Reaching exasperating lows of environment decision making, the Forest Advisory Committee (FAC is a statutory body of the Ministry of Environment Forests and Climate Change (MoEFCC) formed under the Forest Conservation Act of 1980. FAC appraises Forest diversion proposals) has recommended Forest Clearance to the 3000 MW Dibang Project on Dibang river in Arunachal Pradesh.
While we had already written against this recommendation, what is nearly unbelievable is that this recommendation has come at just 10 meters height reduction of the dam from the proposed 288 meters.
This was the very same NHPC proposal which was rejected twice by the FAC in the past,[1] despite this token 10 meter height reduction. In fact in April 2014, the FAC said that 10 mt reduction does not take care of any pertinent impacts for which the proposal was rejected in the first place in July 2013! A 10 m reduction would still mean destruction of 3.24 lakh trees and submergence of 4577.84 hectares, nearly 12000 acres, of rich bio-diverse forest.
Dibang River. Photo with thanks from Global Post, Scot Ligare
The usually reticent MoEFCC (Ministry of Environment, Forests and Climate Change, MoEF earlier) too had issued a strong-worded rejection to this scheme in August 2014, stating that 10 meters reduction is nothing in the face of what is being lost. The rejection letter stated: “Such a marginal reduction in requirement of the forest land (445 hectares reduction, reducing forest requirement from 5056 hectares to 4577 hectares) for the project may not be able to reduce the adverse impact of project on such a biodiversity-rich mature forest ecosystem to the extent which could make the project environmentally as well as socio-economically viable in forest dependent tribal society of Arunachal Pradesh”.
This letter from the same ministry certified that the 10 m reduction proposal still leaves the project environmentally, socio-economically unviable. So an environmentally and socio-economically unviable project has been recommended clearance by the statutory FAC (and also the separate recommendation a week earlier by the same MEFCC’s Expert Appraisal Committee on River Valley Projects)!
This shows that the decision of FAC is devoid of merits, will invite huge opposition from Arunachal Pradesh, Downstream Assam, North East India, and even beyond and will not pass legal scrutiny. The decision seems to have been taken under pressure from the political masters. Union Power Minister Piyush Goyal has been dreaming of clearance to this project, as is clear from his road map published on completion of 100 days of office for the new NDA government[2]. He has also been pressurizing the MoEFCC to clear the project by hook or by crook. The FAC was reconstituted and the reconstituted FAC has obliged the minister in its very first meeting. In the process, the entire FAC has violated its mandate and should be held accountable for this.
Regrettably, MoEFCC seems to have become the willing punching bag of not only above-mentioned ministries, but even unrelated ministries like Ministry of Mines and Minerals, Ministry of Steel ,etc., whose ministers and Secretaries were present for the meeting: “to Expedite Clearances”. (Incidentally, when was the last time we heard MEFCC resisting such arm-twisting, or forthrightly suggesting any pro-environment measures to other ministries?)
Before the minutes of the September FAC meeting were out on Oct 22, 2014 (there was an inordinate delay this time, raising suspicion of negotiated minutes and again breaking all norms of conduct), there was discussion in media that Dibang was cleared, but even the hard-core skeptics believed that this recommendation must have come after a 20 meter or 40 meter height reduction, for obvious reasons.
But the FAC seems to have outdone itself. As stated above, the recommendation has come at 10 mts height decrease, for which the FAC had rejected the project and MoEF had issued a rejection letter in the past.
As we discussed in detail in our last blog on Dibang project, the twice-rejected project was up for discussions again in Sept 2014 only after considerable arm-twisting of the MEFCC by the Cabinet Committee of Investment, Ministry of Power, Project Developer NHPC and Arunachal State Government. This time it was for a supposed sensitivity analysis (done by the developer!)for studying the feasibility of reducing the height of the project upto 40 meters from its original height of 288 meters.
This sensitivity analysis was not shared with anyone, not even the FAC members till the day of the FAC meeting, breaking all codes of conduct of transparency, participation and informed decision making in governance. SANDRP wrote about this to the Minister and Secretary of MoEFCC as well as the Member of the FAC, but received no response.
Looking at the minutes, it is clear that the FAC members have lapped up the logic presented by the developer and the Ministry of Power which in a nutshell says that “10 meters reduction is sufficient as the ratio of forest land required per MW is lowest at 10 meters reduction.” This twisted logic reduces all decision making related to forests, even biodiversity-rich forests supporting endemic, unstudied species, local protests, downstream impacts etc., to mere number crunching of forest per MW. This criteria alone cannot be the basis for decision for forest appraisal committee.
Dibang Valley Forests Photo: The Telegraph
As per the sensitivity analysis by NHPC, the ratio forest land required per MW for 40 meters reduction is 1.67 MW/ hectare, which is same as no height reduction and 1.78 MW/ hectare in case of 20 meter reduction. In terms of tariff, for 40 meters reduction, the power tariff will be 6.24 Rs./unit while it is 5.66 Rs/unit 10 meters reduction, 5.94 Rs./unit 20 meters reduction and 5.64 Rs. at zero reduction. The installed capacity will reduce by 120 MW (4%) MW for 10 meters reduction, 600 MW (20%) for 20 mt reduction and 780 MW (26%) for a 40 meter reduction.
Height Reduction
Forest land required
MW capacity per ha Forest lost
First Year Tariff: Rs per unit
Reduction in installed capacity
Nil (288 m)
5056 Ha
1.67
5.64
None
10 m
4578 Ha
1.59
5.66
120 (2880 MW)
20 m
4284 Ha
1.78
5.94
600 (2400 MW)
40 m
3703 Ha
1.67
6.24
780 (2200 MW)
The proponent said: “Decrease in dam height and consequent sacrifice of power generation beyond 10 mt is not commensurate with saving forest land.”
How did NHPC reach this conclusion? What is the value of the mature, old growth forest land considered by NHPC? Without knowing this, how can this conclusion be acceptable to the FAC? It has to be remembered that Dibang is not an exclusive hydropower project, but a multipurpose project with a flood moderation component and costs have to be borne for this.
While the proponent and Ministry of Power did their best for pushing the project, the FAC did not do its duty of stating that the sensitivity analysis put forth by NHPC is a sham as it does not consider the worth of the forest being lost.
In this sabji-mandi haggling, when FAC had all the watertight justifications for rejecting the project, it did not bat for even a 40 meter reduction, which could have saved nearly 1355 hectares of forests and would have had a marginal impact on other factors. Its unclear why this happened.
Only one of the FAC members tried to battle the case saying that 10-40 meter reduction still does not address the upstream and downstream impacts, especially considering the biodiversity rich area. The minutes do not disclose the name of this member, but it seems the brute majority (majority of FAC members are govt officials) took the official line, alleging “subjectivity” and said that “To reduce subjectivity, it is important to analyse the issue objectively on objective parameters”. Forgetting that this is Forest Appraisal committee, not Power Developer Committee.
This is ironical. It was indeed the duty of the FAC to appraise the project “objectively” based on issues like destruction of 3.24 lakh trees, invaluable forests, unstudied biodiversity, rich wildlife and several Schedule I species, community dependence, traditional rights, downstream impacts, climate change impacts, options assessment, etc. But it did nothing of that and has in fact recommended the project “subjectively”, bowing to pressures outside their ambit.
Clearly, per MW forest land required and per Unit Tariff from a project are anything but objective criteria for FAC. FAC is supposed to apply its mind to a number of issues like the ones above. If FAC was not supposed to apply its mind to these aspects and its judgment, there was no need for an FAC, Power ministry and developer could have taken the decision independently.
The FAC decision does not address any pertinent issues raised by the same FAC while rejecting the project, it also does not address downstream impacts on Assam or assume any value for a rich forest. There is no discussion why 20 meters or 40 meters reduction is not seriously considered by FAC. Decision-making based on such biased, proponent-driven criteria is bound to be open to legal challenge and public protests.
Sham consideration of Downstream Impacts About Impact of the project on Dibru-Saikhowa National Park, the User Agency said that the issue was considered by EAC in its meeting on the 16th September (Please note this is just 6 days and 5 working days back from FAC meeting. There is no chance of minutes being firmed up by then. They were not in open domain in any case) and the EAC has recommended clearance based on the fact that there is less than 1 meter level fluctuation at DSNP.
This claim in any case is patently incorrect, again a case of project-friendly, anti-environment decision-making. The level fluctuation at DSNP can go way higher than a meter, anywhere from 7-8 feet every day in lean season, according to the studies considered by the EAC of the MEFCC itself. This has been pointed out by SANDRP to the EAC as well. There has been no study of the impacts of this project on downstream Arunachal Pradesh or Assam. The developer seems to assume that Dibru-Saikhowa is the only part of Assam worth considering.
Dibang Valley tribes Photo from go ibibo/dibangvalley
There is no compliance under Forest Rights Act (2006) for such a massive project and despite this, FAC under some supposedly progressive members working on tribal issues, does not bat an eyelid before recommending clearance!
To conclude, pricing mature, biodiversity-rich forests in terms of per MW terms is an insult of those forests, the communities that depend on them and to the mandate of FAC. Downstream impacts of Dibang project are not studied, the impacts on Dibru-Saikhowa are based on compromised studies.
There is no merit in this decision from the newly appointed FAC which includes members also from reputed environment protection organizations in North East and from Tribal Welfare groups like Friends of Baripada. It is also sad to see that there is no dissenting note from a single member. The unnamed member who expressed dissent in the meeting has not written anything about this in public domain.
Decisions like Dibang lay further foundations for poor, pro-developer, anti-people, anti-environment decisions taken due to pressure from proponent and other ministries. Such decisions will not be legally tenable, nor acceptable to affected communities, nor good for sustainability and equity. In fact, by such reversals, FAC decisions are losing their sanctity. FAC has done this in the past too in case of Kalu Dam in Western Ghats which would submerge 18 villages and 1000 hectares forest.
Isn’t it ironical that the new government changed the name of the MoEF to MoEFCC but is sanctioning massive projects like Dibang which will have far reaching impacts on Climate Change as well as adaption and mitigation abilities of the affected communities? Without even considering these aspects or even mentioning them?
The National Green Tribunal, NGT marked its 4th Foundation Day on 18 October 2014, with an impressive fanfare. A full day function was organized at the Plenary hall of the capital’s iconic Vigyan Bhawan. NGT in this short span has acquired a formidable reputation as a unique, vibrant, active institute with independent & unbiased mind and forthright, quick redressal of petitions that come to it.
The function in two separate sessions, one in the forenoon and the other in the afternoon (a Seminar) was attended by large number of government officials, judicial officers, advocates, law school students, NGT petitioners and office bearers and members of the NGT Bar association.
NGT Foundation Function on Oct 18, 2014 (Source: FB page of Information and Broadcasting Ministry)
Invited dignitaries included Mr Justice Ranjan Gogoi (Judge, Supreme Court), Prakash Javadekar (Union Minister of State for Environment, Forests and Climate Change) and Ashok Lavasa (Secretary, MoEF&CC) in the forenoon session and Mr Justice Sudhanshu Jyoti Mukhopadhaya (Judge, Supreme Court) and Piyush Goyal (Union Minister of state for Power, Coal and new and renewable energy). Mr Justice Swatanter Kumar, the Chairperson of the NGT, Mr Justice Dr. P. Jyothimani, Judicial Member, Principal Bench, NGT, Prof. R. Nagendra, and Dr. D.K. Agarwal, Expert Members at the NGT also spoke and graced the dais.
The function included, in addition to the addresses by the invited dignitaries, the release of 2nd issue of NGT International Journal; the launch of new NGT Website (in the first session) and address by invitee experts (in the second session).
In the first session Mr Javadekar informed the gathering about his political beginnings from a water pollution struggle activist against factory pollution and Mr Lavasa categorically stated that the NGT is playing an extremely crucial role and that there is no move to dilute its powers in any manner. It was in the second session that very controversially one Mr M.K. Pandit was invited to speak as an invited expert.
The Minister of State for Environment, Forests and Climate Change (I/C), Shri Prakash Javadekar lighting the lamp at the 4th Foundation Day function of the National Green Tribunal, in New Delhi on October 18, 2014. The Secretary, Environment, Forests and Climate Change, Shri Ashok Lavasa and the Judge, Supreme Court of India, Mr. Justice Ranjan Gogoi are also seen (Source: FB page of I&B Ministry)
Mr Pandit began with highlighting how recent and how fragile the Himalayas were and that a 8+ richter scale earthquake in central Himalayas was round the corner that could flatten Dehradun. Very soon in his almost 25 minute speech changed track as if on a cue to how great the hydropower dam projects in the Himalayas were for the power security of the country. The Union Power Minister had by then just joined the function to nod in full agreement with all that the Mr Pandit was narrating. The audience on the other hand was left perplexed as to what was happening?
An invited speaker was eulogizing the great merits of high dams receiving approving glances from the power minister on an NGT seminar whose topic was “Natural Disasters, Environment & Role of NGT with special reference to Uttarakhand, J&K, Assam & Himachal Pradesh”. Clearly something was amiss, somewhere?
Secondly, Mr Pandit is not a neutral expert, but an interested party. As leader of scores of pro hydro Environmental Impact Assessments that he has led as part of the CISMHE[1] team (Center for Inter-disciplinary studies of Mountain and Hill Environment) has earned them millions as they also continue to mint more money. Typical of Indian EIAs, no EIA done by CISMHE has ever raised any difficult questions for the developers. It has also never concluded that any of the projects is unviable. CISMHE EIAs are as shoddy, incomplete and inadequate as any other[2]. For example on Luhri HEP, the CISMHE EIA was so problematic that even the Ministry of Environment, Forests and Climate Change’s Expert Appraisal Committee on River Valley Projects and the World Bank found it inadequate and unreliable.
Interestingly, CISMHE website says: “Ministry of Power, Government of India established CISMHE as an R&D Centre in power studies in environment in recognition of its excellent past performance”. This means that there is also conflict of interest here in CISMHE doing EIAs, since it has been set up as an R&D Centre by Ministry of Power, that is itself a promoter and developer of hydropower projects. No wonder, Mr Pandit said what the Power Minister wanted to hear and Power Minister made no efforts to hide his approval of what Mr Pandit was saying.
Very strangely, Mr Piyush Goyal claimed that Tehri dam was an example of good project in the Himalayas that saved Uttarakhand in the floods of June 2013. Mr Goyal should know that this claim had absolutely no basis and even an Expert Body appointed by the Supreme Court of India has shown, after listening to THDC, CWC and others that such a claim has no scientific foundation. Mr Pandit did try to support the unfounded contention of Mr Goyal, but the minister asked him to keep quite.
It became clearer, when a pointed question asked by Shri Manoj Misra of Yamuna Jiye Abhiyaan about what would have been the Tehri dam scenario if the Uttarakhand high rainfall event had occurred in the peak monsoon months of July, August or September and not on 16 June 2013 (as in fact happened in Sept 2010, when Tehri created a havoc in the downstream, damaging its own Koteshwar project[3]), when the dam was almost empty and only beginning to get filled, elicited an evasive response first by the Union Minister (we cannot have structures planned for every 365 days in a year). And later when Pandit ji tried to answer, he was asked to shut without him being able to even respond to the other two questions relating to how does he reconcile to the fact of a high intensity earthquake visiting a region where he had been advocating the dams; why was USA (as also some other countries), the mecca of large Dams bringing many of its dams down?
In any case, Mr Maharaj Pandit was contradicting himself, because he said something totally different in his article in The Hindu soon after the Uttarakhand disaster of June 2013: “Most downstream damage in otherwise flood-free areas is caused by dams and barrages, which release large volumes of water to safeguard engineering structures. Dam operators often release more water during rains than the carrying capacity of downstream areas, causing floods… Hydropower policy must consider building fewer dams and prioritise those that have the least environmental and social costs. Independent and serious monitoring of the catchment area treatment plans proposed by Forest Departments with funds from hydropower companies needs to be carried out and reported to the Green Tribunal.” In fact then in June 2013, he was on TV channels almost every night, talking about how Himalayas have the highest dam density in the world and that is such a big invitation to disaster! But he seems ready to change his stand to please the minister or the hydro project developers.
It seems as if Mr Pandit had been invited to justify the building of dams in the Himalayas in front of a large gathering of impressionable judicial officials and young student minds. It is possible that it was also intended to influence the minds of NGT members (judicial and experts) and other persons from judiciary in the face of a number of proposed dams being challenged before the various NGT benches and courts.
If a proper seminar was indeed planned on such an important matter, then there should have been several speakers on wide range of perspectives and topics and not just one speaker with conflict of interest and a clear agenda? The only other technical speaker, Dr R. Nagendran, an expert member with NGT southern bench spoke sensibly on how unscientific management of sanitary projects in hilly regions lead to parallel “Faeco-microbial disaster” which is difficult to tackle.
Mr Ritwick Dutta, secretary of NGT bar association said that the information about Mr Pandit speaking from NGT platform was not available in public domain and it is not clear how he was selected as a speaker.
Such blatant pro hydro bias in an NGT foundation day meeting is certainly unwarranted and out of place for an NGT function. An NGT platform should not have been allowed to be used for such biased presentation. We hope the bias apparent in this aberration is just that, an aberration and does not run deeper, considering that some hydropower professionals have been appointed on NGT benches.
We hope that at least in future the NGT, a statutory judicial body, otherwise doing a great job for the protection of environment, would be more careful in not letting its platform get used by the vested interests. The formidable reputation that NGT has acquired with a lot of remarkable orders should not be allowed to be affected by this one incident. NGT indeed needs to be strengthened in every way and not weakened in any manner.
It would also help if the NGT were to distance itself from this biased episode.
Pushp Jain, EIA Research and Response Centre (http://www.ercindia.org/, Pushp Jain pushp@ercindia.org) & SANDRP (based on interviews with those who were present at the NGT foundation day meeting)
Every possible violation of norms, procedures, law and democratic governance is being committed in pushing clearances for the India’s largest capacity hydropower project, which involves India’s highest dam proposed so far & North East India’s Largest capacity reservoir: the 3000 MW Dibang Multi Purpose Project in Arunachal Pradesh. The players involved in these violations include the Union government of NDA led by BJP (UPA earlier), including its cabinet and Union Ministry of Environment, Forests and Climate Change (MEFCC), Ministry of Power, State government, the project developer company NHPC Ltd, the Expert Appraisal Committee (EAC) and Forest Advisory Committee (FAC).
The project will need more than 4700 hectares of biodiversity rich Forest area with several Schedule I species in Arunachal Pradesh. It will also have significant downstream impacts on the people & environment of Arunachal and Assam and Dibru Saikhowa National Park. Most of its impacts have not been either properly assessed or considered by the developer, EIA agency or the EAC & MEFCC.
Déjà vu: We did the same for Lower Subansiri HEP! It seems the government is indulging in the same blunders that the previous NDA government[1] indulged in over a decade ago while clearing the then-largest capacity hydropower project: the 2000 MW Lower Subansiri Hydropower Project (LSHP), also in Arunachal Pradesh. Environment clearance for LSHP came on July 16, 2003 and stage I forest clearance came on June 10, 2003. Exactly the same set of players were involved in manipulating LSHP clearances over a decade ago. The developer is also the same: NHPC. The government at centre is again led by NDA.
Aaranyak environmental group of Assam, in a letter dated May 16, 2002 to the then-Chief Justice of India had highlighted the violations involved at various stages in the decision making of LSHP including during public hearings, in conducting EIA, in giving environment, forests and wildlife clearances. Almost all the issues that Aranayak letter raised then are applicable in case of Dibang with even greater force. But it seems in the twelve years since 2002 when that letter was written, our environmental governance has only degenerated.
The fate of the LSHP is a lesson in itself. After spending over Rs 5000 crores (Rs 50 Billion), the work on the project came to a standstill in December 2011. It has remained stalled for 34 months since then, following India’s biggest Anti dam People’s movement so far. This is unprecedented in India’s hydropower history. NHPC Ltd has been trying every possible trick to resume the construction work on LSHP, without genuinely trying to address the issues people’s movement has been raising.
Dr Mite Linggi, Representative of Kere A Initiative for Cultural and Ecological Security said exactly that at the public hearing of Dibang Project on March 13, 2013: “It is evident that the 2000 MW Lower Subansiri Project is stalled since Dec 2011 because the technical, environmental and social concerns of the people of Assam were not considered earlier… Ignoring downstream concerns will only ensure that this project to will meet the same fate as Subansiri Lower Project (2000 MW and get stalled by people of Assam.”
It seems none of the players have learnt any lessons from the blunders committed in LSHP’s decision making. If this is how Dibang Project is being pushed down the throat of the people of Dibang Valley, Arunachal Pradesh and the North East India, they will have no option but to oppose the project and the Dibang Project may have the same fate as that of LSHP. Those who have been involved in the decision making now will then be held accountable for the wrong decisions and manipulations.
Dam site and the Dibang River Basin (Source – EMP)
THE DIBANG PROJECT
The foundation stone of 3000 MW Dibang Multipurpose Project on Dibang River was laid on 31st January 2008, by Prime Minister Manmohan Singh[2] when the project had no clearances, showing utter disregard the former PM had for statutory clearances or environment or affected people. The project affects Lower Dibang Valley and Dibang Valley districts of Arunachal Pradesh, and significantly, several districts in downstream Assam.
Considering the fact that Dibang has the largest installed capacity for a project in India, involving highest dam in India and biggest reservoir in North East India so far, one expected the EAC to be much more diligent while considering the project and even more so considering the experience of the LSHP. But that, it seems, was expecting too much.
The first thing that would strike any one who goes through the EAC and FAC documents is that the basic parameters of the project are yet unclear even as the EAC and FAC have recommended clearances, within the span of a week, under pressure from their political masters. Unbelievably, these two committees functioning under the same Ministry have recommended clearance for differing capacities, differing heights, differing submergence areas and so on!
This is because the NHPC knowingly misled the EAC in its meetings by presenting the 288 m height (above the deepest foundation level) dam with 545 m elevation at Full Reservoir Level (FRL) and 3.75 Billion Cubic Meters (BCM) of storage capacity at FRL. The same NHPC, in FAC meeting on Sept 22, 2014 provided sensitive analysis with dam height reduced upto 40 m, but this was not even mentioned before the EAC!
Let us review the how the EAC and FAC dealt with the project.
A. ENVIRONMENTAL CLEARNACE FOR THE DIBANG PROJECT:
The Expert Appraisal Committee (EAC) of the MoEF, which holds the distinction of having a zero rejection rate for the projects it appraises, recommended Environment Clearance to 3000 MW Dibang Multipurpose Project in its 77th meeting on 16th Sept, 2014.
The Project was given TOR (Terms of Refence) clearance on 17.8.2009. Public hearings in Lower Dibang and Dibang Valley districts were held on 11.3.2013 and 13.3.2013 respectively, with huge protests from affected people. The EAC earlier considered the project in 68th meeting in Sept 2013, in 73rd meeting in March 2014, in 74th meeting in May 2014 and now in 77th meeting in Sept 2014.
Some key questions that arise as to how the EAC arrived at the positive recommendation:
1. Was there any Public Hearing in downstream Assam? Was there proper public hearing in Aruunachal Pradesh?
Although Dibang Multipurpose project will have impacts in the downstream Assam, as accepted by NHPC Ltd, WAPCOS and recorded in EAC minutes, no public hearing has been conducted in Assam, in complete violation of the EIA notification which clearly states that in all affected districts public hearings must be held. The submissions from Assam were not discussed during EAC minutes. The people of Assam have been completely ignored in the decision-making about a project that will affect them. Several people who spoke at the Dibang Public Hearing in Arunachal Pradesh in March 2013 raised this issue, but MEFCC and EAC failed to do anything about this even after SANDRP submissions to EAC also raised this issue.
Even in Arunachal, the public hearing process has seen several violations, leading people to oppose the project and the public hearings, see the quotes from the public hearings given below. Consequently, the public hearings were disrupted by the local people and had to be cancelled several times. The MEFCC, unfortunately, has no concern for the quality of the whole consultation process and sees it as only a box to be tick marked. The EAC does not even look at issues related to public hearings.
View of One of the affected villages show the rich forest that the project will destroy (Source – EIA)
2. Were the issues raised at public hearing in March 2013 addressed?
No. As is clear from the report of the public hearing for the project held at Roing and New Anaya on March 11 and 13, 2014 respectively, the affected people raised a lot of critical issues about the project, EIA, EMP and Public hearing.
In the Minutes of the 68th meeting of EAC held in Sept 2013 and the 73rd EAC meeting held in March 2014, there is one paragraph (same para in both minutes) on public hearings: “Concerns Raised During Public Hearings It was explained that in general, the people were satisfied with the EIA and EMP reports and proposed R&R plan and community and social development plan. R&R plan has been formulated in line with the State R&R Policy, 2008. They took keen interest in knowing the R&R package and community and social development (CSD) plan. However, during public consultation prior to public hearing and during public hearings of Dibang Multipurpose Project, in addition to community and social development plan more infrastructural development in both Lower Dibang Valley and Dibang Valley Districts were sought viz., up gradation of District Hospitals in both districts, financial assistance for schools, colleges and polytechnic, and construction of cultural museum at Roing and ITI at Anini etc. Besides this for downstream people, the main concern was protection of downstream area in case of dam break / high flood. Keeping this in view, a lump sum provision of Rs. 17100 lakhs has been proposed for consideration of MoEF for mitigative measures at downstream and other infrastructural facilities as raised during public hearings in addition to R&R and CSD plan.”
The claim that “in general, the people were satisfied with the EIA and EMP reports and proposed R&R plan and community and social development plan” is a complete lie, as we see from the quotes from the official public hearing minutes below.
It seems the EAC members have not bothered to read the public hearing report, and they have willingly or unwillingly been misled by the NHPC and EIA agencies. To illustrate the critical issues raised at the public hearings, we are giving below some quotes from the official public hearing report. Most of these reports remain unaddressed in the EIA-EMP submitted to the MEFCC, but MEFCC and EAC has not bothered to check this.
Shri Lokha Elapra, President, All Idu Mshmi Students Union: “Poor planning of mitigation from impacts during construction phase. Mitigation measures fail to address issues of demographic impacts, socio-cultural concerns and preservation of traditional land and livelihood… EMP does not have any provision to address this. EIA and EMP does not have any mitigation measures to preserve nor compeansation for permanent loss of mithun grazing areas, fishing grounds and medicinal plants thus endangering the loss of Mishmi Takin (rare Animal), Mishmi Monal (rare Bird) and Mishmi Teeta (rare medicinal plant)… Flood control of Eze (Deopani River to protect Roing Township… A cumulative impact study in the Dibang river basin must be undertaken.”
Shri Raju Mimi, Member, Mishmi Scholar’s Association: “NHPC had undermined the seismic design parameters as recommended by the experts of IIT Guwahati, Guwahati University and Dibrugarh University in respect of the Subansiri Dam. In this regard can the community members of the affected areas be certain that such careless disregard for dam safety be not repeated by NHPC in this case? All the documents related to dam design and safety be made public. Also, the documents should be peer reviewed by independent group of scientists. Ecological concerns like extraction of boulders from ecologically sensitive Important Bird Area (IBA). No impact assessment made regarding this in the EIA report… Hence a cumulative impact study in the Dibang river basin must be commissioned. Socio-economic concerns like the catchment area treatment (CAT) plan will restrict land use resulting in loss of land and livelihood. NHPC must ascertain such losses and compensate the people affected by CAT… There is possibility of loss of land by destabilization of soil due to the huge reservoir. What mechanisms will be implemented to address these losses? ”
Shri Kelo Pulu, President IMCLS: “Environment Monitoring Cell to assess and review the various mitigation measures as mentioned in the EMP is not convincing. Therefore, the Government of Arunachal Pradesh should immediately notify the formation of an independent Committee consisting of less than 5 members of local Idu Mishmi people.”
Shri Moba Riba: “Conduct Public hearing at Dambuk Sub division.”
Shri Jibi Pulu: “Additional EIA-EMP must be undertaken to ensure the minimum impacts to the ecology of Dibang area. The Community people will lose an area of 10390 ha that will be required for CAT plan. This area being grazing area of Mithun will be lost. The EIA does not have any data or estimate/ valuation of this resource. Without any compensation the livelihood rights cannot be taken away from the community. EIA studies about wildlife conservation is inadequate. EIA studies carried out regarding assessment of economic and medicinal plants is not project specific nor community focused. It does not have any reference, assessment and compensation of economically valuable plants like Piper mellusa and Paris polyphylla. The impact of 1950 earthquake of 8.7 magnitude.. Is the dam axis and reservoir standing along the seismic fault line? The impoundment of the drainage system by building dam will have major effect.. Hence, EIA studies on downstream impact particularly study of Deopani drainage and its siltation status is absolutely necessary.”
Dr Mite Linggi: “As recommended by the Planning Commission Committee we demand for a Dam safety design panel for an independent assessment of safety of Dibang Dam. There are lacunae in EIA-EMP reports. This must be rectified.”
Shri MartinLego: “Resistance capacity of the mountains which fall in the reservoir is not studied. Dam should be able to withstand flashflood. Construction of flood protection works with RCC wall supported by vegetative cover on both banks of Dibang River… Our demands must be fulfilled then only we will support.”
Shri Mibom Pertin, President Adi Bane Kebang (ABK):“Till date no initiative has been taken by the State Government, the district administration or the NHPC to educate the people… the EIA EMP must be modified/ rectified wherein safety measures and actions to be taken in case of dam break… Until and unless the above points are fulfilled the holding of this public hearing is strongly opposed by ABK.”
Shri Jowar Moyang: “Demand to establish a family dossier of the entire downstream people… Downstream not reflected in the EIA/EMP and DRP therefore, a separate guideline be made to include the downstream within the defined local area. The demands placed above must be addressed to within three months of this hearing or else will protest against the construction of the project.”
Shri Nun Pertin, President, Dibang Adi Students’ Union (DASU): “Downstream people are unaware of the project benefits, impacts and other issues which are mandatory to be known before the commencement of the project. Therefore, public hearing in this regard must be conducted within blocks and subdivision of Lower Dibang Valley. This must be furnished in written assurance form within one week’s time. ”
Shri Anjite Menjo, Zilla Parishad Member, Iduli Anchal Block and Shri Chiliko Meto, ZillaParishad Chairperson: “Environment Monitoring Cell to assess and review the various mitigation measures as mentioned in the EMP is not convincing. Therefore, the Government of Arunachal Pradesh should immediately notify the formation of an independent Committee consisting of less than 5 members of local Idu Mishmi people… Hence a cumulative impact study in the Dibang river basin must be commissioned.”
Dr Mite Linggi, Representative of Kere A Initiative for Cultural and Ecological Security (KICES): “It is evident that the 2000 MW Lower Subansiri Project is stalled since Dec 2011 because the technical, environmental and social concerns of the people of Assam were not considered earlier. Report of the Planning Commission appointed Committee of Dr C D Thatte and M S Reddy has raised several serious concerns about the downstream impacts of the 2000 MW Subansiri Lower Project. Therefore, keeping this in mind, it is absolutely important that public consultation in Assam is carried out before the Dibang project gets environment clearance. Public consultation in Assam is not only necessary to address the concern of the people, but it is a pre-requisite for the people of Dibang Valley in the upstream… Ignoring downstream concerns will only ensure that this project to will meet the same fate as Subansiri Lower Project (2000 MW and get stalled by people of Assam. Rights of the people to use Catchment Area will be denied. Will compensation be included for them? Is it possible for NHPC Ltd to formulate new criteria for all those villages perched atop to include within affected families?”
Shri Lokha Elapra, President, All Idu Mishmi Students’ Union (AIMSU): Raises most of the critical issues raised above including need for Cumulative Impact Asessment, inadequate EIA-EMP, Impacts of demographic changes, lack of assessment of loss of grazing land, fishing right. “We do not want to be refugees in our land.. We the Idu Mishmi have a way of living where we live independently. Past history is proof of it. We had never been ruled and can never be ruled under any circumstance or vice versa. The plot which the NHPC Ltd claim giving free of cost is by virtue forcefully asking us to live in that piece of land where the PAFs are not satisfied.”
Shri Athupi Melo, Ex-ZPM, Anelih-Arju Block and Representing New Endoli village: “Public hearing on Dibang Multipurpose Project (3000 MW) was postponed 10-14 times earlier as the consent of the public was not taken before preparing EIA and EMP reports. The NHPC Ltd had cheated the entire affected people by concealing information and letting the awareness remain within the high reach people only. The NHPC Ltd as per their survey has shown 5 villages, 72 families, 243 persons, 938.8 ha of agriculture land as to be affected by the project. Do they know that the storage reservoir will submerge the land mass which belongs to another 34 villages of the valley?”
Shri Kupu Miku-ASM Arzoo and Representative of Apako village: “Had been resisting NHPC Ltd for the last ten years. Nothing was made known as to how much land would go and how much compensation would be provided.”
Shri Rezina Mihu, General Secretary, All Idu Mishmi Students Union (AIMSU): “It has been six yeas of resistance till this morning. The former President of AIMSU sacrificed his life fighting against the Dibang Project… the EIA-EMP is still not upto the mark.”
This selection of quotes from the Public hearing and reading of NHPC response, EIA-EMP and EAC minutes show that not only NHPC has failed to satisfactorily respond to most of these issues, the EAC and MEFCC has not even bothered to check the veracity of the claims of NHPC and uncritically accepted the NHPC claims. Inadequate response to the issues raised at the public hearing means that environmental clearance given to the project is legally untenable.
Anxious afffected people outside the public hearing Hall in March 2013 (Source – PH Report)
3. Has there been proper Environmental Impact Assessment of the project? Kalpavriksh, SANDRP, affected groups from Assam and Arunachal have made several independent submissions to EAC on the inadequacies of the EIA (Environmental Impact Assessment). SANDRP itself sent four different submissions (dated Sept 20, 2013, April 2014, May 2014 and Sept 12, 2014) highlighting various inadequacies of the EIA including:
Lack of compliance with the Terms of Reference of the EIA
Lack of basin wide cumulative impact assessment
Impact of mining of materials for the project not assessed
Lack of downstream impact assessment (more details below)
Lack of assessment of how climate change will affect the project and how the project will worsen the climate change impacts.
Lack of options assessment
Severe Impacts of Migration of Outsider on Local Tribal Community not assessed
Impact of the project on disaster potential in the project area as well in the downstream including Assam not assessed
Impact of changing silt flows downstream not assessed
As noted above, large number of speakers at the public hearing also pointed out the inadequacies of the EIA-EMP.
4. Are downstream impacts on Assam & Arunachal Pradesh Studied?
No credible study of the impact of the dam, dam break and peaking on Assam and Arunachal Pradesh in the downstream has been done.
Several speakers at the public hearing raised this issue of inadequate downstream impact assessment, as can be seen from the quotes from the public hearing listed above.
It may be mentioned here that the biggest issue plaguing the LSHP is lack of downstream impact assessment, and the EAC, MEFCC, NHPC or the EIA agencies (WAPCOS, which by now is notorious for doing substandard studies and National Productivity Council). Even Assam and Arunachal Pradesh state governments also seem least bothered. Also, it seems no lessons have been learnt after Larji mishap when 25 students were washed away due to demand-driven water releases by upstream hydropower project.
5. Has the impact of Peaking on Downstream Assam & Arunachal Pradesh studied?
NO
This is despite the fact that submissions were sent to the EAC from several organizations and individual also from Assam, drawing their attention to impact of peaking in downstream Assam, especially in lean season (winter) when flow fluctuations will range from 111 cumecs (Cubic meters per second) to about 13 time rise in volume at 1441 cumecs in a single day. Fluctuations can happen twice or thrice in a single day.
6. Has the impact on Dibru Saikhowa National Park in the downstream Assam studied?
NO
The EAC has shown zero application of mid in this respect. There are several hydropower projects being constructed on the three main tributaries of Brahmaputra upstream of Dibru Saikhowa National Park in Assam. All these hydropower projects will undertake peaking operations. EAC has considered these projects separately, as a part of basin studies and as a part of downstream impact studies on Dibru Saikhowa National Park.
In all these studies, the level fluctuation at the National Park when the three major projects in the upstream undertake peaking operations is different, as per the convenience of the project proponent! EAC has considered all these studies without raising any questions about this convenient difference in figures even when the contradictions were brought to EAC’s attention by SANDRP.
The EAC has recommended Clearance to Dibang Multipurpose Project accepting the contention of the NHPC that “water level fluctuation in Dibru Saikhowa National Park (DSNP) will be less than one meter.”
However, the same EAC has considered EIA of Lower Siang HEP (by WAPCOS) where the fluctuation at Dibru Saikhowa when all projects are peaking is said to be 8 feet (2.38 meters)
The Report on “Effect of Peaking power generation by Siang Lower HEP, Demwe Lower HEP and Dibang Multipurpose HEP on Dibru Saikhowa National Park” also by WAPCOS states that level difference when all three projects are peaking is estimated to be 34 mts i.e. 7.67 feet. (Page 26)
EAC did not question these glaring differences in these models even when a submission highlighting these points was sent to the EAC on 13.09.14, before the 77th EAC meeting. The submission is not mentioned in the minutes, neither discussed, also violating Hon. Delhi High Court Orders (Utkarsh Mandal Case).
7. EAC decision violates its mandate; MEFCC & NHPC guilty of misleading EAC.
During the entire appraisal process, the EAC has failed to pose any difficult questions to NHPC, has not taken a stand supporting Assam, has not even initiated discussion in that direction, has turned blind eye towards submissions it received raising critical concerns, has overlooked contradictions, has overlooked precautionary principle and welfare of people in the downstream Assam and has refused to learn any lessons from the LSHP experience or the Larji Mishap.
While discussion about height reduction of Dibang upto 40 meters were initiated in MEFCC/ NHPC since Feb 2014, the MEFCC or the NHPC has not brought this proposal to the attention of the EAC and the EAC has taken absolutely no notice of this and has not even asked for this 40 m height reduction. The only reference we can find to the height reduction proposal is in the minutes of the 73rd EAC meeting, where too there is reference to only 10 m ht reduction. And yet, there is no mention of this in the minutes of the 77th EAC meeting where the EAC recommended clearance to the project.
This alone is sufficient to make the EAC decision legally untenable and make both MEFCC and NHPC guilty of not informing the EAC about these developments more than six months after they were initiated.
The EAC on its part has not shown the will to ask for a realignment of the project to minimize its downstream impacts, peaking impacts and submergence impacts. Such biased conduct and the decisions of the EAC, sidelining genuine concerns are in complete violation of the mandate given to EAC and extremely damaging to environmental governance of the country and are a reason for increasing conflicts, delays, protests and strife underlining its callousness towards environmental impacts and local resistance.
The issues that FAC raised while rejecting the Forest clearance are the very issues that EAC should be concerned about since they are under their mandate. But not only EAC did not raise them on their own, but even after they were brought to the EAC’s attention by SANDRP, the EAC failed to even discuss those issues.
8. Issues on Dibang raised in earlier EAC meeting remains unanswered
The decision making paragraph of the minutes of the EAC meeting of Sept 16-17, 2014 on Dibang Project reads: “After critically examining the proposal and considering the response to various issues raised in the earlier EAC meetings, the project was recommended by EAC for accord of Environmental Clearance to Dibang Multipurpose Project. However, EAC suggested that 20 cumec flow may be released towards e-flow in the 1.2 km diverted stretch as 15 cumec gives just sufficient quantity. EAC noted that beyond this 1.2 km, adequate flow will be available from TRT which will be minimum in the order of 85 cumec at 80% rated discharge of one turbine.”
It is clear that this paragraph does not reflect any application of mind by EAC if the response provided by NHPC to the various issues raised by EAC and others’ submissions to EAC are adequate. Even in this paragraph, it is not clear what is the basis of EAC decision to recommend 20 cumecs flow downstream of the dam and not the norm that EAC is following for other projects (30% in monsoon, 20% in lean season and 20-25% in non monsoon non lean season). Nor is it clear what is the basis and impact of operation of one of the (there are 12 turbines, each of 250 MW installed capacity in this project) turbine at minimum 80% capacity round the clock. This non application of mind on the part of the EAC is the norm of EAC and not an isolated incident.
In fact, reading through the minutes of all the EAC meetings since Sept 2013 where Dibang EC (Environment Clearance) was discussed, it is clear that while EAC has raised a large no of questions and reported some of the information submitted by NHPC, no where can we find application of mind of the EAC where it is stated that the information/ responses provided by NHPC is adequate or not. The uncritical acceptance by the EAC about the information/ responses provided by the developer is another noteworthy feature of EAC decision.
Let us illustrate this. The minutes of the 73rd EAC meeting held in March 2014 says: “A detailed fisheries (also flora and fauna) survey was conducted by Centre for Inter-Disciplinary Studies for Mountain and Hill Environment (CISMHE), Delhi University in the month of December 2013.” Immediate question than arises is, why were the fisheries and other surveys done only in one month and not across the year as is the normal practice? What were the outcomes of the study? You will find neither critical questions, nor any answers in the EAC proceedings.
Here is another example. The minutes of the 74th EAC meeting held in May 2014 says: “It was informed that fluctuation in the water level at upstream of Dibang-Lohit confluence due to peaking operation will be about 17 cm which is almost negligible considering the size of the river.” Shockingly, the EAC does not even ask: A. If this estimate is sound and if it is consistent with conclusions of other studies; B. What will be the level fluctuation at different points along 60 km stretch of the river upstream from this point to the project site and what will be the impact there of. EAC’s such uncritical acceptance of apparently contradictory and inadequate responses from the developer is the norm and not an isolated incident. Considering that EAC was considering the largest installed capacity project of India, highest dam of India and biggest reservoir in North East India so far, one expected the EAC to be more diligent. This was even more so considering the experience of the LSHP.
To further illustrate, the minutes of the 74th EAC held in May 2014 says: “The point-wise reply to the two representations submitted by Kalpavriksh was submitted to MoEF and EAC members and the same was also presented before EAC during the meeting.” Similarly, the minutes of the 73rd EAC meeting held in March 2014 says: “point-wise replies to the issues raised by Shri Chow Rajib Gogoi, Secretary, All Tai Ahom Student Union, Jorhat and Shri Pushp Jain, Director, EIA Resource and Response Centre (ERC), New Delhi were also given”. But in both cases, there is not even a word as to whether EAC discussed the NHPC response and if they did what was their conclusion about adequacy or acceptability of the NHPC responses.
As far as four separate submissions sent by SANDRP to EAC on Dibang Project are concerned, EAC neither mentioned them, nor did it seek NHPC’s response on them.
Considering all this, the decision of the EAC to recommend EC to the Dibang Project is clearly wrong, based on inadequate appraisal, in the absence of application of mind and legally untenable.
Active Lanslide zone in submergence area of Dibang Project (Source – EIA)
B. FAC DECISIONS ON DIBANG PROECT
It has been reported[3] that the Forest Advisory Committee of the MoEF has recommended clearance to 3000 MW Dibang Multipurpose project in its meeting on Sept 22, 2014, though the minutes of the FAC meeting are as yet unavailable. This decision is reversal of FAC’s clear rejection to the project twice in past 2 years[4] in addition to MEFCC’s rejection letter to the project as late as on the 28th August 2014.
MEFCC was pressurized by the Cabinet Committee on Investment, Ministry of Power and even unrelated Ministries like Ministry of Mine, Ministry of Steel and Ministry of Coal into clearing the Dibang project. FAC itself was under pressure of the MEFCC minister and its highest officials to clear Dibang at any cost.
Relevant papers regarding height reduction proposal by NHPC were not uploaded on FAC Website in advance of the Sept 22, 2014 Meeting.
It is unclear if even the FAC Members had these documents, which form the basis of project consideration.
The height reduction proposal was not available to the EAC members a week earlier before EAC recommended clearance to the project.
FAC’s recommendation on Dibang project is clearly an undemocratic and illegal decision in the absence of prior information in public domain for all concerned, and when all the original objections raised by FAC while rejecting the project twice remain unaddressed.
Let us look at the timeline of FAC decision making on Dibang Project:
12.06.13: FAC rejects Dibang FC (Forest Clearance) Proposal. Reasons: “huge forest area with very good forest cover, irreparable and adverse impact on general eco-system of the area by felling of more than 3.5 lakhs of trees, several other HEP have been proposed in the same river valley apart from Dibang HEP, unavailability of study on cumulative impact of all the HEP, etc. The Committee is also of the opinion that ecological, environmental and social costs of diversion of such a vast track of forest land, which is a major source of livelihood of the tribal population of the State, will far outweigh the benefits likely to accrue from the project.”
13.08.2013: Meeting of Secretary, Ministry of Environment and Forests and the Secretary, Ministry of Power held and it was decided that proposal will be considered again after exploring the possibility to reduce the requirement of forest land for the project.
9.12.2013: Project discussed by the Cabinet Committee of Investment which nearly ordered fast clearance for Dibang Project. It stated: “Ministry of Environment and Forests may grant the requisite clearance for diversion of forest land expeditiously.” Such direction from CCI was clearly in violation of the Forest Conservation Act 1980 which clearly defines the process for forest clearance and where CCI has no role.
10.02.14: NHPC revises proposal and submits two alternatives, reducing height by 5 m and 10 meters respectively. Marginal decrease in submerge of forest land due to 10 meters reduction. NHPC Officials say any further reduction will not be possible.
Revised Diversion proposal with reduction of 10 mts height and 445 hectares forest area submitted to MoEF with new proposal for total diversion of 4577.84 hectares.
29th-30th April 2014: Revised proposal discussed in FAC with 10 meters reduction. The revised proposal was incomplete in many basic respects like absence of maps, CAT Pan, FRA compliance, identified land for Compensatory afforestation, etc. In addition, the FAC noted that the region is home to Schedule I species, the reduction in forest loss due to decrease in height in minimal and will not have substantial ameliorative impact, It said “Such a marginal reduction in requirement of the forest land for the project may not be able to reduce the adverse impact of project on such a biodiversity rich mature forest ecosystem to the extent which could make the project environmentally as well as socio-economically viable in forest dependent tribal society of Arunachal Pradesh”. FAC also noted that impact of reduction of dam height on its economic feasibility was not put before the committee.
16.06.2014: Secretary Power writes to Secretary, MEFCC on 16.06.2014 to review the decision of FAC and accord the Stage-I forest clearance. Such direction from letter was clearly in violation of the Forest Conservation Act 1980 which clearly defines the process for forest clearance and where Power Ministry secretary has no role.
19.06.2014: Joint meeting held between Ministry of Mine, Ministry of Steel, Ministry of Environment Forests and Climate Change and Ministry of Coal, attended by the Ministers and Secretaries of the respective Ministries, as well as Secy, Ministry of Power wherein it was decided that a report on sensitivity analysis of dam height reduction by 40 meters shall be submitted to MoEF and action will be taken only after that.
24.06.2014: Secy, Ministry of Power writes to MEFCC & submitted a report on the sensitivity analysis on the dam height reduction upto 20 meters. However, MEFCC maintained that that as decided in the meeting the sensitivity analysis report was not submitted by the project proponent.
28.08.14: MEFCC sends letter rejecting Forest Diversion Proposal of Dibang Multipurpose Project on the basis of 10 meters height reduction, rich forest, social impacts and also downstream impacts on Assam, including Dibru Saikhowa.
5.09.2014: MEFCC writes to (NHPC/ Min of Power) to submit sensitivity analysis of reduction by 40 meters.
08.09.14 (This letter of 08.09.14 was uploaded on MEFCC FAC website on the day of the FAC meeting, 22.09.14): NHPC submits letter to MEFCC about sensitivity analysis for height reduction from 5m-40 meters. While it highlights the loss in installed capacity (780 MW) and loss in revenue due to 40 m reduction, it downplays the fact that 40 mts reduction will bring down forest land requirement by 26%. It concludes, without substantiation that “Decrease in dam height and consequent sacrifice in power generation beyond 10 mts reduction is not commensurate with saving forest land” and further recommends only 10 mts height reduction, which proposal the MEFCC had rejected in its Apr 29-30, 2014 meeting.
21.09.14: No sensitivity Analysis uploaded on MoEF FAC Website. SANDRP sends a submission urging FAC not to consider the project in the absence of this analysis in public domain as it violates CIC orders. People affected by the project have no idea of this analysis which is the basis of decision making in the next day’s meeting.
22.09.14: Day of the Meeting: Suddenly Additional Information document accessed (and downloaded) on 21.09.14 changes, with two additional pages and letter from NHPC about sensitivity analysis is uploaded ON THE DAY OF THE MEETING.
23.09.14: News that FAC has recommended clearance to Dibang was already public.
CONCLUSION As noted earlier, the Dibang Project is the largest capacity hydropower project, the highest proposed dam and largest proposed reservoir of North East India. One expected all concerned to be diligent in taking decisions on such a project. However, it is clear from this narrative that the process of environment and forest clearance for the Dibang Project is fundamentally flawed, inadequate and in violation of all norms of democratic and informed governance. Significantly, it is also illegal and untenable. Such manipulative decision-making has led to flawed decisions of environmental and forest clearances in case of LSHP in 2003, with the project stalled by people’s agitation since 34 months now. If the Dibang Project, which is bigger than LSHP in every respect and with much greater impacts, is pushed in such a manner, it is likely to face the same fate as that of the LSHP. We hope that the final decisions related to Dibang Project will be more informed, diligent, democratic, unbiased and objective. Admittedly, such hope seems rather farfetched at this moment.
[1] This is not to state that the UPA government that ruled India during the 2004-2014 decade was in anyway more sensitive to environment or democratic concerns. In fact part of the EC and FC time line and some of the manipulations happened before May 2014 when the current government took over. However, it is apparent that the current government has indulged in much more violations and manipulations and pressurized the statutory bodies (including FAC & NBWL reconstitution).
[5] A video titled “Dibang Resistance (Arunachal Pradesh)” depicts the protest and blockade by local people against the Dibang dam. The video can be viewed here: https://www.youtube.com/watch?v=m8TCUKh2hQY
[6] Mimi, R., “The Dibang Multipurpose Project, Resistance of the Idu Mishmi” published in “Water Conflicts in Northeast India – A Compendium of Case Studies” edited by Das, Partha J. et. all, 2013
It is close to a year after the worst ever Himalayan flood disaster that Uttarakhand or possibly the entire Indian Himalayas experienced in June 2013[1]. While there is no doubt that the trigger for this disaster was the untimely and unseasonal rain, the way in which this rain translated into a massive disaster had a lot to do with how we have been treating the Himalayas in recent years and today. It’s a pity that we still do not have a comprehensive report of this biggest tragedy to tell us what happened during this period, who played what role and what lessons we can learn from this experience.
Floods in Uttarakhand Courtesy: Times of India
One of the relatively positive steps in the aftermath of the disaster came from the Supreme Court of India, when on Aug 13, 2013, a bench of the apex court directed Union Ministry of Environment and Forests (MoEF)[2] to set up a committee to investigate into the role of under-construction and completed hydropower projects. One would have expected our regulatory system to automatically initiate such investigations, which alas is not the case. Knowing this, some us wrote to MoEF on July 20, 2013[3], to exactly do such an investigation, but again MoEF played deaf and blind to such letters.
5 MW Motigad Project in Pithorgarh District destroyed by the floods. Photo: Emmanuel Theophilus, Himal Prakriti
The committee report, signed by 11 members[5], makes it clear that construction and operation of hydropower projects played a significant role in the disaster. The committee has made detailed recommendations, which includes recommendation to drop at least 23 hydropower projects, to change parameters of some others. The committee also recommended how the post disaster rehabilitation should happen, today we have no policy or regulation about it. While the Supreme Court of India is looking into the recommendations of the committee, the MoEF, instead of setting up a credible body to ensure timely and proper implementation of recommendations of the committee has asked the Court to appoint another committee on the flimsy ground that CWC-CEA have submitted a separate report advocating more hydropower projects! The functioning of the MoEF continues to strengthen the impression that it is working like a lobby for projects rather than an independent environmental regulator. We hope the apex court see through this.
Boulders devouring the Vishnuprayag Project. 26th June 2013 Photo: Matu jan Sangathan
Let us turn our attention to hydropower projects in Himalayas[6]. Indian Himalayas (Himachal Pradesh, Uttarakhand[7], Jammu & Kashmir, Sikkim, Arunachal Pradesh and rest of North East) already has operating large hydropower capacity of 17561 MW. This capacity has leaped by 68% in last decade, the growth rate of National Hydro capacity was much lower at 40%. If you look at Central Electricity Authority’s (CEA is Government of India’s premier technical organisation in power sector) list of under construction hydropower projects in India, you will find that 90% of projects and 95% of under construction capacity is from the Himalayan region. Already 14210 MW hydropower capacity is under construction. In fact CEA has now planned to add unbelievable 65000 MW capacity in 10 years (2017 to 2027) between 13th and 14th Five Year Plans.
Meanwhile, the Expert Appraisal Committee of Union Ministry of Environment and Forests on River Valley Projects has been clearing projects at a break-neck speed with almost zero rejection rate. Between April 2007 and Dec 2013[8], this committee recommended final environment clearance to 18030.5 MW capacity, most of which has not entered the implementation stage. Moreover, this committee has recommended 1st stage Environment clearance (what is technically called Terms of Reference Clearance) for a capacity of unimaginable 57702 MW in the same period. This is indicative of the onslaught of hydropower projects which we are likely to see in the coming years. Here again an overwhelming majority of these cleared projects are in Himalayan region.
Agitation Against Lower Subansiri Dam in Assam Source: SANDRP
What does all this mean for the Himalayas, the people, the rivers, the forests, the biodiversity rich area? We have not even fully studied the biodiversity of the area. The Himalayas is also very landslide prone, flood prone, geologically fragile and seismically active area. It is also the water tower of much of India (& Asia). We could be putting that water security also at risk, increasing the flood risks for the plains. The Uttarakhand disaster and changing climate have added new unknowns to this equation.
We all know how poor are our project-specific and river basin-wise cumulative social and environmental impact assessments. We know how compromised and flawed our appraisals and regulations are. We know how non-existent is our compliance system. The increasing judicial interventions are indicators of these failures. But court orders cannot replace institutions or make our governance more democratic or accountable. The polity needs to fundamentally change, and we are still far away from that change.
Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan
The government that is likely to take over post 2014 parliamentary elections has an opportunity to start afresh, but available indicators do not provide such hope. While UPA’s failure is visible in what happened before, during and after the Uttarakhand disaster, the main political opposition that is predicted to take over has not shown any different approach. In fact NDA’s prime ministerial candidate has said that North East India is the heaven for hydropower development. He seems to have no idea about the brewing anger over such projects in Assam and other North Eastern states. That anger is manifest most clearly in the fact that India’s largest capacity under-construction hydropower project, namely the 2000 MW Lower Subansiri HEP has remained stalled for the last 29 months after spending over Rs 5000 crores. The NDA’s PM candidate also has Inter Linking of Rivers (ILR) on agenda. Perhaps we have forgotten as to why the NDA lost the 2004 Parliamentary elections. The arrogant and mindless pursuit of projects like ILR and launching of 50 000 MW hydropower campaign by the then NDA government had played a role in sowing the seeds of people’s anger with that government.
In this context we also need to understand what benefits these hydropower projects are actually providing, as against what the promises and propaganda are telling us. In fact our analysis shows that the benefits are far below the claims and impacts and costs are far higher than the projections. The disaster shows that hydropower projects are also at huge risk in these regions. Due to the June 2013 flood disaster large no of hydropower projects were damaged and generation from the large hydro projects alone dropped by 3730 million units. In monetary terms this would mean just the generation loss at Rs 1119 crores assuming conservative tariff of Rs 3 per unit. The loss in subsequent year and from small hydro would be additional.
It is nobody’s case that no hydropower projects be built in Himalayas or that no roads, townships, tourism and other infrastructure be built in the Himalayan states. But we need to study the impact of these massive interventions (along with all other available options in a participatory way) in what is already a hugely vulnerable area, made worse by what we have done so far in these regions and what climate change is threatening to unleash. In such a situation, such onslaught of hydropower projects on Himalayas is likely to be an invitation to even greater disasters across the Himalayas. Himalayas cannot sustain this onslaught.
It is in this context, that the ongoing Supreme Court case on Uttarakhand provides a glimmer of hope. It is not just hydropower projects or other infrastructure projects in Uttarakhand, or for that matter in other Himalayan states that will need to take guidance from the outcome of this case, but it could provide guidance for all kinds of interventions all across Indian Himalayas. Our Himalayan neighbors can also learn from this process. Let us end on that hopeful note here!
National Democratic Alliance (NDA) led by BJP’s Mr. Narendra Modi has been given a mandate to govern India for the next five years. Without going into the political and social facets related to this issue, there are a number of justifiable concerns about this government’s stand on critical issues of water and environment.
While the importance of water and environment sectors for the people, their livelihoods, society and economy is acknowledged, how crucial these sectors are for them is not easily appreciated. For example, environment is important not only for tigers and trees, but also for livelihoods of hundreds of millions of Indians who depend on natural resources. More than 60-65% Indians continue to depend on agriculture and every farm can benefit from better water resource management.
Some of the major challenges plaguing the water and environment sectors in India include: urgent need for an inclusive, democratic and accountable governance, holistic assessment of impacts the very many interventions in the Himalayas (lessons from Uttarakhand flood disaster of June 2013[1]), ecological restoration of Ganga and other rivers, dealing with climate change in a way that protects lives and livelihoods of the vulnerable sections, etc., to name a few.
The leaders of the party forming the new government have already declared their agenda in terms of completion of Sardar Sarovar Project (SSP) on Narmada, pushing interlinking of rivers (ILR), pushing for more dams in the name of irrigation, pushing big hydropower projects in North East India (Mr Modi had said in his campaign that NE is heaven for hydropower projects) and mega industrial initiatives like the Delhi Mumbai Investment Corridor.
This agenda indicates that the importance of water and environment to the vast millions is not understood. Nor is the significance of the challenges to this sector appreciated. Pushing the above agenda is not only fraught with serious risks in terms of social, environmental, economic and interstate issues, but these projects are not likely to deliver the promise of this party at the elections: Better life, more jobs, more development, fulfillment of basic needs of the people who do not have access to these at the moment. Pushing this agenda is not likely to deliver stated promises, however blind push for more and bigger projects will compound strife and conflicts.
Let us look at the issues related to the NDA Agenda. These are not incidental issues, but issues inherent to the nature of these centralized, mega projects themselves.
Does ILR have scientific basis? The basic premise of ILR is that certain basins are water surplus and others are water deficit. It is assumed that occurrence of floods in a basin means there is surplus water in the basin and occurrence of drought or water scarcity in other basin means it is water deficit. This premise itself is not scientifically, ecologically and socially robust.
While this is said, there is no attempt at assessing and exhausting the available water options in any basin in India. Twithout this exercise, there can be no scientific basis for declaring a basin surplus or deficit. The ILR advocates seem to ignore the reality that India’s water lifeline is groundwater and the best way to sustain groundwater is through local water systems and recharge. They also seem to ignore the massive social, environmental impacts and constitutional issues. ILR is basically a collection of large number of major irrigation projects (over 84), but proponents of ILR do not seem to realize that in last two decades, there has been no addition to net irrigated area by these projects, in spite of addition of thousands of new projects.[2]
“Sabarmati Model” holds no water for Ganga or other rivers During the elections in Varanasi constituency that elected Mr Modi, the issue of cleaning of Ganga remained prominent. BJP claimed that they will clean up Ganga at Varanasi the way they cleaned up Sabarmati River that flows through Ahmedabad in Gujarat. The trouble with this claim is that Sabarmati has not been cleaned up at all. The water flowing through Sabarmati as it flows through the city of Ahmedabad is actually the water of Narmada River, diverted into Sabarmati. Ahmedabad has no right over this water which was supposed to be meant for Kutch, Saurashtra and North Gujarat. If you go upstream along Sabarmati River from the point where Narmada Main Canal releases water in Sabarmati, you will see the reality of dry Sabarmati River. And if you go down to the Vasna barrage, downstream of Ahmedabad along the Sabarmati, you will see the state of polluted Sabarmati River. This model clearly holds no water either for Ganga or any other river.
River Ministry? There is speculation in media[3] that the new NDA government is going to create a new River Ministry at the centre. The same media report also stated that this ministry will push Inter Linking of Rivers (ILR)! This seems like a proposal for Ministry of River Destruction, since ILR is a recipe for destruction of rivers. If at all the new government is interested in an act of goodwill towards rivers, it needs to start with understanding what is a river and what are its various functions along the various stretches during various periods, including the social, ecological, economic, hydrological, geo morphological, biodiversity related, groundwater related and most importantly, livelihoods related functions. This exercise will mean understanding the roles of various arms of the government which affect the river. Some key ministries which affect river profoundly include: Ministry of Water Resources, Ministry of Environment and Forests, Ministry of Power, Ministry of Urban Affairs, Ministry of Rural Development, Ministry of Home Affairs (Disaster Management), Ministry of Agriculture, Department of North East Region, Ministry of Non Conventional Sources of Energy, to name only a few. How is this new proposed Ministry of River Going to coordinate with these ministries? Moreover, according to India’s constitution, Rivers are essentially state subjects and no state is likely to welcome such infringement of centre into what the states see as their domain of responsibility.
Ganga a National Project? There are statements from Mr Amit Shah[4], that the new government will give National status to the Ganga Project. It is not clear what is meant by this. Ganga is already under the Prime-Minister headed National Ganga River Basin Authority, but the Authority, five years after its constitution, has failed to change a single attribute affecting the Ganga. Similarly, Ganga River Basin Management Plan that IIT consortium is working on is already known to be pathetic in its understanding of the river, while pushing for privatization. We do not need another project in the name of Ganga, national or local. If the aim of declaring Ganga as a National Project is to wrest its control from the state, as the media suggests, then it is going to raise a lot of hackles.
What we need is a new approach to river governance, which is based on ecological, and not engineering principles, which is participatory, and not exclusive and which is democratic and not autocratic.
Himalayas & Hydro-onslaught Irrefutable evidence shows that building large number of major hydropower projects in Himalayas is having unprecedented impacts, some are known, many are unknown. The flawed environmental governance around these projects is well known in terms of dishonest EIAs, flawed and compromised appraisals, ineffective (these are consultations just in the namesake, in reality there is no basis for informed participation) public hearing and non-existent compliance, both at project and cumulative level. One implication of this was felt in terms of the role of such projects in the Uttarakhand flood disaster of June 2013, after which, no political leader from any party spoke about this. It was left to the Supreme Court to order and enquiry into this. The report of this investigation clearly indicates the role of hydropower projects in increasing the proportions of the disaster, and more work on this issue remains to be done. In North East itself, India’s biggest mass based public agitation against dams & hydropower projects has been going on. The anger of people has led to stoppage of the work on 2000 MW Lower Subansiri Hydropower project (largest capacity hydropower project under implementation in India) for 30 months now, after over Rs 5000 crores were irresponsibly spent by NHPC without completing even basic studies. Mindless pushing of more such projects in the region is clearly not a prudent move.
Source: MATU Jansangathan
BJP manifesto’s promise of expeditious and single window environment clearances is clearly dangerous in this context. What India needs is stronger and not weaker environmental governance. The advocacy[5] to “reduce time and transaction costs for the industry” under the circumstances seems inappropriate particularly from an organisation which was possibly the only environmental organisation represented on the completely flawed EIA registration process at Quality Council of India. The QCI process failed to achieve any improvement in the quality of EIA in almost 4 years of its existence
Sardar Sarovar Dam The new government wants to take the SSP Dam from its current height of 121.92 m to its final design height of 138.68 m. Firstly, there are serious doubts if this height increase is required since it can be shown that Gujarat and Rajasthan can get their share of water from Narmada without this increase in height. Secondly, Gujarat is not even in a position to use more than 20% of the water it already gets from the river at current height of the dam for the purposes for which the project was designed: providing water for the drought affected regions in Kutch, Saurashtra & North Gujarat. On the other hand, urban centres, industrials areas, SEZs, cosmetic river beautification schemes have appropriated a large chunk of SSP waters without legal, democratic sanction or justification. Gujarat really does not have a case for increasing the height of SSP Dam.
Moreover, this will also entail such massive additional submergence, displacement and disruption of lives of tribals and farmers that it is sure to create huge opposition. The just rehabilitation of already affected people is far from complete, in fact, most of the affected population has not been given minimum 2 ha of land required under the Narmada Tribunal award and subsequent accepted policies.
Mr Modi during his tenure of 13 years as Chief Minister of Gujarat failed to complete the canal network of SSP in the drought prone areas in whose name the project has always been justified. It needs to be noted that the agitation against SSP did not stop Gujarat government from going ahead with construction of canal network. It was not for lack of finances that SSP could not complete the canal network. SSP has been getting largest quantum of money from the Government of India’s Accelerated Irrigation Benefits Programme ever since the AIBP scheme started in 1996. This support to SSP from AIBP was clearly wrong since SSP was never the last mile project for which AIBP was meant, but the big dam lobby in Union Water Resources ministry and Gujarat government were hand in glove in this misallocation of AIBP money for SSP. In fact, Mr Modi arm-twisted the Planning Commission in 2011-12 to sanction the escalated costs for SSP even when the issues raised by Planning Commission officers remained unanswered.
Unused Narmada Canal waters flow into Salt pans, not only at a huge cost, but also affecting livelihoods of salt pan workers and the ecology Photo: Counterview
It is the ineptitude of Gujarat Government under Mr Modi that is on show in why it could not complete the canal network on drought prone areas in Gujarat. Mr Modi would do well to remember the reasons for that failure before he considers the mega projects agenda as Prime Minister.
Moreover, on SSP, the issues of completing repairs of the damages the Sardar Sarovar dam structure suffered four years ago & related issue of safety of the dam are yet to be resolved[6] and Gujarat has embarked on building another Garudeshwar Dam in immediate downstream without any impact assessments, participatory democratic process or required sanctions[7]. The legality of the Garudeshwar Dam work stands challenged in the National Green Tribunal by the affected tribals.
MAJOR RISKS FOR NEW GOVERNMENT Some major risks for the new government include: the track record of Gujarat government that Mr Modi headed for the last 13 years; no checks from coalition of parties; poor image, strength, morale and track record of Congress as the chief opposition party; large sections of almost completely subservient media[8] and BJP’s problematic manifesto[9].
Why UPA faced people’s anger The new government also needs to remember why the outgoing ruling coalition of UPA (United Progressive Alliance) lost so badly in spite of some unprecedentedly remarkable, and pro people steps taken by it. Absence of accountable and participatory governance (which also manifested in terms numerous scams) was one of the major reasons as to why there was huge anger in people’s mind about the UPA regime. Another aspect of corruption and high-handedness was apparent in the scandalous way UPA dealt with governance of environmental issues: blatantly changing its environment ministers from bad to worse.
Even if we leave aside the Rajas and Balus of UPA I, the UPA II began on a positive note with appointment of Mr Jairam Ramesh as environment minister. While we had our share of criticism of functioning of Mr Ramesh as environment minister[10], he was possibly the best environment minister India have had.
But under pressure from misguided and misinformed corporate vested interests, Mr Ramesh was removed (kicked upstairs) and Mrs Jayanthi Natarajan was brought in. She did not really help the cause of environment as is apparent, for example, from her answers to the two debates on Ganga river in Parliament (these debates were unprecedented in their own right) as also sanctioning projects rejected by statutory bodies like Forest Advisory Committee.
Strangely, she too was removed to bring in disastrously, Mr Veerappa Moily[11], who also held the Oil and Petroleum ministry. Mr Moily then went about the designated task of green lighting everything, not bothering about governance issues, people’s concerns or environmental consequences. This led to massive anger anger against Moily as well as UPA.[12]
Such arrogant handling of governance of environmental issues that affect the lives and livelihoods of millions of most vulnerable sections of people was bound to be punished[13]. This is clearly another reason behind the anger of people that UPA government faced in the elections.
Playing favorites UPA is also guilty of playing favorites when it came to appointing non governmental persons in environmental decision making. In almost every committee on environmental decision making, including Prime Ministers’ Council on Climate Change, National Tiger Task Force, Coastal Zone Management Committee, National Ganga Authority, Inter Ministerial Group on Ganga, Western Ghats Task Force, QCI process on registration of EIA consultants, 12th Plan working Groups to name only a few, everywhere one could find representatives of only particular organisation. Leaving aside the issue of effectiveness of the role played by representatives from this organisation, such tendencies of playing favorites is bound to raise serious questions. While many people at grassroots may not be aware of this inappropriate action by UPA government, the resultant outcomes of these committee invited various reactions ranging from disbelief, anger and even an uproar, as it happened in case of Kasturirangan Committee on Western Ghats.
While the result of anger of the voters could be seen in decimation of the UPA in the elections, the new NDA government will also do well to remember that even the Vajpayee government was voted out in 2004 for similar reasons. The mindless pursuit of agenda of inter linking of rivers and 50000 MW Hydropower initiatives, disregarding all the concerns and protests of the people across the country, along with the rejection of India Shining campaign were some of the causes for the voting out of the previous NDA regime in 2004.
SOME SPECIFIC TASKS In what follows we have given several examples of specific tasks before the new government. This is not an exhaustive, but only an indicative list.
Ganga Action Plan, Rivers Action Plans, NGBRA, CPCB, SPCBs Mr Modi has said that he would like to give priority to cleaning of Ganga River. Any such effort has any chance of success only if there is an attempt at understanding why our efforts at river pollution for the last 40 years have shown no impact:
Þ Water Pollution Control Act, 1974 The Water Pollution Control Act led to setting up a huge and powerful bureaucracy including Central and state pollution control boards. 40 years after setting up of this whole institutional and legal infrastructure, we do not have a single that this establishment can claim to have cleaned up.
Þ Ganga Action Plan, 1986 This plan was launched with much fanfare by the then Prime Minister Rajiv Gandhi, but without trying to understand why the water pollution bureaucracy failed.
Þ National River Conservation Authority 1994 This authority, the only institution in the name or river conservation in India, had Prime Minister of India, no less, its chairman. In ten years of UPA, the Prime Minister of India did not get time for a single meeting of this authority.
Þ GAP II 2000 The second phase of GAP was launched, again without making any honest attempt at understanding the failure of GAP I.
Þ NGBRA 2009 In Feb 2009, just before the last parliamentary elections, National Ganga River Basin Authority, again under Prime Minister. As noted earlier, this too has failed to make any impact on the state of Ganga.
What all this shows is that we have tried many things, including legal, institutional, financial, and authoritative, with Prime Minister at the helm, but have achieved no success. This is also true of the previous NDA regime during 1998-2006. If we do not make an honest attempt at understanding the reasons for these failures, there is little hope for success in future. The efforts at river cleaning has not suffered due to lack of money (over Rs 20 000 crores have been spent on Ganga alone, as per one estimate), for lack of institutions, for lack of political attention, for lack of media attention, for lack of judicial attention, for lack of infrastructure [where infrastructure exists (e.g. Delhi with the highest Sewage Treatment Capacity], there too there is no change in state of river), or technology. One major reason for the failure was the complete disconnect between the people whose lives depend on the river and those who took the decisions or managed the system. In other words, unless you make the river governance more democratic, there is no hope for Ganga or other rivers.
Some basic steps to make governance of rivers democratic could include: Setting up of management committee (with 50% independent members from outside the government) for management of each Sewage Treatment Plant, each freshwater treatment plant, each tributary, each 10 km stretch of river, each water utility, each city (& sub city level where cities have population above 1 lakh). These committees should be legally empowered and the officials should be made responsible to these committees.
Jayanthi Tax In this regard, it would be useful to remember that during the election campaign, Mr Modi had accused Mrs Jayanthi Natarajan for collecting Jayanthi Tax as environment Minister, allegedly for collecting bribes for environment clearances. This was a very serious charge Mr Modi had leveled. Now that he heads the new government at centre, he must institute a credible enquiry into this charge to prove that he was not making just frivolous statements.
Maharashtra Irrigation Scam One state that has given NDA the highest number of seats after Uttar Pradesh is Maharashtra, the NDA coalition got 42 of 48 seats in this state. One of the major reasons for this debacle of UPA was that the UPA here got a very corrupt image, in spite of its Chief Minister having a relatively clean image. This was largely due to the massive Rs 70 000 crores irrigation scam in that state. The NDA partners in Maharashtra also played a role in exposing this corruption, although the top brass of NDA was also allegedly involved in the scandal. To this corrupt image was added the arrogance shown, for example, by deputy Chief Minister (who resigned on charges of corruption, but came back even without any investigation into the charges) when he first asked how are people expecting him to give water from dams – by urinating in the dams? During elections he actually threatened a village that water will be cut off if they do not vote for his party! This combination of corruption and arrogance was sufficient to enrage the voters.
Here again one expects the NDA government at centre to take decisive credible action in exposing the guilty in Maharashtra irrigation scam and brining to book those who are responsible both among the politicians and bureaucrats-engineers. Here, as BJP spokespersons in Maharashtra have been saying, the Madhav Chitale committee has basically done white washing role[14] and hence we need an independent investigation. We hope NDA government at centre will take this up urgently.
Andhra Pradesh Irrigation Scam Similar action is also required in Andhra Pradesh Irrigation scam exposed by the CAG report[15].
AIBP As noted above, the Accelerated Irrigation Benefits Program has majorly failed in achieving any additional net irrigation area by major projects at national level. The CAG has noted in more than one report the failure of AIBP and so has the Planning Commission. The new NDA government could start with instituting a credible independent enquiry into the reasons for failure of this scheme.
Uttarakhand Disaster and role of hydropower projects[16] Following the worst ever disaster faced by the state of Uttarakhand in June 2013, the role played by indiscriminate construction of hydropower projects and other infrastructure needed to be investigated since prime facie they had played significant role in increasing the proportions of disaster. The UPA government did nothing, and it was left to the Supreme Court to ask MoEF to set up an Expert Body for this. In the meantime, SC ordered stay on any more projects. The MoEF along with Central Water Commission and Central Electricity Authority and the Congress’s Uttarakhand state government, have been trying to push more projects in stead of honoring the Apex Court orders. In April 2014, the report of Expert Body lead by Dr Ravi Chopra has been submitted. The new Union government, it is hoped, will take credible steps to implement the recommendations of the Expert Body at the earliest date.
Independent National Environment Monitor It is well known that MoEF as an independent environmental regulator is seriously compromised with shoddy EIAs, flawed appraisal and non existent compliance. This situation has remained unchanged for the last decade and more. The Supreme Court of India, seeing this, had in 2011 ordered that an Independent Environment Regulator needs to be set up at National and state level. The outgoing central government had shown reluctance to do anything in this regard, in spite of repeated Supreme Court orders. The new government has a historical opportunity to indeed set up a truly independent & accountable environment regulator, at the same time increasing the transparency and participation of people in the environmental governance through fresh round of democratic reforms.
Cabinet Committee on Investment One of the flawed legacy of the previous UPA government is the Cabinet Committee on Investment, which has been created to bypass the statutory work of the MoEF. The new Union government would do well to disband this extra legal committee.
Polavaram Project Authority Even as elections were underway, in a most inappropriate decision, the outgoing government set up a Polvaram Project Authority, without even consulting affected states of Orissa and Chhattisgarh. In both these states there is either BJP government or BJP led government. There are also cases going on against this project, including civil suits filed by the governments of Chhattisgarh and Orissa. In the interest of these states and affected tribals, the new Union Government should scrap the Polavaram Project Authority.
Mullaperiyar The 119 year old Mullaperiyar dam has already suffered damages in the past and there is no doubt that it has limited life. To overcome the inflexible attitude of Tamil Nadu and respecting the constitutional duty of Kerala government to protect the life and property of people of Kerala, it become the duty of the Union government to initiate process for new a arrangement (e.g. lower the intake level to 50 ft from current 106 ft, as seen promising both by the Empowered Body and Supreme Court in May 2014) and decommissioning of the dam in a time bound manner. The previous Union government completely failed in this and the new government has an opportunity to correct this.
Central Water Commission Central Water Commission is India’s premier technical body on water resources. Water resources development and management has always remained crucial to any country’s water, food, livelihood and environment security. However, for this we need a really independent and credible technical body at the top, on the lines of United States Geological Survey (USGS). USGS, is known to be source of very reliable water resources data world over. However, USGS’s main task is to gather data and put it in public domain. Use of that data for development tasks and such other functions are not the mandate of USGS, there are other bodies for that. Unfortunately in India, CWC tasked with data gathering, sanctioning projects, monitoring and so many other contradictory functions. Moreover, CWC is working more like a big dam lobby, and even the assessment of hydrological data, flood forecasting functioning, water use data and projections, climate change implications, dam safety issues, etc are all getting colored by the lobbying tendency of those who head CWC. This is having a very deleterious effect on the water resources development and management in India.
It is high time that there are reforms in CWC to separate its various contradictory functions and make its functioning transparent, accountable and participatory. The new Union government has a chance to initiate such reforms in CWC and Ministry of Water Resources.
Technical Advisory Committee of CWC The TAC of CWC is a very little known, but powerful body. It sanctions projects worth thousands of crores every year, but its functioning is completely non transparent, unaccountable and it has no independent members. Since the new government has been raising the issue of corruption by UPA during the election campaign, it is hoped that the new government will work to fight corruption and one of the key steps it can do is to make the functioning of TAC transparent, accountable and ensure that at least 50% members of the TAC are non governmental, independent people with track record of having shown independent mind.
Urban Water Sector The social, environmental, economic and carbon footprint of this sector increasing at huge pace, without any success story in sight. The big cities are find it easy to promote construction of big dams rather than go for rain water harvesting, sewage water treatment & recycle, demand side measurement, groundwater recharge, reduction in losses and such other measures. SANDRP report on unjustified dams being pushed in Mumbai highlights this issue. The 12th Plan Working Group report on Urban water issues have several useful recommendations that has remained unimplemented. These need to be urgently implemented.
Climate Change Climate change in the biggest threat that vulnerable sections of Indian people face, as do the vulnerable sections of the rest of the world. This is not only relevant for water and environment sectors that we are discussing here, but for all sectors. As Environmental Groups in Gujarat have noted[17], people of Gujarat do not have good experience of the Modi regime in the state. The record of the 10 year long UPA government is very poor on this issue. We hope the new Union government will do better and begin with identification of the sections of the people who are vulnerable and start working on action plan to address the concerns of such sections, while also reducing the carbon footprint of India through reduction in consumption patterns of richer sections.
Suggestions for positive actions As analysed by Dr. Ashok Gulati (former chairman of Commission for Agricultural Costs and Prices) and Dr. Tushar Shah (International Water Management Institute) separately, the relatively high agricultural growth in Gujarat in first decade of current millennium was largely due to local water harvesting work that happened in Gujarat through check dams, groundwater recharge etc, largely in non governmental sector. The new government at centre can bring about changes in policies and programs to learn lessons from such success stories to achieve such results all over India.
Similarly on the issue or river rejuvenation, management and conservation front as also environmental management front, a decentralized bottom up community driven approach can be taken up.
It can encourage people led, scientific and ecological river restoration work.
Promote System of Rice Intensification in a major way, it can not only reduce water use, fertiliser use, use of other chemicals, reduce seed requirement, increase farmers’ income, reduce agriculture sector’s carbon footprint and thus help mitigate and also adaptation to changing climate. This is possible in other crops too, as has been demonstrated at farmer level.
Encourage measures that can help increase carbon content of the soil, this will also have multiple benefits to farmers, economy and environment.
It can strengthen implementation of Forest Rights Act which UPA, despite introducing it, failed to do.
It can protect free flowing rivers for their social, ecological, cultural values.
It can also engage more effectively with civil society and community groups in a credible manner.
A recent SANDRP study “Shrinking and Sinking Deltas: Role of Large Dams” has shown that large dams are playing big role in sinking of deltas in India. This is not even properly studied. The new government can initiate a scientific study in this regard and ensure that before taking up any new project, this aspect is studied.
Conclusion I started writing this brief note following questions from several media friends, but it has become much longer! So let us come to the conclusion. I am not even sure if the new government is in any mood to listen to such unsolicited suggestions, but let us put it out and hope for the best! I decided to put this out, even as Mr Modi prepares to take office on May 26.
This article tries to show the risks, challenges and some immediate tasks of the new government at the centre. In sum, the new NDA government would do well not to forget the reasons for rejection of NDA in 2004 and UPA now in 2014. Both were guilty of bull dozing ahead with their agendas without listening to the people. Avoiding that may be the biggest challenge this government faces, besides the specific ones mentioned above.
[13] For example, Dakshin Kannada and Mangalore saw a huge socio-political movement against Moily and Congress due to his politically motivated support to Yettinahole Diversion Project.
At least 49 large[1] hydropower projects are under construction in India today, with a cumulative capacity of 15006 MW[2]. As per the latest bulletin from Central Electricity Authority[3], “Status of Hydro Electric Projects under Execution for 12th Plan & beyond (Excluding projects above[4] 25 MW)” dated March 31, 2014, 35 of these projects (9934 MW) are expected to be commissioned in 12th Five Year Plan[5] and remaining 14 with installed capacity of 5072 MW would provide benefit beyond 12th Plan.
Considering that 1534 MW capacity has already been added in first two years of ongoing 12th Five Year Plan (during 2012-13 and 2013-14), CEA projections means that India hopes to add massive 11468 MW capacity during the current five year plan. This will be higher than capacity added in any other five year plan and 254% of the capacity addition during the last, 11th Five Year Plan (2007-12) when India added 4514 MW. The graph below shows how steeply our hydropower installed capacity is going up over the last 25 years.
Rapidly Increasing installed capacity of Large Hydropower Projects in India
The proponent of even more accelerated hydro capacity addition misleadingly talk about the need for having 40% of installed grid capacity as hydro.
In line with this, the CEA came out with plans to add 65000 MW in 13th Five Year Plan (2017-2022: 30 000 MW) and 14th Five Year Plan (2022-2027: 35 000 MW). (see http://www.energylineindia.com/ of May 6, 2014)
There is no science behind this advocacy. It is basically a suggestion possibly based on the general assumption that peaking demand is 40% higher than base-load demand. Hence if we have 40% installed capacity from hydro in the grid, this can take care of total demand optimally. However, this is based on assumption that hydro capacity is indeed used for peaking. This assumption is completely wrong in India, with no agency monitoring or even reporting how much of the hydro generation currently provide peaking power. Without such optimum use of current hydro capacity, where is the case for 60:40 grid capacity ratio for hydro? It goes without saying that when hydro projects are used for peaking power, there are additional social and environmental impacts in the downstream and upstream. These need to assessed and those who suffer are compensated.
On similar lines, one can answer the advocacy for claim that hydro is clean, green, renewable and cheap source of power or that run of the river or small hydropower projects are more environmentally benign. However, this blog is not attempting to answer all such fallacies here, it needs a separate blog.
While this is happening, the Expert Appraisal Committee of Union Ministry of Environment and Forests on River Valley Projects has been clearing projects at break a neck speed with almost zero rejection rate. Between April 2007 and Dec 2013, this committee recommended environment clearance to 18030.5 MW capacity, most of which has not entered the implementation stage. Moreover, this committee has recommended 1st Environment clearance (what is technically called Terms of Reference Clearance) for a capacity of unimaginable 57702 MW in the same period. This is indicative of the onslaught of hydropower projects which we are likely to see in the coming years.
Figure 1 TORs (First Stage EC) and EC recommended by EAC between April 2007 – December 2013
Table: Sector-wise & plan-wise number of & capacity of under construction HEPs
Sector
During 12th FYP
After 12th Plan
Total
No of Projects
Installed capacity, MW
No of Projects
Installed capacity, MW
No of Projects
Installed capacity, MW
Central
11[6]
5312
3
2615
14
7927
State
12
1506
3
736
15
2242
Pvt
12
3116
8
1721
20
4837
Total
35
9934
14
5072
49
15006
Among the three sectors, the largest number of under construction projects (20) are from private sector. However, among all sectors of under construction projects, central sector projects have the highest installed capacity (7927 or 53% of under construction capacity of 15006 MW).
Figure 2 Sectorwise ownership of under-construction HEPs in Numbers
Vulnerable Himalayas are the target In the second table the state-wise and sector-wise break of numbers and capacity of under construction HEPs has been given. Himachal Pradesh has the highest number and highest installed capacity projects among all states. That state also has the highest installed capacity (8139 MW or over a fifth of operating HEP capacity at national level) of large operating hydropower projects. Sikkim, however, has the highest number and capacity of private sector hydropower projects under construction. In fact, half of the total national-level private sector projects which are under construction are in that tiny state. Their installed capacity is more than half the installed capacity of all the private sector hydropower projects under construction at national level. Ironically, the state also has the highest biodiversity in the country.
Figure 3 Installed Capacity of under construction HEPs, sector-wise ownership, in MW
Himachal Pradesh and Uttarakhand also have 5 and 3 private sector HEPs under construction respectively. The 5 Himalayan states of Jammu & Kashmir (J&K), Himachal Pradesh, Uttarakhand, Sikkim and Arunachal Pradesh between them have 38 of the 49 under construction hydropower projects with total capacity of 13550 MW or over 90% of under construction capacity. In addition, the projects of Mizoram, Meghalaya, W Bengal (Teesta L Dam IV) and Punjab (Shahpur Kandi on Ravi River) are also in Himalayan zone.
Table: State-wise & sector-wise number and capacity of under-construction HEPs
State
Central Sector
State Sector
Private Sector
Total
No of projects
Installed Capacity, MW
No of projects
Installed Capacity, MW
No of projects
Installed Capacity, MW
No of projects
Installed Capacity, MW
J&K
1
330
1
450
1
850
3
1630
Himachal P
4
2532
6
956
5
460
15
3948
Uttarakhand
4
2135
–
–
3
505
7
2640
Sikkim
–
–
–
–
10
2622
10
2622
Arunachal P
3
2710
–
–
–
–
3
2710
Mizoram
1
60
–
–
–
–
1
60
Meghalaya
–
–
1
40
–
–
1
40
W Bengal
1
160
–
–
–
–
1
160
Punjab
–
–
1
206
–
–
1
206
Madhya Pr
–
–
–
–
1
400
1
400
Maharashtra
–
–
1
80
–
–
1
80
Andhra Pr
–
–
3
410
–
–
3
410
Kerala
–
–
2
100
–
–
2
100
Total
14
7927
15
2242
20
4837
49
15006
Figure 4 State-wise and sector-wise number of HEPs under constructionFigure 5 State-wise installed capacity of under construciotn HEPs
Diminishing Returns This blind rush for hydropower projects (which have serious and irreversible impacts on social and ecological systems) is difficult to understand and justify considering their poor generation performance, rising costs and availability of better options. To illustrate, in the graph below we can see how power generation per unit (MW) installed capacity has been steadily reducing over the last two decades. From 1993-94 to the latest year of 2013-14, there has been a huge drop of 16.5%.
Diminishing power generation from India’s Hydropower Projects over the last two decades
Yawning gap between promised and actual generation of Hydro Projects Another way to look at performance of hydropower projects would be to compare the projected (as promised in Techno Economic Clearance) and actual generation (both at 90% dependability) of electricity by HEPs. This assessment shows that about 89% of India’s operating hydropower projects are generating at below the promised levels. Shockingly, half of under performing projects are generating at below 50% of promised generation levels.
How much Peaking Power are we generating? A third way to assess the hydropower generation is in terms of peaking power, a USP[7] of hydropower projects. However, no figures are available as to how much of the generation from hydropower projects are happening during peaking hours. No agency in India is even monitoring this or reporting this: including CEA, Central or State Electricity Regulatory Authority, National, Regional or State Load Dispatch Centers, Union or state Power Ministries or individual operators. In short, there is no case for justifying more hydro in the name of providing peaking power if we are neither monitoring nor optimizing hydropower generation during peaking hours. One expected CEA to do this job, but it seems they are busy lobbying for hydropower projects rather than functioning as India’s premier Technical Power sector agency.
Invitation to disaster? The consequences of such massive capacity addition are and will continue to be disastrous for the rivers, forests, biodiversity and people. The Uttarakhand disaster of June 2013 has shown the vulnerability of hydropower projects in Himalayas, as well as their impacts. The disaster and independent reports[8] also show how the construction and operation of these projects have contributed to compounding the proportion of the disaster. Climate Change is accentuating this situation and will continue to do so with increasing intensity as per the IPCC reports.
Role of HEPs in Uttarakhand disaster: CEA and CWC in denial mode This analysis of under construction hydropower projects as reported in the latest CEA bulletin shows that Himalayas is the target for overwhelming majority of hydropower projects being taken up India (& neighbouring countries like Bhutan, Nepal, Pakistan and Tibet). The Uttarakhand disaster showed how hydropower projects are increasing the existing vulnerabilities and disaster potential of the Himalayan region in times of natural calamities. An independent committee appointed by MoEF following Supreme Court orders of Aug 13, 2013 pointed out the role of hydropower projects in Uttarakhad disaster of June 2013.
It should be highlighted here that multiple hydropower projects should invite cumulative impact assessment. As Supreme Court order of Aug 13, 2013 highlighted, such cumulative impact assessment need to be done in a credible way and not the way AHEC of IITR did for the Bhagirathi-Alaknanda basin.
Strangely, instead of accepting this reality and taking this into account in decision making processes, Central Water Commission and Central Electricity Authority are in a denial mode! They collectively submitted a completely unscientific and unfounded report to Union Environment & Forests Ministry, advocating for hydropower projects rather than assessing their role in disaster, which was the mandate given by Supreme Court of India to MoEF. The CEA is clearly jeopardizing whatever credibility it has in joining hands with CWC. It would be better for both the agencies to accept and wake up to these realities.
Else, such onslaught of hydropower projects on Himalayas is likely to be an invitation to further disasters all across the Himalayas. All our decision makers and all others concerned need to take note of this urgently.
[4] In reality, this should be “below”, we have italicized the word since the error is in the original.
[5] Ending on March 31, 2017
[6] CEA projects that out of 2000 MW installed capacity of Lower Subansiri HEP in Arunachal Pradesh, 1000 MW will be commissioned in 12th Plan and the rest of 1000 MW thereafter.
Now that the Bharatiya Janta Party (BJP) has made its manifesto for the 2014 Parliamentary elections in India public on April 7, 2014, we are in a position to make a comparative reading of manifestoes of three most prominent parties in fray at national level, namely the BJP, Congress and Aam Aadmi Party (AAP). While manifestos are largely ritualistic exercises, they are also the most important documents that declare the intentions of the political outfits, besides the other statements of the party leaders and track records of the parties and their leaders. These documents need to be read both in terms of the promises that they make as also the roadmaps that the parties provide to achieve the promises.
Overall impression In that respect, the overall impression that BJP manifesto (let us begin with a comment on BJP manifesto since all the opinion polls are giving the party an edge over others, though it is well known that opinion polls are largely doctored exercises that have proved wrong so many times) gives is one of an arrogance: both in terms of the content and the timing of the document. The BJP manifesto reads more like a laundry list of feel good factors, without any roadmap as to how the party hopes to achieve the listed objectives. The fact that the party came out with manifesto even as the voting in first phase of the elections was already underway, signals that it is not bothered to tell people why they should vote for them. There is little in the track record of the party in the states it is in power for over a decade, like Gujarat, Madhya Pradesh and Chhattisgarh, to show that it is serious on these issues in these states.
Congress manifesto, also of 52 pages like that of the BJP manifesto, provides much more details about the specific issues they list, but it is not written in particularly imaginative style, nor is it making any attempt at taking care of the negativity that has been generated around its performance over the last decade. In that sense, Congress’s manifesto makes for somewhat bureaucratic and boring reading. It also lacks in providing the big picture and a big vision.
The AAP manifesto at 28 pages is more interesting as it is not written as a marketing product pamphlet. It starts with the section on Jan Lokapal, their main plank and tries to answer why people should vote for AAP. The major highlight of the whole manifesto is that the party wants to give Gram Sabhas and mohalla sabhas a decisive say in all matters at their respective levels and in overall governance. This is a major departure from other two manifestos, besides their reliance on tackling corruption & Crony Capitalism with more seriousness and convincingly than other two parties. However, while it is more elaborate than the BJP and Cong manifestos in describing how the party seeks to change the governance in India, it seems less comprehensive. Another lacuna of the AAP manifesto’s PDF file is that it is not searchable, unlike the other two manifestos.
Having taken an overall view, let us look at some specific issues that we are concerned about.
Natural Resource Management The BJP manifesto seems to have poor understanding of the scope of ‘Natural Resources’. The manifesto lists only coal, minerals and spectrum among natural resources. The most important natural resources of land, forests, rivers, water sources and biodiversity are not even listed. It seems the party is only interested in directly marketable (as in equity market) commodities that their industry friends are interested in. Interestingly, the section starts with Gandhi’s famous quote on need vs greed, but there is no reflection of this principle in what is said here.
The Congress manifesto talks about “establishment of a clearly defined policy for fair, transparent equitable and time bound development of natural resources. The Indian National Congress will immediately put in place a Special Purpose Vehicle for this.” The fact that this comes in industries section does not sound very confidence inspiring.
The AAP has a section on natural resources that does include water and forests among natural resources along with major minerals and provides Gram Sabha pivotal role, without whose consent, decisions about exploitation of such major natural resources cannot be taken. The ownership of the minor natural resources remains with the gram sabhas in AAP scheme of things.
Environmental governance The BJP section on this issue has interesting heading: “Flora, Fauna and Environment – Safeguarding Our Tomorrow”. However, the section or the rest of the document does not tell us anything how they are going to improve environment governance in India or do they even see this need. On the contrary, by stating in Industry section that it intends to “Frame the environment laws in a manner that provides no scope for confusion and will lead to speedy clearance of proposals without delay” and talking about single window and speedy clearance elsewhere, it is clear what is their understanding is and where they intend to go. This can only be disastrous for India’s environment and environmental governance.
The Congress Manifesto claimed that it intends to set up National Environment Appraisal and Monitoring Authority. However, as Supreme Court judges promptly remarked, this is actually the order of the Supreme Court and Congress had no business of putting it on their manifesto. Moreover, Congress lacks credibility on this, since, when Jairam Ramesh, as environment minister proposed this, he was actually removed and his successor did nothing to implement this. Moreover, the environment ministry under UPA II actually filed an affidavit in the Supreme Court saying that it is not possible to set up such an authority with any teeth. The appointment of Union Oil Minister Veerappa Moily as Environment Minister, forgetting about conflict of interest and the actions that Moily as been taking subsequently including pushing the disastrous Yettinahole Diversion Project to benefit his parliamentary constituency in Karnataka takes away any credibility the party may have had. It is true that National Green Tribunal is the only major contribution of UPA on this issue, but that too is largely due to Mr Ramesh as his successor ministers tried their best to scuttle the functioning of NGT.
The AAP manifesto talks about reforming “Ministry of Environment and Forests and its agencies so that they can empower and facilitate Gram Sabhas to be effective custodians and managers of their local natural resources.” This is certainly welcome. However, there are insufficient details as to how this will be achieved. Their clubbing of Ecology and Economy in one section sounds promising at one level, again how this will be implemented without allowing ecology to be subservient to economic interests is not described.
Rivers It is well known that Inter Linking of Rivers (ILR) is high on agenda of BJP and Mr Modi. However, for some unclear reasons, they have played down ILR, saying, “Inter-linking of rivers based on feasibility.” Possibly they do not want to raise the hackles prematurely. However, the Narmada Kshipra link that was recently inaugurated and the track record of the BJP in Madhya Pradesh and elsewhere seems to suggest that BJP state governments are working at cross purposes with the national ILR plan.
The BJP manifesto says, “BJP commits to ensure the cleanliness, purity and uninterrupted flow of the Ganga on priority”, but this is not helpful, since no roadmap is given how this will be achieved. Moreover, this intentionally ignores the three biggest threats that the Ganga and other rivers face: The dams & hydropower projects, the urban & industrial pollution & encroachment. The BJP manifesto is silent on all these three threats to the river. Even on the issue of River Pollution, the only thing the party manifesto condescends to inform the readers is that “a massive ‘Clean Rivers Programme’ will be launched across the country driven by people’s participation.” No details again. Even on the issue of seemingly unsolvable urban water pollution, the only solution party can offer is more sewage treatment plants, choosing to ignore that the existing STPs are non functional most of the places. Interestingly, BJP manifesto has a section on North East India (unlike the other two manifestos) and mentions the flood problem of Assam and promises tackling the river, but without any details as to how.
It is worth noting in this context that when BJP’s PM candidate Mr Modi visited North East India in general and Arunachal Pradesh in particular he did not mention ILR or large hydropower projects in that region, knowing that local sentiments are totally against them. However, Mr Modi, while proposing his national energy plan in Madhya Pradesh in March 2014, said that North East India is heaven for hydropower projects! The manifesto again is expectedly silent on this issue!
The Congress manifesto says that “The National Ganga River Basin Authority has begun the ambitious task of cleaning the Ganga River. We will use similar models of creating empowered, well-funded agencies to clean other major rivers in the country”. Now this sounds mindless and incredible! NGRBA, five years after it was notified, has been the most ineffective, non transparent institution that has achieved no change in the state of the river. How can such an institution be used as a model for other rivers? The authors of the Congress manifesto seem completely ill informed on this score.
The AAP manifesto seems to have nothing on Rivers: a major omission of the manifesto.
Water The BJP manifesto promises piped water supply to all households! Irrespective of if all households need it or not or is it feasible or appropriate or not. The BJP manifesto claims that there will be 50% gap between demand and supply of water in India by 2050. This is totally off the mark, according to Govt of India’s National Commission for Integrated Water Resources Development, country’s water requirement will match the available resources in 2050, even considering high growth trajectory, we are going far below that level currently. The BJP manifesto writers seem to have no clue about the realities, or they are just trying to push greater market for water companies. There is one promise in this regard that is welcome: “We will promote decentralized, demand-driven, community-managed water resource management, water supply and environmental sanitation.” However, how they will promote this is not given. Moreover, this promise remains unconvincing considering they also talk about river linking.
The Congress manifesto talks about adding 1 crore ha in gross irrigated area in 12th Plan, two years of which are already over! It clearly looks impossible, but more importantly, it does not say how they will achieve it. Both Congress and BJP manifestoes talk about water conserving irrigation techniques, which is actually seems to be scam ridden and affected by crony capitalism. Congress manifesto also talks about increasing irrigation efficiency and water use efficiency in general, but without any roadmap. More worryingly, the UPA government has pushed the proposal to allow Jain Irrigation (the biggest private supplied of drop and sprinkler systems) to set up the National Bureau of Water Efficiency! Crony capitalism?
The AAP manifesto talks about giving priority to watershed development to reduce pressure on big irrigation projects, but fails to take an informed and prudent stand on performance of big irrigation projects. This is certainly a major let down of AAP manifesto.
Urban Water Issues There is nothing noteworthy in BJP manifesto in this regard, even as it plans to prioritise Urban Development. It has no clue about how to tackle Urban Wastewater as it only talks about more STPs when existing STPs are not working, including in Modi’s Gujarat.
The Congress manifesto talks about continuing the problematic Jawaharlal Nehru Urban Renewal Mission under which over Rs 70000/- crores have been spent, mostly on Urban water issues, without any attempt at democratic governance, local water options, demand side management or recycle and reuse of treated sewage. This is creating havoc on surrounding areas with displacement of tribals, destruction of forests and pushing unjustifiable dams. But it seems Congress is least bothered about it. The problem is so acute that some 18000 people in Thane to be displaced by Kalu dam meant for Mumbai have decided to boycott the polls, since the dam is being taken up without any clearances and when all the gram sabhas have passed resolutions against it. The writing is clearly on the walls for the Congress.
The only positive aspect in this regard in AAP manifesto is the proposed empowerment of Mohalla Sabhas. Let us hope they are able to show how this will work.
Climate Change It is interesting to see that Climate Change is an issue recognised by BJP and Congress manifestos, but what they say there is disappointing in both cases. BJP manifesto talks about launching a National Mission on Himalayan Ecosystem, but there is already one existing, which is supposed to be under implementation for some years, but no one seems to know what it is doing! BJP Manifesto also talks about program devised to arrest melting of Himalayan glaciers, sounds strange, since no such program is known.
The Congress manifesto promises of continued implementation of National Action Plan on Climate Change when the plan and its mission stand discredited, along with the Prime Minister’s Council on Climate Change. These are the things that make the Congress manifesto sound so bureaucratic.
AAP manifesto seems silent on climate change.
Renewable Energy It is welcome to note that BJP manifesto talks about promoting small hydro with local support and without displacement. However, it is not welcome that there is no mention of big hydro and big dams. Their promise to push infrastructure development in Arunachal Pradesh without any mention of participatory decision making with the local communities is likely to raise suspicion that this is for pushing big hydro there. The manifesto is also silent about promoting household level solar power projects.
The Congress manifesto is also silent on promoting household level solar power projects. It talks about giving new thrust to small hydro under new and renewable energy sources, but these projects need social and environmental impact assessment, the manifesto is silent on this.
The AAP manifesto is the only one that does talk about pushing decentralized renewable energy plants, which is welcome.
Tribal Development The scary part in BJP manifesto in this regard is that tribal development in India will be pushed on the lines of what has been achieved in Gujarat, Madhya Pradesh and Chhattisgarh! If this is the tribal development model for tribals in other areas, tribals all over India need to be very wary of this party.
The Congress manifesto says: “We will ensure the stringent implementation of PESA, 1996 and the Forest Rights Act, 2006 to ensure that Scheduled Tribes are empowered and brought into the mainstream.” Sounds good, but the trouble is what has Congress governments both at centre and states done? Nothing about PESA and very little to implement FRA in letter and spirit.
In that respect AAP manifesto does make such commitment and this is most welcome. This is possibly the only useful thing for tribals among all three manifestos, in addition to the fact that AAP provides separate section for Tribals, for Scheduled castes and also for Valmikis, unlike the BJP and Congress manifestos basically clubbing all under one head.
In conclusion It is apt that the last page of the BJP manifesto says “Time for Modi” and not for BJP! The Congress manifesto on last page shows Rahul Gandhi sitting with urban youth. This appeal will have limited catchment. The last page of AAP manifesto asks voters in Hindi to vote for the honest party.
This blog also hosted at: http://www.write2kill.in/himanshu-thakkar/election-manifestos-of-bjp-congress-and-aap-comparative-reading-on-environment.html
and at: http://indiatogether.org/comparing-manifestos-of-national-parties-environment.
8. Great to see hydropower projects become election issue in Sikkim: http://www.firstpost.com/politics/in-sikkim-environmental-issue-get-top-priority-1470713.html
10. EPW editorial: “The absence of any engagement with climate change in the planet’s biggest elections is shocking” http://www.epw.in/system/files/pdf/2014_49/15/King_Canutes_Land.pdf
This is analysis of the decisions of the Advisory Committee in the Union Ministry of Water Resources for consideration of techno-economic viability of Irrigation, Flood Control and Multi Purpose Project Proposals (TAC in short) for North East India[1] from 95th meeting of January 2009 to 122nd meeting held in December 2013. In our last analysis of TAC minutes we have covered the decision taken for NE states from July 2011 to December 2013 which is available at – https://sandrp.wordpress.com/2014/03/19/lack-of-transparency-and-accountability-remains-the-norm-of-functioning-for-mowrs-advisory-committee/. In this analysis, we have covered the same for an extended period. In these five years TAC has accepted project proposals worth of 5515.46 crores. In calculating the total cost of the projects considered we have considered only the projects whose proposals were given clearance by TAC. In these five years, some of the projects also made two appearances with revised costs. In such cases the higher revised cost has been taken into consideration, e.g. Khuga Multipurpose Project and Dolaithabi Barrage Project, both located in Manipur were accepted by the committee in its 100th meeting (held on 9th October 2009) with revised cost of Rs 381.28 crore and 251.52 crore respectively. In the 115th meeting (held on 24th July 2012) of the TAC, these two projects were considered again where the cost for Khuga Project was Rs. 433.91 cr and for Dolaithabi Project it was Rs. 360.05 Cr. The same is the case for the Thoubal Multipurpose Project which appeared in 101st and 115th meeting of the TAC.
Within these five years, TAC has given financial clearance to 26 flood and erosion control projects and majority of these projects are from Assam. The committee gave the clearance to 6 irrigation projects, 3 barrage projects and 3 multipurpose projects.[2] The committee also gave clearance to a strom water drainage improvement project below Greenfield Airport at Pakyong in Sikkim within this period.
In this period, largest no of considered (25) and approved (20) projects were from Assam. Assam also has the maximum cost of projects among all states (Rs. 2631.99 Cr). Highest number of projects were considered (16) and approved (14) in the year 2009, with total cost of Rs 2321 Crores, which too was highest among all the years.
As found in our previous analysis, in the last five year from 2009 to 2013 TAC has not rejected a single project. Five projects had been deferred but were approved in the subsequent meetings within the same period. In the 108th meeting (held on 4th January 2011), the TAC did not discuss two projects on the Brahmaputra river stating “It was observed that the flood control and anti erosion scheme of Brahmaputra Board are implemented through Central Fund, which do not require investment clearance from the Planning Commission. Therefore, these schemes need not be put up to the Advisory Committee. However, the technical aspect of such project may be looked into by Central Water Commission as per past practice.” But both these projects were reconsidered in the 110th meeting of TAC (held on 20th July 2011) and were cleared by the committee.
So this seems like a rubber stamping committee, clearing everything that comes to it. Reading of the minutes of the meetings also reveals that there are hardly any critical questions asked on merits of the questions for the massive delay and cost escalations that most of the projects suffer. Nor is there an discussion about the performance of the projects.
As we noted earlier, this committee functions in most non transparent, non participatory and unaccountable way. Neither the minutes nor the agenda notes of the meetings are in public domain. Following our letters along with TAC analysis in April 2011, addressed to Planning Commission, Union Ministry of Water Resources, Central Water Commission and members of the National Advisory Council, for the first time, TAC minutes were put up on CWC website (see: http://www.cwc.gov.in/main/webpages/TAC%20minutes.html). However, the last uploaded minutes were for the 115th meeting held in July 2012, after which minutes have stopped being uploaded. Secondly, some of the links are not working and all the files are unnecessarily large PDF files since only scanned pages of the minutes are put up, in place of the PDFs of normal word files, which would be of much smaller size. The TAC also has no independent, non government members, all the members are government officials. As we wrote to MoWR and Planning Commission in April 2011 and again in March 2014, there is urgent need for TAC to have such members so that they provide objective perspective about the projects that come up before TAC.
The importance of functioning of this committee cannot be over emphasised. As we wrote in our letter to MoWR and Planning Commission, TAC “considers dozens of such projects with huge economic, social, environmental and other implications for the country in every one of its meetings. All of these projects are supposed to be public purpose projects, and are taken up using public resources. The Planning Commission accords investment clearance to the projects only after the TAC clearance. This Committee’s decisions are perhaps the ones which impact on India as a whole the most – as they relate to land and water – which are the basic life sustaining and livelihood providing resources for the people.”
It is high time that first effective steps are taken to ensure that the functioning of this committee becomes more transparent, participatory and accountable.
State-wise list of projects cleared by TAC
State
No of Projects Considered
No of projects approved
Total cost of the projects
Arunachal Pradesh
4
4
106.6
Assam
25
20
2631.99
Manipur
10
10
2268.99
Meghalaya
1
1
5.63
Sikkim
1
1
48.55
Tripura
6
6
453.7
Note: No projects from Mizoram and Nagaland have come to TAC in this 5 years period.
Year-wise List of Projects Cleared by TAC
Year
No of Projects Considered
No of projects approved
Total cost of the projects
2009
16
14
2321
2010
5
5
663.67
2011
12
9
497.33
2012
5
5
2208.81
2013
9
9
1439.45
Meeting-wise List Projects Cleared by TAC January 2009 to December 2013
Sl. No
Meeting no
Date of meeting
No of projects considered
No projects approved
No of projects deferred
No of projects rejected
Total cost of the accepted projects, Rs Crore
95th
20.01.2009
4
3
1
0
196.07
96th
16.02.2009
2
2
0
0
168.14
100th
09.10.2009
6
5
1
0
264.73
101st
30.11.2009
4
4
0
0
77.26
102nd
28.01.2010
1
1
0
0
59.91
103rd
11.03.2010
1
1
0
0
302.22
106th
16.09.2010
3
3
0
0
301.54
108th
04.01.2011
2
0
2
0
0
109th
04.03.2011
3
3
0
0
70.13
110th
20.07.2011
5
4
1
0
211.56
111th
17.08.2011
1
1
0
0
167.09
112th
14.09.2011
1
1
0
0
48.55
115th
24.07.2012
5
5
0
0
2208.81
117th
21.03.2013
1
1
0
0
155.87
118th
30.07.2013
2
2
0
0
467.38
119th
29.08.2013
2
2
0
0
601.67
120th
13.09.2013
1
1
0
0
42.96
121st
08.10.2013
2
2
0
0
146.01
122nd
20.12.2013
1
1
0
0
25.56
Total
47
42
5
0
5515.46
95th meeting (20.01.2009): Accepted TOTAL – Rs 196.07 crores (revised costs have been taken into consideration)
SN
Project
Dist/ State
Appr. year
River/ Basin
Original (revised) Cost-CrRs
Decision
1
Protection of Sialmari Area
Morigaon/ AS
2002
B’putra
14.29 (25.73)
Accepted
2
Protection of Bhojaikhati, Doligaon and Ulubari
AS
2002
B’putra
14.52 (27.92)
Accepted
3
Protection of Majuli Island Ph II-III
AS
New
B’putra
116.02
Deferred the proposal with suggestion to prepare the cost at current prices.
4
Raising & strengthening Dyke from from Sissikalghar to Tekeliphuta including closing of breach by retirement and anti erosion measures
AS
New
B’putra
142.42
Accepted
96th meeting (16.02.2009): Accepted Total – Rs 168.14 crores
SN
Project
Dist/ State
Appr. year
River/ Basin
Original (revised) Cost-CrRs
Decision
1
Flood protection of Majuli Island Ph-II & III
AS
New
B’putra
115.03
Accepted
2
Restoration of Dibang & Lohit rivers to their original courses at Dholla Hattiguli
AS
New
B’putra
23.32(53.11)
Accepted partially & suggested that proposal of coffer dam, pilot channel, etc. may be put up to the Standing Committee for expert opinion
100th meeting (09.10.2009): Accepted: TOTAL – Rs 897.53 crores
SN
Project
Dist/ State
Appr. year
River/ Basin
L of Dam
Original (revised) Cost-CrRs
Benefit Irri CCA
Annual Irrigation
Decision
1
Borolia Irrigation Project
AS
1980
Brahmaputra
92 m
6.775 (135.93)
9717
15,000 Ha
Deferred due to non-submission of State Finance Concurrence
2
Khuga Multipurpose (Major- Revised)
Manipur
1980
Khuga/ Imphal
230 m
15 (381.28)
9575
14,755 Ha
Accepted
3
Dolaithabi Barrage Project (Med Revised)
Manipur
1992
Iril/ Manipur
79 m
18.86 (251.52)
5,500
7,545 Ha
4
Gumti Irrigation Project (Revised)
Tripura
1979
Gumti
96 m
5.88 (83.01)
4,486
9,800 ha
Accepted
5
Khowai Irrigation Project (Revised)
Tripura
1980
Khowai
96 m
7.10 (83.01)
4,515
9,320 Ha
Accepted
6
Manu Irrigation Project
Tripura
1981
Manu
82 m
8.18 (98.71)
4,198
7,600 Ha
Accepted
101st meeting (30.11.2009): Accepted TOTAL – Rs 1059.26 crores
SN
Project
State
Appr. year
River/ Basin
L of Dam
Original (revised) Cost-CrRs
Benefit Irri CCA/ flood prot.
Annual Irrigation
Decision
1
Raising & strengthening to Puthimari embankment
Assam
New
B’putra
NA
30.23
15000 Ha
NA
Accepted
2
Anti Erosion measures to protect left B’putra Dyke
Assam
New
B’putra
NA
27.97
5000 Ha
NA
Accepted
3
Protection of Gakhirkhitee and its adjoining areas
Assam
New
B’putra
NA
19.06
20,000 Ha
NA
Accepted
4
Thoubal Multipurpose Project (revised)
Manipur
1980
Thoubal/ Imphal
1074 m
47.25 (982)
21,862 ha
33,449 Ha
Accepted
102nd meeting (28.01.2010): Accepted TOTAL – Rs 59.91 crores
SN
Project
Dist/ State
Appr. year
River/ Basin
Original Cost-CrRs
Benefit-flood protsn
Decision
1
Emergent measures for protection of Rohmoria in Dibrugarh Dist
Assam
New
Brahmaputra
59.91
18,000 Ha
Accepted
103rd meeting (11.03.2010): Accepted: TOTAL Cost of approved projects: Rs 302.22 crores
Project
Dist/ State
Appr. year
River/ Basin
L of Dam
Original (revised) Cost-CrRs
CCA (Ha)
Annual Irrigation (Ha)
Decision
Champamati Irrigation Project
Chirag/AS
1980
Champamati/B’putra
258.5 m
15.32 (309.22)
17,414
24,994
Accepted
106th meeting (16.09.2010): Accepted TOTAL – Rs 301.54 crores
SN
Project
Dist/ State
Appr. year
River/ Basin
Original (revised) Cost-CrRs
Decision
1
Raising & strengthening of tributary dyke on both banks of Kopili River
Assam
New
Kopilli/ B’putra
110.72
Accepted
2
Assam Integrated Flood River Bank Erosion Risk Management Project
Dibrugarh/ Assam
New
Brahmaputra
61.33
Accepted
3
Assam Integrated Flood River Bank Erosion Risk Management Project
Palasbari/ Assam
New
Brahmaputra
129.49
Accepted
108th meeting (04.01.2011): Accepted TOTAL- Rs 0
SN
Project
Dist/ State
Appr. year
River/ Basin
Original (revised) Cost-CrRs
Decision
1
Restoration of Dibang & Lohit rivers to their original courses at Dholla Hattiguli
AS
New
Brahmaputra
23.32(53.11)
The technical aspect pf this type of project may be looked in to by CWC as per past Practices.
2
Protection of Majuli Island from flood & erosion, Ph II-III
AS
New
Brahmaputra
116.02
The technical aspect pf this type of project may be looked in to by CWC as per past Practices.
109th meeting (04.03.2011): Accepted TOTAL – Rs 70.13crores
SN
Project
Dist/ State
Appr. year
River/ Basin
Original (revised) Cost-CrRs
Decision
1
Anti Erosion & Flood Protection work in Dikrong Basin
Arunachal Pradesh
New
Dikrong
23.68
Accepted
2
Anti Erosion & Flood Protection work in Bhareli sub Basin
Arunachal Pradesh
New
Bhareli
16.81
Accepted
3
Anti Erosion & Flood Protection work in Siyom Basin
Anti erosion work along river Gumti from Dlak Samatal Para to Durgapur under Amarpur, Udaipur & Sonamura subdivision
S & West Tripura
Gumti
54.99
2209
Accepted
Anti erosion work along river Khowaii from Netajinagar to Banglahour under Telimura subdivision and from south L. N. Pur to Paharmura bridge under Khowai subvision
[1]While this article only contains the details of the North East India Projects considered in TAC for the five years, we hope to soon provide details of the projects considered by TAC from all over India.
[2] Sicne Khuga Multipurpose, Thoubal Multipurpose and Dolaithabi barrage project, all from Manipur appears twice in this period, they have calculated only for once here.
The Advisory Committee in the Union Ministry of Water Resources (MoWR) for consideration of techno-economic viability of Irrigation, Flood Control and Multi Purpose Project Proposals (TAC in short) is a very important committee. It accords the financial clearance for any irrigation, flood control and multipurpose project. TAC is supposed to discuss the techno-economic viability of projects as per the resolution published in the Union of India Gazette Notification No. 12/5/86-P-II dated Nov 27, 1987. This committee came into being replacing a similar committee that existed earlier in the planning commission. Even now, the guidelines for functioning of the committee are issued by the Planning Commission.
The Gazette notification cited above also said, “The committee may also invite representatives of any other Government organizations, scientific body of experts in the relevant fields to participate in its deliberations.” This seems like a window to appoint credible, independent, non-government persons in the committee, but this window does not seem to have been used. Among the functions of the committee listed in this notification include, “The functions of the Committee will be to examine projects proposed by State Governments, Central Government or other organizations and satisfy itself that the schemes have been prepared after adequate investigations” and “the need of environment conservation and proper rehabilitation of project-affected persons have been taken into account.” However, our perusal of the functioning of the TAC shows that TAC has failed to fulfill both these mandates.
As noted in the Guidelines for Submission, Appraisal and Clearance of Irrigation and Multipurpose Projects, 2010 available on the CWC website (see: http://www.cwc.nic.in/main/webpages/publications.html), “The project proposal, thereafter, is put up to the Advisory Committee for clearance, which is, by and large, like single window clearance.” The importance of such a single window clearance becomes all the more important. The guidelines further note, “On the basis of examination conducted by the Advisory Committee, decision on techno-economic viability of the projects is taken in the meeting of this Committee. The projects found acceptable by the Advisory Committee shall be recommended for investment clearance by the Planning Commission and inclusion in the Five Year Plan/Annual Plan.” This shows how important is the role of the TAC in judging techno-economic viability of projects and also from the point of view of prudent planning.
No Transparency, independent participation or accountability of TAC Considering the above, there is strong case for clearly defined norms for transparency, participation and accountability in (1) functioning of TAC; (2) The screening process of the projects at initial stages that also happen under these guidelines in the Central Water Commission, based on which approval for DPR preparation is given.
In view of the significance of TAC, this is SANDRP’s third analysis of the decisions taken in TAC meetings. The present analysis covers decisions taken for North East India from 110th to 122ndTAC meeting. In the two previous analysis done by SANDRP, TAC meeting decisions taken from 95th meeting to 109th meeting has been covered. Here it is important to note that lack of transparency has been observed right from the agenda and minutes of the TAC meetings. The agenda and minutes of the TAC meetings should be uploaded on CWC website but CWC website has minutes only till the 115th meeting held on 24th July 2012 and the website has been last updated on 31/08/2012.
In this analysis we have covered 13 TAC meetings held from July 2011 to December 2013. In these 13 meeting, 21 projects from 6 northeastern states have been considered. But out of the 13 meetings held, projects from northeast were considered only in 10 meetings. TAC has accepted the proposals for projects with a total cost of rupees 4075.46 crore. Majority of the projects were given clearance at the first time of consideration. Thus, on an average TAC had cleared projects worth of 407.55 crores from the North East in each of these 10 meetings. Number of the projects considered by TAC in each meeting along with their total cost is given below. A state-wise and a project-wise list is also provided.
Total Cost of Projects Cleared by TAC July 2012 to December 2013
Sl No
Meeting no
Date of meeting
No of projects considered from NE
No projects approved
No of projects deferred
No of projects rejected
Total cost of the accepted projects, Rs Crore
1
110th
20-07-11
5
4
1
0
211.56
2
111th
17-08-11
1
1
0
0
167.09
3
112th
14-09-11
1
1
0
0
48.55
4
115th
24-07-12
5
5
0
0
2208.81
5
117th
21-03-13
1
1
0
0
155.87
6
118th
30-07-13
2
2
0
0
467.38
7
119th
29-08-13
2
2
0
0
601.67
8
120th
13-09-13
1
1
0
0
42.96
9
121st
08-10-13
2
2
0
0
146.01
10
122nd
20-12-13
1
1
0
0
25.56
Total
20
4075.46
State-wise list of projects cleared by TAC
Sl. No
State
No of projects approved
Total cost of the approved projects, Rs Crore
1
Arunachal
1
36.47
2
Assam
7
1526.85
3
Manipur
7
2268.99
4
Meghalaya
1
5.63
5
Sikkim
1
48.55
6
Tripura
3
188.97
Note: No projects from Mizoram and Nagaland have come to TAC in this 30 month period.
Some observations regarding TAC meetings
1. Zero Rejections The TAC did not reject a single project. There was only one project which was deferred in the 110th meeting but it was approved in the next meeting. Rest of the new projects were were approved in the very first meeting of their consideration.
2. Lack of information The TAC minutes provide little information about projects. Specially in case of newer projects, detailed discussions should have happened. The minutes of TAC meetings do not give much of an idea about size, location, benefits of a particular project. In the project- wise list provided towards the end of this analysis, we have provided limited information available in the minutes. Some of the noteworthy missing information is listed below:
– In the 115th meeting, 5 projects from Manipur were considered. Out of these five projects, 2 were multipurpose projects and 3 were barrage projects. Surprisingly, there was no information about where these projects are located, on which river, what the size of these projects. None of the minutes mentioned about whom these projects will actually benefit. Only two projects mentioned about increase in annually irrigated land but no more detail was provided.
– In the 118th meeting, construction of embankments on both banks of river Ranganadi for flood management and river training was considered. But the cost of the project was on the higher side compared to the embankment construction work to be done on the river Dikrong, considered in the same meeting. This cost escalation may be due to the difference in the length of the projects. But this cannot be confirmed since minutes do not mention the length of the proposed embankments.
India’s First Geo-tube embankment in Matmora in Dhakuakhana sub-division of Lakhimpur district in Assam. Photo: Parag Jyoti Saikia
But the increased costs may also be due to the use of Geo bag technology for construction of Ranganadi embankments. Use of Geo-bag technology is a costly affair but nothing has been mentioned about the use of this technology in the minutes of 118th meeting. This is stated in the annexure (Annex VI as mentioned in the document) of the meeting. Interestingly this annexure too has been mentioned only as a corrigendum.
3. No Detailed Discussion on Projects Considered This was very evident in the two previous analysis done by SANDRP and situation remains the same this time as well. In case of all the projects, including the ones considered for the first time, there was no detailed information or any detailed discussion. There is no discussion on technical viability of the project. Reading through the minutes gives an impression that approval for any project considered by TAC is fait accompli.There is no discussion about whether the project is a desirable project, if there are other options available, if this is the best option and so on. Under the mandate given to it, TAC is supposed to discuss all these issues. TAC accepted projects proposals with huge cost and time overruns but little enquiry has been made why such escalation happened.
Dhansiri irrigation project This is a glaring example of cost escalation. The project was discussed in the 119th meeting on 29.08.2013 for consideration of cost of Rs 567.05 crores. But, it was surprising to find that original cost of the project in 1975 was Rs 15.83 crores as according to the information available in Assam State Irrigation Department website.[1] The same website states that project started in 1975 and supposed to be completed 35 years later in 2010. In the TAC meeting a new time schedule of March 2015 was stated. The cost of the project has increased by 35.82 times over a period of 40 years but the advisory committee accepts proposal without much scrutiny or enquiry.There was no detailed assessment of the reasons for time and cost over runs (there is no question of delay due to clearances or agitations here) or whether this project which will take 40 years just to complete will be viable or not. On the contrary, the planning commission representatives said, “the benefit cost ratio of the project was 1.2 and any further escalation in cost would result in the project becoming techno-economic unviable.”
The TAC should have done a detailed assessment why the project took so long time to complete. But it seemed to be contended with the rational that the project authorities provided which was that due land acquisition and law and order problem the project has not been completed. But in the meantime minutes of the meeting also showed that that major components of the project are in advanced stages of construction with 93% of barrage work, 99% of the canal works and about 83% of works in the distribution system were reported to have been completed. There has been no detailed assessment in to any of these aspects.
Imphal Barrage project In this project, the cost of the project mentioned in the minutes of the 115th meeting contradicted with the cost provided in the annexure. The cost of Extension, Renovation and Modernization (ERM) of the Imphal barrage project as mentioned in the minutes is Rs 16.80 crores. But a letter from the Under Secretary, Govt. of Manipur to the Chief Engineer of Irrigation and Flood Control Department, Manipur dated 21.07.2012 stated the cost of the project as 23.41 crores. This reflects the lack of serious discussion over projects in TAC. It is also surprising that TAC, being the committee which gives the techno economic clearance to projects, does not have clarity about even the cost of the project.
4. No Discussion over Social, Environmental and Other impacts of the Projects The projects cleared by TAC have serious social, environmental and other impacts but the committee never discussed these impacts. TAC does not at all take into account the impacts a project would have on the environment.
In the 118th meeting (30.07.2013), while considering the proposal for flood management of Dikrong along with river training works on both banks, the minutes stated “Effectiveness of existing embankments of river Dikrong has been deteriorating due to lack of repair, siltation of river bed and consequential change in river behaviour, change in flow pattern due to release of Ranga Nadi hydel project etc.” But this is one of the rare instances when TAC mentioned about the environmental impacts on embankments. But rather than asking for more details on these impacts or to see whether embankment would really be a viable option or not, the TAC accepted the proposal. On the other hand nowhere the committee discussed what impacts an embankment has on river bed, siltation or downstream stretches of a river.
Dikrong Power Station at Hoz where water from Ranganadi HEP is released in Dikrong/Pare. Photo: Parag Jyoti SaikiaRiver Dikrong at Dikronghat in Lakhimpur district of Assam where it erodes rapidly. The impacts of change is water flow is clearly visible. Due to release of water in upstream water at night covers the lower portion of the bank. This photo was taken around 8am in the morning when the water receded. The lower bank portion was wet in the morning. According to the local the water further recedes by the evening and again increases at night. Photo: Parag Jyoti Saikia
It is also important to note here TAC also does not take into consideration impacts of the hydropower projects on the embankments in the downstream of the river. In the above mentioned case, the increased costs of Dikrong embankment should have been charged on the Ranga Nadi HEP, but there is no discussion on this. The Pare hydropower project (110 MW) in Papumpare district of Arunachal Pradesh is currently under construction on Dikong / PareRiver. Moreover there are at least 10 hydropower projects at various stages in the combined Ranganadi-Dikrong basin in Arunachal Pradesh, including one operating, three TOR approvals given and five additional MoA signed (in addition to a proposed project). There is no provision to assess the impacts of these projects on the embankments downstream of DikrongRiver in Assam. In fact there is no provision for any impact assessment study for embankments even though studies show the disastrous impacts of embankments on environment, floods and on the lives of the people living close to the river.
5. Clearing Same Embankment Projects over Years In terms of embankments, it is observed that the TAC had cleared same projects over the years. Not emphasizing on the environmental impacts of embankment projects is one of the major reasons for this. In the 117th TAC meeting held on 21.03.2013 the proposal for “Protection of Brahmaputra dyke from Sissikalghar to Tekeliphuta at different reaches from Lotasur to Tekeliphuta from the erosion of river Brahmaputra Assam” was considered. The estimated cost of the project was Rs 155.87 crore. But on the same embankment, a project titled “Raising and Strengthening to Brahmaputra dyke from Sissikalghar to Tekeliphuta including closing of breach by retirement and anti-erosion measures (to protect Majuli and Dhakukhana areas against flood devastation by the Brahmaputra, Lakhimpur district, Assam) was accepted in the 95th TAC meeting held on 20.01.2009. The estimated cost of the earlier project was 142.42 crore.
A Hoarding on the way to Geo-tube embankment in Matmora, describing the project. Photo: Parag Jyoti Saikia
The minutes of the 117th meeting, about the previous scheme said that it “was taken up primarily for closure of breach in the then existing embankment including raising of embankment around the breach area only.” But the minutes of the 95th TAC meeting had said something totally different about the project. The minutes stated that project proposal envisaged – (i) Raising and strengthening of embankment for a length of 13.9 km, (ii) Construction of retirement bund with geo-textile tubes of length 5000 m. This shows how the discussion on the Brahmaputra dyke Sissikalghar to Tekeliphuta is 117th meeting is completely misleading. TAC does on even take into account its previous meeting discussions before clearing a project. This possibly gives a hint of a scam.
The Brahmaputra dyke from Sissikalghar to Tekeliphuta has a long history of facing severe erosions. The first geo-tube embankment was constructed on this dyke in Dec 2010. Crores have been spent for the protection of this embankment. But even after that the Dhakukhana sub-division always remained in the headlines during the flood season in Assam. There is need for area specific detailed study assessing the impact on and of the embankment, but little has been done in this regard. Besides, the Bogibeel Bridge, the fourth one on the BrahmaputraRiver, is coming up in the upstream of this embankment. Construction of this bridge would make this dyke even more prone to erosion since the length of this bridge will be 4.94 km, shrinking the wide river to great extent. In a personal visit to the area, one of the government officials informed that as a result of this “funneling action”, the force of water will increase and it will directly hit the embankment leading to more erosion. But TAC has never dealt with these issues in its meetings but cleared all the proposals that it considered. Short History Brahmaputra Dyke from Sissikalghae to Tekeliphuta[2]
6. There is no independent, critical voice in the meetings. The agenda, proceedings, or decisions of the meetings are not even in public domain.
7. There is no mechanism to hold the TAC accountable for any wrong decisions taken.
8. The TAC is clearly not fulfilling the mandate given to it in the guidelines for TAC meetings. The guidelines themselves need revision from several points.
9. There is no attempt to assess the justifiability of the kinds of projects that are being accepted and if they are indeed delivering the promised benefits.
Anti erosion work along river Gumti from Dlak Samatal Para to Durgapur under Amarpur, Udaipur & Sonamura subdivision
S & West Tripura
Gumti
54.99
2209
Accepted
2
Anti erosion work along river Khowaii from Netajinagar to Banglahour under Telimura subdivision and from south L. N. Pur to Paharmura bridge under Khowai subvision
Most of the major rivers in the North East India are largely free-flowing till date, which is a rarity in India and the world. Their basins are home to unbelievable ecological and cultural diversity. Main rivers in Arunachal Pradesh which form the mighty Brahmaputra are the Siang (the Yarlung Tsang Po), Dibang and Lohit, which meet at the trijunction to form Brahmaputra.
Massive hydropower projects are planned on these rivers in cascade. They will have irreversible destructive impacts on the society, forests, rivers, biodiversity, ecosystems, cultural identity and downstream Assam.
Hydropower Flood in Arunachal Pradesh Map: Neeraj Vagholikar, Sanctuary Asia
Siang River alone has 44 dams planned along its entire length.
Yes, 44 dams. You have read it correctly. At least 44 dams in one sub basin of Brahmaputra River Basin. This is what was meant by MOU virus as Jairam Ramesh described it.
Siang River Basin The Siang river originates in the Chemayungdung mountain ranges which nearly sixty miles south-east of Mansarovar lake in the Mount Kailash range in Southern Tibet at an elevation of 5300 m. A spring called Tamchok Khambab spills from the glaciers which later gather breath and volume to become the Tsangpo, the highest river in world. Tsangpo river flows 1625 km in Tibet parallel to the main range of Himalayas before entering India through Arunachal Pradesh.
Before entering India, the river passes Pi (Pe) in Tibet and suddenly turns to the north and northeast and cuts a course through a succession of great narrow gorges between the mountain Gyala Peri and Namjabarwa (Namcha Barwa) in a series of rapids and cascades. The river then turns south and southwest and flows through a deep gorge across the eastern extremity of the Himalayas with canyon walls that extends upward for 16,500 feet (5,000 meters) and more on each side.
The river enters Arunachal Pradesh near Gelling from where it is known as Siang. The total length of Siang River is 294 km till its point of confluence with Dibang and Lohit River. After entering India the river traverses approximately 197.0 km to join the Siyom river. From there the length of the river till Assam border is 86.3 km. Flowing further 10.6 km in Assam the river joins the confluence of Lohit and Dibang. From this point forward it flows as Brahmaputra river in Assam and traverses a distance of about 195 km up to the confluence of Subansiri river on its right bank. Further downstream it is joined by Kameng at Jamugurihat near Tezpur, after another 123 km. From here it travels for another 134 km up to Guwahati.
River Siang Photo from: Global Descents
The elevation of Siang river catchment area ranges from 90 m to around 5800 m. The total catchment area of Siang river from its origin to its confluence with Lohit and Dibang rivers is 251,521 sq km. Out of this 236555.7 sq km area lies in Tibet. The total catchment area of Siang river in India upto its confluence with Lohit and Dibang rivers is 14965.30 sq km.
A question arises here, what will be the condition of the 294 km long Siang river if the proposed 44 dams are being built on the river. The Siang river basin study has the answer for this which is actually alarming “Only 85.5 km (29%) of free flowing water regime of Siang river will be left out of its total course in India i.e. 294 km of lotic ecosystem will be converted into 208.5 km of lentic ecosystem altering the entire Siang river aquatic system which will adversely impact the aquatic biodiversity and seriously affecting fish populations and their migration behaviour.”(page 11.23)
Three dams on the main Siang will convert the free flowing river into a three-stepped reservoir, without ANY flowing length of the river! These dams alone will affect more than 18,000 hectares of forests! If all the dams are built, water level fluctuations in the downstream D’Ering Sanctuary will be more than 23 feet every single day in the winter and other non monsoon seasons!
82.26% of the Siang basin is under forest cover (more than 15,000 sq kms), it is rich in orchids (more than 100 species!), holds 16 species of rhododendrons, 14 species of Bamboos and 14 species of canes and overall 27 RET species and 46 endemic plant species. 25 (18%) mammalian species found are Schedule I of WPA (Wildlife Protection Act), while 26 are under Schedule II! There are 447 species of birds, of which 31 are Schedule I species. The single basin consists of 5 Important Bird Areas !!(IBAs)
Formation of River Siyom, which will have multiple dams in a cascade Photo from: Team BHP
This information has been collated by the CIA (Cumulative Impact Assessment)/ CCS (Carrying Capacity Study) of the Siang Basin, which was an attempt to look at the scale and cumulative impacts of projects in Siang holistically.
Has the CIA commissioned by Central water Commission and done by RS Envirolink Technologies done an objective, scientific, independent assessment?
SANDRP sent comments about this 2-volume study with over 1500 pages to the Expert Appraisal Committee, Ministry of Environment and Forests which will be considering this basin study in its upcoming meeting on Feb 20-21, 2014. Submission below highlights that the study has very serious short comings and bias. The recommendation of dropping 15 (mostly small ones, all below 90 MW installed capacity) HEPs and re-configuring some others is welcome, but far from sufficient. The study itself is disappointing:
Projects planned in the Siang Basin Phot from CIA/ CCS of Siang Basin
Time Line of Siang Basin Study
Feb 2010
Ministry of Water Resources constituted an Inter-Ministerial Group on the directions of Prime Minister’s Office with a view to evolve a suitable framework to guide and accelerate the development of hydropower in the North East and also to assess the impact of the massive hydropower development in Arunachal Pradesh on downstream areas in Assam
Nov 2010
EAC discussed TOR for the Siang Basin CIA
Dec 23, 2010
MoEF issues TORs for the Siang Basin CIA
April 2011
EAC discusses sampling locations for the CIA on request of CWC
Dec 2011
Work of CIA for Siang awarded to RSET Pvt Ltd
May 2012
RSET says draft interim report discussed by TAC, but there is no meeting of TAC in May 2012, minutes of March and July TAC meetings (the ones before and after May 2012) on CWC website also do not mention any such discussion.
Nov 2012
EAC discusses Draft Interim report
Aug 2013
Draft Final report submitted to CWC
Sept 2013
RSET says Draft final report discussed by TAC, but the minutes of the Sept 2013 meeting of the TAC obtained under RTI donot contain any reference to the Siang basin study
DEC 2013
Draft Final Report submitted to MoEF
Feb 17, 2014
Critique of the Draft Final report submitted by SANDRP to EAC
Feb 20, 2014
MoEF’s EAC to discuss the Draft Final report
To,
Chairperson and Members,
Expert appraisal Committee
Ministry of Environment and Forests
Delhi
Subject: Serious inadequacies of Cumulative Impact Assessment (CIA) and Carrying Capacity Study (CCS) of Siang Sub-basin including Downstream Impacts
Respected Chairperson and Members,
We see from the agenda uploaded on the MoEF Website that Final Report of the Siang CIA/CCS Study commissioned by CWC and conducted by RS Envirolink Technologies Pvt Ltd will be discussed in the 72nd EAC Meeting to be held on 20-21 February 2014.
SANDRP has been analysing basin studies in the Western Himalayas and Brahmaputra Basin for some time now. Looking at the aggressive cascade hydropower development and its far reaching cumulative impacts, CIA/ CCS and Basin Studies should form the backbone of informed decision making by MoEF. Unfortunately, most studies being considered by the EAC are of a sub-standard quality and are shying away from addressing the cumulative impacts [1]. EAC itself is delinking appraisal of individual projects from basin studies, rendering the crucial process meaningless which is in violation of EIA notification of Sept 2006, wherein Form 1 Section 9 actually asks for cumulative impact assessment. Some of the recent orders of National Green Tribunal also make it CIA mandatory, thus making such delinking legally untenable.
Looking at the scale of ecological and social impacts of these projects and the significance of MoEF’s and EAC’s role, we urge the EAC to consider CIA/ CCS/ Basin Studies more seriously.
Main issues with Siang Basin Study include: (These are elaborated with reasons below)
1.No mention of social and cultural impacts!
2.Downstream impacts on Assam not studied in detail
3.Cumulative Disaster vulnerability, impact of projects on such vulnerabilities, Dam Safety Assessment, risk assessment not done
4.“Cumulative” Impacts not assessed on several aspects
5.Non-compliance with critical recommendations by the EAC:
a.Study is not compatible with similar studies done worldwide
b.No suggestions about ramping to reduce downstream impacts
c.No recommendation on free flowing length between two projects
d.No mention of cumulative impact on sediment regime
e.No mention of impact of road construction
f.BBM for eflows not used, despite agreeing to use it before EAC
g.Impact of Sand mining, boulder mining not conducted
h.Impact of specific projects not clearly studied
6.Eflows, one of the most significant issues, handled erroneously: NO ACTUAL ASSESSMENT OF E-FLOWS REQUIREMENTS AS REQUIRED BY TORs
7.No mention of Climate Change, reservoir emissions vis-à-vis cumulative impacts of such massive scale, how the projects would affect the adaptation capacity of the communities and region in the context of climate change
8.No stand taken on three mega projects on Siang Main Stem and other big hydro projects
9. No conclusion about how much length of the river is to be compromised
10. Number of sampling locations: TOR not followed
11. Source of information not given
12. Inconsistency, contradictions in listing of flora-fauna
13.Unsubstantiated advocacy: going beyond the TOR & mandate
14. Other inadequacies of CIA
15.Study should not be finalised without credible Public consultation across the basin.
Division of the Siang Basin into sub basins Phot from : CIA/ CCS Report of the Siang Basin
DETAILED CRITIQUE
1. No mention of social and cultural impacts! In the entire basin study, there is no mention of social and cultural impacts by these 44 projects which will together submerge more than 21,000 hectares of forests and affect the entire Siang Basin adversely. Needless to say, local communities depend heavily on the basin resources like fish, medicinal and food plants, timber varieties for their livelihoods. For example, more than 2000 hectares of multi-cropped, irrigated rice fields will be submerged by Lower Siang Project alone.
Adi Community that will be affected by the dams on Siang Photo with thanks from : Kaushik Shil
The CIA/CCS study needs to be re-conducted, in which social and cultural cumulative impacts are assessed with participation of local communities and downstream communities from Arunachal Pradesh and Assam. It may be remembered that Public Hearing of Lower Siang (in the latest instance, slated to be held on 31st January 2014) had to be cancelled due to a number of procedural issues, and also opposition from local residents [2]. It is incomprehensible how the CIA Study has no assessment of impacts on communities!
2. Downstream impacts on Assam not studied in detail The study assesses impacts specifically on Dibrugarh, Bokaghat (Kaziranga) and Guwahati. However, there are several villages, settlements, tea estates, agriculture, forests etc., on the Right Bank of Siang in Assam after Pasighat. This includes a major part of Dhemaji District of Assam. Impact on this region needs to be assessed. There has been opposition to Siang Dams from places like Jonai from Dhemaji, which have been ignored.[3]
Meeting protesting against Public Hearing of 2700 MW Lower Siang HEP Photo: Echo of Arunachal
According to the model used, the chainage for assessing impacts at D’Ering Sanctuary is between 20-33 kms from Lower Siang Dam. The next chainage is at 102 kms at Dibrugarh. Impacts on the stretch between D’Ering and Dibrugarh, for nearly 70 kilometres are simply not assessed! What can be reason behind this?
Level fluctuations at D’Ering Sanctuary, with Lower Siang, Middle Siyom and Upper Siang Projects is to the tune of 7.2 meters (23.66 feet!!) in lean season. This highlights the need to study impacts on the intermediate zone in Assam between Dering Sanctuary and Dibrugarh. The Study should not be accepted without these assessments.
3.Cumulative Disaster vulnerability, impact of projects on such vulnerabilities, Dam Safety Assessment, risk assessment not done
Upper Siang Stage I, Stage II and Lower Siang are huge projects with direct impact on downstream state. Even as issues of dam safety and risk assessment have gained high significance in Assam as can be seen in Lower Subansiri protests, the basin study/CIA does not include a word on dam safety, cumulative risk assessment, risk of landslips and landslides, seismic zones of projects, past earthquakes in the region, possible mitigation measures, disaster management, etc. There is no assessment of baseline situation about disaster vulnerability of the region and how the projects will change that. By its nature, a CIA/CCS/ basin study is best placed to assess these impacts.
Lanslides are a common feature of this region. Pic shows Yinkiong in Siang II Sub basin where several projects are planned. Photo: Team BHP
These points have been raised by KMSS, Assam and others. The Uttarakhand disaster of June 2013 underlines this and even the Supreme Court of India has asked for an assessment of how hydropower projects contributed to disaster in Uttarakhand. Looking at Uttarakhand Disaster as well as protests from downstream Assam where dam safety is a major issue, dam safety needs to be addressed in the CIA/ CCS. In the absence of all this, projects will not be allowed by communities, as can be seen with Lower Subansiri and Lower Siang.
4.Cumulative impacts not assessed on several aspects The study has a sketchy section (Chapter 11) on Cumulative impact assessment.
The minutes of 62nd EAC meeting noted, “The main objective of the study is to bring out the impact of dams being planned on the main Siang River and its seven tributaries on terrestrial and aquatic ecology, plant and animal biodiversity, including wild life, hydrology of the basin, etc.” (Emphasis is as in original.) However, the study has not placed emphasis on assessing these impacts.
Yar Gyap Chu: a River and basin which holds high religious significance for the Buddhists Photo: Kaushik Shil
Moreover, the study does not attempt to assess cumulative impacts of all the projects due to:
Blasting and Tunnelling: This is not mentioned even once in the entire study! When the disastrous impacts of blasting, tunnelling and related activities are fresh in our minds w.r.t Uttrakhand and Himachal Disasters, it is incomprehensible to see that this section is not mentioned at all in the basin study!
Community resources: No mention on loss of agricultural lands, homesteads, displacement, loss of forest rights, etc.
Infrastructure development: No mention of the impact of workers colonies, buildings on the society, landscape and cultural aspects, etc.
Greenhouse gas Emissions: Considering submergence of more than 20,000 hectares of dense to very dense forests and building of a large number of reservoirs in tropical climate, cumulative impacts on green house gas emissions should have been assessed.
Biodiversity, RET Species, Deforestation: While the report deals with these issues very sketchily, there is no statement as to what will be the cumulative impact of 44 projects on the above issues.
5.Non-compliance with critical recommendations by the EAC Interim basin study was discussed in the 62nd EAC meeting in November 2012. The EAC had given some important recommendations at that stage to be included in the study. However, most of the recommendations have not been complied with, these include:
Study is not compatible with similar studies done worldwide: EAC had specifically recommended compatibility with global studies. However, Siang CIA is not compatible with any global Basin and Cumulative impact Assessment Study. A Cumulative Impact Assessment is a multi-stake – holder process that assesses the cumulative and indirect impacts as well as impact interactions of the proposed dam or set of dams, as well as existing and planned projects from other sectors, on ecosystems, communities, and identified Valuable Ecosystem Components (VECs) within a specific spatial and temporal boundary. [4]
No suggestions about ramping to reduce downstream impact: EAC had specifically asked for ramping study with reference to downstream impacts. However, ramping studies are not done at all, although downstream impacts of the projects in isolation as well as together are huge.
No recommendation on free flowing length between two projects Although Upper Siang I, Upper Siang II and Lower Siang have no free flowing stretch between each other, the study refrains doing any assessments or from making any recommendations in this regard, contrary to EAC’s recommendation.
No mention of cumulative impact on sediment regime 44 projects with several mega reservoirs will have a profound impact on the sediment regime of the rivers as well as downstream impacts thereof. EAC had specifically asked to include sediment balance and impact, which is not discussed in the report.
The minutes of 62nd meeting of EAC says: “The Consultants were also asked to study and recommend on silt management considering “no dam” and “with dam” scenario as silt substantially impact the ecology and cause sedimentation particularly when its velocity is affected d/s due to construction of dam.” No such study has been conducted. In fact globally, sediment balance on cascade projects is a crucial element of study, which is completely left out in the present study.
No mention of impact of road construction Roads and related activities like deforestation, slope destabilisation, blasting, mining, muck dumping, all the cumulative impacts of peaking operation (needs to be done comprehensively, including the limitations that such operation of upstream projects will impose on downstream projects), etc have a critical impact on fragile geology. Role of roads for hydel projects was significant in Uttarakhand Tragedy in June 2013. EAC had specifically asked for “Impacts due to construction of approach roads”. This point is not touched upon in the report.
BBM for eflows not used, despite agreeing to use it in front of EAC Although the consultant agreed in the 62nd meeting that BBM will be used to assess eflows regime,[5] at the insistence of the EAC, in reality BBM has not been used in the study. The reasons given [6] that BBM is a “prescriptive approach”, “it takes too much time” and “only stakeholder in the basin is river and fish” is wrong, shocking and unacceptable.
The study forgets about the people, biodiversity and other stakeholders. Requirements of BBM were known at the time consultant agreed to use this methodology before the EAC. Is fluvial geomorphology, cultural practices, hydrological requirements and sediment balance not important blocks of BBM study?
Impact of Sand mining, boulder mining not conducted EAC had specifically asked for this study. This is critical as mining of sand and boulders from river bed has severe impact on riverine ecology, bed stability, erosion, flow velocity, etc. However, the study has not even mentioned this issue.
Yargyap Chu or the Medicinal RIver Photo: Team BHP
Cumulative Impacts of projects on biodiversity in sub-basins not clearly studied While the study has done impressive job in inventorysing ecological attributes of 11 sub basins, it has fallen woefully short in clearly communicating the individual and cumulative impacts of projects on Valued Ecosystem Components (VECs). This reduces practical application of the report. EAC had brought this up during the 62nd meeting.
Length of rivers to be assessed for downstream studies As per the minutes of the 43rd meeting of EAC held in Nov 2010 the report was to recommend: “What may be criteria for downstream impact study in terms of length of the river downstream to the tail water discharge point and what may be the parameters of such a study”.
The same EAC meeting recommended: “If the states do not change their policy of allotting elevation-wise river reaches for hydropower development, what criteria the EAC may adopt in restricting the river reach for hydropower development. Alternatively, what should be the clear river length of uninterrupted flow between the reservoir tip at FRL of a downstream project and the tail water discharge point of the immediate upstream project.”
“For peaking stations, what extent of diurnal flow variation may be considered safe for the aquatic life. There are examples where the release is drastically reduced during the long time for reservoir filling and huge discharge flows through the river during the few hours of peak power generation. This is detrimental to the aquatic environment of the downstream stretch of the river.”
“For muck disposal, what may be minimum distance that must be maintained between the outer boundary of the muck disposal sites and the river bank.”
6. Eflows, one of the most significant issues handlederroneously: NO ASSESSMENT OF E-FLOWS REQUIREMENTS The CIA has not done assessment of e-flows requirements at various locations keeping in mind the upstream projects. The very crude assumption it has made is by dividing the entire basin in Mahseer and Trout Zone and assuming certain water depths for these fish in lean, monsoon and non-lean, non-monsoon months. Several fisheries scientists do not support this classification or accept these two species alone as representing the ecosystem. The study assumes 50 cms water depth for Mahseer and 40 cms depth for Trout in lean season.[7] Then flows for maintaining that particular depth are calculated and recommended. Added criteria is that depth should not be less that 50% pre-project river depth.
Luxuriant Biodiversity of the Siang basin Photo: Team BHP
Here it is worth quoting the minutes of 62nd meeting of EAC:
“The EAC asked the Consultants to take comprehensive view of the environmental flow assessment and make final recommendations for each stretch. Committee asked to study international literature available on the subject and use the best suitable methodology for this exercise suiting to Indian conditions. The Consultants said that most appropriate method such as Building Block Methodology would be used by them. Detailed habitat simulation modelling for the entire year needs to be considered so that flow release requirement can be established not only for lean season but also for monsoon season and other months… The Consultants while submitted that public hearing as such is not a part of the study as per ToR, informed that BBM entails expert and stakeholder‟s consultations and would be followed.”
This has clearly not been done.
This approach is incorrect on various counts:
The habitat requirements of Mahseer and Snow Trout are higher than the assumed 0.5 m and 0.4 m. This has been confirmed by several fisheries scientists. The WII study on Upper Ganga Projects recommends a minimum of water depth of 1 meter for adult Mahseer (Tor species) (Table 7.6, Page 148) and at least more than 50 cms for Trouts (Schizothorax sps) (Table 7.8, Page 150). Incidentally these tables from WII Cumulative Impact Assessment have been used in the report without stating the source or credit. SANDRP has interacted with several fisheries experts who claim that 0.5 meters is a completely inadequate depth for adult Mahseer.
This faulty assumption has led to low eflows recommendations of 15% of average flows in non-lean non-monsoon months for Heo and Tato I Projects, this is lower even that EACs norms. This assessment and recommendations are clearly unacceptable.
The criteria of 50% water depth wrt pre-project depth is arbitrary and without any scientific justification. For Himalayan rivers with a stable hydrograph like Siang, 50% depth reduction is very high. As can be seen from Eflows chapter, after 50% depth reduction, most river stretches have less than 100 cms depth, which is just about the minimum depth required for an adult Mahseer or a spawning snow trout. However, Mahseer and trouts are abundant in these rivers. This just indicates the problems behind 50% water depth criteria. This should not be accepted.
The entire eflows discourse is not based on assessment of environment flows for various objectives and ignores most critical requirements.
Division of the Basin into Trout and Mahseer Zones Photo: From CIA/ CCS Report of Siang Basin
7. No mention of Climate change In the entire study, there is no mention of climate change, how changing climate would affect the rivers and projects and how project construction would add to climate change impacts and how they will reduce the adaptation capacity of the people and environment to cope with the changing climate. Deforestation to the scale of 21000 hectares of thick forests and complete loss of a biodiversity rich free flowing river has strong impacts in the context of climate change and these need to be assessed.
8. No stand taken on three mega projects on Siang Main Stem and other big hydro projects Three mega projects on Siang Main stem, namely the 6000 MW Upper Siang I, 3750 MW Upper Siang Stage II and 2700 MW Lower Siang will have a huge destructive impact on the entire ecology and society of the region. These three projects together will submerge 18,100 hectares of dense forest area and will convert entire river length between these projects: 208.5 kilometers, into unbroken sequence of reservoir-dam-reservoir-dam-reservoir-dam, with no flowing river between two consecutive projects. The study has not even attempted assessment of length of flowing river required between the projects and eflows allocation for this stretch.
L Section of the Siang River with 3 mega projects which do not leave any flowing river between them. Photo from: CIA/ CCS Report of the Siang Basin
Oppsition to Public Hearing of 2700 MW Lower Siang Project Photo: Echo of Arunachal
These projects in a cascade, destroying a complete flowing river are against the principle of sustainable development and even EAC’s minimalist norm of 1 km of flowing river between projects. A CIA/ CCS study should have raised this issue strongly as these projects are undoing most of the other recommendations. However, the study refuses to take an independent stand against these projects and fails its mandate of being an independent study.
Yamne Basin, claimed to host highest biodiversity in Siang is planned to have 4 projects back to back! Photo: Abor Country Travels
Similarly the study does not take stand on other big hydropower projects proposed in the basin. Most of the projects it has recommended to be dropped are relatively smaller projects, none are big ones. This shows bias of the consultants. The report is also not in consistent in its recommendations.
Positive suggestions: The study recommends dropping 15 projects and keeping some tributaries free from any hydel development. It also calls for including small hydel projects under the ambit of EIA. These suggestions are important and should be accepted. EAC should immediately ask MoEF to recommend changes in the EIA notifications to include all hydro projects above 1 MW.
The study has also asked for change in parameters of Tato II, Hirong, Naying and Siang Middle HEPs so that at least 1 km of river is left flowing between them. This is welcome and EAC should accordingly ask for changes in these projects. But the report has not done any study in this regard.
9. No conclusion about how much length of the river is to be compromised One of the TORs of the study include, as per the minutes of the 43rd meeting of EAC held in Nov 2010: “Considering the total length of the main river in the basin and the HEPs already existing and planned for future development, how many more HEPs may be allowed to come up. In other words, how much of the total length of the river that may be tunneled inclusive of the tunnelling requirement of all the projects that have been planned for development so that the integrity of the river is not grossly undermined.” (Emphasis added.) The report does not do an assessment on this. The B K Chaturvedi committee had recommended that not more than 50% of the river can be compromised. However, this report was to study this aspect, but has neither studied this, nor done analysis or reached any conclusion.
10. Number of sampling locations The minutes of 49th meeting of EAC held in April 2011 concluded that the number of sampling locations will be decided based on this criteria: 3 sites for project with over 1000 MW installed capacity, 2 sites for projects with 500-1000 MW installed capacity and one site for projects below 500 MW installed capacity. In addition 2-3 locations will be selected in the downstream areas.
If we go by this criteria, and considering 44 planned projects listed in the CIA, there should have been 15 locations for 5 projects with capacity 1000 MW or above, 4 for two projects with 500-1000 MW capacity and 37 for projects below 500 MW capacity, in addition to the locations in downstream areas. The CIA has not followed these directions from EAC, else sampling locations would have been about 60 and not 49 as included in the report.
11. Source of information not given Several annexures in Vol II (this too should have been put up on EAC website, but has not been, we got it from other sources), including Annex I says that it is prepared from “PREPARED FROM SECONDARY DATA & FIELD SURVEYS”, but which information has been obtained from field surveys and which information is obtained from which secondary source is not given. In absence of this it is difficult to verify the claims.
12. Inconsistency, contradictions in listing of flora-fauna
– In volume II, Annex I titled “LIST OF PLANT SPECIES REPORTED FROM SIANG BASIN”, which is supposed to include data from secondary sources and field surveys lists 1249 angiosperms and 11 gymnosperms. However, the pteridophytes listed in Annex II titled “LIST OF PLANT SPECIES RECORDED FROM DIFFERENT SUB BASINS OF SIANG DURING FIELD SAMPLING” do not find mention in Annex I or Annex III a/b/c.
– Out of 11 Gymnosperms listed in Annex I, only two figure in Annex II, rest do not get listed in any of the sub basins.
– The species Dicliptera bupleuroides and Phlogacanthus thyrsiflorus listed in Annex 1 Angiosperms do not get listed in any of the sub basins.
– Section 4.1.4 says Paphiopedilum fairrieanum is an endangered and Cymbidium eburneum is an endemic and vulnerable orchid species in Siang basin, however, these species do not get listed in any sub-basins in Annexure II or in any season in Annexure III. Same is the case with endemic orchid species of Siang basin, namely Calanthe densiflora, Dendrobium cathcartii, D hookerianum, Galeola falconeri, Liparis plantaginea and Paphiopedilum fairrieanum.
– Similarly among the Rhododendron species, threatened species like Rhododendron boothii, threatened species like Rhododendron falconeri, newly discovered and critically endangered species like Rhododendron mechukae (even though it was found in Yargyap Chhu sub basin), Rare species like Rhododendron arizelum, Rhododendron dalhousieaevar. rhabdotum,Rhododendron kenderickii, and R edgeworthii are not found in Annex II or III.
Rhododendron Species of Siang Basin Photo: Abor Country Travels
– Endemic cane species Calamus leptospadix also do not figure in Annex II or III.
– The CIA says, “The Siang basin as discussed above is also very rich in floristic resources and there are still number of areas in the basin which are either under-explored or yet to be explored”, however, a CIA is supposed to make recommendation how to ensure that such areas are explored before any more projects are taken up, but this report makes no recommendation in this regard.
– The CIA says that 17 Near Threatened (regional level) medicinal plants, 46 endemic species and additional 55 endemic species are reported in Siang basin, but CIA neither gives list of them, nor locations, how these will be affected by hydropower projects or recommendations to conserve them.
– The scope of study given in Annex 1, Vol. I says: “Preparation of comprehensive checklist of flora (Angiosperms, Gymnosperms, Lichens, Pteridophytes, Bryophytes, Fungi, Algae etc.) with Botanical and local name.” However, we do not find the local names listed.
The situation with respect to fauna species is no different, with similar inconsistencies, lack of specific sub-basin wise situations and recommendations to conserve them. This is true in case of mammals, birds, butterflies, amphibians, reptiles, inspects as also aquatic biodiversity. While the report makes some impressive general statements, but is found to be lacking in specifics mentioned above.
This sample list of inconsistencies and gaps shows that there are serious problems in these lists and the consultant should be asked to remove all these inadequacies. There is also need to get these lists peer reviewed by credible independent experts like those from WII.
13. Unsubstantiated advocacy: going beyond the TOR & mandate The CIA says in last para in section 12.3 titled “Downstream Impacts”, “Keeping the substantial storage requirement in Siang, storage projects in Siang needs to be re-configured, which may lead to merging of Siang Upper Stage I and II into single project to create storage.” There are several other such sentences in this section and elsewhere. This is uncritical acceptance of CWC assertions and is an advocacy for more storage projects in the name of flood moderation. This is clearly uncalled for in a CIA report and such uncritical acceptance of CWC assertions is also not what is expected from a CIA. In any case, this is also beyond the mandate of the CIA.
14. Other inadequacies of CIA
– The CIA does not contain the TOR, the scope of the study given Annex 1 of Vol I is not the TOR.
– 49th EAC meeting had asked for inclusion of Assam Experts in the study, but the study does not mention this.
– The 43rd EAC meeting held in Nov 2010 had asked for inclusion of assessment of the impacts of the projects on wetlands, floodplains, river morphology, sediment transport/ erosion/ deposits, impact on human activities and livelihoods and recommend necessary measures in these regard. The report mentions all these aspects, but fails to assess these impacts and make necessary recommendations.
– The Preface of the CIA claims that the TAC reviewed the draft interim report in May 2012 and draft final report in Sept 2013. We have checked the minutes of the TAC meetings and find that in May 2012 there was no TAC meeting. The 114th TAC meeting happened in March 2012 and 115th TAC meeting happened in July 2012, neither of the minutes include any mention of Siang basin study.
– The Sept 2013 meeting also did not include this report in its agenda. The report seems to be making false claims in this regard, they should be asked to provide minutes of the TAC meeting where this was discussed and what were the outcomes.
15. Study should not be finalised without credible Public consultation across the basin A comprehensive Siang Basin Study will give a cumulative picture of impacts on basin and on basin residents, including downstream population in Assam. The study is supposed to include important findings, which are separate from individual EIA reports. Even MoEF’s Strategic 12th Five Year Plan notes:
Paddy feilds in Siang Basin. Agriculture finds no place in the CIA Photo: Kaushik Shil
“Of late, the limitations of project-level EIA are being realized internationally. Project EIAs react to development proposals rather than anticipate them, so they cannot steer development towards environmentally “robust” areas or away from environmentally sensitive sites. Project EIAs do not adequately consider the cumulative impacts caused by several projects or even by one project’s subcomponents or ancillary developments. The new trend is to address environmental issues earlier in planning and policy making processes. This could be done through cumulative impact assessment.”
However, such a study cannot be complete without consultations held across the basin in a credible way with full information to the communities in the language and manner they can understand. The study should not be accepted without a credible process of Public hearing [8].
CONCLUSION We would like to urge the EAC NOT TO CONSIDER INDIVIDUAL PROJECTS UNLESS THE CIA/CCS Study is APPROVED through a participatory process. In Siang basin, the EAC has already granted EC to 2 projects, Scoping clearance to 16 projects (of which PH has been held for 8 projects) and nine projects will not need EC as they are below 25 MW. This renders the whole exercise of CIA/CCS meaningless!
We urge the EAC to consider all projects from Siang Basin only after CIA-CCS is finalised and keep the scoping and environmental clearances of projects in abeyance till then.
A good report on the Siang Basin CIA: Damn that river Author: Karthik TeegalapalliPosted on: 13 Oct, 2014: http://www.downtoearth.org.in/content/damn-river
SANDRP 