Expert Appraisal Committee

EAC and FAC Decisions on Hydro Projects during 2020

(Feature image: Yamuna river at Lakhwar dam site, April 2019. Bhim Singh Rawat/SANDRP)

Details of proposals related to hydro power projects discussed by Expert Appraisal Committee for River Valley Projects during Dec 2019-Feb. 2021

SNProject NameCapacity (in Mw)DeveloperDistrict StateRiver BasinDateProposalDecision
HIMACHAL PRADESH
1Sutlej basin Cumulative Impact Assessment and Carrying Capacity Study of HEPs including less than 10 MW projects.NANAHimachal PradeshSutlej26 Dec. 2019CIAApproved[i]
2Integrated Kashang HEP243HPPCLKinnaur Himachal PradeshKashang/ Sutlej15 May 2020Extension of validity of ECProject Proponent absent
24 June 2020Not Required!
3Dugar HEP449 NHPCLChamba Himachal PradeshChenab/ Indus24 June 2020For ToRApproved
4Dugar HEP449 NHPCLChamba Himachal PradeshChenab/ Indus2 Dec 2020For amendment in ToRApproved
20 Jan. 2021
5Jangi Thopan Powari HEP804 SJVNLKinnaur Himachal PradeshSutlej31 Aug. 2020For ToRApproved
6Shongtong-Karcham HEP450HPPCLKinnaur Himachal PradeshSutlej 31 Aug. 2020For revalidation of install capacity vis-à-vis Satluj River Basin StudyDeferred
29 Oct. 2020Project Proponent absent
7Gyspa Hydro Power Project300 HPPCLLahaul Spiti Himachal PradeshBhaga/ Indus02 Dec. 2021For ToRMore Info Sought
8Luhri HEP-1210 Shimla, Himachal PradeshSutlej07 Feb. 2021For amendment in ECApproved
9Reoli Dugli HEP430 SJVNLLahaul Spiti Himachal PradeshChenab/ Indus07 Feb. 2021For ToRApproved
10Bardang BHEP175SJVNLLahaul Spiti Himachal PradeshChenab/ Indus07 Feb. 2021For ToRApproved
11Purthi HEP232SJVNLChamba Himachal PradeshChenab/ Indus07 Feb. 2021For ToRApproved
UTTARAKHAND
12Jakhol Sankri HEP44SJVNLUttarkashi UttarakhandYamuna26 Dec. 2019For ECApproved
13Sela Urthing HEP230UJVNLPithorgarh UttarakhandDhauliganga/ Sarda05 March 2020For ToRApproved
14Sela Urthing HEP202UJVNLPithorgarh UttarakhandDhauliganga/ Sarda29 July 2020For ToRApproved
15Sirkari Bhyol Rupsiabagar HEP120UJVNLPithorgarh UttarakhandGauriganga/ Sarda29 July 2020For ToRApproved
16Sirkari Bhyol Rupsiabagar HEP120UJVNLPithorgarh UttarakhandGauriganga/ Sarda07 Feb. 2021For ECMore info sought
17Vishnugad Pipalkoti HEP444THDC Chamoli UttarakhandAlaknanda29 July 2020For ToRApproved
18Lakhwar Multipurpose Project300UJVNLTehri Garhwal UttarakhandYamuna02 Dec. 2020For ECApproved
NORTH EAST INDIA
19Demwe Lower HEP1750Athena Demwe Power Pvt. LtdLohit, Arunachal PradeshLohit/ Brahmaputra05 March 2020For ECApproved
20Rongnichu HEP115Madhya Bharat Power Corp LtdGangtok, SikkimRongnichu/ Teesta29 July 2020For ECDeferred
21Simsang Dam Project65 East Garo Hills, MeghalayaSimsang02 Dec. 2020For ToRApproved
EAST INDIA
22Rammam-III HEP120NTPCDarjeeling W BengalRammam/ Teesta15 May 2020  Extension of validity of ECAsked to apply for fresh EC[ii]
23Rammam-III HEP120NTPCDarjeeling W BengalRammam/ Teesta29 July 2020For ToRApproved
24Teesta Intermediate HEP930 (2×30+2×15)W Bengal State Electricity Distribution CompanyW BengalTeesta07 Feb. 2021For ToRApproved
25Dagmara Multipurpose Hydropower Project130Bihar-State Hydro-Electric Power Corp.Supaul, BiharKosi27 Jan. 2020For ToRApproved
26Shaheed Lakhan Nayak SHEP25Meenakshi Odisha Power Pvt LtdKoraput, OdishaKolab (SAbari)/ Godavari05 March 2020For ToRApproved
SOUTH INDIA
27Saundatti HEP Integrated Renewable Energy with Pumped Storage Project1200Greenko Solar Energy Pvt. Ltd.Belgaum, KarnatakaMalaprabha/ Krishna29 Oct. 2020For ECApproved
28Completion of Balance Works of Two Units at Lower Sileru Hydro Power House and Improvement of Power Canal Works230 (2×115)V. Surya LakshmiEast Godavari, Andhra PradeshGodavari02 Dec. 2020For ToRApproved
29Sillahalla Pumped Storage HEP-I1000 (4×250)TN Gen & Distribution CorpNilgiris, Tamil NaduSillahalla26 July 2020For ToRApproved
30Kundah Pumped Storage HEP500 (125×4)TN Gen & Distribution CorpNilgiris, Tamil NaduKundah02 Dec. 2020For ECMore Info Sought
20 Jan. 2021For ECApproved

EC: Environmental Clearances, ToR: Terms of References; NA: Not Applicable

Between Dec. 26, 2019 and Feb. 7, 2021, the EAC on River Valley Projects held 11 meetings. In this period EAC considered about 30 proposals of hydro projects (non-hydro projects considered by the EAC were additional to this number). Of these 11 proposals were from Himachal Pradesh and 7 from Uttarakhand. The EAC approved ToR to 16 projects and ECs to 5 projects. It also approved amendments in
ToR and EC of one project each and also approved the Sutlej Basin Cumulative Impact Assessment in Himachal Pradesh. About proposal for extension of validity of the Kashang Hydro project in HP, the EAC controversially decided that it is not required! Some projects for which the EAC decision is deferred for want of more information include: Validity of Installed capacity for Shongtong Karcham, ToR for Gyaspa Hydro project, EC for Sirkari Bhyol Rupsiabaghar HEP, Rongnichu HEP.  For Rammam III HEP in W Bengal, EAC asked the project to apply for the EC afresh. The meetings dates and links of proposal discussed is given below.

SNEAC MeetingLinks
126 Dec. 2019http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/261220193FSH2QF929.pdf  
227 Jan. 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/21022020I24YMGJ230.pdf 
35 March 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/200320206F8JBC6N31.pdf 
415 May 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/30052020EU1CLA1T32EAC.pdf
524 June 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/1007202019HCQ4QA33.pdf
629 July 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/07082020V6OE5PKR1stEACMoM.pdf
731 Aug. 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/01102020W1QIGJVE2ndMoM.pdf
829 Oct. 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/11112020KU3MG7AN3rdEACRiverMoM.pdf
92 Dec. 2020http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/17122020I4SYXARI4thEACRVHEPMoM.pdf
1020 Jan. 2021http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/28012021UZ80QY68Approved_MoM6thEAC_RiverValley.pdf
117 Feb. 2021http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/18022021CAO72PG4ApprovedMOM_7thEAC_RVHEP.pdf 

Details of hydro and dam projects considered by FAC for forest clearances in 2020

SNProject NameCapacity (in Mw)DeveloperDistrict/ StateRiver BasinDateProposalDecision
1Talong Londa HEP225 (3×75)GMR Londa Hydro Power Pvt. LtdKameng/ Arunachal PradeshKameng/ Brahma- putra27 Feb. 2020For diversion of 280.54 ha forest landDeferred
2Etalin HEP3097Etalin Hydro-Electric Power CompanyDibang Valley Arunachal PradeshDri, Talo/ Dibang23 April 2020For diversion for 1165.66 Ha of forest landDeferred
3Pauk HEP145Heo Hydro Power Pvt LtdWest Siang Arunachal PradeshYarjep/ Siang11 June 2020Additional forest area of 0.6 ha and re appropriation of 4.2 ha forest area from already diverted forest area (PH & Barrage Quarry of 0.5 ha and Muck Access road of 3.7 ha) and to surrender 0.6 ha forest area in respect of Heo HEP (240 MW)Approved
4Tato-I HEP186Siyota Hydro Power Pvt LtdWest Siang Arunachal PradeshYarjep/ Siang11 June 20200.8 ha forest land and to surrender equal forest land from already diverted 52.8 ha forest area (surface forest land-47.1 ha, riverbed-2.3 ha & underground area-2.8 ha) -change in location of PH quarry site of 0.5 ha.Approved
5Bajoli- Holi HEP180GMR Bajoli Holi Hydro Power Pvt. LtdChamba/ Himachal PradeshRavi/ Indus27 Feb. 2020Diversion of 75.304 ha of forest land in Bharmour Forest Division. Permission for felling of additional 12 trees and use of non-diverted degraded/blank forest land in lieu of diverted dense forest land of almost equal area.Approved
6Luhri HEP Stage-I172SJVNLKullu/ Himachal PradeshSutlej11 June 2020Additional area of 0.9486 ha (in addition to the already diverted 98.1004 ha) of forest land for approach road under the jurisdiction of Ani at Luhri Forest DivisionState Govt to examine 3 alternatives and provide compliance of the conditions of earlier approval.
7Ujh Multipurpose HEP186JKSPDCKathua/ J&KUjh/ Ravi22 Dec. 2020680.1 ha (instead of 1100 ha.) of Forest landApproved
8Shahpurkandi Dam206JKSPDCKathua/ J&KRavi 13.24 ha forest landApproved

In 2020, FAC considered 8 proposals giving approvals to 5 proposals while deferring 3. Dates and links of relevant FAC meetings held in 2020 are given in table below.

SNDateLinks
127 Feb.http://forestsclearance.nic.in/writereaddata/FAC_Minutes/31130125512101DraftFACMoM27022020.pdf
223 Aprilhttp://forestsclearance.nic.in/writereaddata/FAC_Minutes/51111121912211FACminutes23April20_compressed.pdf
311 Junehttp://forestsclearance.nic.in/writereaddata/FAC_Minutes/7116124112131MoMofFACheldon11June2020.pdf
422 Dec.http://forestsclearance.nic.in/writereaddata/FAC_Minutes/111181233121111515_1610947481346.pdf 

Compiled by Bhim Singh Rawat (bhim.sandrp@gmail.com)

End Notes:-


[i] EAC minutes does not say that explicitly

[ii] Extension of validity of EC granted on Aug 17, 2007: 13 yrs will be over on Aug 16, 2020, rules do not allow further extension, apply de novo for fresh EC

Dams · Environment Impact Assessment · Expert Appraisal Committee · Himalayas · Irrigation · Landslide · Ministry of Environment and Forests · Nepal · Public Hearing

Who exactly needs the Pancheshwar Dam?

Bolo Jai Jai Baba Bhole”, the Prime Minister Narendrabhai Modi, while speaking at Kedarnath in Uttarakhand in Oct 2017[i], asked the people in audience to chant with him. Indian deity Mahadev, the presiding deity at Kedarnath on the banks of Mandakini river is possibly the closest to rivers and nature among all the deities, as is also clear from his attire. Baba Bhole is one of the many names of this deity. Incidentally, the massive, controversial Pancheshwar Dam a pet project of Mr Modi will also submerge the Pancheshwar Mahadev Temple, where too, the presiding deity is same Bhole Baba. But we will come back to Bhole Baba. Continue reading “Who exactly needs the Pancheshwar Dam?”

Interlinking of RIvers

NWDA & EIA lies on Ken Betwa River Link nailed by IGF (WL): Will EAC take action against them now?

A fabulous view of Ken river. Nesting sites of Long-billed vultures are to the right. All will go under water if Ken-Betwa linkup is carried out,AJT Johnsingh
ABOVE: A fabulous view of Ken river. Nesting sites of Long-billed vultures are to the right. All will go under water if Ken-Betwa linkup is carried out,AJT Johnsingh

The official minutes of the 37th meeting of the Standing Committee of the National Board of Wild Life (NBWL) held on Feb 26, 2016, about the Ken Betwa Link Project (KBLP) Phase I have exposed the lies of project developer National Water Development Agency (NWDA) and its consultant for Environment Impact Assessment (EIA) about a number of crucial aspects of the project impact on the Panna Tiger Reserve, Vulture Habitat and Ken Ghariyal Sanctuary.

It now becomes clear that both NWDA and EIA consultant AFCL (formerly Agriculture Finance Corporation Ltd) are guilty of misleading the MoEF’s (Ministry of Environment, Forests and Climate Change) Expert Appraisal Committee (EAC) on River Valley Projects, when the KBPL was discussed by the EAC during Aug 24-25, 2015, Oct 26-27, 2015 and Feb 7-8, 2016. We hope the EAC will take appropriate action against the developer and the EIA consultant for misleading the statutory official agency. Continue reading “NWDA & EIA lies on Ken Betwa River Link nailed by IGF (WL): Will EAC take action against them now?”

Dams

LETTERS TO EAC & MOEF: KEN BETWA LINK IS A TRAGEDY: DON’T BURN LIFEBOATS TO STAY WARM ON SINKING TITANIC SHIP

Even as the Expert Appraisal Committee on River Valley and Hydropower Projects sits to decide about Environment Clearance to Ken Betwa River Link Proposal on Feb 8-9, 2016, a number of people have written to the committee against recommending clearance to the project. We are publishing here some of them: Continue reading “LETTERS TO EAC & MOEF: KEN BETWA LINK IS A TRAGEDY: DON’T BURN LIFEBOATS TO STAY WARM ON SINKING TITANIC SHIP”

Arunachal Pradesh · Environment Impact Assessment · Expert Appraisal Committee · Hydropower

Subansiri Basin Study – Another Chapter of Environment Subversion in Northeast

The Study The study has been done by IRG Systems South Asia Private Limited (http://www.irgssa.com/, a subsidiary of US based IRG Systems) and http://www.eqmsindia.com/[i]. It is supposed to be a Cumulative Impact Assessment of 19 HEPs planned in the basin, out of which PFRs of 7 are available, DPR of two, and one of which, the 2000 MW Subansiri Lower HEP is under construction.

Subversion of Environment Governance in the Subansiri basin While looking at this basin study, the subversion of environment governance in Subansiri basin this very millennia should be kept in mind. A glimpse of it is provided in Annexure 1. In fact, one of the key conditions of environmental clearance to the 2000 MW Lower Subansiri HEP was that no more projects will be taken up in the basin upstream of the Lower Subansiri HEP, which essentially would mean no more projects in the basin, since LSHEP is close to the confluence of the Subansiri River with Brahmaputra River. That condition was also part of the Supreme Court order in 2004. The need for a carrying capacity study was also stressed in the National Board of Wild Life discussions. We still do not have one. In a sense, the Subansiri basin is seeing the consequences of that subversion.

Map of Subansiri RIver Basin  Source: https://sandrp.in/basin_maps/Subansiri_River_Basin.pdf
Map of Subansiri RIver Basin
Source: https://sandrp.in/basin_maps/Subansiri_River_Basin.pdf

Information in public domain not known to consultants The report does not even state that Middle Subansiri dam have also been recommended TOR in 41st EAC meeting in Sept 2010. This project will require 3180 ha of land, including 1333 Ha forest land, and 2867 ha area under submergence. Even about Upper Subansiri, the consultants do not know the area of forest land required (2170 ha). So the consultants have not used even the information available in public domain in EAC meetings.

Study based on flawed and incomplete Lohit Basin Study The Study claims that it is based on Lohit Basin Study done by WAPCOS. Lohit Basin Study is an extremely flawed attempt and does not assess cumulative impacts of the cascade projects. Civil society has written about this to the EAC and the EAC itself has considered the study twice (53rd and 65th EAC Meetings), and has not accepted the study, but has raised several doubts. Any study based on a flawed model like Lohit Basin Study should not be acceptable.

A house in the upstream of Subansiri River  Source: http://cooperfreeman.blogspot.in/2012/12/the-wild-east-epic.html
A house in the upstream of Subansiri River
Source: http://cooperfreeman.blogspot.in/2012/12/the-wild-east-epic.html

No mention of Social impacts Major limitation of the study has been absolutely no discussion on the severe social impacts due to cumulative forest felling, flux of population, submergence, livelihoods like riparian farming and fishing, etc. Though this has been pointed out by the TAC in its meeting and field visit, the report does not reflect this.

Some key Impacts Some of the impacts highlighted by the study based on incomplete information about HEPs are:

Þ    The length of the river Subansiri is 375 km up to its outfall in the Brahamaputra River. Approximately 212.51 km total length of Subansiri will be affected due to only 8 of the proposed 19 HEPs in Subansiri River basin.

Þ    Total area brought under submergence for dam and other project requirements is approx. 10, 032 ha of eight proposed HEPs. The extent of loss of forest in rest of the 9 projects is not available.

Þ    62 species belonging to Mammals (out of 105 reported species), 50 Aves (out of 175 reported species) and 2 amphibians (out of 6 reported species) in Subansiri Basin are listed in Schedules of Wildlife Protection Act, 1972 (as amended till date).

Þ    99 species belonging to Mammals (out of 105 reported species), 57 species belonging to Aves (out of 175 reported species), 1 Reptilian (out of 19 reported species), 2 Amphibians (out of 6 reported species), 28 fishes (out of 32 reported species), 25 species belonging to Odonata of Insecta fauna group (out of 28 reported species) are reported to be assessed as per IUCN’s threatened categories.

Even this incomplete and partial list of impacts should give an idea of the massive impacts that are in store for the basin.

Cumulative impacts NOT ASSESSED Specifically, some of the cumulative impacts that the report has not assessed at all or not adequately include:

1. Cumulative impact of blasting of so many tunnels on various aspects as also blasting for other project components.

2. Cumulative impact of mining of various materials required for the projects (sand, boulders, coarse and fine granules, etc.)

3. Cumulative impact of muck dumping into rivers (the normal practice of project developers) and also of also muck dumping done properly, if at all.

Subansiri River in the Upper Reaches  Source: Lovely Arunachal
Subansiri River in the Upper Reaches
Source: Lovely Arunachal

4. Changes in sedimentation at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof.

5. Cumulative impact on aquatic and terrestrial flora and fauna across the basin due to all the proposed projects.

6. Cumulative impact of the projects on disaster potential in the river basin, due to construction and also operation at various stages, say on landslides, flash floods, etc.

7. Cumulative dam safety issue due to cascade of projects.

8. Cumulative change in flood characteristics of the river due to so many projects.

9. Cumulative impacts due to peaking power generation due to so many projects.

10. Cumulative sociological impact of so many projects on local communities and society.

11. Cumulative impact on hydrological flows, at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof. This will include impacts on various hydrological elements including springs, tributaries, groundwater aquifers, etc. This will include accessing documents to see what the situation BEFORE project and would be after. The report has failed to do ALL THIS.

12. Impact of silt laden water into the river channel downstream from the dam, and how this gets accumulated across the non-monsoon months and what happens to it. This again needs to be assessed singly and cumulatively for all projects.

13. Impact of release of silt free water into the river downstream from the power house and impact thereof on the geo morphology, erosion, stability of structures etc, singly and cumulatively.

14. Impact on Green House Gas emissions, project wise and cumulatively. No attempt is made for this.

15. Impact of differential water flow downstream from power house in non-monsoon months, with sudden release of heavy flows during peaking/ power generation hours and no releases during other times.

16. Cumulative impact of all the project components (dam, tunnels, blasting, power house, muck dumping, mining, road building, township building, deforestation, transmission lines, etc.,) for a project and then adding for various projects. Same should also be done for the periods during construction, operation and decommissioning phases of the projects.

17. Cumulative impact of deforestation due to various projects.

18. Cumulative impact of non compliance of the environment norms, laws, Environment clearance and forest clearance conditions and environment management plans. Such an assessment should also have analysed the quality of EIA report done for the Subansiri Lower hydropower project.

Wrong, misleading statements in Report There are a very large number of wrong and misleading statements in the report. Below we have given some, along with comment on each of them, this list is only for illustrative purposes.

Sr No

Statement in CIA

Comment

1 “During the monsoon period there will be significant discharge in Brahmaputra River. The peaking discharge of these hydroelectric projects which are quite less in comparison to Brahmaputra discharge will hardly have any impact on Brahmaputra.” This is a misleading statement. It also needs to be assessed what will be the impact on specific stretches of Subansiri river. Secondly, the projects are not likely to operate in peaking mode in monsoon.
2 “However, some impact in form of flow regulation can be expected during the non-monsoon peaking from these projects.” This is not correct statement as the impact of non-monsoon peaking is likely to be of many different kinds, besides “flow regulation” as the document describes.
3 “Further, during the non-monsoon period the peaking discharge release of the projects in upper reaches of Subansiri basin will be utilized by the project at lower reaches of the basin and net peaking discharge from the lower most project of the basin in general will be the governing one for any impact study.” This is again wrong. What about the impact of such peaking on rivers between the projects?
4 “The construction of the proposed cascade development of HEPs in Subansiri basin will reduce water flow, especially during dry months, in the intervening stretch between the Head Race Tunnel (HRT) site and the discharge point of Tail Race Tunnel (TRT).” This statement seems to indicate that the consultants have poor knowledge or understanding of the functioning of the hydropower projects. HRT is not one location, it is a length. So it does not make sense to say “between HRT and the discharge point of TRT”.
5 “For mature fish, upstream migration would not be feasible. This is going to be the major adverse impact of the project. Therefore, provision of fish ladder can be made in the proposed dams.” This is simplistic statement without considering the height of the various dams (124 m high Nalo HEP dam, 237 m high Upper Subansiri HEP dam, 222 m high Middle Subansiri HEP dam), feasibility of fish ladders what can be optimum design, for which fish species, etc.
6 “…water release in lean season for fishes may be kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20% water flow in lean season may be maintained at Hiya and Nyepin HEP for fish migration.” This conclusion seems unfounded, the water release suggested is even lower than the minimum norms that EAC of MoEF follows.

Viability not assessed The report concludes: “The next steps include overall assessment of the impacts on account of hydropower development in the basin, which will be described in draft final report.”

One of the key objective of the Cumulative Impact assessment is to assess how many of the planned projects are viable considering the impacts, hydrology, geology, forests, biodiversity, carrying capacity and society. The consultants have not even applied their mind to key objective in this study. They seem to assume that all the proposed projects can and should come up and are all viable. It seems the consultant has not understood the basic objectives of CIA. The least the consultant could have said is that further projects should not be taken up for consideration till all the information is available and full and proper Cumulative impact assessment is done.

The consultants have also not looked at the need for free flowing stretches of rivers between the projects.

Section on Environmental Flows (Chapter 4 and 9): The section on Environmental flows is one of the weakest and most problematic sections of the report, despite the fact that the Executive summary talks about it as being one of the most crucial aspects.

The study does not use any globally accepted methodology for calculating eflows, but uses HEC RAS model, without any justification. The study has not been able to do even a literature review of methodologies of eflows used in India and concludes that “No information/criteria are available for India regarding requirement of minimum flow from various angles such as ecology, environment, human needs such as washing and bathing, fisheries etc.”

This is unacceptable as EAC itself has been recommending Building Block Methodology for calculating eflows which has been used (very faultily, but nonetheless) by basin studies even like Lohit, on which this study is supposedly based. EAC has also been following certain norms about E flow stipulations. CWC itself has said that minimum 20% flow is required in all seasons in all rivers. BK Chaturvedi committee has recently stipulated 50% e-flows in lean season and 30% in monsoon on daily changing basis.

The assumption of the study in its chapter on Environmental Flows that ‘most critical reach is till the time first tributary meets the river” is completely wrong. The study should concentrate at releasing optimum eflows from the barrage, without considering tributary contribution as an excuse.

First step of any robust eflows exercise is to set objectives. But the study does not even refer to this and generates huge tables for water depths, flow velocity, etc., for releases ranging from 10% lean season flow to 100% lean season flow.

After this extensive analysis without any objective setting, the study, without any justification (the justification for snow trout used is extremely flawed. Trouts migrate twice in a year and when they migrate in post monsoon months, the depth and velocity needed is much higher than the recommended 10% lean season flow) recommends “In view of the above-said modeling results, water release in lean season for fishes maybe kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at all HEP for fish migration and ecological balance.”

The study does not recommend any monsoon flows. Neither does it study impact of hydro peaking on downstream ecosystems.

Shockingly, the study does not even stick with this 20-25% lean season flow recommendation (20-25% of what? Average lean season flow? Three consecutive leanest months? The study does not explain this). In fact in Chapter 9 on Environmental Flows, the final recommendation is: “Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at Hiya and Nyepin  HEP or all other locations for fish migration.” (emphasis added)

So it is unclear if the study recommends 20-25% lean season flows or 10-15% lean season flows. This is a very flawed approach to a critical topic like eflows.

The study keeps mentioning ‘minimum flows’ nomenclature, which shows the flawed understanding of the consultants about e-flows.

The entire eflows section has to be reworked, objectives have to be set, methodology like Building Block Methodology has to be used with wide participation, including from Assam. Such exercises have been performed in the past and members of the current EAC like Dr. K.D. Joshi from CIFRI have been a part of this. In this case, EAC cannot accept flawed eflows studies like this. (DR. K D. Joshi has been a part of a study done by WWF to arrive at eflows through BBM methodology for Ganga in Allahabad during Kumbh: Environmental Flows for Kumbh 2013 at Triveni Sangam, Allahabad and has been a co author of this report)

Chocolate Mahseer in Subansiri  Source: http://www.flickr.com/photos/8355947@N05/7501485268/
Chocolate Mahseer in Subansiri
Source: http://www.flickr.com/photos/8355947@N05/7501485268/

Mockery of rich Subansiri Fisheries Subansiri has some of the richest riverine fisheries in India. The river has over 171 fish species, including some species new to science, and forms an important component of livelihood and nutritional security in the downstream stretches in Assam.

But the study makes a mockery of this saying that the livelihoods dependence on fisheries is negligible. The entire Chapter on Fisheries needs to be reworked to include impacts on fisheries in the downstream upto Majuli Islands in Assam at least.

No mention of National Aquatic Animal! Subansiri is one of the only tributaries of Brahmaputra with a resident population of the endangered Gangetic Dolphin, which is also the National aquatic animal of India (Baruah et al, 2012, Grave Danger for the Ganges Dolphin (Platanista ganegtica) in the Subansiri River due to large Hydroelectric Projecthttp://link.springer.com/article/10.1007/s10669-011-9375-0#).

Shockingly, the Basin Study does not even mention Gangetic Dolphin once in the entire study, let alone making recommendations to protect this specie!

Gangetic Dolphin is important not only from the ecological perspective, but also socio cultural perspective. Many fisher folk in Assam co-fish with the Gangetic River Dolphin. These intricate socio ecological links do not find any mention in the Basin study, which is unacceptable.

Agitation Against Lower Subansiri Dam in Assam Source: SANDRP
Agitation Against Lower Subansiri Dam in Assam
Source: SANDRP

Lessons from Lower Subansiri Project not learnt A massive agitation is ongoing in Assam against the under construction 2000 MW Subansiri Lower HEP. The people had to resort to this agitation since the Lower Subansiri HEP was going ahead without studying or resolving basic downstream, flood and safety issues. The work on the project has been stopped since December 2011, for 22 months now. In the meantime several committee have been set up, several changes in the project has been accepted. However, looking at this shoddy CIA, it seems no lessons have been learnt from this ongoing episode. This study does not even acknowledge the reality of this agitation and the issues that the agitation has thrown up. There is no reflection of the issues here in this study that is agitating the people who are stood up against the Lower Subansiri HEP. The same people will also face adverse impacts of the large number of additional projects planned in the Subansiri basin. If the issues raised by these agitating people are not resolved in credible way, the events now unfolding in Assam will continue to plague the other planned projects too.

Conclusion From the above it is clear that this is far from satisfactory report. The report has not done proper cumulative assessment on most aspects. It has not even used information available in public domain on a number of projects. It does not seem to the aware of the history of the environmental mis-governance in the SubansiriBasin as narrated in brief in Annexure 1. For most projects basic information is lacking. Considering the track record of Central Water Commission functioning as lobby FOR big dams, such a study should have never been given to CWC. One of the reasons the study was assigned by the EAC to the Central Water Commission was that the CWC is supposed to have expertise in hydrological issues, and also can take care of the interstate issues. However, the study has NOT been done by CWC, but by consultants hired by CWC, so CWC seems to have no role in this except hiring consultant. So the basic purpose of giving the study to CWC by EAC has not been served. Secondly the choice of consultants done by the CWC seems to be improper. Hence we have a shoddy piece of work. This study cannot be useful as CIA and it may be better for EAC to ask MoEF for a more appropriate body to do such a study. In any case, the current study is not of acceptable quality.

South Asia Network on Dams, Rivers & People (https://sandrp.in/https://sandrp.wordpress.com/)

ANNEXURE 1

Set Conditions to be waived Later – The MoEF way of Environmental Governance

In 2002, the 2,000 MW Lower Subansiri hydroelectric project on the Assam-Arunachal Pradesh border came for approval to the Standing Committee of the Indian Board for Wildlife (now called the National Board for Wildlife) as a part of the Tale Valley Sanctuary in AP was getting submerged in the project. The total area to be impacted was 3,739.9 ha which also included notified reserved forests in Arunachal Pradesh and Assam.  The Standing Committee observed that important wildlife habitats and species well beyond the Tale Valley Sanctuary, both in the upstream and downstream areas, would be affected (e.g. a crucial elephant corridor, Gangetic river dolphins) and that the Environmental Impact Assessment studies were of a very poor quality. However, despite serious objections raised by non-official members including Bittu Sahgal, Editor, Sanctuary, Valmik Thapar, M.K. Ranjitsinh and the BNHS, the Ministry of Environment & Forests (MoEF) bulldozed the clearance through in a May 2003 meeting of the IBWL Standing Committee. Thus a project, which did not deserve to receive clearance, was pushed through with certain stringent conditions imposed (Neeraj Vagholikar, Sanctuary Asia, April 2009).

Lower Subansiri HEP Source: The Hindu
Lower Subansiri Dam
Source: The Hindu

The EC given to the project was challenged in Supreme Court (SC) by Dr L.M Nath, a former member of the Indian Board for Wildlife. Nath pleaded, these pristine rich and dense forests classified as tropical moist evergreen forest, are among the finest in the country. Further the surveys conducted by the Botanical Survey of India and the Zoological Survey of India were found to be extremely poor quality. The Application mentions that the Additional DG of Forests (Wildlife) was of the view that the survey reports of the BSI and ZSI reports were not acceptable to him because these organisations had merely spent five days in the field and produced a report of no significance.

The SC gave its final verdict on 19-4-2004, in which the Court upheld the EC given by MoEF to NHPC but with direction to fulfill some important conditions. Out these conditions there were two conditions which were very significant – “The Reserve Forest area that forms part of the catchment of the Lower Subansri including the reservoir should be declared as a National Park/ Sanctuary. NHPC will provide funds for the survey and demarcation of the same.”, and “There would be no construction of dam upstream of the Subansri River in future.” These conditions were also mentioned in the original EC given to the project in 2003.

In May 2005, two years after the EC was given the Arunachal Pradesh govt and NHPC approached the SC to waive or modify the above two conditions. The state government calimed that following these conditions would imply loss of opportunity to develop 16 mega dams in the upstream of Lower Subansiri (this including 1,600 MW Middle Subansiri and 2,000 MW Upper Subansiri to be developed by NHPC). The SC sent it back to National Board for Wildlife to review the conditions.

The petition was done strategically. “The strategy of the dam proponents is simple. They raised no objection to the terms until the construction of the Lower Subansiri project had proceeded beyond a point when it could have been cancelled. Armed with this fait accompli, they asked for a review of the clauses on the very basis on which the original clearance – laid down by members who were subsequently dropped from the wildlife board – was granted.”[ii]

Then nonofficial members of NBWL expressed their dissent to the proposal. In a May 2008 communication to the Chairman of the NBWL Standing Committee, member Dr. Bibhab Talukdar observed: “If the Standing Committee agrees to waive the conditions, we would be setting a dangerous precedent and sending a wrong signal regarding the credibility of decision-making by us. This would mean that projects impacting rich wildlife habitats can receive clearances based on stringent conditions, only to be up for review later. Such an approach is undesirable both from a perspective of good governance as well as the long-term interest of wildlife in the country.”

Dr. Asad Rahmani of the BNHS, who was part of a sub-committee of the NBWL Standing Committee conducting a site visit to the project area, stated in his report: “Under no circumstances should new projects be allowed in the Subansiri river basin until an advance cumulative assessment of proposed projects and a carrying capacity study of the Subansiri river basin are completed.”

In the December 12 2008 meeting of NBWL Standing Committee, even after these dissenting opinions from nonofficial members MoEF managed to do a dilution of the above two conditions. Assam that time was witnessing a major protest concerning the downstream impacts of Lower Subansiri HEP but it was not even consulted. Shockingly the “no dam upstream” condition was removed and it was decided that “any proposal in the upstream of the SubansiriRiver would be considered independently on its merit by the Standing Committee as and when submitted by the proponents”.

Now the Arunachal Pradesh government needs to declare a smaller area of 168 sq. km. as a sanctuary and “make serious efforts” to bring an additional 332 sq. km. reserved forest under the category of Conservation Reserve (CR) in consultation with the MoEF. The latter part of the condition (declaration of CR) is non-enforceable because of the choice of words. Even the demand to at least conduct an advanced cumulative impact assessment of proposed projects and a carrying capacity study of the Subansiri river basin has been ignored[iii].

As Bittu Sahgal, Editor, Sanctuary Asia says, “The Lower Subansiri is one such, where the PMO has placed a very dubious role in forcing clearances, agreeing to clearance conditions and then starting the project, only to loosen the environmental conditions. In this whole scam the Zoological Survey of India and the Botanical Survey of India have been co-conspirators that have suppressed the ecological value of the forests to facilitate the building of the dam, which will drown pristine elephant, tiger and clouded leopard forests and cause havoc downstream as well.”

The above sequence of events are very pertinent to remember as we see the Subansiri basin study.

END NOTES:


[i] Website says: “More than 200 successful environmental Impact Assessment Clearance from Ministry of Environment & Forests, Government of India for Industry, Infrastructure & Construction projects” Sounds strange from an EIA consultant.

[iii] For more details please see – “Forest Case Update”, Issue 1, June 2004 and “The Subansiri Subversion” by Neeraj Vagholikar published in Sanctuary Asia, April 2009 issue