NIH Roorkee’s Workshop on Eflows: Where is the credibility?

National Institute of Hydrology (NIH), Roorkee, an organisation under Union Ministry of Water Resources (MoWR) is organising a workshop on Assessment of Environmental flows (E-flows) in Rivers in Roorkee on the 2-3 October 2013.

Any serious engagement with e-flows, from any quarter is a welcome sign. However, NIH’s engagement with eflows is a bit ironic, looking at its past work and support for hydroelectric and large infrastructure projects, without any consideration for environmental flows.

Not surprisingly, NIH has refrained from inviting almost any voices that have been critical about MoWR’s Large Dam agenda. On the other hand, main ‘stakeholders’ invited are representatives from Hydroelectric dam projects! Expectedly, the workshop is looking at environmental flows in a role adversarial to “development”, without understanding the role the rivers play in a society. In fact there is no session on value of rivers, which forms the basis of the concept like eflows.

Let us have a quick look at NIH’s track record and its response to the concept of eflows so far.

Following the Uttarakhand Disaster, Supreme Court on the 13th of August, 2013 said in no uncertain terms that the Cumulative Impact Assessment Study done by AHEC, Roorkee on Upper Ganga Projects “has not made any in-depth study on the cumulative impact of all project components”, practically rejecting AHEC Study. Even the members of the MoEF’s (Ministry of Environment and Forests) EAC (Expert Appraisal Committee) on River Valley Projects have said that e-flows estimated in the AHEC report are unclear. Inter-ministerial Group Report (The BK Chaturvedi Committee) on Upper Ganga Projects has rejected most of the AHEC recommendations for eflows.

National Institute of Hydrology, Roorkee (NIH Roorkee) was a part of the study team of the AHEC Report on Upper Ganga[I] and hence, what this SC order and other agencies have said about AHEC report applies to NIH too.

NIH is supposed to be India’s premier institute on hydrology, but a closer look at the research and projects its done so far makes it clear that NIH is a also an integral part of the lobby that pushes large dams as the only solution to all of India’s water-related problems. The lobby includes the Ministry of Water Resources and the Central Water Commission. These organisations form an integral part of NIH’s organisational structure. Chairman of the governing body of NIH[II] is Secretary, MoWR. Its members include MoWR Joint Secretary and planning commission members. Its Standing Committee is comprised exclusively of MoWR representatives.

NIH introduces Environmental Hydrology as its area of specialisation. One of its tasks is[III] “Estimation of surplus and deficit water availability considering water demand and available water supply”. This concept of surplus and deficit has been used to support Interlinking of Rivers, which is ecologically one of the most destructive water projects in India. This too is explicitly supported by NIH. Note that while doing the studies related to ILR, NIH has assumed NO water for the environment!

It has estimated[IV], “In India, the estimates put a requirement of 10 BCM (billion cubic meters) for the year 2025 and 20 BCM for the year 2050 for EFR purpose.” This estimate, coming from an institute which is supposedly India’s Premier institute on hydrology lacks any ecological, social and scientific justification.

NIH’s thrust on ‘Water Resource Projects’ is so strong that its ‘water resources section’[V] pushes projects like the 2000 MW Lower Subansiri HEP, in Brahmaputra basin, without even mentioning that work on the project has stalled since Dec 2011 and  it is facing the biggest anti dam protest in India, mainly due to downstream impacts and non-transparent decision making processes.

As hydropower projects are being built in cascades in vulnerable regions, NIH has been conspicuously absent from the discourse. It has not taken a stand about e-flows, distance of free flowing rivers between projects and other environmental measures when hydropower projects are being built from Kashmir to Arunachal Pradesh with high disaster potential. On the other hand, through its studies like GLOF Analysis for Jelam Tamak Hydropower project [2] in Alaknanda basin in Uttarakhand, NIH has been largely supporting these projects, underplaying their impacts.

In fact, NIH did a eflows study for Loharinagpala HEP in Bhagirathi, where it assumed that Bhagirathi is a highly degraded river and recommended that 10% MAR will suffice as e-flows[VI], using the Tennant Method. Bhagirathi, which is hailed as the original stream of Ganga is not a ‘highly degraded’ river by stretch of imagination upstream of Maneri Bhali projects, but it will be ‘highly degraded’ if projects pushed by institutes like NIH are implemented. Significantly, Loharinagpala HEP was scrapped because of issues related to e-flows and aviral dhara of Ganga.

Strangely, NIH workshop on Assessing E-flows program starts not by addressing the importance of e-flows, but by stressing the importance of dams! The first session will be on Water Resources Development in India – need for power, irrigation, water supply and dams, to be conducted by NIH itself. It seems that this workshop is an attempt to get more eflows consultancies from private and government hydel projects.

Groups like WAPCOS (also a MoWR institute) and CIFRI have been churning out studies after studies with shoddy analysis and wrong biodiversity assessments, helping the project proponents and destroying the river further. However, communities, groups, and even judiciary are now putting its foot down about these shoddy studies.

NIH should realise that eflows are not one more of their studies which can be carried out excluding wide range of stakeholders: from communities to ecosystems. NIH has poor track record on eflows and it will have to do much more than organising workshops on eflows, if it is looking to establish its credibility on the issue.  


[1] Environmental flows or E-Flows are defined as: ‘Environmental Flows describe the quantity, quality and timing of water flows required to sustain freshwater and estuarine ecosystems and the human livelihoods and well-being that depend on these ecosystems.” (Brisbane Declaration 2007)

[2] which has been rejected by Wildlife Institute of India and even BK Chaturvedi committee has suggested that the project should be taken up only after Ganga Basin Management Plan from IIT Consortium

[VI] “The E-Flow value computed by the Tenants method, considering it as 10% of the MAR, is 3848 Cumec Days for a calendar year” (NIH: Concluding Remarks No 10): Source: Dr. Bharat Jhunjhunwala’s Letter to IITR xa.yimg.com/kq/groups/8723444/2093659328/name/iitr

Expert Appraisal Committee · Hydropower · Ministry of Environment and Forests

EAC’s norms for Eflows need to Change: Submission from civil society

The following submission has been sent to the Expert Appraisal Committee, River Valley and Hydro Power Projects, Ministry of Environment and Forests, India. The current norms recommended by EAC while clearing hydropower and irrigation projects are hardly leaving any water for the rivers (eflows), thereby destroying rivers as well as livelihoods.

  Norms on e-flows followed by EAC need to change

 Respected Chairperson and members,

As you know, the Inter ministerial Group on Ganga Basin was constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012. It has subsequently submitted its report to the MoEF in April 2013.

While there are several issues about IMG’s report and recommendations, some of the recommendations are the minimum, urgent stop gap measures that need to be implemented by the EAC. IMG’s recommendations are relevant for nearly all rivers across the country. All of the rivers have rich social and religious values and a large proportion of population depends on them for livelihood. Hence, the recommendations of IMG logically apply to all the rivers. In line with the IMG Report recommendations, we urge the EAC to modify its recommendations about eflows and environmental impacts as suggested below:

1.           Eflows

a.           Eflows to be based on daily uninterrupted flows, not seasonal flows

The IMG report states that: “An important component of the e-flows regime has to be mimicking of the river flows so as to keep it very close to the natural flows. Cumulative norms even on seasonal basis do not meet this objective. Daily inflow norms may, however, enable a sustained river flow as well as have large flows in the high season and hence are more suitable.” (emphasis added)

IMG has thus recommended that all dams and hydro projects should release water based on daily inflows, following the % releases recommended in each season, but the releases must change as per daily inflows.

 b.           Eflows as 30-50% of daily lean season flows

The IMG report recommends that releases should be 50% of lean season flows where average lean season flow is less than 10% of the average high season flow. Where average lean season flow is 10-15% of the average high season flows, the releases should be 40% of inflows and where 30% for the rest of the rivers.

In keeping with IMG recommendations, we urge that the EAC should be recommending 50% average daily flows in lean season as eflows.

c.           Independent, community-based monitoring of Eflows releases

Monitoring of eflows releases from operating projects is crucial, given the fact that it is currently entirely in the hands of the proponent without any monitoring of compliance by the MoEF. In such a situation, proponents are not releasing any eflows as pointed out by the one person Avay Shukla Committee Report, recent CAG report of Himachal Pradesh.

IMG recommends: The IMG has considered the need for an effective implementation of the e-flows as cardinal to its recommendations. It is recommended that the power developer must be responsible for developing a monitoring system which is IT-based and gives on a real time basis the flow of water in the river, both at the inflow and in the outflow after the river gates in the river stream. This should be

(a) monitored by an independent group

(b) reviewed yearly by the Ministry of Environment and Forests in the first five years and

(c) put in public domain the e-flows. This real time public monitoring of e-flows will be the key.

We urge that that EAC recommends similar monitoring norms for all projects. Effective monitoring cannot be done if local affected population is not a part of this process, hence, in addition to above points, EAC should recommend that eflows should be monitored by an independent group which has at least 50% participation of downstream communities facing the impacts of these projects.

d.           Assessing eflows only through participatory and true Building block Methodology (BBM)

The IMG states: “Considering environment, societal,  religious needs of the community and also taking  into taken in to account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirements on a long-term basis. This recognizes the fact that the riverine species are reliant on basic elements (Building Block) of the flow regime, including low flows, and floods that maintain the sediment dynamics and geo-morphological structure. It also includes an understanding of the functional links between hydrology and ecology of the river systems.”

However, the EAC is accepting any eflows assessment as BBM, simply looking at the label provided by EIA consultants, without applying its mind. We have pointed out that BBM purportedly used by consultants like WAPCOS in Lohit Basin Study is not BBM in any sense.

We urge the EAC to:

·                     Recommend methodology of BBM assessment clearly at the time of granting TORs (This is available from WWF or here: King, J.M., Tharme, R.E., and de Villers, MS. (eds.) (2000). Environmental flow assessments for rivers: manual for the Building Block Methodology. Water Resources Commission Report TT 131/100, Pretoria, South Africa. ),

·                     Recommend sectors which should be included in BBM study of a specific river (downstream users, fishermen, geomorphology experts, ecologists, etc.) clearly at the time of granting TOR. Downstream users should form a part of the BBM Group in all circumstances.

·                     Check whether these sectors are duly represented in flows studies

And only then accept the study as being based on BBM methodology. The current practice of EAC of accepting any shoddy assessment as BBM is serving neither the rivers, nor the communities, nor is it expanding India’s experience with BBM.

e. Release of Eflows

It is not just how much the releases are, but how the releases are made that decides if the releases are useful for the rivers, biodiveristy and the society. Unfortunately, EAC has given no attention to this issue.

In this context, one of the guideline of the IMG says, “Fish passes may be made an integral part of hydropower projects. Regular monitoring for their effectiveness be done by project developers.”

EAC should follow this and make well designed eflow release mechanism mandatory part of the EIA study and post-construction monitoring.

2. Free flowing river stretch between projects

Currently, the EAC has a very lax norm of recommending 1 km distance of the river between two projects. In many cases, the EAC is not following even this minimalist distance criterion. Nor is it following recommendations of civil society, or expert committees of having minimum 5 kms of free flowing river before it meets the downstream project/submergence.

In this regard, the IMG notes “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.” 

The EAC should include, as part of EIA and TOR a detailed study of:

·                     “Time” required by the river between two projects to rejuvenate itself and how much distance the river need to have such time to rejuvenate itself.

·                     Ecology (including livelihood fisheries) downstream of a project and how it will be affected by modified flows while granting TORs to hydro projects.

·                     Social and cultural use of the river downstream the project: presence of religious sites, river sanctuaries, etc. while granting TORs to hydro projects.

Based on this, the EAC should recommend distance of free flowing river that needs to be maintained downstream a specific project. This should be applicable even if this was not stated at the time of deciding TOR.

3.           Recommend Free flowing and Pristine rivers in all basins

World over, there exist norms and laws to protect free flowing rivers as “Pristine, Wild or Heritage Rivers”. EAC has been recommending damming most of the rivers in the country in the recent years. The EAC should recommend that some rivers should be maintained in their pristine, undammed (or with the current stage of development, no further) condition.

In fact, the IMG has specifically recommended: “ The River Ganga has over a period of years suffered environmental degradation due to various factors. It will be important to maintain pristine river in some river segments of Alaknanda and Bhagirathi. It accordingly recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, AssiGanga, 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.”

Unfortunately, currently the EAC is actually clearing projects when Cumulative Impact Studies or Basin Studies on such rivers are not completed or are on-going (Example: Chenab Basin Projects, Satluj Basin Projects, Lohit Basin Projects). We have pointed this out to the EAC on number of occasions, without any response.

We urge the EAC to recommend a few ecologically and socially important rivers in each basin as pristine rivers, to be protected from any projects at the time of clearing basin studies or cumulative impact assessment studies. At the same time, the EAC should analyse the present development stage of a basin while clearing specific projects and should recommend some rivers in pristine state. In places like North East India and western Ghats, certain river basins may need to be left in pristine state.

 4.           Recommendations to the MoEF about eflows from existing projects

The IMG has made a clear recommendation in this regard: “The suggested e-flows should be applicable to the existing power projects in operation in these States.” IMG has given maximum of three years for the projects to achieve e-flows.

We urge the EAC to make a recommendation to the MoEF to look at existing projects and recommend eflows norms on the same lines as those for new projects in time bound manner.

As the World Environment Day is drawing close, we are sure that the EAC will look at its role of protecting the Riverine environment and communities and will take proactive steps in this regard.

Looking forward to your point-wise response to the issues raised above.

Thanking you,

Yours Sincerely,


Himanshu Thakkar and Parineeta Dandekar, 

South Asia Network on Dams, Rivers and People (ht.sandrp@gmail.comparineeta.dandekar@gmail.com)

Samir Mehta, 

International Rivers (samir@internationalrivers.org)

Dr. Latha Anantha, 

River Research Centre, Kerala (rrckerala@gmail.com)