Reconstituted Expert Appraisal Committee on River Valley Projects:
MoEF has neither environment sense, nor guts: Unacceptable Committee
On Sept 5, 2013, Union Ministry of Environment and Forests came out with “Re-constitution of Expert Appraisal Committee (EAC) for River Valley & Hydro Electric Project” (see: http://envfor.nic.in/sites/default/files/EAC-Order-05092013.pdf). Mr Alok Perti, former Coal Secretary, has been made chairperson of the committee that appraises all major irrigation projects, dams, hydropower projects and river valley projects for Environment clearances at two stages (TOR and final). It is shocking to see that Mr Perti who has absolutely no environment credentials, who has been known to be anti environment, who has been accusing the environment ministry to be in road block of coal mining and who has shown his ignorance of environment issues on several occasions has been selected as chair person, putting aside basic environmental sense. This reconstituted EAC on RiverValley and Hydropower projects is completely unacceptable.
It is equally disturbing to see that the committee has no woman representation, no sociologist, no one from non-government organisations. All ten members are either from government, government organisations or government funded academic organisations. This means that none of them would be in a position to take a stand independent of the government stand. The committee also has no river expert, climate change-water expert or disaster management expert, all of which are crucially important issues for a committee like this that decides the fate of India’s rivers, even more so after the Uttarakhand disaster. P K Chaudhuri, one of the members of the new committee also has had nothing to do with rivers, water or environment. Hardip S Kingra, who was involved in Commonwealth games organisation and also chairman of National Scheduled Castes Finance and Development Corporation has had no work related to rivers or environment.
Specifically, Mr Alok Perti, who has been senior functionary, including secretary of currently controversial Coal Ministry from Oct 2009 to earlier this year and before Oct 2009 in ministries like defense and family welfare, clearly has had no background on environment or rivers. As coal secretary, he had accused MoEF for stalling the growth by not giving clearances to coal mining projects automatically. The Economic Times quoted Perti as saying in a report[1]: “India has to decide whether she wants electricity or tigers.” Such simplistic statements reflect he has absolutely no understanding of environment, biodiversity, leave aside rivers. Perti’s anti civil society stance was also exposed when he refused to discuss issues with activists and asked them to go and file RTIs[2]. These are only a couple of examples we are giving here, there are many others. By appointing such a person as chairman of the EAC on RVP, the MoEF has shown it has no guts or interest in protecting the environment or forests which is supposed to be its mandate. This committee is clearly unacceptable and will also not stand legal scrutiny.
Union Ministry of Environment and Forests, New Delhi, vrg.iyer@nic.in
Maninder Singh
Joint Secretary,
Union Ministry of Environment and Forests, New Delhi, jsicmoef@nic.in
Mr. B. B. Barman
Director (IA) River Valley Projects,
Union Ministry of Environment and Forests, New Delhi, bidhu-mef@nic.in
Subject: Urgent concerns about reconstituted Expert Appraisal Committee on River Valley Proejcts
Respected madam and sirs,
On Sept 5, 2013, Union Ministry of Environment and Forests came out with “Re-constitution of Expert Appraisal Committee (EAC) for River Valley & Hydro Electric Project” (see: http://envfor.nic.in/sites/default/files/EAC-Order-05092013.pdf). Mr Alok Perti, former Coal Secretary, has been made chairperson of the committee that appraises all major irrigation projects, dams, hydropower projects and river valley projects for Environment clearances at two stages (TOR and final). It is shocking to see that Mr Perti who has absolutely no environment credentials, who has been known to be anti environment, who has been accusing the environment ministry to be in road block of coal mining and who has shown his ignorance of environment issues on several occasions has been selected as chair person, putting aside basic environmental sense. This reconstituted EAC on River Valley and Hydropower projects is completely unacceptable.
It is equally disturbing to see that the committee has no woman representation, no sociologist, no one from non-government organisations. All ten members are either from government, or from government organisations or government funded academic organisations. This means that none of them would be in a position to take a stand independent of the government stand. The committee also has no river expert, climate change-water expert or disaster management expert, all of which are crucially important issues for a committee like this that decides the fate of India’s rivers, even more so after the Uttarakhand disaster. P K Chaudhuri, one of the members of the new committee also has done no work with rivers, water or environment, going by his CV. Hardip S Kingra, who was involved in Commonwealth games organisation and also chairman of National Scheduled Castes Finance and Development Corporation has had no work related to rivers or environment.
Specifically, Mr Alok Perti, who has been senior functionary, including secretary of currently controversial Coal Ministry from Oct 2009 to early 2013 and before Oct 2009 he has been in ministries like defense and family welfare, clearly has had no background on environment or rivers. As coal secretary, he had accused MoEF for stalling the growth by not giving clearances to coal mining projects automatically. The Economic Times quoted Perti as saying in a report[1]: “India has to decide whether she wants electricity or tigers.” Such simplistic statements reflect he has absolutely no understanding of environment, biodiversity, leave aside rivers. Perti’s anti civil society stance was also exposed when he refused to discuss issues with activists and asked them to go and file RTIs[2]. By appointing such a person as chairman of the EAC on RVP, the MoEF has shown it has no interest in protecting the environment or forests which is supposed to be its mandate. This committee is clearly unacceptable and will also not stand legal scrutiny.
Under the circumstances, we demand that:
1. The notification (No. J-12011/EAC /2010-IA-I dated Sept 5, 2013) of reconstitution of the EAC be cancelled;
On August 13, 2013, while disposing off a bunch of petitions[i] regarding the controversial 330 MW Srinagar Hydropower Project on AlaknandaRiver in Uttarakhand, the Supreme Court bench of Justice K S Radhakrishnan and Dipak Misra have given some welcome directions on the Uttarakhand hydropower projects.
Perusal of the full judgment[ii] shows that the decision is disappointing on the Srinagar project issue, since the court has directed that the project be completed and disposed off all objections to that, while asking for implementation of the Environment Managemnet Plan and conditions etc. However, there are several contradictions in this regard that seems to have escaped the attention of the court, and a review petition on that part could be field by the petitioners. Importantly, Prof Bharat Jhunjhunwala, who argued the case in person, should be thanked for the role he played in this case.
Courts’s concerns on Uttarakhand Hydro Projects However, the most pertinent and interesting part of the order starts at the bottom on p 62 with the title “Court’s concerns” and goes on till the end of the order on p 72.
In these pages, the order notes that AHEC (Alernate Hydro Energy Centre at IIT Rurkee) has not done the cumulative impact assessment it was asked to do. This is very important to note. The order says, (para 46), “We have gone through the Reports and, prima facie, we are of the view that the AHEC Report has not made any in-depth study on the cumulative impact of all project components like construction of dam, tunnels, blasting, power-house, Muck disposal, mining, deforestation etc. by the various projects in question and its consequences on Alaknanda as well as Bhagirathi river basins so also on Ganga which is a pristine river.” After this clear statement from the Highest Court, no one should rely on this report now on.
We are glad that this statement of Supreme Court supports what SANDRP has been saying for years[iii].
This part the order also refers to the BK Chaturvedi Committee (appointed by the National Ganga River Basin Authority in June 2012) report submitted in April 2013 to emphasise that, “The River Ganga has over a period of years suffered environmental degradation due to various factors.” The court should have directed that the MoEF should make the report of the BK Chaturvedi committee report public since the MoEF has not yet done that. The committee itself stands discredited[iv] since none of the independent members of the committee accepted the report.
The operative part of the order says:
“(1) We direct the MoEF as well as State of Uttarakhand not to grant any further environmental clearance or forest clearance for any hydroelectric power project in the State of Uttarakhand, until further orders.”
This means that environment or forest clearance to any hydropower projects of any size in Uttarakhand cannot be given either by MoEF or by the Government of Uttarakhand till further orders.
“(2) MoEF is directed to constitute an Expert Body consisting of representatives of the State Government, WII, Central Electricity Authority, Central Water Commission and other expert bodies to make a detailed study as to whether Hydroelectric Power Projects existing and under construction have contributed to the environmental degradation, if so, to what extent and also whether it has contributed to the present tragedy occurred at Uttarakhand in the month of June 2013.”
This direction has two parts: A. assessment of cumulative impacts of existing and under construction hydropower projects[v] to the environment degradation in Uttarakhand and B. Whether the projects have contributed to the Uttarakhand flood disaster, if so to what extent.
Only a credible independent panel with sufficient number of independent members can provide a credible report in this regard, the committee should be chaired by a non government person of the stature of Prof Madhav Gadgil. We hope the MoEF will soon constitute such an expert body and also ask the expert body to hold public hearings at various relevant places and seek wider public consultation. The mandate of the committee should be for the entire Uttarakhand and not just Bhagirathi and Alaknanda sub basins. The committee should have credible and independent geologist, sociologist, environmentalist, river expert and disaster management expert.
“(3) MoEF is directed to examine, as noticed by WII in its report, as to whether the proposed 24 projects are causing significant impact on the biodiversity of Alaknanda and BhagirathRiver basins.”
Here it may be remembered that it was MoEF that had asked Wildlife Institute of India to submit a report on the cumulative impact of the hydropower projects in Uttarakhand on aquatic and terrestrial biodiversity. It should also be remembered that WII is one of the credible institutes and is also a centre of excellence of the MoEF. There is no reason for MoEF to reject the clear recommendation of the WII report that the 24 projects listed by it should be dropped. The clearances given to the projects like the 300 MW Alaknanda Badrinath HEP of GMR should be suspended immediately keeping this direction in mind.
“(4) The Disaster Management Authority, Uttarakhand would submit a Report to this Court as to whether they had any Disaster Management Plan is in place in the State of Uttarakhand and how effective that plan was for combating the present unprecedented tragedy at Uttarakhand.”
This direction should have also been for the National Disaster Management Authority since preparation of proper State Disaster Management Plan and ensuring setting up of required machinery for its implementation is also a mandate of the NDMA. This is particularly important in view of the failure also of NDMA as reported by the Comptroller and Auditor General of India report of March 2013. Since the court has asked in para 52 that, “Reports would be submitted within a period of three months. Communicate the order to the Central and State Disaster Management Authority, Uttarakhand.”, it is implied that NDMA is also to submit a report.
Since the original petitions and applications are disposed off, it is not clear if the original petition survives or a new case will be registered. It is also not clear if the original petitioners survive. In such cases it is the normal practice of the court to appoint and Amicus Curie and it would be interesting to see whom the court appoints for such a purpose.
These orders are indeed welcome in view of the fact that hydropower projects in Uttarakhand have certainly played big role in increasing the disaster potential and disaster proportions in Uttarakhand floods in June 2013. More than twenty groups and individuals of Uttarakhand, Himachal Pradesh and other states have already written to the MoEF in July 2013[vi], asking for suspension of such hydropower projects that have prime facie played such a role and set up an independent enquiry. The MoEF has not yet responded to this letter. We are glad now SC has asked for such an inquiry.
[i] These includes Civil Appeal No 6736 of 2013, Special Leave Petition no 362 of 2012, Civil Appeal nos 6746-47 of 2013 (arising out of SLP (Civil) nos 5849-50 of 2012 and Transfer cases (C) (National Green Tribunal) numbers 55 to 57 of 2013.
“At the ground level people are really interested and they want to get involved and our report if nothing else, seem to have serve the purpose of triggering such kind of an interest” said Prof. Madhav Gadgil who delivered a lecture on “Democracy and ecology in contemporary India” at the Nehru Memorial Museum and Library (NMML) on 17th July 2013. His lecture was part of the public lecture series on ‘Science Society and Nature’ and the event was attended by more than 400 people, the second highest audience NMML has witnessed for public lecture as Director Mahesh Rangarajan revealed at the end of the lecture. The lecture was chaired by Jairam Ramesh, the former Minister of Environment and Forests and currently the minister for Rural Development and also in charge of Ministry of Drinking Water and Sanitation.
Prof. Gadgil in his lecture presented several case studies through which he showed how in the name of ‘development’ only lip service has been paid to the environmental norms and all democratic processes have been sidelined. Dr. Gadgil also shared his experiences of working for the Western Ghats Ecology Expert Panel (the report submitted by this panel can be accessed here – http://moef.nic.in/downloads/public-information/wg-23052012.pdf) which was formed by the Ministry of Environment and Forests (MoEF) to study the ecological and environmental concerns of the Western Ghats under his aegis.
Talking about iron mining in Goa, Prof Gadgil said the government of Goa even does not have any account of how much ore has been extracted by the mining contractors, leaving aside environmental concerns. Bringing the issue of unprecedented dam construction in Western Ghats, he gave the example of Athirappilly dam in ChalakudyRiver in Kerela which was the eight dam proposed in the river. There was a clear violation of Forest Rights Act, as construction of this dam would lead to displacement and subsequent extinction of the ‘primitive tribal’ community named Kadar. The government officials were claiming that if this dam was not constructed Kerela would starve for electricity. But a detailed presentation by RiverResearchCenter, Kerela covering technical, economic and social aspects of the proposed dam showed this dam was not viable as there would be not be sufficient water left in the river for this dam as the water would already be harnessed in the seven upstream dams. The government officials, who were claiming that Kerela would go power hungry, had no reply to this.
Presenting the case of Plachimada village in Perumatti Panchayat in Palakkad district of same state, he said that Coca Cola Company had not paid any compensation that it was supposed to pay to the farmers of Plachimada as ordered by the Supreme Court. Coca Cola was also supposed to pay a tax of Rs 60 cores to the government of Kerela but the government had surprisingly given tax exemption of Rs 6 crores to the company. In both these examples he showed how the acts of democratically elected government were actually against people and environment. But he hailed the Plachimada struggle against Coca Cola as a ray of hope since this was a struggle led by a Panchayat, a local level democratic institution which brought a multi-national company to its knees. He also pointed out how law and order mechanism of state had been used to suppress people’s protests against illegal pollution in Lotte, in Ratnagiri district of Maharashtra.
Throughout his lecture Dr. Gadgil strongly argued for decentralization of power in order to protect ecology and environment. He mentioned about the powers given in the hands of the local bodies through the 73rd and 74th amendment of the constitution of India. He said that there are several laws and policies e.g. Bio-logical Diversity Act (2002), National Gene Funds which talked about participation of citizens in the decision making but this was never implemented on the ground. He said that the Environmental Impact Assessment (EIA) documents and the whole environmental clearance process should be reconsidered and reviewed (a press release on the functioning of Expert Appraisal Committee which grants environment clearance termed the committee as Expert Approval Committee – https://sandrp.wordpress.com/2013/02/05/analysis-of-moefs-eac-on-river-valley-projects-the-expert-approval-committee-has-zero-rejection-in-six-years/).
Taking the case of mining in Goa, he said that his team of the Ecology Expert Panel reviewed EIA documents of 75 mines and found that all the mines had made fraudulent statements about how the mines would impact the rivers and rivulets. There were EIA documents of these mines which even denied the existence of perennial streams in the hill plateau where these mines existed. In one case when he wrote to one of the mine managers about the existence of a famous stream near that mine, but the reply was that since there were no blue lines in the geological map of Goa, there are no streams.
He stressed on the need to engage local people in the decision making process and increase dissemination of information. He took the example of ‘Australian River Watch’ programme where the citizens are trained to monitor the health of a river just by looking at the bio-logical indicators. He opined that India should take lessons from this and should initiate such programmes. He said that in our democracy we have many possibilities of engaging in decision making. He ended his speech by saying that for India to progress, India should take bottom up approach and strengthen its democracy, rule of law, scientific temperament and traditional ecological knowledge.
Q&A session brought out more issues – The question-answer session which followed the lecture also brought several important issues in to the foray. Answering a question about how much scientific peoples’ knowledge is, he said that one must understand that peoples’ knowledge is historical and locality specific and traditional. So the people of a certain locality would know better about the ecology and environment of a specific place rather than experts or engineers. Here again he emphasized on the need to include of common people in the decision making process.
Answering a question about the climate change impacts in the Western Ghats, he said that there are no immediately visible impacts of climate change in Western Ghats. But he said that Himalayan range already had visible impacts of climate change in the form of glacier melting and increased precipitation. But he warned that Western Ghats will surely have climate change impacts in the future.
When asked about his opinion on the future of Western Ghats if the diluted version of his report, i.e. Report of the High Level Working Group headed by Dr Kasturirangan (A blog that compares Kasturirangan and Gadgil Panel report can be found here – https://sandrp.wordpress.com/2013/04/24/how-much-does-the-kasturirangan-committee-understand-about-water-issues-in-western-ghats/) gets accepted by the government, Dr. Gadgil laughingly said that he knew that his report would not be accepted but he was sure that Kasturirangan’s report would also not be implemented (A letter by Prof Gadgil on Kasturirangan committee can be found here: https://sandrp.wordpress.com/2013/05/18/prof-madhav-gadgil-writes-to-dr-kasturirangan/). But he expressed his surprise on the fact that after his report, people are really awakened and they are now paying attention to these issues. He is happy to see that at the people in the ground level are really interested to know about the environmental issues. He said that the report by his group, had served the purpose of triggering this interest if not anything else. He expressed his optimism about the report. (SANDRP comment on Kasturirangan Committee submitted to MoEF can be found at: https://sandrp.wordpress.com/2013/05/20/comments-on-hlwg-report-submitted-to-ministry-of-environment-and-forests/)
Talking about gender imbalance he narrated an experience of 1984 of a Zila Parishad in Uttar Kannada district in Karnataka. There he organized a meeting of all the Zila Parishad members to know their views on environmental issues in their zila (district). In that meeting it was mainly the women members who vociferously talked about the environmental concerns and they gave excellent feedback on the issue. He added that from his experience of working on such issues all these years, he has found that in the local elected bodies it is the women members who are more concerned with environmental issues.
Answering a question regarding dam construction in northeast he said that very less knowledge is available about the geology of young HimalayanMountain. Giving the example of the recent Uttarakhand disaster he said that one of renowned environmentalist from the state, Dr. K. S. Valdiya have been completely ignored and was never consulted for any of the developmental activity in the state even though he has written extensively about the geology of the hilly state. This is actually ignoring scientific knowledge about the area and he expressed his fear that similar things might be happening in the northeast as well.
Answering a question about recent flood devastation in Uttarakhand, he said that from Dr. K. S. Valdiya what he had come to know is that lawless and a mindless construction activity like dhabas and hotels, in the river bed of Mandakini in Uttarakhand is one of the major reasons for the increased amount of devastation in the recent flood. He said that traditionally the people of Uttarakhand used to construct houses far from the river in order to save themselves from the fury of floods. He was also informed that for hydroelectric dam the residences of project engineers and labour have been constructed at wrong places and in the recent floods these constructions must have been affected (a detailed report on Uttarakhand floods is available here – https://sandrp.wordpress.com/2013/06/21/uttarakhand-deluge-how-human-actions-and-neglect-converted-a-natural-phenomenon-into-a-massive-disaster/).
Answering a question about whether inter-linking of rivers in justified or not and if environmental movements have taken a view of ‘changelessness’, Professor Gadgil said he is not sure whether environmental movements are trying to suppress debate and pushing for only one kind of debate, which is undermining scientific spirit. Regarding inter-linking of rivers, he said that all the pros and cons should be thoroughly studied and then only the decision should be taken. However what he has been informed by Dr. K. S. Valdiya that those who are in favour of pushing through the projects are often suppressing all kinds of debates. Here he brought the issue of Athirappilly dam again and said that River Research Centre which had been long talking about the pros and cons of the project, their voices had been suppressed. He said that if environmentalists are trying to suppress the debate then that is clearly wrong but he has got no evidence of that. But he has seen evidences of things happening in the other way round where project proponents are suppressing questioning of project proposals.
On a question regarding faster growth versus sustainable growth, he said that if faster growth is genuinely leading to employment generation and improve quality of life, then following the path of faster growth is right. But if this is not happening, he said there were many evidences that faster is obviously not better. He ended the question answer session by quoting a German proverb which said ‘if you are running in the wrong direction then it is better to run slowly than fast.’
Concluding Remarks by Former MoEF – Jairam Ramesh in his concluding remarks highlighted couple of points which Prof. Gadgil has raised. He said that the greatest contribution of the work done by Prof. Gadgil is that it had brought high levels of ecological sensitivity which is grounded in the primacy of local democratic institutions and anchored in a belief on the scientific method. He said for the younger generation Prof. Gadgil is a role model. But he also points out that as a democracy India has to make a choice between growth and environmental concerns and he warned against the romanticization with environmental movements. He pointed out that India faces a unique challenge of adding 10 million jobs to its labour force every year. He opined that India cannot choose between faster or sustainable growth but India’s growth has to be faster and sustainable. The responsibility of the scholars, activists and government here, according to him is to find ways and means to reach this. The twin pillars to reach this have to be what Prof. Gadgil has mentioned in his talk – 1. Organized skepticism or the respect for the scientific methods and 2. Respect for full functioning of democratic institutions at all levels, from bottom to the top. Emphasizing on the need for laws to implement environment policies in a fast growing economy, he said that Indian Parliament has passed some of the most progressive laws in the world but it is in the implementation and enforcement of these laws where India has failed again and again.
As Uttarakhand faced unprecedented flood disaster and as the issue of contribution of hydropower projects in this disaster was debated, questions for which there have been no clear answers were, how many hydropower projects are there in various river basins of Uttarakhand? How many of them are operating hydropower projects, how many are under construction and how many more are planned? How many projects are large (over 25 MW installed capacity), small (1-25 MW) and mini-micro (less than 1 MW installed capacity) in various basins at various stages?
This document tries to give a picture of the status of various hydropower projects in various sub basins in Uttarakhand, giving a break up of projects at various stages, As per available information in July 2013.
River Basins in Uttarakhand Entire Uttarakhand is part of the larger Ganga basin. The Ganga River is a trans-boundary river, shared between India and Bangladesh. The 2,525 kms long river rises in the western Himalayas in the Indian state of Uttarakhand, and flows south and east through the Gangetic Plain of North India into Bangladesh, where it empties into the Bay of Bengal. The Ganga begins at the confluence of the Bhagirathi and Alaknanda rivers and forms what we have called Ganga sub basin till it exits Uttarakhand. Besides Bhagirathi, Alaknanda and Ganga sub basin, other river basins of Uttarakhand include: Yamuna, Ramganga (Western Ramganga is taken as Ramganga basin in this document, eastern Ramganga is considered part of Sharda basin) and Sharda. Sharda sub basin includes eastern Ramganga, Goriganga, Dhauliganga, Kaliganga and part of Mahakali basin.
Destroyed 400 MW Vishnuprayag HEP on Alaknanda. Photo: Matu Jan Sangathan
Existing hydropower projects in Uttarakhand In the table below we have given the sub basin-wise list of existing hydropower projects in Uttarakhand along with their capacities. The list has been prepared based on various sources including Central Electricity Authority, Uttarakhand Jal Vidhyut Nigam (UJVNL), Uttarakhand Renewable Energy Development Authority (UREDA) and Report of Inter Ministerial Group on Ganga basin.
Existing Hydropower projects in Uttarakhand
Projects
Installed Capacity (MW)
Projects in Alaknanda River Basin
1. Vishnu Prayag (P)
400
2. Tilwara
0.2
3. Soneprayag
0.5
4. Urgam
3
5. Badrinath II
1.25
6. Rajwakti (P)
3.6
7. Tapowan
1
8. Jummagad
1.2
9. Birahi Ganga (P)
7.2
10. Deval (P Chamoli Hydro P Ltd on Pinder)
5
11. Rishiganga (P)
13.5
12. Vanala (P Hima Urja P Ltd Banala stream)
15
13. Kaliganga I (ADB)
4
Alaknanda Total
455.45
Projects in Bhagirathi River Basin
14. Maneri Bhali-1 (Tiloth)
90
15. Maneri Bahli-2
304
16. Tehri St-I
1000
17. Koteshwar
400
18. Harsil
0.2
19. Pilangad
2.25
20. Agunda Thati (P Gunsola hydro Balganga river)
3
21. Bhilangana (P – Swasti)
22.5
22. Bhilangana III (P – Polyplex)
24
23. Hanuman Ganga (P – Regency Aqua)
4.95
Bhagirathi Total
1850.9
Projects in Ganga River sub basin downstream of confluence of Bhagirathi and Alaknanda
24. Chilla
144
25. Pathri
20.4
26. Mohamadpur
9.3
Ganga sub basin Total
173.7
Projects in Ramganga basin
27. Ramganga
198
28. Surag
7
29. Loharkhet (P Parvatiya Power P Ltd Bageshwar)
4.8
30. Kotabagh
0.2
31. Sapteshwar
0.3
32. Gauri
0.2
Ramganga Total
210.5
Projects in Sharda River Basin
33. Dhauliganga
280
34. Tanakpur
94.2
35. Khatima
41.4
36. Chirkilla
1.5
37. Taleshwar
0.6
38. Suringad
0.8
39. Relagad
3
40. Garaon
0.3
41 Charandev
0.4
42. Barar
0.75
43. Kulagad
1.2
44. Kanchauti
2
Sharda Total
426.15
Projects in Yamuna River Basin
45. Chibro
240
46. Dhakrani
33.75
47. Dhalipur
51
48. Kulhal
30
49. Khodri
120
50. Galogi
3
51. Tharali
0.4
Yamuna Total
478.15
Grand Total
3594.85
Note: (P) in the bracket suggests the project is in private sector, throughout this document. The eastern Ramganga river, which is part of Sharda basin, is included in Sharda basin. Where-ever Ramganga river is mentioned in this document, it refers to Western Ramganga, which is a tributary of Ganga.
Alaknanda flowing beyond the destroyed 400 MW Vishnuprayag Project Photo: Matu Jan Sangathan
In the next table we have given available list of existing mini and micro hydropower projects in Uttarakhand, based on UREDA information.
List of projects up to 1 MW under operation:
SN
Project
Ins Cap (MW)
Dist
Basin
1
Milkhet
0.1
Chamoli
Alaknanda
2
Bamiyal
*
Chamoli
Alaknanda
3
Bursol
0.2
Chamoli
Alaknanda
4
Choting
0.1
Chamoli
Alaknanda
5
Ghagaria
0.1
Chamoli
Alaknanda
6
Ghagaria Extension
*
Chamoli
Alaknanda
7
Ghes
0.1
Chamoli
Alaknanda
8
Gulari
0.2
Chamoli
Alaknanda
9
Niti
0.025
Chamoli
Alaknanda
10
Sarma
0.1
Chamoli
Alaknanda Nandakini/ Maini Gad
11
Wan
0.05
Chamoli
Alaknanda
12
Bank
0.10
Chamoli
Alaknanda Pinder
13
Gamsali Bampa
0.05
Chamoli
Alaknanda Dhauliganga/Ganesh Ganga
14
Kedarnath II
0.2
Rudraprayag
Alaknanda
15
Badiyakot
0.1
Bageshwar
Alaknanda
16
Kunwari
0.05
Bageshwar
Alaknanda
17
Borbalada
0.025
Bageshwar
Alaknanda Pindar/ Chhiyaldi Gad
18
Dokti
0.02
Bageshwar
Alaknanda
19
Dior IInd Phase
*
Pauri
Alaknanda/ Ganga
20
Chandrabhaga Gad
*
Tehri
Bhagirathi
21
Jakhana
0.1
Tehri
Bhagirathi Bhilangana/Balganga
22
Gangotri-I
0.1
UttarKashi
Bhagirathi Kedar Ganga
23
Kanwashram
0.1
Pauri
Ganga
24
Bilkot
0.05
Pauri
Ramganga
25
Dior Ist Phase
0.1
Pauri
Ramganga
26
Gogina II
0.05
Bageshwar
Ramganga
27
Sattshwar
0.05
Bageshwar
Ramganga
28
Toli
*
Bageshwar
Ramganga
29
Ramgarh
0.1
Nainital
Ramganga
30
Lathi
0.1
Bageshwar
E Ramganga/Sharda
31
Liti
0.05
Bageshwar
E Ramganga/Sharda
32
Liti-II
0.05
Bageshwar
E Ramganga/Sharda
33
Ratmoli
0.05
Bageshwar
E Ramganga/Sharda
34
Baghar
0.05
Bageshwar
E Ramganga/Sharda
35
Baicham
0.1
Bageshwar
E Ramganga/Sharda
36
Jugthana
0.1
Bageshwar
E Ramganga/Sharda
37
Kanol gad
0.1
Bageshwar
E Ramganga/Sharda
38
Karmi
0.05
Bageshwar
E Ramganga/Sharda
39
Karmi -III
0.05
Bageshwar
E Ramganga/Sharda
40
Karmi-II
0.05
Bageshwar
E Ramganga/Sharda
41
Bhikuriya Gad
0.5
Pithoragarh
Sharda
42
Kanchauti
*
Pithoragarh
Sharda
43
Lamabager
0.20
Bageshwar
Sharda Saryu
44
Lamchula
0.05
Bageshwar
Sharda Saryu
45
Tarula
0.10
Almora
Sharda Saryu/Jataya Ganga
46
Taluka
0.025
Uttarkashi
Yamuna Tons/ Gattu Gad
47
Bhadri Gad
0.02
Tehri
Yamuna
From http://ahec.org.in/, capacity of some of the projects is as per the UJVNL website. The capacity comes to 3.815 MW for the 41 projects for which capacity is available, for six mini-micro HEPs in Uttarakhand listed above, this information is not available..
5 MW Motigad Project in Pithorgarh District destroyed by the floods. Photo: Emmanuel Theophilus, Himal Prakriti
Based on above two tables, in the following table we have provided an overview of operating hydropower projects and their capacity, with basin wise and size wise break up.
Uttarakhand has total of 98 existing hydropower projects, with total installed capacity of close to 3600 MW. At least eleven of these projects are in private sector with total capacity of over 503 MW. An additional about 1800 MW capacity is in central sector. It means that majority of the power generation capacity in the state is not owned by the state and there is no guarantee how much of that power would be available to the state.
Basin wise number of operating hydro projects in Uttarakhand
Basin
Large Hydro projects (above 25 MW)
Small Hydro projects (1-25 MW)
Mini-micro Hydro projects (below 1 MW)
Total Hydro projects
No of projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
Alaknanda
1
400
10
54.75
21
2.22
32
456.97
Bhagirathi
4
1794
5
56.7
4
0.4
13
1851.1
Ganga Sub basin
1
144
2
29.7
1
0.1
4
173.8
Ramganga
1
198
2
11.8
9
1.05
12
210.85
Sharda
3
415.6
4
7.7
21
4.45
28
427.75
Yamuna
5
474.75
1
3
3
0.445
9
478.195
TOTAL
15
3426.35
24
163.65
59
8.665
98
3598.665
Here we should note that as per the Union Ministry of New and Renewable Energy sources, in Uttarakhand, by March 2013, 98 small hydro schemes has been installed with total capacity of 170.82 MW. If we add the small and mini-micro projects in above table, we have 83 operating schemes with installed capacity of 172.315 MW. This mis-match is not possible to resolve since MNRE does not provide full list of operating SHPs in Uttarakhand.
Under Construction Hydropower projects in Uttarakhand In the table below we have given available list of under construction hydropower projects in Uttarakhand. Actual list of under construction projects is likely to be larger than this, since clear and uptodate information is not available on official website. Please note that this does not include the list of mini and micro hydropower projects that are under construction. Even in case of small hydro projects (1-25 MW capacity), the list is not complete. According to this list, 41 projects with 2378.115 MW capacity are under construction in Uttarakhand. 6 of them are large hydropower projects and rest 35 are small or mini-micro hydro projects. Of the 6 large hydropower projects, three are in private sector and three are in central sector, none in state sector.
Mountains of Muck generated by under construction 330 MW Shrinagar Hydel Project
List of under construction projects:
SN
Project
Ins Cap (MW)
Dist
Sub-Basin
1
Srinagar
330
Pauri
Alaknanda
2
Phata- Byung
76
Rudraprayag
Alaknanda
3
Singoli-Bhatwari
99
Rudraprayag
Alaknanda
4
Lata Tapovan
171
Chamoli
Alaknanda
5
Tapovan Vishnugad
520
Chamoli
Alaknanda
6
Madhmaheshwar (ADB)
10
Rudrprayag
Alaknanda
7
Kaliganga-II (ADB)
6
Rudrprayag
Alaknanda
8
Bgyunderganga (P)
24.3
Chamoli
Alaknanda
9
Birahi Ganga-I (P)
24
Chamoli
Alaknanda
10
Devali (P)
13
Chamoli
Alaknanda
11
Kail ganga
5
Chamoli Pinder
Alaknanda
12
Khiraoganga (P)
4
Uttarkashi
Alaknanda
13
Sobla I
8
Pithoragarh
Alaknanda
14
Hafla
0.2
Chamoli
Alaknanda Hafla Gad
15
Nigol Gad
0.1
Chamoli
Alaknanda Nigal Gad
16
Wachham
0.50
Bageshwar
Alaknanda Pindar/SunderDhunga Gad
17
Tehri stage-II
1000
Tehri
Bhagirathi
18
Asiganga-I
4.5
Uttarkashi
Bhagirathi
19
Asiganga-II
4.5
Uttarkashi
Bhagirathi
20
Suwarigad
2
Uttarkashi
Bhagirathi
21
Limchagad
3.5
Uttarkashi
Bhagirathi
22
Kaldigad (ADB)
9
Uttarkashi
Bhagirathi
23
Balganga-II
7
Tehri Garhwal
Bhagirathi
24
Jalandhari Gad (P)
24
Uttarkashi
Bhagirathi
25
Kakora Gad (P)
12.5
Uttarkashi
Bhagirathi
26
Kot-Buda Kedar (P)
6
Tehri
Bhagirathi
27
Siyangad (P)
11.5
Uttarkashi
Bhagirathi
28
KotiJhala
0.2
Tehri
Bhagirathi Bal Ganga
29
Pinsward
0.05
Tehri
Bhagirathi Bal Ganga
30
Dunao
1.5
Pauri
Ganga sub basin
31
Gaudi Chida
0.25
Pauri
Ganga sub basin E Nayar
32
Rotan
0.05
Pithoragarh
Sharda E Ramganga/Rotan
33
Duktu
0.025
Pithoragarh
Sharda Kali/ Nati Yanki
34
Nagling
0.05
Pithoragarh
Sharda Kali/ Nagling Yanki
35
Sela
0.05
Pithoragarh
Sharda Dhauli Ganga/ Seal Gad
36
Kutty
0.05
Pithoragarh
Sharda Kali
37
Napalchu
0.05
Pithoragarh
Sharda Kali/ Piear Yanki
38
Bundi
0.05
Pithoragarh
Sharda Kali/ Pulung Gad
39
Rongkong
0.05
Pithoragarh
Sharda Kali/ Dangiang Yanki
40
Chiludgad
0.10
Uttarakashi
Yamuna Supin/Chilude Gad
41
Khapu Gad
0.04
Uttarakashi
Yamuna Supin/Khapu Gad
Total Under Construction 2378.115 MW
Note: Projects like Loharinag Pala, Pala Maneri, Bhairoghati and other projects along Bhagirathi upstream of Uttarkashi along the Eco Sensitive zone have been dropped from this list. Rest of the list is from the IMG report or from UJVNL website. P in the bracket indicates the project is in the private sector. ADB in the bracket indicates that the project is funded by the Asian Development Bank.
Proposed hydropower projects in Uttarakhand In following tables we have provided available list of proposed hydropower projects in the Alaknanda, Bhagirathi, Yamuna, Sharda and Ramganga basins in Uttarakhand. The list is likely to be longer than the list in these tables since full and upto-date information is not available. Also there are different agencies involved in proposing, sanctioning and executing these projects and there is no single agency which can provide comprehensive picture of what is happening in the basin. However, even this available list is frightening.
List of proposed projects in Alaknanda Basin
SN
Project
Ins Cap (MW)
Dist
Sub-Basin
Status
1
Vishnugad Pipalkoti (WB)
444
Chamoli
Alaknanda
Construction to be started
2
Kotli Bhel (IB)
320
Pauri
Alaknanda
EAC ok/FAC u/consideration
3
Alaknanda (P Badrinath)
300
Chamoli
Alaknanda
EC & FC ok IA not signed
4
Devsari Dam
252
Chamoli
Alaknanda
EC & FC ok CEA concrnce?
5
Kotli Bhel II
530
Pauri
Ganga sub basin
EAC ok/FAC u/consideration
6
Bowla Nandprayag
300
Chamoli
Alaknanda
EAC TOR Approved
7
Tamak Lata
280
Chamoli
Alaknanda
EC ok, DPR under revision
8
Nand Prayag
100
Alaknanda
DPR returned
9
Jelam Tamak
108
Chamoli
Alaknanda
EAC ok in June 2013
10
Maleri Jelam
55
Chamoli
Alaknanda
PFR prepared
11
Rishiganga I
70
Chamoli
Alaknanda
PFR prepared
12
Rishiganga II
35
Chamoli
Alaknanda
PFR prepared
13
Gohana Tal
60
Chamoli
Alaknanda
PFR prepared
14
Rambara
24
Rudraprayag
Alaknanda
IMG report
15
Birahi Ganga-II (P)
24
Chamoli
Alaknanda
DPR under revision
16
Melkhet (P)
56
Chamoli
Alaknanda Pinder
Proposed
17
Urgam-II
3.8
Chamoli
Alaknanda
Under S&I
18
Bhyunder Ganga
243
Chamoli
Alaknanda
FC under consideration
19
Nand Pyayag Langasu
141
Chamoli
Alaknanda
EAC TOR Approved
20
Rambara
76
Rudraprayag
Alaknanda
EAC TOR u/consideration
21
Bagoli
90
Chamoli
Alaknanda
Proposed
22
Bangri
44
Chamoli
Alaknanda
Pinder
23
Madhya Maheshwar
350
Chamoli
Alaknanda
Proposed
24
Ming Nalgaon
114
Chamoli
Alaknanda
Pinder
25
Padli
66
Chamoli
Alaknanda
Proposed
26
Thapli
44
Chamoli
Alaknanda
Proposed
27
Utyasu-I
70
Chamoli
Alaknanda
Proposed
28
Utyasu-II
205
Chamoli
Alaknanda
Proposed
29
Utyasu-III
195
Chamoli
Alaknanda
Proposed
30
Utyasu-IV
125
Chamoli
Alaknanda
Proposed
31
Utyasu-V
80
Chamoli
Alaknanda
Proposed
32
Utyasu-VI
70
Chamoli
Alaknanda
Proposed
33
Rampur Tilwari
25
Rudraprayag
Alaknanda
Proposed
34
Chunni semi
24
Rudraprayag
Alaknanda
Proposed Mandakini
35
Kosa
24
Chamoli
Alaknanda
Dhauliganga
36
Vijay nagar- Rampur
20
Rudraprayag
Alaknanda
Proposed
37
Nandakini-III
19.5
Chamoli
Alaknanda
Proposed
38
Nayar
17
Pauri
Ganga sub basin
Nayar
39
Alaknanda I
15
Chamoli
Alaknanda
Proposed
40
Buara
14
Bageshwar
Alaknanda
Pindar
41
Duna Giri
10
Chamoli
Alaknanda
Dhauliganga
42
Alaknanda II
10
Chamoli
Alaknanda
Proposed
43
Balkhila-II
10
Chamoli
Alaknanda
Proposed
44
Mandani Ganga
10
Rudraprayag
Alaknanda
Mandakini Mandani ganga
45
Rishiganga
8.25
Chamoli
Alaknanda
Proposed
46
Subhain
8
Chamoli
Alaknanda
Dhauliganga
47
Son
7
Rudraprayag
Alaknanda
Mandakini son gad
48
Kalp ganga
6.25
Chamoli
Alaknanda
Proposed kalpganga
49
Lustar
6
Rudraprayag
Alaknanda
Mandakini Lustar
50
Madhya maheshwar -II
6
Rudraprayag
Alaknanda
Mandakini madmaheshwar
51
Hom 6
6
Chamoli
Alaknanda
Dhauliganga
52
Amrit ganga
6
Chamoli
Alaknanda
Amrit ganga balsuti gadera
53
Gaddi
5.25
Chamoli
Alaknanda
dhauliganga Gaddi Gadera
54
Deval
5
Chamoli
Alaknanda
Proposed
55
Ghrit Ganga
5
Chamoli
Alaknanda
Proposed
56
Jumma
5
Chamoli
Alaknanda
Proposed
57
Ringi
5.5
Chamoli
Alaknanda
Dhauliganga
58
Tamak
5
Chamoli
Alaknanda
Proposed
59
Balkhila-I
5.5
Chamoli
Alaknanda
Proposed Balkhila
60
Basti -I
4
Rudraprayag
Alaknanda
Proposed
61
Basti -II
4
Rudraprayag
Alaknanda
Proposed
62
Laxmanganga
4
Chamoli
Alaknanda
Proposed
63
Nil ganga
3
Chamoli
Alaknanda
Proposed
64
Santodhar – I
2
Pauri
Ganga sub basin
W Nayar
65
Santodhar – II
2
Pauri
Ganga sub basin
W Nayar
66
Birahiganga
4.8
Chamoli
Alaknanda
Proposed
67
Byaligaon
2.25
Pauri
Ganga sub basin
E Nayar
68
Ghirit Ganga
1.3
Chamoli
Alaknanda
Proposed
69
Jummagad
1.2
Chamoli
Alaknanda
Proposed
70
Kailganga
3
Chamoli
Alaknanda
Proposed
71
Kakra
1
Rudraprayag
Alaknanda
Proposed
72
Kali Ganga
3
Chamoli
Alaknanda
Proposed
73
Garud Ganga
0.6
Chamoli
Alaknanda
Proposed
74
Gansali Bampa
0.05
Chamoli
Alaknanda
Dhauliganga/Ganesh Ganga
Alaknanda Total
5199.25
List of proposed projects in Bhagirathi Basin
SN
Project
Ins Cap (MW)
Dist
Sub-Basin
Status
1
Kotli Bhel (IA)
195
Pauri
Bhagirathi
EC/FAC stage 1
2
Jhalakoti (P)
12.5
Uttarkashi
Bhagirathi
Proposed dharamganga
3
Bhilangana II A
24
Uttarkashi
Bhagirathi
Proposed
4
Karmali
140
Uttarkashi
Bhagirathi
IMG, on Eco-sensitive zone?
5
Jadhganga
50
Uttarkashi
Bhagirathi
IMG: PFR prepared
6
Bhilangana IIB
24
Tehri
Bhagirathi
Under S&I
7
Bhilangana IIC
24
Tehri
Bhagirathi
Under S&I
8
Pilangad-II
4
Uttarkashi
Bhagirathi
Proposed
9
Bhela Tipri
100
Uttarakashi
Bhagirathi
Proposed
10
Nelong
190
Uttarakashi
Bhagirathi
Proposed
11
Asiganga-III
9
Uttarkashi
Bhagirathi
Proposed
12
Gangani (P)
8
Uttarkashi
Bhagirathi
Proposed
13
Balganga-I
5
Tehri Garhwal
Bhagirathi
Proposed
14
Khirao ganga
4
Uttarkashi
Bhagirathi
Proposed
15
Lagrasu (P)
3
Tehri Garhwal
Bhagirathi
Proposed
16
Songad
3
Uttarkashi
Bhagirathi
Proposed
17
Jalandhari Gad
3
Uttarakashi
Bhagirathi
Proposed
18
Jalkurgad I
2
Tehri Garhwal
Bhagirathi
Proposed jalkur gad
19
Rataldhara
0.4
Tehri Garhwal
Bhagirathi
Proposed Jalkur Gad
20
Lamb Gaon
0.4
Tehri Garhwal
Bhagirathi
Proposed Jalkur gad
21
Dhatirmouli
0.4
Tehri Garhwal
Bhagirathi
Proposed Jalkurgad
22
Gangi-Richa
0.2
Tehri Tehri
Bhagirathi
Bhilangana/ Re Gad
Bhagirathi Total
801.9
List of proposed projects in W Ramganga Basin
Golden Mahseer in Ramganga
SN
Project
Ins Cap (MW)
Dist
Sub-Basin
Status
1
Babas Dam
88
Almora
Ramganga
Proposed
2
Khati
63
Bagehwar
Ramganga
Proposed
3
Lumi
54
Bagehwar
Ramganga
Proposed
4
Kuwargarh
45
Bagehwar
Ramganga
Proposed
5
Bawas Gaon
34
Nainital
Ramganga
Proposed
6
Jamrani Dam
30
Ramganga
Proposed
7
Khutani
18
Bageshwar
Ramganga
Proposed
8
Sarju Stage-II (P)
15
Bageshwar
Ramganga
Proposed
9
Sarju Stage-III (P)
10.5
Bageshwar
Ramganga
Proposed
10
Sheraghat
10
Almora
Ramganga
Kho
11
Baura
14
Bageshwar
Ramganga
Proposed
12
Sarju Stage-I (P)
7.5
Bageshwar
Ramganga
Proposed
13
Balighat
5.5
Bageshwar
Ramganga
Proposed
14
MehalChaura-I
4
Pithoragarh
Ramganga
Proposed
15
MehalChaura-II
3
Pithoragarh
Ramganga
Proposed
16
Agarchatti
2
Pithoragarh
Ramganga
Proposed
17
Kho I
2
Pauri
Ramganga
Kho
18
Kho II
2
Pauri
Ramganga
Proposed
19
Harsila
0.7
Bageshwar
Ramganga
Proposed harsila gad
20
Kalsa
0.3
Nainital
Ramganga
Proposed
Ramganga Total
408.5
List of proposed projects in Sharda Basin
SN
Project
Ins Cap (MW)
Dist
Sub-Basin
Status
1
Mapang Bogudhiyar (P)
200
Pithoragarh
Sharda
EAC TOR Approved
2
Bogudhiyar Sarkaribhyol (P)
170
Pithoragarh
Sharda
EAC TOR Approved
3
Sarkaribhyol Rupsiabagar
210
Pithoragarh
Sharda
EAC TOR Approved
4
Rupsiabagar Khasiabara
260
Pithoragarh
Sharda
EAC Ok / FAC Rejected
5
Bokang Baling
330
Pithoragarh
Sharda
Proposed THDC
6
Chungar Chal
240
Pithoragarh
Sharda
Proposed NHPC
7
East Ram Ganga Dam
30
Pithoragarh
Sharda
Proposed
8
Khartoli Lumti Talli
55
Pithoragarh
Sharda
Proposed
9
Budhi
192
Pithoragarh
Sharda
Mahakali
10
Garba Tawaghat
610
Pithoragarh
Sharda-Mahakali
Proposed NHPC
11
Garbyang
131
Pithoragarh
Sharda
Mahakali
12
Lakhanpur
160
Pithoragarh
Sharda
Proposed
13
Malipa
138
Pithoragarh
Sharda
Mahakali
14
Pancheshwar
6000
Pithoragarh
Sharda
Indo Nepal Project
15
Purnagiri Dam
1000
Champawat
Sharda
Indo Nepal Project
16
Tawaghat – Tapovan
105
Pithoragarh
Sharda
Mahakali
17
Taopvan Kalika
160
Pithoragarh
Sharda
Mahakali
18
Tapovan Chunar
485
Pithoragarh
Sharda
Proposed
19
Sela Urthing
230
Pithoragarh
Sharda
Proposed
20
Urthing Sobla (P)
340
Pithoragarh
Sharda
Proposed
21
Sobla Jhimjingao
145
Pithoragarh
Sharda
Proposed
22
Kalika – Baluwakot
120
Pithoragarh
Sharda
Mahakali
23
Kalika Dantu
230
Pithoragarh
Sharda
Proposed
24
Dhauliganga Intermediate
200
Pithoragarh
Sharda
Proposed NHPC
25
Gauriganga III A & B
140
Pithoragarh
Sharda
Proposed NHPC
26
Madkini (P)
39
Pithoragarh
Sharda
Proposed
27
Burthing – Purdam
5
Pithoragarh
Sharda
Proposed Jakula
28
Jimbagad
7.7
Pithoragarh
Sharda
Proposed
29
Suringad-II
5
Pithoragarh
Sharda
Proposed
30
Tanga (P)
5
Pithoraharh
Sharda
Proposed
31
Tankul
12
Pithoragarh
Sharda
Proposed
32
Motighat (P)
5
Pithoraharh
Sharda
Proposed
33
Painagad
9
Pithoragarh
Sharda
Proposed
34
PhuliBagar- Kwiti
4
Pithoragarh
Sharda
Proposed Jakula
35
Kumeria- Garjia (Bawas)
12.5
Nainital
Sharda
Kosi
36
Balgad
8
Pithoragarh
Sharda
E Ramganga
37
Kuti SHP
6
Pithoragarh
Sharda
Maha Kali/ Kuti yangti
38
Palang SHP
6.5
Pithoragarh
Sharda
Maha Kali/ Plang gad
39
Najyang SHP
5.5
Pithoragarh
Sharda
Maha Kali/ Najyang gad
40
Simkhola SHP
8.75
Pithoragarh
Sharda
Maha Kali/ Simkhola gad
41
Birthi
1
Pithoragarh
Sharda
Balchinn
42
Baram
1
Pithoragarh
Sharda
Dhauli Ganga/ Baram Gad
43
Unchiya
0.05
Pithoragarh
Sharda
Dhauli Ganga/ Khari Gad
44
Murtoli
0.02
Pithoragarh
Sharda
Goriganga/ Martoligad
45
Burphu
0.03
Pithoragarh
Sharda
Goriganga/ Martoligad
46
Ralam
0.03
Pithoragarh
Sharda
Goriganga/ Ralangad
47
Ram Gad-II
0.1
Nainital
Sharda
Kosi/ Ramgad
48
Watcm
0.1
Pithoragarh
Sharda
Ramgad E/ Watchraila
Total Sharda Basin
12022.28
List of proposed projects in Yamuna Basin
SN
Project
Ins Cap (MW)
Dist
Sub-Basin
Status
1
Lakhwar
300
Dehradun
Yamuna
EAC TOR Approved
2
Vyasi
120
Dehradun
Yamuna
EAC Recommended
3
Arakot Tuni
81
Uttarkashi
Yamuna
EAC TOR Approved
4
Tuni Plasu
66
Dehradun
Yamuna
EAC TOR Approved
5
Mori-Hanol (P)
63
Uttarkashi
Yamuna
EAC TOR Approved
6
Naitwar Mori (Dewari Mori)
60
Uttarkashi
Yamuna
EAC Recommended
7
Hanol Tuni (P)
60
Uttarkashi
Yamuna
EAC Recommended
8
Jakhol Sankri
45
Uttarkashi
Yamuna
EAC TOR Approved
9
Kishau
600
Dehradun
Yamuna
Proposed
10
Chammi Naingaon
540
Uttarakashi
Yamuna
Proposed
11
Chatra Dam
300
Uttarakashi
Yamuna
Proposed
12
Taluka Sankri
140
Uttarkashi
Yamuna
Proposed
13
Taluka Dam
112
Uttarakashi
Yamuna
Proposed
14
Sankri Mori
78
Uttarakashi
Yamuna
Proposed
15
Barkot Kuwa
42
Uttarakashi
Yamuna
Proposed
16
Hanuman Chatti Sianachatti
33
Uttarakashi
Yamuna
Proposed
17
Barnigad Naingaon
30
Uttarakashi
Yamuna
Proposed
18
Rupin Stage V (P)
24
Uttarkashi
Yamuna
Proposed
19
Damta – Naingaon
20
Uttarkashi
Yamuna
Proposed
20
Tons
14.4
Uttarkashi
Yamuna
Proposed
21
Supin
11.2
Uttarkashi
Yamuna
Proposed
22
Rupin Stage IV (P)
10
Uttarkashi
Yamuna
Proposed
23
Rupin Stage III (P)
8
Uttarkashi
Yamuna
Proposed
24
Barnigad
6.5
Uttarakashi
Bhagirathi
Proposed
25
Pabar
5.2
Dehradun
Yamuna
Proposed
26
Badyar (P)
3
Uttarkashi
Yamuna
Proposed
27
Lagrasu
3
Tehri
Yamuna
Proposed
28
Rayat (P)
3
Tehri
Yamuna
Proposed
29
Ringali
1
Tehri Garhwal
Yamuna
Proposed Aglar Ringaligad
30
Purkul
1
Dehradun
Yamuna
Tons
31
Paligad
0.3
Uttarkashi
Yamuna
Proposed Paligad
32
Rikhani Gad
0.05
Uttarkashi
Yamuna
Rikhanigad
33
Bijapur
0.2
Dehradun
Yamuna
Tons
Yamuna Total
2780.85 MW
Grand Total
21212.78 MW
Note: EAC: Expert Appraisal Committee of MoEF; FAC: Forest Advisory Committee of MoEF; EC: Environment Clearance: FC: Forest Clearance; TOR: Terms of Reference (of EIA); for Alaknanda, the first 17 projects are listed as given in IMG report and for Bhagirathi first 8 projects are as listed in IMG report. However, many of these projects have been recommended to be dropped by the WII (Wildlife Institute of India) report. Also, IMG and other have said that no further projects should be taken up in Bhagirathi and Alaknanda basins. The projects listed above in the Bhagirathi basin beyond serial number 8 and those in Alaknanda basin beyond 17 would, in any case, not be taken up.
In the table below we have provided and overview of proposed hydropower projects in Uttarakhand based on the information from above five tables.
Overview of Proposed Hydropower Projects in Uttarakhand
Basin
Large Hydro projects (above 25 MW)
Small Hydro projects (1-25 MW)
Mini-micro Hydro projects (below 1 MW)
Total Hydro projects
No of projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
Alaknanda
29
4823
43
375.6
2
0.65
74
5199.25
Bhagirathi
5
675
13
125.5
4
1.4
22
801.9
Ramganga
6
314
12
93.5
2
1
20
408.5
Sharda
26
11920
16
101.95
6
0.33
48
12022.28
Yamuna
17
2670
13
110.3
3
0.55
33
2780.85
TOTAL
83
20402
97
806.85
17
3.93
197
21212.78
Overview of hydropower projects in Uttarakhand In the table below we have put together the number and capacities of existing, under construction and proposed hydropower projects in various basins of Uttarakhand. Uttarakhand government has plans to have total of 337 hydropower projects with total capacity of 27191.89 MW. Largest number (124) of such projects are in Alaknanda basin, the largest capacity is proposed to be in Sharda basin at 12450.905 MW.
In the table below we have given basin wise figures of total large, small and mini-micro hydropower proejcts (including existing, under construction and proposed) projects in Uttarakhand. According to Union Ministry of New and Renewable energy, total potential of small hydro in Uttarakhand is 1707.87 MW from 448 small hydro projects. If we take that into account the figures in the following tabes would change (go up) accordingly.
Basin wise total capacities for large, small and mini HEPs in Uttarakhand
Basin
Large Hydro projects (above 25 MW)
Small Hydro projects (1-25 MW)
Mini-micro hydro projects (<1 MW)
Total Hydro projects
No of projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
Alaknanda
35
6419
61
524.65
26
3.67
122
6947.32
Bhagirathi
10
3469
28
266.7
10
2.05
48
3737.75
Ganga Sub basin
1
144
3
31.2
2
0.35
6
175.55
Ramganga
7
512
14
105.3
11
2.05
32
619.35
Sharda
29
12335.6
20
109.65
35
5.155
84
12450.405
Yamuna
22
3144.75
14
113.3
8
1.135
44
3259.185
TOTAL
104
26024.35
140
1150.8
92
14.41
336
27189.56
In the table below we have given basin wise figures of existing, under construction and proposed hydropower projects of all sizes in Uttarakhand.
Overview of all Hydropower projects in Uttarakhand
Basin
Existing Hydro projects
Under construction projects
Proposed hydropower projects
Total Hydro projects
No of projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
No of Projects
Capacity, MW
Alaknanda
32
456.97
16
1291.1
74
5199.25
122
6947.32
Bhagirathi
13
1851.5
13
1084.75
22
801.9
48
3737.75
Ganga Sub basin
4
173.8
2
1.75
–
–
6
175.55
Ramganga
12
210.8
–
–
20
408.5
32
619.35
Sharda
28
427.75
8
0.375
48
12022.28
84
12450.405
Yamuna
9
478.195
2
0.14
33
2780.85
44
3259.185
TOTAL
98
3598.665
41
2378.115
197
21212.78
336
27189.56
Basin Maps Maps of Hydroelectric Projects in various sub basins of Uttarakhand are available at the following links. Please note that the maps are based on information available when the maps were created in 2011:
How do the hydropower projects increase the scale of disaster?
This is a question that a lot of journalists and TV anchors have been asking me since the Uttarakhand disaster. Here is a quick response:
Þ Almost all hydropower projects of Uttarakhand involve deforestation. Deforestation directly increases the potential of erosion, landslides and floods since water now just runs off to the rivers. Moreover the compensatory afforestation and catchment area treatment, even when done, usually involves planting of commercially important variety of trees like pine and teak and not broad leaf tress like oaks which not only adds humus in the soil, but also allows rich under growth. Pine does not allow this to happen. This change in character of forests is something Gandhiji’s disciple Mira Behen has been warning since independence, but there is little impact of this on the forest department.
Þ In fact largest proportion of deforestation in Uttarakhand has happened basically for hydropower projects.
Þ All run of the river projects involve building of a dam, diversion structure, desilting mechanism, tunnels which could have length of 5 to 30 km and width sufficient to carry three trains side by side, as also roads, townships, mining, among other components. All of these components increase the disaster potential of the area in one or the other way. Cumulative impacts of all the components of any one project and all projects together in a given basin is likely to be larger than the addition of the impacts of individual projects in many cases.
Þ Massive blasting of massive proportions is involved in construction of all these components, which adds to landslide risks. In fact Uttarakhand’s Disaster Mitigation and Management Centre in their report of Oct 2012 after the Okhimath disaster of Sept 2012 recommended that no blasting should be allowed for any development activity anywhere in Uttarakhand, but Uttarakhand government did nothing about this recommendation.
Þ The massive tunneling by itself weakens the young and fragile Himalayan mountains, increasing the disaster potential.
Þ Each of the hydropower project generates immense amount of muck in tunneling, blasting and other activities. A large hydropower project could typically generate millions of cubic meters of muck. The large projects are supposed to have muck disposal plan, with land acquired for muck disposal, transportation of muck to the designated sites above the High Flood levels, creation of safety walls and stabilization process. But all this involves costs. The project developers and their contractors find it easier to dump this muck straight into the nearby rivers. In the current floods, this illegally dumped muck created massive disaster in downstream areas in case of 330 MW Srinagar HEP, the 76 MW Phata Byung HEP and the 99 MW Singoli Bhatwari HEP. When the flooded rivers carry this muck, boulders and other debris, has much greater erosion capacity and also leaves behind massive heaps of this muck in the flooded area. In Srinagar town about 100 houses are buried in 10-30 feet depth of muck. Such debris laden rivers also create massive landslides along the banks.
Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan
Þ Wrong operation of hydropower projects can also create greater disasters in the downstream areas. For example the operators of 400 MW Vishnuprayag HEP on Alaknanda river did not open the gates when the river was flooded on June 16-17, possibly to maximize power generation. However, this lead to accumulation of massive quantities of boulders (for photos of dam filled with such boulders see: http://matuganga.blogspot.in/) behind the dam, so much so that that there was no space for water to flow. The river then bypassed the dam and started flowing by the side of the dam, creating a new path for its flow. This created a sudden flashflood in the downstream area, creating a new disaster there.
Boulders devouring the Vishnuprayag Project. 26th June 2013 Photo: Matu jan Sangathan
Þ The incomplete, broken and ill designed protection wall of the Maneri Bhali projects in Uttarkashi lead to erosion and landslides in the downstream areas.
DAMAGED HYDRO PROJECTSA large number of hydropower projects are likely to have suffered damage due to the flood disaster in Uttarakhand. Some of the projects that have suffered damage include:
According to the update from http://www.energylineindia.com/on June 27, 2013, the 520 MW under construction Tapovan Vishnugad HEP has suffered damaged by rains on June 16, 2013: “While construction of diversion tunnel was completed in April this year, the same was washed away due to heavy rains on June 16. Diversion dyke has washed away and damages have been observed in chormi adit approach road. In August last year, the flash floods had caused serious damages in the coffer dam of the project.”
76 MW Phata Byung HEP of Lanco in Mandakini Valley in Uttarakhand
99 MW Singoli Bhatwari HEP of L&T in Mandakini Valley in Uttarakhand NDTV India reported that the water level of the river has gone up due to the silt dumped by dams. This is likely to be due to the Phata Byung and Singholi Bhatwari HEPs.
Assiganga projects on Assiganga river in Bhagirathi basin in Uttarakhand
5 MW Motighat I HEP in Goriganga basin in Pithoragarh (Himalprakriti report)
280 Dhauliganga Project of NHPC in Pithoragarh district of Uttarakhand (reports said the power house was submerged, but is now working, part of the township was submerged.)
The Himalaya Hydro (HH) Tanga Phase I for 5 MW, located along the Paina gad in Goriganga basin, is badly damaged. The dam has got smashed by a deluge of huge boulders. One sluice gate is torn through. The metal filter-gates are all choked with boulder debris, and the remnant concrete and gate pulleys of the dam are now stranded mid-river, with both banks eroded and the river now running along the true-left bank. (Himalprakriti report)
The UREDA 500 KW Motigad microhydel on Moti gadh (a tributary of Paina gadh) at Bindi (Dani Bagad) is also badly damaged. The water has broken through the wall, cut under the foundation, inundated the turbines with water and debris, and smashed the housing for the electrical distribution system. (Himalprakriti report)
The 5.5′ diameter head race waterpipes taking water to the HH Phase II, located on the Gori opposite Seraghat, has also been damaged. The generator and housing for the HH Ph II has collapsed into the river. All this damage is said to have happened on the evening of 17th June. People working as non-skilled labour have been sent home for a few months, but welding work on the new pipes feeding the powerhouse is still underway! (Himalprakriti report)
Down to Earth (http://www.downtoearth.org.in/content/hydropower-projects-suffer-severe-damage) has given some details of damage to some of the hydropower projects, quoting UJVNL sources. It says: 19 small hydropower projects have been completely destroyed, while others have been damaged by the raging waters (see table below)
Project
Location
Capacity
Estimated Loss
Dhauli Ganga
Pithoragarh
280 MW
Rs 30 crore (project completely submerged)
Kaliganga I
Rudraprayag
4 MW
Rs 18-19 crore (power house and 4 houses washed away)
Kaliganga II
Rudraprayag
6 MW
Rs 16 crore (power house and 4 houses washed away)
In addition, a large number of projects had to stop generation temporarily due to high silt content, including Maneri Bhali I and II, Tanakpur, Dhauli Ganga, Kali Ganga I, some of the Yamuna basin projects among others.
Conclusion This article was intended to give an overview of hydropower projects in Uttarakhand. However, we should add that there are many glaring issues related to these hydropower projects, some of the key issues include:
Most of these projects are out of the environmental governance. Projects below 25 MW do not require EIA, Social Impact Assessment, public consultation, environmental clearance, environmental management plan or monitoring. This is clearly wrong as all projects have environmental impacts, and they are particularly serious in Himalayan region with multiple vulnerabilities. We have for years demanding that all projects above 1 MW should need environment clearance, EIA and so on.
Even for projects above 25 MW we do not have any credible environmental or social impact assessment. Former Environment Minister Jairam Ramesh is on record having accepted that most EIAs are dishonest cut and paste jobs. We do not have any credible process in place to ensure that EIAs are proper and those that are not are rejected and consultants are black listed. Jairam Ramesh did put in place a process of registration of EIA consultants under the Quality Council of India, but that is completely non transparent, unaccountable and ineffective process. It is amazing that reputed NGOs like the Centre for Science and Environment are on board of this process, but they have completely failed to achieve any change and have chosen to remain quiet.
The Environment clearances of the River Valley Projects (which includes hydro projects and dams) is considered by the Expert Appraisal Committee on River Valley Projects appointed by Union Ministry of Environment and Forests. However, the ministry chooses members of the EAC such that they rarely object to any project. As per SANDRP analysis in six years ending in Dec 2012, the EAC had not said NO to any project for environment clearance. Its appraisal of projects, EIAs, public consultation process and its own minutes were found to be inconsistent, unscientific and loaded in favour of the project developers.
Our environment compliance system is non-existing. The projects are supposed to implement the environment management plan pari passu with the project work, they are supposed to follow the conditions of environment clearance, follow the environmental norms, but who is there to ensure this actually happens? The Union Ministry of Environment and Forests which is supposed to ensure this compliance has no capacity the officials tell us. The officials do not have time to even check if six monthly compliance reports are being submitted or make any surprise visits. However they do not even seem to have will, since we have seen no change in this situation for decades. Nor do they seem to have willingness, since even when NGOs present photographic and video and other evidence of violations they refuse to take action.
One way to achieve compliance is to have a project monitoring committee for each project where over 50% of the members are from local communities and other independent persons and such committees ok must be required each stage for the project to go ahead. We have been suggesting this for long, but the MoEF has shown no willingness to follow this.
More pertinently, none of the assessment reports look at the impact on the disaster potential of the area. Each of these projects have significant impact on the disaster potential of the area, particularly in the context of a vulnerable state like Uttarakhand. This should be a must for all such projects.
Similarly the projects must also be assessed in the context of climate change, again in vulnerable area like the Himalayas. How the project will impact the local climate, how it will have impact on adoption capacity of the local communities and also how the project itself will be impacted in changing climate. This again we have been writing to the MoEF numerous times, but without any success so far.
Most significantly, the only impact assessments that we have is for specific projects of over 25 MW capacity. However, we have no credible cumulative impact assessment for any of the river basins of Uttarakhand, which also takes into account carrying capacity of the river basins and all the interventions that are happening in the basins. As our critique of so called cumulative impact assessment of Bhagirathi-Alaknanda basins done by AHEC of IIT Roorkee shows (see: http://www.sandrp.in/hydropower/Pathetic_Cumulative_Impact_Assessment_of_Ganga_Hydro_projects.pdf), it was not much of a cumulative impact assessment. WII (Wildlife Institute of India, Dehradun) report was somewhat better within the mandate given to it (assessment of hydro projects on aquatic and terrestrial biodiversity), but the most important recommendation of the WII report that at least 24 projects should be dropped has not been accepted by the MoEF, so what is the use of the cumulative impact assessment in such a situation?
Unless we address all of the above issues in a credible way, there is little wisdom in going ahead with more hydropower projects in Uttarakhand.They will invite greater disasters. Uttarakhand has many other options for development.
Firstly people of Uttarakhand should get first right over all the power that is getting generated within Uttarakhand.
Secondly, this is not a plea for no projects, but to address the crucial issues without addressing which we are in no situation to even know the impacts or address the issues.
Thirdly, Uttarakhand needs to take up power generation options that do not accentuate the disaster potential of the area. Such options include micro hydro, hydro kinetics, and solar and biomass based power in addition to better utilization of existing infrastructure.
Going ahead with more hydropower projects in current situation would be invitation to greater disasters. In fact, the Uttarakhand government should not allow even the damaged and under construction hydropower projects until al the conditions mentioned above are satisfied.
Some of the hydropower projects that have surely seem to have added to the disaster proportions of current Uttarakhand flood disaster include the 400 MW Vishnuprayag HEP, the 280 MW Dhauliganga HEP, the 330 MW Shrinagar HEP, the 304 and 90 MW Maneribhali II and I HEPs, the 99 MW Singoli Bhatwari HEP and the 76 MW Phata Byung HEP, the last two on Mandakini river.
In response to my question on a programme on Headlinestoday channel anchored by Rahul Kanwal on July 8, 2013 (in presence of panel that also included Dr Vandana Shiva and Vimlendu Jha), the Uttarakhand Chief Minister Shri Vijay Bahuguna agreed that he will institute an enquiry into the damage due to these hydropower projects and hold them accountable for such damage.
Let us see how soon and how independent and credible enquiry he institutes.
– Himanshu Thakkar
South Asia Network on Dams, Rivers & People (www.sandrp.in) July 2013
The following submission has been sent to the Expert Appraisal Committee, River Valley and Hydro Power Projects, Ministry of Environment and Forests, India. The current norms recommended by EAC while clearing hydropower and irrigation projects are hardly leaving any water for the rivers (eflows), thereby destroying rivers as well as livelihoods.
Norms on e-flows followed by EAC need to change
Respected Chairperson and members,
As you know, the Inter ministerial Group on Ganga Basin was constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012. It has subsequently submitted its report to the MoEF in April 2013.
While there are several issues about IMG’s report and recommendations, some of the recommendations are the minimum, urgent stop gap measures that need to be implemented by the EAC. IMG’s recommendations are relevant for nearly all rivers across the country. All of the rivers have rich social and religious values and a large proportion of population depends on them for livelihood. Hence, the recommendations of IMG logically apply to all the rivers. In line with the IMG Report recommendations, we urge the EAC to modify its recommendations about eflows and environmental impacts as suggested below:
1. Eflows
a. Eflows to be based on daily uninterrupted flows, not seasonal flows
The IMG report states that: “An important component of the e-flows regime has to be mimicking of the river flows so as to keep it very close to the natural flows. Cumulative norms even on seasonal basis do not meet this objective. Daily inflow norms may, however, enable a sustained river flow as well as have large flows in the high season and hence are more suitable.” (emphasis added)
IMG has thus recommended that all dams and hydro projects should release water based on daily inflows, following the % releases recommended in each season, but the releases must change as per daily inflows.
b. Eflows as 30-50% of daily lean season flows
The IMG report recommends that releases should be 50% of lean season flows where average lean season flow is less than 10% of the average high season flow. Where average lean season flow is 10-15% of the average high season flows, the releases should be 40% of inflows and where 30% for the rest of the rivers.
In keeping with IMG recommendations, we urge that the EAC should be recommending 50% average daily flows in lean season as eflows.
c. Independent, community-based monitoring of Eflows releases
Monitoring of eflows releases from operating projects is crucial, given the fact that it is currently entirely in the hands of the proponent without any monitoring of compliance by the MoEF. In such a situation, proponents are not releasing any eflows as pointed out by the one person Avay Shukla Committee Report, recent CAG report of Himachal Pradesh.
IMG recommends: The IMG has considered the need for an effective implementation of the e-flows as cardinal to its recommendations. It is recommended that the power developer must be responsible for developing a monitoring system which is IT-based and gives on a real time basis the flow of water in the river, both at the inflow and in the outflow after the river gates in the river stream. This should be
(a) monitored by an independent group
(b) reviewed yearly by the Ministry of Environment and Forests in the first five years and
(c) put in public domain the e-flows. This real time public monitoring of e-flows will be the key.
We urge that that EAC recommends similar monitoring norms for all projects. Effective monitoring cannot be done if local affected population is not a part of this process, hence, in addition to above points, EAC should recommend that eflows should be monitored by an independent group which has at least 50% participation of downstream communities facing the impacts of these projects.
d. Assessing eflows only through participatory and true Building block Methodology (BBM)
The IMG states: “Considering environment, societal, religious needs of the community and also taking into taken in to account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirements on a long-term basis. This recognizes the fact that the riverine species are reliant on basic elements (Building Block) of the flow regime, including low flows, and floods that maintain the sediment dynamics and geo-morphological structure. It also includes an understanding of the functional links between hydrology and ecology of the river systems.”
However, the EAC is accepting any eflows assessment as BBM, simply looking at the label provided by EIA consultants, without applying its mind. We have pointed out that BBM purportedly used by consultants like WAPCOS in Lohit Basin Study is not BBM in any sense.
We urge the EAC to:
· Recommend methodology of BBM assessment clearly at the time of granting TORs (This is available from WWF or here: King, J.M., Tharme, R.E., and de Villers, MS. (eds.) (2000). Environmental flow assessments for rivers: manual for the Building Block Methodology. Water Resources Commission Report TT 131/100, Pretoria, South Africa. ),
· Recommend sectors which should be included in BBM study of a specific river (downstream users, fishermen, geomorphology experts, ecologists, etc.) clearly at the time of granting TOR. Downstream users should form a part of the BBM Group in all circumstances.
· Check whether these sectors are duly represented in flows studies
And only then accept the study as being based on BBM methodology. The current practice of EAC of accepting any shoddy assessment as BBM is serving neither the rivers, nor the communities, nor is it expanding India’s experience with BBM.
e. Release of Eflows
It is not just how much the releases are, but how the releases are made that decides if the releases are useful for the rivers, biodiveristy and the society. Unfortunately, EAC has given no attention to this issue.
In this context, one of the guideline of the IMG says, “Fish passes may be made an integral part of hydropower projects. Regular monitoring for their effectiveness be done by project developers.”
EAC should follow this and make well designed eflow release mechanism mandatory part of the EIA study and post-construction monitoring.
2. Free flowing river stretch between projects
Currently, the EAC has a very lax norm of recommending 1 km distance of the river between two projects. In many cases, the EAC is not following even this minimalist distance criterion. Nor is it following recommendations of civil society, or expert committees of having minimum 5 kms of free flowing river before it meets the downstream project/submergence.
In this regard, the IMG notes “There is a clear need to ensure that adequate river length is available to meet the societal needs and River gets adequate time during its flow to regenerate itself.”
The EAC should include, as part of EIA and TOR a detailed study of:
· “Time” required by the river between two projects to rejuvenate itself and how much distance the river need to have such time to rejuvenate itself.
· Ecology (including livelihood fisheries) downstream of a project and how it will be affected by modified flows while granting TORs to hydro projects.
· Social and cultural use of the river downstream the project: presence of religious sites, river sanctuaries, etc. while granting TORs to hydro projects.
Based on this, the EAC should recommend distance of free flowing river that needs to be maintained downstream a specific project. This should be applicable even if this was not stated at the time of deciding TOR.
3. Recommend Free flowing and Pristine rivers in all basins
World over, there exist norms and laws to protect free flowing rivers as “Pristine, Wild or Heritage Rivers”. EAC has been recommending damming most of the rivers in the country in the recent years. The EAC should recommend that some rivers should be maintained in their pristine, undammed (or with the current stage of development, no further) condition.
In fact, the IMG has specifically recommended: “ The River Ganga has over a period of years suffered environmental degradation due to various factors. It will be important to maintain pristine river in some river segments of Alaknanda and Bhagirathi. It accordingly recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, AssiGanga, Dhauli Ganga (upper reaches), Birahi Ganga and Bhyunder Ganga, should be kept in pristine form and developments along with measures for environment up gradation should be taken up.”
Unfortunately, currently the EAC is actually clearing projects when Cumulative Impact Studies or Basin Studies on such rivers are not completed or are on-going (Example: Chenab Basin Projects, Satluj Basin Projects, Lohit Basin Projects). We have pointed this out to the EAC on number of occasions, without any response.
We urge the EAC to recommend a few ecologically and socially important rivers in each basin as pristine rivers, to be protected from any projects at the time of clearing basin studies or cumulative impact assessment studies. At the same time, the EAC should analyse the present development stage of a basin while clearing specific projects and should recommend some rivers in pristine state. In places like North East India and western Ghats, certain river basins may need to be left in pristine state.
4. Recommendations to the MoEF about eflows from existing projects
The IMG has made a clear recommendation in this regard: “The suggested e-flows should be applicable to the existing power projects in operation in these States.” IMG has given maximum of three years for the projects to achieve e-flows.
We urge the EAC to make a recommendation to the MoEF to look at existing projects and recommend eflows norms on the same lines as those for new projects in time bound manner.
As the World Environment Day is drawing close, we are sure that the EAC will look at its role of protecting the Riverine environment and communities and will take proactive steps in this regard.
Looking forward to your point-wise response to the issues raised above.
Summary A month after its submission to the Union Ministry of Environment and Forests, the Inter Ministerial Group on Upper Ganga basin Hydropower projects and Ganga river in general is yet to be put in public domain. A detailed perusal of the report shows that the report is hugely biased in favour of large hydropower projects, and has not done justice to the task given to it or to the Ganga river, people or environment. Out of the three non government members (out of total 15 members) on the Group, Dr Veer Bhadra Mishra expired during the working of the group. Rajendra Singh has given a dissent note, not agreeing with the report in its totality. The “alternative view” note from Sunita Narain, the third non-government member, is not much of an alternative and is not in the interest of the river, people or the environment. However, the fact that none of the non-government members have endorsed the report speaks volumes about the credibility of the report.
The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations.
A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. The report gives a list of positive aspects of the IMG report on which there is a lot of scope for positive action, which the MoEF should initiate, while rejecting the report.
FULL TEXT
1. The Inter Ministerial Group (constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012) report has been submitted around April 22, 2013, but it is still not in public domain a month later. The report should have been promptly put in public domain as in the case of the HLWG report on WGEEP panel recommendation on the Western Ghats, which was made public the day after the submission of the report to MoEF. These comments[1] are based on the hard copy of the final report made available by a colleague[2].
2. The IMG final report has been endorsed by all members, except the dissent note by Rajendra Singh attached at Annexure X and a note on “alternate approach” from Sunita Narain, attached at Annexure XI. Shri Veer Bhadra Mishra, who was the third non-government member, expired during the period of functioning of the IMG group. The committee constitution was heavily loaded in favour of the government officers (ten of the fifteen members were government officials), so its independence was already in doubt. With none of the non-government members endorsing the report, the report has little credibility. This review tries to look at the report with an open mind.
3. While SANDRP as a group is critical of large, destructive and non participatory hydropower projects, it does not mean the group is against all hydropower projects. For example, if the projects were to be set up through a participatory and informed, decentralized, bottom up decision making process or if projects were to follow the recommendations of World Commission on Dams, such projects would certainly have greater public acceptance. That is not the case for any of the projects today.
4. The main TOR given to the IMG was to decide the quantum of environment flows for the upper Ganga basin rivers, keeping in mind the IIT (Indian Institute of Technology Roorkee, the report was basically from some individual of Alternate Hydro Electric Centre of IIT-R) and WII (Wildlife Institute of India) reports on cumulative impact assessment of the projects in these river basins. However, IIT (Roorkee) report has been found to be so flawed and compromised (for details see: http://www.sandrp.in/hydropower/Pathetic_Cumulative_Impact_Assessment_of_Ganga_Hydro_projects.pdf) that it should have been rejected by the MoEF and the NGRBA. Even the MoEF’s Expert Appraisal Committee on River Valley Projects has been critical of the IIT-R report. However, since a member of the IIT-R was present on the IMG, it may not have been possible for the IMG to take an objective view of the merits of IIT-R report. It is however, welcome that IMG has relied on WII rather than IIT-R report while accepting recommendations on e-flows. WII report was better in some respects, though still suffering from some basic infirmities. Moreover, to set up an IMG to decide on the course of action considering these two reports (and any other relevant reports) was compromised at the outset and was an invitation for further dilution of the environment norms, considering the track record of the most of the members of IMG.
Ganga river flowing through a channel, diverted for the 144 MW Chilla hydropower project
5. The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even
where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations. All of these points are further elaborated in this note.
6. Cancelled projects & those on Bhagirathi Eco Sensitive Zone shown as under development Shockingly, even the projects like the Loharinag Pala, Pala Maneri and Bhairon Ghati that have been officially dropped are shown as under development by the IMG, see Annex VID! In fact in Table 12 and 13 IMG even calculates the reduction in power generation and increase in tariff at Loharinag Pala (among others) if the IMG recommended e-flows are implemented! The 140 MW Karmoli HEP on Bhagirathi, on a stretch that the MoEF has been declared as Eco Sensitive Zone, and on which the GOI has said no large hydro will be taken up, the IMG has actually suggested that the project can be taken up! The 50 MW Jadhganga project, very close to the Gangotri, is shown to be project under development by the IMG! These examples show how the IMG has played a role of supporter of the hydropower lobby.
7. Wrong classification of projects as under construction and under clearance projects IMG has divided the 69 hydropower projects in Upper Ganga basin (leaving our the Kotli Bhel 2, since it is on Ganga river and not on Bhagirathi or Alaknanda) in four categorie
s: Operating projects, under construction projects, under clearance projects and under development projects. It is here that IMG has done its biggest manipulation by classifying a number of projects as under construction when they are not and cannot be under construction. IMG classification of projects under clearances is equally problematic. IMG and even the “alternative View” by Sunita Narian says all these projects in first three categories can go ahead without any change, except the e-flows recommendations. This manipulation shows the stark pro hydro-bias of the IMG.
Dry Ganga river after the river is diverted for Chilla HEP. Photos by SANDRP
8. Manipulations about percentage length of river that the projects can destroy On the one hand, the IMG has recommended that “projects may be implemented so that not more then 60% of the length (of the river) may be affected.” There is no mention how they have arrived at this magic figure of 60%, what is the basis or science behind that magic figure. At the same time the IMG has said that if all the 69 projects were to be implemented than 81% of Bhagirathi and 65% of Alaknanda will be affected. Firstly these numbers are not correct if we taken into account the full length of the reservoirs and the bypassed river lengths by the hydro projects, in many cases the length of the submerged reservoir behind the dam has not been counted. Here we need to add the fact that the reservoir of the 70th Project on its list, the Kotlibhel 2 project will submerge parts of both Bhagirathi and Alaknanda rivers, which has also not been counted by the IMG. WII had to recommend 24 projects to be dropped, and even after that, WII assessed that 62.7% of the rivers would still be affected. However, the IMG has made no recommendation as to which of the projects need to be dropped (except vague review of the projects in Annex VI-D) to achieve that magic figure of 60%. This again shows how non serious IMG is, making this recommendation meaningless.
9. IMG double talk on distance criteria The IMG has said that “There is a clear need to ensure that adequate river length is available to meet the societal needs and River gets adequate time during its flow to regenerate itself” (emphasis added). This sounds good. But IMG has shown no will or interest in ensuring that this happens. In fact IMG exposes its understanding on this matter when it says, “the distance between two hydro projects should generally be such as to ensure that over-crowding is avoided”. What is over-crowding, how do you define it? This is a funny word IMG has used, not even bothering to define it. However, when it comes to implementation, dumping all these requirements, IMG has justified smaller distance (read zero distance) between projects where gradient is high. Now let us understand this: where gradient is high, if the distance left between the projects is less, will the time the river flows between projects be smaller or greater than if the gradient is low? Clearly, if gradient is high, for the same distance, the river will have less time to travel then if the gradient were low. It is in fact the time of free flow that is a crucial driving parameter for river to regenerate itself. So if the river were to have the same amount of time to flow between two points, with higher gradient, river will require more distance, not less. This again exposes the poor understanding of IMG members about science of the rivers.
The IMG even goes on to say that “distance will have to be smaller in view of technical requirement of the hydro power. This could result in continuity in some cases.” Firstly it is clear here again that IMG is basically catering to the hydropower lobby, it is completely non serious about the environmental issues. That is why after all those great sentences, it goes on to say that it is the technical requirement of the hydropower project that will be the decider! If technical requirements means no distance between two projects, then river can disappear, environmental issues do not matter! In case of many projects where the distance of free flowing river between projects is very little or nil and where the construction has not started or has not progressed much, there is today scope for change. For example in case of Vishnudgad Pipalkoti HEP on Alaknanda: the Full Reservoir Level of the VPHEP is same as the Tail Water Level of the upstream Tapovan Vishnugad HEP. This means that there is zero length of free flowing river between the projects. VPHEP does not have all the clearances and its construction has not started. Even for the upstream Tapovan Vishnugad HEP, the construction has not gone far enough and there is scope for change in both projects to ensure that there is sufficient length of free flowing river between the projects. IMG should have recommended change in parameters in this and other such cases, but it has done no such thing, it has shown no interest in any such matter! Even the “alternative approach” note in Annexure XI has not bothered to recommend such changes even while recommending 3-5 km free flowing river between two projects.
The IMG makes another unscientific statement in this context when it says, “With the recommendation of IMG for environment flow which will be available and which would have traveled throughout the diverted stretch, any significant gaps and large distance may not be required.” This is an unscientific, unfounded statement. Firstly where is the evidence that the environment flows that IMG has suggested would take care of the need for river to flow on stretches between the projects? Secondly, the need for river to flow between the projects to rejuvenate itself will also depend on the length of the rivers submerged by the reservoirs, and also depend on the biodiversity, the social, cultural and religious needs in addition to the ecological needs. By making such ad hoc unfounded statements devoid of scientific merit, the IMG has exposed itself.
While the IMG talks about the rich diversity of fish species and other aquatic diversity of the river, it has no qualms in saying that e-flows alone will address all the problems caused by bumper to bumper projects. As many including Government of India’s CIFRI (Central Inland Fisheries Research Institute) have concluded, Dams have been the primary reason for the collapse of aquatic diversity in India, not only because of the hydrological modifications and lack of e-flows, but also because of the obstruction to migration they cause, destruction of habitat during construction, muck disposal, trapping of sediments, destruction of terrestrial (especially riparian) habitats. But these concerns are not even considered by the IMG while saying that recommended e-flows will be able to solve all problems caused by bumper to bumper projects.
Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute
10. WII recommendation of dropping 24 HEPs rejected by IMG without any reason The IMG notes that WII has recommended that 24 hydropower projects of 2608 MW installed capacity should be dropped in view of the high aquatic and terrestrial biodiversity. However, IMG decides to dump this WII recommendation without assigning any reasons. This again shows the strong pro hydro bias of the IMG. WII report says that even after dropping these 24 projects, at least 62% of the river will be destroyed.
It is shocking that projects like Kotlibhel 1B and Alaknanda HEP, which have been rejected by WII and Forest Advisory Committee, is considered as “under development” by IMG, when they should have been rejected. While the IMG Report talks of unique biodiversity of the Ganga Basin, Valley of Flowers and Nanda Devi National Parks, it still supports projects which will be affecting these National Parks like the 300 MW Alakananda GMR HEP, which was also rejected by the WII and FAC (twice).
As a matter of fact, of the 24 projects that WII report recommended to be dropped, the IMG has shown 8 as under construction and 4 as “projects with EC/FC clearances”. This is sheer manipulation, in an attempt to make them a fait accomplice. Strangely, the “alternative approach” note in Annexure XI does not say anything about this manipulations and in fact says the projects in Annexure VI-B and VI-C can go ahead!
11. Non serious recommendation about keeping six tributaries in pristine state IMG (Para 3.70) “recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, Assi Ganga, Dhauli Ganga (upper reaches), Birahi Ganga and Bhyunder Ganga should be kept in pristine form and developments along with measures for environment up gradation should be taken up. No new power projects should be taken up in these River Basins.” This sounds good, but turns out to be like a joke, since firstly, IMG recommends construction of projects on these rivers that yet to be constructed! If these rivers are to be kept in pristine state then IMG should have asked for immediate stoppage of under construction projects and also time bound decommissioning of the operating projects on each of these rivers. In stead, the IMG report shows that projects are under construction on rivers like Assi Ganga (stage I and stage II projects each of 4.5 MW), Birahi Ganga (24 MW stage I project), Bal Ganga (7 MW stage II project listed in Annex VI B of IMG report, in addition to the 1 MW Balganga and 5 MW Balganga I project are also under construction as per IIT Roorkee report) and Bhyunder Ganga (24.3 MW stage II project) and IMG has (implicitly) recommended that these projects be allowed to continue, on rivers that IMG says it wants to remain pristine! Moreover, Rishi Ganga (13.2 MW project) and Birahi Ganga (7.2 MW) have operating projects on these rivers to be kept pristine! In addition, on Assi Ganga the 9 MW stage III project, is considered by the IMG as ready for development since it has some of the clearances.
Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu
The IMG has noted that 70 MW Rishi Ganga Stage-1 and 35 MW Stage II Project are under development on Rishi Ganga (IIT-R report mentioned another project on Rishi Ganga, namely the 60 MW Deodi project, it is called Dewali project by WII report; WII report also mentions 1.25 MW Badrinath II existing project on Rishi Ganga) and 24 MW Birahi Ganga-II project is under development. But the IMG does not recommend dropping of these projects.
So at least five of the six rivers that the IMG claims it wants to stay in pristine state are no longer pristine! They have multiple projects, most of them under construction or yet to be developed and the IMG has not said that any or all of these projects should be stopped, cancelled and those under operation be decommissioned in time bound manner. Even on Nayar, the sixth small tributary that IMG said should be kept in pristine condition has a 1.5 MW Dunao project under development by UJVNL, as per the UJVNL website. It’s clear how non serious IMG is about its own recommendation. IMG has included Dhauli Ganga (upper reaches) in this recommendation, but has not even bothered to define which stretch of the Dhauli Ganga this applies to, again showing the non-seriousness of IMG.
In para 4.22 IMG says, “Specifically, it is proposed that (a) Nayar River and the Ganges stretch between Devprayag and Rishikesh and (b)… may be declared as Fish Conservation Reserve as these two stretches are comparatively less disturbed and have critically important habitats for long-term survival of Himalayan fishes basin.” If IMG were serious about this, they would have also said that Kotli Bhel II project should be cancelled since it is to come in this very stretch.
IMG’s claim that not having any more projects on these six streams will mean loss of generating capacity 400 MW is also not backed by any sort of information or list of projects to be dropped, it seems IMG is in the habit of making such claims and does not feel the need to back them.
12. IMG on environmental impacts of Hydropower projects One of the key TORs given to IMG was “to make a review of the environmental impacts of projects that are proposed on Bhagirathi, Alaknanda and other tributaries of river Ganga and recommend necessary remedial action.” What has the IMG done about this TOR? IMG wrongly claims (Para 4.18), “The environment impact of proposed 69 hydropower projects has been considered by IMG.” It has done absolutely no justice to this very crucial TOR. First thing IMG has done in this regard is to dump the WII recommendation to cancel 24 hydropower projects, without giving any justifiable reasons. The IMG has produced a set of guidelines for the hydropower projects, which have almost nothing new, they are certainly not comprehensive or legally binding. They miss the most important issues of inadequate environment impact assessment, inadequate public consultation process, inadequate appraisal, lack of accountable governance and compliance.
What is required is certainly not new set of guidelines. MoEF already has a long list of environment and forest clearance conditions, environment management plans and manuals. But there is no interest, will or willingness to achieve compliance in MoEF. IMG is obviously aware of this state of affairs. Yet they have happily prepared a new set of five page guidelines just to show they have done something about this TOR. The “alternative approach” in Annex XI also has nothing to offer on this score.
Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan
13. Unwarranted conclusion about BBM methodology The IMG has said, “Considering environment, societal, religious needs of the community and also taking into account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirement”. This is good and needs immediate and credible implementation.
However, IMG says this will be applicable only “in situation where the required conditions are satisfied and resources, time and data are available.” The only basis for this conclusion by IMG is the fact that WWF took three years to do a study of environment flow requirements of three sites along Ganga involving large number of experts. This is clearly an unwarranted conclusion since WWF was only doing it first time and has much less resources at its disposal than the government have. By arriving at this unjustified conclusion that has no basis, the IMG implies is that BBM methodology is required and is justified, but Indian rivers including the Ganga won’t get it since IMG (wrongly) thinks that “required conditions” are not satisfied. This is clearly wrong and unwarranted conclusion. The BBM can and must be applied in all cases immediately, including for all existing and under construction projects and cumulative impact assessments.
Also, while stating multiple times that BBM for three locations for Ganga took three years, the IMG does not go into the details of what caused this delay. One of the important reasons stated by WWF itself is that required data was not made available to them, which contributed to the delay. So it is the government itself that was part of the reason for the delay in WWF study, and now IMG uses that delay to suggest that BBM is not practicable for Ganga! If the Government has the will to implement a more holistic methodology like BBM, it can be done and IMG conclusion is unwarranted and wrong.
14. Unjustified pro hydro bias of the IMG The IMG has shown its pro hydro bias at several places. At one place it says that a balanced approach needs to be taken as “It is important to see that the flows do not result in exorbitant cost of power which the people of the region may not be able to afford. This would make these power projects uneconomic and un-implementable”. Firstly, as far as people in immediate neighbourhood of the projects are concerned, history of grid connected hydropower projects in India shows that local and particularly the affected people almost never get power benefits from projects but they surely suffer all the negative impacts. IMG is wrong as far as this section of the people is concerned.
Secondly as far as the people of Uttarakhand in general are concerned, where all the projects in Upper Ganga basin are situated, the state would get 12+1 % of free power. Since most of the projects are in central or private sectors, the rest of the electricity would mostly go outside the state. As far as this 13% free power is concerned, since it is supposed to be free, there will be no impact of e-flows on the tariff of such projects, except some marginal reduction in quantum of power.
Lastly, is it the bottom line of the IMG that projects must be economic and implemented at all costs, by hook or by crook, as is apparent from the above quoted sentence? How can that be the bottom line of IMG considering its TORs? Moreover, by making the projects economic and implementable by hook or by crook, the IMG seems to be saying that irrespective of the social, environmental, cultural, religious and even economic costs, the projects must go on. Thus what IMG is suggesting is that artificially low cost electricity must be produced for the cities and industries irrespective of any concerns of costs and impacts on people, environment, future generations and rivers including the national river! This is clearly a plea to export the water, livelihood and environment security of the people for the short term economic prosperity of far off city dwellers and industrialists. Is this acceptable?
15. What is environment flow? IMG should have provided a definition of what is meant by river and environment flow. Since it is linked with enabling the river to perform its various roles and services in the downstream area, it cannot be just limited to water flow downstream. The downstream river also needs silt and nutrition from the upstream and the biodiversity and geomorphology in the river crucially depends on such flows of nutrition and silt. However, IMG has said nothing on this count.
Dry River at Uttarkashi Photo: Open Magazine
16. Environment flows = aviraldhara? The IMG has said, “Environment flows in the river must lead to a continuous availability of water (aviraldhara) in the river for societal and religious needs.” This equation of aviral river with continuous flow of water is clearly flawed, since by that token even a pipeline has aviraldhara, but a pipeline is not the same as aviral River. For a river to be flowing aviral, continuous flow of water is a necessary but not a sufficient condition. A river means so much more.
17. No attempt at assessment of social, religious, cultural needs The IMG keeps talking about social, religious and cultural perspective and needs of the society from the river and so on. However, there has been no attempt to assess what exactly this means in terms of river flow, quality, content of flow across the time and space. More importantly, how is all this to be decided and who all are to be involved in the process. IMG just assumed that this has already been done by IITR and WII, which is flawed assumption, since WII or IIT-R has clearly not done any such assessment. So in stead of giving standard monthly flow release percentage across the rivers (releases to vary based on daily flow variations, this recommendation of daily changing flow is certainly an improvement from IMG), IMG should have asked for actual assessment of such needs across the rivers and IMG should also have given the process for arriving at such decisions. But while deciding social, religious or cultural needs, the IMG sees no role for the society, religious groups or cultural institutions.
In this context it may be added that the IMG has also not taken note of the legal stipulations like the order of the Allahabad High Court that says that no project can divert more than 50% of river flows existing at the point of diversion.
DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia
18. IMG recommendation during High Flow Season (May-Sept) The IMG has recommended 25% of daily uninterrupted (no clear definition is given how this will be arrived at) flow, with the stipulation that the total inflow in the river would not be less than 30% of the season flows. This is same as 30% of mean seasonal releases recommended by WII (para 8.3 of WII report, para 4.11 of IMG report) and also used by even Expert Appraisal Committee on River Valley Projects currently. The recommendation of releases based on daily flow is an improvement compared to the earlier situation, but its implementation is in serious doubt considering the weak compliance requirements from IMG.
It should be added here that IMG has not mentioned how the environment flow will be released. Just dropping it from the top of the dam won’t help, the flow must be allowed to flow downstream in an environmentally sound manner that is as close as possible to the flow of the river and helpful for the biodiversity in the river to link up from downstream to upstream and vice versa. Moreover, while deciding flows, IMG has largely followed the recommendations of the WII. However, WII conclusion of classifying Upper Ganga basin under EMC class C itself is flawed. IMG should have corrected this flaw, before concluding on environment flows.
19. IMG recommendation during Lean Flow season (Dec-March) The IMG has recommended (Para 3.48) release of 30% of daily uninterrupted river flows, this will go up to 50% where the average monthly river flows during lean season (Dec-March) is less than 10% of average monthly river inflows of the high flow season (May-Sept) and to 40% (however, Para 3.51 does not mention this 40% norm) where this ratio is 10-15%. While this is an improvement in the current regime, this remains weak considering that IMG has not done project wise calculations where 30, 40 and 50% stipulation is applicable, which it could have easily done at least for the existing and genuinely under construction projects.
20. IMG recommends lower flow for India’s national river compared to what India promises Pakistan in Jhelum basin The IMG has recommended 30-50% winter flows for all projects as described above. This in case of a river everyone recognizes as the heart and soul of India, a river that has such an important social, religious, spiritual significance and it has been declared as the national river. Let us compare this with what e-flows Indian government has promised to Pakistan downstream of the Kishanganga Project in Jhelum river basin in Kashmir. In a case before the Permanent (International) Court of Arbitration (PCA), Indian government has assured that India will release more than 100% of the observed minimum flow from the dam all round the year, and now in fact the government is considering even higher than 100% of the observed minimum flow all round the year. The PCA is yet to decide if what India has proposed will be sufficient or more water flow is required. So, as against the assurance of more than 100% of minimum flow at all times on another river, for the river flowing into another country; for the national river Ganga, for India’s own people and environment, all that the IMG recommends is 30-50%. On most winter days, KishengangaRiver downstream of the hydropower project, flowing into Pakistan, thus will have higher proportion of its daily flows than what Bhagirathi or Alaknanda will have.
Dry Ganga at Haridwar in August 2012 Photo: SANDRP
21. Monitoring and compliance of Environment Flows The IMG has said that effective implementation is cardinal part of its recommendations. This is good intention. However, by asking the power developer to be responsible for the implementation, the IMG has made the recommendations ineffective. IMG has chosen to ignore the fact that there is clear conflict of interest for the power developer in assuring e-flows, since the e-flows would reduce the power generation and profits of the developer. Its faith in IT based monitoring is also completely untested and there is no evidence to show that such monitoring will be free of manipulation. Secondly, to ask the MoEF to do annual review, that too only for first five years ignores the track record of MoEF in such matters where MoEF has shown no will, capacity or interest in achieving post-clearance compliance of the environment laws of the country. Thirdly, to require this only for projects above 25 MW shows the lack of understanding of IMG as to how important the smaller streams are for the water, ecology and livelihood security of the community in hills. Its recommendation of monitoring by an independent group is welcome, but lacks credibility in the absence of sufficient involvement of local community groups in such a mechanism.
22. Baseless assumption of low water requirement for fish in the Himalayan region The IMG has assumed that in the Himalayan region, the water requirement for fish in the river is less and hence the rivers here will not require as much water as the rivers do in the plains. This is completely unscientific, flawed and baseless assumption. The amount of e-flows needed has to be assessed not only based on the requirement of fish (IMG has not done even that assessment), but entire aquatic and connected terrestrial biodiversity across the seasons, in addition to the water needs of a river for providing the social and environmental services.
23. Suggestions that are bad in Law The IMG report shows several projects as “Under Construction” (Annex VI B) category, when they do not even have statutory clearances and hence cannot even legally start the work. This is a ploy to make these projects a fait accomplice when these projects are perfectly amenable to review and rejection since the project work has not started. In fact to categorise such projects without having all the statutory clearances (e.g. Vishnugad Pipalkoti does not have forest clearance) as under construction project is plain illegal.
24. Wrong representations The IMG has shown several projects in Annex VI C, as “Hydropower projects with EC/FC Clearances and others”, basically a ploy to push the projects that do not even have all the statutory clearances. None of these projects have all the statutory clearances and are certainly not in position to start construction and hence these projects are the ones where dropping of the projects or modifications in dam location, dam height, FRL, HRT length, e-flows, capacities etc are still possible. But IMG did not do it for any of the projects. As mentioned above, four of these projects have been recommended by WII to be dropped, and IMG should have recommended dropping these or should have categorized them as ‘to be reviewed’.
25. No mention of impact of peaking operation of hydropower projects The IMG has missed many crucial environmental impacts. One crucial one that it has missed is the issue of peaking operation of hydropower projects on the downstream people, environment, flood plains, geo morphology, biodiversity and other aspects of the river. This is very important since one of the Unique Selling Proposition (USP) of hydropower projects is supposed to be that they can provide peaking power. However, peaking operation means sudden changes of huge magnitude of flows in downstream river, having far reaching impacts including those on safety of people, flood plain cultivation, impacts on cattle and property, impact on ecology, amongst many others. The IMG has completely missed this, which is very strange since this is a huge issue being taken up by people and campaigns in the North East against large hydropower projects there.
26. IMG cannot see through poor work of IIT-R It is well known that IIT-R report on Ganga basin study is of poor quality. In the IMG report there is an attempt to respond to only a couple of the criticism of IIT-R report, but IMG could not even see through the wrong facts presented by IIT-R report. For example, IMG report says, “The requirement of flushing during monsoon is not required in both rivers as all hydro projects except Tehri reservoir are run of river types where silt is not stored.” This is completely wrong. All the projects, even if run of the river, have storage behind the dam where the coarser silt will settle down and will need to be flushed out periodically. The dams are being provided with bottom sluices to facilitate this. A quick perusal of the EIA reports of some of the hydropower projects in the region shows that Vishnugad Pipalkoti, Srinagar, Kotli Bhel 1-A, Kotli Bheal 1-B, to name only a few all have proposed to provide bottom sluices for periodic release of silt accumulated behind the dam. Thus the contention that most projects do not need flushing is wrong. In any case, for all projects, the de-silting chambers would be releasing silt laden water and there is no attempt to assess the cumulative impacts of such actions. IMG’s attempt to provide scope for some defense for the IIT-R has clearly back fired on IMG! Moreover, even in case of Tehri, the biggest project in the region under review, IMG report has nothing at all, about it social, environmental impacts and performance, about its power generation, irrigation, water supply, flood control performance or even its silt management performance.
The contention that all projects except Tehri are ROR is entirely wrong and misleading. Even as per the WII report, out of the 69 projects, a whopping 13 projects are storage projects. This includes the biggest and most problematic projects like Srinagar, KotliBhel IB, KotlibhelIA, Koteshwar, Vishnugad Pipalkoti, Devsari, etc.
27. IMG on Srinagar HEP and Dharidevi Temple The IMG was also asked to “review the impacts of the Alaknanda (GVK) Hydro Power Project on flow of the River and the issues related to the temple relocation.” The IMG gave an interim report on this issue, which was so disappointing that Rajendra Singh and Late Shri Veer Bhadra Mishra both members of the IMG, gave a dissenting note, Rajendra Singh also suggested shelving the project. The IMG rejected the suggestion of its own members without giving any justifiable reasons.
DhariDevi Temple threatened by submergence
28. Time bound action plan for E-flows from existing projects The IMG says that the existing projects should also follow the suggested e-flows and this should be achieved in three years (Para 3.52). However, IMG should have been more clear about the role of different agencies (MoEF, state government, developers, state electricity regulatory commissions and power purchases) and what is the legal backing such a step will have.
29. Lack of understanding of conflicting projects and public protests The IMG report, Annex VI B shows 12.5 MW Jhalakoti (wrongly) as under construction project. In fact the Jhalakoti project has been recommended by WII to be dropped. The IMG seems to have no clue that Jhalakoti project is being strongly opposed by the local communities and no work has started on the project. The under construction status given by IMG for this project is clearly wrong. If the Jhalakoti HEP comes up then the existing 40 KW Agunda micro HEP will no longer be able to function. Many of the other projects including the Devsari and Vishnugad Pipalkoti HEP are also facing strong opposition, but the IMG has not taken note of these or any of the social impacts of the projects in the Upper Ganga basin.
Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan
30. IMG onTOR on pollution abatement in Ganga It is good to see that IMG has suggested that “all users must be forced to plan for water needs based on what the river can spare, not what they can snatch.” However this should not mean an advocacy for more big dams and storages on the rivers. This seems to be the case when we read the IMG recommendation that says, “The government then has a choice to build storages to collect monsoon water for dilution within its territory or to ‘release’ water to rivers and make other choices for use in agriculture, drinking or industry”. Storages can come in many forms and sizes and IMG should be careful not to recommend more big storages on the rivers. The suggestion that “there will be a clear conditionality in Central government funding, which is matched to the quantum of ecological flow released by the state in the river” is welcome. Linking of JNNURM-II and National Mission for Clean Ganga to the above norm, incentivisation of use of innovative bioremediation and in-situ drain treatment are also welcome. However, IMG has shown no interest in understanding or tackling the real problem in river pollution: Lack of participatory, democratic governance in urban water and pollution control regime.
IMG has recommended in Para 6.7(i), “Ecological flow will be mandatory in all stretches of the river.” This is welcome. IMG goes on to suggest some norm for the urbanized stretches of rivers, but no norms are suggested for the non urbanized stretches of river in the lower river basin.
31. Report does not reflect the discussions in IMG? The dissent note by Shri Rajendra Singh, a member of IMG says that on several aspects, IMG report does not reflect what transpired in the IMG meetings. This is a very serious charge that puts a big question mark on the IMG report and its recommendations, particularly since Rajendra Singh is the lone independent voice in the IMG after the sad demise of Shri Veer Bhadra Mishra[3].
32. Incomplete project list The IMG does not seem to have full information about the existing, under construction and planned hydropower projects in the Upper Ganga basin in Uttarakhand. Some of the projects not listed in the IMG report include:
A. Operating projects under 1 MW: According to the website of UJVNL (Uttarakhand Jal Vidhyut Nigam), the state has 12 such projects with total capacity of 5.45 MW, see for details: http://www.uttarakhandjalvidyut.com/cms_ujvnl/under_operation1.php. Most of these projects are in Upper Ganga basin, though it is not clear how many.
B. UJVNL has larger list of schemes under development by UJVNL including in the Upper Ganga basin, not all of them are included in the IMG list, see: http://uttarakhandjalvidyut.com/bd2.pdf.
D. There is another “full list” of hydropower under development in Uttarakhand including sub-MW size projects, see: http://uttarakhandjalvidyut.com/bd5.pdf. Some of the projects here in Upper Ganga basin do not figure on IMG list.
One would expect better information base of the IMG than what they have shown.
33. No specific recommendation to save the prayags There are five holy prayags (confluence of rivers) along Alaknanda river in Uttarkhand, including Deoprayag, Vishnuprayag, Karnaprayag, Rudraprayag and Nandprayag.
Vishnuprayag has already been destroyed by the 400 MW existing Vinshnuprayag HEP of Jaiprakash Associates, rest would be destroyed by the projects listed by IMG. The IMG keeps talking about cultural importance of the rivers, but has not said a word about how it plans to save these culturally important confluences and how it plans to rejuvenate the Vishnuprayag already destroyed.
34. “Alternative View” in Annexure 21: How much of an alternative is it? In Annexure XI of IMG report, a note authored by one of the IMG members, Sunita Narian of Centre for Science is given, it is titled: “TOR (ii): Alternative View: Environment flow”. The Annexure opens with the line “The recommendations of this IMG report are not acceptable.” It is not clear if this sentence applies to all the recommendations of the IMG or about environment flows mentioned in the title or it applies to TOR (ii) that applies to all environmental aspects, not just environmental flows. The Annexure also deals with some issues besides environment flows, so one assumes this “alternative view” is about environmental aspects of hydropower projects.
The Annexure XI seems to give an impression that, principles of distance between dams, ecological flow and limit on % of river than can be “affected” will lead to “sound hydropower development, balanced for energy and environment”.
One of the three principles listed in the note says: “Distance between projects: 3-5 km”. The note does not say how this distance has been arrived at or how this distance is to be measured, the least the note should have mentioned was that this is not distance between projects but distances of flowing river between the Tailwater level of upstream and full reservoir level of downstream project. No elaboration is given about this criterion at all. Most importantly, there is not even any attempt to apply this criterion to the projects that IMG is supposed to look into. On the contrary, the note says that “The projects under construction can be built” (point 7(ii)) and “projects with EC and FC clearances can be taken up for construction” (point 7(v)). So in fact there is absolutely no application of the criterion to the projects on hand. The conclusion that this is half baked and non serious criterion is inescapable.
Another of the three principles listed in Annexure XI is: “Maximum intervention allowed in river length: 50-60 per cent”. Again there is no elaboration as to how these figures are arrived at, why there is a range, what is meant by “intervention”, which lengths it will apply and so on. Again, the note does not bother to apply this criterion to the rivers under review and actually says in point 7(ii) and 7(v) described above, that projects in Annexure VI (B) and VI(C) can go ahead without even checking if in that case this criterion will be violated or not. Again the conclusion that this is also a half baked and non serious criterion is inescapable.
The whole of the Annexure XI is basically devoted to application of the third principle: “Ecological flow regime: 30/50 per cent (high and lean period)”. About this, the annexure says: “The engineering design of the uninterrupted flow would take into account the need for sediment and fish transfer”, not clear how this will be achieved. The Annexure does not suggest any new measure of achieving compliance with its recommendations. The note mentions “design changes incorporated to maximize energy generation during high discharge season” but does not elaborate what these would mean.
Annexure XI says that IIT-R tried to suggest that e-flows must be low and in this effort did “big and large manipulation of data”. This is good. However, it would have been better if the full data and notes from IIT-R were annexed here to illustrate how the manipulation was done.
Bullet point 3 in Annexure XI reads, “It is important to consider that water of a river is similar to the coal or gas as raw materials used in thermal plants”. This statement needed to be qualified that the impact of taking out coal or gas from its source is not comparable to taking out water from the river, the latter’s impact is much more severe, since river is not equal to just water flowing in it.
Since Annexure XI does not raise objection to any other conclusions and recommendations of the IMG except the three principles mentioned above, it would not be incorrect to assume that author agrees to the rest of the IMG report. This, when taken together with the fact that at least two of the three principles in the alternative view note have not been applied to the projects under review, leads to the conclusion that there is not much of an alternative in “alternative view” note and this won’t help the cause of the river, people, environment or even sustainable and sound development.
35. Conclusion A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. One of the positive aspect of this report is that possibly for the first time heads of central organizations like CWC and CEA have sat with some non government members to discuss some important subjects that have remained contentious for these official agencies.
However, as noted above, on most positive aspects, while IMG has been less than sincere, there is a huge potential to take the environment flow movement forward.
The MoEF and NGBRA should, considering all the above points, take some positive aspects forward. Some of the positive retrievable aspects of the IMG report include the following, on each of which there is a lot of scope for serious action:
Ensuring at least 50% E-flows in non monsoon months in all rivers.
Keeping some rivers in pristine form, stopping all ongoing and planned projects on suggested rivers and time bound decommissioning of existing projects on such rivers that are to be in pristine form. This should be immediately implemented on the rivers recommended by IMG and also in other selected rivers in all river basins.
Rejecting planned and under construction projects which have high impact on terrestrial and aquatic biodiversity, as per score developed by WII Report as well as projects which irreversibly impact spiritual and religious places like rivers, prayags, places of worship and ghats.
Give deadline of one year and maximum of two years for all the existing dams, diversions and hydropower projects across the Ganga basin (& other rivers) to achieve the suggested e-flows with clear inbuilt mechanisms for monitoring and compliance with participation of river basin communities, as a first step.
Accepting BBM as the standard methodology for E-flows assessment, e-flows to mimic the river flows and involving communities as an important stakeholder in this methodology.
Ensuring Aviraldhara.
Ensuring rivers have adequate free flow time between projects to regenerate itself. Mandating at least 5 km free flowing river between any two projects as an immediate measure pending site specific studies and reviewing all under construction, under clearance and under development projects in the basin keeping this in mind.
Releases based on daily flows rather than monthly or seasonal averages in all rivers. Define uninterrupted flows to arrive at uninterrupted daily flows.
Monitoring of e-flows and other environmental compliance by independent group involving at least 50% of the monitoring group from local communities.
Assuring that e-flows through well designed fish passages (taking consideration of Guideline 7, Annex IX).
The IMG has recommended that a technical group may be made to study alternatives including the alternative suggested by Prof Bharat Jhunjhunwala that only partial dams across rivers may be allowed. This should happen expeditiously. The proposed projects should be stopped till this is done.
[3] One of the members of the IMG started discussing the report in public domain through her writings even before the report was in public domain, see: http://www.downtoearth.org.in/content/training-engineers-not-ganga and http://www.downtoearth.org.in/content/ganga-saga-part-ii-redesign-dams-not-rivers. This can create misleading impression about the report, when the readers do not have benefit of cross checking what the report is actually saying. The articles in any case are full of serious errors, for example it said: “Most of the proposed projects are run-of-the-river schemes, which are seemingly benevolent as compared to large dams”, not understanding that EACH of the so called run of the river schemes ALSO involves a dam, most of them are large dams as per international definition. It incorrectly said, “Run-of-the-river projects, which used flowing water as the raw material for energy”, in reality NONE of the so-called ROR projects generate power from flow of the water in the river, they all dam and divert the water away from the river to produce power. It also tried to dilute the impact of the projects on rivers (akin to killing of rivers) by saying projects “affect” rivers. It misleadingly wrote, “The hydropower engineers argued for 10 per cent e-flow” without mentioning that the EAC of MoEF is prescribing 20-30% of mean season flows. The article claimed that figures of water flow and tariffs were modified by IIT-Roorkee, but in the entire IMG report, (except the Annexure XI written by author of the articles), there is no mention of any of these. The article talks about engineers’ claims that “this source provides power during peak demand hours”, but as we noted above the IMG has not even looked at the impact of peaking generation. There is not even an attempt to understand how much of the current generation from hydropower projects is happening during peaking hours, or what is the generation performance of hydropower projects, issues that SANDRP has been raising for many years.
2 Irrigation Projects from Buldhana: Ar Kacheri Irrigation Project and Alegaon IrrigationProject, Vidarbha Irrigation Development Corporation (VIDC), were discussed for granting Terms of Reference (TORs). However, on the ground, both the projects have started work without an Environmental Clearance and this work was stopped only after strong local protests and even litigation. This was pointed out by the EAC and admitted by Vidarbha Irrigation Development Corporation. Together, both projects are set to submerge 436 hectares of forest and irrigated, cultivated land. Although 80% of the land under submergence is cultivated and irrigated by ground water, the Pre-feasibility reports (PFR) of the projects say that they will not cause submergence or affect population. EAC has pointed out this discrepancy too.
Alewadi project is just 1.75km from the core boundary of Melghat Tiger Reserve while Ar-Kacheri is 4.75km from the same. The projects have also received Stop Work order from the Forest Department in 2012.
Wan Wildlife Sanctuary from where Ar Nallah originates. Photo: Wikimedia
Despite all these serious issues, the project proponent chose to hide these facts from the EAC. SANDRP had sent a submission to the EAC prior to the meeting, highlighting many issues and saying: “Considering the violations by both the project developers of EIA notification 2006 by starting work without the required clearances, the EAC should first recommend an enquiry into these violations and ask the responsible officials to be held accountable before even considering any clearance.”
The EAC has observed that both the projects have indulged in violations. According to the EAC: “Such cases are to be dealt in terms with the MoEF OM No. J-11013/41/2006-IA.II (I) dated 12.12.2012. Accordingly, the project proponent is required to submit an affidavit with an undertaking not to execute works without obtaining environmental clearance and furnish photographs of the site from all four sides of the project.” The OM also states for such violations, the State Government will have to take necessary legal action against the violations as per the Environment Protection Act. In case of serious violations, the MoEF reserves the right to reject projects all together.
Even as the White Paper on Irrigation Projects points fingers at Green Clearances as one of the reasons for time and cost overruns of irrigations projects in Maharashtra, the functioning of Water Resource Department itself has been responsible for these delays and irregularities. Without an Environmental Clearance, work on the project cannot start as per the EIA Notification 2006 and EPA 1986.
However, all Irrigation Development Corporations in Maharashtra have been breaking this law with impunity many times over. This was observed in case of Konkan Irrigation Development Corporation for several projects, Maharashtra Krishna Valley Development Corporation for numerous lift Irrigation schemes on Ujani and Vidarbha Development Corporation, for Lower Painganga Project.
With this decision, there is hope that VIDC and other IDCs in Maharashtra become less callous about issues relating to environment and affected communities.
Through an unfortunate and short sighted decision, the Forest Advisory Committee of the Ministry of Environment and Forests has gone back on its decision of rejecting Forest Clearance to Kalu Dam that it took on 2nd April 2012. It reconsidered the project and in its last meeting on 3rd-4th April 2013, and has actually recommended the Kalu Dam project for FC, involving 1000 hecatres of Forests in the Western Ghats. It has done this when all the illegalities and irregularities from the proponent still stand today, entirely unaddressed.
We have sent a submission condemning this decision on behalf of Shramik Mukti Sangathana as well as villagers to be affected by Kalu Dam to the Forest Advisory Committee and Minister of Env and Forests Ms. Jayanthi Natarajan. (see below)
You can support the communities and Forests in Kalu by sending similar letters to MoEF Minister and Forest Advisory Commitee.
Illegal Work on Kalu Dam Site by FA Constructions Photo: SANDRP, May 2011
To,
Ms. Jayanthi Natarajan,
Minister of State (IC) for Environment and Forests,
Ministry of Environment and Forests, New Delhi
Subject: Request not to grant Forest Clearance to Kalu Dam in Maharashtra due to several procedural and legal irregularities on the part of the Project Proponent and also the Forest Advisory Committee.
Respected Madame Minister,
This is to express our utter shock and dismay at FAC’s decision of recommending Forest Clearance to Kalu Dam falling in Western Ghats area in Murbad, Thane District, Maharashtra as seen in the minutes of the FAC meeting of April 3-4, 2013.
Just one year ago on the 2nd of April 2012, the Forest Advisory Committee had rejected this proposal, raising substantial points against the proposal and closed the file. This was a respite for the communities facing displacement, community groups working on the issue, for the Western Ghats ecology and the forests. We had then thanked FAC for this decision of April 2012.
On 4th of April 2013, the same Forest Advisory Committee (now with a changed constitution) went back on its decision and recommended Forest Clearance (FC) to Kalu Dam even when nothing has changed on ground and all of the objections based on which FC was rejected in the first place still stand today. The Project Proponent (PP): KIDC, Maharashtra Water Resource Department, has not been able to respond in credible way to any of the points raised by the FAC, Chief Conservator of Forests (Central), State Forest Department, affected villagers or civil society organisations.
We strongly condemn this decision by the FAC of recommending Forest Clearance for diverting nearly 1000 hectares of Forests in the Western Ghats.We urge you (i) not to recommend FC for Kalu Dam; (ii) request you to take steps to make Forest Advisory Committee more transparent, responsive and accountable to issues of communities and forests; specifically, all the documents from the project proponent, including all the annexures of the Form A and gram sabha resolutions for the projects on FAC agenda must be on FAC website at least ten days in advance as per CIC orders and as also assured by you in public; (iii) We also urge you to direct action against those responsible for illegal construction of the Kalu dam as noted by the FAC minutes; (iv) urge you ask FAC to hence forth recommend strict action against such violations.
Major issues about recommending FC to Kalu Dam:
Non-transparent decision making in violation of CIC Orders: None of the documents submitted by the project proponent about the Kalu Project were available in full with all the annexures on the MoEF website even a week before FAC meeting on the 3rd and 4th of April. This is a blatant violation of the CIC orders and we had pointed this out to the FAC through our letter dated March 25, 2013, but the FAC chose to ignore this. As a Minister, you had taken a strong stand against this and had said in October 2012 “These actions and decisions of the officials are unacceptable to me. The forthcoming meeting of the FAC will be postponed, and I shall resolve these (violation of CIC orders and non-compliance of FRA) issues.”[1]
Considering that the lives and livelihoods of about 18000 people will be affected by this project, and when they have the first and foremost right to have all the information on decision making around this project, such irresponsibility on the part of FAC is unacceptable and it is also bad in law. Petition against Kalu Dam is in the High Court of Bombay currently and this point will be raised there.
Complete reliance on Project Proponent’s (PP) claims While recommending FC, the FAC has relied entirely on claims of the proponent, without checking the veracity of the claims or applying its mind. FAC has not even mentioned the numerous submissions made by communities and community-based organisations raising pertinent points against PP’s claims. The FAC needed to keep in mind that the same proponent has gone against its word many times earlier and each time, it has been pointed out to the FAC. It has wilfully violated the Forest Act by starting construction of the project in the absence of FC when the project is to submerge nearly 1000 hectares of land in a biodiversity hotspot, it has gone against its written word when it said that ‘no new project will be required for Mumbai until 2031”, in the process of seeking Stage I Forest Clearance for Shai Project, barely 20 kilometres from Kalu Project.
But the FAC, instead of taking any strict action against the proponent in this regard, has simply accepted its claims, which are again misleading and false.
Grounds for rejection of Kalu Project in 2nd April 2012 by FAC: The FAC minutes state:
· Submergence of 18 villages and their connectivity,
· Initiation of construction without Forest Clearance,
· Breach of commitment given by the Project Proponent during Stage I clearance of Shai Dam,
· Location of the dam within 7 kms of Protected Area
· Location of the project in eco sensitive Western Ghats
· Non-furnishing of: Rehabilitation Plan, Environment Impact Assessment report, Technical Report on Wildlife Status, Gram Sabha resolutions about compliance of Forest Rights Act
NONE of the issues stated above are resolved through the PP’s responses as clarified below:
· No Gram Sabha Resolutions Passed supporting the project: Misleading the Forest Advisory Committee: PP has claimed that it has secured Gram Sabha Resolutions from 8 villages out of the 11 villages that will be fully or partially submerged by the dam. In fact, Shramik Mukti Sangathana has letters from 10 Gram Panchayats out of these 11 that they have not issued any such resolutions at any stage. The last resolution in this regard that they passed was AGAINST the project. These were sent to the FAC on 16.11.11.
If the Project Proponent has the resolutions as claimed, why have they not put these up on the FAC website with the necessary documentation from the PP?
Why did the FAC not see the need to ascertain this even when it was pointed out by us in our letter dated 29.10.12 and again in 25.03.13 that no such resolutions exist?
· Clear violation of the Forest Conservation Act (1980): The proponent accepts that it violated the Forest Conservation Act (1980) by starting work before an FC, but states that it stopped AFTER High Court Orders. High Court Orders were in response of a PIL filed by Shramik Mukti Sangathana against the illegal nature of the work. So, stopping AFTER HC orders is no justification for committing the illegality. Before the High Court orders, Shramik Mukti Sangathana had written several letters about this violation to the Collector, Chief Secretary and Forest Department and had also served a notice to the PP. It did not stop work then.
Considering this, the Forest Advisory Committee ought to have penalised the project proponent for violation of Forest Conservation Act (1980), not recommend the same project for clearance.This only gives out a signal that no action will be taken by the MoEF even after it knows that violation of Forest Act is happening, that too by a state agency.
· Continued violation of the Forest Rights Act (2006) It has been pointed out several times to the FAC that Kalu Project is violating the Forest Rights Act (2006) as community and individual claims are yet to be settled. The Forest Rights Act was passed to safeguard historical injustice on Forest-dependent communities, but the FAC itself is encouraging the PP to violate FRA, PESA, Rehabilitation Policy and Forest Conservation Act. You, as a Minister, had reasserted MoEF’s commitment to implementation of Forest Rights Act.
· No Rehabilitation Plan has been submitted at the time of recommending Forest Clearance There is no such plan available in public domain, nor has there been any participatory process of approval of the plan with the affected people. A claim of a rehabilitation package of Rs 68.75 Crore does not constitute a Rehabilitation Plan. This point was raised several times by community organisations, State Forest Department, Chief Conservator of Forests as well as the FAC. Villages to be affected by Kalu Dam fall in Tribal Subplan and attract PESA. Without any legally mandatory process, just the claim of rehabilitation package of Rs 68.75 crore seems good enough for FAC. It was clearly wrong on the part of the FAC to recommend FC based on such claims.
· Konkan Irrigation Development Corporations letter that “it is not necessary to construct any new water source till 2031”: This was submitted to the MoEF while seeking Stage I Forest Clearance for Shai Dam, less than 25 kms from proposed Kalu dam in 2010-11. FAC recommended Stage I Clearance to Shai Dam based on that assurance. In less than 3 years, the proponent feels that Shai dam, whose clearance was obtained on such a claim, will not be sufficient till 2031. This is unjustifiable and tantamount to misleading the FAC with false assurances.
· No Environment Impact Assessment (EIA) Conducted The Kalu Dam falls in ecologically sensitive Western Ghats. The Western Ghats Expert Ecology Panel had categorised the region in ESZ I where no large dams should be permitted. Even as per the Kasturirangan Committee Report, more than 5 villages affected by Kalu Dam are falling in the ESA.
The State forest Department, Chief Conservator of Forests (Central), community groups have all urged that EIA as well as a Cumulative Impact Assessment of the Project has to be done before granting Forest Clearance. In fact, this was one of the conditions laid by the State Forest Department. Looking at the ecologically sensitive location of Kalu Dam and submergence of nearly 1000 hectares of Western Ghats Forest Land, this was a reasonable expectation.
Despite these clear conditions, the PP argues that EIA is not required. And despite this, the FAC recommends FC to this project!
In this context, Section 2.3 (ii) of FCA (1980) read, “Notwithstanding the above, if in the opinion of the Ministry or the Advisory Committee, any proposal should be examined from the environmental angle, it may be required that the project proponent refer the case to the Environment Wing of the MOEF.” So irrespective of the requirement of EIA notification, the FAC has been provided powers to refer to an such project to the environment wing of MoEF or EAC for examination of the project from the environment angle, but FAC failed to do this just under the claim of the PP that EIA is not required under EIA notification.
FAC recommendation that Cumulative Impact Assessment has to be undertaken for drinking water projects around Mumbai is welcome but again, it could have been done before considering this project for clearance and not after recommending clearance. Similarly their recommendation to the MoEF to amend the EIA notification to ensure that such dams are included for environmental impact assessment is welcome, but they could have waited for MEF response rather than recommending Forest Clearance.
In this regard we urge you: (i) immediately change the EIA notification to include Kalu and all such large dams under the ambit of the EIA notification, irrespective of the purpose of the project; (ii) Direct specifically that Kalu Dam require EIA and Env clearance, using the above mentioned part of the Forest Conservation Act, 1980 and EPA, 1986; (iii) Order a cumulative impact assessment of all the projects in the western ghats region around Kalu dam, as recommended by FAC and (iv) direct that FC for Kalu will NOT be considered till all these requirements are fulfilled.
· Forest Conservation Act requires Gram Sabha clearance Moreover, section 2.1(vii)(4) of the Forest Conservation Act, 1980 clearly states: “Therefore, whenever any proposal for diversion of forest land is submitted, it should be accompanied by a resolution of the ‘Aam Sabha’ of Gram Panchayat/Local Body of the area endorsing the proposal that the project is in the interest of people living in and around the proposed forest land except in cases wherever consent of the local people in one form or another has been obtained by the State or the project proponents and the same is indicated in the proposal explicitly. However, it would be required where the project activity on forest land is affecting quality of life of the people residing in nearby areas of the site of diversion; like mining projects, displacement of people in submergence area, etc.” This provision is particularly applicable to a project like Kalu that has not had EIA or public hearing as stated in the same section in FCA, 1980. Recommending FC for Kalu Dam project without fulfilling this requirement is clearly a violation of the FCA, 1980 by the FAC.
We urge you to direct the project proponent to get gram sabha resolutions on the lines mentioned above in FCA Section 2.1(vii)(4) and direct FAC consider the project only after these have been received.
· Distance from Protected Area: The submergence of the project is less than 10 kms from Kalsubai Sanctuary. Considering the fact that no EIA is conducted, no report on Wildlife Status exists, this makes ecological impacts of Kalu Dam on Western Ghats ecosystem even more serious. Considering all these issues, FC should have been rejected on this ground alone. In fact the PP goes ahead to say: “No rare or endangered flora or fauna has been reported from this site” How can this be stated when no EIA has been conducted and no wildlife report exists?
· The PP states that only “44566” and “44611” that is ‘only’ 89177 tress will be felled during and the rest ‘may be’ saved. Ninety thousand trees in Western Ghats is a huge number. But it seems FAC does not see any objection in this. The claim that the rest of the 60 000 trees can be saved is of doubtful credibility. Similarly the claim in the FAC meeting minutes that “No rare or endangered species of flora and fauna has been reported in the area” is also without any credible basis.
· We would like to reiterate that no options assessment about water supply options to Mumbai has been done. No consideration of rainwater harvesting, using saline water for some uses, grey water recycling, demand management, water use efficiency, and conjunctive groundwater use has been done. The FAC minutes notes this, but from the minutes it seems it has not applied its mind to these issues and recommended FC as a matter of blind support for the project. The mention of the letter from the Chief Minister in the minutes only adds to the suspicion that the FAC has cleared the project without looking into merits of the issue.
· Contradictions in FAC conditions? The FAC has recommended FC to the project, with some additional conditions, one of the additional conditions states: “The User agency will abide by all conditions by Regional Office, Bhopal and State Government during inspection of the project.” So the PP has to adhere to all the conditions imposed by the Regional Office, Bhopal and the State forest Department while inspecting the project.
One of the conditions imposed by the Regional office, Bhopal included: “…the State Govt. may be directed to stop all the construction related activities till all the legal formalities and forest, wildlife and environment related studies are completed and a well-considered decision regarding forest diversion is taken based on proper scientific documentation and studies.”
We seem to be in a funny situation now. The FAC, while recommending FC, put a condition that says that decision of FC should not be taken without “proper scientific documentation and studies”, but FAC has done just that! In any case, one implication of this is that the project should not get even first stage FC without the studies recommended by Regional Office, Bhopal, including EIA has been done.
Similarly the State forest department too has asked for (i) Rehabilitation Plan (ii) EIA (iii) technical report from WII on impact of project on wildlife in and around the project area (iv) gram sabha resolutions from all affected villages under FRA. The project should not thus be given even stage I clearance without satisfaction of all these conditions.
Most of these issues have been brought to the attention of the FAC time and again by us, Shramik Mukti Sangathana and other community groups. However, the FAC still went ahead with the incomprehensible decision. Hence, we are writing to you with the hope that after looking at all the points raised above, you will definitely not recommended Forest Clearance to Kalu Dam. We also hope that MoEF will punish violators of FC and FRA Acts to send a strong signal and will take steps to make the present Forest Advisory Committee more transparent, accountable and responsive to issues ailing our forests and forest-dependent communities.
We will look forward to detailed response on this from you. Thanking you for your attention,
The MoEF is seeking comments on “Report of the Committee to formulate objective parameters for identification of inviolate forest areas”. 23rd Feb is the last day! The comments are to be sent to secy-moef@nic.inwith subject line “Comments on “Report o the Committee to formulate objective parameters for identification of inviolate forest areas”” as per announcement on MoEF website.The report of the committee can be found at: http://moef.nic.in/assets/Report_on_Inviolate_Forest_area.pdf
Looking at the highly unacceptable nature of the report as it now stands, SANDRP (and its partners) have sent the following letter to the MoEF. We urge as many people to send in comments on this report.
Subject: “Comments on “Report o the Committee to formulate objective parameters for identification of inviolate forest areas”: Faulty and exclusionary process to determine criteria for the declaration of inviolate forest areas with respect to coal mining
Dear Ms. Natarajan and Dr Rajagopalan,
We the undersigned would like to put forward our strong objection to the process followed by the MoEF in the drafting of the above mentioned criteria (Report of the Committee to Formulate Objective Parameters for Identification of Inviolate Forest Areas, July 2012) and the short-sighted nature of the approach to identify which forests of India are to be exposed to exploitation by coal mining. Here we would like to point out that the GOM that asked for the expert committee report on this issue was the GOM for environment and development issues in general and if the specific areas need protected since they are inviolate, they should also be inviolate for all purposes and projects?
This process should be open to public input and engagement, and highlighting that any criteria must take into account the multifaceted nature of human-forest interactions in the country and the millions of livelihoods that depend on the country’s forests, aside from issues of forest cover, forest types, biodiversity, wildlife and endangered species and areas, intact landscapes and hydrological value. Some key missing issues include livelihood issues, cultural issues and interlinking issues with other areas. Another set of parameters missing are: seismically active, flood prone, erosion prone, coastal and such other vulnerable areas. Areas where tribals are in majority should also be excluded without free, prior and informed consent of all the gram sabhas in the region. It is amazing that the social and democratic governance issues get no place in the parameters.
The grids are not being assigned values of eco sensitivity as per the Pronab Sen Committee report or as per the methodology followed by the WGEEP for the Western Ghats.
Issue of carrying capacity and cumulative impact assessments and linkages across the areas are key issues.
The MoEF has kept this process secretive and opaque. By keeping this process behind closed doors and only at internet level in English language, the MoEF has made this process to determine “forest trade-offs” extremely exclusive, expert-driven and narrow in scope. This is contrary our constitution’s stated objectives of upholding democracy and promoting inclusive growth. The fact that this report was finalised in July 2012 and yet only uploaded in the public domain on January 24, 2013, with a period of less than one month for comments, is unacceptable and indicative of the opaque manner in which this critical issue has been approached.
Our overarching and firm objection is that the MoEF has adopted a non-participatory and undemocratic approach of arriving at these parameters, preferring to work behind closed doors. Our first demand therefore is that these parameters be opened up for extensive public debate, scrutiny and contribution, in such a manner as to hear from those people and organisations that stand to be most affected. This process, of course, cannot be accomplished in less than a month, so we are asking that a new process to achieve the same be announced. Some essential parameters of the process include: translation of the report in local languages, facilitation to ensure that it reaches the communities concerned and affected and a credible independent and transparent process for getting inputs, the process should also be transparent to show how the inputs were used.
Without prejudice to the above, we would also like to raise strong substantive concerns related to the parameters that have been suggested, which go beyond the issues of process stated above. While the suggested criteria appear to recognise the importance of forests for their biological, landscape, hydrological, wildlife and forest cover and forest type values, they are completely silent on the issue of the livelihoods of forest-dependent communities, their cultural issues and also the inter-linkage issues. As you are no doubt aware, India’s forests are a critical survival resource of millions of Indians. These livelihoods are invariably severely compromised, if not destroyed entirely, by mining, dams and other activities that destroy the forests.
Such a contradictory approach to India’s forests devoid of their socio-economic context is disconcerting and is also illegal in the context of forest rights act, PESA, Scheduled areas act and Panchayat Raj act. For a country which has a large part of its population dependent directly or indirectly on forests, the future of these same forests cannot be determined solely through the parameters listed in the report.
The proposed system of weights/scoring is also faulty and arbitrary. The system of averaging the score rigs the process such that a high score on any one parameter (for example, areas notified as Conservation Reserves) is not sufficient to protect the area. By stating that only areas with an average score above 70 will be considered inviolate, the system is in effect discounting the need to protect any area that scores less than 70. This includes, by the committee’s proposal, areas outside the PA network with more than 5 Schedule I species, or areas with occasional wildlife presence, or most Dry Deciduous Forests. The vast majority of wildlife corridors in Western, Central, Eastern, Southern and North Eastern India will fall in these categories.
Identification of Biodiverse areas through IIRS Data While IIRS data can be one of the useful tools, it cannot be the only one for selection of biodiverse areas. Information and knowledge about the local biodiversity through the involvement of the local communities, academics and civil society should also be used in this process. Under the National Biodiversity Authority Act, Peoples Biodiversity Registers were mandated. Hundreds of villages across India have worked on these registers and documented their biodiversity. The current report cannot just chose to neglect all these institutional and legal mechanisms in place
A relevant question in this regard is: Do we have sufficient information about for example biodiversity in various Himalayan and Western Ghat forests? New species are being discovered every month even without a concerted effort from the government. Hence, total dependence on IIRS data will be a blunder.
Wildlife value There is no mention of the aquatic biodiversity in this subject head or anywhere else in the document. Aquatic biodiversity also needs to be taken note of and needs protection. Particularly in the context of protected areas, it needs to be recognised that the aquatic biodiversity within the protected areas would be affected by interventions in the aquatic sources, upstream and downstream of the protected areas and thus would need protection in that respect. Secondly, we have very few protected areas for aquatic biodiversity and we need many more of them.
Hydrological Value In the committee report there is mention of maintenance of forest cover in the catchment of only first order perennial streams. This, though a step in right direction, is only limited step. It needs to be recognised and understood that the natural forest cover in the catchment of all streams would be of equal importance since destruction of such forest cover has implications for hydrological flow pattern in the downstream areas, aquatic biodiversity in the downstream streams, silt flow patterns in the downstream flows and all the connected water-fish-food-energy securities for the downstream areas.
This complexity is missed when the suggestion is to declare only the following areas as inviolate areas:
1. The directly draining catchment of the first order streams that are used as drinking water streams for towns and villages,
2. Areas located in direct draining catchments of the first order perennial streams feeding the irrigation and hydropower projects,
3. Areas located within 250 m of the banks of the perennial streams/ rivers, boundary of important wetlands (not clear what is the definition of important wetlands, are all wetlands with area more than 10 ha to be considered as important wetland, is river and its floodplain included in the definition of the wetland?) and storage reservoirs of water supply/ irrigation/ hydropower/ multipurpose projects (does it mean this applies to all natural and man made reservoirs of India, since all such reservoirs are used for one or the other purpose listed here?).
There is also contradiction when, while on the hand areas within 250 m of the banks of perennial streams and rivers is supposed to be inviolate (and thus get a score of 100), in section 3.6.1 it is suggested that areas within 100 m of the major seasonal streams or rivers should get a score of 70. The trouble is, we do not have ready made baseline data or clear definition as to what areas are supposed to be included when it is mentioned “banks of perennial rivers and streams”. Secondly, there is no clarity as to what would be called a seasonal or perennial river. For example, there are rivers that were perennial but has become seasonal because of human interventions. Then there are some rivers that were seasonal, but have become perennial due to the community conservation actions.
Moreover as far as hydrological value is concerned, the sustainable existence of value for any sq km grid area would actually depend on what is going on in a much wider area, almost whole of the catchment and also what is happening in the downstream. This reality does not seem to be captured by the suggested methodology. It would not make sense to give value in this sense to only the specific grid, but to protect that much larger area would need to be given implied value and any decisions would need to be keep in mind such inter-linkages.
The inter-linkages are also important for the implied change in pressures on specific grid element when decisions lead to violation of value of linked grid elements.
Community conserved areas: Across India, traditional communities have protected stretches of forest, grasslands, wetlands and river through community conservation. As India hosts the CBD this year, we cannot simply neglect Indigenous Community Conserved Areas (ICCAs) even as a signatory to the CBD. All community conserved areas should be declared as inviolate zones.
FragmentationSimilarly, the parameters do not deal effectively with the critical issue of fragmentation of forests as a result coal-mining related infrastructure and ancillary activities – roads, railways, power lines etc. If some areas are recognised as inviolate and the adjoining areas are opened up for mining, there will be demands on the adjoining forests for ancillary infrastructure. Fait accompli arguments will be advanced, as is currently the practice among industry proponents. Any discussion on excluding mining from critical forest areas needs to take on board cumulative impacts of the land use change which is likely to take place. The MoEF needs to engage with this critical question through widespread debate and consultation as a first step.
Faulty Decision Rules: Decision Rule 1: They have not included already identified ecologically sensitive areas.
Decision Rule 2: A score of 70 is way too high for determining that the grid is inviolate. The rule should be that any area that gets over 70% score with respect to any one of the parameter should be inviolate area.
Decision Rule 3: Only if 90% or more grid from any coal blocks are outside inviolate zone, should there be consideration for such block for mining.
Compliance A key question in this regard is, who will monitor and ensure that the inviolate forests will remain inviolate? Considering the past track record of the bureaucracy in MoEF, there is little credibility of their ability or interest in keeping such areas inviolate. The example of areas declared earlier as no go areas for mining and how almost of them are now gone is fresh in the minds of the people. We need a credible mechanism involving the local people in ensuring compliance of the decisions.
Keeping in mind all of the above, we demand that:
a) The above mentioned criteria be opened up for more detailed scrutiny and debate with an acceptance of the multiple roles played by our forest areas. This process (some essential elements of the process are mentioned above) must be inclusive and broad-based, in contrast to the exclusionary process followed thus far.
b) That the ministry uphold the spirit of environment justice and the need to safeguard the livelihoods of forest dependent communities as also their cultural issues when making decisions on forest diversion.
c) That no further forest diversion for mining should be allowed until the conclusion of a transparent and open process as specified in point a) above. This is especially important given the growing conflict in forest areas.
d) Any further criteria setting process be inclusive and broadbased rather than the exclusive and expert dominated processes like is in the present case. This goes completely against the government’s constitutional commitment to being a sovereign, socialist republic.
We look forward to your response and the announcement of an open consultation process on the need to protect our remnant forests from coal mining and other activities in forest areas.
Introduction Following the implementation of EIA notification of Sept 2006, the Ministry of Environment & forest (MoEF) has constituted different committees for the appraisal of various developmental projects including River Valley & Hydroelectric projects. The committees are called as Expert Appraisal Committees (EAC). The EAC for River Valley & Hydroelectric projects has had 63 meetings till date from the date of constitution of Committee in April 2007 to the latest meeting in Dec 2012. The committee generally recommends for any River Valley projects, at first stage the Terms of Reference (TOR) for the Environment Impact Assessment (EIA) to be carried out for the proposals along with permission for pre construction activities or works related to survey and investigation.
Figure 1: Stage 1 clearance figures across India
Model TOR The MoEF has also put up what the Ministry calls “Model TOR for River Valley and Hydroelectric Projects”, but when you click on the link[1], it opens into a document that is titled, “Model TOR for Hydropower Projects”, it does not even claim to be a model TOR for any other river valley projects. This is a big lacuna, since over 95% of India’s large dams are irrigation projects[2], not hydropower projects. Moreover, substantial proportion of the projects coming before the EAC is irrigation projects, including river linking projects. Not having a Model TOR for such projects is a big gap. This does not mean that the Model TOR given on the MoEF website is adequate or comprehensive. Only to illustrate, the Model TOR does not look into the impacts of the various integral components of the hydropower projects like colonies, roads, mining, blasting etc that the hydropower projects invariably have. Model TOR does not look at the social, environmental, economic or cultural services that a river provides. On downstream impacts, the model TOR says under Impact Prediction, “Downstream impact on water, land & human environment due to drying up of the river in the stretch between dam site and powerhouse site.” This completely negates the impacts that the project would have either on the upstream or in the river downstream from the power site or along the tributaries both upstream and downstream of the projects. Nor does it mean that these grossly inadequate Model TOR is followed by the developers. Even the ministry or the EAC does not bother to check if the EIA submitted to them follows either the specific TOR given to the project or the Model TOR on the MoEF website.
Environment Clearance At the next stage, the EAC considers the projects for the Environment Clearance (EC), at this stage the EIA is supposed to have been conducted as per the approved TOR and the public hearing is also supposed to have been conducted as per the norms set in the EIA notification of Sept 2006. The EIA notification is issued under the Environment Protection Act, 1986. We have tried to analyse the recommendations of the EAC from the minutes of 63 meetings for the period April 2007 to Dec 2012.
The EAC members The reconstituted EAC in April 2007 was headed by Shri P Abraham, former Power Secretary. Over the years, EAC included members like Dr Sanchita Jindal, Dr A R Yousuf, Dr OP Sisodia, Dr Dinesh Kr Alva, Dr. Dulal Goswami, Prof D K Paul, Dr (Mrs) Usha Bhat, Dr Bithin Datta, Dr Pushpam Kumar, Dr. Devendra Pandey (chairman of EAC from Aug 2009 to April 2010, current Chairman took over as chairman during 38th meeting held on June 30, 2010), none of them are members of the EAC for RVP currently. The member representing Central Water Commission in the EAC included R K Khanna, R K Singh, N Mukherjee but has been changing over the years and full list of their names is not available. Shri P Abraham resigned following our letter to the then Union Minister of State for Environment and Forests (Independent Charge) Shri Jairam Ramesh, showing the conflict of interests involved in he being on the board of a number of hydropower companies whose projects came up for clearance before the EAC chaired by him.
The current composition of EAC for RVP is as follows (as per MEF website[3] as on Jan 30, 2013):
S.No.
Name & Address
Role in Committee
1
Shri. Rakesh Nath, C-1/29, Bapa Nagar New Delhi-110 003
Chairman
2
Dr. B.P Das, 717 Saheed Nagar Bhubaneswar -751007
Vice-Chairman
3
Dr .A. K. Bhattacharya, Flat No-805,Pocket-3,Akshardham Apt. sec-19 Dwarka New Delhi-110075
Member
4
Chief Engineer(Hydrology), Central Water Commission, Sewa Bhawan, R.K. Puram,New Delhi-110 066
Member
5
Dr. Jyoti Kumar Sharma, Professor School of Environment & Natural Resources 14/15, Old Survey road Dehradun-248 001 Uttrakhand
Member
6
Dr. K.D. Joshi, Principal Scientist and Head Central Inland Fisheries Research Institute Regional Centre Allahabad Uttar Pradesh
Member
7
Dr. Praveen Mathur, Associate Professor & Head Department of Environmental Science P-5, Professor’s Colony MDS University Campus Ajmer-305 009 Rajasthan
Member
8
Dr. S Bhowmik, 40 C, Pocket 1, Sector 10, Dwarka, New Delhi
Member
9
Dr. Surendra kumar Mishra, Department of Water Resources, Development & Management, Indian Institute of Technology, Roorkee – 247667
Member
10
Dr. (Mrs.) Maitreyee Choudhary, Professor & Director, Centre for Himalayan Studies, University of North- Bengal, W.B.
Member
11
Prof. (Dr.) Dhananjai Mohan, Wildlife Institute of India, Dehradun, 248 001 Uttarakhand
Member
12
Prof. Arun Kumar, Department of Earth Sciences, Manipur University, Imphal, 795003, Manipur.
Member
13
Prof. S. K. Mazumdar, 242, FF, Sidharth Enclave Ashram Chowk New Delhi-110 014
Member
14
Sh. B B Barman, MOEF, Paryavaran Bhavan, New Delhi
Member Secretary
In addition to the above, Dr P V Subba Rao (Scientist from MoEF) is listed as EAC member in the minutes of the meetings. Interestingly, he, Dr B P Das and Dr A K Bhattacharya seem to be constant members of the EAC throughout the period under study.
Role of MoEF All the comments about the EAC here apply equally to the Union Ministry of Environment and Forests as two officials of the ministry have always been part of the EAC, including the member secretary of the EAC. In fact MoEF has a greater role in selection of the chairman and members of the EAC, deciding what projects should be put on the agenda, what happens after the EAC recommendations, ensuring that all the required information about the projects on the agenda is available and is in public domain, encouraging EAC to invite to EAC meetings individuals and groups who have written to EAC and MoEF on substantial aspects, and otherwise setting the policies and norms for the EAC and projects. The MoEF performance has been pathetic. Even now it’s not possible to even know the status of the clearances of the projects from the MoEF website, even though it is statutory requirement for MoEF (under EIA notification 2006) to display the clearance letters on its website. In Feb 2012 Central Information Commission (CIC) directed MoEF under the Right to Information Act 2005 to put all the documents submitted by the project developers for clearance, at least ten days before the projects are considered by the EAC. When this was not followed, SANDRP wrote to CIC and CIC issued notice to MoEF. This is still to be followed by MoEF fully. Now some of the documents are put up on the website before the EAC meetings, this is not the case even for the 63rd and 64th meetings of EAC. The EAC, in spite of repeatedly writing to them on this violation of the CIC directions, did not take steps to ensure that CIC directions are fully complied with for the projects that come up before the EAC.
Even though MoEF may be equally if not more responsible for the various violations listed here, that does not reduce the responsibility of the EAC members. Once someone is selected as EAC member, he or she has the duty to ensure basic norms in functioning of the EAC. Evidence presented here shows if the EAC members have succeeded in achieving even basic norms in governance of EAC.
Results and Analysis
The Union Ministry of Environment and Forests’ (MoEF) Expert Appraisal Committee (EAC) on River Valley and Hydroelectric Projects (RVP) has considered a total of 262 hydropower and irrigation projects in close to six years since April 2007 when the new committee was set up to its latest, 63rd meeting in December 2012. It has not rejected any project in this period. Even in case of the two projects that it declined to recommend clearance for the Terms of Reference (TOR) of their Environment Impact Assessment (EIA), it has basically asked the developers to come back with reformulated proposals. It seems the committee is actually an Expert Approval Committee, since it seems to have expertise in approving rather than appraising the projects objectively.
EAC has strong pro project and anti people bias The Committee has shown its strong bias for the projects. Many groups from all over India have sent hundreds of submissions to the EAC over these years. The committee has never called any of the groups for the meetings where the specific projects on which groups have sent submissions. The EAC has never even acknowledged any of such submissions in the minutes of the meetings. In case of some of the recent submissions from SANDRP and others, the chairman of the EAC wrote back saying that this will be discussed in the next meeting, but there has been no mention of such submissions in the minutes of the EAC meetings. The EAC has shown its strong bias against people, environment and all those who represent the interests of the local communities and environment. In February 2012 some of us were invited for a discussion with the EAC, but we saw little impact of our discussions on the functioning of the EAC.
Opposition to Dams on Teesta, many of which are cleared by the EAC Photo: Affected Citizens of Teesta
The table below gives an overview of the situation of TORC (Terms of Reference Clearance) and EC (Environment Clearance) for the projects cleared by the EAC on RVP between April 2007 (when the then newly constituted EAC met for the first time) to its 63rd meeting as in December 2012. The table shows that the EAC has not rejected any of the projects for EC. As against the 211 projects considered by the EAC for TORC, it (only temporarily) rejected TORC for two projects. Hence its rejection rate for TORC is less than 1%. EAC’s rejection rate of environment clearance is nil as it has never rejected any project that has come to it for environment clearance. It seems the EAC for RVP has been basically rubber stamping approval for every project that comes their way. The EAC was expected to do much better than that, as it clear from the reading of EIA notification of Sept 2006, following which the EAC was set up.
Overview of Clearance status across India
Region
Projects for TORC
Projects for EC
Total projects considered
TORC given
TORC Rejected
Projects considered for TORC
EC given
EC rejected
Projects considered for EC
North
50
1 (300 MW)
57
31
0
34
72
North East
70
1 (420 MW)
87
17
0
19
99
East
10
0
13
7
0
8
20
West
28
0
39
14
0
17
49
South
7
0
14
6
0
8
22
Total
165
2
210
75
0
86
262
Temporary rejections for two TORC Only two projects were rejected TORC. Among these, for the 420 MW Kameng Dam, the EAC rejected the proposal from KSK Ltd, since the submergence area was just 350 m from Pakke Tiger Reserve. The EAC however, said, “The Committee suggested that possibilities of locating a suitable site on Kameng River, upstream of confluence of Bichom & Kameng may be explored.” So the project is likely to come back to EAC. It is surprising, however, that another project in the same basin, namely the 1120 MW Kameng I on Bhareli / Kameng River in East Kameng district in Arunachal Pradesh came before the EAC during its first meeting in April 2007. The minutes of the EAC meeting clearly says about this project, “A part of the submergence area falls under the Pakke Tiger Reserve.” And yet the EAC gave TOR clearance to the project! Inconsistency seems to be the first name of the EAC.
Similarly the 200 MW Bara Bangahal HEP in Kangra district in Himachal Pradesh was accorded TOR clearance in 21st meeting of EAC in Dec 2008, even as the minutes recorded, “The project is located within the wildlife sanctuary.” Similarly the 76 MW Rambara project on Mandakini River in Rudraprayag district in Uttarakhand, just 6 km from Kedarnath, was given TOR approval in the 19th EAC meeting in Oct 2008 even as the minutes noted, “The whole project is located within Kedarnath Musk Deer Sanctuary.”
Thousands of Monks opposing dams in Tawang, Arunachal cleared by the EAC Photo: Seven Sisters Post
Similarly while rejecting the TORC for the 300 MW Purthi HEP in Lahaul and Spiti District in Himachal Pradesh, the EAC said, “The Committee concluded that the project proponent and Govt. of Himachal Pradesh may review and revise the proposal in the light of the above observations for reconsideration.” So it is clear in this case too that the rejection is temporary. In reality, the EAC has rejected none of the projects that came to it for clearance.
Massive hydropower capacity cleared The EAC for RVP basically considers hydropower projects having installed capacity over 50 MW, projects of 25-50 MW going to the state Environment Impact Assessment Authorities and those below or requiring any environment clearance under EIA notification 2006. The table below shows that in less than 6 years, the EAC has recommended TORC for hydropower projects proposed with installed capacity of 49458 MW, which is about 25% more than what India has installed in about 66 years since independence.
Status of clearance for Hydropower Projects
Region
Capacity for which TORC given, MW
Capacity for which EC given, MW
Capacity of projects considered, MW
North
12823
6843.5
18087.5
North East
31541
8258
46658
East
3434
120
3684
West
1320
–
1586
South
340
863
2178
Total
49458
16084.5
72193.5
Figure 2: Zone wise status of Environment Clearance
During the period, the EAC has recommended EC for hydropower capacity of 16084.5 MW, which is about three times the hydro capacity of 5544 MW added during the just concluded 11th five year Plan. EAC has recommended all these clearances without giving any consideration to carrying capacity, cumulative impact assessment, democratic decision making, sustainable development criteria, full and proper social and environment impact assessment or desirability of such capacity addition, including from climate change perspective.
Opposition to 775 MW Luhri Project cleared recently by EAC Photo: Himdhara
Zero rejection for irrigation projects The EAC for RVP considers irrigation projects with Cultivable Command Area (CCA) above 10 000 Ha. In the table below are the region wise details of the TORC and EC recommended by EAC for the Cultivable Command Area figures of the major and medium irrigation projects.
During the period under study (Apr 2007 to Dec 2012), EAC has given TORC for 3.28 million ha of CCA and EC for 1.59 million Ha of CCA. Here we should note that since 1991-92, there has been no addition to the net area irrigated by major and medium irrigation projects at all India level as per Govt of India figures[4]. In light of that fact and considering the overcapacity already built into a number of basins across India already, such clearances by EAC are highly questionable.
Status of clearance for Irrigation Projects
Region
CCA for which TORC given, L Ha
CCA for which EC given, L Ha
CCA of projects considered, L Ha
North
2.02
3.53
6.17
North East
0
0
4.00
East
11.30
1.20
12.80
West
8.34
4.65
13.01
South
7.70
6.50
22.96
Total
29.36
15.88
58.94
Land requirement Full details of the land required for the projects are never properly assessed by the EIAs. The EAC minutes reflect only indicative figures of land requirement of some of the projects considered by the EAC as mentioned in the EIAs.
Figure 3: Zone wise status of Stage 1 clearances (TORC)
Land required for the projects considered by EAC
Region
No of projects for which land requirement figures are available
Land required for the projects in previous column
North
62
29932.77 Ha
North East
72
76768.27 Ha
East
9
16809.24 Ha
West
15
31858.57 Ha
South
13
57398.82 Ha
Total
171
212767.67 Ha
Following table gives an over view of land requirement for some of the projects as mentioned in the EAC minutes. Based on available figures, the Highest land requirement in a state is for Andhra Pradesh, at 45913.26 ha the second rank state is Arunachal Pradesh with land requirement of 35485.3 Ha. Arunachal being smaller and hilly state and most of the land being required are forested and close to the rivers, the impact in Arunachal Pradesh would be much greater. Based on above information, for the projected land requirement for the 262 projects considered by the EAC during the period under study would come to over 325995 Ha. However, these land requirement figures are gross under estimates and too much need not be read into them.
The flawed functioning of EAC It has not mattered to the EAC that the EIAs of the projects that come to it are shoddy, dishonest, cut and paste jobs. The Committee has not rejected a single EIA, even through evidence was repeatedly presented to the committee about shoddy nature of the EIAs. It has not mattered to the committee that there has been no credible public consultation process and there have been serious anomalies in public hearing processes. The committee did not order fresh public hearings even when evidence was provided to it about serious violations in public hearing processes.
Figure 4: Zone wise figures of TORC and EC given for hydropower installed capacities
Even when the committee asked for fresh studies or significant changes in EIA, it did not ask the project proponent to go back for fresh public hearing. It has not mattered to the committee that EIAs of the projects it cleared did not have full year round ground level surveys, did not have full social impact assessment, did not have downstream impact assessment, did not have options assessment to establish that the proposed project was least cost option, did not have assessment of impacts due to blasting of tens of kilometer long tunnels, did not have proper flora or fauna studies, did not include impact of the project on rivers and the services provided by the river or impact on downstream projects or flood plain use, or had used flawed, false or inconsistent data base.
Figure 5: Zone wise figures of TORC and EC given for irrigated area CCA in lakh Ha
SANDRP had put together a detailed submission[5] and mobilized endorsements of large number of concerned groups and individuals, including over ten eminent scientists on World Fisheries Day on Nov 21, 2012 and sent to EAC, raising issues concerning riverine fisheries in functioning of the EAC and suggesting specific measures to improve the same. The chairman of the EAC wrote back to SANDRP that this will be discussed in the next meeting of EAC, but there was no mention of it in the minutes of the EAC, nor any concrete action taken by the EAC after that. Earlier in November 2012, SANDRP had organized a side event on issues related to riverine biodiversity in India at the Hyderabad Conference of Parties of Convention on Biodiversity. Considering the importance of the issue for the functioning of the EAC, we had invited the members, including the Chairman and member secretary for the side event. No one came.
Figure 6 Overview of State-wise installed capacities of HEPs considered by EAC in North India
No appreciation of Cumulative Impacts It has not mattered to the committee that there has been no Cumulative Impact Assessment (CIA) when large number and bumper to bumper hydropower projects are proposed on number rivers including Bhagirathi, Alaknanda, Mandakini, Sutlej, Ravi, Beas, Chenab, Teesta, Lohit, Tawang, Siang, Subansiri, Narmada, to name only a few. It does not matter to them that there is no flowing river between two projects, it has recommended clearance to Luhri HEP most recently with zero flowing river length with both immediately upstream (Rampur HEP) and immediate downstream (Kol dam) projects.
Figure 7 Basin-wise overview of number of Hydro Projects considered by EAC in North India
Even in few cases that the EAC has asked for CIA, it has asked the CIA to be done by an agency like WAPCOS Ltd that has an abysmally poor track record in doing such studies and it has serious issues of conflict of interests since the agency is also involved in feasibility studies and detailed project reports as part of its business model. But EAC has never understood these concerns. Nor has the EAC really bothered to look at the quality of the CIA. Most significantly, the EAC refused to wait for the CIA report of a basin before considering individual projects in such basins, showing its complete lack of understanding of the importance of CIA.
Section 9 of the Form I (the developer is supposed to apply for stage I clearance with this form duly filled in, as per Para 6 of the notification)) prescribed in Annexure 1 of the EIA notification of Sept 2006 is supposed to be about “Factors which should be considered (such as consequential development) which could lead to environmental effects or the potential for cumulative impacts with other existing or planned activities in the locality”. Section 9.4 under this reads: “Have cumulative effects due to proximity to other existing or planned projects with similar effects”. So even legally the EAC and MoEF are supposed to look at the cumulative impact assessment issues under the EIA notification, both at scoping at appraisal stage, which they are clearly not doing.
Here it may be noted that recommending Environment clearance without first undertaking carrying capacity and cumulative impact assessment is in violation of Supreme Court order in “Karnataka Industrial Areas … vs Sri C. Kenchappa & Ors on 12 May, 2006” which has said:
A. “The pollution created as a consequence of environment must be commensurate with the carrying capacity of our ecosystem. In any case, in view of the precautionary principle, the environmental measures must anticipate, prevent and attack the causes of environmental degradation.”
B. “…the preventive measures have to be taken keeping in view the carrying capacity of the ecosystem operating in the environmental surroundings under consideration.”
C. “The pollution created as a consequence of development must not exceed the carrying capacity of ecosystem.”
Without knowing carrying capacity of a basin it cannot be ascertained if the proposed project is “commensurate with the carrying capacity of our ecosystem”, ecosystem in this context is the river basin.
Figure 8 Overview of Basin-wise installed capacity of HEPs that EAC considered in North India
Figure 9 State wise overview of installed capacity of HEPs considered by EAC in North East India
EAC’s double standards While EAC itself has not rejected any of the proposals that came to it, few, rare environment friendly recommendations that have been made by other committees have also been rejected by the EAC, without any convincing reasons. To illustrate, when the carrying capacity study of the Teesta basin recommended that no projects should be taken upstream of Chungthang in North Sikkim, the EAC in its meeting overturned this decision and decided to consider all such projects. Similarly, the recommendations of the Ganga Basin Cumulative Impact Assessment study by the Wildlife Institute of India, suggesting that at least 24 hydro projects proposed in Ganga basin be dropped and much higher environment flows than those directed by EAC should be mandated, were all rejected by the EAC.
The recommendations of the Western Ghats Ecology Panel headed by Prof Madhav Gadgil were also rejected on grounds such as inadequate studies. Overturning the recommendations of the WG Ecology Panel report, the EAC recommended clearance to the controversial Gundia hydropower project in Western Ghats in Karnataka. If the standards applied by the EAC while rejecting the recommendations of all these committees were to be applied to the EIAs and CIAs based on which the EAC approved the projects, than none of the projects approved by the EAC would merit clearances. But the EAC has very lax standards for its own work, and for the EIAs and CIAs that favour projects, but different ones for the reports that recommend rejection of projects. This contradiction is highlighted here only for illustration of double standards of the EAC and it does not mean that the EAC decisions in rejecting any recommendations of any of these committees have any merits.
Western Ghats Expert Ecology Panel assessing Ecosystems to be affected by Gundia HEP. EAC recommended clearance to this project despite rejection by WGEEP Photo: India Together
It may be noted that the previous chairman (former power secretary Shri P Abraham who chaired EAC till June 2009) had serious conflict of interest issues with he being on board of several power companies whose projects came up before the committee and the current chairman has had no back ground on environment issues. It has not mattered to the committee whether the Environment Management Plans that accompany the EIAs that it clears are implemented or not, or if there is any credible mechanism and legally empowered process in place to ensure its implementation. The EAC has not even shown concern for legal norms that the TOR clearances are valid only for two years. MoEF has recently issued a notification dated Oct 30, 2012[6] that said that project for which the proponents have not come back with the requested additional information for more than six months should be delisted. Luhri project thus should not have been considered by the MoEF from more than one legal point view. MoEF and EAC have yet to follow such notifications of the ministry.
The minutes of many of the EAC meetings make pathetic reading, if read carefully. One can find contradictions, inconsistencies, plain wrong facts being mentioned in the minutes of the EAC meetings[7], which are all approved by the EAC. Even when such errors are pointed out, the EAC has not even bothered to correct the mistakes or review its decisions.
Cleared by EAC, Rejected by others Many of the projects cleared by the EAC have faced serious road blocks for the shoddy appraisal done by the EAC. For example, the then Union Environment Minister himself decided not to clear the Renuka dam project cleared by the EAC. The Rupsiabagar Khasiabara project cleared by the EAC could not get forest clearance, for many reasons, including the fact that the EIA of the project was found to be so shoddy and wrong, that any other committee would have considered this an insult to its work. The Kotlibhel 1B and Kotlibhel 2 projects, cleared by this committee have been rejected clearances by the Forest Advisory Committee, following recommendation of the Wildlife Institute of India.
Figure 10 State wise overview of number of projects considered by EAC in North East India
Athirapally hydropower project in Chalakudy basin in Kerala was recommended Environment Clearance by the EAC for the third time (earlier two clearances were quashed by the Kerala High Court) in May 2007, but the project again came back to the EAC in March 2010, following Kerala High Court directions. Earlier on January 4, 2010, following directions from the then Union Environment Minister of State Shri Jairam Ramesh, Dr S Bhowmik, than director in MoEF, issued show cause notice under Environment Protection Act, 1986, to the developer agency, Kerala State Electricity Board, to show cause in 15 days as to why the environment clearance granted to the project should not be revoked and why the direction of closure of the project not be issued. It is not clear if the MoEF took the next step hinted in the notice. Its strange that the EAC, in which the same Dr Bhowmik was member secretary, did not mention the issuance of this notice in the EAC meetings when the EAC discussed this project between March and July 2010. There is no mention of the MoEF show cause notice in the minutes of the EAC meetings held during the period.
Figure 2 Athirappilly Water Falls at the proposed Athirappilly HEP site Photo: Southernsojourns
Several projects cleared by the EAC stand challenged in the National Green Tribunal, some of them (e.g. Renuka dam) have got a Stay Order. The World Bank too finds the EIAs based on which the EAC cleared the projects so poor that it has asked for fresh EIAs for the projects it wants to fund (e.g. Rampur and Vishnugad Pipalkoti hydropower projects).
Figure 11 Basin wise overview of number of projects considered by EAC in North East India
Climate Change It is well known that the worst impacts of climate change is going to be felt in terms of impacts on water resources. It is also well known that the natural resources like the biodiversity, forests, rivers, wetlands, fertile flood plains and riverine lands are some of the important resources that would help us adapt to the climate change impacts. Hydropower and dams that the EAC considers adversely affect all of these natural resources. It is well established that large sections of people of India who depend on such natural resources are the poorest and most vulnerable to climate change impacts and when the resources that these vulnerable sections depend on are destroyed by the hydropower projects and dams that the EAC appraises, the committee would be expected to consider the climate change context. Consideration of climate change context is thus important from several angles while appraising the river valley projects. It’s also well established now that past is not the best guide while estimating river water flows. Research over the last two decades have also established that reservoirs in a tropical country like India would also be source of methane and CO2 emissions, methane being about 21 times more potent in global warming terms than CO2. In view of all this, one would have expected elaborate discussion of climate change issues in the functioning of the EAC. One would expect the EAC to mandate the EIAs and CIAs to look at these issues comprehensively.
Unfortunately, we are disappointed on every one of these counts. We find little mention of climate change issues in the work of the EAC. In fact the model Terms of Reference for the hydropower projects put up on the MoEF website[8] does not have the word “climate” in it, leave aside “climate change”.
E-flows For Hydroelectric and River valley Projects which dewater and divert rivers entirely or partially and change its natural hydrograph, EAC has now[9] been arbitrarily recommending release of 20% of average lean season flow for lean months, between 20-30% e-flows (short for Environmental flow) for non-lean, non-monsoon months and 30% average monsoon flow for monsoon flows. This standard is entirely arbitrary, without any scientific, ecological or sociological basis, blanket for all rivers from Himalayan to peninsular.
This too has happened not suo motto, but after huge pressure from civil society and various other committees. And when the proponent says it cannot release these inadequate flows, EAC is actually ready to negotiate, which is acceptable between the EAC and the proponents (like in the case of 300 MW Alaknanda HEP by GMR Energy). Like any negotiation in a fish or vegetable market. While taking these decisions, EAC has never recommended that a more holistic and participatory method for assessing e-flows needs to be developed. Or that certain rivers needs to be left undammed. Even when other committees like the Wildlife Institute of India have recommended higher e-flows, the EAC or MoEF has refused to follow such recommendations.
Figure 12 State wise overview of number of Projects considered by EAC in East India
Biodiversity Violating the National Biodiversity Act of 2002, EAC does not ask for Biodiversity Impact Assessment of projects, does not think twice while recommending clearances to projects affecting severely threatened, endemic and endangered biodiversity and RET (Rare Endangered Threatened) species. This has had disastrous impacts for critically endangered fauna like Black Necked Cranes, Red Pandas (780 MW Nyamjangchu HEP), Several endemic species including Gundia Indian Frog (200 MW Gundia HEP), Snow Leopard (Projects in Upper Ganga including 300 MW Alaknanda HEP), Gangetic Dolphin (Upper Ganga and Brahmaputra Projects), Bengal Florican (1750 MW Lower Demwe Project), Fish like Golden Mahseer, Snow Trout (most dams in Himalayas and North East) to name a very few.
Figure 13 Basin wise overview of number of projects considered by EAC in East India
Even while noting in the 56th meeting of EAC, while discussing the 775 MW Luhri HEP on Sutlej river in Himachal Pradesh, that as per the EIA of the project, “However, 21 species are listed in the Red data book of Indian plants”, the EAC does not even bother to enquire about which are these plants and why decide to sacrifice their loss. While discussing Shongtong Karcham hydropower project, the EAC noted in the minutes of the 30th meeting of EAC, “Considering the presence of 51 species of fish in the upper reaches of Sutlej, it is reported (in EIA) that only three species of fish were found in the study area”. But amazingly, the EAC has no qualms in accepting such fundamentally flawed EIA. Two of these species are simply human intervention.
Dibru Saikhowa National Park and its endangered species are thretened by the 1750 MW Lower Demwe Dam on Lohit cleared by EAC Photo: assam Portal
In case of the Rupsiabagar Khasiabara Hydro Power Project in Uttarakhand[10], the EIA report prepared by the WAPCOS to obtain Environment Clearance for the RKHPP reports presence of only 8 bird species. The EAC actually gave clearance to the project without raising any issues of the flawed EIA. The Inspection Report of the Sub-Committee of the Forest Advisory Committee to assess wildlife values and ecological impact of the project, led by Dr Ullas Karanth makes interesting reading.
Figure 14 State wise over view of number of projects considered by EAC in West India
Figure 15 Basin wise overview of number of projects considered by EAC in West India
Figure 16 Basin wise overview of CCA of Irrigation Projects considered by EAC in West India
The Inspection Report noted, “However, as per the existing literature a total of 228 bird species in 30 families and 118 genera, representing more than 45% of the breeding bird diversity of the Western Himalaya and nearly 55% of breeding bird species of the kumaon Himalaya are recorded in the region. Ten species of pheasants are found in the area, including Himalayan monal, and the Koklass pheasant, and several other altitudinal migrants. This assemblage represents 6 out of seven West Himalayan endemics found in Kumaon.” But the EAC did not even note any of these flaws of the EIA and obediently cleared the project. The project currently stands cancelled after the sub committee recommended that the project be rejected forest clearance. All this shows how little significance is of biodiversity for the EAC and MoEF.
Regional and detailed analysis These conclusions are based on analysis of the agenda and minutes of 63 meetings of EAC spread over close to six years from April 2007 to December 2012, done by South Asia Network on Dams, Rivers & People (www.sandrp.in)[11] in light of other related information and experiences. SANDRP has been monitoring the functioning of the EAC over the years, has been writing to the EAC about its concerns and also those of partner organisations about specific projects and general functioning of the EAC. This analysis is based on this experience and we hope it will be useful for all concerned.
In what follows we have given region wise status and analysis of the project wise clearances recommended by the EAC for RVP for the five regions of India, namely: North, North East, East, West and South. The tables for each region give state wise list of projects with some basic features of the projects. An overview of number of projects and their capacities is given in tables that give status wise, state wise and river basin wise figures for the projects that EAC considered in these six years.
Figure 17 State wise Overview of hydropower installed capacities considered by EAC in South India
Figure 18 Overview of Irrigation Projects: Culturable Command Area (CCA) of Projects in South India
In an accompanying document[12], also from SANDRP, we have given more details for each project and date-wise decisions of the EAC for each of the projects on EAC agenda. We are hopeful that these two documents will be helpful in giving clear picture about functioning of the EAC to all concerned.
We should add here that these two documents are only limited to giving a picture about functioning of the Expert Appraisal Committee on River Valley Projects. There are many other equally serious problems plaguing the environmental governance of River Valley Projects in India, they will require separate work.
NORTH INDIA
TOR & Environment Clearance status in North India
Following table gives project wise information about basic features and clearance status for the projects that came to EAC from North Indian states of Jammu and Kashmir, Haryana, Punjab, Himachal Pradesh, Uttar Pradesh, Delhi and Uttarakhand. The maximum no of projects are (34) from Himachal Pradesh among all states, Uttarakhand coming second with 25 projects. Jammu and Kashmir has less no of projects at 11, but the proposed installed capacity of the J&K projects is highest at 7573 MW. The land requirement is also highest in J&K among North India states at over 10170 Ha. Among all regions, the EAC has given the highest number of environment clearances in North India.
SN
Project
State
Basin
I/H/M
Ins Cap (MW)
CCA (Ha)
TOR
Meeting date
Env Clearance
Meeting date
Total Area Req (Ha)
Haryana
1
Dadupur – Nalvi Irrigation Project
Haryana
Yamuna
I
–
92532
Approved
16/05/2007
Recommended
16/06/2009
NA
2
Hansi – Butana Link Channel
Haryana
Yamuna
M
–
232024
–
Waiting
19/07/2007
553.21
Himachal Pradesh (HP)
3
Dhaulasidh HEP
HP
Beas
H
66
–
Approved
22/04/2010
Recommended
23/11/2012
NA
4
Lambadug HEP
HP
Beas
H
25
–
–
Recommended
22/08/2008
9.7914
5
Nakthan HEP
HP
Beas
H
520
–
Approved
20/12/2010
–
–
97.76
6
SAINJ HEP
HP
Beas
H
100
–
Approved
22/06/2007
Recommended
20/03/2009
56.763
7
Thana-Plaun HEP
HP
Beas
H
141
–
Approved
7/9/2012
–
–
497
8
Triveni Mahadev
HP
Beas
H
78
–
Approved
7/9/2012
–
–
482
9
Chhatru HEP
HP
Chenab
H
108
–
Approved
8/5/2008
Waiting
28/04/2012
95.26
10
Dugar HEP
HP
Chenab
H
380
–
Approved
12/10/2012
–
–
NA
11
Gondhala HEP
HP
Chenab
H
144
–
Approved
16/10/2008
–
–
214
12
Gyspa HEP
HP
Chenab
H
300
–
Approved
26/03/2011
–
–
1635
13
Miyar HEP
HP
Chenab
H
120
–
Approved
25/09/2010
Recommended
12/11/2011
69.94
14
Purthi
HP
Chenab
H
300
–
Not approved
23/11/2012
–
–
72
15
Reoli–Dugli HEP
HP
Chenab
H
420
–
Approved
26/12/2012
–
–
182
16
Sach Khas HEP
HP
Chenab
H
267
–
Approved
24/11/2012
–
–
102.48
17
Seli HEP
HP
Chenab
H
400
–
Approved
19/02/2012
Recommended
1/6/2012
292.9654
18
Telling HEP
HP
Chenab
H
94
–
Approved
23/11/2012
–
–
83
19
Bajoli Holi
HP
Ravi
H
180
–
Approved
16/01/2008
Recommended
21/12/2010
85.7
20
Bara Bangahal HEP
HP
Ravi
H
200
–
Approved
16/12/2008
–
–
53.64
21
Chanju-I HEP
HP
Ravi
H
36
–
–
Recommended
26/02/2011
NA
22
Kutehar HEP
HP
Ravi
H
260
–
Approved
7/5/2008
Recommended
21/01/2011
85.36
23
Chango-Yangthang HEP
HP
Sutlej
H
180
–
Approved
8/9/2012
–
–
146
24
Lara Sumta
HP
Sutlej
H
104
–
Approved
12/10/2012
–
–
97.75
25
Luhri HEP
HP
Sutlej
H
775
–
Approved
18/04/2007
Recommended
24/11/2012
380
26
Shongtong-Karcham HEP
HP
Sutlej
H
402
–
Approved
16/08/2007
Recommended
18/02/2010
79.17
27
Sumte Kothang
HP
Sutlej
H
130
–
Approved
12/10/2012
–
–
110
28
Tidong -I
HP
Sutlej
H
100
–
–
Recommended
16/08/2007
46.66
29
Tidong -II
HP
Sutlej
H
60
–
Waiting
29/07/2009
–
–
164.53
30
Yangthang – Khab HEP
HP
Sutlej
H
261
–
Approved
16/06/2009
–
–
1532.6
31
Chirgaon-Majhgaon HEP
HP
Yamuna
H
60
–
Approved
24/11/2012
–
–
31.58
32
Dhamwari Sunda HEP
HP
Yamuna
H
70
–
Approved
28/07/2009
Recommended
15/07/2011
23.3025
33
Renuka Dam Project
HP
Yamuna
M
40
–
Approved
16/08/2007
Recommended
28/07/2009
1532.6
34
Rupin
HP
Yamuna
H
45
–
Approved
24/11/2012
–
–
27
Jammu & Kashmir (JK)
35
Baglihar stage- II HEP
JK
Chenab
H
450
–
Approved
22/04/2010
Recommended
8/9/2012
NA
36
Bursar HEP
JK
Chenab
H
1500
–
Approved
2/6/2012
–
–
1665
37
Kirthai HEP
JK
Chenab
H
250
–
Approved
8/5/2008
–
–
290
38
Kirthai Stage-II HEP
JK
Chenab
H
990
–
Waiting
31/03/2012
–
–
NA
39
Kiru HEP
JK
Chenab
H
600
–
Approved
22/08/2008
–
–
295
40
Kwar HEP
JK
Chenab
H
520
–
Approved
19/02/2010
–
–
326
41
Pakal Dul HEP
JK
Chenab
H
1000
–
–
Recommended
7/1/2008
1163.898
42
Ratle HEP
JK
Chenab
H
690
–
Approved
27/12/2011
Recommended
21/07/2012
567.22
43
Sawalkote HEP
JK
Chenab
H
1200
–
Approved
3/6/2011
–
–
1099
44
New Ganderbal HEP
JK
Jhelum
M
93
–
Approved
8/5/2008
Recommended
26/12/2012
63.7
45
Ujh Multipurpose Project
JK
Ravi
M
280
32000
Waiting
13/11/2010
–
–
4700
Uttarakhand (UA)
46
Alaknanda Hydro Power Project
UA
Alaknanda
H
300
–
–
–
Recommended
17/01/2008
83.9
47
Bowala Nand Prayag HEP
UA
Alaknanda
H
300
–
Approved
22/08/2008
–
–
64.069
48
Devsari HEP
UA
Alaknanda
H
252
–
Approved
18/03/2008
Recommended
26/12/2011
223.36
49
Jelam Tamak HEP
UA
Alaknanda
H
128
–
Approved
28/04/2012
–
–
96.27
50
Kotlibhel 1-B
UA
Alaknanda
H
320
–
–
–
Recommended
19/07/2007
550.619
51
Kotlibhel-stage II HEP
UA
Ganga
H
530
–
–
–
Recommended
19/07/2007
676.071
52
Nand Prayag Langasu
UA
Alaknanda
H
100
–
Approved
25/09/2010
–
–
79.8177
53
Phata Byung HEP
UA
Alaknanda
H
76
–
–
–
Recommended
17/01/2008
22.72
54
Rambara HEP
UA
Alaknanda
H
76
–
Waiting
16/10/2008
–
–
17.78
55
Singoli Batwari
UA
Alaknanda
H
99
–
–
–
Recommended
18/07/2007
43
56
Tamak Lata HEP
UA
Alaknanda
H
280
–
Waiting
21/01/2011
–
–
77.26
57
Bhilinagana Project
UA
Bhialangana
H
22.5
–
–
–
Recommended
26/12/2011
NA
58
Bogudiyar-Sirkari Bhyol HEP
UA
Sarda
H
170
–
Approved
14/05/2009
–
–
75
59
Mapang-Bogudiyar HEP
UA
Sarda
H
200
–
Approved
14/05/2009
–
–
70
60
Rupsiabagar Khasiabara HEP
UA
Sarda
H
260
–
–
–
Recommended
17/02/2009
32
61
Sirkari Bhyol Rupsiabagar HEP
UA
Sarda
H
210
–
Approved
29/07/2009
–
–
NA
62
Jamrani Dam Multipurpose Project
UA
Sarda
M
30
150302
–
–
Recommended
18/02/2010
529.57
63
Arakot Tiuni HEP
UA
Yamuna
H
81
–
Approved
21/01/2011
–
–
38
64
Hanol -Tiuni HEP
UA
Yamuna
H
60
–
–
–
Recommended
8/5/2008
48.982
65
Jakhol Sankhri HEP
UA
Yamuna
H
45
–
Approved
15/06/2009
–
–
24
66
Lakhwar HEP
UA
Yamuna
H
300
–
Waiting
12/11/2010
–
–
NA
67
Mori- Hanol HEP
UA
Yamuna
H
63
–
Approved
14/12/2007
–
–
45
68
Naitwar Mori HEP
UA
Yamuna
H
60
–
Approved
22/06/2007
Recommended
27/12/2011
47.05
69
Tiuni Plasu HEP
UA
Yamuna
H
66
–
Approved
17/01/2008
–
–
NA
70
Vyasi HEP
UA
Yamuna
H
120
–
–
–
Recommended
16/09/2007
135.425
Uttar Pradesh (UP)
71
Badaun Irrigation Scheme
UP
Ganga
I
–
53,054
Approved
16/07/2008
Recommended
30/06/2010
5053
72
Arjun Sahayak Pariyojna
UP
Yamuna
I
–
57000
Approved
18/03/2008
Recommended
19/08/2009
2891
Purpose: H- Hydropower; I- Irrigation; M- Multipurpose.; NA- Not available
State-wise Overview of Projects in North India
Projects
Ins Cap
Irrigation
Drinking water
Land Req
Land Req Info available for projects
State wise Projects
Nos
MW
CCA (Ha)
MLD
(Ha)
Nos
Total Projects
72
18087.5
616912
145
29932.77
62
HP
32
6366
—
8285.85
29
UA
25
4148.5
150302
145
2979.89
21
J&K
11
7573
32000
—
10169.82
9
UP
2
—
110054
—
7944
2
Haryana
2
—
324556
—
533.21
1
Overview of Status of clearance of projects in North India
TOR & EC Status
Nos
MW
CCA
MLD
Land Req
Land Req Info available for projects
TOR approved
50
12823
202586
—
21005.36
44
TOR not approved
1
300
0
—
72
1
TOR Waiting
6
1986
32000
—
4959.57
4
TOR approved before this committee
15
2978.5
382326
145
3895.85
13
Env Cl. Recommended
31
6843.5
352888
—
14793.77
27
Env Cl. Waiting
3
171
232024
—
648.47
2
Env Clearance not Recommended
0
0
0
0
0
0
Basin-wise overview of projects in North India
Projects on basins
Nos
MW
CCA
MLD
Bhilangana (Ganga)
1
22.5
—
—
Alaknanda (Ganga)
10
1931
—
—
Sarda (Ganga)
5
870
150302
145
Yamuna (Ganga)
15
1010
381556
—
Ramganga (Ganga)
1
0
53,054
—
Ganga
1
530
—
—
Ganga total
33
4363.5
—
—
Beas
6
930
—
—
Chenab
19
9733
—
—
Sutlej
8
2012
—
—
Ravi
5
956
32000
—
Jhelum
1
93
—
—
From the above tables it is clear that while largest number of projects from North India came from Ganga Basin at 33, the installed capacity of projects proposed in Chenab basin is highest at 9733 MW.
NORTH EAST INDIA
TOR & Environment Clearance status in North-East India
The region comprises of eight states including Arunachal Pradesh, Assam, Manipur, Meghalaya, Mizoram, Sikkim, Tripura and Nagaland. The Highest number of projects (99) has come to EAC from the North East region, and the highest number of first stage clearances at 70 have been given by EAC from this region. Within the North East Region, by far the highest number of projects (69) have come to EAC from Arunachal Pradesh. The EAC has the highest approval % in Arunachal Pradesh, every project has been given approval. Only for the 420 MW Kameng HEP of KSK Ltd, the EAC asked the developer to come back with reformulated proposal, rest were all given approval by the EAC. Over 35000 MW of hydropower projects have come to EAC from Arunachal Pradesh alone, by far the highest in the country for any state. Maximum no of projects that came to EAC among all river basins is from Siang basin at 21, though in terms of installed capacity, the highest installed capacity has come from Lohit basin at 10250 MW, among all the sub basins in the region. It was amazing to see the EAC promptly clearing the controversial Tipaimukh project way back in 2008, but the project is yet to get forest clearance and is unlikely to be able to start work in near future.
Purpose: H- Hydropower; I- Irrigation; M- Multipurpose.; NA- Not available
State-wise Overview of Projects in North-East India
Projects
Ins Cap
Irrigation
Land Req
Land requirement info available for projects
State wise Projects
Nos
MW
CCA (Ha)
(Ha)
Nos
Total Projects
99
46658
—
76768.27
72
ARP
69
35474
—
36454.34
56
Sikkim
14
3274
—
510.37
6
Meghalaya
9
1488
—
5345
6
Manipur
2
1566
—
32161.57
2
Assam
2
210
—
1577
1
Nagaland
1
186
—
NA
0
Mizoram
1
460
—
720
1
Multi state
1
4000
400000
NA
0
Overview of Status of clearance of projects in North East India
TOR & EC Status
Nos
MW
CCA
Land Req
Land Req Info available for projects
TOR approved
70
31541
—
31180.47
55
TOR not approved
1
420
—
3764
1
TOR Waiting
16
9301
400000
8223.2
6
TOR approved prior to this EAC
12
4940
—
33600.6
10
Env Clearance Recommended
17
8256
—
35682.58
15
Env Clearance Waiting
2
1320
—
324
1
Env Clearance rejected
0
0
0
0
0
Basin-wise overview of projects in North East India
Projects on basins
Nos
MW
CCA
Lohit
10
10250
—
Siang
21
6766
—
Kameng
14
4060
—
Kopili
7
676
—
Teesta
14
3274
—
Sankhosh
1
4000
400000
Myntdu
2
406
—
Dikhu
1
186
—
Barak
4
2266
—
Dibang
9
8615
—
Tawang
9
2757
—
Subansiri
3
3960
—
Kolodyne
1
460
—
Pare
3
186
—
EAST INDIA
TOR & Environment Clearance status in East India
The region comprises of Bihar, W Bengal, Jharkhand, Chhattisgarh and Orissa. Among all regions, the least number of projects came to EAC from Eastern region at 20. Interestingly, not one project from Jharkhand has come to the EAC in this period. However, TOR clearance given for the 16.54 lakh CCA in this region is highest among all states and total proposed CCA among all regions is second highest for the Eastern region. This highest contribution for this large CCA from the Eastern region is coming from the proposed Saptakoshi High Dam at 15 lakh Ha (of which 9.76 lakh ha is supposed to be in India), the project also has the highest proposed installed capacity (3000 MW), but that project is supposed to come up in Nepal and there is little likelihood of the project going ahead in near future.
Purpose: H- Hydropower; I- Irrigation; M- Multipurpose.; NA- Not available
State-wise Overview of Projects in East India
Projects
Ins Cap
Irrigation
Land Req
Land Req Info available for projects
State wise Projects
Nos
MW
CCA (Ha)
(Ha)
Nos
Total Projects
20
3684
1279960
16809.24
9
West Bengal
7
404
181700
5729
3
Orissa
8
100
74460
1912.73
3
Bihar
2
3130
976000
7,595.35
1
Chhattisgarh
3
50
47,800
1572.105
2
Overview of Status of clearance of projects in East India
TOR & EC Status
Nos
MW
CCA
Land Req
Land Req Info available for projects
TOR approved
10
3434
1654340
15810.185
6
TOR not approved
0
0
0
0
0
TOR Waiting
3
130
29000
927.05
2
TOR approved before this committee
7
120
120620
72
1
Env Clearance Recommended
7
120
120620
72
1
Env Clerance Waiting
1
130
0
7595.35
1
Env Clearance not Recommended
0
0
0
72
1
Basin-wise overview of projects in East India
Projects on basins
Nos
MW
CCA
Teesta
4
404
0
Mahanadi
6
100
105900
Brahmani
3
0
16090
Rushikulya
1
0
270
Kosi
2
3130
1500000
Hoogly
2
0
67500
Subernrekha
1
0
114,200
Son
1
50
0
WEST INDIA
TOR & Environment Clearance status in West India
49 projects came to EAC from this region (comprising of states of Gujarat, Maharashtra, Madhya Pradesh, Rajasthan and Goa), most of them were irrigation projects, unlike the situation in North and North East India where most projects that came to EAC during the study period were hydropower projects. Out of these, land availability figures are available only for 14 projects, the least % of the total projects compared to all regions. Land availability figure for none of the 20 projects of MP is mentioned in the EAC minutes. Within the region, highest number of 21 projects came from Maharashtra and close second was Madhya Pradesh. Maharashtra incidentally has the largest number (10) of giant lift irrigation schemes coming for approval before the EAC. Two of the biggest projects came up before the EAC were from Gujarat, the Kalpsar (Gulf of Khambat Development Project) and Par Tapi River Link Project. It was strange to see the EAC clearing the Par Tapi Narmada and the Ken Betwa Phase 1 river link proposals, both for TOR clearance. Both are facing strong opposition. Stranger it is to see the EAC noting in a latter meeting that the MoEF has conveyed to NWDA that the Ken Betwa Phase I link proposal cannot be cleared due to huge submergence it will entail in the Panna Tiger Reserve. Why did the EAC not review its decision regarding the TOR clearance in that case? Parwan irrigation project in Chambal basin in Rajasthan is another project that is facing massive opposition on ground, but the EAC has recommended it for final clearance. Even more shockingly, in its meeting on Nov 20, 2008, EAC opined that the Damanganga Pinjal link (involving several massive dams) does not require any environment clearance since it is a drinking water project. Its clear from these decisions how callous has been the treatment of the EAC to such massive projects.
SN
Project
State
Basin
I/H/M
Ins Cap (MW)
CCA (Ha)
TOR
Meeting date
Env Clearance
Meeting date
Total Area Req (Ha)
Gujarat (GJ)
1
Gulf of Khambat development project
GJ
Multiple
M
–
NA
Waiting
25/09/2010
–
–
–
Maharashtra (MH)
2
Ajansara Barrage
MH
Godavari
I
–
30004
Approved
18/03/2008
–
–
NA
3
Dhapewada LIS-II
MH
Godavari
I
–
67,506
Approved
22/08/2008
Recommended
21/12/2010
NA
4
Upper Penganga Project Stage -II
MH
Godavari
I
–
28,600
–
–
Recommended
2/6/2011
NA
5
Upper Pravara Irrigation Project
MH
Godavari
I
–
64260
Waiting
20/09/2007
–
–
3504
6
Kanhan River Project
MH
Godavari
M
–
–
Approved
14/05/2009
Recommended
12/11/2011
1434.54
7
Malshej Ghat Pumped Storage Sch
MH
Kalu
H
600
–
Approved
22/08/2008
–
–
511.06
8
Ekrukh Lift Irrigation Scheme
MH
Krishna
I
–
25,240
Approved
17/07/2010
–
–
NA
9
Expansion of Krishna – Koyna LIS
MH
Krishna
I
–
40219
–
–
Recommended
16/06/2009
NA
10
Janai Shirsai Lift Irrigation Scheme
MH
Krishna
I
–
14080
Waiting
22/08/2008
–
–
NA
11
Jihe Kathapur Lift Irrigation
MH
Krishna
I
–
27500
–
–
Recommended
8/5/2008
218.46
12
Krishna Marathwada Irrigation Prjct
MH
Krishna
I
–
92141
Approved
16/10/2008
–
–
2819.7
13
Purander Lift irrigation
MH
Krishna
I
–
21500
Approved
15/11/2007
–
–
NA
14
Shirapur Lift Irrigation Scheme
MH
Krishna
I
–
10,000
Waiting
26/12/2012
–
–
507.43
15
Thembu Lift Irrigation Project
MH
Krishna
I
–
–
–
Recommended
19/07/2007
NA
16
Wakurde Lift Irrigation Scheme
MH
Krishna
I
–
28,035
–
–
Recommended
17/07/2010
865
17
Humbarli Pumped Storage Scheme
MH
Krishna
H
400
–
Approved
19/08/2009
–
–
NA
18
Augmnetation Project at Bhira
MH
Krishna
H
100
–
Waiting
19/07/2007
–
–
NA
19
Bodwad Parisar Sinchan Yojana
MH
Tapi
I
–
42,420
Approved
17/02/2009
Recommended
19/02/2012
1729.64
20
Kurha Badoda Islampur Upsa
MH
Tapi
I
–
14586
Approved
20/03/2009
–
–
NA
21
Lower Pedhi irrigation project
MH
Tapi
I
–
12230
Recommended
14/12/2007
2532
22
Lower Tapi LIS
MH
Tapi
I
–
54500
Approved
30/06/2010
Waiting
26/12/2012
6913.25
Madhya Pradesh (MP)
23
Kundaliya Major Irrigation Project
MP
Chambal
M
–
–
Approved
27/12/2011
–
–
NA
24
Mohanpura Major Irrigation Project
MP
Chambal
M
–
65000
Approved
17/12/2011
–
–
NA
25
Punasa Lift Irrigation Scheme
MP
Narmada
I
–
35008
–
–
Recommended
26/05/2007
NA
26
Sip Kolar Medium Irrigation Project
MP
Narmada
I
–
6400
Approved
12/10/2012
–
–
NA
27
Upper Narmada Project
MP
Narmada
I
–
21276
Approved
18/04/2007
Recommended
19/08/2009
NA
28
Halon Irrigation Project
MP
Narmada
I
–
16782
–
–
Recommended
16/11/2009
NA
29
Integrated Raghavpur, Rosara, Basania with Bargi Multipurpose Prjt
[7] SANDRP had written to EAC about the glaring errors in the minutes of the 60th and 61st meetings of the EAC, pointing out the errors in capacities, names of places and even names of river in the minutes, but the EAC neither acknowledged the letter or errors, nor bothered to correct them.
[9] EAC has remained on rather steep learning curve on a number of issues, including on Environmental flows. It first questioned the wisdom or need for e-flows, than graduated to recommending 10% of minimum lean season flow, than 15%, later changing to 20% and now it has a little more detailed norms, still far from asking for actual assessment for each river stretch.
[11] Both the documents authored by Himanshu Thakkar and Bipin Chandra Chaturvedi, Bipin has done the detailed compilation for the two documents. Thanks a due to Parineeta Dandekar (for all the charts in addition to valuable comments, Dr Latha Anantha, Shripad Dharmadhikary and Neeraj Vagholikar for some very useful comments and suggestions.
[13] Clearance sought for adding the third 42 MW unit to the existing 84 MW project.
[14] The project is listed here since it came back before the EAC in Feb 2010 as it had yet to get NBWL clearance.
[15] The TOR clearance was only for the irrigation component in India, the main dam, barrage and headwords will all be in Nepal, which is beyond the jurisdiction of EIA notification 2006 of India.
[16] Part of Ken Beta Link River Link project phase II
[17] The Polavaram project got Environment Clearance in Oct 2005, however, came back to EAC for clearance of the embankments in Orissa and Chhattisgarh as these were not part of the proposal cleared by EAC. The Ministry of Environment and Forests had asked the project authority to get these components cleared and hence the embankment portion came to EAC for clearance. The EAC noted that there has been no public hearings conducted in Orissa and Chhattisgarh as required under EIA notification and asked project authorities to come back to EAC after conducting the public hearings. The project authorities have yet to comply with this requirement and hence the clearance to the project is yet to be recommended by the EAC.
[18] The Athirapally project, following directions by Kerala High Court to KSEB (the MoEF show cause notice of Jan 4, 2010 could also be a factor, but there is no mention of that in the EAC minutes), came back before EAC in March 2010 and was again discussed in April 2010 and July 2010, till when no conclusion could be reached by EAC and EAC had asked for more information and clarifications. There is no mention of the project in any of the subsequent minutes of meetings.
SANDRP 
