Dams

Celebrating our Rivers on the World Rivers Day, 2016!

Above: Parshuram Kund on River Lohit, Arunachal Pradesh

Since 2005, last Sunday of every September is celebrated as the World Rivers Day. The tradition started in 1980s in British Columbia when some river activists came together for their rivers. Its only grown since then.

All through the year we hear about water conflicts, river pollution, degrading freshwater biodiversity, damming of living rivers, mismanagment, concretisation and encroachment on Indian Rivers. As I write this, Cauvery Water Conflict and simmering, serious discontent over the Indus Water Treaty governing 6 rivers between India and Pakistan is mounting. A simple google search on Indian Rivers throws up images of filth, pollution, droughts and floods. Lest we forget, thats not the whole picture. We are still the custodians of an amazing legacy. India still holds some of the most beautiful, healthy and life giving rivers in the world. There are people and communities nurturing their rivers and protecting them. All is not lost and this is a battle worth fighting, full of positive energy. Continue reading “Celebrating our Rivers on the World Rivers Day, 2016!”

Arunachal Pradesh · Cumulative Impact Assessment · Dams · Himachal Pradesh · Ministry of Environment and Forests

Cumulative Impact Assessment documents not in public domain anymore? Letter to MoEF and CC

Even as the Ministry of Environment, Forests and Climate Change has been sanctioning cascades of hydropower projects on here-to free flowing rivers in the Himalaya and North East India, Cumulative Assessment of the Impacts of these projects became a crucial area of concern. Over 70 dams are planned one after other for the rivers of the Upper Ganga Basin, 44 dams across the Siang Basin in Arunachal Pradesh famed for its pristine forests and biodiversity, 12 dams across the Lohit Basin, 19 for Subansiri basin. These are bumper to bumper projects, one starting where the other ends. Continue reading “Cumulative Impact Assessment documents not in public domain anymore? Letter to MoEF and CC”

Dams · Hydropeaking · Hydropower

India’s Free Flowing Frontier Part I: Dibang at Nizamghat

What does it mean when landscapes, riverscapes, ways of life are altered forever? When a mighty, flowing river is plugged and made to stop, flow in tunnel and released as per our whims? For most of us, life and environment are so fundamentally modified that we would hardly question it. But as our worldview and our politics is set to dam some of the last free flowing rivers in the North East India into Hydro-Electricity Banks, what is at stake? Continue reading “India’s Free Flowing Frontier Part I: Dibang at Nizamghat”

Dams · Fish Sanctuaries

Celebrating India’s Riverine Fisheries on the World Fisheries Day

Above: Women fishing in small pools near (सादिया घाट) Sadiya Ghat on (लोहित) Lohit and Dibang Rivers. Women use several gear, baskets and nets to catch fish from the slush. The activity is accompanied by laughter, chatter and songs. Photo: Author

21st November is celebrated as World Fisheries Day. Since the past few years we have been trying to highlight the significance and richness of India’s riverine fisheries which support over 10 million people by providing livelihoods and nutritional security. Ironically, although India is the world’s biggest inland fish producer, our riverine fisheries are woefully neglected. We do not have a record of riverine fish catch and its trends, people dependent on riverine fishing, species of fish and their population trends, etc. Interventions like dams, water abstraction and pollution have severely affected riverine fisheries, which do not find a place in the dominant water management narrative. Continue reading “Celebrating India’s Riverine Fisheries on the World Fisheries Day”

Dams

International Day for Biological Diversity, 2015: Biodiversity Rich Rivers are a fundamental building block of Development

May 22 has been proclaimed as the International Day for Biological Diversity by the United Nations (https://www.cbd.int/idb/). The theme for this year’s celebration is Sustainable Development[1].

Beyond its ceremonial value, what is the status of biodiversity in India and what are the safeguards in place? Let us look at the issue from the prism of rivers. Rivers are an apt indicator as they connect terrestrial, riparian, aquatic, estuarine, even marine biodiversity as they flow and are a reflection of the issues faced by these ecosystems. Although it is difficult to believe, Indian Rivers are the richest repositories of biodiversity and can be classified as Endangered Species themselves[2]! We are the 8th richest country in the world and third in Asia when it comes to fish diversity: a megadiverity hotspot. Indian rivers hold about 50% of all aquatic water plants and are home to thousands of species of migratory and resident water birds, amphibians, reptiles, riparian plants, phyto and zoo plankton, etc.

So how are we treating our rivers?

Just three days ahead of the International Day for Biological Diversity, the Ministry of Environment, Forests and Climate Change (MoEF&CC) issued Environmental Clearance to 3000 MW Dibang[3] Hydropower Project on Dibang River, one of the important tributaries of Brahmaputra in Arunachal Pradesh. The project will submerge more than 4700 hectares or 11,624 acres of rich forests under its reservoir. The EIA of the project done by National Productivity Council (Guwahati) was so flawed that it included exotic fish species never found in the river in its list, while omitting Rare, endangered and threatened species. These forests harbor endangered species such as tiger, leopard, serow as well as the critically endangered takin, all of which are protected under Schedule I of the Wildlife (Protection) Act, 1972. The grasslands in the area are home to endangered Bengal Florican. Other species include the critically endangered white-rumped vulture, the slender-billed vulture and the white-winged wood duck. The project site lies in an area identified by the Bombay Natural History Society as a Ramsar site and an Important Bird Area. The habitat of six endangered plants (Aconitum ferox, Coelogyne mossiae, Dendrobium aurantiacum, Paphiopedilum fairieanum, Paphiopedilum venustum and Vanda coerulea) will be submerged by the reservoir. The project will also impact aquatic species; the dam will block the breeding migration of several endangered fish species.[4]

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

The Expert Appraisal Committee for River Valley and Hydropower Projects (EAC) which gives Environmental Clearance to dam projects in two stages has a flawless rack record of 100% project clearance[5]. Never in the past has this committee rejected a proposal, based on merits or for its irreversible environmental impacts. Nor has it recommended strict action against EIA agencies which churn out compromised, cut & paste EIA reports[6]. SANDRP has pointed out several instances where projects have been started without environmental clearance and at times even finished, but the EAC does not seem particularly bothered.

In its upcoming meeting on the 4th June, just a day ahead of World Environment Day, the EAC will discuss 3097 MW Etalin HEP by Jindal Power also in Dibang valley in Arunachal Pradesh, which is set to submerge 1165.6 hectares of forest. The EIA of this project has been remarkably poor in recording the rich biodiversity of the region. SANDRP has pointed this out to the EAC. For the region where species like Tiger are recorded, the EIA study mentions only 45 mammal species. This region is being marked for its importance even by the National Tiger Conservation Authority (NTCA).

The Siang Basin Study conducted by RS Envirolinks Pvt Limited to understand the impacts of over 44 Hydropower dams in Basin which the EAC cleared in 2014, involves submergence of more than 18,000 hectares of virgin forests also in Arunachal. The regions 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)[7]

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

The Subansiri Basin Study done by IRG System South Asia to study impact of over 19 dams in this basin, does not even mention the presence of Gangetic Dolphins in the river, which is India’s National aquatic animal and will be severely impacted by the dam. Subansiri is one of the only tributaries of Brahmaputra with a resident population of the endangered Gangetic Dolphin (Baruah et al, 2012, Grave Danger for the Ganges Dolphin (Platanista ganegtica) in the Subansiri River due to large Hydroelectric Project).

There is no consolidated estimation of the impact of all the dams in Arunachal on rare and endangered species or their migratory routes or the biodiverse habitats in the downstream including the Memorial D Erring Sanctuary, where Lower Siang HEP and all the projects in the upstream will lead to water level fluctuation of more than 22 feet in a single day[8]! Most of the aquatic as well as riparian species are sensitive to flow changes, but so far there has been no study to understand the impacts of water level fluctuation, peaking, damming, erosion and changes in silt pattern, etc., on any species, before clearing these projects. Similarly, the impacts of peaking of all these projects on Dibru Saikhowa National Park in Assam, which is a habitat of the critically endangered Bengal Florian, Gangetic Dolphin and a number of RET species is again left to imagination.

Dibru Saikhowa National Park  Photo: Kolkata Birds
Dibru Saikhowa National Park Photo: Kolkata Birds

In case of 780 MW Nyamjang Chhu Hydropower project in Tawang basin in Arunachal Pradesh, the EIA did not even mention that the dam site itself was at the breeding and wintering grounds of Black Necked Cranes, which are not only rare, but worshipped by local Buddhist Monpa Communities. No questions were asked either by the EAC or the MoEF about this omission. Environmental Clearance was granted to this project without considering these aspects. It is only now that Tawang Basin Study, of which Nyamjangchhu is an important tributary, is mentioning this issue strongly[9]. Will the MoEF and CC act on it or will the recommendation be stifled?

In case of Uttarakhand, a state with an unprecedented flood of hydropower projects and associated tunneling, blasting and disasters, Wildlife Institute of India had clearly recommended way back in 2012 dropping 24 HEPs in Alaknanda-Bhagirathi basin being planned and constructed, for their irreversible impacts on land and aquatic biodiversity and protected areas. This recommendation was also upheld in 2014 by the Committee (headed by Dr. Ravi Chopra) appointed under Supreme Court orders following the Uttarakhand Disaster in June 2013. The MoEF did not act on this report,  and even presented contradictory affidavits on this report to the Hon. Supreme Court and the PMO itself has pressurized that 24 projects cannot be dropped. Even the IIT Consortium, working on Ganga River Basin Management Plan gave an ambiguous report to push these projects[10]! These projects are affecting even protected areas like Valley of Flowers, Nandadevi Biosphere Reserve, etc. Same is the case with Himachal Pradesh and Sikkim.

Why are biodiversity issues so chronically neglected in our river governance?

It is darkly ironical to note that erstwhile Environment Minister Jayanti Natarajan pushed Wildlife Clearance for Lower Demwe Dam[11] in Arunachal even when its impacts on Dibru Saikhowa National Park were not completely studied, stating that such studies should be carried out “Concurrently” with dam construction! The present regime has gone a step further. The Environments Clearance letter of Dibang issued four days back (19th May 2015), which did not pay heed to critical issue raised by several groups, has stated that a study on downstream impact and ecosystem has to be undertaken “5 years after commissioning of the project”. Needless to say, no comprehensive downstream impact assessment for Dibang has been carried out before issuing this EC letter.

There is a member from the National Biodiversity Authority, formed under the National Biodiversity Act 2002 at all times in the EAC on River Valley Projects. Till now, we have not seen a single project being rejected because of its impacts on biodiversity. In fact, biodiversity issues are not even discussed in the EAC minutes. As per the National Biodiversity Act 2002 (Section 4), the National Biodiversity Authority or the Central government is empowered to conduct biodiversity impact assessment and public hearing for projects which endanger biodiversity, but it has never done that in the past! In effect, there has been no Biodiversity Impact Assessment of any dam projects till date.

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

The National Board for Wildlife, through its Standing Committee recommends Wildlife Clearance to projects within Protected Areas, or within 10 kms radius of Protected Areas. The constitution of Wildlife Board was by the new government has made the Board ineffectual. The New National Board for Wildlife constituted by the government included only a fraction of members against the clear provision of this Law. It has no NGO representation, only 2 experts in place of 10 and incomplete state representation. Despite huge opposition to this blatantly illegal constitution, the NBWL conducted its first meeting and cleared almost all projects before it, including Teesta IV Hydropower project in Sikkim. Shockingly, the members from the earlier NBWL had actually visited the region and had prepared an extensive report on violations by Teesta IV [12]as well as other HEPs in Sikkim which encroached in various protected areas of the State. But the new NBWL did not even mention this report while clearing the project! In tandem, the ministry severely reduced Eco-sensitive zoning around Protected Areas in Sikkim, leaving it to mere 25 meters in most cases![13] Incidentally, Sikkim is the most species-rich state in the country, which is facing the maximum impact of hydropower dams by private and government dam lobby.

The NBWL is still in project clearing spree, having cleared Shirapur Lift Irrigation Project in its latest 33rd meeting in March 2015. The Shirapur project cuts right through the habitat of critically endangered Great Indian Bustard (it will take 93 hectares of the Great Indian Bustard Sanctuary itself), despite the fact that the scheme had violated Wildlife Protection Act 1986, is half-complete already and is remarkably unviable![14]

In the 33rd Meeting, the NBWL also sanctioned one more water abstraction project inside the National Chambal Sanctuary, a 26 MLD Chambal Bundi Water Supply project despite the fact that Wildlife Institute of India had issued a strict warning against any further abstraction of water from the sanctuary, looking at its impact of critically endangered Ghariyal.

The Forest Advisory Committee, instituted under the Forest Conservation Act (1974) does not consider biodiversity issues while sanctioning forest diversion for projects. It has already issued a Stage I Forest clearance to the controversial Dibang Hydropower Project, bowing down to the pressures from Power Ministry and higher offices after rejecting it several times.

Similar is the case with Western Ghats where the Ministry shockingly rejected Western Ghats Expert Ecology Report by Prof. Madhav Gadgil. This was preceded by efforts of hiding the report as long as possible. In the meantime, the EAC considered and recommended 220 MW Gundia HEP in Western Ghats of Karnataka, despite a poor EIA by Karnataka Power Corporation Limited. The MoEF&CC has also stifled the Kasturirangan Committee report which was a severely diluted and flawed as compared to Gadgil Committee Report. In effect, Western Ghats does not have any protection from the Ministry at this time.

These are governance issues at a scale which can be hardly monitored by any single group. Actual issues related to compliance, implementation, people’s participation are independent of these issues and just as stark. But it is unfortunate to see that environmental governance of rivers, at this moment does not place any value on the biodiversity supported by rivers. One exception is the report on Environmental Flows recently brought out by the Ministry of Water Resources which at least attempts to give some importance to ecological integrity of rivers.[15] This report needs to be implemented urgently.

In stead the government is pushing ill conceived project like the Ken Betwa River Link project that will not only submerge 4600 ha of Panna tiger Reserve, destroy the Ken Ghariyal Sanctuary in the downstream and thus also affected habitat of some rare and endangered fish species, destroy the habitat of rare and endangered vulture species, all for projects that have almost no justification.

In India, as in the world, biodiversity is closely linked with human well-being, livelihoods, cultural values and even mitigation of Climate Change. Riverine fish like Hilsa (Tenuolsa ilisha) are not only important for their biodiversity values, but are an important source of protein and livelihoods for millions of fishermen, who are today impacted by dams. Mahseer is not only an endangered fish as per the Wildlife Protection Act, it is also worshipped as a reincarnation of Vishnu in riverine fish sanctuaries. Black Necked Cranes are not only a rare specie, but believed to be a reincarnation of the 6th Dalai Lama by Monpa tribes, Khangchengdzonga National Park is not only a Protected Area as per the law, it is also a sacred mountain for the Sikkimese, Free flowing rivers, mangrove forests, riparian zones are not only an abstract value, but a robust mitigation measure against climate change. It’s not for nothing that Biodiversity is referred to as a “Fundamental building block for Sustainable Development”.[16]

But in the race for short sighted projects in terms of irrigation dams, Hydropower projects, water diversion schemes, Interlinking schemes, embankments, riverfront development and even ill conceived “River Cleaning” drives, biodiversity values and all those who depend on it are suffering. The statement brought out by India’s Environment Minister Prakash Javdekar on this day[17]says the same old things and provides no new direction. Perhaps the new direction lies with the people themselves.

– Parineeta Dandekar (parineeta.dandekar@gmail.com)

END NOTES:

[1] https://www.cbd.int/idb/

[2] https://sandrp.in/rivers/Endangered_Riverine_Biodiversity_India_Nov2012.pdf

[3] https://sandrp.wordpress.com/2014/10/06/manipulating-environment-forest-clearances-for-dibang-project-deja-vu-lshp-history-repeated-will-it-be-tragedy-or-comedy/

[4] https://sandrp.wordpress.com/2014/11/13/submerged-what-to-expect-if-the-dibang-river-is-dammed/

[5] https://sandrp.in/env_governance/EAC_meetings_Decisions_All_India_Apr_2007_to_Dec_2012.pdf

[6] https://sandrp.wordpress.com/2014/03/12/tragedy-of-errors-environmental-governance-and-the-sonthi-lift-irrigation-scheme/, https://sandrp.wordpress.com/2013/11/15/mohanpura-dam-in-madhya-pradesh/,

[7] https://sandrp.wordpress.com/2014/02/18/cumulative-impact-assessment-study-of-siang-basin-in-arunachal-needs-urgent-improvement/

[8] https://sandrp.wordpress.com/2014/02/18/cumulative-impact-assessment-study-of-siang-basin-in-arunachal-needs-urgent-improvement/

[9] https://sandrp.wordpress.com/2015/04/10/cumulative-impact-assessment-of-tawang-basin-highlights-from-the-nehu-study/

[10] https://sandrp.wordpress.com/2014/11/01/why-is-the-iit-consortium-acting-like-a-hydropower-lobby/

[11] https://sandrp.in/dams/Demwe_Lower_Unacceptable_Wildlife_Clearance.pdf

[12] https://sandrp.wordpress.com/2014/02/26/mockery-of-esas-in-sikkim-when-governments-collude-to-violate-laws/, https://sandrp.wordpress.com/2013/10/09/hydro-power-projects-violating-sc-order-in-greenest-state-of-india/,

[13] https://sandrp.wordpress.com/2014/02/26/mockery-of-esas-in-sikkim-when-governments-collude-to-violate-laws/

[14] https://sandrp.in/irrigation/ShirapurLIS_SANDRP_Sbmsn_to_EAC_Jan2013.pdf

[15] https://sandrp.wordpress.com/2015/04/15/mowr-report-on-assessment-of-e-flows-is-welcome-needs-urgent-implementation/

[16] http://www.iied.org/biodiversity-fundamental-building-block-sustainable-development

[17] http://pib.nic.in/newsite/PrintRelease.aspx?relid=121919

Arunachal Pradesh · Environment Impact Assessment · Expert Appraisal Committee

Submerged – what to expect if the Dibang river is dammed

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

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

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

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

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

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

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

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

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

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

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

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

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

References:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

THE DIBANG PROJECT

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

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

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

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

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

A. ENVIRONMENTAL CLEARNACE FOR THE DIBANG PROJECT:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

NO

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

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

NO

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

B. FAC DECISIONS ON DIBANG PROECT

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

END NOTES:

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

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

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

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

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

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