projects: “Oju – I (1925 MW), Oju – II (2580 MW)”. However, the proposal now before the EAC is one project with capacity lower than any single project! However, Table on page 15 of CIA says Oju I has 700 MW and Oju II has 1000 MW capacity! The CIA says the submergence area of Oju I is 72.3 ha, though the proposal now before EAC for the same dam says the dam has submergence area of 42.3 ha! CIA says design flood is 10500 cumecs for Oju I (same dam as Oju now before EAC), but the proposal before EAC says PMF is much lower at 5983. This shocking series of numbers show that both the reports of Oju project before EAC and the CIA are misleading and do not seem to know what they are talking about. This is not an exhaustive list of contradictions, there are many more, this is only for illustration. 

Map of Subansiri RIver Basin  Source: https://sandrp.in/basin_maps/Subansiri_River_Basin.pdf
Map of Subansiri RIver Basin
Source: https://sandrp.in/basin_maps/Subansiri_River_Basin.pdf

Proposal different than allotment The PP was allotted two separate projects Oju I and II by Arunachal Pradesh government, but they have decided to club the two, but there is no agreement between Arunachal Pradesh and PP for the new parameters in the project proposed before EAC. Without such an agreement, EAC consideration of the project would be vacuous.

Huge Land Requirement The Form I of Oju project states that the area which will come under submergence due to the formation of the reservoir excluding the river bed is 34.3 ha. Including the river bed the total submergence is 43.2 ha. But the total land requirement is 760 ha implying that the required for dam, water conductor system, power house and other project appurtenances is about 727 ha. It is not clear why 760 ha of land is required for the project when reservoir submergence is 43.2 ha.

Contradictory figures about Land Requirement The Form I in the table providing basin information about the project states that “The total land to be acquired for the project is 760 ha.” But the PFR in section 12.2 in page 15 states “It is estimated that about 790 Ha of land would be required for development of the Project.” This shows that the project proponent is not clear about the land requirement for the project. 

Threat to Huge Forest area The construction of Oju HEP will be a threat to a huge forest area. Page 17 the Form I states “…760 ha of land with forest cover is to be acquired for the project. Forest cover is also observed within the project as well as area within 15 km from the project site.” But the PFR does not specify how much forest area will be actually diverted. 

River Subansiri flowing through its lush green valley
River Subansiri flowing through its lush green valley

Installed Capacity is more than 1850 MW The installed capacity of Oju project is more than 1850 MW since a dam toe power house of 28 MW is also planned. This makes the total installed capacity in 1878 MW. The documents in most of the places mentioned installed capacity of the project as 1850 MW. The EAC therefore should ask the project proponent to apply for fresh TOR clearance with renewed installed capacity.

Oju Project Proponent aims to Construct Three Projects in the Name of One: Small Hydro project to Power the Construction Work The EAC should take a note that project proponent of Oju, is aiming to construct three hydro power projects in the name of one. We have already mentioned about the first two. Now in section 10.7 of page 10-7, the PFR documents states “The power requirement for construction activities is estimated to about 25.0 MVA taking into consideration the capacity of electric driven equipments which are to work during the construction period and lighting. The possibility of constructing small hydro power plants on streams in the vicinity of the project would also be explored at DPR stage.”

The Form I also mentioned about small HEP in page 10 -“The estimated peak requirement of power is about 25MW required for construction activity of major works such as tunnels, adits, barrage area and power house complex. Construction power requirement is proposed to be met by DG Sets/Small HEP.” Full details including impact assessment of this small HEP should be included in the TOR.

Stretch of Free Flowing River between Two Projects on Subansiri It is not clear how much flowing river stretch is available between Oju and downstream Nare HEP. According to the minimalist norms followed by EAC the free flowing stretch between two projects should be minimum one kilometer. But the PFR of Oju HEP have not clearly mentioned this distance anywhere. The Cascade development figure given in the PFR says that the elevation difference between TWL of Oju (1300 m) and FRL of Nare (1280 m) is just 20 m. If we look at the average slop at the site, this translates to about half a km. The PP should be asked to change the parameters to increase this to more than a km at least.

It is also important to specify this distance between two projects because of the cumulative impacts of the project. The Siang basin study in its recent version, which will be discussed in the same 72nd EAC meeting has asked to change the FRL and TWL of some of the projects because they have not kept minimum distance of one kilometer between projects. The basin study report in section 12.1.3 stated “…..it is recommended that FRL of three projects viz. Tato II, Naying and Siyom Middle should be slightly reduced so that free flowing river stretches of 1 Km can be maintained between FRL and TWL of these four projects in cascade.”

Therefore Oju HEP PFR should clearly mention the distance between its TWL and FRL of the downstream project. EAC also should make this compulsory for all the projects in other river basins.

Form I and PFR contradictory about the Generating Units The Form I of Oju HEP in page 20 states that the installed capacity of 1850 MW will be generated through eight units of 231.25 MW each. But PFR on the other hand, in section 9 of page 8 states “The underground powerhouse, housing eight units of 225 MW each, is proposed on the right bank of the river Subansiri.” It is surprising to find such contradictions in the Form I and PFR of Oju project.

The PFR in page 13 again states “As mentioned earlier, project’s installed capacity has been fixed at 1850 MW and correspondingly, eight generating units of 231.25 MW, each, are proposed in the powerhouse.”

Huge Diversion of the River The Oju HEP will divert a huge length of the river. Page 1 of the PFR states, “The dam site is located at about 60 km upstream of Limeking and powerhouse site is located at about 40 km upstream of Limeking on the right bank of Subansiri river.” This implies that the river has been diverted for 20 km between the dam site and the power house (The head race length is 14.82 km). . This is a huge diversion of the river Subansiri which will have disastrous impacts on the health and ecosystem of the river. But neither the Form I nor the PFR provide what is the length of the river to be diverted for the project.

Subansiri carries significant amount of sediment The PFR report of Oju project in section 7.5.2 states “Since Subansiri River is expected to carry some amount of sediment during monsoons, effective management of sediment removal from the reservoir should be ensured.” Stating that the river carries some sediment is not correct since this river system is known for high sedimentation due to its location in the young Himalayan mountain range.

Reference to this can be found in the January-March, 2003 issue Ecologist Asia (page 12) which was focused on dams in northeast “The catchments of the Brahmaputra and its tributaries show significantly high rates of basin denudation especially after the great earthquake of 1950. The catchments of the Subansiri, Jia Bharali and the Manas along with the Dihang (Siang) are estimated to have experienced an average denudation of 73-157 cm./1000 years over just 24 years (1955-79). The increasing amounts of sediment and water yields downstream indicate an increase in sediment yield by a whopping 240% accompanied by an equally significant rise of nearly 120% in water yield during the period 1971-1979 between Tsela D’Zong (China) and Ranaghat (India).

Therefore first the sediment flow should be properly assessed.

Detailed and Thorough Options Assessment A detailed and through options assessment should be done for Oju project. There can be several other cost effective options for power generation in this area and options assessment should look into all such options. The options assessment should also look at whether the local people or the state needs such a huge capacity hydropower project.

It is important here to note that successful sub-megawatt capacity hydropower projects (Less than 1 MW) are currently under operation in Anjaw district of Arunachal Pradesh. (see – Anjaw shines in hydro power sector).

The TOR for the project does not include the following key aspects:

1. Issues related to cumulative impact assessment due to various components of the project and various projects in the basin.

2. The disaster vulnerability of the area on various aspects like landslides, earthquakes, floods, etc and how these will change with changing climate and how the project will change the disaster vulnerability of the area. There should be a separate chapter in EIA on this.

3. The project should do actual environment flow assessment and not just take the EAC norms as given. There should be separate chapter in EIA on this. The statement in Form 1 section 1.24 “Environmental Flows as per MOEF norms shall be released” is thus clearly premature and unwarranted. Eflows should be on daily changing basis and not seasonal averages.

4. Full Downstream social and environmental Impact Assessment

5. Impacts Peaking Power Operations

6. Assessment of impact of reservoir operation and mechanism to achieve transparent, accountable reservoir operation.

7. Impacts of Silt Management operations at various points of time and space.

8. Impacts of Tunneling and Blasting

9. Impacts of Mining of materials for the project.

10. Impacts of Backwater Effects of the reservoir in flood season

11. Impacts of Climate Change on dam

12. Impacts of the project on the adaptation capacity of the people in view of changing climate

13. Impact of peaking operation of the project on downstream areas and communities

No de-sanding chambers proposed in Silt Laden River The PFR in section 7.5.2 in page 7-5 states that “In this regard, it may be noted that no de-sanding chambers are proposed in the project in view of a relatively high dam with reservoir extending to almost 3.13 km.” Keeping no provision of de-sanding or de-silting chamber in the dam could have serious impacts on reservoir operations.

Form 1 undertaking not signed Page 2 of Form 1 is supposed to be an undertaking about the accuracy of information in Form 1, but there is no name, place or date for the signatory, all places are blank.

Poor reputation of consultants The PP has hired SNC Lavalin as consultant for DPR. However, SNC Lavalin has poor reputation in their country of origin (Canada[1]), globally[2] and even in Indian state of Kerala[3]. How dependable would the work of such an agency be is a big question mark.

Parag Jyoti Saikia (with inputs from Himanshu Thakkar)


[1] Out of  over 250 companies on World Bank’s current black listed from bidding on its global projects under its fraud and corruption policy, 115 are from SNC Lavalin and its affiliates, see: http://business.financialpost.com/2013/09/18/canada-now-dominates-world-bank-corruption-list-thanks-to-snc-lavalin/

[2] See: http://www.huffingtonpost.ca/daniel-tencer/snc-lavalin_b_4110591.html, the company has been banned by the World Bank due to corruption issues: “SNC-Lavalin, the engineering giant based out of Montreal that has now pretty much become a national (and international) embarrassment.” Its CEO has been arrested more than once for corruption charges.

[3] See: http://en.wikipedia.org/wiki/SNC_Lavalin_scandal, there was a CBI inquiry in relation to hydropower projects related work and several politicians have been charge sheeted.

Arunachal Pradesh · brahmaputra · Cumulative Impact Assessment · Ministry of Environment and Forests · Siang

Cumulative Impact Assessment Study of Siang Basin in Arunachal Pradesh: Serious shortcomings; pro large hydro bias

Most of the major rivers in the North East India are largely free-flowing till date, which is a rarity in India and the world. Their basins are home to unbelievable ecological and cultural diversity. Main rivers in Arunachal Pradesh which form the mighty Brahmaputra are the Siang (the Yarlung Tsang Po), Dibang and Lohit, which meet at the trijunction to form Brahmaputra.

Massive hydropower projects are planned on these rivers in cascade. They will have irreversible destructive impacts on the society, forests, rivers, biodiversity, ecosystems, cultural identity and downstream Assam.

Hydropower Flood in Arunachal Pradesh Map: Neeraj Vagholikar, Sanctuary Asia
Hydropower Flood in Arunachal Pradesh
Map: Neeraj Vagholikar, Sanctuary Asia

Siang River alone has 44 dams planned along its entire length.

Yes, 44 dams. You have read it correctly. At least 44 dams in one sub basin of Brahmaputra River Basin. This is what was meant by MOU virus as Jairam Ramesh described it.

Siang River Basin The Siang river originates in the Chemayungdung mountain ranges which nearly sixty miles south-east of Mansarovar lake in the Mount Kailash range in Southern Tibet at an elevation of 5300 m. A spring called Tamchok Khambab spills from the glaciers which later gather breath and volume to become the Tsangpo, the highest river in world.  Tsangpo river flows 1625 km in Tibet parallel to the main range of Himalayas before entering India through Arunachal Pradesh.

Before entering India, the river passes Pi (Pe) in Tibet and suddenly turns to the north and northeast and cuts a course through a succession of great narrow gorges between the mountain Gyala Peri and Namjabarwa (Namcha Barwa) in a series of rapids and cascades. The river then turns south and southwest and flows through a deep gorge across the eastern extremity of the Himalayas with canyon walls that extends upward for 16,500 feet (5,000 meters) and more on each side.

The river enters Arunachal Pradesh near Gelling from where it is known as Siang. The total length of Siang River is 294 km till its point of confluence with Dibang and Lohit River. After entering India the river traverses approximately 197.0 km to join the Siyom river. From there the length of the river till Assam border is 86.3 km. Flowing further 10.6 km in Assam the river joins the confluence of Lohit and Dibang. From this point forward it flows as Brahmaputra river in Assam and traverses a distance of about 195 km up to the confluence of Subansiri river on its right bank. Further downstream it is joined by Kameng at Jamugurihat near Tezpur, after another 123 km.  From  here  it  travels  for  another  134  km  up  to Guwahati.

River Siang Photo from: Global Descents
River Siang Photo from: Global Descents

The elevation of Siang river catchment area ranges from 90 m to around 5800 m. The total catchment area of Siang river from its origin to its confluence with Lohit and Dibang rivers is 251,521 sq km. Out of this 236555.7 sq km area lies in Tibet. The total catchment area of Siang river in India upto its confluence with Lohit and Dibang rivers is 14965.30 sq km.    

A question arises here, what will be the condition of the 294 km long Siang river if the proposed 44 dams are being built on the river. The Siang river basin study has the answer for this which is actually alarming “Only 85.5 km (29%) of free flowing water regime of Siang river will be left out of its total course in India i.e.  294 km of lotic ecosystem will be converted into 208.5 km of lentic ecosystem altering the entire Siang river aquatic system which will adversely impact the aquatic biodiversity and seriously affecting fish populations and their migration behaviour.”(page 11.23)

Three dams on the main Siang will convert the free flowing river into a three-stepped reservoir, without ANY flowing length of the river! These dams alone will affect more than 18,000 hectares of forests! If all the dams are built, water level fluctuations in the downstream D’Ering Sanctuary will be more than 23 feet every single day in the winter and other non monsoon seasons!

82.26% of the Siang basin is under forest cover (more than 15,000 sq kms), it is rich in orchids (more than 100 species!), holds 16 species of rhododendrons, 14 species of Bamboos and 14 species of canes and overall 27 RET species and 46 endemic plant species. 25 (18%) mammalian species found are Schedule I of WPA (Wildlife Protection Act), while 26 are under Schedule II! There are 447 species of birds, of which 31 are Schedule I species. The single basin consists of 5 Important Bird Areas !!(IBAs)

Formation of River Siyom, which will have multiple dams in a cascade Photo from: Team BHP
Formation of River Siyom, which will have multiple dams in a cascade Photo from: Team BHP

This information has been collated by the CIA (Cumulative Impact Assessment)/ CCS (Carrying Capacity Study) of the Siang Basin, which was an attempt to look at the scale and cumulative impacts of projects in Siang holistically.

Has the CIA commissioned by Central water Commission and done by RS Envirolink Technologies done an objective, scientific, independent assessment?

SANDRP sent comments about this 2-volume study  with over 1500 pages to the Expert Appraisal Committee, Ministry of Environment and Forests which will be considering this basin study in its upcoming meeting on Feb 20-21, 2014. Submission below highlights that the study has very serious short comings and bias. The recommendation of dropping 15 (mostly small ones, all below 90 MW installed capacity) HEPs and re-configuring some others is welcome, but far from sufficient. The study itself is disappointing:

Projects planned in the Siang Basin Phot from CIA/ CCS of Siang Basin
Projects planned in the Siang Basin Phot from CIA/ CCS of Siang Basin

 

Time Line of Siang Basin Study

Feb 2010 Ministry of Water Resources constituted an Inter-Ministerial Group on the directions of Prime Minister’s Office with a view to evolve a suitable framework to guide and accelerate the development of hydropower in the North East and also to assess the impact of the massive hydropower development in Arunachal Pradesh on downstream areas in Assam
Nov 2010 EAC discussed TOR for the Siang Basin CIA
Dec 23, 2010 MoEF issues TORs for the Siang Basin CIA
April 2011 EAC discusses sampling locations for the CIA on request of CWC
Dec 2011 Work of CIA for Siang awarded to RSET Pvt Ltd
May 2012 RSET says draft interim report discussed by TAC, but there is no meeting of TAC in May 2012, minutes of March and July TAC meetings (the ones before and after May 2012) on CWC website also do not mention any such discussion.
Nov 2012 EAC discusses Draft Interim report
Aug 2013 Draft Final report submitted to CWC
Sept 2013 RSET says Draft final report discussed by TAC, but the minutes of the Sept 2013 meeting of the TAC obtained under RTI donot contain any reference to the Siang basin study
DEC 2013 Draft Final Report submitted to MoEF
Feb 17, 2014 Critique of the Draft Final report submitted by SANDRP to EAC
Feb 20, 2014 MoEF’s EAC to  discuss the Draft Final report

To,

Chairperson and Members,

Expert appraisal Committee

Ministry of Environment and Forests

Delhi

Subject: Serious inadequacies of Cumulative Impact Assessment (CIA) and Carrying Capacity Study (CCS) of Siang Sub-basin including Downstream Impacts

Respected Chairperson and Members,

We see from the agenda uploaded on the MoEF Website that Final Report of the Siang CIA/CCS Study commissioned by CWC and conducted by RS Envirolink Technologies Pvt Ltd will be discussed in the 72nd EAC Meeting to be held on 20-21 February 2014.

SANDRP has been analysing basin studies in the Western Himalayas and Brahmaputra Basin for some time now. Looking at the aggressive cascade hydropower development and its far reaching cumulative impacts, CIA/ CCS and Basin Studies should form the backbone of informed decision making by MoEF. Unfortunately, most studies being considered by the EAC are of a sub-standard quality and are shying away from addressing the cumulative impacts [1]. EAC itself is delinking appraisal of individual projects from basin studies, rendering the crucial process meaningless which is in violation of EIA notification of Sept 2006, wherein Form 1 Section 9 actually asks for cumulative impact assessment. Some of the recent orders of National Green Tribunal also make it CIA mandatory, thus making such delinking legally untenable.

Looking at the scale of ecological and social impacts of these projects and the significance of MoEF’s and EAC’s role, we urge the EAC to consider CIA/ CCS/ Basin Studies more seriously.

Main issues with Siang Basin Study include: (These are elaborated with reasons below)

1. No mention of social and cultural impacts!

2. Downstream impacts on Assam not studied in detail

3. Cumulative Disaster vulnerability, impact of projects on such vulnerabilities, Dam Safety Assessment, risk assessment not done

4. “Cumulative” Impacts not assessed on several aspects

5. Non-compliance with critical recommendations by the EAC:

a. Study is not compatible with similar studies done worldwide

b. No suggestions about ramping to reduce downstream impacts

c. No recommendation on free flowing length between two projects

d. No mention of cumulative impact on sediment regime

e. No mention of impact of road construction

f. BBM for eflows not used, despite agreeing to use it before EAC

g. Impact of Sand mining, boulder mining not conducted

h. Impact of specific projects not clearly studied

6. Eflows, one of the most significant issues, handled erroneously: NO ACTUAL ASSESSMENT OF E-FLOWS REQUIREMENTS AS REQUIRED BY TORs

7. No mention of Climate Change, reservoir emissions vis-à-vis cumulative impacts of such massive scale, how the projects would affect the adaptation capacity of the communities and region in the context of climate change

8. No stand taken on three mega projects on Siang Main Stem and other big hydro projects

9. No conclusion about how much length of the river is to be compromised

10. Number of sampling locations: TOR not followed

11. Source of information not given

12. Inconsistency, contradictions in listing of flora-fauna

13. Unsubstantiated advocacy: going beyond the TOR & mandate

14. Other inadequacies of CIA

15. Study should not be finalised without credible Public consultation across the basin.

Division of the Siang Basin into sub basins Phot from : CIA/ CCS Report of the Siang Basin
Division of the Siang Basin into sub basins Phot from : CIA/ CCS Report of the Siang Basin

DETAILED CRITIQUE

1. No mention of social and cultural impacts! In the entire basin study, there is no mention of social and cultural impacts by these 44 projects which will together submerge more than 21,000 hectares of forests and affect the entire Siang Basin adversely. Needless to say, local communities depend heavily on the basin resources like fish, medicinal and food plants, timber varieties for their livelihoods. For example, more than 2000 hectares of multi-cropped, irrigated rice fields will be submerged by Lower Siang Project alone.

Adi Community that will be affected by the dams on Siang Photo with thanks from : Kaushik Shil
Adi Community that will be affected by the dams on Siang Photo with thanks from : Kaushik Shil

The CIA/CCS study needs to be re-conducted, in which social and cultural cumulative impacts are assessed with participation of local communities and downstream communities from Arunachal Pradesh and Assam. It may be remembered that Public Hearing of Lower Siang (in the latest instance, slated to be held on 31st January 2014) had to be cancelled due to a number of procedural issues, and also opposition from local residents [2]. It is incomprehensible how the CIA Study has no assessment of impacts on communities!

2. Downstream impacts on Assam not studied in detail The study assesses impacts specifically on Dibrugarh, Bokaghat (Kaziranga) and Guwahati. However, there are several villages, settlements, tea estates, agriculture, forests etc., on the Right Bank of Siang in Assam after Pasighat. This includes a major part of Dhemaji District of Assam. Impact on this region needs to be assessed. There has been opposition to Siang Dams from places like Jonai from Dhemaji, which have been ignored.[3] 

Meeting protesting against Public Hearing of 2700 MW Lower Siang HEP Photo: Echo of Arunachal
Meeting protesting against Public Hearing of 2700 MW Lower Siang HEP Photo: Echo of Arunachal

According to the model used, the chainage for assessing impacts at D’Ering Sanctuary is between 20-33 kms from Lower Siang Dam. The next chainage is at 102 kms at Dibrugarh. Impacts on the stretch between D’Ering and Dibrugarh, for nearly 70 kilometres are simply not assessed! What can be reason behind this?

Level fluctuations at D’Ering Sanctuary, with Lower Siang, Middle Siyom and Upper Siang Projects is to the tune of 7.2 meters (23.66 feet!!) in lean season. This highlights the need to study impacts on the intermediate zone in Assam between Dering Sanctuary and Dibrugarh. The Study should not be accepted without these assessments.

3. Cumulative Disaster vulnerability, impact of projects on such vulnerabilities, Dam Safety Assessment, risk assessment not done

Upper Siang Stage I, Stage II and Lower Siang are huge projects with direct impact on downstream state. Even as issues of dam safety and risk assessment have gained high significance in Assam as can be seen in Lower Subansiri protests, the basin study/CIA does not include a word on dam safety, cumulative risk assessment, risk of landslips and landslides, seismic zones of projects, past earthquakes in the region, possible mitigation measures, disaster management, etc. There is no assessment of baseline situation about disaster vulnerability of the region and how the projects will change that. By its nature, a CIA/CCS/ basin study is best placed to assess these impacts.

Lanslides are a common feature of this region. Pic shows Yinkiong in Siang II Sub basin where several projects are planned. Photo: Team BHP
Lanslides are a common feature of this region. Pic shows Yinkiong in Siang II Sub basin where several projects are planned. Photo: Team BHP

These points have been raised by KMSS, Assam and others. The Uttarakhand disaster of June 2013 underlines this and even the Supreme Court of India has asked for an assessment of how hydropower projects contributed to disaster in Uttarakhand. Looking at Uttarakhand Disaster as well as protests from downstream Assam where dam safety is a major issue, dam safety needs to be addressed in the CIA/ CCS. In the absence of all this, projects will not be allowed by communities, as can be seen with Lower Subansiri and Lower Siang.

4. Cumulative impacts not assessed on several aspects The study has a sketchy section (Chapter 11) on Cumulative impact assessment.

The minutes of 62nd EAC meeting noted, “The main objective of the study is to bring out the impact of dams being planned on the main Siang River and its seven tributaries on terrestrial and aquatic ecology, plant and animal biodiversity, including wild life, hydrology of the basin, etc.” (Emphasis is as in original.) However, the study has not placed emphasis on assessing these impacts.

Yar Gyap Chu: a River and basin which holds high religious significance for the Buddhists Photo: Kaushik Shil
Yar Gyap Chu: a River and basin which holds high religious significance for the Buddhists Photo: Kaushik Shil

Moreover, the study does not attempt to assess cumulative impacts of all the projects due to:

  • Blasting and Tunnelling: This is not mentioned even once in the entire study! When the disastrous impacts of blasting, tunnelling and related activities are fresh in our minds w.r.t Uttrakhand and Himachal Disasters, it is incomprehensible to see that this section is not mentioned at all in the basin study!
  • Community resources: No mention on loss of agricultural lands, homesteads, displacement, loss of forest rights, etc.
  • Infrastructure development: No mention of the impact of workers colonies, buildings on the society, landscape and cultural aspects, etc.
  • Greenhouse gas Emissions: Considering submergence of more than 20,000 hectares of dense to very dense forests and building of a large number of reservoirs in tropical climate, cumulative impacts on green house gas emissions should have been assessed.
  • Biodiversity, RET Species, Deforestation: While the report deals with these issues very sketchily, there is no statement as to what will be the cumulative impact of 44 projects on the above issues.

5. Non-compliance with critical recommendations by the EAC Interim basin study was discussed in the 62nd EAC meeting in November 2012. The EAC had given some important recommendations at that stage to be included in the study. However, most of the recommendations have not been complied with, these include:

  • Study is not compatible with similar studies done worldwide: EAC had specifically recommended compatibility with global studies. However, Siang CIA is not compatible with any global Basin and Cumulative impact Assessment Study. A Cumulative Impact Assessment is a multi-stake – holder process that assesses the cumulative and indirect impacts as well as impact interactions of the proposed dam or set of dams, as well as existing and planned projects from other sectors, on ecosystems, communities, and identified Valuable Ecosystem Components (VECs) within a specific spatial and temporal boundary. [4]
  • No suggestions about ramping to reduce downstream impact: EAC had specifically asked for ramping study with reference to downstream impacts. However, ramping studies are not done at all, although downstream impacts of the projects in isolation as well as together are huge. 
  • No recommendation on free flowing length between two projects Although Upper Siang I, Upper Siang II and Lower Siang have no free flowing stretch between each other, the study refrains doing any assessments or from making any recommendations in this regard, contrary to EAC’s recommendation. 
  • No mention of cumulative impact on sediment regime 44 projects with several mega reservoirs will have a profound impact on the sediment regime of the rivers as well as downstream impacts thereof. EAC had specifically asked to include sediment balance and impact, which is not discussed in the report. 

The minutes of 62nd meeting of EAC says: “The Consultants were also asked to study and recommend on silt management considering “no dam” and “with dam” scenario as silt substantially impact the ecology and cause sedimentation particularly when its velocity is affected d/s due to construction of dam.” No such study has been conducted. In fact globally, sediment balance on cascade projects is a crucial element of study, which is completely left out in the present study. 

  • No mention of impact of road construction Roads and related activities like deforestation, slope destabilisation, blasting, mining, muck dumping, all the cumulative impacts of peaking operation (needs to be done comprehensively, including the limitations that such operation of upstream projects will impose on downstream projects), etc have a critical impact on fragile geology. Role of roads for hydel projects was significant in Uttarakhand Tragedy in June 2013. EAC had specifically asked for “Impacts due to construction of approach roads”. This point is not touched upon in the report. 
  • BBM for eflows not useddespite agreeing to use it in front of EAC Although the consultant agreed in the 62nd meeting that BBM will be used to assess eflows regime,[5] at the insistence of the EAC, in reality BBM has not been used in the study. The reasons given [6] that BBM is a “prescriptive approach”, “it takes too much time” and “only stakeholder in the basin is river and fish” is wrong, shocking and unacceptable.

The study forgets about the people, biodiversity and other stakeholders. Requirements of BBM were known at the time consultant agreed to use this methodology before the EAC. Is fluvial geomorphology, cultural practices, hydrological requirements and sediment balance not important blocks of BBM study? 

  • Impact of Sand mining, boulder mining not conducted EAC had specifically asked for this study. This is critical as mining of sand and boulders from river bed has severe impact on riverine ecology, bed stability, erosion, flow velocity, etc. However, the study has not even mentioned this issue. 
Yargyap Chu or teh Medicinal RIver Photo: Team BHP
Yargyap Chu or the Medicinal RIver Photo: Team BHP
  • Cumulative Impacts of projects on biodiversity in sub-basins not clearly studied While the study has done impressive job in inventorysing ecological attributes of 11 sub basins, it has fallen woefully short in clearly communicating the individual and cumulative impacts of projects on Valued Ecosystem Components (VECs). This reduces practical application of the report. EAC had brought this up during the 62nd meeting. 
  • Length of rivers to be assessed for downstream studies As per the minutes of the 43rd meeting of EAC held in Nov 2010 the report was to recommend: “What may be criteria for downstream impact study in terms of length of the river downstream to the tail water discharge point and what may be the parameters of such a study”.

The same EAC meeting recommended: “If the states do not change their policy of allotting elevation-wise river reaches for hydropower development, what criteria the EAC may adopt in restricting the river reach for hydropower development. Alternatively, what should be the clear river length of uninterrupted flow between the reservoir tip at FRL of a downstream project and the tail water discharge point of the immediate upstream project.”

“For peaking stations, what extent of diurnal flow variation may be considered safe for the aquatic life. There are examples where the release is drastically reduced during the long time for reservoir filling and huge discharge flows through the river during the few hours of peak power generation. This is detrimental to the aquatic environment of the downstream stretch of the river.”

“For muck disposal, what may be minimum distance that must be maintained between the outer boundary of the muck disposal sites and the river bank.”

6. Eflows, one of the most significant issues handled erroneously: NO ASSESSMENT OF E-FLOWS REQUIREMENTS The CIA has not done assessment of e-flows requirements at various locations keeping in mind the upstream projects. The very crude assumption it has made is by dividing the entire basin in Mahseer and Trout Zone and assuming certain water depths for these fish in lean, monsoon and non-lean, non-monsoon months. Several fisheries scientists do not support this classification or accept these two species alone as representing the ecosystem. The study assumes 50 cms water depth for Mahseer and 40 cms depth for Trout in lean season.[7] Then flows for maintaining that particular depth are calculated and recommended. Added criteria is that depth should not be less that 50% pre-project river depth. 

Luxuriant Biodiversity of the Siang basin Photo: Team BHP
Luxuriant Biodiversity of the Siang basin Photo: Team BHP

Here it is worth quoting the minutes of 62nd meeting of EAC:

“The EAC asked the Consultants to take comprehensive view of the environmental flow assessment and make final recommendations for each stretch. Committee asked to study international literature available on the subject and use the best suitable methodology for this exercise suiting to Indian conditions. The Consultants said that most appropriate method such as Building Block Methodology would be used by them. Detailed habitat simulation modelling for the entire year needs to be considered so that flow release requirement can be established not only for lean season but also for monsoon season and other months… The Consultants while submitted that public hearing as such is not a part of the study as per ToR, informed that BBM entails expert and stakeholder‟s consultations and would be followed.”

This has clearly not been done.

This approach is incorrect on various counts:

  • The habitat requirements of Mahseer and Snow Trout are higher than the assumed 0.5 m and 0.4 m. This has been confirmed by several fisheries scientists. The WII study on Upper Ganga Projects recommends a minimum of water depth of 1 meter for adult Mahseer (Tor species) (Table 7.6, Page 148) and at least more than 50 cms for Trouts (Schizothorax sps) (Table 7.8, Page 150). Incidentally these tables from WII Cumulative Impact Assessment have been used in the report without stating the source or credit. SANDRP has interacted with several fisheries experts who claim that 0.5 meters is a completely inadequate depth for adult Mahseer.
  • This faulty assumption has led to low eflows recommendations of 15% of average flows in non-lean non-monsoon months for Heo and Tato I Projects, this is lower even that EACs norms. This assessment and recommendations are clearly unacceptable.
  • The criteria of 50% water depth wrt pre-project depth is arbitrary and without any scientific justification. For Himalayan rivers with a stable hydrograph like Siang, 50% depth reduction is very high. As can be seen from Eflows chapter, after 50% depth reduction, most river stretches have less than 100 cms depth, which is just about the minimum depth required for an adult Mahseer or a spawning snow trout. However, Mahseer and trouts are abundant in these rivers. This just indicates the problems behind 50% water depth criteria. This should not be accepted.
  • The entire eflows discourse is not based on assessment of environment flows for various objectives and ignores most critical requirements.

    Division of the Basin into Trout and Mahseer Zones Photo: From CIA/ CCS Report of Siang Basin
    Division of the Basin into Trout and Mahseer Zones Photo: From CIA/ CCS Report of Siang Basin

7. No mention of Climate change In the entire study, there is no mention of climate change, how changing climate would affect the rivers and projects and how project construction would add to climate change impacts and how they will reduce the adaptation capacity of the people and environment to cope with the changing climate. Deforestation to the scale of 21000 hectares of thick forests and complete loss of a biodiversity rich free flowing river has strong impacts in the context of climate change and these need to be assessed.

8. No stand taken on three mega projects on Siang Main Stem and other big hydro projects Three mega projects on Siang Main stem, namely the 6000 MW Upper Siang I, 3750 MW Upper Siang Stage II and 2700 MW Lower Siang will have a huge destructive impact on the entire ecology and society of the region. These three projects together will submerge 18,100 hectares of dense forest area and will convert entire river length between these projects: 208.5 kilometers, into unbroken sequence of reservoir-dam-reservoir-dam-reservoir-dam, with no flowing river between two consecutive projects. The study has not even attempted assessment of length of flowing river required between the projects and eflows allocation for this stretch.

L Section of the Siang River with 3 mega projects which do not leave any flowing river between them. Photo from: CIA/ CCS Report of the Siang Basin
L Section of the Siang River with 3 mega projects which do not leave any flowing river between them. Photo from: CIA/ CCS Report of the Siang Basin

 

Oppsition to Public Hearing of 2700 MW Lower Siang Project Photo: Echo of Arunachal
Oppsition to Public Hearing of 2700 MW Lower Siang Project Photo: Echo of Arunachal

These projects in a cascade, destroying a complete flowing river are against the principle of sustainable development and even EAC’s minimalist norm of 1 km of flowing river between projects. A CIA/ CCS study should have raised this issue strongly as these projects are undoing most of the other recommendations. However, the study refuses to take an independent stand against these projects and fails its mandate of being an independent study. 

Yamne Basin, claimed to host highest biodiversity in Siang is planned to have 4 projects back to back! Photo: Abor Country Travels
Yamne Basin, claimed to host highest biodiversity in Siang is planned to have 4 projects back to back! Photo: Abor Country Travels

Similarly the study does not take stand on other big hydropower projects proposed in the basin. Most of the projects it has recommended to be dropped are relatively smaller projects, none are big ones. This shows bias of the consultants. The report is also not in consistent in its recommendations. 

Positive suggestions: The study recommends dropping 15 projects and keeping some tributaries free from any hydel development. It also calls for including small hydel projects under the ambit of EIA. These suggestions are important and should be accepted. EAC should immediately ask MoEF to recommend changes in the EIA notifications to include all hydro projects above 1 MW. 

The study has also asked for change in parameters of Tato II, Hirong, Naying and Siang Middle HEPs so that at least 1 km of river is left flowing between them. This is welcome and EAC should accordingly ask for changes in these projects. But the report has not done any study in this regard. 

9. No conclusion about how much length of the river is to be compromised One of the TORs of the study include, as per the minutes of the 43rd meeting of EAC held in Nov 2010: “Considering the total length of the main river in the basin and the HEPs already existing and planned for future development, how many more HEPs may be allowed to come up. In other words, how much of the total length of the river that may be tunneled inclusive of the tunnelling requirement of all the projects that have been planned for development so that the integrity of the river is not grossly undermined.” (Emphasis added.) The report does not do an assessment on this. The B K Chaturvedi committee had recommended that not more than 50% of the river can be compromised. However, this report was to study this aspect, but has neither studied this, nor done analysis or reached any conclusion. 

10. Number of sampling locations The minutes of 49th meeting of EAC held in April 2011 concluded that the number of sampling locations will be decided based on this criteria: 3 sites for project with over 1000 MW installed capacity, 2 sites for projects with 500-1000 MW installed capacity and one site for projects below 500 MW installed capacity. In addition 2-3 locations will be selected in the downstream areas. 

Menchuka_Team BHP

If we go by this criteria, and considering 44 planned projects listed in the CIA, there should have been 15 locations for 5 projects with capacity 1000 MW or above, 4 for two projects with 500-1000 MW capacity and 37 for projects below 500 MW capacity, in addition to the locations in downstream areas. The CIA has not followed these directions from EAC, else sampling locations would have been about 60 and not 49 as included in the report. 

11. Source of information not given Several annexures in Vol II (this too should have been put up on EAC website, but has not been, we got it from other sources), including Annex I says that it is prepared from “PREPARED FROM SECONDARY DATA & FIELD SURVEYS”, but which information has been obtained from field surveys and which information is obtained from which secondary source is not given. In absence of this it is difficult to verify the claims. 

12. Inconsistency, contradictions in listing of flora-fauna

– In volume II, Annex I titled “LIST OF PLANT SPECIES REPORTED FROM SIANG BASIN”, which is supposed to include data from secondary sources and field surveys lists 1249 angiosperms and 11 gymnosperms. However, the pteridophytes listed in Annex II titled “LIST OF PLANT SPECIES RECORDED FROM DIFFERENT SUB BASINS OF SIANG DURING FIELD SAMPLING” do not find mention in Annex I or Annex III a/b/c.

Out of 11 Gymnosperms listed in Annex I, only two figure in Annex II, rest do not get listed in any of the sub basins.

– The species Dicliptera bupleuroides and Phlogacanthus thyrsiflorus listed in Annex 1 Angiosperms do not get listed in any of the sub basins.

Section 4.1.4 says Paphiopedilum fairrieanum is an endangered and Cymbidium eburneum is an endemic and vulnerable orchid species in Siang basin, however, these species do not get listed in any sub-basins in Annexure II or in any season in Annexure III. Same is the case with endemic orchid species of Siang basin, namely Calanthe densifloraDendrobium cathcartiiD hookerianumGaleola falconeriLiparis plantaginea and Paphiopedilum fairrieanum.

– Similarly among the Rhododendron species, threatened species like Rhododendron boothii, threatened species like Rhododendron falconeri, newly discovered and critically endangered species like Rhododendron mechukae (even though it was found in Yargyap Chhu sub basin), Rare species like Rhododendron arizelumRhododendron dalhousieaevar. rhabdotum,Rhododendron kenderickii, and R edgeworthii are not found in Annex II or III.

Rhododendron Species of Siang Basin Photo: Abor Country Travels
Rhododendron Species of Siang Basin Photo: Abor Country Travels

Endemic cane species Calamus leptospadix also do not figure in Annex II or III.

– The CIA says, “The Siang basin as discussed above is also very rich in floristic resources and there are still number of areas in the basin which are either under-explored or yet to be explored”, however, a CIA is supposed to make recommendation how to ensure that such areas are explored before any more projects are taken up, but this report makes no recommendation in this regard.

– The CIA says that 17 Near Threatened (regional level) medicinal plants, 46 endemic species and additional 55 endemic species are reported in Siang basin, but CIA neither gives list of them, nor locations, how these will be affected by hydropower projects or recommendations to conserve them.

– The scope of study given in Annex 1, Vol. I says: “Preparation of comprehensive checklist of flora (Angiosperms, Gymnosperms, Lichens, Pteridophytes, Bryophytes, Fungi, Algae etc.) with Botanical and local name.” However, we do not find the local names listed.

The situation with respect to fauna species is no different, with similar inconsistencies, lack of specific sub-basin wise situations and recommendations to conserve them. This is true in case of mammals, birds, butterflies, amphibians, reptiles, inspects as also aquatic biodiversity. While the report makes some impressive general statements, but is found to be lacking in specifics mentioned above.

This sample list of inconsistencies and gaps shows that there are serious problems in these lists and the consultant should be asked to remove all these inadequacies. There is also need to get these lists peer reviewed by credible independent experts like those from WII.

13. Unsubstantiated advocacy: going beyond the TOR & mandate The CIA says in last para in section 12.3 titled “Downstream Impacts”, “Keeping the substantial storage requirement in Siang, storage projects in Siang needs to be re-configured, which may lead to merging of Siang Upper Stage I and II into single project to create storage.” There are several other such sentences in this section and elsewhere. This is uncritical acceptance of CWC assertions and is an advocacy for more storage projects in the name of flood moderation. This is clearly uncalled for in a CIA report and such uncritical acceptance of CWC assertions is also not what is expected from a CIA. In any case, this is also beyond the mandate of the CIA.

14. Other inadequacies of CIA

– The CIA does not contain the TOR, the scope of the study given Annex 1 of Vol I is not the TOR.

– 49th EAC meeting had asked for inclusion of Assam Experts in the study, but the study does not mention this.

– The 43rd EAC meeting held in Nov 2010 had asked for inclusion of assessment of the impacts of the projects on wetlands, floodplains, river morphology, sediment transport/ erosion/ deposits, impact on human activities and livelihoods and recommend necessary measures in these regard. The report mentions all these aspects, but fails to assess these impacts and make necessary recommendations.

– The Preface of the CIA claims that the TAC reviewed the draft interim report in May 2012 and draft final report in Sept 2013. We have checked the minutes of the TAC meetings and find that in May 2012 there was no TAC meeting. The 114th TAC meeting happened in March 2012 and 115th TAC meeting happened in July 2012, neither of the minutes include any mention of Siang basin study.

– The Sept 2013 meeting also did not include this report in its agenda. The report seems to be making false claims in this regard, they should be asked to provide minutes of the TAC meeting where this was discussed and what were the outcomes.

15. Study should not be finalised without credible Public consultation across the basin A comprehensive Siang Basin Study will give a cumulative picture of impacts on basin and on basin residents, including downstream population in Assam. The study is supposed to include important findings, which are separate from individual EIA reports. Even MoEF’s Strategic 12th Five Year Plan notes: 

Paddy feilds in Siang Basin. Agriculture finds no place in the CIA Photo: Kaushik Shil
Paddy feilds in Siang Basin. Agriculture finds no place in the CIA Photo: Kaushik Shil

“Of late, the limitations of project-level EIA are being realized internationally. Project EIAs react to development proposals rather than anticipate them, so they cannot steer development towards environmentally “robust” areas or away from environmentally sensitive sites. Project EIAs do not adequately consider the cumulative impacts caused by several projects or even by one project’s subcomponents or ancillary developments. The new trend is to address environmental issues earlier in planning and policy making processes. This could be done through cumulative impact assessment.” 

However, such a study cannot be complete without consultations held across the basin in a credible way with full information to the communities in the language and manner they can understand. The study should not be accepted without a credible process of Public hearing [8].

CONCLUSION We would like to urge the EAC NOT TO CONSIDER INDIVIDUAL PROJECTS UNLESS THE CIA/CCS Study is APPROVED through a participatory process. In Siang basin, the EAC has already granted EC to 2 projects, Scoping clearance to 16 projects (of which PH has been held for 8 projects) and nine projects will not need EC as they are below 25 MW. This renders the whole exercise of CIA/CCS meaningless!

We urge the EAC to consider all projects from Siang Basin only after CIA-CCS is finalised and keep the scoping and environmental clearances of projects in abeyance till then. 

Prayer Flags in Siang basin Photo: Team BHP
Prayer Flags in Siang basin Photo: Team BHP

Looking forward to you point-wise response,

Yours Sincerely,

Parineeta Dandekar, Himanshu Thakkar SANDRP

(with inputs from Parag Jyoti Saikia)

END NOTES:
[1] SANDRPs assessment of Lohit Basin Study, Bichom Basin Study, Subansiri Basin Study and Upper Ganga Cumulative Impact Assessment.
[2] – This news was covered widely in the media – Arunachal Pradesh Groups Ask MoEF to Cancel Illegal Public Hearing of Lower Siang 2,700 mw Lower Siang Hydro Electric project runs into rough weather ,  GreenTalk: Activists to protest public hearing for dam on Arunachal’s Lower Siang river,  Protests against Siang dam,  Anti-dam stir hits Arunachal too, AASU,  TMPK oppose move on Lower Siang project,  Public hearing for Lower Siang project opposed,  Several organisations demand scrapping of Lower Siang project.
[3] Jonai meet opposes Arunachal dams
[4] Some such relevant benchmark norms include:
The World Commission on Dams Report, Nov 2000
International Rivers, Dam Standards: A Rights Based Approach, January 2014
The European Commission’s Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions (1999)
The U.S. NEPA Analysis Guidance Manual (2007)
The Canadian Environmental Assessment Agency’s Cumulative Effects Assessment Practitioners Guide (1999)
– International Finance Corp’s (The World Bank Group) “Good Practice Note on Cumulative Impact Assessment and Management”, Jan 2013
– The World Bank’s “Sample Guidelines: Cumulative Environmental Impact Assessment for Hydropower Projects in Turkey”, Dec 2012
[5] “It was informed that BBM would be applied in addition to other applicable methodologies for working out EFR. The Consultants while submitted that public hearing as such is not a part of the study as per ToR, informed that BBM entails expert and stakeholder’s consultations and would be followed.” 62nd EAC Meeting, November 2012
[6] Section 9.9 of the CIA CCs Report
[7]“ To assess the minimum environment flow requirement in lean season a criteria has been defined that projects in the Mahseer zone needs to provide a minimum 0.5 m average depth in the initial reach studied, and for projects in the trout zone this depth is considered as 0.4m.” (Section 9.6.1 Environmental Flows Assessment in Lean Season)
[8] Himachal Pradesh Government had conducted such a Public Hearing on Satluj Basin Study recently
 

Post Script:

A good report on the Siang Basin CIA: Damn that river Author: Karthik Teegalapalli Posted on: 13 Oct, 2014: http://www.downtoearth.org.in/content/damn-river

Arunachal Pradesh

Arunachal Pradesh Groups Ask MoEF to Cancel Illegal Public Hearing of Lower Siang

22nd January 22, 2014

Dr. V. Rajgopalan

Secretary,

Ministry of Environment and Forests,

New Delhi.

Sub: 2700 MW Lower Siang project – Cancel Illegal Public Hearings proposed for January 31st 2014.

Dear Dr. Rajgopalan,

We write to you on behalf of the Forum for Siang Dialogue (FSD), Siang Peoples’ Forum (SPF) Sirit-Siyom Banggo Dam Affected peoples’ Forum (SSBDAPF), Siang Bachao Andolan (SBF), Nyiko Bachao  Forum (NBF) to seek cancellation of the Three public hearings proposed to be held for the 2700 MW Lower Siang hydroelectric project in the East Siang, West Siang and Upper Siang districts of Arunachal Pradesh  on January 31, 2014.

Through a notification dated 30th December 2013 published in the Arunachal Times dated 31st December 2013 the Arunachal Pradesh State Pollution Control Board (APSPCB) has announced the conduct of public hearings for the 2700 MW Lower Siang project in three districts of Arunachal Pradesh. A scanned copy of the notice is attached for reference (Annexure 1).

There are a number of legal reasons due to which the public hearings need to be cancelled, here are a few of them:

1)      Public hearing on the same day and time in the West Siang, East Siang and Upper Siang districts of Arunachal Pradesh 

There are a number of local persons/clans/local communities who have land directly affected by the Lower Siang project cross-cutting the district boundaries. Such persons/clans/local communities will not be able to exercise their legal right to participate in all the public hearings in the districts where their ancestral lands are affected, since they are being held on the same day, at the same time. This is a gross violation of the letter and spirit of the EIA notification 2006 as well as the article 14 of Right to equality and article 19, the freedom of Speech under the Constitution of India.  

It is crucial that the public hearings are held in the three districts with sufficient days in between to enable the affected persons to participate in the public hearings wherever their ancestral lands are affected.

It cannot be argued that they should put their viewpoints in one of the public hearings in one of the districts. It is their legal right to participate in the public hearings wherever their lands are affected. This is a clear ground for cancellation of the public hearings and re-announcement  by keeping sufficient days in between hearings being held in different districts.

2)      Location of public hearing venue more than 100 km. away from 11 villages

The public hearing venue fixed for the East Siang district is Pasighat, the district headquarters, in the downstream-affected area of the project. While the APSPCB is welcome to organise a separate public hearing for the downstream-affected area, this is an extremely inconvenient location for the upstream-affected villagers in the East Siang district who are directly affected. And Pasighat town is nowhere listed as an affected village/area/circle in the EIA,EMP and Social Impact Assessment report of the Project Proponent. (Attached is the list of the affected villages as prepared by WAPCOS for the project.

The Public Hearing for Upper Siang District is also fixed at Katan which is 40 Kms away from Geku villages, which is encompassing the majority of the villages to be affected by the dam and above all there are not even a single Govt/Public or Private transport plying/ operating there. And the only village which is going to be completely submerged happens to be Pongging village under Upper Siang district, and the people have to walk on foot covering a distance of 17 kilometers to reach Katan as there is no Public/Private/Govt Transport system plying there.

Out of the 25 villages directly affected in East Siang district, at least 11 are more than 100 kms. away from the public hearing venue! In fact Riga village, one of the severely affected village under East Siang District is 172 km. away from Pasighat. A further nine villages are 60 – 100 km. away. Please note that 6 (Six) villages have to walk for up to 12 km. even before reaching the motor able road.

It is clear that the public hearing venue in East Siang district has been decided in order to disallow active participation of directly affected villages. This is completely unacceptable as per the letter and spirit of the EIA notification 2006 and various court orders/judgements on the need for proximity of the public hearing venue to the affected area. Public hearings cannot be located as per convenience of government officials who do not want to travel to affected areas and stay in the district headquarters. This another strong ground why the public hearings announced for 31st January 2014 have to be cancelled immediately.

And Chapter II U/s 5 of The Right to Fair Compensation and Transparent Land Acquisition Relief and Resettlement Act 2013 also clearly states that Public Hearing should be held in the Affected area and not otherwise.

3)      Siang river basin cumulative impact assessment study is not complete and placed in the public domain at designated places before public hearing

Section 9.4 of Form I of the EIA notification requires that cumulative impacts of a project are examined during the EC process. Further the Ministry of Environment and Forests (MoEF) has issued an OM dated 28th May 2013 stating that it will consider hydropower projects based on cumulative impact assessment and carrying capacity studies. The OM is attached as Annexure 2.

The OM states that:

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

An important aspect of Appraisal done by EAC/MoEF is detailed scrutiny done of all documents including public consultation proceedings. As per the EIA notification 2006 (section 9.4 of Form I) and the MoEF’s OM dated 28th May 2013 if cumulative impacts studies have to be the basis for decision-making, then such studies have to placed in the public domain at designated places 30 days prior to the public hearing.

However, the Siang river basin cumulative impact assessment is neither complete nor placed in the public domain at the designated places prior to the public hearing. Please note that this study currently underway is looking at all projects in the Siang river basin (Siang and its tributaries).

Although we disagree with the logic that the first project could come up without ‘insisting’ on a cumulative impact assessment study (since that project could be the most ecologically and socially destructive), in this case Lower Siang is NOT even the first project in the river basin for which either a public hearing is being held or being considered for environmental clearance. A number of public hearings have been held for other projects in Siang river basin and projects have also been already considered for Appraisal by EAC/MoEF. In fact 1000 MW Siyom and 700 MW Tato II project in the Siang river basin have already received final environmental clearance from the MoEF.

By no stretch of imagination is the 2700 MW Lower Siang project the first project being considered in the Siang river basin. Therefore as per the MoEF’s own OM dated 28th May 2013, Siang river basin cumulative impact assessment will first have to be completed. Public hearing should only be held after this is completed and these reports are placed in the public domain at least 30 days before the hearing.

Keeping all this in mind we strongly urge the MoEF to direct the APSPCB to cancel the Illegally notified public hearings proposed for the 2700 MW Lower Siang project on 31st January 2014.

Thanking you,

Sincerely,

Vijay Taram  Oyar Gao   Tayek Mize  Tasong Mibang    Takar Komut   Kento Jini  Reken Ingo

Forum for Siang Dialogue, Siang Peoples’ Forum, Sirit Siyom Banggo Dam Affected Peoples’ Forum, Siang Bachao Andolan, Nyiko Bachao Forum

Cc:

1) EAC on River Valley & Hydroelectric projects

2) Chairperson, Arunachal Pradesh State Pollution Control Board

3) Member Secretary, Arunachal Pradesh State Pollution Control Board