As Prime Minister Narendra Modi inaugurated the RE-Invest 2015, India’s first Renewable Energy Global Investors’ Meet and Expo in New Delhi on February 15, 2015, full-page advertisements in the National Capital declared the target of adding 5000 MW of small hydro capacity by 2022, in addition to other renewable energy targets. A part of this renewed focus on small hydro, a subset of India’s new push for Renewable Energy, involves a new Mission for Small Hydro Projects. Even as it has some welcome features, the new Mission will not help if the government continues to ignore significant social and environmental impacts of small hydro projects. Continue reading “Mission on Small Hydro Projects: Ignoring social and environmental impacts will not help”
24.75 MW Mouneswar + 24.75 MW Basavanna ‘Small’ Hydel Projects = One large HEP
According to the Ministry of New and Renewable Energy (MNRE), hydel projects between 2-25 MW are classified as Small Hydel Projects (SHPs). These projects are exempt from Environmental Clearance, impact assessment, public consultation or any monitoring from the Ministry of Environment and Forests (MoEF), receive subsidies from the MNRE and apply for Carbon Credits from United Nations Framework Convention on Climate Change (UNFCCC).
Though the concept of encouraging small hydel projects as sources of decentralized energy, also supplying off grid power seem welcome, the happenings on ground are vastly different. As these projects are excluded from environmental governance, there are several examples of fraudulent Small Hydro projects, which exploit the lax governance mechanism to hoodwink all concerned.[i]
One such recurring fraud is showing two separate projects on paper, in order to avoid environmental scrutiny and avail subsidies meant for SHPs, while building one single big dam on site, clubbing the two projects. Projects like Perla and Shemburi by Greenco in Mangalore or Maruthi Gen projects in Sakaleshpur (http://www.dnaindia.com/bangalore/report-maruti-power-gen-s-hydel-project-an-environmental-disaster-1617237), all in Karnataka Western Ghats, are two example of this fraud.
One more case has now come to light, this one from Gulberga district in north Karnataka when I visited the project area recently. Although called by two different names, 24.75 MW Mouneswar Small Hydel Project and 24.75 MW Basavanna Hydro Project are operating from a single dam/diversion weir across the KrishnaRiver, just downstream Narayanpur Dam. As such, the project should be considered as a single 49.50 MW hydel project and should undergo immediate environmental, social and legal scrutiny and further assessment. We tried to conatct the officials of the company several times for questions related to the projects, but we got no response.
24.75 MW Mouneswar and 24.75 MW Basavanna SHEPs are built across river Krishna in Benchagaddi village of Shorpur taluk of Gulberga district in Karnataka.
The projects have also applied for Carbon credits under the United National Framework Convention on Climate Change (UNFCCC). Basavanna Hydro Project has been registered as a Clean Development Mechanasim (CDM) project with the UNFCCC on 28th December 2012 and its crediting period has been fixed as 1st March 2013 to 28th February 2023[ii]. 24.75 MW Mouneswar SHP has applied for registration[iii]. SANDRP has sent comments against registration of this project.[iv]
Shockingly, both projects have requested separate registrations, hiding the fact that both will be using the same dam, the same intake/power canal and the same tail race canal.
Project design documents (PDDs) submitted to United Nations Framework Convention on Climate Change Executive Board (UNFCCC – EB) mention the same coordinates as the project location:
Latitude- 16°19’52 “N
Longitude- 76°33’48” E
PDDs of both the projects do not even mention the other project, clearly misleading the UNFCCC. Not only do the PDDs show same coordinates, the lengths of the intake canals are exactly the same at 2771 meters, so are the RCC conduits and penstocks, because we are talking of the same project!
Carbon Credits are supposed to be provided to projects only when they prove beyond doubt that they will be economically unfeasible without such support. However, in this case the expenses of dam, power canal, and tail race tunnel is shared and hence the costs will be lowered, the Internal Rate of Return (IRR) of the projects will be higher than what is quoted in the PDDs and they will be profitable even without additional ‘pocketable’ finance from the UNFCCC in the name of Clean Development! (IRR claimed in the PDD is 9.14% for Mouneswar SHP and 11.38% for Basvanna SHP.)
Same Proponent, different names
Interestingly, project proponents of both the projects are shown to be different in respective PDDs. For Mouneswar Small Hydel Project it is Lakshmi Jalavidyut Limited and that for Basavanna Hydro Project it is Krishna Hydro Energy Limited. However, the registered office of both these firms is the same! This address also belongs to Penna Cements, Hyderabad, which is a player in Mini hydel projects in Karantaka. Penna Cements and its subsidiary Pioneer Genco already operate two SHPs, each of 24.75 MW capacity across Cauvery in Karnataka.
From the ground
When SANDRP visited the project sites, the officials were hostile to any entry in the premises or even near the site.
The dam/ diversion weir built by the projects is inside the KrishnaRiver bed and diverts the water through a power canal which runs approximately 3 kms downstream. The power canal takes most of the water from the river rendering the river dry in lean season.
Farmers told power canal as irrigation canal:
When I talked with the farmers in the downstream, they told me that they were under the impression that this canal is meant for irrigation, like Narayanpur Dam canals in the upstream (about 26 km). However, Benchagaddi village which is situated next to the tail race canal of the project not allowed to take even its drinking water from the canal.
There have been strong protests from the villages to this project as the diversion has dried the river bed and more than 300 irrigation pumps of villages like Bechagaddi, Hosur and Yedalabhavi used for irrigating paddy are now useless. Karanataka Bhagya Jal Nigam had also taken serious exception to the projects and had ordered a stop work notice.[v] (It subsequently issued an NOC, without providing any resolution to the issues raised by it earlier.)
The Benchagaddi village which is right next to the power canal experiences power cuts lasting 18-20 hours daily. Around 40 farmers from this village lost their lands for the canal. Rates of compensation given were Rs 25-85 thousand per acre.
Shockingly fraudulent Local Stakeholder Consultations!
The projects have claimed to have organised ‘Local Stakeholder Consultations’ about the CDM mechanism, which is mandatory when applying for CDM credits. PDD claims that Mouneswar project organised stakeholder consultations on 21st December 2011 and Basavanna project organized it on 26th September 2011.
Now see this, both PDDs mentions exactly the same people asking exactly the same questions with exactly the same answers being given!! It is absolutely clear that these meetings and these reports are fake. Amazingly, UNFCCC could not see through this clear fraud.
Local Development through Small Hydels?
As per the villagers, affected families were promised a job in the power plant although none of them received any jobs there. Even the JCB and truck operators are from other states. Security guards too aren’t from the same village.
Unaddressed impacts of Submergence:
In Geddamari village near the diversion weir, around 15-20 families lost their lands for construction of the dam. Bill collector (Talathi) of the village told SANDRP that around 50 acres of land was SUBMERGED due to dam (diversion weir) construction. He further added that farmers whose lands were submerged, have not received the compensation as yet. They have been talking with the company and have been verbally promised some compensation, though nothing on paper. Problems in this village too are like Benchagaddi village. Limited drinking water, disturbed power supply etc.
Applicable for Environmental Clearance:
As the projects use a single dam and are a single project of 49.50 MW and they qualify for a full environmental clearance process, including an EIA, public hearing, and Environmental appraisal by the state or central EAC and an Environmental Management Plan. However, the projects have illegally escaped all this.
Executive Engineer of Krishna Bhagya Jal Nigam (KBJN) – controlling state authority in case of Krishna River- confirmed, “Both the projects are operating using the same weir .The power houses of two projects are housed behind the same diversion weir. There are three 8.25 MW turbines for each of the projects situated downstream of the same diversion weir.”
According to the Executive Engineer, KBJN has granted NOCs to both the projects and that both of them being fully operational for last 6-8 months. When SANDRP visited the project site, the HEPs were found to be fully operational.
24.75 MW Mouneswara and 24.75 Basvanna Projects are operating from the same diversion weir, use the same intake canal and same tail race. They are in fact one single project which has fraudulently shown itself as two separate projects. The proponent and the consultants have hidden this fact from the UNFCCC, the MoEF, the MNRE, KREDL, State Pollution Control Board and State Environmental Department. The Local Stakeholder Reports of the projects are a sham. Submergence impacts are still unaddressed.
These issues need to be addressed urgently by all concerned including the MoEF, the Karnataka Government, UNFCCC, MNRE and KREDL. Such frauds are giving a bad name to the all these institutes.
-Damodar Pujari (firstname.lastname@example.org) with inputs from Parineeta Dandekar
Ministry of New and Renewable Energy (MNRE), Government of India recently published a report on ‘Developmental Impacts and Sustainable Governance Aspects of Renewable Energy Projects’. Around the same time, Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of Small Hydro Projects (SHPs) on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats[i]. SHPs are hydel projects between 2 MW-25 MW installed capacity. Looking at the unaddressed impacts of SHPs, such a report by MNRE was sorely needed and was looked at as a welcome initiative.
Unfortunately, the MNRE Report has entirely excluded the small hydel sector from its assessment.
SHPs can have and are having severe impacts on communities and ecosystems. They fall under the MNRE and are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restricts itself to projects above 25 MW. They get subsidies, tax rebates, tax holidays from the MNRE, apart from other benefits and preferential tariffs from states. Most of the SHP sector is crowded with private investors, wanting to make a quick buck from rivers, without any regulations. The rush is most prominent in Uttarakhand, Himachal Pradesh, Karnataka, Odisha and now Kerala, where cascades of such dams are coming across pristine rivers.
Despite MNRE’s supposed intention, most SHPs are not supplying electricity to any “remote and inaccessible areas”.[ii] Most projects are grid connected, so the local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitat loss, submergence and fraudulent practices.
Following a petition from Western Ghats Forum, Karnataka High Court has ordered a ban on SHPs in Western Ghats, Uttarakhand High Court had cancelled as many as 56 SHPs. In Himachal, communities fought a long and lonely struggle against the 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests. [iii]Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely biodiverse forests, plantations and houses.[iv] Greenko’s Perla and Shemburi Projects[v], Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects on the same river with a common dam. Maruthi Gen projects, also in Karnataka were not only clubbed together, but also hid their significant impact on forest land[vi] . Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands.
The issues are serious and have been raised by many. As the projects are outside the purview of EIA Notification, none of their impacts are studied; neither do the communities get a platform to record their protests. Hence, a study on the environmental impacts of renewable energy projects was needed to address these issues.
Considering these serious aspects, it is very surprising that MNRE Report on impacts of Renewable Energy projects has chosen not to look at this sector at all. The report does not assess impacts of any such projects, neither does it offer any recommendations for this sector under MNRE. It only makes a sketchy study of wind and solar energy projects. The report makes incorrect statements like: “All hydroelectric power projects have to get environmental clearances which under two categories: category B if capacity of projects is between 50 to 25 MW”, effectively refusing to acknowledge hundreds of SHPs, under the purview of MNRE not requiring any environmental regulation.It states incorrect facts like “There are institutions and processes governing every operational aspect of RE project development and local institutions, in the form of democratic bodies, to safeguard micro level ecological and social concerns.” This is patently untrue for SHPs, which are highly unregulated and non-participatory.
The TORs of the study stress assessment of impacts of solar and wind projects, but do not exclude hydel projects. While TORs should have stressed on impacts of SHPs, looking at the number of protests and inherent problems, that does not warrant report writers’ complete neglect of this sector. Executive Summary states that this study has been done in response to WGEEP and HLWG report recommendations. Despite the fact that WGEEP specifically banned SHPs in Ecologically Sensitive Zone I, this report has chosen to turn a Nelson’s eye to the sector.
Even with regards to solar and wind projects, the report seems inadequate. For primary data, the authors visited 6 wind energy farms and 1 solar energy site. At the solar energy site, interaction was exclusively with project management and engineers. Social and environmental impacts cannot be understood through interviews with project management alone. While the report documents the devastation around wind energy farms in Maharashtra, it is not reflected in conclusions and recommendations.
The report is entirely silent on Clean Development Mechanism applications of SHPs, which are routinely full of lies and incorrect information. CDM credits give project additional pocketable profits, while the affected communities get only unaddressed impacts. Considering the forest land submerged by Small hydel Projects, and their impacts on adaptation and mitigation potential of local communities, they are also problematic from perspective of climate change.
The report ends with unacceptable conclusions and recommendations, most surprising being: “The RE project development is regulated by environmental and social governance system. The current regulatory mechanism is strong… No new changes are required in the legal framework or the governance structure to mitigate environmental and social impacts.” It even pushes for a “fast channel for quick clearances”.
The report says that environmental impacts of RE projects “are not significant” and social impacts of are “not negative”. Report writers need to visit SHPs in Himachal, Uttarakhand and Karnataka where people have lost irrigation channels, water mills, plantations and even lives, when sudden water was released from projects like Perla-Shemburi in Bantwal[vii], Karnataka.
Sweeping conclusions and recommendations for the entire RE sector is highly problematic, especially when there are several examples of unaddressed impacts, which depend on specific site and project.
The report does include some welcome recommendations. These include: siting policy for projects including zonation and increased participation of local communities in planning and decision making about natural resources, affected by the projects. It recommends issuing clear guidelines such that community welfare is not compromised due to RE projects and about proponent’s responsibilities in the zone of influence of the RE project. The report recommends zonation of projects in go-green (no objection), go slow and no go areas for RE project development. These need to be implemented by the MNRE. If the report would have looked at the entire RE sector, it could have made some valuable observations and recommendations.
There is a very urgent need to bring projects between 1 – 25 MW under the purview of EIA Notification 2006. Several representations and evidences later, it is clear that MoEF does not have the will to do so. It was expected that MNRE will raise these issues, but if this report is an indication, MNRE too is not willing to accept the challenges of SHP development, or regulating the impacts.
Lower installed capacity does not always mean lower social or environmental impacts. Targeted efforts are needed to assess, address and mitigate impacts. For this, the first step will be to acknowledge impacts, not brush them under the carpet. World over, impacts of small hydro projects are being highlighted.
As India is looking at expanding its renewable energy sector, it needs to be truly sustainable and clean, not just an assumption. Hence, MNRE’s effort at addressing environmental and social impacts of renewable energy projects is a welcome move. But by refusing to acknowledge the impacts of Small Hydel Projects in its report, MNRE reminds one of Nero, playing his fiddle, when the forests around are being submerged or destroyed in the name of clean energy.
Himdhara’s Report on Mini Hydel Projects in Uttarakhad: http://www.himdhara.org/2012/09/09/small-hydropower-big-impact-a-discussion-on-issues-facing-local-communities-in-himachal-pradesh/
Meeting on Mini hydel projects in Karnataka: https://sandrp.in/hydropower/PR_Halt_Mini_Hydel_Projects_in_Karnatka_pending_regulation_and_review_080812.pdf