Cumulative Impact Assessment · Dams · Hydropower · Ministry of Environment and Forests

Upper Ganga Report with Pro Hydro Bias does not do justice to its terms or to Ganga, people or environment

Summary A month after its submission to the Union Ministry of Environment and Forests, the Inter Ministerial Group on Upper Ganga basin Hydropower projects and Ganga river in general is yet to be put in public domain. A detailed perusal of the report shows that the report is hugely biased in favour of large hydropower projects, and has not done justice to the task given to it or to the Ganga river, people or environment. Out of the three non government members (out of total 15 members) on the Group, Dr Veer Bhadra Mishra expired during the working of the group. Rajendra Singh has given a dissent note, not agreeing with the report in its totality. The “alternative view” note from Sunita Narain, the third non-government member, is not much of an alternative and is not in the interest of the river, people or the environment. However, the fact that none of the non-government members have endorsed the report speaks volumes about the credibility of the report.


The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations.

A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. The report gives a list of positive aspects of the IMG report on which there is a lot of scope for positive action, which the MoEF should initiate, while rejecting the report.


1. The Inter Ministerial Group (constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012) report has been submitted around April 22, 2013, but it is still not in public domain a month later. The report should have been promptly put in public domain as in the case of the HLWG report on WGEEP panel recommendation on the Western Ghats, which was made public the day after the submission of the report to MoEF. These comments[1] are based on the hard copy of the final report made available by a colleague[2].

2. The IMG final report has been endorsed by all members, except the dissent note by Rajendra Singh attached at Annexure X and a note on “alternate approach” from Sunita Narain, attached at Annexure XI. Shri Veer Bhadra Mishra, who was the third non-government member, expired during the period of functioning of the IMG group. The committee constitution was heavily loaded in favour of the government officers (ten of the fifteen members were government officials), so its independence was already in doubt. With none of the non-government members endorsing the report, the report has little credibility. This review tries to look at the report with an open mind.

3. While SANDRP as a group is critical of large, destructive and non participatory hydropower projects, it does not mean the group is against all hydropower projects. For example, if the projects were to be set up through a participatory and informed, decentralized, bottom up decision making process or if projects were to follow the recommendations of World Commission on Dams, such projects would certainly have greater public acceptance. That is not the case for any of the projects today.

4. The main TOR given to the IMG was to decide the quantum of environment flows for the upper Ganga basin rivers, keeping in mind the IIT (Indian Institute of Technology Roorkee, the report was basically from some individual of Alternate Hydro Electric Centre of IIT-R) and WII (Wildlife Institute of India) reports on cumulative impact assessment of the projects in these river basins. However, IIT (Roorkee) report has been found to be so flawed and compromised (for details see: that it should have been rejected by the MoEF and the NGRBA. Even the MoEF’s Expert Appraisal Committee on River Valley Projects has been critical of the IIT-R report. However, since a member of the IIT-R was present on the IMG, it may not have been possible for the IMG to take an objective view of the merits of IIT-R report. It is however, welcome that IMG has relied on WII rather than IIT-R report while accepting recommendations on e-flows. WII report was better in some respects, though still suffering from some basic infirmities. Moreover, to set up an IMG to decide on the course of action considering these two reports (and any other relevant reports) was compromised at the outset and was an invitation for further dilution of the environment norms, considering the track record of the most of the members of IMG.


Ganga river flowing through a channel, diverted for the 144 MW Chilla hydropower project

5. The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even

where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations. All of these points are further elaborated in this note.

6. Cancelled projects  & those on Bhagirathi Eco Sensitive Zone shown as under development Shockingly, even the projects like the Loharinag Pala, Pala Maneri and Bhairon Ghati that have been officially dropped are shown as under development by the IMG, see Annex VID! In fact in Table 12 and 13 IMG even calculates the reduction in power generation and increase in tariff at Loharinag Pala (among others) if the IMG recommended e-flows are implemented! The 140 MW Karmoli HEP on Bhagirathi, on a stretch that the MoEF has been declared as Eco Sensitive Zone, and on which the GOI has said no large hydro will be taken up, the IMG has actually suggested that the project can be taken up! The 50 MW Jadhganga project, very close to the Gangotri, is shown to be project under development by the IMG! These examples show how the IMG has played a role of supporter of the hydropower lobby.

7. Wrong classification of projects as under construction and under clearance projects IMG has divided the 69 hydropower projects in Upper Ganga basin (leaving our the Kotli Bhel 2, since it is on Ganga river and not on Bhagirathi or Alaknanda) in four categorie

s: Operating projects, under construction projects, under clearance projects and under development projects. It is here that IMG has done its biggest manipulation by classifying a number of projects as under construction when they are not and cannot be under construction. IMG classification of projects under clearances is equally problematic. IMG and even the “alternative View” by Sunita Narian says all these projects in first three categories can go ahead without any change, except the e-flows recommendations. This manipulation shows the stark pro hydro-bias of the IMG.


Dry Ganga river after the river is diverted for Chilla HEP. Photos by SANDRP

8. Manipulations about percentage length of river that the projects can destroy On the one hand, the IMG has recommended that “projects may be implemented so that not more then 60% of the length (of the river) may be affected.” There is no mention how they have arrived at this magic figure of 60%, what is the basis or science behind that magic figure. At the same time the IMG has said that if all the 69 projects were to be implemented than 81% of Bhagirathi and 65% of Alaknanda will be affected. Firstly these numbers are not correct if we taken into account the full length of the reservoirs and the bypassed river lengths by the hydro projects, in many cases the length of the submerged reservoir behind the dam has not been counted. Here we need to add the fact that the reservoir of the 70th Project on its list, the Kotlibhel 2 project will submerge parts of both Bhagirathi and Alaknanda rivers, which has also not been counted by the IMG. WII had to recommend 24 projects to be dropped, and even after that, WII assessed that 62.7% of the rivers would still be affected. However, the IMG has made no recommendation as to which of the projects need to be dropped (except vague review of the projects in Annex VI-D) to achieve that magic figure of 60%. This again shows how non serious IMG is, making this recommendation meaningless.

9. IMG double talk on distance criteria The IMG has said that “There is a clear need to ensure that adequate river length is available to meet the societal needs and River gets adequate time during its flow to regenerate itself” (emphasis added). This sounds good. But IMG has shown no will or interest in ensuring that this happens. In fact IMG exposes its understanding on this matter when it says, “the distance between two hydro projects should generally be such as to ensure that over-crowding is avoided”. What is over-crowding, how do you define it? This is a funny word IMG has used, not even bothering to define it. However, when it comes to implementation, dumping all these requirements, IMG has justified smaller distance (read zero distance) between projects where gradient is high. Now let us understand this: where gradient is high, if the distance left between the projects is less, will the time the river flows between projects be smaller or greater than if the gradient is low? Clearly, if gradient is high, for the same distance, the river will have less time to travel then if the gradient were low. It is in fact the time of free flow that is a crucial driving parameter for river to regenerate itself. So if the river were to have the same amount of time to flow between two points, with higher gradient, river will require more distance, not less. This again exposes the poor understanding of IMG members about science of the rivers.

The IMG even goes on to say that “distance will have to be smaller in view of technical requirement of the hydro power. This could result in continuity in some cases.” Firstly it is clear here again that IMG is basically catering to the hydropower lobby, it is completely non serious about the environmental issues. That is why after all those great sentences, it goes on to say that it is the technical requirement of the hydropower project that will be the decider! If technical requirements means no distance between two projects, then river can disappear, environmental issues do not matter! In case of many projects where the distance of free flowing river between projects is very little or nil and where the construction has not started or has not progressed much, there is today scope for change. For example in case of Vishnudgad Pipalkoti HEP on Alaknanda: the Full Reservoir Level of the VPHEP is same as the Tail Water Level of the upstream Tapovan Vishnugad HEP. This means that there is zero length of free flowing river between the projects. VPHEP does not have all the clearances and its construction has not started. Even for the upstream Tapovan Vishnugad HEP, the construction has not gone far enough and there is scope for change in both projects to ensure that there is sufficient length of free flowing river between the projects. IMG should have recommended change in parameters in this and other such cases, but it has done no such thing, it has shown no interest in any such matter! Even the “alternative approach” note in Annexure XI has not bothered to recommend such changes even while recommending 3-5 km free flowing river between two projects.

The IMG makes another unscientific statement in this context when it says, “With the recommendation of IMG for environment flow which will be available and which would have traveled throughout the diverted stretch, any significant gaps and large distance may not be required.” This is an unscientific, unfounded statement. Firstly where is the evidence that the environment flows that IMG has suggested would take care of the need for river to flow on stretches between the projects? Secondly, the need for river to flow between the projects to rejuvenate itself will also depend on the length of the rivers submerged by the reservoirs, and also depend on the biodiversity, the social, cultural and religious needs in addition to the ecological needs. By making such ad hoc unfounded statements devoid of scientific merit, the IMG has exposed itself.

While the IMG talks about the rich diversity of fish species and other aquatic diversity of the river, it has no qualms in saying that e-flows alone will address all the problems caused by bumper to bumper projects. As many including Government of India’s CIFRI (Central Inland Fisheries Research Institute) have concluded, Dams have been the primary reason for the collapse of aquatic diversity in India, not only because of the hydrological modifications and lack of e-flows, but also because of the obstruction to migration they cause, destruction of habitat during construction, muck disposal, trapping of sediments, destruction of terrestrial (especially riparian) habitats. But these concerns are not even considered by the IMG while saying that recommended e-flows will be able to solve all problems caused by bumper to bumper projects.

Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute
Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute

10. WII recommendation of dropping 24 HEPs rejected by IMG without any reason The IMG notes that WII has recommended that 24 hydropower projects of 2608 MW installed capacity should be dropped in view of the high aquatic and terrestrial biodiversity. However, IMG decides to dump this WII recommendation without assigning any reasons. This again shows the strong pro hydro bias of the IMG. WII report says that even after dropping these 24 projects, at least 62% of the river will be destroyed.

It is shocking that projects like Kotlibhel 1B and Alaknanda HEP, which have been rejected by WII and Forest Advisory Committee, is considered as “under development” by IMG, when they should have been rejected. While the IMG Report talks of unique biodiversity of the Ganga Basin, Valley of Flowers and Nanda Devi National Parks, it still supports projects which will be affecting these National Parks like the 300 MW Alakananda GMR HEP, which was also rejected by the WII and FAC (twice).

As a matter of fact, of the 24 projects that WII report recommended to be dropped, the IMG has shown 8 as under construction and 4 as “projects with EC/FC clearances”. This is sheer manipulation, in an attempt to make them a fait accomplice. Strangely, the “alternative approach” note in Annexure XI does not say anything about this manipulations and in fact says the projects in Annexure VI-B and VI-C can go ahead!

11. Non serious recommendation about keeping six tributaries in pristine state IMG (Para 3.70) “recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, Assi Ganga, Dhauli Ganga (upper reaches), Birahi Ganga and Bhyunder Ganga should be kept in pristine form and developments along with measures for environment up gradation should be taken up. No new power projects should be taken up in these River Basins.” This sounds good, but turns out to be like a joke, since firstly, IMG recommends construction of projects on these rivers that yet to be constructed! If these rivers are to be kept in pristine state then IMG should have asked for immediate stoppage of under construction projects and also time bound decommissioning of the operating projects on each of these rivers. In stead, the IMG report shows that projects are under construction on rivers like Assi Ganga (stage I and stage II projects each of 4.5 MW), Birahi Ganga (24 MW stage I project), Bal Ganga (7 MW stage II project listed in Annex VI B of IMG report, in addition to the 1 MW Balganga and 5 MW Balganga I project are also under construction as per IIT Roorkee report) and Bhyunder Ganga (24.3 MW stage II project) and IMG has (implicitly) recommended that these projects be allowed to continue, on rivers that IMG says it wants to remain pristine! Moreover, Rishi Ganga (13.2 MW project) and Birahi Ganga (7.2 MW) have operating projects on these rivers to be kept pristine! In addition, on Assi Ganga the 9 MW stage III project, is considered by the IMG as ready for development since it has some of the clearances.

Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu
Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu

The IMG has noted that 70 MW Rishi Ganga Stage-1 and 35 MW Stage II Project are under development on Rishi Ganga (IIT-R report mentioned another project on Rishi Ganga, namely the 60 MW Deodi project, it is called Dewali project by WII report; WII report also mentions 1.25 MW Badrinath II existing project on Rishi Ganga) and 24 MW Birahi Ganga-II project is under development. But the IMG does not recommend dropping of these projects.

So at least five of the six rivers that the IMG claims it wants to stay in pristine state are no longer pristine! They have multiple projects, most of them under construction or yet to be developed and the IMG has not said that any or all of these projects should be stopped, cancelled and those under operation be decommissioned in time bound manner. Even on Nayar, the sixth small tributary that IMG said should be kept in pristine condition has a 1.5 MW Dunao project under development by UJVNL, as per the UJVNL website. It’s clear how non serious IMG is about its own recommendation. IMG has included Dhauli Ganga (upper reaches) in this recommendation, but has not even bothered to define which stretch of the Dhauli Ganga this applies to, again showing the non-seriousness of IMG.

In para 4.22 IMG says, “Specifically, it is proposed that (a) Nayar River and the Ganges stretch between Devprayag and Rishikesh and (b)… may be declared as Fish Conservation Reserve as these two stretches are comparatively less disturbed and have critically important habitats for long-term survival of Himalayan fishes basin.” If IMG were serious about this, they would have also said that Kotli Bhel II project should be cancelled since it is to come in this very stretch.

IMG’s claim that not having any more projects on these six streams will mean loss of generating capacity 400 MW is also not backed by any sort of information or list of projects to be dropped, it seems IMG is in the habit of making such claims and does not feel the need to back them.

12. IMG on environmental impacts of Hydropower projects One of the key TORs given to IMG was “to make a review of the environmental impacts of projects that are proposed on Bhagirathi, Alaknanda and other tributaries of river Ganga and recommend necessary remedial action.” What has the IMG done about this TOR? IMG wrongly claims (Para 4.18), “The environment impact of proposed 69 hydropower projects has been considered by IMG.” It has done absolutely no justice to this very crucial TOR. First thing IMG has done in this regard is to dump the WII recommendation to cancel 24 hydropower projects, without giving any justifiable reasons. The IMG has produced a set of guidelines for the hydropower projects, which have almost nothing new, they are certainly not comprehensive or legally binding. They miss the most important issues of inadequate environment impact assessment, inadequate public consultation process, inadequate appraisal, lack of accountable governance and compliance.

What is required is certainly not new set of guidelines. MoEF already has a long list of environment and forest clearance conditions, environment management plans and manuals. But there is no interest, will or willingness to achieve compliance in MoEF. IMG is obviously aware of this state of affairs. Yet they have happily prepared a new set of five page guidelines just to show they have done something about this TOR. The “alternative approach” in Annex XI also has nothing to offer on this score.

Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan
Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan

13. Unwarranted conclusion about BBM methodology The IMG has said, “Considering environment, societal, religious needs of the community and also taking into account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirement”. This is good and needs immediate and credible implementation.

However, IMG says this will be applicable only “in situation where the required conditions are satisfied and resources, time and data are available.” The only basis for this conclusion by IMG is the fact that WWF took three years to do a study of environment flow requirements of three sites along Ganga involving large number of experts. This is clearly an unwarranted conclusion since WWF was only doing it first time and has much less resources at its disposal than the government have. By arriving at this unjustified conclusion that has no basis, the IMG implies is that BBM methodology is required and is justified, but Indian rivers including the Ganga won’t get it since IMG (wrongly) thinks that “required conditions” are not satisfied. This is clearly wrong and unwarranted conclusion. The BBM can and must be applied in all cases immediately, including for all existing and under construction projects and cumulative impact assessments.

Also, while stating multiple times that BBM for three locations for Ganga took three years, the IMG does not go into the details of what caused this delay. One of the important reasons stated by WWF itself is that required data was not made available to them, which contributed to the delay. So it is the government itself that was part of the reason for the delay in WWF study, and now IMG uses that delay to suggest that BBM is not practicable for Ganga! If the Government has the will to implement a more holistic methodology like BBM, it can be done and IMG conclusion is unwarranted and wrong.

14. Unjustified pro hydro bias of the IMG The IMG has shown its pro hydro bias at several places. At one place it says that a balanced approach needs to be taken as “It is important to see that the flows do not result in exorbitant cost of power which the people of the region may not be able to afford. This would make these power projects uneconomic and un-implementable”. Firstly, as far as people in immediate neighbourhood of the projects are concerned, history of grid connected hydropower projects in India shows that local and particularly the affected people almost never get power benefits from projects but they surely suffer all the negative impacts. IMG is wrong as far as this section of the people is concerned.

Secondly as far as the people of Uttarakhand in general are concerned, where all the projects in Upper Ganga basin are situated, the state would get 12+1 % of free power. Since most of the projects are in central or private sectors, the rest of the electricity would mostly go outside the state. As far as this 13% free power is concerned, since it is supposed to be free, there will be no impact of e-flows on the tariff of such projects, except some marginal reduction in quantum of power.

Lastly, is it the bottom line of the IMG that projects must be economic and implemented at all costs, by hook or by crook, as is apparent from the above quoted sentence? How can that be the bottom line of IMG considering its TORs? Moreover, by making the projects economic and implementable by hook or by crook, the IMG seems to be saying that irrespective of the social, environmental, cultural, religious and even economic costs, the projects must go on. Thus what IMG is suggesting is that artificially low cost electricity must be produced for the cities and industries irrespective of any concerns of costs and impacts on people, environment, future generations and rivers including the national river! This is clearly a plea to export the water, livelihood and environment security of the people for the short term economic prosperity of far off city dwellers and industrialists. Is this acceptable?

15. What is environment flow? IMG should have provided a definition of what is meant by river and environment flow. Since it is linked with enabling the river to perform its various roles and services in the downstream area, it cannot be just limited to water flow downstream. The downstream river also needs silt and nutrition from the upstream and the biodiversity and geomorphology in the river crucially depends on such flows of nutrition and silt. However, IMG has said nothing on this count.

Dry River at Uttarkashi Photo: Open Magazine
Dry River at Uttarkashi Photo: Open Magazine

16. Environment flows = aviraldhara? The IMG has said, “Environment flows in the river must lead to a continuous availability of water (aviraldhara) in the river for societal and religious needs.” This equation of aviral river with continuous flow of water is clearly flawed, since by that token even a pipeline has aviraldhara, but a pipeline is not the same as aviral River. For a river to be flowing aviral, continuous flow of water is a necessary but not a sufficient condition. A river means so much more.

17. No attempt at assessment of social, religious, cultural needs The IMG keeps talking about social, religious and cultural perspective and needs of the society from the river and so on. However, there has been no attempt to assess what exactly this means in terms of river flow, quality, content of flow across the time and space. More importantly, how is all this to be decided and who all are to be involved in the process. IMG just assumed that this has already been done by IITR and WII, which is flawed assumption, since WII or IIT-R has clearly not done any such assessment. So in stead of giving standard monthly flow release percentage across the rivers (releases to vary based on daily flow variations, this recommendation of daily changing flow is certainly an improvement from IMG), IMG should have asked for actual assessment of such needs across the rivers and IMG should also have given the process for arriving at such decisions. But while deciding social, religious or cultural needs, the IMG sees no role for the society, religious groups or cultural institutions.

In this context it may be added that the IMG has also not taken note of the legal stipulations like the order of the Allahabad High Court that says that no project can divert more than 50% of river flows existing at the point of diversion.

DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia
DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia

18. IMG recommendation during High Flow Season (May-Sept) The IMG has recommended 25% of daily uninterrupted (no clear definition is given how this will be arrived at) flow, with the stipulation that the total inflow in the river would not be less than 30% of the season flows. This is same as 30% of mean seasonal releases recommended by WII (para 8.3 of WII report, para 4.11 of IMG report) and also used by even Expert Appraisal Committee on River Valley Projects currently. The recommendation of releases based on daily flow is an improvement compared to the earlier situation, but its implementation is in serious doubt considering the weak compliance requirements from IMG.

It should be added here that IMG has not mentioned how the environment flow will be released. Just dropping it from the top of the dam won’t help, the flow must be allowed to flow downstream in an environmentally sound manner that is as close as possible to the flow of the river and helpful for the biodiversity in the river to link up from downstream to upstream and vice versa. Moreover, while deciding flows, IMG has largely followed the recommendations of the WII. However, WII conclusion of classifying Upper Ganga basin under EMC class C itself is flawed. IMG should have corrected this flaw, before concluding on environment flows.

19. IMG recommendation during Lean Flow season (Dec-March) The IMG has recommended (Para 3.48) release of 30% of daily uninterrupted river flows, this will go up to 50% where the average monthly river flows during lean season (Dec-March) is less than 10% of average monthly river inflows of the high flow season (May-Sept) and to 40% (however, Para 3.51 does not mention this 40% norm) where this ratio is 10-15%. While this is an improvement in the current regime, this remains weak considering that IMG has not done project wise calculations where 30, 40 and 50% stipulation is applicable, which it could have easily done at least for the existing and genuinely under construction projects.

20. IMG recommends lower flow for India’s national river compared to what India promises Pakistan in Jhelum basin The IMG has recommended 30-50% winter flows for all projects as described above. This in case of a river everyone recognizes as the heart and soul of India, a river that has such an important social, religious, spiritual significance and it has been declared as the national river. Let us compare this with what e-flows Indian government has promised to Pakistan downstream of the Kishanganga Project in Jhelum river basin in Kashmir. In a case before the Permanent (International) Court of Arbitration (PCA), Indian government has assured that India will release more than 100% of the observed minimum flow from the dam all round the year, and now in fact the government is considering even higher than 100% of the observed minimum flow all round the year. The PCA is yet to decide if what India has proposed will be sufficient or more water flow is required. So, as against the assurance of more than 100% of minimum flow at all times on another river, for the river flowing into another country; for the national river Ganga, for India’s own people and environment, all that the IMG recommends is 30-50%. On most winter days, KishengangaRiver downstream of the hydropower project, flowing into Pakistan, thus will have higher proportion of its daily flows than what Bhagirathi or Alaknanda will have.

Dry Ganga at Haridwar in August 2012 Photo: SANDRP
Dry Ganga at Haridwar in August 2012 Photo: SANDRP

21. Monitoring and compliance of Environment Flows The IMG has said that effective implementation is cardinal part of its recommendations. This is good intention. However, by asking the power developer to be responsible for the implementation, the IMG has made the recommendations ineffective. IMG has chosen to ignore the fact that there is clear conflict of interest for the power developer in assuring e-flows, since the e-flows would reduce the power generation and profits of the developer. Its faith in IT based monitoring is also completely untested and there is no evidence to show that such monitoring will be free of manipulation. Secondly, to ask the MoEF to do annual review, that too only for first five years ignores the track record of MoEF in such matters where MoEF has shown no will, capacity or interest in achieving post-clearance compliance of the environment laws of the country. Thirdly, to require this only for projects above 25 MW shows the lack of understanding of IMG as to how important the smaller streams are for the water, ecology and livelihood security of the community in hills. Its recommendation of monitoring by an independent group is welcome, but lacks credibility in the absence of sufficient involvement of local community groups in such a mechanism.

22. Baseless assumption of low water requirement for fish in the Himalayan region The IMG has assumed that in the Himalayan region, the water requirement for fish in the river is less and hence the rivers here will not require as much water as the rivers do in the plains. This is completely unscientific, flawed and baseless assumption. The amount of e-flows needed has to be assessed not only based on the requirement of fish (IMG has not done even that assessment), but entire aquatic and connected terrestrial biodiversity across the seasons, in addition to the water needs of a river for providing the social and environmental services.

23. Suggestions that are bad in Law The IMG report shows several projects as “Under Construction” (Annex VI B) category, when they do not even have statutory clearances and hence cannot even legally start the work. This is a ploy to make these projects a fait accomplice when these projects are perfectly amenable to review and rejection since the project work has not started. In fact to categorise such projects without having all the statutory clearances (e.g. Vishnugad Pipalkoti does not have forest clearance) as under construction project is plain illegal.

24. Wrong representations The IMG has shown several projects in Annex VI C, as “Hydropower projects with EC/FC Clearances and others”, basically a ploy to push the projects that do not even have all the statutory clearances. None of these projects have all the statutory clearances and are certainly not in position to start construction and hence these projects are the ones where dropping of the projects or modifications in dam location, dam height, FRL, HRT length, e-flows, capacities etc are still possible. But IMG did not do it for any of the projects. As mentioned above, four of these projects have been recommended by WII to be dropped, and IMG should have recommended dropping these or should have categorized them as ‘to be reviewed’.

25. No mention of impact of peaking operation of hydropower projects The IMG has missed many crucial environmental impacts. One crucial one that it has missed is the issue of peaking operation of hydropower projects on the downstream people, environment, flood plains, geo morphology, biodiversity and other aspects of the river. This is very important since one of the Unique Selling Proposition (USP) of hydropower projects is supposed to be that they can provide peaking power. However, peaking operation means sudden changes of huge magnitude of flows in downstream river, having far reaching impacts including those on safety of people, flood plain cultivation, impacts on cattle and property, impact on ecology, amongst many others. The IMG has completely missed this, which is very strange since this is a huge issue being taken up by people and campaigns in the North East against large hydropower projects there.

26. IMG cannot see through poor work of IIT-R It is well known that IIT-R report on Ganga basin study is of poor quality. In the IMG report there is an attempt to respond to only a couple of the criticism of IIT-R report, but IMG could not even see through the wrong facts presented by IIT-R report. For example, IMG report says, “The requirement of flushing during monsoon is not required in both rivers as all hydro projects except Tehri reservoir are run of river types where silt is not stored.” This is completely wrong. All the projects, even if run of the river, have storage behind the dam where the coarser silt will settle down and will need to be flushed out periodically. The dams are being provided with bottom sluices to facilitate this. A quick perusal of the EIA reports of some of the hydropower projects in the region shows that Vishnugad Pipalkoti, Srinagar, Kotli Bhel 1-A, Kotli Bheal 1-B, to name only a few all have proposed to provide bottom sluices for periodic release of silt accumulated behind the dam. Thus the contention that most projects do not need flushing is wrong. In any case, for all projects, the de-silting chambers would be releasing silt laden water and there is no attempt to assess the cumulative impacts of such actions. IMG’s attempt to provide scope for some defense for the IIT-R has clearly back fired on IMG! Moreover, even in case of Tehri, the biggest project in the region under review, IMG report has nothing at all, about it social, environmental impacts and performance, about its power generation, irrigation, water supply, flood control performance or even its silt management performance.

The contention that all projects except Tehri are ROR is entirely wrong and misleading. Even as per the WII report, out of the 69 projects, a whopping 13 projects are storage projects. This includes the biggest and most problematic projects like Srinagar, KotliBhel IB, KotlibhelIA, Koteshwar, Vishnugad Pipalkoti, Devsari, etc.

27. IMG on Srinagar HEP and Dharidevi Temple The IMG was also asked to “review the impacts of the Alaknanda (GVK) Hydro Power Project on flow of the River and the issues related to the temple relocation.” The IMG gave an interim report on this issue, which was so disappointing that Rajendra Singh and Late Shri Veer Bhadra Mishra both members of the IMG, gave a dissenting note, Rajendra Singh also suggested shelving the project. The IMG rejected the suggestion of its own members without giving any justifiable reasons.

DhariDevi Temple threatened by submergence
DhariDevi Temple threatened by submergence

28. Time bound action plan for E-flows from existing projects The IMG says that the existing projects should also follow the suggested e-flows and this should be achieved in three years (Para 3.52). However, IMG should have been more clear about the role of different agencies (MoEF, state government, developers, state electricity regulatory commissions and power purchases) and what is the legal backing such a step will have.

29. Lack of understanding of conflicting projects and public protests The IMG report, Annex VI B shows 12.5 MW Jhalakoti (wrongly) as under construction project. In fact the Jhalakoti project has been recommended by WII to be dropped. The IMG seems to have no clue that Jhalakoti project is being strongly opposed by the local communities and no work has started on the project. The under construction status given by IMG for this project is clearly wrong. If the Jhalakoti HEP comes up then the existing 40 KW Agunda micro HEP will no longer be able to function. Many of the other projects including the Devsari and Vishnugad Pipalkoti HEP are also facing strong opposition, but the IMG has not taken note of these or any of the social impacts of the projects in the Upper Ganga basin.

Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan
Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan

30. IMG on TOR on pollution abatement in Ganga It is good to see that IMG has suggested that “all users must be forced to plan for water needs based on what the river can spare, not what they can snatch.” However this should not mean an advocacy for more big dams and storages on the rivers. This seems to be the case when we read the IMG recommendation that says, “The government then has a choice to build storages to collect monsoon water for dilution within its territory or to ‘release’ water to rivers and make other choices for use in agriculture, drinking or industry”. Storages can come in many forms and sizes and IMG should be careful not to recommend more big storages on the rivers. The suggestion that “there will be a clear conditionality in Central government funding, which is matched to the quantum of ecological flow released by the state in the river” is welcome. Linking of JNNURM-II and National Mission for Clean Ganga to the above norm, incentivisation of use of innovative bioremediation and in-situ drain treatment are also welcome. However, IMG has shown no interest in understanding or tackling the real problem in river pollution: Lack of participatory, democratic governance in urban water and pollution control regime.

IMG has recommended in Para 6.7(i), “Ecological flow will be mandatory in all stretches of the river.” This is welcome. IMG goes on to suggest some norm for the urbanized stretches of rivers, but no norms are suggested for the non urbanized stretches of river in the lower river basin.

31. Report does not reflect the discussions in IMG? The dissent note by Shri Rajendra Singh, a member of IMG says that on several aspects, IMG report does not reflect what transpired in the IMG meetings. This is a very serious charge that puts a big question mark on the IMG report and its recommendations, particularly since Rajendra Singh is the lone independent voice in the IMG after the sad demise of Shri Veer Bhadra Mishra[3].

32. Incomplete project list The IMG does not seem to have full information about the existing, under construction and planned hydropower projects in the Upper Ganga basin in Uttarakhand. Some of the projects not listed in the IMG report include:

A. Operating projects under 1 MW: According to the website of UJVNL (Uttarakhand Jal Vidhyut Nigam), the state has 12 such projects with total capacity of 5.45 MW, see for details: Most of these projects are in Upper Ganga basin, though it is not clear how many.

B. UJVNL has larger list of schemes under development by UJVNL including in the Upper Ganga basin, not all of them are included in the IMG list, see:

C. Private sector has been given license for a large number of hydropower projects, not all the projects of Upper Ganga basin here are on IMG list, see for full list of projects being developed by IPPs in Uttarakhand:

D. There is another “full list” of hydropower under development in Uttarakhand including sub-MW size projects, see: Some of the projects here in Upper Ganga basin do not figure on IMG list.

One would expect better information base of the IMG than what they have shown.

33. No specific recommendation to save the prayags There are five holy prayags (confluence of rivers) along Alaknanda river in Uttarkhand, including Deoprayag, Vishnuprayag, Karnaprayag, Rudraprayag and Nandprayag.

Vishnuprayag has already been destroyed by the 400 MW existing Vinshnuprayag HEP of Jaiprakash Associates, rest would be destroyed by the projects listed by IMG. The IMG keeps talking about cultural importance of the rivers, but has not said a word about how it plans to save these culturally important confluences and how it plans to rejuvenate the Vishnuprayag already destroyed.

34. “Alternative View” in Annexure 21: How much of an alternative is it? In Annexure XI of IMG report, a note authored by one of the IMG members, Sunita Narian of Centre for Science is given, it is titled: “TOR (ii): Alternative View: Environment flow”. The Annexure opens with the line “The recommendations of this IMG report are not acceptable.” It is not clear if this sentence applies to all the recommendations of the IMG or about environment flows mentioned in the title or it applies to TOR (ii) that applies to all environmental aspects, not just environmental flows. The Annexure also deals with some issues besides environment flows, so one assumes this “alternative view” is about environmental aspects of hydropower projects.

The Annexure XI seems to give an impression that, principles of distance between dams, ecological flow and limit on % of river than can be “affected” will lead to “sound hydropower development, balanced for energy and environment”.

One of the three principles listed in the note says: “Distance between projects: 3-5 km”. The note does not say how this distance has been arrived at or how this distance is to be measured, the least the note should have mentioned was that this is not distance between projects but distances of flowing river between the Tailwater level of upstream and full reservoir level of downstream project.  No elaboration is given about this criterion at all. Most importantly, there is not even any attempt to apply this criterion to the projects that IMG is supposed to look into. On the contrary, the note says that “The projects under construction can be built” (point 7(ii)) and “projects with EC and FC clearances can be taken up for construction” (point 7(v)). So in fact there is absolutely no application of the criterion to the projects on hand. The conclusion that this is half baked and non serious criterion is inescapable.

Another of the three principles listed in Annexure XI is: “Maximum intervention allowed in river length: 50-60 per cent”. Again there is no elaboration as to how these figures are arrived at, why there is a range, what is meant by “intervention”, which lengths it will apply and so on. Again, the note does not bother to apply this criterion to the rivers under review and actually says in point 7(ii) and 7(v) described above, that projects in Annexure VI (B) and VI(C) can go ahead without even checking if in that case this criterion will be violated or not. Again the conclusion that this is also a half baked and non serious criterion is inescapable.

The whole of the Annexure XI is basically devoted to application of the third principle: “Ecological flow regime: 30/50 per cent (high and lean period)”. About this, the annexure says: “The engineering design of the uninterrupted flow would take into account the need for sediment and fish transfer”, not clear how this will be achieved. The Annexure does not suggest any new measure of achieving compliance with its recommendations. The note mentions “design changes incorporated to maximize energy generation during high discharge season” but does not elaborate what these would mean.

Annexure XI says that IIT-R tried to suggest that e-flows must be low and in this effort did “big and large manipulation of data”. This is good. However, it would have been better if the full data and notes from IIT-R were annexed here to illustrate how the manipulation was done.

Bullet point 3 in Annexure XI reads, “It is important to consider that water of a river is similar to the coal or gas as raw materials used in thermal plants”. This statement needed to be qualified that the impact of taking out coal or gas from its source is not comparable to taking out water from the river, the latter’s impact is much more severe, since river is not equal to just water flowing in it.

Since Annexure XI does not raise objection to any other conclusions and recommendations of the IMG except the three principles mentioned above, it would not be incorrect to assume that author agrees to the rest of the IMG report. This, when taken together with the fact that at least two of the three principles in the alternative view note have not been applied to the projects under review, leads to the conclusion that there is not much of an alternative in “alternative view”  note and this won’t help the cause of the river, people, environment or even sustainable and sound development.

35. Conclusion A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. One of the positive aspect of this report is that possibly for the first time heads of central organizations like CWC and CEA have sat with some non government members to discuss some important subjects that have remained contentious for these official agencies.

However, as noted above, on most positive aspects, while IMG has been less than sincere, there is a huge potential to take the environment flow movement forward.

The MoEF and NGBRA should, considering all the above points, take some positive aspects forward. Some of the positive retrievable aspects of the IMG report include the following, on each of which there is a lot of scope for serious action:

  • Ensuring at least 50% E-flows in non monsoon months in all rivers.
  • Keeping some rivers in pristine form, stopping all ongoing and planned projects on suggested rivers and time bound decommissioning of existing projects on such rivers that are to be in pristine form. This should be immediately implemented on the rivers recommended by IMG and also in other selected rivers in all river basins.
  • Rejecting planned and under construction projects which have high impact on terrestrial and aquatic biodiversity, as per score developed by WII Report as well as projects which irreversibly impact spiritual and religious places like rivers, prayags, places of worship and ghats.
  • Give deadline of one year and maximum of two years for all the existing dams, diversions and hydropower projects across the Ganga basin (& other rivers) to achieve the suggested e-flows with clear inbuilt mechanisms for monitoring and compliance with participation of river basin communities, as a first step.
  • Accepting BBM as the standard methodology for E-flows assessment, e-flows to mimic the river flows and involving communities as an important stakeholder in this methodology.
  • Ensuring Aviraldhara.
  • Ensuring rivers have adequate free flow time between projects to regenerate itself. Mandating at least 5 km free flowing river between any two projects as an immediate measure pending site specific studies and reviewing all under construction, under clearance and under development projects in the basin keeping this in mind.
  • Releases based on daily flows rather than monthly or seasonal averages in all rivers. Define uninterrupted flows to arrive at uninterrupted daily flows.
  • Monitoring of e-flows and other environmental compliance by independent group involving at least 50% of the monitoring group from local communities.
  • Assuring that e-flows through well designed fish passages (taking consideration of Guideline 7, Annex IX).
  • The IMG has recommended that a technical group may be made to study alternatives including the alternative suggested by Prof Bharat Jhunjhunwala that only partial dams across rivers may be allowed. This should happen expeditiously. The proposed projects should be stopped till this is done.

Himanshu Thakkar (

South Asia Network on Dams, Rivers & People (

Endorsed by:
EAS Sarma, Former Union Power Minister, Visakhapattanam,

Vimal Bhai, Matu Jansangathan, Uttarakhand,

Malika Virdi, Himal Prakriti, Uttarakhand,

E Theophilus, Himal Prakriti, Uttarakhand,

Ramnarayan K,  Save the Rivers Campaign Uttarakhand,

Dr Latha Anantha, River Research Centre, Kerala,

Parineeta Dandekar, SANDRP, Pune,

Samir Mehta, International Rivers, Mumbai,

Tarini Manchanda, Independent film maker, Delhi,


Current state of our National River at Haridwar  Photo: SANDRP
Current state of our National River at Haridwar Photo: SANDRP

[1] The author is thankful to Parineeta Dandekar, Shripad Dharmadhikary and Samir Mehta among others for providing comments on earlier drafts.

[2] Prof Bharat Jhunjhunwala provided the copy.

[3] One of the members of the IMG started discussing the report in public domain through her writings even before the report was in public domain, see: and This can create misleading impression about the report, when the readers do not have benefit of cross checking what the report is actually saying. The articles in any case are full of serious errors, for example it said: “Most of the proposed projects are run-of-the-river schemes, which are seemingly benevolent as compared to large dams”, not understanding that EACH of the so called run of the river schemes ALSO involves a dam, most of them are large dams as per international definition. It incorrectly said, “Run-of-the-river projects, which used flowing water as the raw material for energy”, in reality NONE of the so-called ROR projects generate power from flow of the water in the river, they all dam and divert the water away from the river to produce power. It also tried to dilute the impact of the projects on rivers (akin to killing of rivers) by saying projects “affect” rivers. It misleadingly wrote, “The hydropower engineers argued for 10 per cent e-flow” without mentioning that the EAC of MoEF is prescribing 20-30% of mean season flows. The article claimed that figures of water flow and tariffs were modified by IIT-Roorkee, but in the entire IMG report, (except the Annexure XI written by author of the articles), there is no mention of any of these. The article talks about engineers’ claims that “this source provides power during peak demand hours”, but as we noted above the IMG has not even looked at the impact of peaking generation. There is not even an attempt to understand how much of the current generation from hydropower projects is happening during peaking hours, or what is the generation performance of hydropower projects, issues that SANDRP has been raising for many years.

Forest Advisory Committee · Ministry of Environment and Forests · Western Ghats

How much does the Kasturirangan Committee understand about Water Issues in Western Ghats?

The Ministry of Environment and Forests constituted the Western Ghats Experts Ecology Panel (WGEEP) in March 2010 under the Chairmanship of Prof. Madhav Gadgil. The Panel submitted its report on 31st August 2011. Here on, the report was kept under wraps by the MoEF and only after strict orders from the CIC and High Court was it released to the public in May 2012.

On Aug 17, 2012, MoEF set up the High Level Working Group (HLWG) under the Chairmanship of Dr. K. Kasturirangan to study recommendations of this Report. Members of this Committee include Sunita Narain, Prof. C.R. Babu, J.M. Mauskar, Prof. Kanchan Chopra, Shri Darshan Shankar etc. The HLWG was to look into the recommendations of the WGEEP report and the comments from the various stakeholders. The very constitution of the HLWG raised suspicions that this has been formed to dilute the recommendations of the WGEEP. The functioning of the HLWG left a lot to be desired, it refused to give time to listen to the affected people at many places. On April 17, 2013, after a number of extensions, the HLWG submitted its report. 

It seems the HLWG Report (HLWGR) has worked hard to hugely dilute the WGEEP reccomendations. In many cases, HLWG report has made the recommendations of the WGEEP report ineffective. No wonder, Prof. Madhav Gadgil himself has said: “ The initial impression (about HLWG Report) is that there are differences of approach in protecting the ecology of the region. The WGEEP report talks about the facts and we have pointed out that misgovernance is a major issue affecting the ecology of the Western Ghats. This was totally neglected in the new report, which calls for more role for bureaucracy. Providing more power and money to bureaucracy is like giving it to ‘Dusshasana’, and it is a wrong approach” . (


Dilution of WGEEPs strong recommendations is highlighted in the case of 200 MW Gundia Hydel Project in Karnataka and 163 MW Athirappilly Hydel Project in Kerala. While WGEEP Report has categorically rejected these projects based on their severe impacts on ecology and communities, the HLWG has refrained from doing so. The HLWG Report has gone ahead to recommend a few largely irrelevant, measures, while actually giving OK to these projects. Whatever suggestions of review HLWGR has given, the governments would be happy to do the necessary paper work and show that they have done that. The authors of the HLWG report seemed happy to toe the lines that government wants, rather than do justice to the mandate given to them. This was unexpected as both the projects not only have severe impact on ecology, but are also facing stiff and sustained local opposition. The HLWG Report does not seem to give any value or try to understand the reasons behind these local protests.

HLWGR has certified that Athirappilly Project is required for Kerala for peaking power. This is very strange certificate. Do we have an assessment of how much of the power generation from Kerala Hydro projects (incidentally Kerala has one of the highest proportion of installed power capacity under hydro projects, compared to any other state) today is providing peaking power? None. Do we have any credible attempt at ensuring more optimum peaking power generation from existing hydro projects in Kerala? None. Do we have any credible attempt at demand side management in Kerala to manage the peak load requirements? None. Have the KSEB and Kerala government implemented the orders of the Kerala High Court while HC rejected the environmental clearance to the Athirappilly project? No. Then on what basis has the HLWGR certified that “the project’s importance for meeting the peaking power requirements of the State cannot be disputed”?

The other recommendations of the HLWGR about hydropower development in Western Ghats are also problematic. It recommends environmental flows as 30% of lean season flow for hydropower dams, rather than asking for assessment of environment and social requirements of flow in the rivers. These studies cannot be done at a later stage as indicated by the HLWG. It makes no recommendations for flows in other seasons, including monsoon. The HLWG recommends that distance between 2 hydel projects should be minimum 3 kms, again without any basis. It should have asked for site specific studies rather than making such one-size-fits-all kind of recommendation, indicating lack of understanding of environmental issues. It should have at least mentioned ‘distance of free flowing river between two projects should be three kilometre”. Even in case of ROR projects, the submergence itself stretches for kilometres. Cascade hydel dam development which is devastating the Himalayas has not started in Western Ghats. Giving a recommendation like this is in fact inviting more cascades in Western Ghats, that too in the ESA.

The HLWGR has allowed what is it calls Green Growth in the Western Ghats area. But there is no credible process suggested as to who will decide this and how? How will such a process be achieved? Where is the road map to achieve it? The government itself calls all hydropower projects as green growth projects. It is shocking to read that HLWGR also describes all hydropower projects as clean and renewable, exposing their lack of understanding of the hydropower projects and their impacts. The HLWGR seems not bothered by the adverse impacts of such projects on the Western Ghats environment, this is clear in its recommendation agreeing to green growth projects without any credible process.

The HLWG has also not rejected Inter basin transfers from Western Ghats. In doing so, they have quoted justification that “Maharashtra that Rain Shadow Regions” need drinking water. Ironically, all the inter basin transfers happening in Maharashtra (Koyana and six Tata Dams) actually involve transfers FROM the rain shadow region TO water-rich Konkan region for power generation. But the HLWG Report says nothing about this Ulti Ganga. They should have actually recommended stoppage of these diversions if they had the interest of drought prone areas of Maharashtra in mind.

The HLWG Report is also entirely silent on the need to amend the EIA Notification 2006 to include Drinking Water and Industrial Water Supply Dams and Mini Hydel Projects below 25 MW and irrigation projects with command less than 10000 ha under the purview of this Notification. This has been one of the most serious challenges faced by Rivers in Western Ghats right now and the HLWG does not comment on this. It has not commented on dams like Kalu, Shai, Balganga, Lendhi, Gargai, Pinjal, Khargihill which will have a huge impact on Western Ghats ecology and communities. The extent of this damage is evident in the fact that in a recent Forest Clearance granted to Kalu Dam, the Forest Advisory Committee has asked the proponent to follow the recommendations of the Kasturirangan Committee Report. If only the report had made strong and proactive recommendations there was a chance of saving 1000 hectares of forests of Western Ghats

The HLWGR has not commented on fisheries at all.

While a more detailed critical look at the HLWGR will take time, this compilation puts before the readers exact passages from HLWG (see Section A below) and WGEEP (see Section B that comes after Section A) Reports for ready reference. It shows how much understanding of water issues the members of HLWG have or do not have.



A. High Level Working Group (HLWG) Report on Western Ghats (Kasturirangan Committee Report)

(HLWG Report Volume I, pp. XII-XXIII)

Out of the estimated 164,280 km2 of the Western-Ghats area, the natural landscape constitutes only 41 per cent. The area identified as ecologically sensitive is about 37 per cent i.e., about 90 % of the natural landscape.

1. Hydropower

Hydropower projects may be allowed in the ESA but subject to following conditions:

(a) Uninterrupted ecological flow at least 30 per cent level of the rivers flow in lean season till a comprehensive study establishes individual baselines.

(b) After a cumulative study which assesses the impact of each project on the flow pattern of the rivers and forest and biodiversity loss.

(c) Ensuring that the minimum distance between projects is maintained at 3 km and that not more than 50 per cent of the river basin is affected at any time.

The villages falling under ESA will be involved in decision making on the future projects. All projects will require prior-informed consent and no objection from the Gram Sabha of the village. The provision for prior informed consent under the Forest Rights Act will also be strictly enforced.

The strategy evolved for the continuation of the Western Ghats Development Programme, in the 12th Plan centres around, besides watershed based development, fragility of the habitat, and development needs of the people i.e. a Watershed + approach – an approach which emphasizes conservation, minimal ecological disturbance, involvement of locals along with sustainable model of economic development and livelihood generation with enhanced allocation.

2. Power/Energy, including hydropower and wind-

(HLWG Report, Volume I, pp. 106-108)

Hydroelectric projects, proposed and planned in the forested regions of the Western Ghats have often come in for opposition. It is clear that as much as the country needs hydroelectric power, which is renewable and clean, but it also needs to balance this requirement with the loss of biodiversity in forests and the need for ecological flow in rivers. Both are essential components and policy must determine that these elements are safeguarded. It is also clear that rivers in India play more than just basic ecological functions. These are lifelines for local livelihood, nutrition and water security. The desire to use the river for generating electricity cannot be at the cost of the value of the river. It is this balance that needs to be maintained. In fact, the potential of hydroelectric power has remained the sole driver for management of the river, particularly in its upper reaches. In the lower reaches, the use of the river for large-scale water diversion projects for irrigation and industrial uses becomes the criterion for development. But these single focus objectives must be enlarged so that the competing – and often the primary needs – can be taken into account at the time of planning and management.

It is also clear that rivers do not know boundaries. Therefore, the conditions for hydropower will be stipulated for the entire Western Ghats and not just for ESA. HLWG recommends that future hydroelectric projects in the ESA and the entire Western Ghats must only be considered on the basis of the following policies:

a. Hydropower development must be based on the acceptance of uninterrupted ecological flow at 30 per cent level of the rivers flow in lean seasons till a comprehensive study establishes individual baselines. The 30 per cent ecological flow is mandated in Western Ghats keeping in mind the shorter length of rivers in this region. The compliance with this condition will require rigorous and seasonal data collection in upper reaches of rivers to prepare a hydrological mapping of the basin. It is also clear that this hydrological assessment is critical given the changes in rainfall patterns because of climate change.

b. Hydropower projects must be considered only after a cumulative impact assessment on the flow pattern of the rivers and forest and biodiversity loss. Currently, individual projects are planned and executed without consideration of these impacts. The Environment Assessment Committees will only consider proposals for individual projects after cumulative impacts have been studied.

c. Current and future hydropower development in the Western Ghats must be based on clear rules that stipulate distance between projects and that do not allow for over-exploitation of the basin. The minimum distance between projects must be maintained at 3 km in most cases (shorter distance requirement because of the short length of the rivers in Western Ghats as compared to other regions) and not more than 50 per cent of the river basin should be affected at any time. This will require reworking the current projects to provide for optimized energy generation but it is necessary given the need to balance development with ecology.

d. Better and more balanced planning for hydropower will lead correct tariff of energy, taking into account the cost of raw material of water. Energy costs, world over, take into account the cost of raw material. It is imperative that the current subsidies and distortions in raw material supply for energy are minimized. It is in this context that water, as the raw material for generation of hydropower, must be factored in the project design. The ecological, social and cultural health of the river is a price that cannot be discounted at the time of planning for the feasibility of power.

e. There is a need to redesign and reevaluate small hydropower projects – below 25 mw as these often have limited impact on energy generation and can lead to huge impacts on ecology. The rationale for small projects must be considered within a policy framework, which provides for mini-grids and local energy distribution.

HLWG about Inter-basin transfers-

(HLWG Volume-I. pp- 100-103)

WGEEP recommendations for sector level planning and their implications

The WGEEP has recommended guidelines for sector-wise activities, which would be permitted in categorized ecologically sensitive area of the region. In this way, regions with the highest ecological sensitivity would have restricted developmental activities – from a total ban on mining to large hydroelectric projects or inter-basin transfer of water and even plantations. The listing is comprehensive and provides an important direction to what will constitute environmentally sound development in this ecologically rich region. The question is how such a development plan will be implemented. Furthermore, it is also important that environmentally sound development should be incentivized and not only practiced through fiat. It is also clear that this recommendation of the WGEEP has evoked the strongest criticism from many quarters. There is apprehension that this ‘blanket prescription’ could be detrimental to economy and livelihoods.

It is also a fact that permit-based regulations are often open for misinterpretation and misuse. A similar issue was raised with the High Level Group on its visit to Maharashtra, when officials explained that there was concern that the WGEEP, if implemented could lead to complete halt of all economic activity. “It would condemn people to live in stone-age”. According to them, the guidelines would not allow for any infrastructure development, from renewable energy to inter-basin transfer of water. This would be a problem, they explained, as many regions of the Western Ghats lie in the rain shadow area and need water to be diverted for irrigation and drinking. Clearly, their concern was the impact of the sweeping nature of the recommendations on the region’s economy. It is not possible to design an effective framework for sustainable development based on such an approach. It is clear that large -scale water diversion projects, which have impacts on the environment and forests, should not be allowed. However, this recommendation should not imply that all water diversion would be stopped even without any study or scrutiny about the individual project or cumulative impact of the projects.

HLWG recommendations for two hydel projects that were categorically rejected by the WGEEP Report

  • 163 MW Athirappilly HEP, Kerala:

HLWG is of the view that while the importance of the proposed Athirappilly hydropower project for meeting the peaking power requirements of the State cannot be disputed, there is still uncertainty about ecological flow available in the riverine stretch, which has a dam at a short distance upstream of the proposed project.

It recommends that given the increased variability due to unpredictable monsoon, the project must be revaluated in terms of the generation of energy and whether the plant load factor expected in the project makes it viable against the loss of local populations of some species. Based on this revaluation and collection of data on ecological flow, the Government of Kerala, could take forward the proposal, if it so desires with the Ministry of Environment and Forests.

The HLWG along with the officials of Kerala State Electricity Board and Kerala Forest Department visited the Athirappilly Hydropower Project, after hearing the presentations made by Kerala State Electricity Board (KSEB) and also a local NGO (River Research Centre, Trissur). The team visited the dam site, the settlement of Kadar tribes impacted by the dam, rapids and waterfalls and irrigation dam site. During presentation, the KSEB explained the upstream run of the river hydropower projects – the Sholayar project on the Sholayar river which is tributary of Chalakudy river, the tail water of which is discharged into downstream that flows into Poringalkuthu project which is on the main river itself, the tail water of which is discharged into downstream of Chalakudy river and is used for the proposed Athirappilly project which is about 40 km away from the backwaters of Cochin. All these projects are run of the river projects and there are no dry stretches of the rivers. If these streams/rivers are not dammed, the excess monsoon run off cannot be stored and enters into sea within 48 hours. The average annual inflow, based on 32 years data at Athirappilly, is 1169.Mm3. This is confirmed from the flow data of Chalakudy river at Arangals collected by Central Water Commission. The tail water from Athirappilly will be released into Chalakudy via its tributary at Kannankuzhithodu.

The fluctuations in the water flow in different months and the plant load factor were also explained. The issues relating to Kadar tribal families living close to the submergible portion of the dam were explained to HLWG and it was informed that a package has been worked out for their welfare without rehabilitation as the areas inhabited by them does not come under submergible zone. The NGOs, who met with HLWG, brought to its attention that project would have irreversible impact on the rich biodiversity value of the forest; particularly, along stretch of 7.89 km between dam site and the point where the tail race water joins Chalakudy river. They said that the habitat of the Kadar tribal population would be adversely hit and that people had not yet given their consent. In addition, they said that this project, being built in an area of biodiversity value, would have minimal benefits. The technical feasibility of the project was doubtful with meager amount of power obtained at high cost. In addition, plantation owners and farmer representatives located below the proposed project said it would have adverse impacts on downstream irrigation and drinking water.

The HLWG examined the status of forests, including the riparian forests and submergible slope forest, a small swampy area and the plantations. It is clear that as in all hydropower projects, there is a need to balance the need for energy, particularly peaking power, water supply and irrigation with the loss of biodiversity, forest habitat, displacement of tribal communities and the need for ecological flow in the river.

HLGW, after detailed deliberations on each of the critical issues, is of the view that while the project’s importance for meeting the peaking power requirements of the State cannot be disputed, there is still uncertainty about ecological flow available in the riverine stretch, which has a dam at a short distance upstream of the proposed project. Given the increased variability, in flow from catchments due to unpredictable monsoon rains, the project may be revaluated in terms of the generation of energy and if the plant load factor expected in the project makes it viable against the loss of local populations of some species. Based on this revaluation and collection of data on ecological flow, the Government of Kerala, could take forward the proposal if it so desires with the Ministry of Environment and Forests.

  • 200 MW Gundia HEP, Karnataka:

As the proposed Gundya hydropower project is located in the ESA, it must be proceeded upon with extreme caution. HLWG recommends that the Government of Karnataka should reassess the ecological flow in the downstream areas, based on a thorough evaluation of hydrological regimes in the area. The project should not be given the go-ahead, till such a review and reassessment is made. The Government’s review must also assess local damage to all forests, which will emanate from the construction work and if at all, this can be mitigated. The HWLG has not proposed a complete ban on the construction of hydropower projects in the ESA, but its recommended conditions that balance the needs of energy with environment, must be followed.

Background: The Karnataka Power Corporation Limited (KPCL) has proposed a hydroelectric project in the Gundya River basin in the Hassan and Dakshina Kannada district in two phases: Phase I of 1x 200 MW and Phase II of 1x 200 MW. The project is on Gundya river – a tributary of west flowing river of Netravathi; phase I involves pooling of waters by linking Yettinahole, Kerihole, Hongadhalla and Bettakumari and water from these streams will be intercepted by small weirs and will be drawn through a tunnel running from Yettinahole leading to Bettakumari reservoir. From the foreshore of this reservoir, 7.8 km long head trace tunnel takes water to a surge tank and from there to an underground powerhouse. The Phase II will have two tunnels – one tunnel will take water from Kadumanehalla and surrounding areas by 13 km long unlined tunnel and discharge into tunnel that takes water from Yettinahole weir, and another tunnel of 15 km long will take water from Lingath hole and Kumaradhara to Bettakumari reservoir. The submergible area will be 184.64 ha. An additional 560 ha will be needed for infrastructure. KPCL is not going ahead with the Hongadhalla dam because of the extensive submergible area of 523.80 ha. The project has got necessary clearances from different regulatory agencies; EAC of MoEF has asked KPCL to conduct also public hearing in Dakshna Kannada District, as project area falls in both the districts. The public hearing was conducted at Siribagiln village of Puttur taluka on 25.03.2009. Meanwhile the Malenadu Janapara Horata Samithi made a representation before the subcommittee of EAC during its visit to the site on 5.12.2009. The EAC has recommended clearance but the MoEF has not issued the environmental clearance.

The land required for the project includes forest area of 113 ha, revenue land of 263.63 ha, which also includes forests (though mostly degraded); and 71.5 ha of private land making it a total of 448.13 ha. The site has unique forest types with high biodiversity values (endemic, rare, threatened and new species) and also the cardamom and coffee plantations with scattered forest patches, which will be impacted adversely by land use changes and changes in hydrological regimes in the river basin due to project.

The major impacts of the project would be: (i) submergence of patches of riparian forest, (ii) land degradation/fragmentation of forest patches for tunneling and road construction; (iii) the drying up of down streams of three Yellinahole (with 60.50 km2 catchment area), Kerihole (27.00 km2 catchment area), Hongadahalla (8.50 km2 catchment area) and Bettakumari (35.00 km2 catchment area) before they join Gundya river, although each of them has small catchments, and a stretch of 34 km of Gundya river; and (iv) the apprehension of shortage of water at Subramanya Swami temple.

HWLG notes that the Gundya hydel project is run of the river project, which must ensure ecological flow in the affected stretch of the river. Furthermore, while the area of the submergible portion of forest is small, the construction of the project and tunneling in the region will have adverse impacts on both government forests and green areas on private land. As the Gundya hydropower projects is located in the ESA, HLWG recommends that it must be proceeded upon with extreme caution. It would recommend that the Government of Karnataka should reassess the ecological flow in the downstream areas, based on a thorough evaluation of hydrological regimes in the area. The project should not be given the go-ahead, till such a review and reassessment is made. The Government’s review must also assess damage to all forests, which will emanate from the construction work and if at all, this can be mitigated. The HWLG has not proposed a complete ban on the construction of hydropower in the ESA, but its recommended conditions that balance the needs of energy with environment must be followed.


Athirappilly and Gundia Hydel projects

WGEEP Categorically rejects both the projects for their impact on communities and ecosystems.

Sectoral Recommendations relating to Water

Recommendations for ESZ I, II, III-

Decentralized water resources management plans at Local Self Government level Protect high altitude valley swamps and water bodies. Catchment area treatment plans of hydroelectric and major irrigation projects should be taken up to improve their life span. Improve river flows and water quality by scientific riparian management programmes involving community participation Water conservation measures should be adopted through suitable technology up gradation and public awareness programmes inter-basin diversions of rivers in the Western Ghats should not be allowed

Hydropower projects

For ESZ I-

  • Allow run of the river schemes with maximum height of 3 m permissible which would serve local energy needs of tribal/ local communities / plantation colonies subject to consent of gram sabha and all clearances from WGEA, SEA and DECs.
  • No forest clearance or stream diversion for new projects
  • Run of the river schemes not allowed in first order or second order streams
  • Promote small scale, micro and pico hydropower systems, that are people owned & managed and are off grid
  • New small hydropower projects (10 MW and below) are permissible


  • Small bandharas permissible for local and tribal community use / local self- government use
  • No new dams above 15 m or new thermal plants permissible
  • New hydro projects between 10- 25 MW (up to 10 m ht) permissible
  • All project categories subject to very strict clearance and compliance conditions through SEA and DECs of WGEA
  • Have run off the river hydropower projects but after cumulative impact study of the river basin is done


  • Large Power plants are allowed subject to strict environmental regulations including 1. Cumulative impact assessment studies 2. Carrying capacity studies 3. Minimum forest clearance (norms to be set by WGEA) 4. Based on assessment of flows required for downstream needs including the ecological needs of the river.
  • For already existing dams reservoir operations to be rescheduled for allowing more water downstream

Common recommendations for all the three zones-

  • No diversion of streams/ rivers allowed for any power projects and if already existing, to be stopped immediately.
  • Catchment area treatment in a phased manner following watershed principles;
  • Continuous non-compliance of clearance conditions for three years would entail decommissioning of existing projects
  • Dams and thermal projects that have crossed their viable life span (for dams the threshold is 30–50 years) to be decommissioned in phased manner
  • All project categories to be jointly operated by LSGs and Power Boards with strict monitoring for compliance under DECs


Recommendations for ESZ I, II, III-

  • Strictly control use of dynamite and other explosives to kill fish; provide fish ladders at all reservoirs Introduce incentive payments as ‚conservation service charges‛ for maintenance of indigenous fish species in tanks under control of Biodiversity Management Committees or Fishermen’s co-operatives; monitor and control trade in aquarium fishes with the help of Biodiversity Management Committees

Water use-

(WGEEP Report Volume II, pp. 32-37)

Water resources management in the Western Ghats region is inextricably linked to improving the flows in the rivers and the health of the catchments. Western Ghats is the origin of many of the important Peninsular Rivers like Cauvery, Krishna and Godavari that drain the Deccan Plateau and flow eastwards. The hundreds of shorter perennial monsoon fed west flowing rivers like Sharavati, Netravathi, Periyar, and the Bharathapuzha travel through steeper and more undulating topography before emptying into the Arabian Sea. A rough estimate reveals that 245 million people in the five Western Ghats states directly depend on these rivers for their diverse water needs. Geographically, the Western Ghats is the catchment for river systems that drain almost 40 % of the land area in India. The basin area of west flowing shorter rivers is mostly located on the steep western slopes. Except for a few coastal streams 1/3 rd of the basin area of most of the river basins is located within the Western Ghats. This too makes them fragile and calls for their proper care and management. Once these streams leave the Western Ghats proper, they are drained and enriched by the once fertile steep river valleys, midlands and flood plains. The coastal and backwater fisheries is sustained by the rich nutrients and sediments brought down by the flowing rivers. The musings by fisher folk in coastal Kerala: ‘The Sea begins in the mountains and ‘fertility of the coast and the plains depends on the wealth from the rivers’ holds significance in this context. Open dug wells and springs are the other important water resources being extensively used for irrigation and drinking water purposes in the Western Ghats region. In several places, water–‐ harvesting structures dependent on rainwater are also used. In the Sigur plateau, numerous drinking water schemes dependent on the Moyar River are being operated for the tribal and dalit populations. Bore wells have made their entry in the recent past due to intensive irrigation patterns and lowering of water tables. As for Kerala, the groundwater potential is low when compared to other states and shallow dug wells are the most common source of freshwater. However, over the years the groundwater table is lowering at an alarming rate indicative of poor recharging capacity. On the other hand, water needs for drinking water, energy, irrigation and industrial purposes are growing in the Western Ghats States. More and more water is being diverted even from irrigation dams to meet the thirst of the expanding urban spaces and for industries. We have examples of Siruvani, Kabini, Peechi and Malampuzha reservoirs across the Western Ghats where irrigation water is being diverted for drinking and for the industrial needs of cities in the midlands like Coimbatore, Bangalore and Mysore, Thrissur and Palakkad respectively. New dams are being planned and some of them are in different phases of construction in the Maharashtra Western Ghats to meet the expanding needs of Mumbai and its suburbs. Pinjal, Shai, Gargai, Kalu and Vaitarani dams are recent cases. Water abstraction through check dams across hill streams is being practiced for decades by tea and coffee plantations in upstream catchments of rivers to meet their drinking and irrigation needs. This has resulted in cutting off the stream flows at their origin itself. Indiscriminate and unplanned tourism is another reason for increasing water abstraction and diversion. The tourism industry in Ooty depends on the reservoirs constructed across the tributaries of the Cauvery in the high mountains since the times of the British. Studies reveal that east–‐ flowing Rivers like Krishna, Cauvery are struggling to reach the seas due to over abstraction of both surface and groundwater. Basins are closing and its impact is felt even on delta fishing, farming livelihoods and ecology. During the 2001-2004 drought years, the discharge from the Krishna to the ocean was almost nil! As for the west-flowing rivers, saline ingress is advancing even into the midlands due to reduced downstream flows. Crop losses and saline water intrusion into drinking water has been reported in Kerala during severe summer owing to salinity intrusion. In Goa, mining has affected groundwater and surface flows and drainage patterns of rivers impacting downstream needs and water quality. Tailings from mines are polluting streams and rivers. The Kudremukh mining issue is a classic case of mining- related pollution. This mountain range has a long history of human interventions and each of these have directly or indirectly impacted upon the water resources availability and recharge in the region. Some of the important interventions and issues that have had lasting impacts on water resources and its management in the Western Ghats are briefly discussed below.

Issues of Concern

Forest destruction in the river catchments

Western Ghats has a long history of deforestation. Deforestation of upper catchments of rivers for timber, river valley projects and plantations has drastically reduced the capacity of the hill streams that feed into the rivers to hold and recharge water. Drying up of streams immediately after the monsoons and desiccation related to deforestation is clearly evident. This in turn has contributed to reduced summer flows.

River management in the Western Ghats

Most of the rivers in the Western Ghats are either dammed or diverted, some of them at several sites for power generation in the upper reaches and irrigation in the lower reaches. For instance, the east–‐‑flowing tributaries of Cauvery (Bhavani, Moyar, Kabani) and Krishna (Bhima, Tunga, Bhadra) are already dammed. The west–‐‑flowing shorter rivers (Sharavathi, Periyar) have been dammed at several places. We also have complete diversion of river flows at Mullaperiyar and Parambikulam dams involving Kerala and Tamil Nadu. West-flowing rivers have been virtually made into east–‐‑flowing Rivers by violating all natural laws. Dams are without dispute the most direct modifiers of river flows. They can heavily modify the magnitude (amount) of water flowing downstream, change the timing, frequency and duration of high and low flows and alter the natural rates at which rivers rise and fall during runoff events. Severe daily flow fluctuation between peak and off peak times below dams is commonplace in west–‐‑flowing dammed rivers. This has impacted drinking water schemes, major and minor irrigation projects operating in downstream areas apart from cutting off flood plains and impacting aquatic ecology and riparian systems. However very few studies are available that correlate the reservoir operations with the different types of downstream impacts and put measures in place for mitigation. In the case of inter-basin water, no water flows or even

The Mullaperiyar dam is a classic case where the main tributary of Periyar has been completed diverted to the Vaigai basin in the east. Idukki dam does not even have a spillway for allowing monsoon spills into the river. In Maharashtra, the tail race discharges of Koyna Powerhouse I, II and III are released into the west–‐‑flowing Vashishthi River and lead to heavy floods in Chiplun. Continuous stretches of rivers have dried up irreparably below diversions affecting river ecology, surface flows and even ground water seepage. Many of the reservoirs especially in the steep valleys are silting up prematurely due to the massive encroachment and deforestation of catchments consequent to dam construction. Idukki dam is a classic case wherein the entire catchment was encroached along with dam construction. The operations of hydroelectric stations (reservoir operations) are in tune with the power needs rather than the downstream water needs. Hence daily flow fluctuations created by peak and off peak operations of reservoirs in dammed rivers have led to upstream- downstream conflicts in many river basins. Similarly diversion of flows into another river basin after power generation is creating problems of daily flood in the recipient basin and drought in diverted basins. These are turning into management issues which need to be addressed at a basin level. However, there is a lack of systematic river basin level data on ecological changes due to hydrological alterations created by dams.

Incorrect land use patterns

Mining for mineral ores, granite and lateritic mining has affected water availability and recharge especially in the lower altitude regions and midlands. In Goa alone, the government itself has acknowledged that over half of the 300 odd mining leases are located close to water bodies. Data tabled in the Goa Assembly revealed that several of the 182 mining leases exist within one kilometer of a major irrigation project, the Selaulim dam, which provides drinking water to six lakh people in south Goa, virtually half the population of Goa (Ref: Deccan Herald Article).

In South Karnataka and North Kerala, surangams, a traditional irrigation system in lateritic hills is losing out to lateritic mining. Many of the rivers in this region originate from these lateritic hills and many of the Western Ghats Rivers like Chandragiri, Valapattanam, and Netravathi benefit from the water recharged by lateritic hills in their flow downstream.

Agricultural practices including cropping patterns have a role to play in water resource management in the Western Ghats. Planting steep slopes with soil–‐‑eroding monocu;ture crops like rubber and banana, and heavy tillage, has led to increased surface runoff along with loss of precious top soil. This has contributed to low seepage and infiltration into deeper soil depths. The deforestation for tea, coffee and cardamom plantations located at higher altitudes has contributed to drying up of hill streams.

 Reclamation of high altitude valley swamps is contributing to water scarcity in the upper catchments. Many of the rivers originate from these swamps and are source of perennial flow. In the Nilgiris, most of the fertile water rich swamps have been converted for intensive pesticide-based farming, greenhouse farms, housing, etc.

Sand mining

Most of the rivers in Western Ghats are facing the consequences of indiscriminate sand mining. The lowering of water tables and deterioration of water quality are the immediate impacts. River beds in some stretches are lower than the sea level accelerating saline ingress. Drinking water scarcity is on the rise in river bank panchayats in spite of being close to the river. Plan funds are spent for providing drinking water even to panchayats on river banks. Sand mining has also impacted breeding and feeding grounds of fish and other aquatic species

Measures for Mitigation/Improvement

Time for river basin-­level planning and decentralised management of water resources in the Western Ghats As cited above, the impacts of incorrect land use and interventions are already evident. Reduced summer flows, flow fluctuations, lowering of water tables and degrading water quality are all direct impacts of the presently followed project–‐‑oriented, demand-supply based and ad hoc approach to water resource planning and management. The time is ripe for a paradigm shift in approach to river basin–‐‑level management of water resources where water is considered an integral part of the ecosystem. Some important measures that can be adopted in this regard are briefly detailed.

1. Local self–‑ government level decentralized water management plans to be developed at least for the next 20 years: Water resource management plans with suitable watershed measures, afforestation, eco–‐‑restoration of catchments, rainwater recharging and harvesting, storm water drainage, water auditing, recycling and reuse etc. should be built into the plans. These water management plans should integrate into basin level management plans. The objective is to reduce the dependence on rivers and external sources and to improve recharge.

2. Reschedule reservoir operations in dammed rivers and regulate flows in rivers to improve downstream flows and also to act as a conflict resolution strategy. These should be implemented with an effective public monitoring system in place.

3. Revive traditional water harvesting systems like recharge wells, surangams, etc.

4. Protect high altitude valley swamps that are the origins of rivers from further reclamation and real estate or agricultural development and declare them as ‘hotspots for community conservation’

5. Participatory sand auditing and strict regulations to be put in place.

6. Declare “sand holidays’ based on assessments and sand audits for mined river stretches. Items 5 and 6 would work to improve the water retention capacity in the river.

7. Rehabilitation of mined areas to be taken up by the companies / agencies with special focus on reviving the water resources like rivers, wells, tanks, etc. that have been destroyed by the mines.

8. Planters, local self–‐‑governments and Forest Departments in high altitude areas should come together for eco–‑restoration of the forest fragments between the tea and coffee estates and revive hill streams.

9. Take up catchment area treatment plans of hydro and major irrigation projects to improve their life span.

10. Riparian management can be taken up with community participation and involvement to improve river flows and water quality.

11. Water conservation measures should be adopted through suitable technology upgradation and public awareness programs.

12. Reconnect children and youth to rivers and water resources through basin level education programs.

Actionable points for the WGEA-

The (proposed) Western Ghats Ecology Authority (WGEA) can take a strong recommendatory and advisory role in this regard. Some of the important recommendations for WGEA are:

1. Declare origins of rivers as Ecologically Sensitive Localities (ESLs) (the catchment area)

2. Many projects in the Western Ghats are on–‐‑going or completed with violations in environmental clearance and forest clearance or even no clearances at all, as in the case of the Kalu and Shai dams in Maharashtra. The WGEA should act as an additional layer for screening projects approved by the Expert Appraisal Committees (EACs), subject them to additional scrutiny in terms of the geographical context, ecological sensitivity, status of river basin and need for environmental flows taking into consideration all season flows instead of ad hoc allocations.

3. Till the WGEA comes into operation, issue a moratorium on all on–‐‑going projects like dams and mines that can impact upon water resources in a substantial way. The WGEA should subject the projects to scrutiny for mandatory clearances and compliances, and augment the level of public consultation before deciding on whether to allow them to progress or not.

4. No more inter–‐‑basin diversions of rivers shall be allowed in the Western Ghats.

5. Take up sample river basins in each state and recommend to the State Governments to carry out:

  • Environment flow assessments involving social movements for river protection, research institutions, NGOs along with communities to put in place indicators for environmental flow assessment
  • Assessment of downstream impacts of dams on river ecology, flood plains, fishing habitats, livelihoods, etc.
  • Salinity intrusion mapping so as to suggest improved flows in future
  • Improve reservoir operations management in dammed rivers to improve meeting of water needs of downstream populations. Put proper monitoring of reservoir operations in place involving downstream local self–‐‑governments and departments.
  • Update and upgrade hydrological databases in rivers and consolidate the ecological database and information at river basin level
  • Based on the consolidation of databases, declare high conservation value stretches of rivers as ESAs and keep them free them from further development.

6. Recommend to State Governments to take up decentralized bottom􀈮up river basin planning with restoration built into the plans.

7. River Basin Planning should be supported by suitable legal institutions that are capable of integrating different departments which are presently dealing with or impacting on the rivers in a compartmentalized manner. Put in place river basin organizations adapted to state administrative context.

8. All new projects in the Western Ghats (dams, mines, tourism, housing, etc. that impact upon water resources) should be subject to cumulative impact assessment and should not exceed the carrying capacity.

9. Stronger and stricter laws for regulation of sand mining to be developed

10. Recommend the decommissioning of dams that have outlived their utility, are underperforming, and have silted up beyond acceptable standards, etc.


 (WGEEP, Volume II, pp. 48-49)

Depletion of the fishery resources is a serious issue in the Western Ghats region. Compared to marine fish resources / biodiversity, the freshwater fish diversity is on the decline due to various reasons. Traditionally the conservation and management of fishery resources were vested with local communities, but this has now been altered. Several innovative measures are required to revive this highly valued resource and to use it in a sustainable manner on account of its relevance in livelihood improvement and food security. There is a need to readdress these issues with the fisheries department and other impacting sectors to reorient conservation measures in a participatory mode. Furthermore, local fish consumption has been a traditional source of protein for local people from time immemorial.

Issues of Concern

  • Habitat loss, including loss of mangroves
  • Pollution due to pesticides, industrial effluents/other sources
  • Waste dumping in rivers
  • Improper river maintenance and management
  • Unscientific methods of collection (use of poisons, electro–‐‑fishing, dynamiting etc.)
  • Impoundments in rivers, check dams
  • Introduction of exotic fishes
  • Destruction/loss of breeding grounds
  • Fish diseases
  • Overexploitation
  • Unauthorised ornamental fish trade
  • Sand mining
  • Excessive tourism activities in freshwater lakes
  • Decline of indigenous species due to introduction of exotic and alien fishes species

Measures for Mitigation/Improvement-

  • Regular monitoring of fish wealth to assess the health/ diversity of the fish population.
  • Banning the use of plastics which settle at the bottom of water bodies and lakes and affect breeding of some species.
  • Management measures aimed at conserving freshwater fish biodiversity to be incorporated into the fishery policy.
  • The database on population size and geographical distribution of endangered and endemic species should be strengthened by undertaking extensive micro–‐‑geographical surveys. Information on area of distribution and micro–‐‑geographical characteristics of the habitats of these ecologically sensitive fishes will be inputs for establishment of aquatic reserves for the conservation of these species.
  • Information regarding migration, breeding behavior and spawning grounds of threatened fishes should be generated through extensive surveys and analysis. Such a database is essential for both ex situ and in situ conservation of the species.
  • Techniques should be developed for the captive breeding and brood stock development of fishes of potential economic importance.
  • Brood stock maintenance centers and hatcheries should be established exclusively for indigenous, endangered and critically endangered fishes for their in situ conservation and aqua ranching as a substitute for their natural recruitment.
  • Investigation on the invasive nature of exotic species in the natural habitats should be carried out. The functioning of the committee constituted under the Government of India to quarantine and control introduction of exotic species should be made more effective and foolproof.
  • Strict vigilance and monitoring, including enforcement of laws, to be ensured to reduce the loss of the natural breeding grounds of the fishes arising from reclamation of paddy and wetlands.
  • Strengthen awareness programs to ensure the sustainability and survival of fish resources.
  • Regulation on fishing, during breeding seasons in freshwater environs to restore natural/ wild stock
  • Establishment of fish sanctuaries
  • Sand mining and other activities which destroy the habitat of many endemic fishes to be restricted.
  • Live–‐‑fencing using native plant species instead of stone walls to be encouraged for protecting river banks.
  • River Management Funds to be utilised for activities related to river health programs and not for construction or other developmental activities.
  • Regulation of ornamental fish collection from the wild.

Compiled by Damodar Pujari, SANDRP (


Build them Higher and Higher!!

This week, there was news that Nepal and India have agreed to ‘strengthen’ the embankments on shared rivers like Bagmati, Kamla and Khando in a bid to control floods. “Both the countries have already agreed to strengthen embankments of Bagmati, Kamla, Lalbakeya and Khando rivers and extend the embankments along these rivers to higher ground in Nepal to control spilling of flood water,” Water Resources Minister Harish Rawat said” (

Now while we are busy building our embankments higher and higher, one of the most flood prone country in the world: The Netherlands is doing something drastically different. Through its ‘Room for the River’ Program, Netherlands is actually leaving spaces for floods to spill, and minimise the damage, rather than building higher and higher embankments.roomfortheriver1

“After 800 years of building dikes, we’ve been making them higher and higher,” said Gert-Jan Meulepas, project manager at Royal Haskoning, an engineering and environmental consultancy that developed the project. “But if something goes wrong, the damage will be greater.” (


With Climate Change and extreme weather events a reality, the focus in Europe and America has shifted from making ‘Zero Failure’ infrastructure to infrastructure that is ‘allowed to fail’ with other protective measures in place like flood dissipation, protected floodplains, alert disaster management, etc. “Designing projects so they are safe to fail,  is often cheaper and more efficient, Kirshen believes. A community might opt to build a dam designed to contain up to a 100-year flood, then develop a comprehensive evacuation plan for the surrounding area in the event of a more severe flood. This strategy anticipates that the dam may not control extreme flooding, but adds other protective measures for higher levels of safety.”

One of the best examples of this flexible management is the Yolo Bypass in the Sacramento Basin in California. Yolo Bypass actually accumulates floodwaters in case of extreme floods and is used by water fowl and wildlife. It is the largest public/private restoration project west of the Florida Everglades. The entire bypass forms a valuable wetland habitat when flooded during the winter and spring rainy season. In the summer, areas of the bypass outside the wildlife areas are used for agriculture.(



India and South Asia on the other hand, though facing severe threats from climate change and floods and with a history of embankment breaches are refusing to learn lessons. The recent discussion about strengthening embankments between India and Nepal seems to be  a result of this mindset which is not flexible to include ecosystems, goods and services of floodplains and climate change challenges.Image

Shri. D. K. Mishra jee has written extensively about embankments and floods in Bihar. His latest book on Bagamati:




Freshwater Biodiversity Conservation finds place in Indian Biodiversity Congress!

IBC Recommendation to MoEF: Safeguarding Riverine Biodiversity and ecosystem goods and services of rivers and inland water bodies

Dams, hydropower projects, diversions and hydrological modifications to rivers and inland water bodies are having a huge negative impact on biodiversity and dependent livelihoods across India. Biodiversity Assessments for such projects is nonexistent or fundamentally inadequate or flawed including in in ecological hotspots like Himalayas and Western Ghats. Environmental Impact Assessments are severely flawed. Credible mitigation measures for endangered, threatened, endemic or rare fish and other biodiversity are not in place, even Endangered and iconic species like Ganges River Dolphins are under threat from absence of flows in the downstream and hydrological obstructions. Downstream impacts are neither part of social impact assessment nor part of resettlement and rehabilitation measures. All these  gaps are leading to incremental, cumulative negative impacts on biodiversity and local communities which depend on riverine biodiversity for their livelihoods.

IBC recommends that:

  • EIA notification 2006 should be amended urgently to include all hydel project above 1 MW capacity, all large dams including those for drinking water, industrial use, irrigation above 1000 hectares and flood control structures under its purview
  • Cascade of Hydropower dams in any river basin, including in the Indian Himalayas and Western Ghats should be reviewed, cumulative impact assessment including carrying capacity and river basin studies should be mandatory. No further projects should be considered before such studies in any basin having two or more projects. The studies should be done by credible independent agencies having no conflict of interest.
  • Recommendations of studies like Wildlife Institute of India’s report on Cumulative Impacts of Hydel Development on terrestrial and aquatic ecology of Alaknanda and Bhagirathi Basins should be accepted and 24 hydel projects should be immediately scrapped for their irreversible negative impacts on biodiversity, as recommended by the WII study.
  • Process of Environment Impact Assessments should be made stringent, consultants with conflict of interest should be blacklisted. More scientific inputs and peer reviews should be brought in these studies.
  • Participatory Studies about environmental flow requirements of rivers, free flowing distance of rivers between two dams (should be more than 5 km as suggested by additional chief secretary of Himachal Pradesh in a report to high court) and downstream impacts of dams should be undertaken by the MoEF with participation from scientists and communities across the country. In the absence of these studies, more projects should not be sanctioned.
  • Fish Diversity and dependent livelihoods of inland fisherfolk are being greatly jeopardized by current dam development, in the absence of any mitigation measures. We urge the MoEF to undertake studies about efficacy of current fish farms and hatcheries, studies on fish ladders and passes and impacts of dams on fish diversity in India and not sanction new dams in areas of great fisheries diversity like Western Ghats and Indian Himalayas in the absence of mitigation measures and studies
  • Dams affecting community conserved areas and conservation reserves should be scrapped like 780 MW Nyamjangchhu Project in Arunchal Pradesh affecting last wintering sites of Black-necked Cranes, a community reserve.
  • Free-flowing rivers of India need legal protection as reservoirs of rare biodiversity.
  • Ramsar and other wetlands should get legal protection from impacts due to upstream abstractions.
  • In every state and ecological zone, certain rivers should be left as no go zones for dams and hydropower projects.
  • Community conserved riverine stretches and community fish sanctuaries should get legal protection.