Ground water recharge plan is a non-starter Though the latest report, covering assessment of ground level situation as on March, 2013, is still being compiled, sources in the Central Ground Water Board (CGWB) hinted at further increase in the number of `dark’ (over-exploited) units. Decline in ground water level due to over exploitation of available resources had prompted the Centre in 2013 to come out with a master plan for artificial recharge of ground water, specifying how different states would go about it on priority. But majority of the states have, so far, not implemented the master plan. Only six states -MP, Gujarat, W-Bengal, UP, Chhattisgarh and Karnataka have taken follow-up actions despite the fact that the number of `dark’ units increased from 802 in March, 2009 to 1,071 in March, 2011. This not only says what the title mentions, but also shows how slow our official agencies are in even coming up with groundwater data, the latest data is for March 2011!
Tag: Indus Water Treaty
DRP News Bulletin 19 Dec 2016 (Veteran environmentalist and water conservationist Anupam Mishra passed away)
Above: Anupam Mishra ji at the inaugural session of India Rivers Week 2016
Very sad to say that Anupam Mishra ji is no more. He breathed his last at AIIMS, Delhi at 5.27 am today (Dec 19 2016).
A person with such clarity of thought on water and river issues of India, such effective and simple way of communication, so affectionate and yet so humble will be difficult to find. As Ravi Chopra says, he was truely ANUPAM.
He was chairman of organising committee of India Rivers Week 2016 and also member of of Bhagirath Prayas Samman Jury since inception in 2014 and chairman since 2015. In spite of his poor health and weak body, he came to our organising committee meeting several times, last one in Sept 2016 and also came to the inaugural session of IRW 2016 on Nov 28, 2016 and spoke with characteristic clarity and simplicity and yet effectiveness. He was completely exhausted and pain at the end of it, but that he came in spite of that showed his dedication to the cause.
Personally he was most affectionate and encouraging to me, for so many years. God only knows how can one think of losing someone like that.
Himanshu Thakkar Continue reading “DRP News Bulletin 19 Dec 2016 (Veteran environmentalist and water conservationist Anupam Mishra passed away)”
DRP News Bulletin 11 Oct 2016 (Is there any justification for DESTRUCTION of Panna Tiger Reserve?)
Is there any justification for DESTRUCTION of Panna Tiger Reserve? Can we save our Natural Heritage like the Panna Tiger Reserve (PTR) from being destroyed in the name of baseless, questionable, non transparent, undemocratic and manipulated projects like Ken Betwa inter linking ? It will facilitate export of water from Bundelkhand to OUTSIDE Bundelkhand. Whatever little benefits are claimed, some of them are already available and much more can become available at much lower costs, faster and without destroying the Forests and Tiger Reserve. The project will actually lead to destruction of Ken catchment and hence the Ken River itself. Watch this FASCINATING, AWESOME story of tigers of PTR. This BBC film where Raghu Chandawat is the story teller and Pradip Kishen is lending his voice, tells the story of Tigers of Panna till 2003, it seems. Please watch and let us all try to save it from destruction that is now writ large in terms of Ken-Betwa Link Project (KBLP). One more short film by wildlife biologist Koustubh Sharma illustrates how the Daudhan Dam under KBLP will submerge and destroy the PTR.
Meanwhile, a new analysis of rainfall data reveals that monsoon shortages are growing in river basins with surplus water and falling in those with scarcities, raising questions about India’s Rs 11 lakh crore plan to transfer water from “surplus” to “deficit” basins. According to Himanshu Thakkar of SANDRP river basin interlinking should be considered only after exhausting the local potential for harvesting rain, recharging groundwater, watershed development, introducing better cropping patterns (non water-intensive crops) and methods (such as rice intensification), improving the soil moisture-holding capacity and saving and storing water. Raising alarm over significant increase in ground water use, increasing reliance and fast declining ground water table, he warns that inter-basin links would actually reduce groundwater recharge because forests would be destroyed, the river flow stopped and the local systems neglected.
So who will suffer in the Indus water imbroglio?
Diplomatic and military strategies, by definition, are not decided through public debates. So the jingoism around Indus treaty with Pakistan seems more like an attempt at sending threatening signals. But it will have multiple serious ramifications in any case, so it is worth deliberating about.
The 1960 Indus treaty has allocated rights of development on three eastern tributaries (Sutlej, Beas & Ravi) to India, and we have exhausted that entitlement almost fully. Attempts to use the occasional remaining flow will mean a huge impact in Indian Punjab, which is unlikely to resonate well with the people of Punjab. The treaty gave Pakistan dominant right of development of the three western tributaries (Chenab, Jhelum and Indus), India has limitations about water use (both in terms of quantity and manner of use) in case of the western rivers. India has not yet exhausted the entitlement in this case.
Continue reading “So who will suffer in the Indus water imbroglio?”
DRP News Bulletin 03 Oct 2016 ( Role of Uttarakhand Hydro Projects in Kedarnath Disaster 2013)
Book Review: Rage of the Rivers: Role of Uttarakhand hydro projects in Kedarnath disaster 2013 by Hridayesh Joshi Rage of the River reads not unlike a gripping thriller. Thing is, it is not fiction. It is a true ‘story’ of a cataclysmic event, exacerbated by greed, and twisted notions of development manifested in blasting fragile hills, tunneling rivers, denuding forests, and encouraging illegal encroachments and mindless construction and tourism infrastructure. This is an important chronicle of one of the worst disasters of our times. Joshi has thoroughly analysed the role of endless, ill-planned hydel projects, but inexplicably fails to take into account the wreckage wrought by unrestrained tourism. Joshi points a finger at the unethical practices of construction companies, contractors and operators of hydel dam projects, even in the face of this monumental disaster. The officials of the Vishnuprayag project refused to listen to the pleas of the villagers to open the dam gates and allow the excess water to flow safely from under the barrage. The advice was ignored, either in ignorance of the gravity of the situation, or with an eye on the opportunity to generate more power. The rising waters broke the barrage flooding the valley and its villages.
Sach Khas Hydro project in Chenab Basin: Another example of WAPCOS’s shoddy EIA
Even after multiple appeals by various experts, organizations and local people, Expert Appraisal Committee (EAC) set up by Ministry of Environment & Forest (MoEF) has once again chosen to ignore alarms of changing climate such as disaster of Uttarakhand in 2013 and has continued to consider Hydro Power Projects on Chenab Basin for Environmental Clearance (EC) before the Cumulative Impact Assessment of Chenab Basin has been accepted by MoEF. While on one hand the State Government of Himachal Pradesh has promptly appointed a committee headed by Chief Secretary to supervise and monitor all the progress and to “sort out” problems of getting various clearances “without delay in single window system”[i], on the other hand overall transparency of the Environmental Clearance Process has been steadily decreasing.
Sach Khas HEP (260 + 7 MW) (located in Chamba District of Himachal Pradesh) was considered by EAC in its 76th meeting held on August 11, 2014. Even though the project was considered for EC, no documents were uploaded on the website. Website does not even list the project under “Awaiting EC” category. This is in clear violation with MoEF norms, basic norms of transparency and Central Information Commission (CIC) orders. There are no fixed guidelines for documents to the uploaded, the time by when they should be uploaded and rules that project cannot be considered if the documents are not uploaded.
SANDRP recently sent a detailed submission to EAC pointing out several irregularities of the project. The comments were based on reading of the Environmental Impact Assessment (EIA) report available on the HP Pollution Control Board Website (which cannot be substitute for putting up the documents on EAC website). Environmental Management Plan (EMP) of the project is not accessible at all! Non availability of EMP on the HP Pollution Control Board website too is a violation of EIA notification 2006.
The EIA report which is prepared by WAPCOS is another example of a poorly conducted EIA with generic impact prediction and no detailed assessment or quantification of the impacts. Moreover since EMP is not available in the public domain, there is no way to assess how effectively the impacts have been translated into mitigation measures. Violations of Terms of Reference (TOR) issued by EAC at the time of scoping clearance is a serious concern.
Project Profile
Sach Khas HEP is a Dam-toe powerhouse scheme. The project has a Concrete Dam & Spillway with Gross storage of 25.24 MCM, Live Storage of 8.69 MCM and Reservoir Stretch at FRL of 8.2 km (approx.) Three intakes each leading to 5.8m diameter penstocks are planned to be located on three of the right bank non-overflow blocks. Three penstocks offtaking from the intakes are proposed to direct the flows to an underground powerhouse on the right bank of the Chenab river housing 3 units of 86.67 MW turbines with a total installed capacity of 260 MW. The project also proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project.
Sach Khas Hydro Electric Project was considered before completion of Cumulative Impact Assessment of Chenab Basin
Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[i]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K). 49 of these projects are planned or under construction in Chenab in HP and of which 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[ii]. MoEF sanctioned TORs for Cumulative Impact Assessment (CIA) of the HEPs on Chenab in HP in February 2012 however the project specific ECs were delinked from the CIAs[iii].
MoEFs Office Memorandum dated May 28 2013 states, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.”
We had pointed out in our submission against Kiru & Kwar projects in Jammu & Kashmir that CIA of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the Chenab River basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Looking at the fragility of the Himalayan ecosystem, considering any hydropower project in the basin without these studies will be an invitation to disaster[iv]. This fact has been repeatedly highlighted by multiple organizations and experts including SANDRP.
Sach Khas EIA Study: Gross violation of TOR
The EIA violates several stipulations of TOR issued on Feb 22, 2013, which also included the stipulations of EAC in Sept 2012 and Nov 2012 meetings where the project TOR was considered and also Annexure attached with the TOR. This has severely affected the overall quality of the EIA report.
About assessing the impacts of the project on wild life the TOR said: “Reaching conclusion about the absence of such (Rare, Endangered & Threatened) species in the study area, based on such (conventional sampling) methodology is misleading” as such “species are usually secretive in behavior”, “species specific methodologies should be adopted to ascertain their presence in the study area”, “If the need be, modern methods like camera trapping can be resorted to”. None of this is shown to be done in any credible way in EIA.
TOR also recommends intense study of available fish species in the river particularly during summer (lean) months with help of experimental fishing with the help of different types of cast and grill nets. There is no evidence in EIA of any such intensive efforts detailed here. In fact the field survey in summer moths was done in May June 2010, years before the EAC stipulation.
TOR (EAC minutes of Sept 2012) state “Chenab river in this stretch has good fish species diversity & their sustenance has to be studied by a reputed institute.” This is entirely missing. TOR (EAC minutes of Sept 2012) states “During the day, the adequacy of this discharge (12 cumecs) from aquatic biodiversity consideration needs to be substantiated”. This again is missing. TOR said 10 MW secondary station may be a more desirable option. This is not even assessed. TOR said Impacts of abrupt peaking need to be assessed. This is also not done. Site specific E-Flow studies and peaking studies stipulated by TOR are missing. TOR states that Public Hearing / consultations should be addressed & incorporated in the EIA-EMP. However there is no evidence of this in the report.
TOR also required following to be included in EIA, but many of them found to be missing: L section of ALL upstream, downstream projects; Project layout showing all components with A-3 scale of clarity and 1: 50000 scale; drainage pattern map of river upto project; critically degraded areas delineated; Demarcation of snowfed/ rainfed areas; different riverine habitats like rapids, pools, side pools, variations, etc;
Contradictions in basic project parameters
The EIA report provides contradictions in even in basic parameters of the project components: So section 2.1 on page 2.1 says, “The envisaged tail water level upstream of the Saichu Nala confluence is 2150 m.” This i s when the TWL is supposed to 2149 m as per diagram on next page from the EIA. Section 2.3 says: “River bed elevation at the proposed dam axis is 2145m.” At the same time, the tail water level is 2149 m. How can Tail water level of hydropower project be higher than the river bed level at the dam site? This means that the project is occupying the river elevation beyond what HPPCL has allocated to it. Page 23 of EIA says: “…the centerline of the machines in the powerhouse is proposed at 2138.00m…” So the Centre line o the power house is full 11 m BELOW the tail water level of 2149 m? How will the water from power house CLIMB 11 m to reach TWL level?
EIA report unacceptable on many fronts
Dam ht of 70 m was stated in TOR, however the report states it to be 74 from river bed. The submergence area, consequently has gone up from 70 ha at TOR stage to 82.16 ha, as mentioned in Table 2.2 of EIA. Total land requirement which was 102.48 ha as per TOR ha has now increased to 125.62 ha, with forest land requirement going up to 118.22 ha. This is a significant departure from TOR that should be requiring fresh scoping clearance. Part of the field study has been done for the project more than four years ago and rest too more than three years ago. There are not details as to exactly what was done in field study. EAC had noted in their meeting in Sept 2012, while considering fresh scoping clearance for the project, “EIA and EMP should be carried out afresh keeping in view the drastic changes in the features due to increase in installed capacity of the power house.” (Emphasis added.) The EIA report is thus unacceptable on multiple fronts.
No cognizance of Cumulative Impacts
CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.
On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.
The project is located between Purthi HEP upstream and Duggar HEP downstream. Elevation difference between TWL of Purthi (2220m) and FRL of Sach Khas (2219m) is barely 1 m. The horizontal distance between them is as less as 117m. This is clearly unacceptable and in violation of the minimalist EAC-MoEF norms.
Elevation difference between TWL of Sach Khas (2149m) and the FRL of Duggar (2105 m) is 44 m and the horizontal distance is 6 km. This is thus a cascade of three among many other projects in the basin.
Even so the report does not even mention the other two projects. EIA study is project specific and no cumulative impacts are assessed along with the other two projects. The EIA does not provide a list of all the HEP projects taken up in the Chenab basin in HP state[i]. The MoEF sanctioned TORs for conducting Cumulative Impact Assessment (CIA) of Chenab In February 2012. EAC considering any further project in Chenab basin before completion of the CIA study of the basin by a credible agency (not WAPCOS) and finalised in a participatory way will be in violation of the MoEF order of May 2013.
EIA report completely misses out on the detailed analysis of cumulative impacts in terms of disaster potential of the area and how the project will increase that; impacts on flora, fauna, carrying capacity, livelihoods; cumulative downstream impact, cumulative impact of hydro peaking. impacts on springs and drainage pattern; impacts of forest diversion on environment, hydrology and society and implementation of the Forest Rights Act; changing silt flow pattern in different phases, impacts of mining, tunneling, blasting etc. Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change has not been assessed. Project makes no assessment of impact of climate change on the project even when over 60% of the catchment area of the project is snow-fed and glacier fed. Options assessment in terms of non dam options as required under EIA manual and National Water Policy are missing.
Generic impact prediction
Impact prediction is too generic with no detailed assessment, which is what EIA is supposed to do. Impacts have not been quantified at all. The EIA report merely states the likely impacts in 2 or 3 sentences. Several important impacts have gone missing. None of the serious impacts have been quantified. For an informed decision making and effective mitigation and EMP quantification of impacts is essentially a pre requisite. Following are some such incidences:
Impacts of blasting & tunneling: TOR for the impacts on “Socio-economic aspects” says, “Impacts of Blasting activity during project construction which generally destabilize the land mass and leads to landslides, damage to properties and drying up of natural springs and cause noise pollution will be studied.”(p.196 of EIA Report). The total area required for Underground Works is 2.44 Ha. The project proposes underground power house with an installed capacity of (260+7). There are three TRTs proposed of length 99.75m, 113.13m, and 132.35m. Even so the impacts of blasting for such huge construction are simply disregarded in the EIA report by stating that “The overall impact due to blasting operations will be restricted well below the surface and no major impacts are envisaged at the ground level.” (p.165). While assessing the impacts of blasting on wild life the report states that direct sighting of the animals has not been found in the study area and the possible reason could be habitation of few villages. No attempt has been made to assess impacts of blasting like damage to properties, drying up of springs etc. This is a clear violation of TOR.
Impacts of Peaking & diurnal flow fluctuation: In the lean season during peaking power generation the reservoir will be filled up to FRL. As stated in report, this will result in drying of river stretch downstream of dam site of Sach Khas hydroelectric project for a stretch of 6.0 km, i.e. upto tail end of reservoir of Dugar hydroelectric project. The drying of river stretch to fill the reservoir upto FRL for peaking power will last even upto 23.5 hours, after which there will continuous flow equivalent to rated discharge of 428.1 cumec for 0.5 to 2 hours. Such significant diurnal fluctuation with no free flowing river stretch will have serious impacts on river eco system. There is no assessment of these impacts. Instead the report projects this as a positive impact stating “In such a scenario, significant re-aeration from natural atmosphere takes place, which maintains Dissolved Oxygen in the water body.” This is absurd, not substantiated and unscientific.
International experts have clearly concluded that: “If it is peaking it is not ROR”[ii]. In this case the EIA says the project will be peaking and yet ROR project, which is clear contradiction in terms.
Impacts on wild life: EIA report lists 18 faunal species found in the study area. Out of them 8 species are Schedule I species and 8 Schedule II species. Even so while assessing the impacts of increased accessibility, Chapter 9.6.2 b(I) of the report mentions “Since significant wildlife population is not found in the region, adverse impacts of such interferences are likely to be marginal.” If the project has so many schedule I and II species, the impact of the project on them must be assessed in the EIA. Moreover, massive construction activities, the impacts of long reservoir with fluctuating levels on daily basis, high diurnal fluctuation and dry river stretch of 6km on wild life could be serious. But the report fails to attempt any assessment of the same.
Impacts on geophysical environment are missing: The project involves Underground Works of 2.44 Ha. This involves construction of underground powerhouse, three headrace tunnels and several other structures. This will have serious impacts on the geophysical environment of the region and may activate old and new landslides in the vicinity of the project. The report makes no detailed assessment of this. Generic comments like “Removal of trees on slopes and re-working of the slopes in the immediate vicinity of roads can encourage landslides, erosion gullies, etc.” (p.176) have been made throughout the report. Such generic statements can be found in every WAPCOS report. Such statements render the whole EIA exercise as a farce. Project specific, site specific impact assessment has to be done by the EIA. Considering that the project is situated between Purthi HEP upstream and Duggar HEP downstream, a detailed assessment of the geophysical environment and impact of all the project activities is necessary. Further since the EMP is not at all available in public domain, it is difficult to assess what measures are suggested and how effective measures to arrest possible landslides have been suggested.
No assessment for Environmental Flow Releases
TOR states that the minimum environmental flow shall be 20% of the flow of four consecutive lean months of 90% dependable year, 30% of the average monsoon flow. The flow for remaining months shall be in between 20-30%, depending on the site specific requirements (p.192). Further the TOR specifically states that a site specific study shall be carried out by an expert organization (p.193).
The TOR also mandated, “A site specific study shall be carried out by an expert organisation.” However completely violating the TOR, the EIA report makes no attempt for the site specific study to establish environmental flows. Instead it proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. This completely defeats the basic purpose of the environmental flow releases. Such flows will help neither the riverine biodiversity, nor fish migration nor provide upstream downstream connectivity.
Socio-economic profile of the study area and Rehabilitation & Resettlement Plan are missing
TOR specifies a detailed assessment of socio-economic profile within 10 km of the study area including demographic profile, economic structure, developmental profile, agricultural practices, ethnographic structure etc. It also specifies documentation sensitive habitats (in terms of historical, cultural, religious and economic importance) of dependence of the local people on minor forest produce and their cattle grazing rights in the forest land. As per the TOR the EIA report is required to list details of all the project affected families.
Report however excludes assessment of socio economic impact of the study area. The total land required for the project is 125.62 ha, of which about 118.22 ha is forest land and the balance land 7.4 ha is private land. There are cursory mentions of habitations in the study area. Chapter 8.7 ‘Economically Important plant species’ states that in study area the local people are dependent on the forest produce such as fruits, timber, fuel wood, dyes and fodder for their livelihood. However the EIA report does not even estimate the population displaced due to land acquisition and impact of the various components of the project on livelihood of the people. Further detailed study is then out of question. This is again gross violation of TOR.
Indus Water Treaty
Chenab basin is international basin as per the Indus Water Treaty. A recent order of the international court has debarred India from operating any projects below MDDL and has disallowed provision for facility to achieve drawdown below MDDL in any future project[i] (for details, see: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/). The EIA described gate opening in this project for silt removal, which stands debarred by international court. The EIA thus is in violation of the verdict of international Court.
The EIA says (p. 21 bottom), “Five low level sluices with crest at 2167m of size 7.5m width and 12.3m height are proposed for flood passage. Drawdown flushing of the reservoir shall be carried out through these sluices for flushing out of the sediment entrapped in the reservoir. Detailed studies on sedimentation and reservoir flushing can be taken up at detailed planning stage.” The MDDL of the project is 2209.3 m as mentioned in the same para. This means the project envisages sediment flushing by drawdown to 2167 m (sluice crest level, the sluice bottom level wll be 12.3 m below that), about 42.3 m below the MDDL. This is clearly not allowed under PCA order cited above on Indus Treaty.
Impact of 3.5 MW Chhou Nala HEP to be constructed for the project not assessed
The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project. But the EIA does not contain any impacts of the SHP. The stream on which this is planned is extremely important for the people as drinking water schemes, irrigation Kuhls and gharats of Rai, Chhou and Thandal villages are located on this stream in the proposed project area. Thus the project will have huge impacts, but there is no assessment of these impacts. This is another glaring omission of EIA. It was shocking to read that the resident commissioner said at the public hearing that this question is not part of Environmental Public hearing, when it is very much part of it.
Public hearing report
At several places either no information is given or misleading information has been presented. For example the project representatives mis-informed the people at PH that 15-20% water will be released, when minimum water they need to release is above 20%. DFO said that soil will be spread over the muck disposal site for tree planting over it, but there is no provision of this in EIA-EMP. Many questions were provided with vague answers or no answers at all. No clear answer was given when asked if the muck dumping sites have been decided in consultation with the local people, implied answer is clearly that local people have NOT be consulted. When asked about agreements to ensure that the company implements EMP and Social Management Plan as required, there was no promise that such an agreement will be signed with the village gram sabhas. The affected people raised the issue of erosion impact of diversion tunnel, but no specific response was provided in response to this issue. When a resident of Chhou village raised the issue of vulnerability of the village to the landslides, no clear answer was given by the project developer. When the same person asked that our cremation ground is going under submergence, what is the company planning about it, the project developer replied that IF the cremation ground goes under submergence, we will think about this. This only shows that the project developer and EIA consultant have not even done an assessment of such basic aspects. The PH report accepts that close to 100 workers are already working without even basic sanitation facilities, this is clear violation of EIA notification further the EIA Agency fails to mention this.
EIA is full of cut and paste, generic statements, no actual assessments
Out of nine chapters of EIA, only the last chapter is about impacts assessments! So out of 170 pages of nine chapters, only 31 pages of chapter 9 is supposedly about impact assessment and there too mostly there is no real impact assessment, mostly only generic statements that can be included in any EIA. There are several unnecessary sections in the EIA like chapter 3 on “Construction Methodology” which is unnecessary in EIA. In most other sections too, the information is just cut and paste from DPR. By way of impact prediction, the EIA report is only listing them doing absolutely NO ASSESSMENT and no quantification of impacts is attempted. Further since the EMP is not available in the public domain, it is impossible to assess if the measures provided in the EMP are effective. Such EIA is definitely not acceptable.
No proper referencing The EIA does not provide references to the specific information, without this it is difficult to cross check which information is from which secondary sources and how credible it is and which information is from primary survey.
Conclusion
This is another most shoddy piece of EIA by WAPCOS.
Moreover, as we can see the EIA has not done several impact assessments, has violated large no of TORs on several counts, the EIA-EMP are not available on EAC website, the project parameters have undergone changes necessitating fresh scoping clearance as mentioned in TOR but that has not happened, baseline study is 3-4 years old, EAC stipulation of fresh EIA-EMP has been violated, Project is using larger riverine stretch than given by HP govt, there is no proper referencing, hydrology is weak, EMP is not available on HPPCB website in violation of EIA notification, among several other issues listed above. Every conceivable serious problem can be found in this EIA of WAPCOS.
It is full of generic statements that can be pasted in any EIA without any attempt at project specific impact assessment. SANDRP has been pointing to EAC and MoEF about such unacceptable EIA by WAPCOS for several years, but neither EAC, nor MoEF has taken any action in this regard. SANDRP has once again urged to EAC and MoEF to reject this EIA and recommend blacklisting of WAPCOS and to issue fresh scoping clearance for the project as mentioned in the TOR since the project parameters (dam height, submergence area, land requirement, etc) have gone through significant changes.
We sincerely hope the EAC will not only take serious cognition of these and not recommend clearance to the project, but also direct the project proponent and EIA consultant to implement other recommendations made above.
Amruta Pradhan (amrutapradhan@gmail.com), Himanshu Thakkar (ht.sandrp@gmail.com)
[i] https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/
[ii] See for example https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf
[iii] https://sandrp.wordpress.com/2014/07/01/if-its-peaking-its-not-an-ror-interview-with-dr-thomas-hardy-iahr-and-texas-state-university/
[iv] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/
[v] https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf
[vii] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/
[viii] Refer to SANDRP studies on Chenab
– https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf
[ix] http://northgazette.com/news/2013/04/25/special-committee-to-monitor-hydro-projects-in-hp-cm/
Massive Kwar and Kiru HEPs on Chenab, J and K : Poor quality & cut paste EIAs, flawed public hearing
Massive Kwar and Kiru HEPs on Chenab, J and K : Poor quality & cut paste EIAs, flawed public hearing
It seems we do not want to learn any lessons from the massive Uttarakhand disaster of June 2013. Two more huge capacity hydropower projects have been submitted to the Expert Appraisal Committee (EAC) of Ministry of Environment & Forest (MoEF) for grant of Environmental Clearance (EC) with very poor quality Environmental and Social Impact Assessment (EIA) reports.
EIA reports of Kiru Hydro Electric Project (HEP) (660MW) and Kwar HEP (560 MW) proposed in Kishtwar district, Jammu and Kashmir by Chenab Valley Power Projects Ltd. (CVPP) were submitted to the EAC for River for its 74th meeting held on 5-6 May, 2014 for grant of EC. The projects are run-of-river schemes proposed on river Chenab as a part of cascade development of Chenab basin.
Vicinity Map (Source Kiru EIA Report)
Partial Map of Commissioned and Proposed HEPs in Chenab River Basin (Map by SANDRP)
Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[1]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K).
While 49 of these projects are planned or under construction in Chenab in HP, 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[2]. State of J&K has 13 projects planned of total capacity 8,623 to 8,923 MW. These consist of at least four operational projects (of total 1563.8 MW), three under construction projects (of 1450.5 MW) and six proposed projects (of 5608.7 MW).
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Table 1: Cascade Development of Chenab Basin Source: EIA report of Kiru & Kwar |
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| Sr. No. | Scheme | River | Capacity |
| 1 | Salal (Stage- I & II) | Chenab | 690 MW |
| 2 | Sawalkot | Chenab | 1856 MW |
| 3 | Baglhar (Stage-I & II) | Chenab | 900 MW |
| 4 | Shamnot | Chenab | 370 MW |
| 5 | Ratle | Chenab | 850 MW |
| 6 | Dulhasti | Chenab | 390 MW |
| 7 | Kwar | Chenab | 560 MW |
| 8 | Kiru | Chenab | 660 MW |
| 9 | Kirthai-I | Chenab | 350 MW |
| 10 | Kirthai-II | Chenab | 990 MW |
| 11 | Barinium | Chenab | 240 MW |
Himalayan ecosystem, of which the Chenab river basin is a part, is known to be geologically fragile. Cascade of hydel projects proposed on the river basins of this region would make the region even more vulnerable to extreme and erratic weather events, which will increase in changing climate. This has already been witnessed during Uttarakhand disaster of June 2013. Expert Body (EB) headed by Dr Ravi Chopra recently has officially acknowledged this connection in the report submitted to MoEF[3]. In light of this, a thorough impact assessment of all the proposed hydro power projects in this region is thus of critical importance. Various organizations and experts including SANDRP have repeatedly highlighted the fact that Cumulative Impact Assessment (CIA) of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the river basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Without such a study, considering any hydropower project in the basin will be an invitation to disaster[4].
Even though the MoEF sanctioned TORs for cumulative impact assessments of the HEPs on Chenab in HP in February 2012, this critical task was entrusted to the Directorate of Energy, Government of Himachal Pradesh. This is a clear case of conflict of interest. Further the project specific ECs were delinked from the CIAs[5].
More importantly, no such study has been initiated in Chenab basin in J&K or in the Chenab basin as a whole. State of Jammu and Kashmir is not even considering CIA of HEPs on Chenab in the state as MoEF has not asked for it yet. CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.
On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.
MoEF continues to give clearances to individual HEP projects despite of poor quality Project Feasibility Reports (PFRs) and EIA reports submitted for appraisal. Kiru & Kwar EIA reports are a classic example of such poorly conducted EIAs. The EIAs demonstrate several serious issues across various stages from TOR non-compliance, non assessment of impacts, cut and paste job, lack of any references, faulty public hearings, the issued raised at public hearings have not been addressed in EIAs, as statutorily required. SANDRP recently made detailed submissions to EAC highlighting these issues for both the projects. Some highlights below:
Copy paste job while preparing EIA reports Both the reports are prepared by a consortium of RS Envirolink Technologies Pvt. Ltd. (Gurgaon) and Jammu University. Kiru EIA report demonstrates a casual approach towards impact prediction and proposing mitigation measures in EMP. The report also misses out on a number of important aspects of EIA like impact of construction activities on geology, flora fauna, impact of climate change, cumulative impacts of cascade development in Chenab basin etc. While Kiru EIA is inadequate on several fronts it was utterly shocking to discover that Kwar EIA report is a complete replica of the Kiru EIA Report. Entire text, save project specific numbers, remains the same in both reports, to the extent that the Kwar EIA report mentions Kiru instead of Kwar at several places!! The impact prediction for both the cases is so vague and generic that the changes in numbers for project-specific details like proposed installed capacity, submergence of reservoir, FRL, head race tunnels etc. do not reflect at all in the reports!
Brief Project Profiles Kiru H.E. Project and Kwar H.E. Project are run-of-river schemes proposed on river Chenab located in the district Kishtwar of J&K.
Kiru HEP envisages the construction of a 193 m long and 123 m high concrete gravity dam above the river bed across river Chenab at village Kiru with four intake, four pressure shafts, an underground powerhouse of 4 units of 165 MW each. Impoundment will cover an area of 1.03 Km extending 6.5 km upstream of dam. The average river bed level at the dam site is about EL 1394 m corresponding to an FRL of 1515 m, the gross storage of the reservoir is 41.50 Mcum and area under submergence is 1.03 Km.
Proposed dam site for Kiru HEP(Source Kiru EIA Report)
Kwar HEP envisages construction of a concrete gravity dam 101 m high from river bed across river Chenab at village Padyarna, four number intakes, four pressure shafts, an underground powerhouse to accommodate 4 units of 140 MW each and two number tail race tunnel. FRL of reservoir is proposed at EI 1385M. Gross storage of the reservoir at FRL is 27.167 Mcum. The reservoir will submerge an area of about 0.8 Sq. Km at FRL.
Proposed dam site for Kwar HEP (Source Kwar EIA Report)
TOR non-compliance First and foremost glaring issue about the proposed projects is the non-compliance with the TORs (Terms of Reference) laid down for conducting the EIA. These TORs were granted by MoEF. We have listed here only an indicative list of non compliance below, not an exhaustive one.
Kiru HEP The TOR clearance letter was issued for Kiru project on Sept 9, 2008, the TORs are valid for a period of 3 years, but the project developer never came back for extension of the TOR on expiry of 3 year period and has come now for EC over 5.5 years after the TOR clearance. Thus the TOR clearance is no longer valid for Kiru HEP as per the law. Also originally the TOR clearance for Kiru was given for 600 MW installed capacity. The EIA however has been conducted for 660 MW capacity. No permission was sought by the PP for this increased capacity.
Kwar project has undergone several changes since the grant of TOR on 17 March 2010. Table given below compares some of these changes. First and foremost alteration has been in the proposed total power generation. While the TORs were granted for 520 MW the EIA has been conducted for 560 MW. Number of affected families goes up by 160% and project cost escalates by 29%. The TORs were granted for over four years back and the project authority never got back to EAC/MoEF for renewal of the TOR as other projects do. Thus the TORs granted originally do not remain valid in this case too.
| Table 2: Changes in the scope of Kwar project after grant of TOR on 17 March 2010 | |||
| Sr. No. | Parameter | Scope at the time of TOR clearance | Current scope of the Proposed Project |
| 1 | Total power Generation | 520MW | 560 MW |
| 2 | Land requirement | 5 Ha Government land | 93.66 Ha Government land |
| 3 | Power House Units | 4 x 130 MW | (4 x 140MW) |
| 4 | Affected families | 35 | 91 |
| 5 | Project Cost | Rs 3386.11 Cr | Rs. 4375.50 Crores at Jan’2012 PL |
Casual approach towards impact prediction
Kwar EIA copy pasted from Kiru EIA report: It is evident that the EIA consultants have done nothing but copy paste job while preparing Kwar EIA report. At certain places Kwar report mentions ‘Kiru’ instead of Kwar. See for example point number 1.7 in Index of Kwar EIA mentions ‘Need of the Kiru HE project’ instead of Kwar and point number 4.4 mentions ‘Basin characteristics of free draining area of Kiru HEP’ (p.3 & p.6 of the document). Page 28 of Kwar EIA states that “The case for forest clearance of Kiru HE Project for diversion of 29.75 ha of forest land has been approved in the 81st meeting of J&K State Forest Advisory Committee (FAC) held on 09.12.2013…”
Other than very project specific figures, the entire text for both the reports is exactly the same. Impact prediction is the heart of an EIA study. However in Kwar EIA report an important chapter like Chapter 8- “Identification, Prediction and Evaluation of Environmental Impacts” is also copy pasted. The text of the chapter is same as that of Chapter 8 from Kiru EIA report save the project specific numbers and their description. The impacts predicted are vague and are conveniently kept the same in both the reports. It is clear that no real field work or application of mind is done. Such an EIA study defeats the basic purpose of conducting an EIA.
Impact of construction activities: The Kiru project involves a reservoir of live storage 10.5 MCM, a concrete dam on height (from river bed) 123.0 M & length 193 M, construction of 4 head race tunnels (of 7 m dia and 165 to 190 m length each) for discharging the water to an underground powerhouse of 4 units of 165 MW each. The project also envisages 33.4 Lakh CuM of construction material required from the project site.
The Kwar project involves construction of 101 m (above river bed)/ 109 m (above deepest foundation) high concrete gravity dam, Underground power house complex of four units of 140 MW each, Two concrete lined 9.5 m internal diameter main tailrace tunnels (having length of 2676 m and 2883 m) amongst several other features like four 5.65 m internal diameter main pressure shafts (each with a length of 108-182 m), etc. The project also envisages 38.36 Lakh CuM of construction material required from the project site.
View of Naigarh Nala Rock Quarry at Kwar Dam site (Source Kwar EIA Report)
All these activities will have significant impact on the geology and hydrology of the region. However no significant assessment or quantification of these impacts in terms of change in drainage patterns, springs in the project area, increased thereat of landslides, seismic activities has been carried out.
While talking about the impact of construction activities, the only impact of these two EIAs discussed in the chapter is ‘muck generation’. It does not mention impacts of tunneling and blasting involved in construction and also does not talk about its impact on fragile geology and hydrology of Himalayan region at all[6]. While talking about quarrying activities in the same chapter it states only two impacts viz. visual impacts and noise generation[7]. Impacts on landslides have been randomly dismissed stating that the sliding activity may not be significantly induced by project construction activities[8]. The reports trivialize the impacts on migratory fish Mahseer by stating that the upstream migration of this fish from the lower reached of the Chenab River have already been blocked by Salal and Baglihar, Dul Hasti dams. Thus they conclude that impact of this project on this fish species is not expected to be significant[9]. Option for fish ladder and fish lift has been ruled out for both the projects stating that it is not techno-economically feasible at the project site. Development of a hatchery at the project site has been proposed instead. The impact of the project on all the fish available in the river should have been assessed based on baseline assessment of the fisheries in Chenab River, which is not done. Secondly, there is no credible evidence to show that hatchery as a management option is useful or effective.
Left Bank slide for Kiru Project downstream of Ludrari Nala (Source Kiru EIA Report)
Right Bank slide for Kiru Project about 16 km downstream of Gulab Gargh (Source Kiru EIA Report)
The southern boundary of the Kishtwar National Park is approximately at an aerial distance of 11 km away from the proposed project, it is claimed, but this needs to be independently assessed. Also, just because it lies outside the boundary of study area which is radius of 10 KM, the EIA does not consider the impacts on this national park at all! EIA reports for both Kiru and Kwar HEPs simply state that the proposed activities shall have no impact on the National park[10].
Biodiversity at Kishtwar National Park (Photo: Travel Places[11] & Beauty Spots of India[12])
Several Important aspects of EIA are missing
No mention of free flowing river stretch: There is no mention of what is the flowing river stretch upstream and downstream of the project. As is clear from the EIA, the elevation difference between FRL of Kiru HEP (1515 m) and TWL of upstream Kirthan II (1526.5 m) is just 11.5 m. The elevation difference between TWL of Kiru HEP (1388 m) and FRL of downstream Kwar HEP (1385 m) is just 3 m. Similarly the elevation difference between TWL of Kwar HEP (1270 m) and FRL of downstream Hasti HEP (1264 m) is just 6 m. However, it is not clear what the flowing river lengths in all these locations are. Unless this length is assessed and is found to be adequate for river to regain its vitality, the project should not be considered and it should be asked to change the parameters.
Environmental Flows: The Kiru EIA report states that significant downstream impacts related to the water quality, fisheries, socio-economic and aquatic biodiversity are not foreseen since toe power house is proposed downstream of the dam and tail water level is EL 1388.52 m, discharge will be less only in a “very small stretch of about 800 m”. This seems to show the ignorance of the EIA consultants about how biodiversity in a flowing, lively river like Chenab survives.
Kwar EIA report states that the water entering the reservoir will be released back to river at a distance of 2.6 KM downstream. The report claims that though there in no human activity in this stretch of 2.6 KM the aquatic life will be definitely affected, as also terrestrial biodiversity, groundwater recharge, use of river and silt flow pattern.
10% of average of lean season discharge has been prescribed to be released through the dam gates as environmental flow for both the projects. This quantity has been calculated as 9.0 cumecs based on discharge data of the river. There is no mention of environmental flows in EMP. Firstly, this is even below the norms being followed by EAC and MoEF (30% in monsoon, 20% in lean season and 25% in rest, each at 90% dependability). Secondly, the amount of E-flow required needs to be arrived at based on actual assessment, but no such assessment has been done.
Impact of peaking generation not assessed: The reports talk about advantage of hydropower in terms of ability to providing peaking power. However, when a project operates as peaking station, there are severe impacts in the downstream and also upstream (rim stability). These impacts have not been assessed, nor is it assessed how the project will perform in the cascade development it is in.
Some other important aspects of impact assessment that report misses out on are:
- Impact of the project on disaster potential in the project area as well in the downstream due to construction and also operation at various stages, say on landslides, flash floods, etc.
- Social and Environmental Impacts of construction and operation of the coffer dams and diversion tunnels during construction phase are not included.
- The reports do not even mention Climate Change.Impact of climate change on the project and impact of the project on the local climate has not been assessed. No mention or attempt has been made about or to assess the impact of green house gas emissions from the project.
- Impacts on the flood characters of the river due to this dam, what will be the changes and how these will impact downstream areas.
- Impact of changing silt flows downstream from desilting chamber and from silt flushing in monsoon on the downstream areas not analyzed. A detail account of how the silt from the dam would be flushed out annually and what would be the impact of this in the downstream as well as on the geo morphology, erosion, stability of structures etc was not done.
- Options Assessment is missing, this is crucial part of the EIA to establish that among all options, including non project option, the given option is the least cost and best option.
Cumulative Impacts not assessed The EIA report gives list of Major hydroelectric projects executed /under execution/ under investigation so far in the basin in J&K which are a part of Cascade Development. Kirthan HE Project (990MW with proposed FRL at 1764 m and TWL at 1526.50m) which is yet to be commissioned is proposed upstream of Kiru (660 MW with FRL at 1515M). Downstream of Kiru is Kwar HE Project (560 MW with FRL at 1385 m and TWL at 1270 m) which is yet to be appraised and Dul Hasti HE Project (390 MW with FRL at 1264 m) which is commissioned.
Impoundment of Chenab at Dul Site (Source: Kwar EIA Report)
Moreover, the EIA does not provide the list of hydropower projects being taken up in Chenab basin in upstream Himachal Pradesh[13]. The cumulative impacts of all such projects will be huge.
The report summarizes cumulative impacts in single sentence: “The increased pressure will include uncontrolled logging, hunting of wildlife, non-timber forest product collection, livestock husbandry, the cultivation in forest areas and forest fires.”[14]
EIA report completely misses out on the detailed analysis of cumulative impacts in terms of
- Impacts on flora, fauna, carrying capacity, livelihoods
- Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change
- Impacts on springs and drainage pattern
- Disaster potential of the area
- Tunneling and blasting
- Geological disturbance caused
- Seismic impacts
- Carrying capacity
Inadequate Dam Break AnalysisThe Dam break analysis does not take into account the cumulative disaster potential including existing and proposed upstream and downstream projects. The EIA report also does not include cumulative disaster management plan.
Improper Public Hearing Public hearing conducted for both the projects were flawed. Excerpts from the speeches made by the officials from J&K State Pollution Control Board (SPCB) and CVPP that are noted in the public hearing report show that what these persons spoke was inappropriate, misleading and intimidating[15]. Also point wise responses to the issues raised by people at the Public Hearing are not provided in the EIA, as statutorily required. Hence even when people ask for Resettlement and Rehabilitation as per latest Act of 2013 (made effective from Jan 1, 2014), the EIA talks about National Resettlement and Rehabilitation Policy of 2007. The public hearing report strangely end for both projects with the officials asking those who are for the projects to raise their hands. There is no formal provision for voting for or against the project. Such public hearing should be declared null and void and fresh public hearing should be conducted.
Poor quality EIA reports that reflect pro hydro bias of the consultant EIA is the most effective tool to ensure environmental compliance in India. Needless to state that it is of critical importance. Casually predicted, unaddressed impacts and copy paste job of the Kiru and Kwar EIA reports once again highlights the poor quality of EIA reports submitted to the ministry for grant of EC. These reports decide fate of the project, of the people and environment surrounding the project site. Such quality of the report is most definitely not acceptable.
Further, an EIA report is an attempt to understand what are the adverse social and environmental impacts of a project and weather the impacts are acceptable, if the project is viable, optimal and desirable. The answer to this exercise can also include the answer that the project is not viable or desirable or acceptable. In view of this, the EIA consultant needs to be completely unbiased and should be ready to even conclude that the project is unacceptable. However, in case of the EIA consultant for the Kiru & Kwar HEP, EIA starts in very 1st chapter with a shockingly unscientific and biased statement: “Hydropower projects are dependable, renewable, economic, environmentally benign sources of energy with ability to stop and start instantaneously.” This statement is factually wrong on many counts (e.g. hydropower project is renewable or dependable or environmentally benign source of energy). It, along with whole para 1.2 also reflects the bias of the EIA consultants RS Envirolink Technologies Pvt Ltd (with Jammu University) and we urge the EAC and MoEF to reject such poor quality and biased EIAs and take other necessary steps to debar such agencies from doing any EIA or environmental studies in future.
CONCLUSION Looking at serious issues above, based on merit of the EIA reports, as well as complete cut-paste jobs, we are hopeful that the MoEF will not recommend EC for these projects. This case also highlights the importance of cumulative impact assessment in an over developed Himalayan basin. When the experience with Uttarakhand flood disaster of June 2013 is fresh, we hope that MoEF will not commit another blunder.
Amruta Pradhan, SANDRP
END NOTES:
[2]https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf
[4] Refer to SANDRP studies on Chenab
https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf
[6]p.291 of Kiru EIA Report & p.288 of Kwar EIA report
[7]p.293 of Kiru EIA Report & p.289 of Kwar EIA report
[8]p.298 of Kiru EIA Report & p.294 of Kwar EIA report
[9]p.307 of Kiru EIA Report & p.303 of Kwar EIA report
[10]p.221 of Kiru EIA Report & p.223 of Kwar EIA report
[11]http://www.4to40.com/travel/index.asp?p=Kishtwar_National_Park&state=Jammu_and_Kashmir
[12]http://beautyspotsofindia.com/kishtwar-national-park-jammu-kashmir/
[13] See for example: https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf
[14]P. 306 of Kiru EIA
[15]The Public hearing report of Kiru says that Shri Sajjad Mufti, Regional Director of J&K SPCB said at the public hearing, “Construction of project should not deteriorate the environment….” This is a very strange, untruthful and inappropriate statement from J&K SPCB official. Why should the official be speaking at all at the public hearing and that too make such a statement that would also affect the atmosphere of the public hearing? Similarly the statement of GM of CVPP at the public hearing, “The most viable and cleanest of all (sources of power) is hydro power” was again, wrong, intimidating and inappropriate. The statement of Shri Khursheed Ahmed Butt of CVPP, “forest clearance has already been granted to the proposed project” is incorrect since the proposal for forest clearance for the project has not even come before FAC. Such public hearing should be declared null and void and fresh public hearing should be conducted.
The Public hearing report of Kwar says that the GM of CVPP said at the public hearing, “The best source of power generation is hydro power” was wrong, intimidating and inappropriate. The statement, “forest clearance has already been granted to the proposed project” is incorrect since the proposal for forest clearance for the project has not even come before FAC.
[16] See for details and link to PCA orders: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/
SANDRP 