‘MoU Virus’ was the term used by former environment minister Jairam Ramesh in May 2008 to describe the speed at which the Memorandum of Understanding or MoUs for hydropower projects were signed by Arunachal Pradesh government. Five years after that virus attack, the ill-effects are clearly visible. The construction of Lower Subansiri hydropower project has been stopped for 26 months now. Environment and Forest clearances are yet to be accorded to 3000 MW Dibang Multipurpose dam, even though the foundation stone for this dam was laid by none other than the Prime Minister Dr. Manmohan Singh on 31st January 2008. Lower Siang hydropower project public hearing was vehemently opposed by people. But learning no lesson from these, the government of Arunachal Pradesh and the center is going ahead with its gigantic plan to make Arunachal Pradesh the ‘future powerhouse’ of the country. In doing so scientific studies and ground realities have been blatantly neglected.
Oju hydropower project in the Subansiri river basin with a proposed installed capacity of 1850 MW is the latest example of the hydromania, which has gripped the government of Arunachal Pradesh and the center. Oju HEP is the upper most project proposed on the Subansiri river in the Upper Subansiri district with a catchment area of 9827 sq. km. up to the dam site. The project was considered for Terms of Reference (TOR) or first stage of environmental clearance by the Expert Appraisal Committee on River Valley and Hydroelectric projects (EAC) in its 72nd meeting held on 20th and 21st February this year. But there is little information available about the actual situation of the project area. Before going any further, consider the following situations –
* Any scientific study is yet to be done at the dam site. Water flow data which is a prerequisite for construction of a hydropower dam is not available for the proposed dam site. No gauge and discharge measurement site at the project site or anywhere in the catchment of the dam.
* The project area is totally under forest cover. It holds rich biodiversity which is yet to be explored.
* There is no road to reach the project area. The distance between the dam site of Oju hydropower project and Limeking town, the last point of motarable road is 60 km. From Daporijo, the headquarters of Upper Subansiri district, the dam site is 210 km away.
* A small hydropower project is proposed to be constructed in a nearby stream in order to fulfill the electricity requirement during the construction of the project.
* SNC-Lavalin, the consultants hired for preparation of detailed project report, is known to be one of most corrupt engineering firms in the world.
All the situations mentioned above are drawn from the project documents submitted to MoEF. It was shocking to find that without any environmental baseline assessment, the Pre Feasibility Report and Form I made all kinds of sweeping assertions. This hydromania is leading to nothing but ignorant, unscientific and corrupt decision making.
SANDRP after reviewing the project documents, made a detailed submission to EAC on February 13th pointing out the critical issues related with Oju HEP. We asked the EAC not to consider the project for TOR clearance. We also demanded that the project proponent should be asked to get at least five years’ daily water flow, gauge, rainfall and sediment data at the project site before applying for TOR clearance. The critical issues mentioned in SANDRP’s submission on Oju HEP to EAC are listed below.
Critical Issues of Oju HEP
No More Projects Should be Cleared in Subansiri basin before Completion of Basin Study From 20007 to 2013, four projects in Subansiri basin has been considered by EAC along with one sub-basin study. All the four projects have been given TOR clearance. Subansiri Upper HEP has been given TOR extension on 6th June 2013. The total installed capacity of these projects are 4960 MW. It is also important to note that 2000 MW Lower Subansiri project is in under construction phase. This implies that nearly 6960 MW of capacity has already been given clearance by EAC without any cumulative impacts assessment study of Subansiri basin being completed through a participatory process. This capacity is in addition to the small hydropower projects in the basin.
The Subansiri sub-basin study was discussed for the first time in 68th EAC meeting in 2013. In that meeting the EAC had stated that “optimal number and locations of HEPs and similar projects to be planned in the basin conforming strictly to ecological and environmental sustainability is to be clearly delineated.” This can only be known once the basin study is completed.
In this situation, no more projects in Subansiri basin should be given any clearance till the cumulative study is being completed. Besides, the EAC must take into account the fact that cumulative impact assessment study of the basin is major demand of the organizations whose agitation has stopped the construction work of Lower Subansiri with the support of the people of Assam. Therefore it is very essential that a through and detailed cumulative impact assessment study is done for Subansiri in participation with all the people of the basin. Without this, clearances given to projects would face the same fate as the Lower Subansiri project is now facing: Work stopped for 26 months till now.
A list of projects cleared by EAC in Subansiri basin is given below.
|Sl. No||Project||State||Sub-Basin||Ins Cap||Status||Meeting date||Total Area Req. ha||Forest Land, ha|
|1.||Subansiri Lower||AP||Subansiri||2000||Under construction||EC on 16-07-03||4111||4039.9|
|2.||Subansiri Middle||AP||Kamla||1600||TOR Approved||25-09-10||3180||1333|
|3.||Nalo HEP||AP||Subansiri||360||TOR Approved||11-12-11||662.94|
|5.||Subansiri Upper||AP||Subansiri||2000||TOR Ext Granted||06-06-13||3155||2170|
Premature application Reading the PFR and Form I on the EAC website shows that project has come rather prematurely for TOR clearance. There is no gauge and discharge measurement site at the project site or anywhere in the catchment, the nearest site is at Upper Subansiri dam site with catchment area about 50% higher than that of Oju HEP. Even for this site, the flow measurement observations are available only for 6 years. How can optimum parameters of a massive project with 1850 MW capacity be formulated without any flow measurements, which is the most important parameter for hydropower project. Even now the flow measurements do not seem to have begun. There are no roads to the project area. It should be remembered that this is a virgin site, and there have been no environmental baseline assessments and yet the PFR and Form I are making all kind of sweeping assertions. The PP should be asked to get back with such an application only after they have at least five years of observation data of water flow and other parameters. That the application is premature is also apparent from the drastic changes the project capacity has gone through so far, as described in PFR.
This premature-ness of the proposal is further confirmed when we see contradictory figures in the submitted documents about basic project parameters. For example dam height is given as 110 m (sec 8) at one place and 115 m at another place. Live Storage capacity is given as 2.065 MCM at some place, 3.3 MCM elsewhere (e.g. sec 4.4 of PFR). Power intake design discharge is given as 327.4 cumecs at some places and 333.39 cumecs elsewhere (e.g. sec 2.2 of Form 1).
Proposal in contradiction with Cumulative Impact Assessment This proposal before EAC for a 1850 MW Oju project is in contradiction with what is given in the Cumulative Impact Assessment (CIA) commissioned by the CWC and which was discussed in the 68th meeting of EAC. The CIA says (see para 3 of Ex Summary) that there are two Oju projects: “Oju – I (1925 MW), Oju – II (2580 MW)”. However, the proposal now before the EAC is one project with capacity lower than any single project! However, Table on page 15 of CIA says Oju I has 700 MW and Oju II has 1000 MW capacity! The CIA says the submergence area of Oju I is 72.3 ha, though the proposal now before EAC for the same dam says the dam has submergence area of 42.3 ha! CIA says design flood is 10500 cumecs for Oju I (same dam as Oju now before EAC), but the proposal before EAC says PMF is much lower at 5983. This shocking series of numbers show that both the reports of Oju project before EAC and the CIA are misleading and do not seem to know what they are talking about. This is not an exhaustive list of contradictions, there are many more, this is only for illustration.
Proposal different than allotment The PP was allotted two separate projects Oju I and II by Arunachal Pradesh government, but they have decided to club the two, but there is no agreement between Arunachal Pradesh and PP for the new parameters in the project proposed before EAC. Without such an agreement, EAC consideration of the project would be vacuous.
Huge Land Requirement The Form I of Oju project states that the area which will come under submergence due to the formation of the reservoir excluding the river bed is 34.3 ha. Including the river bed the total submergence is 43.2 ha. But the total land requirement is 760 ha implying that the required for dam, water conductor system, power house and other project appurtenances is about 727 ha. It is not clear why 760 ha of land is required for the project when reservoir submergence is 43.2 ha.
Contradictory figures about Land Requirement The Form I in the table providing basin information about the project states that “The total land to be acquired for the project is 760 ha.” But the PFR in section 12.2 in page 15 states “It is estimated that about 790 Ha of land would be required for development of the Project.” This shows that the project proponent is not clear about the land requirement for the project.
Threat to Huge Forest area The construction of Oju HEP will be a threat to a huge forest area. Page 17 the Form I states “…760 ha of land with forest cover is to be acquired for the project. Forest cover is also observed within the project as well as area within 15 km from the project site.” But the PFR does not specify how much forest area will be actually diverted.
Installed Capacity is more than 1850 MW The installed capacity of Oju project is more than 1850 MW since a dam toe power house of 28 MW is also planned. This makes the total installed capacity in 1878 MW. The documents in most of the places mentioned installed capacity of the project as 1850 MW. The EAC therefore should ask the project proponent to apply for fresh TOR clearance with renewed installed capacity.
Oju Project Proponent aims to Construct Three Projects in the Name of One: Small Hydro project to Power the Construction Work The EAC should take a note that project proponent of Oju, is aiming to construct three hydro power projects in the name of one. We have already mentioned about the first two. Now in section 10.7 of page 10-7, the PFR documents states “The power requirement for construction activities is estimated to about 25.0 MVA taking into consideration the capacity of electric driven equipments which are to work during the construction period and lighting. The possibility of constructing small hydro power plants on streams in the vicinity of the project would also be explored at DPR stage.”
The Form I also mentioned about small HEP in page 10 -“The estimated peak requirement of power is about 25MW required for construction activity of major works such as tunnels, adits, barrage area and power house complex. Construction power requirement is proposed to be met by DG Sets/Small HEP.” Full details including impact assessment of this small HEP should be included in the TOR.
Stretch of Free Flowing River between Two Projects on Subansiri It is not clear how much flowing river stretch is available between Oju and downstream Nare HEP. According to the minimalist norms followed by EAC the free flowing stretch between two projects should be minimum one kilometer. But the PFR of Oju HEP have not clearly mentioned this distance anywhere. The Cascade development figure given in the PFR says that the elevation difference between TWL of Oju (1300 m) and FRL of Nare (1280 m) is just 20 m. If we look at the average slop at the site, this translates to about half a km. The PP should be asked to change the parameters to increase this to more than a km at least.
It is also important to specify this distance between two projects because of the cumulative impacts of the project. The Siang basin study in its recent version, which will be discussed in the same 72nd EAC meeting has asked to change the FRL and TWL of some of the projects because they have not kept minimum distance of one kilometer between projects. The basin study report in section 12.1.3 stated “…..it is recommended that FRL of three projects viz. Tato II, Naying and Siyom Middle should be slightly reduced so that free flowing river stretches of 1 Km can be maintained between FRL and TWL of these four projects in cascade.”
Therefore Oju HEP PFR should clearly mention the distance between its TWL and FRL of the downstream project. EAC also should make this compulsory for all the projects in other river basins.
Form I and PFR contradictory about the Generating Units The Form I of Oju HEP in page 20 states that the installed capacity of 1850 MW will be generated through eight units of 231.25 MW each. But PFR on the other hand, in section 9 of page 8 states “The underground powerhouse, housing eight units of 225 MW each, is proposed on the right bank of the river Subansiri.” It is surprising to find such contradictions in the Form I and PFR of Oju project.
The PFR in page 13 again states “As mentioned earlier, project’s installed capacity has been fixed at 1850 MW and correspondingly, eight generating units of 231.25 MW, each, are proposed in the powerhouse.”
Huge Diversion of the River The Oju HEP will divert a huge length of the river. Page 1 of the PFR states, “The dam site is located at about 60 km upstream of Limeking and powerhouse site is located at about 40 km upstream of Limeking on the right bank of Subansiri river.” This implies that the river has been diverted for 20 km between the dam site and the power house (The head race length is 14.82 km). . This is a huge diversion of the river Subansiri which will have disastrous impacts on the health and ecosystem of the river. But neither the Form I nor the PFR provide what is the length of the river to be diverted for the project.
Subansiri carries significant amount of sediment The PFR report of Oju project in section 7.5.2 states “Since Subansiri River is expected to carry some amount of sediment during monsoons, effective management of sediment removal from the reservoir should be ensured.” Stating that the river carries some sediment is not correct since this river system is known for high sedimentation due to its location in the young Himalayan mountain range.
Reference to this can be found in the January-March, 2003 issue Ecologist Asia (page 12) which was focused on dams in northeast “The catchments of the Brahmaputra and its tributaries show significantly high rates of basin denudation especially after the great earthquake of 1950. The catchments of the Subansiri, Jia Bharali and the Manas along with the Dihang (Siang) are estimated to have experienced an average denudation of 73-157 cm./1000 years over just 24 years (1955-79). The increasing amounts of sediment and water yields downstream indicate an increase in sediment yield by a whopping 240% accompanied by an equally significant rise of nearly 120% in water yield during the period 1971-1979 between Tsela D’Zong (China) and Ranaghat (India).”
Therefore first the sediment flow should be properly assessed.
Detailed and Thorough Options Assessment A detailed and through options assessment should be done for Oju project. There can be several other cost effective options for power generation in this area and options assessment should look into all such options. The options assessment should also look at whether the local people or the state needs such a huge capacity hydropower project.
It is important here to note that successful sub-megawatt capacity hydropower projects (Less than 1 MW) are currently under operation in Anjaw district of Arunachal Pradesh. (see – Anjaw shines in hydro power sector).
The TOR for the project does not include the following key aspects:
1. Issues related to cumulative impact assessment due to various components of the project and various projects in the basin.
2. The disaster vulnerability of the area on various aspects like landslides, earthquakes, floods, etc and how these will change with changing climate and how the project will change the disaster vulnerability of the area. There should be a separate chapter in EIA on this.
3. The project should do actual environment flow assessment and not just take the EAC norms as given. There should be separate chapter in EIA on this. The statement in Form 1 section 1.24 “Environmental Flows as per MOEF norms shall be released” is thus clearly premature and unwarranted. Eflows should be on daily changing basis and not seasonal averages.
4. Full Downstream social and environmental Impact Assessment
5. Impacts Peaking Power Operations
6. Assessment of impact of reservoir operation and mechanism to achieve transparent, accountable reservoir operation.
7. Impacts of Silt Management operations at various points of time and space.
8. Impacts of Tunneling and Blasting
9. Impacts of Mining of materials for the project.
10. Impacts of Backwater Effects of the reservoir in flood season
11. Impacts of Climate Change on dam
12. Impacts of the project on the adaptation capacity of the people in view of changing climate
13. Impact of peaking operation of the project on downstream areas and communities
No de-sanding chambers proposed in Silt Laden River The PFR in section 7.5.2 in page 7-5 states that “In this regard, it may be noted that no de-sanding chambers are proposed in the project in view of a relatively high dam with reservoir extending to almost 3.13 km.” Keeping no provision of de-sanding or de-silting chamber in the dam could have serious impacts on reservoir operations.
Form 1 undertaking not signed Page 2 of Form 1 is supposed to be an undertaking about the accuracy of information in Form 1, but there is no name, place or date for the signatory, all places are blank.
Poor reputation of consultants The PP has hired SNC Lavalin as consultant for DPR. However, SNC Lavalin has poor reputation in their country of origin (Canada), globally and even in Indian state of Kerala. How dependable would the work of such an agency be is a big question mark.
Parag Jyoti Saikia (with inputs from Himanshu Thakkar)
 Out of over 250 companies on World Bank’s current black listed from bidding on its global projects under its fraud and corruption policy, 115 are from SNC Lavalin and its affiliates, see: http://business.financialpost.com/2013/09/18/canada-now-dominates-world-bank-corruption-list-thanks-to-snc-lavalin/
 See: http://www.huffingtonpost.ca/daniel-tencer/snc-lavalin_b_4110591.html, the company has been banned by the World Bank due to corruption issues: “SNC-Lavalin, the engineering giant based out of Montreal that has now pretty much become a national (and international) embarrassment.” Its CEO has been arrested more than once for corruption charges.