In a shocking development, Consortium of Indian Institute of Technology (IITC) has submitted a report that is a shot in the arm for the hydropower lobby in Ganga basin in Uttarakhand. This IITC report is being used by the Union Ministry of Environment, Forests and Climate Change (MoEF&CC) to push ahead 24 Hydropower Projects in Uttarakhand which were recommended to be cancelled by two official expert reports, both commissioned on the orders of the Supreme Court of India. It seems the authors of the IITC report are jeopardizing the formidable reputation of the IITs and over a dozen other institutes which are a part of IITC, possibly for some short term gains.

Sounds ridiculous? Read on..

WII report The first expert report mentioned above is the report of the Wildlife Institute of India (WII), commissioned by the MoEF & CC to assess the cumulative impact of some 70 hydropower projects in Alaknanda-Bhagirathi basin in Uttarakhand. WII submitted the report to MoEF&CC in April 2012 and among other recommendations, said that 24 of these projects should be dropped due to their irreversible & long term impact on aquatic and terrestrial biodiversity. At the outset it should be mentioned that the WII (“an internationally acclaimed”, “autonomous institute of MoEF&CC”, see: http://www.wii.gov.in/) recommendation of dropping 24 projects was based on assessment of aquatic and terrestrial biodiversity impacts of the series of hydropower projects in Bhagirathi-Alaknanda basins in Uttarakhand. WII was commissioned to do this study by the MoEF&CC following an earlier SC order based on CEC (Central Empowered Committee) recommendation.

MoEF&CC, did not want to take the recommended action, so it sat on the recommendation of the WII report.

EB report following SC directions to Ministry to take stand on WII report On Aug 13, 2013, following the Uttarakhand disaster of June 2013, the Supreme Court directions, among other things included, “MoEF is directed to examine, as noticed by WII in its report, as to whether the proposed 24 projects are causing significant impact on the biodiversity of Alaknanda and Bhagirath River basins.” Again, MoEF&CC did not want to do any such examination on its own. Since MoEF&CC was setting up an expert body to examine the role of hydropower projects in the Uttarakhand disaster as per other directions of the same SC order of Aug 13, 2013, the ministry included such examination also in the Terms of Reference of the Expert Body (EB) under chairmanship of Dr Ravi Chopra.

The EB terms of reference were even wider than that of WII study and the expertise available with EB was also wider. With such expertise and terms of reference, the EB report (by 11 of the 13 members of EB) submitted to MoEF&CC in April 2014 came to the conclusion that 23 of the 24 projects in WII list should be dropped and even the 24^th project, namely the Kotli Bhel 1A should go ahead only after significant modifications. Thus, essentially, EB too endorsed the WII recommendation.

It should be noted here that the WII recommendations were peer reviewed (during the work of Expert Body in 2013-14) by renowned biodiversity expert Dr Brij Gopal. Dr Brij Gopal too endorsed WII recommendation that the 24 projects should be dropped. The peer review was sought by the Central Water Commission representative at the 2^nd EB Meeting. Despite objections from some EB members, the Chairman agreed to such a review and proposed the name of Dr. Brij Gopal which was promptly seconded by the Vice-Chairman, Dr. B.P. Das – a former Chief Engineer (Irr), Govt of Odisha and former Vice Chairman of the MOEF&CC’s Expert Appraisal Committee on River Valley Projects. In fact Dr. Brij Gopal suggested that more projects needed to be dropped.

MoEF&CC still did not want to take action on the 24 projects. So using the dissenting report by two government agencies which were largely toeing their official position in EB, the MoEF&CC suggested to the Supreme Court of India on May 7, 2014 that it wants to set up another committee. Seeing no validity in this, the Honorable SC rejected this suggestion and asked MoEF&CC to take a stand. SC has also since then put a stay on any further work on these 24 projects.

Still not ready to take a stand, MoEF&CC, used the reason that since IITC was already working on Ganga River Basin Management Plan (GRBMP) for the ministry since 2010 went ahead and gave the task of reconciling the two EB reports to IITC. In effect this is tantamount to violating the SC directions of not appointing another committee. However, unlike the picture it tried to give to SC, this task was not part of GRBMP work, but given to IITC through a fresh TOR.

Perturbed at not receiving any serious required response from MoEF&CC after repeated orders, the apex court judges of the Supreme Court rightly said the ministry was behaving like Kumbhakarna and Rip Van Winkle.

On Oct 9, 2014, the MoEF&CC submitted an affidavit to the SC, relying entirely on a report from IITC. And lo and behold, IITC had provided a report to the MoEF&CC, certifying that with some vaguely defined criteria, all the 24 projects can go ahead and there is no need to cancel any project! Serendipitously, this is exactly what the MoEF&CC & the hydropower lobby wanted!

It needs to be stated here that IITC had no mandate to submit such a report and the report is unprofessional, inadequate, unwarranted and inconsistent.

Let us see how.

Authors of the IITC report IITC report was authored by eight persons: Dr Vinod Tare (Civil Engineering Dept, IIT Kanpur, see: http://www.iitk.ac.in/ce/CIVIL/faculty.htm), Dr I M Mishra (Department of Chemical Engineering, IIT Roorkee, see: http://www.iitr.ac.in/departments/CH/pages/People+Faculty+imishfch.html#), Dr Purnendu Bose (Civil Engineering Department, IIT Kanpur, see: http://www.iitk.ac.in/ce/CIVIL/faculty.htm), Dr Ligy Philip (Civil Engineering Dept, IIT Madras, see: http://www.civil.iitm.ac.in/people/faculty/ligy/about.html), Dr B S Murty (Civil Engineering Dept, IIT Madras, see: http://www.civil.iitm.ac.in/?q=murty_edu), Dr R P Mathur (formerly Prof of Civil Engineering, University of Roorkee), Dr M Jawed (Dept of Civil Engineering, IIT Guwahati, see: http://www.iitg.ac.in/jawed/homepage/index.html) & Dr Gautam Roy (Consultant GRBMP and former student of Civil Engineering Department at IIT Kanpur). A perusal of the available information on professional background of these persons shows that none of them have expertise on the aquatic and terrestrial biodiversity of the Bhagirathi-Alaknanda basin, to decide on the appropriateness of the WII recommendations. Hence at the outset it seems inappropriate for IITC to sit on judgment over recommendation of an expert body, on subject matter of which IITC has no expertise.

The IITC team of 8 persons listed above, all with essentially engineering background have now also reviewed the EB report and made their own recommendations, again without having the expertise that was available at EB command. It is thus inappropriate for IITC to comment on the recommendations of the EB which had two biodiversity experts from FRI (Forest Research Institute) and WII, besides experts from Uttarakhand in various other disciplines. IITC is thus being unprofessional.

What does IITC report say The IITC report essentially says that ALL the 24 projects can go ahead if they satisfy three criteria: Aviral Dhara, Environmental flows and longitudinal connectivity. The first thing that strikes about these three terms is that they are all vaguely defined and can have flexible interpretations. They are also interconnected and not necessarily independent of each other. Most importantly, they do not take care of the issues based on which the two expert reports said that these 23 projects should be dropped and even the 24^th Project, namely the Kotli Bhel 1A may be dropped or modified. But first let us understand these three vaguely defined, flexible and interconnected terms.

Aviral Dhara: According to the IITC report para 2.1 (see also: “Ganga River Basin Management Plan Extended Summary” of June 2014 available at: http://gangapedia.iitk.ac.in/sites/default/files/2014-06-12_GRBMP_Extended%20Summary.pdf): “Aviral Dhara in this context means that the flow of water, sediments and other natural constituents are continuous and adequate over the entire length of the river throughout the year.” There is no definition of what is adequate here, nor it is clarified as to adequacy is from what point of view. Here it should be noted that Aviral literally means uninterrupted, but neither IITC nor MOEF&CC provide this interpretation. According to MOEF&CC affidavit of Oct 9, 2014 (para 8(c)), Aviral means “to flow round the clock” or “continuous flow”.

Environment Flows: For Environmental flows, the “objective” of GRBMP is (see p 9 of the GRMBP Extended Summary) “Environmental Flows shall be maintained in all rivers and tributaries of Ganga River System to fulfill their geological, ecological, socio‐economic and cultural functions.” The E-flows thus would than depend on identifying functions of the river from geology, ecology, socio-economic and cultural perspectives, which can vary. The GRMBP extended summary does not provide clarity on e-flows for any of these aspects and how to go about arriving at required environment flow. It should be mentioned here that to arrive at environment flows, there are about 200 methodologies available globally. The IITC report attached with the MOEF&CC affidavit remains even vaguer as it says maintenance of E-flow should lead “to river stability and ecological balance in the downstream areas.”

Clarity on environmental flows is crucial as the affidavit from MOEF&CC itself agrees that MOEF&CC did not address the issue of eflows adequately while granting environmental clearances in Uttarakhand. One of the basic reasons behind this was lack of clarity on the issue and the same mistake is being repeated in the IITC Report.

Longitudinal Connectivity: In MOEF&CC affidavit of Oct 9, 2014, it is stated (para 6(b)/ 8(b)) that longitudinal connectivity is necessary to ensure “non-disruptive biota movement and silt transportation along the river course that are essential ingredients of a river ecology and its wholesomeness. Otherwise, a fragmented river stands to lose its basic character along with its native aquatic bio-diversity and ecological integrity.”

One of the two places where the term longitudinal connectivity appears in the GRMBP Extended Summary quoted earlier, says: “For dams and barrages, a precondition is essential that they cannot violate the longitudinal connectivity in River Ganga and her major tributaries. Besides they must allow E‐Flows (Environmental Flows) all along the river. A potential method for ensuring river connectivity through dams/ barrages has been suggested.”

The only other place in the GRBMP Extended Summary where the term longitudinal connectivity appears is interesting as it connects all the three terms that IITC has used: “Thus, while longitudinal connectivity in river network is an essential first step to maintain “Aviral Dhara”, having adequate river flows depends much on basin’s overall water status.” This statement is thus also making all three terms even more flexible, subjective and vague since they are dependent on “basin’s overall water status”. This leaves the door open to later reduce the quantum of E-Flows.

It is thus clear that the IITC report annexed by the MOEF&CC with their Oct 9, 2014 affidavit says that if these three vaguely defined terms that are flexible and prone to subjective interpretations are satisfied, then all the 24 projects can go ahead.

While these three, when clearly defined and properly implemented, are necessary conditions for any hydropower project, to say that they are sufficient condition is not only misleading, but also showing lack of understanding of the environmental issues related to hydropower projects. The MOEF&CC affidavit of Oct 9, 2014 relies exclusively on this IITC report and wants to allow all 24 project based on these three vaguely defined, flexible criteria from IITC report.

However, these three criteria are not sufficient to take a decision about these 24 projects as they exclude large number of criteria that the two expert reports considered, including: terrestrial biodiversity (completely absent in IITC report), cumulative impact (completely absent in IITC report it only looks at project specific issues), projects’ location in hazardous zone, projects increasing the disaster potential of the area, among many others.

The SC’s original direction was to examine if the 24 projects would have significant impact on the biodiversity. So the examination for these 24 projects must be done from the total biodiversity aspect and not on the basis of flow alone. The IITC itself has said in the GRBMP Interim Report of Sept 2013 that if biodiversity impact is significant then the project should be disallowed. It is clear IITC has again been inconsistent.

IITC is inconsistent It should be added here that in table 4.2 of their “Interim GRBMP” of Sept 2013 (see: https://nmcg.nic.in/writereaddata/fileupload/25_GRBMPInterim_Rep.pdf), IITC provides larger set of criteria for deciding permissibility of dams and barrages in the Ganga Basin, which include criteria like threat to terrestrial biodiversity, rare, endangered and threatened (RET) species, geological hazards, loss of historical, religious and cultural sites, among others. But these are no longer considered by the IITC in their current report under discussion. The IITC is also being inconsistent, besides being unprofessional and vague.

IITC report shows lack of understanding on basic environmental issues It is also disturbing to read the IITC report saying (section 2.1, last but one para), “However, projects on streams/ rivers with negligible biota may be allowed to proceed as per the environmental and other clearances already given to such projects provided that adequate provision is made to ensure the mandated E-flows. The adverse environmental impacts of such projects on the Ganga river system as a whole are expected to be negligible. Such projects may, therefore, be kept out of Cumulative Environmental Impact Assessment (CEIA) for their approval.”

Firstly, this shows that IITC is out-rightly overruling the recommendation of the WII and EB on criteria of terrestrial biodiversity, geological stability and so on. IITC is doing that too without providing any reasoning or basis. Significant number of the 24 projects have been recommended for rejection by WII and EB based on these criteria. Such baseless rejection of the recommendation by IITC not only shows their poor understanding of environmental and geological issues, but also shows their pro hydro bias.

Secondly, IITC makes the contention that the adverse environment impacts of such projects on Ganga river system is expected to be negligible, without providing any basis or scientific logic or reasoning.

Thirdly, suggesting that all such projects may be kept out of the CEIA seems to show poor understanding of the basics CEIA by the authors of IITC report. Large number of even so called low impact interventions can also cumulatively have big impacts and to exclude them is against the very spirit of CEIA. It also then raises doubts about competence of IITC to prepare GRBMP, since GRBMP is supposed to also look at the cumulative impact assessment and carrying capacity of major interventions in the Ganga Basin. IITC authors do not seem to understand that even aquatic biota gets affected by geological and other factors, that fish is not the only aquatic biota and that there is upstream downstream linkages in lifecycle of the aquatic biota and that there are linkages between aquatic and terrestrial biota life cycles, affected by hydrology.

The above stated issues raise serious doubts about the appropriateness of the IITC report and MOEF&CC’s attempts to push ahead with the 24 hydropower projects in fragile and disaster prone Bhagirathi-Alaknanda basin based on the inappropriate IITC report. Particularly when these projects were to be cancelled as per two expert reports, both commissioned following two separate apex court orders.

Issue of cumulative impacts cannot be taken care of through project specific actions Here it should be noted that the WII report has made its recommendation about dropping 24 HEPs based on cumulative impact assessment of all the operating, under construction and planned projects in the Bhagirathi-Alaknanda River basins. The same is true with respect to EB recommendation. The conclusions arrived at based on cumulative impact assessment by the WII and EB cannot and should not be sought to be addressed by looking at project specific steps or actions as MOEF&CC affidavit and IITC reports are doing.

Did Project Management Board allow IITC to do this report? The IITC task of GRBMP is being overseen by a Project Management Board (PMB) comprising of senior persons of all the seven IITs and some invited members. The IITC report dated July 21, 2014 mentions, “The PMB in its fifth meeting held on Tuesday, June 24, 2014 at IIT Delhi agreed to examine the two reports in the broader framework developed for GRMBP.”

While this is what IITC claims in its July 21, 2014 report, this claim is not supported by the Minutes of the relevant meeting of PMB, as we see below. From the reading of the minutes, it seems that the IITC had no mandate or clearance to do this report.

In the minutes of the fifth meeting of PMB held on June 24, 2014, para 7 seems to be the only relevant para in this context, which reads as follows: “Project Coordinator sought the directions from PMB about the modus operandi for follow-up actions after submission of the final draft of GRBMP – such as responding to queries and comments on GRBMP and dealing with requests for other inputs on Ganga Basin received from government and other agencies. He mentioned that IITC is obliged to respond to such requests based on the work done in preparing GRBMP, and the help of only active contributors of IITC would be needed rather than the existing mechanism of going through PICC and PMB. Professor Manna, Director, IIT Kanpur stated that IIT Kanpur is willing to take the responsibility on behalf of IITC of such matters and Project Coordinator may take the help and advice of concerned IIT Team members as and when needed. It was opined that each IIT may compile the list of new faculty members who may have joined after GRBMP project was started and communicate the same to the Project Coordinator. Professor Khakhar suggested that Directors of the 7 IITs may discuss the matter and communicate the decision to the Project Coordinator on modus operandi for submission of first version of GRBMP, and responding to queries and comments on GRBMP and dealing with requests for other inputs on Ganga Basin received from government and other agencies.”

The first thing that strikes about this para is that the Project Coordinator (Dr Vinod Tare) raised this in the context of “follow-up actions after submission of the final draft of GRBMP”, which is not the case with respect to current issue, since the final draft of the GRBMP is yet to be submitted. There is nothing in this para to support the contention quoted above from the preface of the IITC report that PMB “agreed to examine the two reports in the broader framework developed for GRMBP.”

If this is the only para that is relevant in the context of IITC report to MOEF&CC dated July 21, 2014 and if this para is not applicable at this stage since it is applicable only after submission of final draft of GRBMP, then the question arises, if the IITC had the permission from PMB to submit such a report and if the MOEF&CC should have submitted this report as authorized IITC report? These questions can be answered by only the IITC, its PMB and MOEF&CC, but they are relevant since it is this report purportedly from IITC that is sought to be used by MOEF&CC to ensure that all the 24 projects under discussion go ahead. In fact PMB and all concerned from IITC should quickly clarify that this report cannot be called IITC report, but only from the specific 8 persons listed above. The authors should be asked to remove the claim that this is IITC report.

IITR has poor track record and conflict of interest Here it is pertinent to note that of the four IITs involved in this report of IITC, IIT Roorkee (IITR) has already proven to have a poor and biased track record and should not have been involved in any case. The IITR was in fact commissioned in July 2010 by MOEF&CC to do cumulative impact assessment of the hydropower projects in Bhagirathi-Alaknanda basin. The report submitted by IITR was so pathetic that it was not accepted and it invited adverse comments from official agencies like the Expert Appraisal Committee on River Valley Projects, the Inter Ministerial Group on Ganga Basin Projects and also the Supreme Court of India in Aug 2013 order. (The report was also criticized by other organisations[1].)

Thus, IITR stands discredited on the precise issue of cumulative impacts of hydropower projects in Bhagirathi-Alaknanda basin. To include such an institute for another IITC report now on the same issue not only brings discredit to the whole effort, but raises the issue of conflict of interest.

While some issues are based on procedures and propriety, other issues relate to merit of IITC recommendations as they do not hold the experience or expertise to deal with serious problems related to cumulative impacts, terrestrial biodiversity and RET species, deforestation, and disaster potential of the region.

Thus, on both these counts (technical and merit based), the IITC Report is under cloud and does not hold enough ground to base further informed decisions.

Conclusion In view of the above, it is clear that IITC report is not adequate, reliable, or consistent to take a decision about 23 hydropower projects which have been recommended to be dropped and 24^th project, namely the Kotli Bhel 1A project which has been recommended to be dropped/ modified by the WII and EB. IITC had neither the expertise nor the mandate to submit such a report. The MOEF&CC should not be relying on this report and rather coming out with its own position as directed by the Supreme Court of India repeatedly, keeping in mind the issues and merits of the two expert reports, both submitted following two separate apex court orders.

It is unfortunate that IITC has submitted a report that is obviously music to both hydropower developers and government. MoEF&CC has already offered more such work to IITC. We hope IITC will go beyond such short term interests and be more consistent, professional and work towards rejuvenation of the Ganga and other rivers.

This current work is discrediting their future work of GRBMP too.

-Himanshu Thakkar, SANDRP (Being an IIT Mumbai alumni myself, I am writing this with a sense of sadness)

[1] For example, see: http://www.sandrp.in/hydropower/Pathetic_Cumulative_Impact_Assessment_of_Ganga_Hydro_projects.pdf