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.
Sub: Lower Siang HEP (2700 MW) EIA-EMP Report not fully available on APSPCB website; many links not working; Public hearing will be illegal without full EIA-EMP in public domain
This is regarding the EIA-EMP report of Lower Siang HEP (2700 MW) uploaded on APSPCB website. The public hearing for the Lower Siang HEP is schedule to be held on 31st January 2014.
As per the EIA notification of 2006 the full and complete EIA and EMP report should be made available on State Pollution Control Board website, in this case your website at least 30 days in advance of public hearing date as this is necessary not only for the affected people but also for wider consultations for concerned individuals and groups, as required under the EIA Notification. However, full EIA-EMP are not available on your website, with at least three chapters of EIA, one chapter of EMP and several annexures not opening, even ten days before the public hearing date.
It is very surprising and confusing to most people to see that the reports have been uploaded in 145 parts totaling 320 MB file size. These documents should have been uploaded as five reports as done for EIA-EMP report of several other projects. However, we have gone through all the files available on APSPCB website and based on perusal of these files, we find that crucial parts of the statutorily required documents are not available on APSPCB website. The list of missing chapters and annexures with the name of the report is given below. A screenshot of the links to these chapters are also attached and annexure as mentioned below.
Chapter 2 – CONCEPT & METHODOLOGY
Failed to upload
Chapter 10 – AQUATIC ECOLOGY FISH & FISHERIES
An incomplete, possibly irrelevant table on a 1-page
Chapter 12 – CONSTRUCTION METHODOLOGY
Failed to upload
Chapter 10 – REHABILITATION & RESETTLEMENT PLAN
Failed to upload
Fig 3.3 – Gradient profile of Siang river including its major and minor tributaries of the Siang river catchment
Fig 3.4 – Gradient profile of the Siang river with its main tributaries in the Siang river catchment area
Fig 7.3 – Land use/ land cover map of the submergence area of the proposed Lower Siang H.E. project
Failed to upload
Fig. 2.3 – Drainage map of the free-draining catchment area of the proposed Lower Siang H.E. project
Fig 7.3 & 7.4 – Cross-section at the proposed dumping site
Incomplete, failed to upload
We therefore request you to upload these chapters immediately and also upload smaller size single documents of each report for the perusal of the local people and all concerned. In the meanwhile, since non availability of full EIA-EMP on pollution control website a month before the public hearing is a statutory violation, we request you to cancel the public hearing now slated for Jan 31st, 2014 as holding a public hearing without full EIA-EMP on the APSPCB website a month before the PH will not be legally tenable.
Thanking you, we will look for your early response,
Parag Jyoti Saikia
South Asia Network on Dams, Rivers & People (SANDRP), 86-D, AD Block, Shalimar Bagh, Delhi – 110 088
Lohit Basin Peoples’ forum for Project Affected Families
Tezu, Arunachal Pradesh
Press Note January 20, 2014
Kalai II Public hearing was full of violations, must be cancelled
Affected people intimidated, beaten up and not allowed to speak by police & politicians
The statutory Public hearing conducted on Saturday, January 18, 2014 at Hawaii in Anjaw district in Arunachal Pradesh about the proposed 1200 MW Kalai II hydropower project in Lohit River Basin was marked by some serious violations that included intimidation of the affected people who wanted to raise questions and speak up, several people getting beaten up by the police and others, people that were not allowed to speak up, taking over of the public hearing by the MLA with his six hour long speech and public hearing stretched beyond midnight, apparently to manipulate the minutes of the public hearing. All these are serious violations of all the accepted norms of public hearing and cannot be acceptable. This is in addition to many procedural violations that were communicated through our written letter to Arunachal Pradesh State Pollution Control Board, Deputy Commissioner of the Anjaw district and members of the Expert Appraisal Committee on River Valley Projects in Union Ministry of Environment and Forests, the letter remains unanswered.
The hearing began at 10 AM with officials of WAPCOS (the EIA consultant agency) briefing the public about the EIA report. When Mr. Bihenso Pul, one of the project affected person stood up to question the officials on their false claim that a consultation was held with the affected land owners in the third stage of EIA, all of a sudden, the local MLA Mr. Kalikho Pul along with his close relatives and workers started threatening him and warning him of dire consequences. Witnessing this, the whole project affected public who had come to take part in the public hearing stood up in support and defense of Mr. Bihenso Pul. Following this, the personnel of Arunachal Pradesh Police started indiscriminately assaulting and lathi charging the public. Mr. Soti Tawsik, a Gram Panchayat Member from Nukung village from INC ticket was also grievously injured due to the lathi charge by police personnel when he tried to raise questions and express his opinion on the project. He was referred to Dibrugarh for further treatment as he was in a critical condition. Others injured include Baah Tawsik and Checheso Tawsik.
During the presentation on EIA by WAPCOS (it is an agency under Union Ministry of Water Resources, which itself functions like a Big Dam lobby and hence there is conflict of interest in WAPCOS doing any impact assessment work since impact assessment is supposed to be done by an unbiased, independent agency. Moreover WAPCOS is also involved in feasibility studies and detailed project reports for justification of projects, its track record is also very poor with both Expert Appraisal Committee and Forest Adivosry Committee of MoEF having crticised their work), even the illiterate villagers started expressing resentment over WAPCOS’s complete lack of knowledge on the topology, flora and fauna of the project affected region which was evident from the multiple factual mistakes made by the during the presentation. They were showing pictures of common fishes found in Parshuram Kund region and telling the villagers that the fishes were photographed from must higher elevation Kalai II project affected region. They did not even recognize the species of common Mynah available in the region and were calling it with different names.
The Public hearing was completely dominated by Shri. Kalikho Pul, the local MLA who spoke for 6 hours at a stretch starting from 6 pm, trying to convince the project affected families with misleading facts, while his workers and the Police personnel were highhandedly suppressing and manhandling every single person who stood to express his opinion or raise a question. Mr. Kalikho Pul also levelled baseless allegation of corruption against Mr. Bihenso Pul who is not even a government servant. Eventually, after being frustrated by the arbitrary, coercive and one sided conduct of the Public hearing, the project affected people started leaving the venue shouting slogans against the MLA and the administration stating they would never succumb to such illegitimate pressure tactics. If the public had not shown restrain and maturity during the mindless repressive act by police the incident could have taken an extremely dangerous turn.
An overwhelming about 60% of the affected people are against the project now being taken up. Even those 30% of affected who may be giving conditional support, have put forward a list of 23 conditions that are yet to be responded to. The rest 10% of the affected are as yet undecided. It is thus clear that the project as it stands do not have public support and with people not allowed to participate in the public hearing, the opposition will only get stronger. It may also be added that the same WAPCOS had done a shoddy EIA of the under construction Lower Subansiri project that remains stall for over 25 months now due to public opposition. The fate of Kalai II, if pushed without proper credible assessment of the project and basin level impacts and credible public hearing, will not be any different.
Finally, all the members of public left the meeting venue. The request to postpone the Public hearing in view of the incident to the next day by Mr. Bihenso Pul too was turned down and the hearing continued past 12 in midnight with only the Deputy Commissioner of Anjaw District, officials of Reliance Power Limited, Officials of WAPCOS & APSPCB and Mr. Kalikho Pul, Local MLA Anjaw district present during the meeting. This was clearly done to ensure finalization of manipulated minutes of public hearing.
This public hearing must be cancelled, an independent, credible enquiry conducted in the way in was sought to be conducted and in any case a fresh public hearing should be ordered after taking care of all the legal violations.
Kalai II HEP – Status of compliance with TOR in EIA and EMP:
Serious non compliance of EIA-EMP: EIA-EMP must go back to consultants WAPCOS
Public hearing based on such EIA-EMP will not be legally valid
The EIA EMP reports of the proposed 1200 MW Kalai II HEP in Lohit basin in Anjaw district in Arunachal Pradesh has been put up on the Arunachal Pradesh Pollution Control Board in advance of the public hearing slated for January 18, 2014. The EIA-EMP report is supposed to comply with the Terms of Reference (TOR) for the EIA-EMP given by the EAC and MoEF, this is statutory requirement as per the EIA notification of Sept 2006. We have just checked this compliance and find that the EIA and EMP reports have not fulfilled a very large number of the TOR (Terms of Reference) that the project was to cover in EIA-EMP as per the TOR clearance given for the project on 9.12.2009. Such EIA-EMP will clearly not be acceptable even from statutory and legal point of view and cannot be basis for a public hearing. Hence Arunachal Pradesh State Pollution Control Board (APSPCB) and MoEF should immediately cancel the public hearing and ask the EIA-EMP consultants to comply first with the TOR.
Invalid extension since EIA-EMP does not comply with the TOR Here it may be added that as per minutes of 70th EAC meeting dated Dec 10-11, 2013, “In the mean while, MOEF issued an Office Memorandum dated 22-Mar-10 which stipulates that the proposals which were granted TORs prior to the issue of this OM, the EIA / EMP reports should be submitted after public consultation no later than four years from the date of the grant of the TORs with primary data not older than three years. Thus the TOR issued to the project on 9th December 2009 is valid up to 8th December 2013”. By this norm, the Kalai II TOR clearance should have lapsed on Dec 8, 2013. However, EAC decided to give an extension to TOR for this project, since the project developer claimed, as noted in EAC minutes, “With the completion of all the studies, the draft EIA/EMP report for 1200MW Kalai-II HEP was prepared and submitted by the developer to Arunachal Pradesh State Pollution Control Board (APSPCB) vide letter dated 31st July 2013…”. However, this assumes that the EIA-EMP submitted complies with the TOR given by MoEF. But this analysis shows that there is serious non compliance of the EIA-EMP with the TOR and hence submission of such fundamentally inadequate EIA-EMP cannot be a valid reason for providing TOR extension beyong legally stipulated period.
A list of TOR noncompliancein the EIA-EMP is given below.
Noncompliance in EIA Report:
Geological and Geophysical Aspects
Regional Geology and structure of the catchment – some details only about has been mentioned in the EIA, the latter is not available
Seismicity , tectonics and history of past earthquakes in the area – the EIA only mentioned about seismicity, the latter two has been completely ignored
Critical review of the geological features around the project area – not available
Impact of project on geological environment – not available
Justification for location & execution of the project in relation to structural components (Dam height) – not available
Graph of 10 – daily discharge before and after the project at the dam site immediately below the dam should be provided i n the EIA study – Not available
The TOR mentioned “An elementary stream gauging station should be established at a suitable location downstream to the Dam site of the project” and “Installation of two Rainfall Gauge Stations at upstream of dam site” but none of these has been complied with.
Surprisingly the EIA also mentioned “No gauge and discharge (G&D) data is available at the Kalai-II project site or in the neighborhood.”
1) “Cropping and horticulture pattern and practices in the study area” – no mention of this in the EIA
2) Regarding identification of rare and endangered flora and fauna the EIA report mentioned only one “During the study in various seasons in Kalai-II HE project area, following IUCN Red List of threatened plant, Lagerstroemia minuticarpa falls under endangered category. Rest of the species are common in Arunachal Pradesh. However, this species though observed in the study area but not found in the land to be acquired for the project.” (section 8.7 page 8 -22) This is a strange claim that the species is observed in the study area but not found in the land for the project.
3) Fish and Fisheries
a) The 5 location of study of Fish migrations & Breeding grounds was not done
b) Impact of Barrage building on fish migration and habitat degradation was not studied
c) Overall ecological impact upto 10 Km d/ s from the confluence of the TRT with the river or reach of the river in India have not been not studied. The impact of untreated and waste water into the river was not studied and no alternatives explored.
4) In the part of impact prediction, impacts on flora and fauna due to changed water quality has not been assessed
Socio Economic aspects In terms of Socio-economic aspects the following should have been included in the EIA report.
· Land details*
· Demographic profile
· Ethnographic Profile
· Economic structure
· Development profile
· Agricultural practices
· Cultural and aesthetics sites
· Infrastructure facilities: education, health and hygiene, communication network, etc.
· Impact on socio- cultural and ethnographic aspects due to Construction of Barrage
But the EIA does not do several of these profiles and limits itself to – Demographic profile, Educational levels, Occupational Profile, Land holding pattern, Assets owned and Livestock and other socio-economic parameters etc.
In page 11- 8 EIA report says “Impacts on cultural, archeological and religious properties Monuments of cultural/ religious/ historical/ archaeological importance are not reported in the project area. Thus, no impacts on such structures is envisaged.” However, the EIA should have looked into the impact of project on places of cultural, religious importance for the local communities.
Impacts related to Land The EIA ignores what has been suggested in terms of impact prediction for land. The EIA completely ignores –
a) Changes in land use and drainage pattern
b) Changes in land quality including effects of waste disposal
c) River bank and their stability
d) Impact due to submergence
However, in page no 10-23 in the section “Impact of Impoundment on Landuse” the EIA mentions: “The construction of the dam would form the reservoir which will submerge about 640 ha of area in upstream. The area witnessed jhum/shift cultivation practiced by local inhabitants. Submergence of the area would not impact much on the prevailing land use pattern.” This is a false and misleading statement since in the hilly areas of Arunachal Pradesh, shifting cultivation is the main process of cultivation and submergence of such a large area is sure to have impacts on land environment.
TOR Noncompliance in Environment Management Plan:
Under Catchment Area Treatment Plan, the TOR letter had asked the project proponent to prepare 5 thematic maps v i z . Slope map, Drainage map, soil map, Land use/ Land cover Map, Aspect map. Basing on these maps an Erosion Intensity map should have been prepared. But the EMP only has two maps Slope map and Land use Map. No Erosion Intensity map was prepared.
Under Compensatory Afforestation Plan it was mentioned that “The choice of species for Afforestation should be suggested and the proper sites for the same should be demarcated on the maps.” There is no map in the EMP report’s chapter on Compensatory Afforestation Plan.
Under Greenbelt Plan the scoping clearance asked for “….suitable plant species should be recommended with physical and financial details. A layout map showing the proposed sites for developing the green belt should be prepared.” But the EMP report chapter on greenbelt does not at all comply with it. It makes no mention of any species and no map had been prepared.
The TOR clearance letter under “Reservoir Rim Treatment Plan” asked for “Layout map showing the landslide/ landslip zones should be prepared.” But the maps provided in chapter 17 of the EMP report are not at all clear and the when zoomed in they get blurred. So the sites, even if they exist in the maps cannot at all the located.
The TOR clearance letter under “Muck Disposal Plan” had asked for “The quantity of muck to be generated and the quantity of muck proposed to be utilized should be calculated.” This was not complied with and EMP report in chapter 6 mentioned only about the muck generated from excavation. Under the same, the scoping clearance also asked for “Layout map showing the dumping sites viz – viz other project components should be prepared.” There is no layout map showing the dumping sites.
The TOR clearance letter under “Restoration Plan For Stone Quarries” asked for “Layout map showing quarry sites vis-à-vis other project components should be prepared.” There is no map prepared for complying with this condition.
For “Landscaping and Restoration Plan” TOR letter asked for proper map showing landscaping and restoration site but this was not complied with in the EIA report.
The TOR letter asked the consultant to include a “Certificate” in EIA/EMP report regarding portion of EIA/EMP prepared by them and data provided by other organization (s)/Laboratories including status of approval of such laboratories. The consultant WAPCOS did not comply with this.
Conclusion These are crucial issues which were specifically mentioned in the TOR letter and EIA-EMP not complying with such crucial issues is unacceptable. The public hearing of the project is schedule to be held on 18.01.2014 but going for public hearing without complying with the condition mentioned in the TOR clearance is against the due process of law. The public hearing of Kalai II project should not be held and the EIA should be sent back to the projects developer. Moreover, as pointed out at the outset, the TOR extension given to the project beyond the stipulated period was based on false claim of submission of EIA-EMP that adheres to the TOR. Thus the extension given is invalid and the project must be asked to apply for TOR clearance afresh as per the MoEF norms. The public hearing if conducted on January 18, 2014 in spite of this, will not stand legal scrutiny.
Parag Jyoti Saikia (firstname.lastname@example.org)
South Asia Network on Dams, Rivers and People (SANDRP)
The 1200 MW Kalai II HEP located on LohitRiver in Anjaw district of Arunachal Pradesh is being developed by Kalai Power Private Limited (KPPL), which is the Special Purpose Vehicle of Reliance Power Limited. The company had signed the Memorandum of Agreement (MOA) with Govt. of Arunachal Pradesh on 2-Mar-09. The EIA consultant for the project is WAPCOS. The project was recommended for scoping clearance in 31st Meeting of Expert Appraisal Committee (EAC) held on 21-22 October 2009. The project was considered in the 70th EAC meeting on 10-11 Dec 2013 for extension of TOR validity. The advertisement published in Arunachal Times suggests the date as 18th January 2014.
The EIA study cannot clearly state whether Kalai II is a storage project or a run of the river project. The EIA study is also not clear about the height of the dam. Detail analysis of the EIA study reveals that the study is incomplete, inadequate and shoddy. The study cannot qualify to be called an EIA study.
Cumulative Impacts Assessment Study of Lohit Basin Prepared by WAPCOS is Farce The local people from Lohit basin have categorically stated that the cumulative impact assessment study done for the Lohit basin by WAPCOS is farce. In a news published in Arunachal Times (available in Annexure I) people have stated “Water and Power Consultancy Services (WAPCOS) had earlier conducted a cumulative impact assessment of various hydropower projects in the entire Lohit river basin, as per the directives of MoEF. WAPCOS made a farce report, completing within 2-3 weeks. The study is very poor and shoddy…..” Now for the Kalai II project the same organization is preparing the EIA report. From the track record of WAPCOS and from the experiences of the people in the Lohit basin, it is clear that an EIA prepared by WAPCOS cannot at be accepted as a complete, unbiased study.
People of Lohit Basin will not Accept Studies done by WAPCOS It is important to note that people of Lohit basin have already expressed their anger and disbelief on studies done by WAPCOS. In a letter written to the Union Minister on Environment and Forests on 15 march 2012 the, Peoples Forum For Project Affected Family (PFPAF) had clearly stated the following “….no study of WAPCOS would be acceptable to the people of the Lohit Valley and other social and environment conscious people for two main reasons. Firstly, WAPCOS is an organisation under the Union Water Resources Ministry, and Union Water Resources Ministry is basically a pro dam lobby. WAPCOS also does other pro dam studies like the feasibility reports and Detailed Project Reports for Big dams, such studies are done in favour of Big dams and an organisation that is doing such business cannot be entrusted to do an environment or cumulative impact assessment study. Secondly, WAPCOS also has had very poor track record and has done very poor quality EIA and CIA reports. Hence, in future, we will not accept any reports done by such organisations.”
It is important to note that when the people of the whole Lohit basin had raised objections against WAPCOS, the government and companies should not have hired WAPCOS the project consultant. This indicates a hidden strategy on the part of the project authorities to employ only pro-dam EIA consultants to get favourable outcomes.
Critique of the Kalai II EIA study
Biased EIA An EIA report should be an unbiased assessment of impacts of the project. The EIA report of Kalai II HEP is a biased towards hydropower, as can be seen from what has been written in section 1.3, page 1-3: “In Arunachal Pradesh so far a capacity of 423.5 MW has been developed which is just 0.84 % of the total potential. Hydro projects of about 2600 MW are being constructed which is about 5.17 % of the total potential. It is evident from the above that the capacity developed and under development will be achieved for 3023.5 MW in very near future, still leaving behind a potential of about 47304.5 MW (93.99%).” This shows clear towards hydropower project and this EIA report of Kalai II HEP prepared by WAPCOS cannot be considered a neutral assessment of impacts of the project.
EIA does not mention Maximum Water Level of the reservoir The EIA study does not mention the Maximum Water Level of the reservoir when the dam passes peak flood. It only mentions the FRL as 904.80 m.
Large Submergence Area The area which Kalai II project will submerge is very large considering that it is RoR project. The EIA document in Section 6.4 mentioned “The construction of a 198 m high concrete gravity dam shall create a reservoir of area approx. 640 Ha at FRL of El.904.8m. The reservoir will extend up to 15 km along the river Lohit. The reservoir width shall range from about 600 m to 1000 m over most of its length.” But news report published Arunachal Times states that submergence route extends upto 23 km upstream. The report also stated that the project will submerge the entire Hawai circle and all the major villages directly affecting 1500 people.
It is important to note here is that size of the total area required, the number of affected villages and population mentioned in this EIA is much higher than the numbers mentioned for the project when it was considered for TOR clearance in EAC on 21.10.2009. The minutes of that EAC for Kalai II stated that Total land requirement is 830 ha, which has now grown by 32.5% to 1100 ha (Section 2.2 of EIA), No of affected villages has grown from four villages to 25 (525% increase), No of PAFs has grown from 22 to 595 (2605% increase) and no of affected people has grown from 122 to 2279 (1768% increase). This means that the impacts were grossly understated at scoping stage. Is such gross and deliberate understatement acceptable?
Huge land requirement not justified The project claims to require 1100 ha of land, 370 ha more than the land requirement of 830 ha stated at the time of scoping. This land demand seems unjustified and inflated and cannot be accepted at face value. The EIA does not even attempt to look into this issue.
EIA under estimates the number of affected population Even though the EIA has stated 595 as PAFs it still seems a hugely under stated number of affected families. The report claims that their survey team contacted a total of 595 PAFs where the total population of the project affected area is stated as 2279. But the detailed news report of Arunachal Times says that the project will submerge the entire Hawai circle and all the major villages. If this is true then the project will affect much larger no of people.
It is also relevant to note that even as the Kalai II project will affect 595 families (according to the EIA) in order to generate electricity, 565 families or 91.6% project affected families already have electricity supply. (EIA report page 9-13)
Submergence of the existing national highway: Impacts of alternative road not assessed The reservoir of Kalai II HEP will submerge 16 km of existing national highway. The border roads organization will construct two lane road at a higher elevation in place of this. The construction of this alternative road will imply land use, more social impacts, more blasting and other construction related activities, but these impacts have not been included in the EIA.
The alternative highway is planned to be constructed at elevation 910 m. However, since MWL is not given and also backwater effect, which will be higher than MWL at times of peak flood, it is not clear if the alternative elevation would be affected by back water effect.
Many Maps are not readable The project layout map at Figure-2.1 is not legible. The map is very small and except title none of the other details or legends are legible. The EIA must provide a detailed layout map for the Kalai II HEP. The same is case with Geological Plan of Reservoir Area map (Fig 6.1 and 6.2) which are two very important maps but they are not at all legible.
In most places the project consultant have used unclear maps. e.g. ‘Fig 7.7 – Water Sampling location map’ or ‘Fig 8.1 Terrestrial Ecological sampling location map’. An EIA with such illegible maps cannot be acceptable.
Impacts on Migratory Fish Construction of Kalai HEP II will have devastating impacts on fish in the river. The path of the migratory fish will be blocked and this has been accepted by the EIA as well – “The dam construction activities will also create a problem for migratory fish species (Tor tor and Tor putitora).” (Page 8-38). The two species of Mahseer, Tor tor and Tor putitora, locally known as Ngorika and Ngauch respectively and have been listed as ‘endangered’ in IUCN list. But it is surprising to see that EIA opining that “These migratory fish species may move into the small tributaries of LohitRiver.” It is no clear what is the basis of this statement by WAPCOS, it does not seem to show sufficient ecological literacy. The EIA prepared by WAPCOS also seem to ignore that several dams have been proposed in the tributaries as well. The EIA also does not say how well the area has been studied and what kind of biodiversity we may be losing.
Wrong claims about reservoir water quality The EIA says about reservoir water quality, “The proposed project is envisaged as a runoff the river scheme, with significant diurnal variations in reservoir water level. In such a scenario, significant re-aeration from natural atmosphere takes place, which maintains Dissolved Oxygen in the water body. Thus, in the proposed project, no significant reduction in D.O. level in reservoir water is anticipated.” This conclusion is clearly wrong. The EIA says about the reservoir: “The Gross and diurnal Storage of the Kalai-II reservoir are 318.8 M cum and 29.76 M cum with FRL at El 904.80 m and MDDL at El 900.00 m respectively”. This means that 93.35% of the reservoir is dead storage and only 6.65% of the reservoir capacity acts as live storage. Such a large quantity of dead storage will have huge impact on the water quality and the claim to the otherwise by the EIA is clearly wrong and misleading. Similarly the EIA claim of no Eutrophication risk due to “significant diurnal variations in reservoir water level” is clearly wrong.
No Options Assessment The EIA of Kalai II HEP does not do any options assessment. The EIA religiously focuses on the construction of 1200 MW project without mentioning the fact that successful sub-megawatt capacity hydropower projects (Less than 1 MW) are operational in Anjaw district (see Annexure II).
Conversion of community land into forest land can have negative impacts on the communities The EIA on page 10-25 states, “The total land requirement for the project, is 1100 ha. The entire land is considered as forest land. A part of the community land also includes forest land as well. For EMP purposes, the entire quantity of land has been considered as the forest land.” This can lead to severe impacts on the communities.
Here it is important note the implications of actions of similar nature on the Meyor community in the Kithibo area of Anjaw district, in the upstream of Kalai II HEP. A news published by Asian Human Rights Commission (see Annexure III) reports, “The Asian Human Rights Commission (AHRC) has received information from civil society groups regarding death threats, arbitrary detention and harassment of members of the Meyor community, a group of indigenous people in Arunachal Pradesh. They are being targeted for their activities on conservation of community land and natural resources.” The leaders of the community reported to have “protested the conversion of the community forest land of Walong and Kibitho area into reserved forest land because it was carried out without the free, prior and informed consent of the Meyor community.” It is important to note that this report also mentioned about impact of dams and other development activities on tribal ethnic communities. However, the EIA is silent on these aspects.
Cumulative impact migrant population in Lohit valley can be catastrophic The Kalai II project EIA states that the maximum number of people coming from outside the region for construction will be 3000 and the impacts are predicted to be only in the construction phase. Here it is important note that the number of outside workers provided by EIAs have proved to be gross under-estimates. But the EIA here does not mention anything about the cumulative impacts of migrant population for other projects along with Kalai II. In fact in a letter written to the Minister of Environment and Forests by the PFPAF, it was mentioned that the whole area of Lohit valley is inhabited by tribal population. The total tribal population as according to 2011 census is 16500. The cumulative number of migrant workers will clearly surpass this population figure, leading to severe impacts on the people of the area.
Disaster Management Plans do not mention about seismic risks Discussing the disaster management plan for the dam, the EIA study mentions only few issues and ignores the issue of earthquakes: “However, in the eventuality of dam failures in rare conditions, catastrophic condition of flooding may occur in the downstream area resulting in huge loss to human life and property. Floods resulting from the failure of constructed dams have also produced some of the most devastating disasters of the last two centuries. Major causes of failures identified by Costa are overtopping due to inadequate spillway capacity (34 percent), foundation defects (30 percent), and piping and seepage (28 percent).”
The EIA does not include the following important assessments:
a. Assessment of impacts of quarrying on the river bed and river banks The Kalai II project will require 72.6 lac cumec boulders for construction of the project and all of these will be extracted from the river bed and river banks.
Even though the EIA itself mentions how the removing of boulders and gravel from the river bed will affect spawning areas of fishes (page 10-29), but does not suggest for any detail impacts assessment. It limits itself by stating about adequate precautions during dredging period. But it is highly doubtful that any of those precautions will be followed when actual dredging will be done to extract lakh cumecs of construction material when there are no specific steps or mechanisms suggested. Without full assessment and management plan, the EIA cannot be considered adequate.
b. Assessment of impacts of blasting for tunneling and other works in the pristine and fragile hill range – Blasting in the fragile hill ranges of Arunachal can have severe impacts, especially in increasing the probability of landslides. In Such circumstances, the EIA stating that no major impacts of blasting are envisaged at the ground level is wrong and puts a big question mark on the EIA.
c. Impact of the project on disaster potential of the area has not been assessed.
d. Impacts of peaking power operation on hydrological regime, biodiversity, and life & livelihoods of people
e. Impact of flushing out of silt from the reservoir
f. Impacts of climate change on the project and project’s impacts on local climate
g. There is no assessment of the value of the river that will be destroyed by submergence in the upstream and drying up and changed hydrology in the downstream.
h. The EIA has not properly assessed the downstream impacts of the project. It may be recalled that the ongoing massive agitation in Assam against such impacts of the under construction 2000 MW Lower Subansiri HEP, that has led to stoppage of work there since Dec 2011 is focused on downstream impacts and this project will face the same fate if this is not attended to.
i. No public consultations in Assam Linked to the above issue is the need for public consultations in downstream Assam about this and all other Lohit basin projects, without which there will be no question of public acceptability of the project and the project may face the same fate as that of Lower Subansiri HEP.
Doubtful, contradictory and sweeping statements in EIA The EIA at several places have stated made such statements:
Page 10 -23, para 4: “The construction of the dam would form the reservoir which will submerge about 640 ha of area in upstream. The area witnessed jhum/shift cultivation practiced by local inhabitants. Submergence of the area would not impact much on the prevailing land use pattern.”
This is clearly wrong, since jhum cultivation is one of the key livelihood supporting activity in these areas and if such land is submerged, it will have major impacts on the land use pattern.
Page 10 – 30, para 3: “As a result, barring for monsoon season, (May to September), the river Lohit will have dry periods for few hours for generation of peaking power.”
The idea of ‘few hours’ a complete misnomer and misleading, it will happen daily for 15-20 hours. In the analysis of Lohit basin study SANDRP had found that for Kalai II, “In lean season river water will be stored for a period of 15-20 hours. As a result, downstream stretch of river from the dam site will remain dry for that period. This will be followed by a continuous flow of 1112.27 cumecs (rated discharge) for a period of 4 to 9 hours.” (Lohit Basin Study by WAPCOS: A mockery of e-flows and cumulative impacts – https://sandrp.in/rivers/Lohit_Basin_Study_by_WAPCOS_A_mockery_of_e-flows_and_cumulative_impacts.pdf)
Parag Jyoti Saikia (email@example.com)
with inputs from Himanshu Thakkar
Villagers block road demanding scrapping of Kalai II dam
HAWAI, Jun 05: About 500 villagers of Hawai circle on Monday staged a dawn-to-dusk road blockade at Walong-Hawai road demanding scrapping of the 1200 MW Kalai II dam proposed on LohitRiver.
The villagers protested under the banner of Peoples Forum for Project Affected Families (PFPAF). Road communication at Hawai was totally disrupted for the whole day affecting even the movement of military vehicles.
Talking over telephone from Hawai, PFPAF Chairperson Behenso Pul said: We had earlier submitted memorandum demanding scrapping of Kalai II dam to Union Ministry of Forest and Environment, chief minister, local representatives putting our grievances. But no one is listening to us. So we decided to launch our democratic movement.
The villagers staging protest demanded for permanent halt of property survey, and other survey and investigation being carried out for the hydro electric project. A memorandum was submitted to deputy commissioner, Hawai placing all grievances and the demands.
We are highly encouraged by the massive participation of villagers in such short notice. It is a great moral boost for people working against dam, said Pul. But there was no participation from panchayat leaders, students union and other civil society organization.
The Kalai II Hydro Electric Project is to be developed by one of the major Reliance Power subsidiary, Kalai Power Private Limited (KPPL). It was incorporated on September 26, 2007. The project site is in LohitRiver in Kumblung and the submergence route extends upto 23 km upstream.
The project involves construction of 161 meter high concrete dam. An underground power house will be constructed to house 8 units of 150 MW turbines. The total project cost is estimated at Rs. 69,551 million and is likely to be completed in 7 years time.
The Kalai II project will lead to submergence of entire Hawai circle and all the major villages. Around 1500 people are being directly affected by the dam, said Pul. Since last week, we carried out grassroots campaign on dams. We haven’t met one single person who is in favour of dam. Everyone one is scared and against it. In Anjaw district alone, at least 6 large dams are proposed within 150 km of river route out of 13 projects in the entire Lohit basin. Water and Power Consultancy Services (WAPCOS) had earlier conducted a cumulative impact assessment of various hydropower projects in the entire Lohit river basin, as per the directives of MoEF.
WAPCOS made a farce report, completing within 2-3 weeks. The study is very poor and shoddy, said Pul.
According to PFPAF, they are, however, not opposed to all dams in Anjaw district. They view that projects along the tributaries of Lohit river can be harnessed, instead of building large dams along the main river alone. Citing a report in a national news magazine, Pul said the tributaries of Lohit alone had capacity to produce 8000 MW.
Out of the 7 circles in Anjaw district, 5 are situated along the main Lohit river. Even Hawai headquarter is in the bank of Lohit river. So, if dams are built along the main river, majority of the 18000 Mishmi population will be affected, said Pul.
In April 13 meeting with Chief Minister Nabam Tuki at Tezu, the PFPAF had suggested the government to consider harnessing power in the tributaries of Lohit river, not in the main river, where majority of population live. It is learnt that chief minster had made assurance of stopping all dams wherever not required.
If small dams are built in the tributaries, which are in the interior places, people there can benefit in the form of roads and other developments,Pul said.
ITANAGAR: The remote Anjaw district of Arunachal Pradesh is marching ahead to notch a record in the hydropower sector and is being hailed as the future powerhouse of the country with a 58,000 MW hydropower potential.
Kaho, a village in the district located near Kibithoo along the tri-junction of the China-Myanmar-India border, had created a record in 2007 by becoming the first village in the state to have round-the-clock power supply besides supplying power to the Army personnel guarding the frontier.
This feat was achieved thanks to the determination of the lone elected representative of the district, Kalikho Pul, and the equally committed deputy commissioner, Prashant S Lokhande. The two officials were instrumental in commissioning a micro hydel project in the last border village, a 24-hour trek away from last pitch road, for which all the machines and material had to be transported manually.
The duo’s efforts in turning the odds to their advantage made Anjaw the first of the 17 districts in the state to commission many of the ongoing projects.
Pul, who toured the district and inspected all the project sites recently, said the 2X100 KW Yapak, 2X50 KW Khrowtipani, 2X250 KW Matinala and 2X250 KW Teepani projects were commissioned recently and made the border district self-sufficient in power.
At the moment, Hawai, Hayuliang, Goiliang, Manchal, Walong, Kibithoo and Metengliang administrative centres and adjoining villages are getting 24-hour uninterrupted power supply, Pul said, adding that various development activities would begin now with availability of power, thereby boosting the local economy as well.
Located along the Sino-India border, the district is spread across an area of 9,936 sq km and crisscrossed by numerous perennial rivers, including Lohit, Dav, Dalai, Lati, Kulong, Syang, Helei, Yapak and Kathang, has total hydropower potential of above 7,000 MW.
The projects – 2X50 KW Hatipani at Goiliang, 2X30 KW Ashapani, 2X100 KW Kachopani, 2X30 KW Maipani and 2X200 MW Langpani at Gamliang – are likely to be commissioned within a month or two, Pul informed.
He added despite the locational and other disadvantages, the projects could register speedy growth because of proper utilization of funds and strict monitoring.
The hydropower projects were taken up with the vision to benefit the locals as well as the state in general, he said, adding the 16 MW Haleipani project, which is at an advanced stage, is likely to be commissioned within 2012. “It will cater to the needs of Lohit, Dibang and Changlang districts besides meeting the requirements of Anjaw,” he added.
However, according to official sources, no steps have been initiated so far for erecting transmission lines for evacuation of excess power to be generated by the Haleipan project. Once the transmission lines are commissioned the state would be almost self-sufficient and would not need to purchase power at high prices from outside.
Pul added as the Haleipani project is on the verge of completion, the state government, particularly the hydropower department, should take up the transmission line project proposed in Anjaw. The project is pending with the department for the last many years. Without the transmission lines, any quantity of power generated would be futile as it cannot be utilized for any purpose, he said.
Kaho, a village in the district located near Kibithoo along the tri-junction of the China-Myanmar-India border, had created a record in 2007 by becoming the first village in the state to have round-the-clock power supply
INDIA: Violent Attack, Arbitrary Detention, Death Threats to activists of Meyor Community, Arunachal Pradesh
ASIAN HUMAN RIGHTS COMMISSION – URGENT APPEALS PROGRAMME: Urgent Appeal Case: AHRC-UAC-152-2013
9 December 2013
INDIA: Violent Attack, Arbitrary Detention, Death Threats to activists of Meyor Community, Arunachal Pradesh
ISSUES: Arbitrary detention, freedom of speech and expression, indigenous people’s rights, protection of environment, land rights, human rights defenders
The Asian Human Rights Commission (AHRC) has received information from civil society groups regarding death threats, arbitrary detention and harassment of members of the Meyor community, a group of indigenous people in Arunachal Pradesh. They are being targeted for their activities on conservation of community land and natural resources. The Meyor community with about 450 members is classified as one of the Scheduled Tribes under the Indian Constitution and is mostly confined to the Anjaw district of the state. They have been criticized for opposing government activities that includes conversion of community land to reserved forest land and corruption in the Public Distribution System (PDS).
CASE NARRATIVE Several representatives of the community assumed a leadership role. They are, namely:
Mr. Chung Meyor, 33, Dhanbari village
Mr.Chaping Meyor, 55, Gaon Bura (village chief), Khroati village
Mr. Unchen Meyor, 45, Barakhundun village
Mr. Chethel Meyor, 25, Dhanbari village
Mr. Tharpa Meyor, 26, Musai village
Mr. Tenzing Dorjee Meyor, 30, Sotakhundun village
Mr. Fendey Meyor, 30, Musai village of Arunachal Pradesh
These men protested the conversion of the community forest land of Walong and Kibitho area into reserved forest land because it was carried out without the free, prior and informed consent of the Meyor community.
The conversion of community land into forest land was initiated, allegedly, by Mr. Kalikho Pul, a member of the Arunachal Pradesh Legislative Assembly. He allegedly collected signatures from the Meyor community under the pretext of development works in the area. Conversion of this forest area was completed in 1995-1996 with a proposal of afforestation. Through an application, under the Right to Information Act, 2005 filed by Mr Dimso Manyu of the Meyor community, the people came to know of this development only on 14 March 2012.
The villages of the Meyor community are within a 36 square kilometer perimeter and their livelihood is dependent on natural resources. Over a period of time they faced limited access to the land resources due to the conversion of community land into ‘forest land’. Once they came to know of the conversion, the community vehemently opposed it. Due to their opposition, it is alleged that the police and unknown trouble-makers carried out frequent detentions, arrests, tortures and intimidations of community leaders and representatives of the Meyor tribe.
On 26 April 2013, armed reprobates arrived in a white Scorpio Jeep, threatened and attempted to torture Mr. Chung Meyor near Naraliang village on Tezu-Hayuliang Road. On the same day, Mr. Chung lodged a complaint about the incident at the Khupa police station. Police have not taken any action so far.
On 1 June 2013, Mr. Unchen Meyor filed a complaint at the Khupa Police Station. He cited mismanagement, corruption and illegal activities committed at a Fair Price Shop set up under the government’s Public Distribution System. Incidentally, on 12 November 2013 some local youths discovered that Mr. Agam Rai was selling PDS items illegally to people who were not subscribed under the PDS system. In connection to this discovery, a counter- police complaint was lodged by Mr.Kayawlum Tawsik, Chairperson, Zilla Parishad (local government), Anjaw Disttrict, against Mr. Unchen Meyor, Mr. Chethel Meyor and Mr. Tharpa Meyor.
On the night of 13 November 2013, Mr. Unchen and his family were brutally assaulted by a group of criminals at his residence in Barakhundun village. Mr. Unchen is still in critical condition due to injuries to his head, nose and chest. His daughter made a complaint about the attack on 15 November to the Khupa police station. However, till now, the police have not taken any action.
A second time, on 28 November 2013, Mr. Fendey Meyor, member of Gram Panchayat (local government) was arrested by the police from his village, Musai. They demanded the immediate surrender of Mr. Unchen, Mr. Chethen, Mr.Tenjing at the Khupa police. Mr. Fendey was released on 3 December on bail, with fabricated charges of vandalising still pending. Mr. Unchen is in hospital (at Aditya Diagnostic, Diburgar) struggling for his life. Mr. Chethen and Mr. Tenjing are in hiding, fearing for their lives and personal security. Similarly other community activists like Mr. Chung Meyor, Mr. Chaping Meyor and Mr. Tharpa Meyor are equally exposed to threats to their lives.
ADDITIONAL INFORMATION Arunachal Pradesh, bordering on China, is one of the most thinly populated states in India. It has 101 recognized indigenous tribal groups and about 50 languages. There are several rivers with the potential for generating hydro-electric power. The government has planned to construct some 168 mega-dams in the state, a move opposed by the indigenous people living there. There is a heavily militarized presence due to the international border. Draconian measures under the Armed Forces Special Powers Act, 1958 (AFSPA) is applicable in two districts of Arunachal Pradesh, namely Tirap and Changlang, and a 20 kilometer area bordering Assam.
1. Urge the Government Authorities of India and the State Government of Arunachal Pradesh to guarantee the physical and psychological security of the members of the Meyor Community and its leaders.
2. Urge the authorities to protect the indigenous people’s right to land and resources.
3. Urge the authorities to protect the environment and not to grant deforestation rights.
The AHRC is writing a separate letter to the UN Special Rapporteur on the Rights of Indigenous People and the UN Special Rapporteur on Protection of Human Rights Defenders for immediate intervention in this matter.
Sub: Violations in public hearing to be held on Jan 18, 2014 for 1200 MW Kalai – II HEP
The Arunachal Pradesh State Pollution Control Board (APSPCB) has proposed to conduct a public hearing for the 1200 MW Kalai – II project at Hawai on 18–01–2014. Through this communication we urge you to cancel the public hearing which is illegal for the following reasons.
We would also like to point out that EIA and EMP reports prepared by WAPCOS have not fulfilled a very large number of the TOR (Terms of Reference) that the project was to cover in EIA-EMP as per the TOR clearance given for the project on 9.12.2009. Such EIA-EMP will clearly not be acceptable even from statutory and legal point of view and cannot be basis for a public hearing. A report on the status of compliance with TOR in EIA and EMP is attached along with a detailed critique of the EIA-EMP report. APSPCB and MoEF should immediately cancel the public hearing and ask the EIA-EMP consultants to comply with the TOR first.
1) Project currently has no valid Scoping (ToR) clearance The 1200 MW Kalai II project was granted Scoping (ToR) clearance on 9-12-2009 by the Ministry of Environment & Forests (MoEF). As per MoEF Office Memorandum (OM) dated 22-3-2010 the validity of Scoping (ToR) clearances granted for carrying out pre-construction activities is four years and therefore the clearance for Kalai II has expired on 8- 12-2013.
Hence the public notice dated 13-12-2013 issued by the APSPCB in the Arunachal Times dated 14 – 12 – 2013 for conduct of public hearing (a pre-construction activity) is illegal as the project did not have valid Scoping / ToR clearance on those dates. Such a notice can only be issued if there is a valid Scoping clearance for carrying out pre-construction activities which is also placed in the public domain, which is not the case till date.
We have noticed that the Expert Appraisal Committee (EAC) on River Valley & Hydroelectric projects discussed the issue of extension of Scoping clearance for the 1200 MW Kalai II project and recommended extension in its December 10-11 2013 meeting. However, an order granting fresh Scoping clearance for an additional year has not been issued by the MoEF, which is the concerned regulatory authority. A perusal of the MoEF website till today (11-01-2014) shows that the Scoping clearance order available for the 1200 MW Kalai II project is only the original one dated 9-12- 2009 (which has expired on 8–12–2013) and no additional/fresh Scoping clearance is available.
In such a scenario, both the announcement and conduct of the public hearing on January 18th, 2014 is illegal, as no clearance existed on the date of public notice. It is only after the MoEF issues a fresh Scoping clearance for pre-construction activities to the 1200 MW Kalai II project (which is also placed in the public domain) can the APSPCB announce and conduct a public hearing (with no less than 30 days notice).
Hence we urge you to immediately cancel the public hearing announced for the 1200 MW Kalai II project proposed for 18-1-2014. Please note that issue of fresh Scoping clearance for preconstruction activities by MoEF between now and 18-1-2014 will still render the conduct of public hearing on 18–1-2014 illegal. Fresh notice will require to be issued after MoEF issues a fresh Scoping clearance with at least 30 days notice.
2. Law does not provide powers to MoEF to provide back dated extensions There is no provision in the EIA notification of Sept 2006 that could empower MoEF to provide back dated ToR clearances. Hence since MoEF has not issued any extension of the ToR to the Kalai II HEP before 8-12-2013 when the earlier ToR clearance expired, no extension of the ToR clearance can now be issued by MoEF and the project proponent will need to apply afresh for stage I or ToR clearance for the project. This will also be in fitness of things considering that WAPCOS is the consultant for the EIA for Kalai II HEP and we had written to the Chief Minister of Arunachal Pradesh (twice) and to the Union Minister of Environment and Forests that an EIA done by the WAPCOS will not be acceptable. We reiterate that stand and suggest that the fresh EIA should be awarded to a credible independent agency and any study by WAPCOS will not be acceptable, both due to its poor track record and also due to the conflict of interest involved in the governance (WAPCOS is an agency under Union Ministry of Water Resources which is largely functioning as a lobby for large river valley projects) and functioning of WAPCOS (as business model of WAPCOS also involves doing pre-feasibility, feasibility and Detailed Project Reports.
3. Non availability of Cumulative Impact Study Non availability of cumulative impact study of all the hydropower projects (including Kalai II) in the Lohit River Basin in the designated places 30 days before pubic hearing is another reason for the lack of legal backing for the public hearing. As per section 9.4 of form I of the EIA notification, it is necessary for the project proponents to provide information about cumulative impacts of the project along with other projects in the river basin. In the case of Kalai II, it would be cumulative impacts for all the hydropower projects in the LohitRiver Basin. However, a cumulative impact study of Lohit basin is available. Hence the public hearing proposed on Jan 18, 2014 is illegal.
4. ToR of Kalai II not fulfilled As per the scoping Terms of Reference clearance issued to the 1200 MW Kalai II project on Dec 9, 2009, one of the objectives is to “perform a rigorous assessment of the significance of the bio-physical, socio-cultural and cumulative effects of the project.” However, the EIA of the project now available does not fulfill this (and a number of other TORs) and hence public hearing cannot be held without fulfilling the TORs.
5. MoEF OM stands violated Further, the MoEF vide Office Memorandum dated May 28, 2013 has stated that it will assess projects based on cumulative impact assessment studies. A LohitRiver Basin study has been commissioned by EAC/ MoEF to study the cumulative impacts of all the projects in the LohitRiver Basin (including Kalai II HEP). Although the draft report of this study is supposed to have been completed, it has not been approved by the Expert Appraisal Committee and thus and approved study is not available and such an approved study has also not been placed with the individual impact assessment study of the 1200 MW Kalai II project at all the designated places (DC office, etc) 30 days prior to public hearing. Thus public hearing for the project will also be in violation of the MoEF OM of May 28, 2013. This is one more strong ground for rendering the current announcement of the public hearing on 18-1-2014 as illegal.
6. Lessons from Uttarakhand Disaster for June 2013 The Uttarakhand flood disaster of June 2013 and the Supreme Court order of Aug 13, 2013 underscore the need for learning lessons from the disaster and also doing advance and credible cumulative impact assessment of the projects and also assessment of disaster potential and how the large number of projects impact the disaster potential of the area. However, this has not been done as part of the EIA for the project or otherwise and hence conducting a public hearing without such a study will not be prudent or proper.
7. Options Assessment not done Experience has shown that Anjaw district has huge potential of sub MW capacity micro hydro projects and these are sufficient for taking care of the power needs of the district, state and region. However, taking up the public hearing without doing such assessment will be clearly violation of EIA notification as such exercise is necessary part of EIA and this has not been done for Kalai II HEP.
8. Downstream Impacts not assessed, downstream consultations not done Downstream impacts of hydropower projects have proved to be huge and this is a very important and sensitive issue as is evident from the situation with respect of Lower Subansiri HEP in Assam where the project has been stopped for over two years now. In case of Kalai II HEP, comprehensive assessment of downstream impact assessment has not been done, nor has there been public consultations organized in downstream areas, nor has there been any public consultations for the Basin study in Anjaw or downstream areas. Without all these, the project public consultation will neither be useful nor legally valid.
9. Full EIA-EMP not available in local languages The full EIA-EMP or even proper executive summary of the EIA-EMP or the basin study is not available in local languages and also to all the gram sabhas in the affected region a month in advance of the public hearing. Holding public hearing in absence of these will clearly not be valid or proper.
Hoping for the prompt action in this respect from APSPCB to cancel the illegal public hearing for the 1200 MW Kalai II HEP. A failure to take action in this respect will lead to protests and legal action at the appropriate stage.
Himanshu Thakkar and Parag Jyoti Saikia
South Asia Network on Dams, Rivers and People (SANDRP), Delhi
The year 2013 was an important for the water sector of northeastern states of India with several significant events. In this article I have tried to summarize some of the important events, issues and concerns of the water sector in northeast.
Massive hydropower projects considered and cleared for northeast An analysis done by SANDRP for the year 2013 has showed that massive hydropower capacity in northeast India has been considered and cleared by Expert Appraisal Committee (EAC) on River valley and Hydroelectric projects. The total installed capacity of considered by EAC for the year 2013 is 29458 MW and out of which 21805 MW (over 74% of 29458 MW) projects are in the northeast India. On the other hand out of the total capacity considered for northeast, 20180 MW (over 92.5% of 21805 MW) projects are in Arunachal Pradesh. The total number of projects considered from northeast for 2013 was 37, all (including the Dibang multipurpose project, which is basically a hydro project) are hydropower projects. Out of these 37 projects, 10 projects of 4917 MW installed capacity has been given TOR (Terms of Reference) clearance or the Stage 1 clearance. 4 projects with 953 MW installed capacity has been given final environment clearances. 13 projects with 9078 MW capacity had been given extension of their TOR validity which implies that in next 2-3 years all these projects would also come up for final environmental clearance.
India-China Water Information Sharing MoU of October 2013 One of the most important developments of the year 2013 was the signing of this Memorandum of Understanding through which it was agreed that the current hydrological data (Water Level, Discharge and Rainfall) in respect of three stations, namely, Nugesha, Yangcun and Nuxia located on river Yaluzangbu/Brahmaputra from 1st June to 15th October every year will now be extended to May 15th to Oct 15th with effect from 2014. Another important news through this agreement is that the Government of India recognizes the value of river since the agreement writes “rivers and related natural resources and the environment are assets of immense value to the socio-economic development.” But this agreement has been misread and misreported by a large section of the media. SANDRP wrote a detailed blog “Media Hype Vs Reality: India-China Water Information Sharing MoU of Oct 2013” which clears the fog around this agreement. The blog also lists formation and decisions of the meetings of the Expert Level Mechanisms (ELM) on Trans-border rivers and MoUs on Hydrological Data Sharing on River Brahmaputra / Yaluzangbu and Satluj / Langquin Zangbu.
Forest Clearance Rejected for Tipaimukh and Dibang Hydropower Projects In the year 2013 the rejection of forest clearance to 1500 MW Tipaimukh hydropower project and 3000 MW Dibang multipurpose project by the Forest Advisory Committee (FAC) of MoEF is noteworthy. Here it should be noted that the Prime Minister of India laid foundation stone for the Dibang Project in Jan 2008 when the project did not have any of the statutory clearances! However, NHPC has already started lobbying the Prime Minister headed Cabinet Committee on Investments to intervene for the forest clearance for Dibang Project and a note has already been moved for this. We hope these FAC decisions are not reversed as it happened in case of Kalu dam in Maharashtra, where the FAC decision was reversed following a letter from the Chief Minister. The stay over the construction work of Maphithel dam in Manipur by the National Green Tribunal could have been regarded as a positive sign but recent reports suggests that Union Ministry for Tribal Affairs (MOTA) had done a U-turn by going “back on its views to say that the Forest Rights Act should not apply to the acquisition of land from the Tanghkul and Kuki tribal people as a ‘rare and unique’ exception.”
Two years of Anti-dam protests in Assam and Tripartite Talks The protest against large hydropower dams in Arunachal Pradesh had reached a new milestone as the stoppage of construction work of Lower Suabansiri hydropower project completed two year on 16th December 2013. This stoppage of the construction work of the Lower Subansiri project has brought the issue of downstream impacts of large dams to the forefront and also showed how a mass movement can question a top-down development project. These protests were led by Krishak Mukti Sangram Samiti (KMSS), All Assam Student Union (AASU), Asom Jatiyatabadi Yuba-Chatra Parishad(AJYCP) along with several other organizations.
On Dec 6, 2013, a tripartite discussion was held involving the central government, Government of Assam and experts protesting organizations. Though this meeting failed to come to a common resolution, it led to the expert to expert meeting on the Lower Subansiri dam issues on 22nd December 2013.
These discussions not only help in building public opinion about the issue but also provide platform to discuss the larger issues related with 168 hydropower dam proposed for Arunachal Pradesh and its cumulative impacts in the larger Brahmaputra basin.
Foreign Funding of Hydropower projects in Northeast In the year 2013 Asian Development Bank has agreed to give loan of $ 200 million to construct the Lower Kopili Hydropower project in Karbi Anglong and Dima Hasao districts Assam. This project is being constructed by Assam Power Generation Corporation Limited (APGCL) and it is 8 km downstream of Kopili hydropower project, first dam on Kopili river. It is important to note that acidic contamination of water due to unabated mining in the upstream Meghalaya is a poses a major threat for the viability of the dam and this was disclosed in a study initiated by the project proponent. This project was given TOR clearance in the 69th meeting of EAC.
Foreign funding of hydropower project comes with the risk of huge cost overruns. This was evident in the case of Pare HEP on Pare/Dikrong river which NEEPCO constructing taking a loan of 80 million euros from KfW, a German Bank. Incidentally, this project was schedule to be completed in September 2013 but Central Electricity Authority status report on projects under execution now states the completion time as 2015. The cost of this project has already increased by 205% from its initial estimates. The loan amount along with the interest rest is also increasing year by year and NEEPCO’s 36th Annual Report of 2011-12 states that the loan taken from KfW is “repayable in 30 equal half yearly installments w.e.f. 30.12.2013.” This implies that even before the completion of the project the company has to start paying back the loan.
Assam’s Flood Devastation For Assam, the central state of northeast India, flood is an annual event. In the year 2013 Assam witnessed three waves of flood. The table below provides a glimpse of the extent of the flood disaster Assam faced in 2013. The data is sourced from National Disaster Management Institute under the Ministry of Home Affairs of Government of India.
Data from NDMI, Government of India
No of affected People
No. of affected districts
No of affected Villages
But it was surprising to find that the numbers of affected people and villages provided by a central government organization is much less than the number provided by the disaster management department of the state government. The State Disaster Management Authority of Assam (SDMAA) provides much larger number of affected people. During the monsoon months of 2013, SDMAA published daily flood report on its website. After following the flood reports of four months, the following table with some key dates has been prepared to give an idea of the discrepancy between state government and central government data.
Data from SDMAA, Government of Assam
No of People affected
No. of districts affected
No of Villages affected
This discrepancy points towards the lack of the coordination between the state and the central government departments which is clearly not good sign. Floods need serious attention and such misreporting can lead to confusions which will ultimately have bearing on the people of Assam. It is important to mention that many in Assam believe that the problem of flood in Assam has not been dealt adequately by the central government. The discrepancy detailed above reinforces that belief.
False claim about climate induced displacement in Northeast India by a global agency In connection with the flood issue, the year 2013 will also be marked by the publication of the report named “Global Estimates 2012 – People Displaced by Disasters” by Internal Displacement Monitoring Centre (IDMC) based in Geneva, Switzerland. This report had stated that the largest climate induced displacement in the world for the year 2012 happened in two states of Northeast India, Assam and Arunachal Pradesh in June 2012 due to the monsoon floods which displaced 6.9 million people, constituting about 21.2% of the population of the two states. But a detailed analysis of this report by SANDPR revealed that the though these figure are highly exaggerated. This analysis is available at “2012 Floods Displaced 6.9 Million in Northeast-IDMC: Staggering but Highly Exaggerated”.
Havoc of Erosion In Assam, along with annual floods, river bank erosion by Brahmaputra and its tributaries is a major cause of concern. The year 2013 is also no exception and severe erosion was reported in several parts of the state. A report Study of Brahmaputra River Erosion and Its Controldone by IIT Roorkee, published in 2012 measured the loss of land due to erosion of Brahmaputra for nearly two decades in twelve reaches of the river. The total loss of land on both sides of the river Brahmaputra is mentioned below.
Total Erosion Length (km)
1990 to 2007 – 08 (in sq. km)
1997 to 2007-08 (in sq. km)
Total Erosion Length (in km)
1990 to 2007 – 08 (in sq. km)
1997 to 2007-08 (in sq. km)
This report, sponsored by National Disaster Management Authority (NDMA), was a very descriptive report from the point of information and data about the river Brahmaputra and its tributaries. But an analysis of the report done by SANDRP, found that this report was biased towards structural interventions and hydropower projects and oversimplifies the problem of erosion by identifying ‘sediment overloading’ as the main reason for erosion. This analysis can be found at “NDMA Commissioned IIT Roorkee Study on Brahmaputra River Erosion: A Biased and Structural Solution Oriented Report?”.
The year 2013 also witnessed people in river-rine areas of Assam demanding relief from erosion. On May 21st 2013, the people of Bahgara Dhunaguri village panchayat in the Lakhimpur district of Assam floated the effigy of State Water Resources Minister Rajib Lochan Pegu in a traditional raft in the Subansiri River in Dhunaguri Baduli Para area. The TMPK units of Dikrong Awanori and East Dikrong joined in this protest. According to the beliefs of Mishing society when someone dies due to unnatural causes, his/her body is floated in a traditional raft in flowing river. People accused that Mr. Pegu had completely failed to perform his duty as a water resource minister and he had not been able to give any relief to the people by preventing flood and erosion. Failing to perform his duty has been regarded as the ‘unnatural death’ of the minister & that was why people floated the effigy of the minster.
With respect to construction and repair of embankments, some serious issues were brought to light in the year 2013. In May 2013, All Assam Water Resources Contractors’ Association revealed that out of the total embankment length of 4473.82 km in Assam, the government had repaired only 1327 km embankment, leaving 3673 km long embankment completely vulnerable to floods.
Parag Jyoti Saikia (firstname.lastname@example.org)
with inputs from Himanshu Thakkar
In the year 2013, SANDRP has written 13 blogs on issues related to North East India. A list of those blogs is given below. SANDRP has also made continuous submissions on dams and basin studies from Northeast to EAC and those submissions are available in our website https://sandrp.in/.
The Simang River is a tributary of the Siang River which originates at an elevation of 2950 m. The river is 44 km long (as mentioned in the EIA/EMP reports done by consultant R S Environ Link). Total catchment area of Simang River is 554 sq km. There are two projects proposed on the Simang River. The first one is Simang I with an installed capacity of 67 MW (3 x 22.33 MW) and catchment area of 494 sq km. The second one is the upstream project Simang II with an installed capacity of 66 MW (3 x 22 MW) and catchment area of 422 sq km. These two projects were jointly discussed in the 19th meeting of EAC in October 2008 for the first time. Then these projects were subsequently discussed in the 21st, 36th, 66th and 67th meeting of EAC. A diagram of the two projects on the Simang River is given below.
Troubled Figures of EIA/EMP
In order to prepare the above diagram EIA/EMP reports of both Simang I and Simang II has been consulted. A detailed analysis of the numbers and figures mentioned in the EIA/EMPs for the river shows serious inadequacies in both the EIAs and raises questions on the authenticity of the EIA studies being done on the river.
1. EIA Wrong about Length of Simang River: It is surprising to find that the EIA studies for the two projects cannot give the correct the length of Simang River and contradicts each other (e.g. paragrapgh 4 page 1.14 of EIA of Simang I). Even though the total length of the river has been mentioned as 44 km in EIA studies of both the projects, lengths of the river over different parts do not add upto that.
The EIA report of Simang I in map of ‘Figure 1.3: Project in Simang Basin’ of page 1.16 shows that the distance between the origin of the river and reservoir of Simang II HEP is 22.27 km. The EIA report of Simang II states that the distance between barrage axis of Simang II and Simang-Siang confluence is 19.66 km (paragraph 1 page 5.2). The stretch of the Simang River used by Simang II barrage is 1.05km (from page 4.6 paragraph 1 & 2 of Simang II EIA report). If we take the total of these three parts of the Simang River, the total length of the river will be 42.98km and not 44 km.
On the other hand if we take some other figures given for different parts of the river, then we get another length for the Simang River. The Simang I EIA shows that the distance between the barrage axis of Simang II and TWL of Simang I is 15.75 km (Figure 1.3). The distance between the TWL of Simang I and it’s confluence with Siang river is given as 3.29 km. From this the total length of the river comes out as 41.31 km excluding the Simang II reservoir area. The stretch of the Simang River used by Simang II reservoir is 1.05 km. So including this total length of the Simang River is 42.36 km, not 44 km.
This is a serious inadequacy on the part of the EIA studies since the studies are not clear even about the river length across different parts of the projects. Either the EIA consultants do not know the rivers or they are fudging figures. In either case, these EIA reports should not be accepted.
2. Incorrect Assessment of River Use for the Projects The EIA reports of both Simang I and II projects gives incorrect figures for stretch of river used for the projects. The stretch of the Simang River submerged by Simang II barrage is 1.05 km (from page 4.6 paragraph 1 & 2 of Simang II EIA report), stretch of river bypassed between Simang II barrage and TWL is 7.75 km. The EIA report of Simang I states that the stretch of river submerged by Simang I barrage is 1.48 km and stretch of river bypassed between Simang I barrage and TWL is 7 km. This concludes that the total length of the river used by the two projects is 17.28 km and not 15.75 km as claimed in the EIA reports. Not giving the correct information about the stretch of the river used for projects is a major lacunae on the part of the EIAs and hence these EIA should be rejected.
3. Incorrect Assessment Distance between Simang-Siang Confluence and Power House of Simang I: It seems the EIA/EMP consultant has no knowledge of the area since the distance stated between the Simang-Siang confluence and Power House also seems to be incorrect. The Simang I EIA in states that distance between barrage axis of dam and Simang-Siang confluence is 9.34 km. It also stated that the distance between barrage axis and power house is 7 km. This leaves the distance between the Simang-Siang confluence and Simang I power house as 2.34 and not 3.29 as shown in Figure 1.3 in page 1.16 of the EIA. This again proves that the EIA report prepared by the consultant is inadequate and it should not be accepted.
4. Assessment of river length for diversion is doubtful The diverted river length for Simang II HEP given as 7.75 km in the EIA seems to be doubtful. But tunnel lengths mentioned in the same document for Simang II are as follows:
In fact the bypassed length of the river is likely to be longer than this length of the various tunnel components since rivers do not flow in straight lines, unlike the tunnels.
Critical Issues Not Addressed by EIA/EMP The projects on the Simang River were first considered for TOR in 2008 in the 19th EAC meeting. The proposal that time was to construct three hydro electric projects (HEPs) on the river. In reply to this the EAC had asked, “Secretary (Power) and Secretary (Environment) of Government of Arunachal Pradesh should attend the next meeting to clarify the reason for allotting a series of hydroelectric projects on a river which subsequently flows only through tunnels and damage the aquatic ecology.” The Power secretary and Environment secretary attended the 21st meeting of EAC. Going through the minutes of that meeting, it becomes very obvious that Arunachal with its aim to generate more revenue was ready to dam every river or stream in the state. This strengthens the impression that the Simang I or Simang II HEPs are not going to be much beneficial for the local people, environment or the state.
After going through the EIA/EMP of both the projects we have found that there are several critical issues with these studies. There are several issues which are common in both the studies and several others which are particular to each project. Reading these documents thoroughly gives a feeling that the documents don’t have much of a difference from each other and lot of ‘copy-pasting’ has been done. Some of them are also mere replications (e.g. section 4.2 page 4.7 of Simang I EIA and section 4.1.8 in page 4.6 Simang II EIA). There are also many instances where names and words have been confused, e.g. in page 1.15 of Simang II EIA, in the title of the Table 1.1 “Simang I” has been mentioned instead of “Simang II’. This kind of issues raises question on the validity and authenticity of the EIA/EMP studies done. Some of the critical issues are listed below as an example, this is not exhaustive list.
1. EAC Recommendations not Followed: The EIA/EMP studies of these projects have not followed several of the EAC recommendations. EAC in its meetings had recommended the project proponent to address several important concerns but those were no followed.
“To maintain the aquatic life, a study to be conducted by National Institute of Hydrology, Roorkee. Methodology followed for measurement of water flow to be given.” (19th EAC Meeting) – There is no mention of any study done on environment flows. The EIA/EMP report of both the projects does not give any details of how the environment flow was measured except mentioning what will be the environmental flow.
Between dam and power house how many streams/ tributaries join and what is their contribution in turn of water in the lean season and monsoon? (19th EAC meeting) – The EIA/EMP of none of the two projects responded to this. There are no accurate details about number the flow contribution of different streams or river joining Simang.
Seismic Studies, Slope Stabilization measures, Reservoir Rim Treatment should be included in the EIA/EMP studies. (36th EAC meeting) – The EIA/EMP studies of the two projects do not have any details ofseismic studies done in the project area.
Disaster Management Plan should be included in the EIA/EMP studies. (36th EAC meeting) – This is very surprising because none of the two projects in Simang River has any disaster management plan in their respective EIA/EMP documents.
2.Impact of Migration of Outside Workers on Local Communities not Assessed The EIA/EMP reports estimates that there will be migration of nearly 1000 persons for each project during the peak construction period to this very sparsely populated area. People who live in this area belong to several ethnic tribal groups with unique social, economic, political and cultural values. The EIA/EMP reports do not discuss what will be the impact of such migration on the social, political, economic and cultural lives of the people. Influx of such migration will also have impacts on their human rights as well on women. The EIA/EMPs make no mention of these impacts of migration and that is why the EIA/EMP report is incomplete. Besides, even though the projects had been considered together by EAC, no cumulative impact assessment of migration was done.
3. Shoddy Socio-economic Impact Study: The property surveys which the consultant claim to have done for both these projects are inadequate and shoddy socio-economic impact assessment studies. For Simang I a property survey of project affected families in 5 villages was done but it was found incomplete since it does not take into account two of the project affected villages. On page 6A-10 of the EIA report, these 5 villages are stated as Dosing, Lileng, Pareng, Rengo and Boleng. But out of these villages, there are only three villages mentioned in the property survey – Pareng, Rengo and Boleng. The two villages Dosing and Lileng were not found in the list and instead there were two different villages mentioned in the list – Yingku and Sine.
But after reading through the EIA study of Simang II, it becomes clear that project consultant had done only one survey for both the projects. The two villages Yingku and Sine are also found in the property survey list for Simang II EIA with the same number of affected families (page 6A-16).
It is also surprising to see how the opinions can be exactly similar for both the projects when the affected families are different for each project (See page 16A-15 of Simang I HEP EIA and page 16A-17 of Simang II HEP EIA). Besides, in the list mentioned in page 6A-17 of Simang II EIA, village named Yingku is mentioned twice but there is no justification provided for that.
This brings to light how recklessly these EIAs had been prepared. In fact, the whole concept of property survey is questionable. It takes into account very limited concerns related with the projects ignoring many serious issues. One important aspect of what is the value of the river and other common property resources for the people of the area finds no mention in the property survey. Such property survey cannot be taken as a full proof socio-economic impact assessment and hence EIA/EMP is incomplete and cannot be accepted.
4. Options Assessment not Done The EIA/EMPs of the proposed projects have not done any options assessment study. For example, the option of sub megawatt micro hydro project for a sparsely populated and pristine area like this has not been assessed. For ethnic tribal communities with small population micro hydro project is a better option. The option of solar power generation has also not been assessed by the EIA/EMPs of the projects. Options assessment is an important part of the EIA/EMP document and since this is not done the EIA/EMP reports are incomplete and cannot be accepted.
5. Environmental Flows Assessment not Done: The EIA/EMP reports of the two projects do not give any detail of how environment flow was calculated and how environment flow will be released. We have already mentioned that in the 19th EAC meeting, EAC had suggested that in order to maintain the aquatic life, a study should be conducted by National Institute of Hydrology, Roorkee and the methodology followed for measurement of water flow should be made available in the EIA. But there is no mention about any such study in any of the documents.
EIA reports of both projects mentioned about the environment flow release exercise but that should have been done already and should have been a part of the EIA. Since the EIA reports do not mention about any study done on environment flow as asked by the EAC this EIAs cannot be taken as a complete impact assessment.
6. Socio-Economic Impacts of Reduced Flow Ignored: None of EIA/EMP reports mention about the socio economic impacts of reduced flow in the intermediate stretch between the barrage axis and power house. Besides, in questionnaire of the primary survey/property survey which the EIA consultants claim to have done, there is no question on impacts of the reduce flow of water in the river. Besides, the EIA/EMP studies do not discuss the importance of the river for the local people. This proves that EIA report is inadequate and cannot be accepted.
7.Impacts of Non-monsoon Peaking Power Generation not Assessed: EIA/EMP reports of the two projects do not assess how peaking power generation during non-monsoon period will impact the flow in the river downstream from power house. Peaking power generation will have significant impact in the downstream since there will be sudden flow of water in the river for a short period of the day and rest of times it will remain almost dry. This sudden release of water holds threat for the people living downstream as well as their livestock. There are many instances where large number of people and livestock dying due to sudden release of water from upstream dam. Most recently, on Oct 7, 2013, one person was washed away in Arunachal Pradesh due to sudden release of water from the Ranganadi HEP. Besides, this fluctuation in river water on everyday basis will have severe impacts on aquatic bio diversity of the river and use of the river by the people. EIA study ignores all these issues and that is why this study cannot be accepted as a complete study.
8. Impact Assessment of changing sediment releases not Done The EIA/EMP reports do not talk about how sedimentation will impact the reservoir. The EIAs should have included detail analysis of two main impacts – 1.Impact of changing silt flows downstream from desilting chamber and 2. Impacts of silt flushing in monsoon season on the downstream areas. The EIA/EMP report should also do a cumulative study of reservoir sedimentation because the sediment released from the upstream reservoir will affect the reservoir downstream.
9. Socio-economic Impact Assessment of Quarrying not Done: EIA/EMP of any of the two projects on Simang does not talk about the socio economic impact of quarrying on the local people and environment. EIA/EMP reports also have not assessed how the quarrying in a fragile hill range like Eastern Himalayas will increase the risk of landslide and disaster. Ignoring the disaster risk of quarrying in the hills can have disastrous impacts and the recent Uttarakhand disaster is a proof of that. Since EIA/EMP studies ignore all these issues, they cannot be accepted as complete and that is why EIA/EMPs of Simang I and II should be rejected.
10. False Claim about Height of the Dam: The claim made by the EIA/EMP of both the projects that 18 m high dam reservoir is “very low height” is misleading and false. In the 2nd paragraph of page 10.2, the EMP report of Simang I states “Because it is a run of the river hydro project with a small barrage with very low height (18 m), the inundation will be minimized during reservoir filling.” The same claim has been made in the same page of Simang II EMP. This claim is baseless because according to international standards any dam with a wall height of 15 m or above is a big dam.
11. Climate Change Assessment Not Done EIA/EMP studies of both the projects have not done any climate change impact assessment for the proposed projects. Today when climate change impact risks are increasing day by day, it is very essential for studies like these to do an assessment of possible climate change impacts on the project as well as impacts of the projects on local climate. In fact the word “climate change” is nowhere to be found in the EIA or EMP of the two projects. Without climate change risk assessment, an environment impact assessment cannot complete and that is why this report is unacceptable.
The EIA/EMP studies should also have done an assessment of methane release from the reservoir of the project. Since these important issues are not addressed by the impact assessment study, it cannot be accepted as a complete study.
12. False Claims about Flora and Fauna The EIA/EMP of the two projects makes a completely baseless claim that “There will be no negative impact on flora of region during the operation phase.” This cannot be accepted as truth since during the construction phase of Simang I and II, the forest area diverted will be 29.86 ha and 22.02 ha respectively. After such a diversion forest, the impact on flora and fauna is inevitable because the area is covered by dense forest. The EIA report of Simang I states that forests constitute the predominant land use in the 10 km area which was studied for this project and 67.66% of this area is covered by dense forests. Besides, none of the two EIA studies provide any data on how many trees will be cut down for the project. These are serious lacunas on the part of EIA/EMP of these two projects and that is why this report cannot be accepted as a comprehensive study.
14. Barrage Location not Clearly Stated for Simang I The EIA report of Simang I is not clear about where the barrage of proposed Simang I HEP will be located. In page 1.5 the EIA report states “The reservoir created by the barrage located near Boleng town will operate between FRL 339 m and MDDL 334 m.” But the same report in page 5.2 says “The proposed Barrage axis is situated about 9.34 Km upstream of confluence of Simang river with Siang river. The river Simang joins the SiangRiver near Boleng township.” Besides, the maps show that Boleng area is located near the confluence of two rivers not near the barrage site. This is a significant error of the EIA study and hence this study is inadequate and cannot be accepted.
15. Simang II does not assess the project impact on Protected Area EIA states that the distance between Mouling National Park and the reservoir tail at Subbung Nala and Simang River are 5.6 and 5.7 km respectively (page 1.2, paragraph 2). Being in so close proximity of a protected area there should have been impact assessment of the project on the protected area but the EIA/EMP does not mention any such assessment.
16. Threat to Nearly Threatened Mammals The Simang II HEP is a threat to some of the endangered mammal species listed in IUCN Red List. Common leopard (Panthera pardus) and Assamese macaque (Macaca assamensis) which falls in the “Near Threatened” and Gaur (Bos frontalis) falling in “Vulnerable” category of IUCN Red List are found in the project area of Simang II. There are 13 more species of mammals falling under the “Least concern” category of IUCN which are also found in the area. This has been stated in the EIA study of Simang II.
On the other hand, the EIA study of Simang I ignores some the species falling under IUCN Red List. Rhesus macaque, Indian Porcupine and Asiatic Brush Tailed Porcupine which are found in the area fall under the “Least concern” category of IUCN Red List but the EIA report completely ignores this.
The EIA/EMP reports of the two proposed HEP projects on Simang River have significant lacunas and those cannot be ignored. The EIA consultant also had not consulted the local people in preparing the EIA report. This is another significant lacuna on the part of the EIA because it is the local people who are more aware of the local environment and river as they have lived in that place for generations. It is shameful that on the basis of such studies and reports, public hearing for the two HEPs was held without even announcing the Public hearing dates on the AP Pollution Control Board website. If these dams are constructed on the basis of such shoddy reports and flawed public hearings then it will invite an uncertain future for the people of the area and people have to live at the risk of disaster. The EAC should consider these issues seriously and must not accept these reports. The EAC should also consider recommending the black list of the consultants for the serious lacunae in the reports.
The Study The study has been done by IRG Systems South Asia Private Limited (http://www.irgssa.com/, a subsidiary of US based IRG Systems) and http://www.eqmsindia.com/[i]. It is supposed to be a Cumulative Impact Assessment of 19 HEPs planned in the basin, out of which PFRs of 7 are available, DPR of two, and one of which, the 2000 MW Subansiri Lower HEP is under construction.
Subversion of Environment Governance in the Subansiri basin While looking at this basin study, the subversion of environment governance in Subansiri basin this very millennia should be kept in mind. A glimpse of it is provided in Annexure 1. In fact, one of the key conditions of environmental clearance to the 2000 MW Lower Subansiri HEP was that no more projects will be taken up in the basin upstream of the Lower Subansiri HEP, which essentially would mean no more projects in the basin, since LSHEP is close to the confluence of the Subansiri River with Brahmaputra River. That condition was also part of the Supreme Court order in 2004. The need for a carrying capacity study was also stressed in the National Board of Wild Life discussions. We still do not have one. In a sense, the Subansiri basin is seeing the consequences of that subversion.
Information in public domain not known to consultants The report does not even state that Middle Subansiri dam have also been recommended TOR in 41st EAC meeting in Sept 2010. This project will require 3180 ha of land, including 1333 Ha forest land, and 2867 ha area under submergence. Even about Upper Subansiri, the consultants do not know the area of forest land required (2170 ha). So the consultants have not used even the information available in public domain in EAC meetings.
Study based on flawed and incomplete Lohit Basin Study The Study claims that it is based on Lohit Basin Study done by WAPCOS. Lohit Basin Study is an extremely flawed attempt and does not assess cumulative impacts of the cascade projects. Civil society has written about this to the EAC and the EAC itself has considered the study twice (53rd and 65th EAC Meetings), and has not accepted the study, but has raised several doubts. Any study based on a flawed model like Lohit Basin Study should not be acceptable.
No mention of Social impacts Major limitation of the study has been absolutely no discussion on the severe social impacts due to cumulative forest felling, flux of population, submergence, livelihoods like riparian farming and fishing, etc. Though this has been pointed out by the TAC in its meeting and field visit, the report does not reflect this.
Some key Impacts Some of the impacts highlighted by the study based on incomplete information about HEPs are:
Þ The length of the river Subansiri is 375 km up to its outfall in the Brahamaputra River. Approximately 212.51 km total length of Subansiri will be affected due to only 8 of the proposed 19 HEPs in Subansiri River basin.
Þ Total area brought under submergence for dam and other project requirements is approx. 10, 032 ha of eight proposed HEPs. The extent of loss of forest in rest of the 9 projects is not available.
Þ 62 species belonging to Mammals (out of 105 reported species), 50 Aves (out of 175 reported species) and 2 amphibians (out of 6 reported species) in Subansiri Basin are listed in Schedules of Wildlife Protection Act, 1972 (as amended till date).
Þ 99 species belonging to Mammals (out of 105 reported species), 57 species belonging to Aves (out of 175 reported species), 1 Reptilian (out of 19 reported species), 2 Amphibians (out of 6 reported species), 28 fishes (out of 32 reported species), 25 species belonging to Odonata of Insecta fauna group (out of 28 reported species) are reported to be assessed as per IUCN’s threatened categories.
Even this incomplete and partial list of impacts should give an idea of the massive impacts that are in store for the basin.
Cumulative impacts NOT ASSESSED Specifically, some of the cumulative impacts that the report has not assessed at all or not adequately include:
1. Cumulative impact of blasting of so many tunnels on various aspects as also blasting for other project components.
2. Cumulative impact of mining of various materials required for the projects (sand, boulders, coarse and fine granules, etc.)
3. Cumulative impact of muck dumping into rivers (the normal practice of project developers) and also of also muck dumping done properly, if at all.
4. Changes in sedimentation at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof.
5. Cumulative impact on aquatic and terrestrial flora and fauna across the basin due to all the proposed projects.
6. Cumulative impact of the projects on disaster potential in the river basin, due to construction and also operation at various stages, say on landslides, flash floods, etc.
7. Cumulative dam safety issue due to cascade of projects.
8. Cumulative change in flood characteristics of the river due to so many projects.
9. Cumulative impacts due to peaking power generation due to so many projects.
10. Cumulative sociological impact of so many projects on local communities and society.
11. Cumulative impact on hydrological flows, at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof. This will include impacts on various hydrological elements including springs, tributaries, groundwater aquifers, etc. This will include accessing documents to see what the situation BEFORE project and would be after. The report has failed to do ALL THIS.
12. Impact of silt laden water into the river channel downstream from the dam, and how this gets accumulated across the non-monsoon months and what happens to it. This again needs to be assessed singly and cumulatively for all projects.
13. Impact of release of silt free water into the river downstream from the power house and impact thereof on the geo morphology, erosion, stability of structures etc, singly and cumulatively.
14. Impact on Green House Gas emissions, project wise and cumulatively. No attempt is made for this.
15. Impact of differential water flow downstream from power house in non-monsoon months, with sudden release of heavy flows during peaking/ power generation hours and no releases during other times.
16. Cumulative impact of all the project components (dam, tunnels, blasting, power house, muck dumping, mining, road building, township building, deforestation, transmission lines, etc.,) for a project and then adding for various projects. Same should also be done for the periods during construction, operation and decommissioning phases of the projects.
17. Cumulative impact of deforestation due to various projects.
18. Cumulative impact of non compliance of the environment norms, laws, Environment clearance and forest clearance conditions and environment management plans. Such an assessment should also have analysed the quality of EIA report done for the Subansiri Lower hydropower project.
Wrong, misleading statements in Report There are a very large number of wrong and misleading statements in the report. Below we have given some, along with comment on each of them, this list is only for illustrative purposes.
Statement in CIA
“During the monsoon period there will be significant discharge in Brahmaputra River. The peaking discharge of these hydroelectric projects which are quite less in comparison to Brahmaputra discharge will hardly have any impact on Brahmaputra.”
This is a misleading statement. It also needs to be assessed what will be the impact on specific stretches of Subansiri river. Secondly, the projects are not likely to operate in peaking mode in monsoon.
“However, some impact in form of flow regulation can be expected during the non-monsoon peaking from these projects.”
This is not correct statement as the impact of non-monsoon peaking is likely to be of many different kinds, besides “flow regulation” as the document describes.
“Further, during the non-monsoon period the peaking discharge release of the projects in upper reaches of Subansiri basin will be utilized by the project at lower reaches of the basin and net peaking discharge from the lower most project of the basin in general will be the governing one for any impact study.”
This is again wrong. What about the impact of such peaking on rivers between the projects?
“The construction of the proposed cascade development of HEPs in Subansiri basin will reduce water flow, especially during dry months, in the intervening stretch between the Head Race Tunnel (HRT) site and the discharge point of Tail Race Tunnel (TRT).”
This statement seems to indicate that the consultants have poor knowledge or understanding of the functioning of the hydropower projects. HRT is not one location, it is a length. So it does not make sense to say “between HRT and the discharge point of TRT”.
“For mature fish, upstream migration would not be feasible. This is going to be the major adverse impact of the project. Therefore, provision of fish ladder can be made in the proposed dams.”
This is simplistic statement without considering the height of the various dams (124 m high Nalo HEP dam, 237 m high Upper Subansiri HEP dam, 222 m high Middle Subansiri HEP dam), feasibility of fish ladders what can be optimum design, for which fish species, etc.
“…water release in lean season for fishes may be kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20% water flow in lean season may be maintained at Hiya and Nyepin HEP for fish migration.”
This conclusion seems unfounded, the water release suggested is even lower than the minimum norms that EAC of MoEF follows.
Viability not assessed The report concludes: “The next steps include overall assessment of the impacts on account of hydropower development in the basin, which will be described in draft final report.”
One of the key objective of the Cumulative Impact assessment is to assess how many of the planned projects are viable considering the impacts, hydrology, geology, forests, biodiversity, carrying capacity and society. The consultants have not even applied their mind to key objective in this study. They seem to assume that all the proposed projects can and should come up and are all viable. It seems the consultant has not understood the basic objectives of CIA. The least the consultant could have said is that further projects should not be taken up for consideration till all the information is available and full and proper Cumulative impact assessment is done.
The consultants have also not looked at the need for free flowing stretches of rivers between the projects.
Section on Environmental Flows (Chapter 4 and 9): The section on Environmental flows is one of the weakest and most problematic sections of the report, despite the fact that the Executive summary talks about it as being one of the most crucial aspects.
The study does not use any globally accepted methodology for calculating eflows, but uses HEC RAS model, without any justification. The study has not been able to do even a literature review of methodologies of eflows used in India and concludes that “No information/criteria are available for India regarding requirement of minimum flow from various angles such as ecology, environment, human needs such as washing and bathing, fisheries etc.”
This is unacceptable as EAC itself has been recommending Building Block Methodology for calculating eflows which has been used (very faultily, but nonetheless) by basin studies even like Lohit, on which this study is supposedly based. EAC has also been following certain norms about E flow stipulations. CWC itself has said that minimum 20% flow is required in all seasons in all rivers. BK Chaturvedi committee has recently stipulated 50% e-flows in lean season and 30% in monsoon on daily changing basis.
The assumption of the study in its chapter on Environmental Flows that ‘most critical reach is till the time first tributary meets the river” is completely wrong. The study should concentrate at releasing optimum eflows from the barrage, without considering tributary contribution as an excuse.
First step of any robust eflows exercise is to set objectives. But the study does not even refer to this and generates huge tables for water depths, flow velocity, etc., for releases ranging from 10% lean season flow to 100% lean season flow.
After this extensive analysis without any objective setting, the study, without any justification (the justification for snow trout used is extremely flawed. Trouts migrate twice in a year and when they migrate in post monsoon months, the depth and velocity needed is much higher than the recommended 10% lean season flow) recommends “In view of the above-said modeling results, water release in lean season for fishes maybe kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at all HEP for fish migration and ecological balance.”
The study does not recommend any monsoon flows. Neither does it study impact of hydro peaking on downstream ecosystems.
Shockingly, the study does not even stick with this 20-25% lean season flow recommendation (20-25% of what? Average lean season flow? Three consecutive leanest months? The study does not explain this). In fact in Chapter 9 on Environmental Flows, the final recommendation is: “Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at Hiya and Nyepin HEP or all other locations for fish migration.” (emphasis added)
So it is unclear if the study recommends 20-25% lean season flows or 10-15% lean season flows. This is a very flawed approach to a critical topic like eflows.
The study keeps mentioning ‘minimum flows’ nomenclature, which shows the flawed understanding of the consultants about e-flows.
The entire eflows section has to be reworked, objectives have to be set, methodology like Building Block Methodology has to be used with wide participation, including from Assam. Such exercises have been performed in the past and members of the current EAC like Dr. K.D. Joshi from CIFRI have been a part of this. In this case, EAC cannot accept flawed eflows studies like this. (DR. K D. Joshi has been a part of a study done by WWF to arrive at eflows through BBM methodology for Ganga in Allahabad during Kumbh: Environmental Flows for Kumbh 2013 at Triveni Sangam, Allahabad and has been a co author of this report)
Mockery of rich Subansiri Fisheries Subansiri has some of the richest riverine fisheries in India. The river has over 171 fish species, including some species new to science, and forms an important component of livelihood and nutritional security in the downstream stretches in Assam.
But the study makes a mockery of this saying that the livelihoods dependence on fisheries is negligible. The entire Chapter on Fisheries needs to be reworked to include impacts on fisheries in the downstream upto Majuli Islands in Assam at least.
No mention of National Aquatic Animal! Subansiri is one of the only tributaries of Brahmaputra with a resident population of the endangered Gangetic Dolphin, which is also the National aquatic animal of India (Baruah et al, 2012, Grave Danger for the Ganges Dolphin (Platanista ganegtica) in the Subansiri River due to large Hydroelectric Project. http://link.springer.com/article/10.1007/s10669-011-9375-0#).
Shockingly, the Basin Study does not even mention Gangetic Dolphin once in the entire study, let alone making recommendations to protect this specie!
Gangetic Dolphin is important not only from the ecological perspective, but also socio cultural perspective. Many fisher folk in Assam co-fish with the Gangetic River Dolphin. These intricate socio ecological links do not find any mention in the Basin study, which is unacceptable.
Lessons from Lower Subansiri Project not learnt A massive agitation is ongoing in Assam against the under construction 2000 MW Subansiri Lower HEP. The people had to resort to this agitation since the Lower Subansiri HEP was going ahead without studying or resolving basic downstream, flood and safety issues. The work on the project has been stopped since December 2011, for 22 months now. In the meantime several committee have been set up, several changes in the project has been accepted. However, looking at this shoddy CIA, it seems no lessons have been learnt from this ongoing episode. This study does not even acknowledge the reality of this agitation and the issues that the agitation has thrown up. There is no reflection of the issues here in this study that is agitating the people who are stood up against the Lower Subansiri HEP. The same people will also face adverse impacts of the large number of additional projects planned in the Subansiri basin. If the issues raised by these agitating people are not resolved in credible way, the events now unfolding in Assam will continue to plague the other planned projects too.
Conclusion From the above it is clear that this is far from satisfactory report. The report has not done proper cumulative assessment on most aspects. It has not even used information available in public domain on a number of projects. It does not seem to the aware of the history of the environmental mis-governance in the SubansiriBasin as narrated in brief in Annexure 1. For most projects basic information is lacking. Considering the track record of Central Water Commission functioning as lobby FOR big dams, such a study should have never been given to CWC. One of the reasons the study was assigned by the EAC to the Central Water Commission was that the CWC is supposed to have expertise in hydrological issues, and also can take care of the interstate issues. However, the study has NOT been done by CWC, but by consultants hired by CWC, so CWC seems to have no role in this except hiring consultant. So the basic purpose of giving the study to CWC by EAC has not been served. Secondly the choice of consultants done by the CWC seems to be improper. Hence we have a shoddy piece of work. This study cannot be useful as CIA and it may be better for EAC to ask MoEF for a more appropriate body to do such a study. In any case, the current study is not of acceptable quality.
Set Conditions to be waived Later – The MoEF way of Environmental Governance
In 2002, the 2,000 MW Lower Subansiri hydroelectric project on the Assam-Arunachal Pradesh border came for approval to the Standing Committee of the Indian Board for Wildlife (now called the National Board for Wildlife) as a part of the Tale Valley Sanctuary in AP was getting submerged in the project. The total area to be impacted was 3,739.9 ha which also included notified reserved forests in Arunachal Pradesh and Assam. The Standing Committee observed that important wildlife habitats and species well beyond the Tale Valley Sanctuary, both in the upstream and downstream areas, would be affected (e.g. a crucial elephant corridor, Gangetic river dolphins) and that the Environmental Impact Assessment studies were of a very poor quality. However, despite serious objections raised by non-official members including Bittu Sahgal, Editor, Sanctuary, Valmik Thapar, M.K. Ranjitsinh and the BNHS, the Ministry of Environment & Forests (MoEF) bulldozed the clearance through in a May 2003 meeting of the IBWL Standing Committee. Thus a project, which did not deserve to receive clearance, was pushed through with certain stringent conditions imposed (Neeraj Vagholikar, Sanctuary Asia, April 2009).
The EC given to the project was challenged in Supreme Court (SC) by Dr L.M Nath, a former member of the Indian Board for Wildlife. Nath pleaded, these pristine rich and dense forests classified as tropical moist evergreen forest, are among the finest in the country. Further the surveys conducted by the Botanical Survey of India and the Zoological Survey of India were found to be extremely poor quality. The Application mentions that the Additional DG of Forests (Wildlife) was of the view that the survey reports of the BSI and ZSI reports were not acceptable to him because these organisations had merely spent five days in the field and produced a report of no significance.
The SC gave its final verdict on 19-4-2004, in which the Court upheld the EC given by MoEF to NHPC but with direction to fulfill some important conditions. Out these conditions there were two conditions which were very significant – “The Reserve Forest area that forms part of the catchment of the Lower Subansri including the reservoir should be declared as a National Park/ Sanctuary. NHPC will provide funds for the survey and demarcation of the same.”, and “There would be no construction of dam upstream of the Subansri River in future.” These conditions were also mentioned in the original EC given to the project in 2003.
In May 2005, two years after the EC was given the Arunachal Pradesh govt and NHPC approached the SC to waive or modify the above two conditions. The state government calimed that following these conditions would imply loss of opportunity to develop 16 mega dams in the upstream of Lower Subansiri (this including 1,600 MW Middle Subansiri and 2,000 MW Upper Subansiri to be developed by NHPC). The SC sent it back to National Board for Wildlife to review the conditions.
The petition was done strategically. “The strategy of the dam proponents is simple. They raised no objection to the terms until the construction of the Lower Subansiri project had proceeded beyond a point when it could have been cancelled. Armed with this fait accompli, they asked for a review of the clauses on the very basis on which the original clearance – laid down by members who were subsequently dropped from the wildlife board – was granted.”[ii]
Then nonofficial members of NBWL expressed their dissent to the proposal. In a May 2008 communication to the Chairman of the NBWL Standing Committee, member Dr. Bibhab Talukdar observed: “If the Standing Committee agrees to waive the conditions, we would be setting a dangerous precedent and sending a wrong signal regarding the credibility of decision-making by us. This would mean that projects impacting rich wildlife habitats can receive clearances based on stringent conditions, only to be up for review later. Such an approach is undesirable both from a perspective of good governance as well as the long-term interest of wildlife in the country.”
Dr. Asad Rahmani of the BNHS, who was part of a sub-committee of the NBWL Standing Committee conducting a site visit to the project area, stated in his report: “Under no circumstances should new projects be allowed in the Subansiri river basin until an advance cumulative assessment of proposed projects and a carrying capacity study of the Subansiri river basin are completed.”
In the December 12 2008 meeting of NBWL Standing Committee, even after these dissenting opinions from nonofficial members MoEF managed to do a dilution of the above two conditions. Assam that time was witnessing a major protest concerning the downstream impacts of Lower Subansiri HEP but it was not even consulted. Shockingly the “no dam upstream” condition was removed and it was decided that “any proposal in the upstream of the SubansiriRiver would be considered independently on its merit by the Standing Committee as and when submitted by the proponents”.
Now the Arunachal Pradesh government needs to declare a smaller area of 168 sq. km. as a sanctuary and “make serious efforts” to bring an additional 332 sq. km. reserved forest under the category of Conservation Reserve (CR) in consultation with the MoEF. The latter part of the condition (declaration of CR) is non-enforceable because of the choice of words. Even the demand to at least conduct an advanced cumulative impact assessment of proposed projects and a carrying capacity study of the Subansiri river basin has been ignored[iii].
As Bittu Sahgal, Editor, Sanctuary Asia says, “The Lower Subansiri is one such, where the PMO has placed a very dubious role in forcing clearances, agreeing to clearance conditions and then starting the project, only to loosen the environmental conditions. In this whole scam the Zoological Survey of India and the Botanical Survey of India have been co-conspirators that have suppressed the ecological value of the forests to facilitate the building of the dam, which will drown pristine elephant, tiger and clouded leopard forests and cause havoc downstream as well.”
The above sequence of events are very pertinent to remember as we see the Subansiri basin study.
[i] Website says: “More than 200 successful environmental Impact Assessment Clearance from Ministry of Environment & Forests, Government of India for Industry, Infrastructure & Construction projects” Sounds strange from an EIA consultant.
The Brahmaputra River, geologically is the youngest among the major rivers in the world yet it is known as a moving ocean. The river Brahmaputra travels 2880 km from its origin in the young Himalayan range through the Tibet and India and finally merges with the sea in Bangladesh by opening its streams like the roots of a large Banyan tree. While traversing through India the river is astonishingly wide at some areas. In Upper Assam near Dibrugarh the river is 16 km wide where as in lower Assam at Pandu, near Guwahati the river is 1.2 km wide but in the immediate downstream it is nearly 18 km wide. Brahmaputra which is mainly a glacier fed river has also the distinction of being the river with highest sediment yield 852.4 t/km2/y in the world and second highest water yield at delta, next only to Amazon.
Origin and Path
The BrahmaputraRiver originates in the Chemayungdung mountain ranges which nearly sixty miles south-east of Mansarovar lake in the MountKailash 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.
Out of its total length of 2,880 km the Brahmaputra covers a major part of its journey in Tibet as Tsangpo. Tsangpo or the BrahmaputraRiver flows 1625 km in Tibet parallel to the main range of Himalayas before entering India through Arunachal Pradesh.
Apart from the name Tsangpo, the Brahmaputra is also known by its Chinese name, Yarlung Zangbo in Tibet. There are several tributaries of Tsangpo in Tibet. According to Encyclopedia Britannica, Raka Zangbo (Raka Tsangpo), Lhasa (Kyi) and Nyang Qu (Gyamda) are prominent north bank tributaries where as Nyang Qu (Nyang Chu) is a tributary on the south bank. The Raka Zangbo (Raka Tsangpo) joins Tsangpo in the west of Xigazê (Shigatse) and Nyang Qu (Gyamda) River joins the river from the north at Zela (Tsela Dzong). The Lhasa (Kyi) river flows past the Tibetan capital of Lhasa and joins the Tsangpo at Qüxü. The right bank tributary Nyang Qu (Nyang Chu) meets the Tsangpo at Xigazê.
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. This is the celebrated great bend where China has plans to build the world’s biggest hydropower project of 40 000 MW capacity and also divert water from here to the North China, though China is currently denying any such plans.
The river enters Arunachal Pradesh near Gelling where it is known as the Siang or Dihang. The total length of Siang River is 294.5 km till its point of confluence with Dibang and Lohit River. The elevation of Siang river catchment area ranges from 90 m to around 5800 m. In India the total catchment of Siang river up to its confluence with Dibang is 14965.30 sq km.
The SiangRiver meets two other major tributaries of Brahmaputra, Dibang and Lohit in the west of Sadiya, at a place named Kobo. From this confluence point, the river is known as the Brahmaputra till it enters Bangladesh. In India the journey of the river Brahmaputra is 918 km long.
A recent study has shown that Kobo used to be confluence point in 1915. By 1975 the confluence shifted to a place called Laikaghat which is 16 km downstream of the earlier point of confluence. In 2005 through satellite images it was observed that the confluence point has shifted “19 km farther downstream”.
The river crosses Assam below Dhubri and enters Bangladesh where the river is known as Jamuna and it flows for 337 km. Regarding Brahmaputra’s role in Bangladesh a study writes “The Jamuna is the local name given to the river for its entire length in Bangladesh to the Ganges junction.
The Brahmaputra-Jamuna has one principal tributary input, the TeestaRiver in the north-west, and two major offtakes on the left bank that are the Old Brahmaputra and the Dhaleswari. The Brahmaputra/Jamuna River contributes ~51% of the water discharge and 38% of the sediment yield to the Padma (Schumm and Winkley, 1994), with the sediment yield being estimated at 590 MT/ yr and the sand fraction contributing 34% of this total (Sarker, 1996).” The Jamuna joins the Ganges at Goalundo Ghat and from here the combined flows of these two mighty rivers are known as Padma which joins Meghna in the downstream. The united stream thereafter known as the Meghna and with this name the river Brahmaputra ends its journey, entering the Bay of Bengal.
Bhutan forms an integral part of the Brahmaputra river basin even though it does not come in the path of the river. In our subsequent blogs we will bring a detail account of Bhutan’s role in Brahmaputra river basin.
The Brahmaputra River Basin
The Brahmaputra river is an international river and its river basin is spread over four countries Bhutan, Tibet , India and Bangladesh with a total basin area of 5,80,000 sq. km. Out of this total catchment area 50.5% lies in Tibet, 33.6% in India, 8.1% in Bangladesh and 7.8% in Bhutan. For geologist and environmentalist the Brahmaputra is a very unique river because “drains such diverse environments as the cold dry plateau of Tibet, the rain-drenched Himalayan slopes, the landlocked alluvial plains of Assam and the vast deltaic lowlands of Bangladesh.”
In India the total basin area of BrahmaputraRiver is 197 316 sq. km. which 5.9% of the total geographic area of the country. In India the river is spread over states of Arunachal Pradesh, Assam, West Bengal, Meghalaya, Nagaland and Sikkim.
In India state-wise the drainage area of the BrahmaputraRiver is as follows:
Drainage area (sq. km)
% of state area in Brahmaputra basin
Source: ‘Intregrated Water Resource Development: A Plan for Action’, MoWR, Govt. of India, September, 1999
The Arunachal Pradesh and Nagaland portion of the Brahmaputra river basin is mainly covered by mountain ranges and narrow valleys. Meghalaya part of the basin is majorly covered by hills where as Assam and West Bengal are mostly plain areas.
Politically in India the basin is spread over 22 parliamentary constituencies (2009) comprising 12 in Assam, 4 in West Bengal, 2 in Arunachal Pradesh, 2 in Meghalaya, 1 in Sikkim and 1 in Nagaland.
Projected Water Use for Diverse Purposes in the Brahmaputra Basin
197 316 km2
Population (1991 census)
Surface-Water Potential (Av Annual)
Utilisable Surface Water
Total Replenishable Ground Water (Av. Annual)
Natural Groundwater Recharge from Rainfall
Estimated Utilisable Flow excluding Ground Water
Source: ‘Integrated Water Resource Development: A Plan for Action’, MoWR, Govt. of India, September, 1999
Tributaries of Brahmaputra
Studies have stated that the Brahmaputra river in its entire course receive water from a large number of tributaries. A study called “Study of Brahmaputra River Erosion and Its Control” done by IIT Roorkee stated “the Brahmaputra receives as many as 22 major tributaries in Tibet, 33 in India and three in Bangladesh.” However this study did not mention anything about the river in Arunachal. We have already mentioned about the few of the tributaries Tibet. In Arunachal the major tributaries of Siang River are Ringong Asi, Yang Sang Chhu, Sigong/ Sirapateng, Niyikgong, Angong, Simang, Yamne, Siyom, Yargyap, Hirit Korong.
In the course of journey through Assam from east to west, some of the important tributaries of the BrahmaputraRiver which join the river on the north bank are Lohit, Dibang, Subansiri, Jiabharali, Barnadi, Puthimari, Pagladia, Beki, Manas, Ai, Gabhoru, Chompawati, Sankosh, Raidhak, Torsa, Teesta etc. Burhidihing, Desang, Dikhow, Jamji, Bhogdoi, Kakdonga, Dhansiri, Kopili, Kolong, Sonai, Digaru, Bharalu, Krishnai, Dudhnoi are the major tributaries on the left bank. The actual number of rivers and rivulets which joins the mighty river is much larger than this list. In subsequent blogs we will try to go into details of some of the tributaries of the river Brahmaputra.
Hydrology of Brahmaputra
For the river Brahmaputra the average annual flow (water discharge) throughout Assam vary from 8500 to 17000 cubic meters per second. At Pandu Ghat near SaraighatBridge the average annual floods recorded was 16,000 cubic meters per second. During floods water discharge reaches its peak and the yearly average peak flow recorded was approximately 51,000 cubic meters per second. At its mouth in Bangladesh, the average annual discharge of the river is 19,830 cubic meters per second. This is the fourth highest average annual discharge in the world. For the river Brahmaputra the highest daily discharge was recorded in August 1962 at Pandu which was 72,726 cubic meters per second. The lowest daily discharge at the same place was 1757 cubic meters per second in February 1968.
Though the Brahmaputra has been described as a braided river, recent studies have shown that the river does not fit into the conventional definition of braided river. A recent study states “In the study reach of the upper Assam area, the Brahmaputra appears to be a multichannel and multi-pattern river that has a tendency to very frequently generate ananabranching (Latrubesse, 2008) pattern in decadal scale.” 
The Brahmaputra has been widening its (riverbed) size continuously from the last century. Reports from Water Resource Department showed that in Assam the river Brahmaputra was spread over for 4000 sq km in 1920 but in 2008 this has increased to 6000 sq km.
The Brahmaputra along with several of its major tributaries like Subansiri, Jia Bharali, Manas had very high water yields which are higher than most of the major rivers in the world. The reason behind such high water yield for Dr. D.C. Goswami, one of the renowned environmental scientist from Assam is “High monsoon rainfall in the upper catchments and their steep gradients are considered to be the major factors responsible for the high rates of unit discharge which in turn help generate the high sediment yield from the basin and contribute significantly towards causing drainage congestion in the valley.”
Seismicity and Brahmaputra Basin
The Brahmaputra river basin and its adjoining hill ranges are seismically very unstable because it is located in the Eurasian (Chinese) and Indian tectonic plates. The most severe earthquakes with Richter magnitude 8.7 was recorded twice in the valley, in 1897 and 1950. The latter one particularly had severe impacts on the river Brahmaputra. As a result of this earthquake river bed was raised at least by three meters at Dibrugarh which had increased the flood and erosion intensity of the river. In the opinion of geomorphologists “the region’s active seismicity has a significant impact on the hydro-geomorphic regime of the Brahmaputra system of rivers, causing landslides that result in the natural damming of rivers, flash floods due to the bursting of landslide-induced temporary dams, raising of riverbeds by siltation, fissuring and sand venting, elevation of existing river and lake bottoms and margins, creation of new water bodies and waterfalls due to faulting.”
The Brahmaputra in its path from snow covered mountains of Himalaya to the deltaic flood plains of Bangladesh covers different climatic regimes. The mean annual rainfall in the Brahmaputra basin excluding the Tibetan portion is 2300 mm. The distribution of rainfall is different at different parts of the basin. In the southern slopes of Himalaya the rainfall is over 6000 mm but in parts of Nagaland this is 1200 mm. The monsoon rainfall (June to September) contribute 60-70% to the annual rainfall of the basin.
In this basin, areas which are above or equal to the elevation of 1500 m experience snowfall. In the Indian part of Brahmaputra basin there are 610 glaciers which covers an area of 928.91 sq km and the volume of these glaciers are 49.57 cubic km. Out of these 449 glaciers are in Teesta basin and 161 glaciers are in Arunachal. In the Brahmaputra basin, Himalayan snow and glacial melt waters play a very significant role in water availability and climate change will have severe impacts on this. Climate change will also impact the rainfall and snowfall pattern in the Brahmaputra basin. This issue needs more serious attention and we will come up with more detailed blogs on this.
Bio-Diversity in the Brahmaputra Basin
The Brahmaputra river basin hosts very rich and unique bio-diversity. The whole of northeastern region is a globally recognized bio-diversity hot spot. In the Indian territory the total forest cover of the Brahmaputra basin is 1,14,894 sq. km. which is 54% of the total basin area. In the distribution of forest cover among 6 states in Brahmaputra basin, Arunachal Pradesh tops the list with 82.8% forest cover but it is sad that the highest number of hydro-electric dams are planned in this state inviting disastrous impacts for the biodiversity, forests, people and environment. The tally of rest of the five states is as follows – Nagaland (68.9%), Meghalaya (63.5%), Sikkim (38.1%), West Bengal (21.4 %) and Assam (20.6 %).
Besides, the aquatic bio-diversity of the Brahmaputra and its tributaries is also very rich. Here we should also take the case of ‘beel’ or wetlands in the Brahmaputra flood plains which according to experts work as ”ecotonal zones” and ”play an important role in the dynamics of the Brahmaputra ecosystem, as these are natural feeding and breeding grounds for a number of fish species and other aquatic fauna.”
Flood and Erosion
Brahmaputra river basin is known to be very prone to flood and erosion and these two hazards have led to many problems in the basin. In India, out of the eight northeastern states, Assam faces the most severe brunt of flood and erosion. Both flood erosion has been severely affecting the economy as well political, social and cultural milieu of Assam.
Experts opine that natural as well anthropogenic factors lead to devastating floods in northeastern region. “The unique geo-environmental setting of the region vis-à-vis the eastern Himalayas, the highly potent monsoon regime, weak geological formation, active seismicity, accelerated erosion, rapid channel aggradations, massive deforestation, intense land use pressure and high population growth especially in the floodplain belt, and ad hoc type temporary flood control measures are some of the dominant factors that cause and/or intensify floods in the Brahmaputra and the Barak basins (Goswami, 1998).” The Brahmaputra river basin is also prone to flash floods and some of the worst flash floods have occurred in the valley in the new millennium.
Along with floods, erosion is also threatening the lives of the people in the state of Assam as it leads to permanent loss of land. Here we can take the case of the river island Majuli, which had been one of the worst sufferers of the erosion done by Brahmaputra. In 1853 the total area of Majuli was 1129 sq km but it has now reduced to 3.55 sq km.
In Bangladesh the Brahmaputra river which known as Jamuna is also infamous for severe floods and erosion. The river carries huge water and sediment discharge in this deltaic region. Because of its geographical setting, Bangladesh is very much dependent on its river for fertile fields and diverse flora and aqua culture but rivers also brings several hazards in the form of floods and erosion. Bangladesh has witnessed severe annual floods but the floods in 1987, 1988, 1998 and 2004 were the most severe ones in recent decades. But studies have shown that, “The people of Bangladesh have adapted their lifestyle for centuries to live with river flooding – frequently moving their temporary bank-side homes, planting on newly emergent river bars, and sometimes raising their homesteads above water level in flood periods (Paul, 1997). However, a growing population, coupled with the expansion of infrastructure and economic development, has resulted in an increase in the intensity of flood damage (FPCO, 1995; Paul, 1997; CPD, 2004). The lives of many millions of Bangladeshi citizens is thus reliant on these rivers, with up to 600,000 people living on the riverine islands and bars alone (Sarker et al., 2003).”
In order to protect people from the fury of floods and erosion the main measure taken in India as well in Bangladesh is the construction of embankments. In Assam the total length of embankment is 4,473.83 km constructed on a total of 130 small and big rivers. But recent reports say that out this, 3376 km embankments are in a vulnerable condition and need immediate strengthening and repair. As a deltaic region Bangladesh too has put its thrust on increasing length of embankments. In 1989 Bangladesh launched an elaborate flood control programme through construction of embankments which was named as ‘Flood Action Plan’. But this plan was vehemently criticized both at national and international level.
In order to control the floods in Brahmaputra valley one of the proposed solution is construction of multi-purpose dams. In fact flood control was one of the pretexts for hydro-development in the northeastern region. But the idea that multipurpose dams can lead to flood control along with hydro-power generation is actually contradictory and unviable as seen from experience of such projects. Studies done on some of the biggest multi-purpose river valley projects of independent India, e.g. ‘Unravelling Bhakra’ by Shripad Dharmadhikary, ‘Drown and Dammed’ done on Hirakud by Prof Rohan D’Souza, “One Valley and a Thousand: Dams, Nationalism, and Development, Studies in Social Ecology & Environmental History” on Damodar Valley dams by Daniel Klingensmith have shown how unviable this proposition is. A number of these dams have actually created avoidable flood disasters in the downstream areas due to wrong operation of the dams. In case of the mightly Brahmaputra river, this is likely to prove even greater disastrous considering its characteristics described above.
Today Brahmaputra valley is witnessing severe opposition against hydro-power dams. The struggle against the Lower Subansiri hydro-electric project can be regarded as milestone. In the Brahmaputra valley the hydropower projects have been opposed also because of the impacts which it will going to have in the downstream as well as on the biodiversity, seismicity, society and culture of one of the most ecological sensitive areas. .
Institutional Mechanism over Brahmaputra in India
The Brahmaputra Board is the foremost body on Brahmaputra established by Government of India under an Act of Parliament i.e. The Brahmaputra Board Act, 1980 (46 of 1980) under the Ministry of Irrigation which now renamed as Ministry of Water Resources. The main task entrusted on Brahmaputra Board is ‘planning and integrated implementation of measures for the control of floods and bank erosion in the BrahmaputraValley and for matters connected therewith.’BothBrahmaputra and Barak valleys are under the jurisdiction of Brahmaputra Board. Even though this independent board was established to better manage the flood and erosion problem of the two river basins, but its activities have come under severe public criticism. Besides Brahmaputra Board, the State Water Resource Department and Central Water Commission also looks after water issues in the river basin. Recently international funding agency Asian Development Bank (ADB) has come to be associated with flood and erosion control in the Assam but from the experiences of Bangladesh, the advent such agencies must be dealt with precaution.
Brahmaputra Valley as the Point of Confluence for People and Cultures
The Brahmaputra is a dynamic river whose dynamism is not only limited to its physical characters or features of the river, but immersed in social, political, economic and cultural aspects. The Brahmaputra valley has been the space of assimilation for people from different races and the one can find large variety of languages and dialects being spoken in this valley. The northeastern region falls under the Brahmaputra and Barak River basin which is home for more than 166 separate tribes, 160 scheduled tribes and over 400 other tribal and sub-tribal communities and groups, speaking a wide range of languages (Climate Change in India: A 4×4 Assessment, 2010). The northeastern region can also be considered as an ‘ethnological transition zone’ between India and the neighbouring countries of Bhutan, Tibet, Burma and Bangladesh. In this region one can find 220 languages belonging to three language families – Indo-Aryan, Sino-Tibetan and Austric.
Relevance of Brahmaputra for Assam
For Assam, the state located at the center of the northeastern region, the river Brahmaputra paves its way through this state like the lifeline of the state. The river ‘Brahmaputra’ literally means ‘Son of Brahma’. It is also one of the few rivers in India which is regarded as a ‘male’ river. There are several myths and legends about the Brahmaputra’s origin and we will bring those together in our coming blogs.
In Assam Brahmaputra River is also known by several other names i.e. ‘Luit’, ‘Siri Luit’, ‘Bor Luit’ ‘Bor Noi’. For the people of Assam, the Brahmaputra is a symbol of great pride due to its ‘moving ocean’ size but this also ignites fear when it rises to its strength during floods. People of Assam have faced difficult times when the river has come to its full strength. Famous singer Jayanta Hazarika wrote, when he formed ‘Xur bahini’ to gather relief for flood victims “Luitor Bolia baan, toloi koloi nu dhapoli meliso, hir hir sowode kal roop dhori loi kaak nu bare bare khediso (Oh the maddening floods of Luit, where are you heading this time. Whom are you chasing again with frightening sound of your waves)”.
But this river is also the source of strength for the people of Assam. Time and again, they have expressed their unity as ‘Luitporia’ or ‘people from the banks of Luit’. The famous cultural icon of Assam, Jyoti Prasad Agarwala wrote in 1942 during Indian Freedom movement “Luitor parore ami deka lora, moriboloi bhoi nai (we are the youth from the banks of Luit and we don’t have any fear of death)”. For another legendary cultural icon, Dr. Bhupen Hazarika who is known as the bard of Brahmaputra, the river’s power of destruction was the source which will awaken the people. In his famous song “Bistirno parore” he asked the river – “Sahasro barishar, unmadonar, avigyotare, pangu manobok sawal songrami aru agrogami kori nutula kiyo (with your maddening experience of thousand monsoons, why don’t you arouse the disabled human beings for struggle and progress)”.
This blog is a small step to document the various aspects of the river Brahmaputra. It is the need of the hour since a flood of dams are proposed to submerge the Brahmaputra valley. Chinese plans of dam construction is not very much in the public domain but the impacts of dam construction of in the upstream Tibet will have severe impacts on the Brahmaputra river. Besides, the bogey of Chinese threat to divert the waters of Siang is used by the Indian government to push for rapid dam construction sidelining all the social, environmental, safety, sustainability, climate change concerns and impacts on the river ecosystem. The government very shamelessly has also put aside all the democratic processes to push for rapid dam construction. Though there is no proposal for a dam on the Brahmaputra in Assam, there are proposals to dam its major upstream tributaries. This upsurge of dams, if they do get constructed will have huge impacts on the Brahmaputra River which are yet not known due to lack of credible projects specific or cumulative impacts assessment studies. These studies should include issues like the river ecosystem, river bio-diversity, forests and wildlife, climate change, floods and erosion and economic and socio-cultural impacts. However, we are hopeful that the ongoing struggles against such unjustifiable projects will succeed and all these projects won’t come up. Through a series of blogs we will also try to bring together all these different streams of concerns.
Himanshu Thakkar, Parag Jyoti Saikia
South Asia Network on Dams, Rivers & People (www.sandrp.in) Email: email@example.com, firstname.lastname@example.org
 Lahiri, S.K., Sinha, R., Tectonic controls on the morphodynamics of the Brahmaputra River system in the upper As-sam valley, India, Geomorphology (2012)
EnvironmentAssessmentReport SiangBasin In Arunachal Pradesh, Interim Report June 2012, Prepared for Central Water Commission(CWC
 Lahiri, S.K., Sinha, R., Tectonic controls on the morphodynamics of the Brahmaputra River system in the upper As-sam valley, India, Geomorphology (2012)