Above: Ken Yamuna Confluence at Chilla Ghat (Photo by Siddharth Agarwal)
We are thankful & glad that Dr Sharad Jain has responded to our open letter to MoEF, circulated through email and blog[i] that he holding the charge of NWDA Director General and Chairman of Expert Appraisal Committee (EAC) on River Valley and Hydropower Projects (RVP) involves Conflict of Interest. We are also thankful that through the Indian Express report (on June 3, 2017), he has provided another set of answers.
Subject: Submission related to Chenab River and Lahaul Valley in context of EC for 430 MW Reoli Dugli project
We have read reports that the expert appraisal committee (EAC) on river valley and hydel projects of the Ministry of Environment has decided “not to take any cognizance of representations” received by its members since such representations are ‘anti-development’. The article appearing in Indian Express on January 14, 2017 stated, “In its December 30 meeting, the committee concluded that once a project proposal reaches the EAC for appraisal, it has crossed the stage of public consultation and “the EAC should not go back in time, and should not reopen it, by entertaining unsubstantiated representations received from the people”.Continue reading “Lahaul people write to Environment Committee not to clear Reoli Dugli Hydro project”→
EAC against entertaining ‘anti-development’ representationsThe expert appraisal committee (EAC) on river valley and hydel projects of the Union Environment Ministry has decided “not to take any cognizance of such representations” received by its members. In its Dec. 30, 2016 meeting, the committee concluded that once a project proposal reaches the EAC for appraisal, it has crossed the stage of public consultation and “the EAC should not go back in time, and should not reopen it, by entertaining unsubstantiated representations received from the people”.
The EAC noted that in case of any clarification regarding action taken on such representations under the RTI Act, the EAC prescribed that a standard reply “action has been taken in accordance with the decisions taken in the 1st meeting of the EAC for River Valley and HEP on 30.12.2016” should suffice. “It was also felt that many of the objections raised are repetitive. Many such kind of representations have an anti-development attitude so that the projects are kept on hold or delayed. This has financial implications to the developers in particular and to the nation in general.
The committee emphasized that relevant ministries scrutinised every aspect of a project and proposed it for final appraisal only when all details were in place. If not satisfied that public consultation had been completed properly, the EAC said it could ask the project promoter to do the needful. The committee also made allowance for representations with “new points” and “grave consequences” on which comments from project proponents could be sought. The EAC considered 13 projects in its December 30 meeting and cleared eight of them.
Environmental activists, however, pointed out the impracticality of the contention that representations should be restricted to the 30-day public consultation window. Sripad Dharmadhikari also, in his blog has mentions various reasons to counter the EAC’s suspicious justifications. He also says that the fact that a body which is supposed to represent the environmental perspective displays such an attitude is the biggest critique of the EAC and the environmental clearance process that it is a part of. The newly constituted MOEF’s EAC on River Valley Projects has in their very first meeting shown anti people, anti democratic and anti environment attitude.
CentreEAC defers clearance to Yadadri Power project The Expert Appraisal Committee (EAC) under the Ministry of Environment has deferred its decision for granting environmental clearance for the 8,000 MW Yadadri Thermal Power Station in Telangana by TSGENCO due to a “lackadaisical” approach in preparing documentation. The EAC said the Environmental Impact Assessment (EIA) report was incomplete and there was lack of clarity on many issues raised by the Committee earlier. EAC on Thermal Power Companies has in its minutes meeting held on 29-30 2016 held the EIA consultants guilty of cut & paste jobswhich can be found here. At some places, it is mentioned that coal will be transported from two ports and in some other places, four ports are mentioned. Hence, complete and specific details regarding coal import ports and coal transportation routes were not given. Further it is also observed that two important sections of the EIA report- “risk assessment” and “disaster management plan”- are almost entirely generic and contain hardly any site or project specific aspects.
Chairman and Members of EAC on River Valley Projects, MoEF, New Delhi
Urgent: Concerns about Ken Betwa Project on EAC agenda for Environment Clearance for meeting on June 2-3, 2016
Respected Chairman and Members,
No documents since Feb EAC meeting: In continuation of our earlier submissions of Aug 21, 2015, Oct 24, 2015, Feb 6, 2016 and April 15, 2016, we are writing to you again since the Ken Betwa Link is again on the EAC agenda for the meeting on June 2-3, 2016. It may be noted that after the project was earlier considered by the EAC latest in the meeting on Feb 8-9, 2016, no new documents are available on the EC website. This itself is a serious lacuna since this means that all concerned are in dark as to why the project is being reconsidered by the EAC, what progress has been achieved since the last meeting. This is also in violation of the orders of the Central Information Commission that required all such documents be available in public domain at least ten days in advance of the meeting.
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”→
Expert Appraisal Committee on River Valley Projects,
Ministry of Environment and Forests,
Respected Chairman and Members,
We have just seen the minutes of the 86th meeting (uploaded on Sept 14, 2015, but clearance letters in some cases have already been issued even before the EAC minutes are made public or the minutes are finalised at the next EAC meeting) of the Expert Appraisal Committee on River Valley Committee, held on Aug 24-25, 2015.
The 126 MW Larji Hydropower project near Aut on the mainstem of the Beas is run by the Himachal Pradesh State Electricity Board (HPSEB). The dam is constructed a little downstream of the confluence of the two main tributaries upstream, the Sainj and the Tirthan, at the narrowest part of a spectacular gorge, towering with limestone cliffs. The impounded waters of this dam have, since its construction in 2006, drowned the access road to the entire upper Kullu valley including Manali and the hundreds of villages upstream, including access to the entire Lahul valley and the region of Ladakh over the high passes from this end. The HPSEB then constructed a 3 km long tunnel to enable passage of traffic, and many people have warned of the hazardous nature of the tunnel. The 220 odd gods that descend from different valleys, on the backs of people to the lower Kullu valley every year in autumn however, refuse to use this tunnel. This is what compelled the HPSEB to build and maintain this tunnel, and during autumn to winter, to keep the water-storage in the dam low to enable the passage of gods, who have been traveling this route for over three and a half centuries. It is remark-worthy though, that this dam constructed as recently as 2006, seems to be heavily silted-up already and the dark shadows of sediment-shoals are visible just below the waters of the reservoir.
Being among the most recently completed, the Larji dam is the only dam on the Beas that has a fish-ladder, so it was of particular interest to us. Seeing no guard at the security booth, we walk in to the HPSEB dam operating office, and ask to speak to an officer about the fish ladder. To our complete surprise, we are spoken to and even taken on a tour of the ladder by a foreman who has worked on the dam for many years.
Having seen an elaborate fish ladder on the Kuri Chhu river in Bhutan of doubtful effectiveness, we could not help but look at this one with hope and excitement. Located at around 1,000 meters altitude, this dam was clearly in the way of a host of migratory species of fish. If this ladder design was effective, then surely the ‘barrier’ problem to seasonal migration for breeding and dispersal would have been addressed. Here though, is what we saw and heard.
For one, the flow through the fish-pass seems too small to create an ‘attraction flow’ for fish. But even more obviously, the downstream entrance of the fish ladder is a steep cascade over a couple of meters of broken masonry and rock, that would clearly be un-negotiable by any fish that does not jump that high.
2. The outlet from the dam reservoir into the fish ladder is blocked off by a metal grill-mesh that is narrow enough to trap flotsam like Bisleri water-bottles. The mesh seemed too fine to let Mahseer of breeding-age pass through, either upstream or downstream.
3. The fish ladder was in a serious state of disrepair. To our questions about whether the ladder worked or not, the foreman says honestly that it does not. We see the reasons for this when we walk down the ̴100 meter length of the fish-pass channel.
4. The Larji fish ladder seemed to be a hash of different designs of fish passes. There were four different design elements in this one fish-pass. It had a slotted-weir fishway design, a low gradient Denil fishway, a steep-pass Denil fishway and a plain concrete culvert on a grade design. Most of these slotted weirs were clogged with fallen rocks and debris from the slope above, and in places, the pools in them were over-flowing the weir in a vertical fall almost 2 meters high.
5. The oblique baffles on a Denil fishway are supposed to be placed in a manner that provides staggered partial-obstructions that slow the water down at variable velocities to make it passable for fish. However, here we saw that the water picks up momentum down an extremely steep slope with the baffles at 45 degrees to the flow, not offset to slow the water, but concentrating the force of the water in mid-stream flow. The slope seemed to be at almost 40 degrees angle, and the water was turbulent in the extreme in this section. A workable Denilway slope, even for the strongest of swimmers among fish, is not designed to exceed a slope of 20% at most. This was close to a 100% slope.
The last part of the fishway was a plain concrete culvert on a grade channel, essentially a sloping channel, where even the concrete sides of the channel had toppled over into the river-bed, and the final drop was over a two meter fall into the downstream flow. I asked the foreman whether he knew whether fish managed to make it over this extreme gauntlet. He said that they did not, but that he often saw fish gather and concentrate at the bottom of the dam under the sluice gates, and make futile leaps in an attempt to get over the dam. Clearly, the Larji dam fish ladder is just an unlovely trinket, a deceptive ornament.
Watch a 41 seconds video showing how fast the water is moving through the Larji Dam fishladder at: http://youtu.be/grVaxXPdeyY, Video is by the author.
It seemed to me that the dam builders and operators, the HPSEB in this case, both at the design and the executive levels, were not serious about constructing a fish-pass that would work, and neither were they serious about this at the operation and maintenance aspects. Whether they were serious at all even at the conceptual level, to put in place a mitigation measure that actually helped migratory fish bye-pass the barrier of the dam, or was this part of the design merely to obtain environmental clearance, can only be conjectured about. That hydropower projects can devise deceitful strategies for obtaining environmental clearance is one thing, but what does this tell us about the Union Ministry of Environment and Forests, the Expert Appraisal Committee on River Valley Projects appointed by MoEF, the regional office of the MoEF, the state Fisheries Department and also the state pollution Control Board, who are all variously part of the approval processes for hydropower projects, when they get their environmental clearances based on such ‘mitigation measures’?
 The 126 MW Larji project is also infamous for being the costliest hydro-power project per unit electricity generated so far in India. Finally built at a cost of R.s 10.27 billion, which was twice the estimated cost, the Vigilance department unearthed major financial misappropriation by HPSEB officials.
 Other than loaches, those tiny finger sized fish that can even climb (squiggle technique) up high waterfalls, provided there is something like a water-slide at the margins of the fall. They however, are not migratory fish.
 CIFRI recommends that the speed of flow of water in a fish-pass should not exceed 2 meters per second. Please see ‘Status of fish migration and fish passes with special reference to India’. MK Das and MA Hassan. CIFRI 2008.
Guest Blog by: : Karthik Teegalapalli(email@example.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 (Aconitumferox, Coelogynemossiae, Dendrobiumaurantiacum, Paphiopedilumfairieanum, Paphiopedilumvenustum and Vandacoerulea) 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 Schizothoraxrichardsonii, Endangered golden mahseer Torputitora, Near-Threatened mahseer Tortor, and chaguni Chaguniuschagunio. 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.
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!
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.
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.
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.
Sinha, A., Hoque, J., Pradhan, T., Bakshi, M. K., Pulu, J., Singh, A. K. & Ahmed, F. (2012) Sighting record of Bengal Florican Houbaropsisbengalensis (Gmelin, 1789) (Aves: Gruiformes: Otididae) in Lower Dibang Valley District, Arunachal Pradesh, India. Journal of Threatened Taxa, 4(14): 3375-3376.