Ministry of Environment and Forests · Uttarakhand

Uttarakhand Disaster: MoEF should suspend Clearances to Hydropower projects and institute enquiry in the role of HEPs

Letter to MEF:

Suspend ECs to Hydropower Projects in Uttarakhand

Institute independent enquiry into the role of HEPs in increasing the disaster

in Uttarakhand

July 20, 2013


1. Union Minister of State (IC) of Environment and Forests

Paryavaran Bhawan, CGO Complex,

Lodhi Road, New Delhi11003

2. Secretary,

Union Ministry of Environment and Forests

Paryavaran Bhawan, CGO Complex,

Lodhi Road, New Delhi11003

Respected Minister and Secretary,

Sub: Suspend ECs to Hydropower Projects in Uttarakhand

Institute independent enquiry into the role of HEPs in increasing the disaster

in Uttarakhand

1. Uttarakhand Disaster and Hydropower projects It is now beyond doubt that existing and under construction hydropower projects in Uttarakhand have played a significant role in increasing the proportions of disaster in Uttarakhand this June 2013. Here are a few examples just to illustrate:

Þ    Srinagar HEP This 330 MW project under construction had been illegally dumping the muck into the river or piling heaps on the slope without an adequate retaining wall. Moreover, it is learnt that the project closed the gates of the dam on the evening of June 16, 2013, but opened them up suddenly in the early hours of next morning, which led to flooding of hundreds of houses and buildings in the downstream Srinagar town. The piled muck heaps were washed into the town.  The town was submerged in not only water, but also 10-30 feet of muck. The project itself has suffered damages.

Þ    Singoli Bhatwari and Phata Byung HEPs on Mandakini river The 99 MW Singoli Bhatwari and the 76 MW Phata Byung HEPs are both under construction projects on Mandakini river in Rudraprayag district. Both projects have been illegally dumping muck along the river banks, which was carried by the river to the downstream villages and towns upto Rudrapayag and beyond. Both the projects have suffered severe damages. Water levels in the MandakiniRiver rose 30 to 40 feet at various locations, destroying roads, private and public properties. All bridges downstram of the S-B project were washed away snapping links across the river and causing enormous hardships to the local people, rescue, relief anf rehabilitation efforts.

Þ    Vishnuprayag HEP on Alaknanda River The operators of the 400 MW project did not open the gates in time, leading to the reservoir behind the gates filled with boulders, see before and after photos at: The river than bypassed the project and created a new path as can be seen in the photos, firstly, creating a huge flash flood in the downstream area and also eroding the banks and the road. Lambagad market and  Govindghat township have suffered massive destruction of private property and public property, including the bridge to the Hemkund Sahib trek, endangering the lives of pilgrims and tourists.

Þ    Maneri Bhali I and II Due to lack of protection wall and lack of timely opening of the gates, the people residing on the banks of the project suffered huge flood disaster, large number of houses were washed away and lives lost. Maneri Bhali I is itself damaged and yet to start generation, even Maneri Bhali II started generation only after July 12, 2013.

Þ    Dhouliganga HEP This 280 MW Dhouliganga HEP of NHPC is also being held responsible for floods in the downstream area, the power house of the project itself was submerged and project is yet to start generation.

Þ    Small HEPs A large number of small HEPs have suffered damages and are also being held responsible for increased disaster impacts. Such projects include 4 MW Kaliganga I and 10 MW Kaliganga II, 9.5 MW Madhyamaheshwar HEP, 5 MW Motighat HEP, Assiganga I and II HEPs, among others. We have been urging the MoEF to amend the EIA notification to include all hydro projects above 1 MW under category B1 so that they all have EIAs, EMPs, ECs, EAC sanction and public consultation process. Kindly make this change urgently.

For further details about existing, under construction and proposed hydropower projects in Uttarakhand, see:

2. List of Uttarakhand Hydropower projects with EC on the MoEF webiste As per the legal norms under the EPA 1986 and EIA notifications of 1994 and Sept 2006 (both are relevant since some of the projects got clearance under earlier notification), the developers are supposed to send six monthly compliance reports to MoEF and it is also legal obligation of MoEF to put such compliance reports on the MoEF website, see section 10(i) and (ii) of the EIA notification of Sept 2006. It is very important to note that these reports are supposed to reflect the extent to which the projects are complying with the conditions of environment clearance and environment management plans. These reports are an important mechanism for MoEF to know about the status of compliance of the projects. A perusal of the Environment clearance site of the MoEF (See: and looking for the Uttarakhand river valley projects granted Environment clearance, we find that the site displays a list of seven hydro projects, in which since Srinagar project figures twice, the site effectively contains only six names. In the first place this is the first illegality of MoEF, since this is not a complete list. To illustrate, the 76 MW Phata Byung HEP under construction on Mandakini river does not figure on this, there are other projects too that does not figure on this list. We urge MoEF to kindly put up the full list here and also fix responsibility for this legal lapse for not putting up full list.

3. Compliance reports of Under Construction of HEPs not available Since full list of under construction HEPs of Uttarakhand is not displayed on MoEF website, the MoEF is also unable to fulfill its legal duty of putting up compliance reports. Even among the project displayed on the MoEF website, latest compliance report is available only for one project, namely Singoli Bhatwari HEP (it is file of massive size at 30 MB, most people wont be able to download this, MoEF should ask for file size of 1 MB or below and upload them in smaller size segments). So for the rest of the projects there is no compliance report on the MoEF website. This is clearly a serious violations on the part of the MoEF and MoEF needs to urgently hold accountable those who are responsible for this serious legal lapse. The MoEF also needs to take urgent action against those that have not submitted the reports as required, suspension of their environment clearance can be the first step.

4. Suspend Environment Clearance of the projects prime facie responsible for disaster damages MoEF should urgently suspend environment clearance of those projects that have been found to be prime facie responsible for the damages. We urge MoEF to suspend the clearances of following projects: Singoli Bhatwari, Phata Byung, Srinagar (all under construction projects), Vishnuprayag, Dhouliganga, Maneri Bhali I and II (all operating projects), for the reasons described in para 1 above. As a direct consequence there off, MoEF should also ask these projects to suspend their work including repair and reconstruction work till further orders. These are also required from the point of view of future safety of the downstream people and areas and also revisit the features of the projects from this perspective.

Such suspension is also necessary since the projects need a review considering that following issues have not been considered by giving clearances to the projects:

1. Change in climate due to HEPs leading to, among other changes, more erosion and landslides, more irregular rainfall patterns, more violent cloudbursts.

2    Inadequate assessment of landslide impacts of the project by GSI and MoEF.

3    The only norm for use of explosives has been made by Director General of Mines Safety for mines and pucca houses. These norms are being mindlessly applied to the fragile Uttarakhand hills and structures there.

4    Impact on forests of explosives via (1) losening of soil; (2) depletion of aquifers.

5    Impact on global warming by deforestation and depletion of aquifers.

6    Impact of project on disaster potential and implied cost of disaster.

7    Reservoir Induced Seismicity. NCSDP only looks at the safety of the dam structure. There is not agency that looks into the impact on the area, including hills, forests, water sources, houses and other structures.

8. The performance of the projects in view of changing climate, receding glaciers, possibilities of increased flashfloods, landslides and so on.

5. Institute credible, independent enquiry MoEF should urgently institute credible, independent enquiry into the disaster impacts due to the wrong and illegal functioning of the projects mentioned in first para above, including the impacts on people, their lives and property, on the property of the state and other institutions. This should be done on urgent basis so that an assessment of the existing situation can be done urgently before the ground realities change significantly and while the memory of the events are fresh in everyone’s mind.

6. Change EIA notification to include all hydro projects above 1 MW As noted in last bullet points in para 1 above, we urge the MoEF to amend the EIA notification to include all hydro projects above 1 MW under category B1 so that they all have EIAs, EMPs, ECs, EAC sanction and public consultation process.

7. Change EIA notification to include commissioned projects to send six monthly compliance reports and also undergo 5 yearly review For example, in US, the Federal Electricity Regulatory Commission has detailed regulations as to what happens once a project undergoes such emergency situation, see: This includes, “Every 5 years an independent consulting engineer, approved by the Commission, must inspect and evaluate projects with dams higher than 32.8 feet (10 meters), or with a total storage capacity of more than 2,000 acre-feet (2.5 million cubic meters)… The Commission staff also evaluates the effects of potential and actual large floods on the safety of dams. During and following floods, the Commission staff visits project dams and licensed projects, determines the extent of damage, if any, and directs any necessary studies or remedial measures the licensee must undertake.”

Most hydropower projects of Uttarakhand would come under above description and MoEF as a regulator should be following similar review process for all projects sanctioned by it every five years and also ensure that even projects once commissioned also send six monthly reports to MoEF ensuring compliance of the norms. Such a mechanism has also been recommended by the BK Chaturvedi committee.


Hence we urge MoEF to urgently review the EIA notification to ensure submission of six monthly compliance reports for commissioned projects and also ensure 5 yearly review of the environment clearances.

We will look forward to your urgent response on these issues.

Thanking you,

Yours Sincerely,

Endorsed by:

Ravi Chopra, People Science Institute, Dehradoon,

Dr Bharat Jhunjhunwala, Former professor of IIM Bangalore, Uttarakhand,

Prof Prakash Nautiyal Aquatic Biodiversity Unit, H N B Garhwal University, Srinagar, Uttarakhand,

Dr Mohan Singh Panwar, H N B Garhwal University, Srinagar, Uttarakhand

Malika Virdi, Himal Prakriti, Uttarakhand,

E Theophilus, Himal Prakriti, Uttarakhand,

K. Ramnarayan, Save the Rivers Campaign and Himal Prakriti,  Uttarakhand,

Dr Prakash Chaudhary, Uttarakhand Peoples Forum,

Vimal Bhai, Matu Jan Sangathan, Uttarakhand,

Prashant Bhushan, Senior Supreme Court Lawyer, New Delhi,

11. Neeraj Vagholikar, Kalpavriksh, Pune,

Dunu Roy, Hazards Centre, Delhi,

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune,

Dr A Latha, River Research Centre, Kerala,

Samir Mehta, International Rivers and River Basin Friends, Mumbai,

Valli Bindana, Ganga film maker,  Delhi,

Marthand Bindana, Ganga film maker,  Delhi,

Madhu Bhaduri, Ambassador of India (Retd), Delhi,

Vandana Shiva, Navdanya, Delhi,

Manoj Mishra, Yamuna Jiye Abhiyaan, Delhi,

21. Himanshu Thakkar & Parineeta Dandekar, South Asia Network on Dams, Rivers & People, 86-D, AD block, Shalimar Bagh, Delhi,,, 09968242798

Copy to: 1. Jt Secretary, MEF

2. Director-IA, RVP, MEF

News coverage:


2. Activists blame six hydel projects for disaster in Uttarakhand urge moef to suspend clearance, Business Standard, July 21 2013

Dams · Expert Appraisal Committee · Ministry of Environment and Forests

Lessons from Uttarakhand disaster for Selection of River Valley Projects Expert Committee

Select Independent persons with clean track report in transparent way:

Do not select any of the current EAC members

Over 50 individuals and organisations from 15 states all over India have written a letter to the minister and secretary in Union Ministry of Environment and forests about their concerns when the MoEF selects members of the Expert Appraisal Committee for River Valley Projects. The signatories include eminent persons like Prashant Bhushan, Akhil Gogoi, Ramaswamy Iyer, EAS Sarma, Vandana Shiva, Prof M K Prasad and Bittu Sehgal. At least eight organisations/ persons from the disaster affected states of Uttarakhand and Himachal Pradesh have endorsed the letter. The letter makes specific suggestions for the criteria of selection and has requested that none of the members of the outgoing EAC be selected, considering the track record of the outgoing EAC. The letter is self explanatory.

It is this  EAC that considers all the dams and hydropower projects for environment clearance at initial (Terms of Reference of Environment Impact Assessment) and final (Environment Clearance) stage as also the adequacy of the EIAs, public consultation process and cumulative impact assessments. Selection of right kind of persons for chair and members of this committee is very important as past members and their conduct left a lot to be desired. Right selection of members of EAC can also go a long way in avoiding increased impact of the disasters like the one Uttarakhand is currently experiencing.

 June 29, 2013


1. Union Minister of State (IC) of Environment and Forests

Paryavaran Bhawan, CGO Complex,

Lodhi Road, New Delhi11003

2. Secretary,

Union Ministry of Environment and Forests

Paryavaran Bhawan, CGO Complex,

Lodhi Road, New Delhi11003

Respected Minister and Secretary,

Sub: Reconstitution of Expert Appraisal Committee on River Valley Projects

We understand that the term of the current Expert Appraisal Committee on River Valley Projects has come to an end and the ministry is in the process of reconstituting the EAC. In this context, we would like to suggest that the ministry must follow some basic criteria while selecting the chair and members for the new committee. Firstly, the ministry must ensure that all the members of the new committee have credible track record on environmental and related social issues related to the River Valley Projects. This cannot be said to be the case of some members of the outgoing committee. In addition to sociologists, ecologists, hydrologists, the committee needs to have representation from tribal groups, members with proven work on services of the river as against hydrology, experts in climatology and disaster management.  Secondly, all the members of the new committee must have a track record of unimpeachable integrity and professional independence, of taking position independent of government and developers. Thirdly, there should be no issues of conflict of interest for any of the members or their affiliated organisations with respect to the projects and sector they are dealing with.

The members of the EAC should be accountable for their actions. There should be a code of conduct for EAC members, and they should give an undertaking to the MoEF that they will adhere to it. The Code should include items such as a requirement for the members to read the EIA Reports and send it written comments before each meeting on what they consider are the significant issues, declaring conflict of interests, not taking on consultancy, etc.

In this regard, we would urge you not to select any of the members of the current EAC. This is because, firstly, the current EAC has had almost zero rejection rate for the projects they considered, as can be seen from the detailed analysis done by SANDRP (see: and for the six year period ending in Dec 2012, during part of which many of the current EAC were members.

Secondly, the committee has been at best inconsistent in applying:

  • basic parameters of the adequacy of EIA,
  • the adequacy of EMP,
  • need for cumulative impact assessment and carrying capacity,
  • adequacy of public consultation processes,
  • track record of the developers & EIA consultants,
  • adequacy of considering climate change issues,
  • adequacy of consideration of impact of the project on the disaster vulnerability of the area &
  • Most importantly, adequate application of mind to all these issues.

The committee has been sanctioning projects that have been rejected by other government bodies, without providing any reasonable case for rejecting such recommendations. This has in fact resulted in many of the projects that the EAC has cleared, but have remained stranded because of legal, regulatory interventions and people’s opposition. One of the direct consequences of what the EAC has done can seen in the hugely increased proportions of disaster that Uttarakhand is now facing.  It was shocking to see the committee recommending final environmental clearance for the 108 MW Jelam Tamak hydropower project in one of the worst hit Chamoli district in Alaknanda basin in Uttarakhand. This was in spite of at least two government appointed studies recommending that the project should not be cleared, including the Wildlife Institute of India and also the Inter Ministerial Group headed by B K Chaturvedi and SANDRP & Matu jan sangathan writing to the EAC about this and also raising various concerns about the project.  Media articles have also said that the current EAC members should be sacked, see:

MEF should realise that it can discharge its Constitutional obligation under Article 48A to conserve the ecology and ensure the sustainability of development only if the processes under the Environment (Protection) Act, 1986 are fully complied with. In this, the selection of the Chairman and the members of the EACs assume central importance.

We urge you in fact to set in place a transparent process of selection of EAC chair and members.

We hope you will take this into consideration.

Thanking you,

Yours Sincerely,

Endorsed by:

Himanshu Thakkar & Parineeta Dandekar, South Asia Network on Dams, Rivers & People, 86-D, AD block, Shalimar Bagh, Delhi,,, 09968242798

Prashant Bhushan, Senior Supreme Court Lawyer, New Delhi

Akhil Gogoi, General Secretary, KMSS, Assam,

Ramaswamy Iyer, former secretary, Govt of India, Delhi,

E A S Sarma, Former Union Power Secretary, Visakhapattnam,

Prof. M.K.Prasad, Kerala Sastra Sahitya Parishad, Cochin, Kerala,

Dr. Vandana Shiva, Navdanya, Delhi,

Bittu Sehgal, Sanctuary Asia, Mumbai,

Vimalbhai, Convenor, Matu Jansangthan, Uttarakhand,

10. Bharat Jhunjhunwala, former professor, IIM Bangalore, Dt Tehri, Uttarakhand

Malika Virdi, Himal Prakriti Munsiari, Uttarakhand

E Theophilus, Himal Prakriti Munsiari, Uttarakhand

K. Ramnarayan, Save the Rivers Campaign, Uttarakhand  

Tarun Joshi,Vanpanchayat Sangarsh Morcha, Uttrakhand,

Manshi Asher & Rahul Saxena, Himdhara, Himachal Pradesh

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune,

Samir Mehta, International Rivers and River Basin friends, Mumbai

Madhu Bhaduri, Ambassador of India (Retd) and social worker, Delhi

Dr. Latha Anantha, River Research Centre, Thrissur, Kerala.

20. Prof. Vijay Paranjpye, Chairman, Gomukh, Pune, Maharashtra

Rahul Banerjee, Dhas Gramin Vikas Kendra, Indore, MP,

Subhadra Khaperde, Aarohi Trust, Khargone, MP,

Shankar Tadwal, Khedut Mazdoor Chetna Sangath, Alirajpur, MP

Manoj Mishra, Yamuna Jiye Abhiyaan, Delhi,

Ravindranath, River Basin Friends, Dist Dhemaji, Assam,

Ranjan Panda, Convenor, Water Initiatives Odisha, Bhubaneshwar,

Sharad Lele, Centre for Environment & Development, ATREE, Bangalore

KJ Joy, Society for Promoting Participative Ecosystem Management, Pune,

Seema Kulkarni, SOPPECOM, Pune,

30. Meher Engineer, Scientist, Kolkata, W Bengal,

Bela Bhatia, Honorary Professor, Tata Institute of Social Sciences, Mumbai,

Dr Nilesh Heda, Samvardhan, Washim Vidarbha,

Samantha Agarwal, Chhattisgarh Bachao Andolan, Raipur,

Radha Gopalan, Environmental Scientist & Academician, Rishi Valley, Andhra Pradesh,

Nitya Jacob, Delhi,

Aruna Rodrigues, Mhow, M.P.,

Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat

Prof S. Janakarajan, Madras Institute of Development Studies, Chennai,

Prof Rohan Dsouza, JNU, Delhi,

40. Chaoba Takhenchangbam, North East Dialogue Forum, Manipur,

Swathi Seshadri, EQUATIONS, Bangalore,

Prasad Chacko, Behavioural Science Centre, St Xavier’s College Campus, Ahmedabad,

Janak Daftari, Jal Biradari, Mumbai,

Sudhir Pattnaik, Writer and Activist, Bhubaneswar,

Joe Athialy, Bank Information Center Trust, New Delhi

Pushp Jain, EIA Resource and Response Centre, New Delhi,

Pijush Kanti Das,  Committee on peoples and Environment, Silchar, Assam,

Dr Parthankar Choudhury, Society of Activists & Volunteers for Env., Silchar-Assam,

Michael Mazgaonkar, Gujarat,

50. Amit Bhaduri, Professor Emeritus, JNU, Delhi,

Subijoy Dutta, Rivers of the World Foundation, Crofton, MD 21114 USA,

Tarun Nair, Gharial Conservation Alliance, Mamallapuram, Tamil Nadu,

Dunu Roy, Hazards Centre, Delhi,


Copy to: 1. Jt Secretary, MEF

2. Director-IA, RVP, MEF


Jan 2013 issue of “Dams, Rivers & People”

Highlights of  the Jan 2013 issue
Jan-Feb Issue of Dams, Rivers and People
As “Dams, Rivers & People” completes ten years, we are happy to bring it to you in brand new format. Please do let us know how you like it.

Analysis of MOEF’s EAC on RVP: The Expert ApprovalCommittee

The Ministry of Environment & forest (MoEF) has constituted different Expert Appraisal Committees (EAC) for the appraisal of various developmental projects including River Valley & Hydroelectric projects. The Union Ministry of Environment and Forests’ (MoEF) Expert Appraisal Committee (EAC) on River Valley and Hydroelectric Projects (RVP) has not rejected a single one of the 262 hydropower and irrigation projects considered by it. This is one of the clues that EAC has strong pro project and anti people bias

Nyamjang Chu

MoEF’s EAC on River Valley Projects:Project wise details (April 2007 to Dec 2012)

This document presents decisions of meetings of the EAC during the period from Apr 2007 to Dec 2012. The document is organized region wise, then statewise, and finally as per project. This list provides evidence for the information provided in the lead article about the functioning of the EAC.

Man holding a Mahseer

Freshwater Biodiversity Conservation finds place in Indian Biodiversity Congress!

Indian Biodiversity Congress lays stress on Freshwater Biodiversity conservation. Looking at the huge and at time irreversible impact of dams and hydropower projects on aquatic and terrestrial biodiversity, Indian Biodiversity Congress has made some specific recommendations to the MoEF

People protesting against Luhri HEP

Reject Environment Clearance for the proposed 775 MW Luhri hydropower project

This letter to the MOEF draws attention to the many inconsistencies in the EAC’s approval of this project on the Sutlej River. It points out that the EIA is ‘inadequate, full of contradictions and misrepresentations’ and recommends blacklisting of the agency involved

Photo of plants in a wetland

Include rivers in India’s definition of Wetlands, follow the Ramsar Convention

The Ramsar Definition of wetlands includes permanent, seasonal, and intermittent Rivers.Despite this, Wetlands (Conservation and Management) Rules 2010 EXCLUDE Rivers from the definition of Wetlands, thus ensuring that no riverine stretches will be nominated for protection.

South Asia Network on Dams Rivers and People

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