Expert Appraisal Committee · Ministry of Environment and Forests

Reconstituted Expert Appraisal Committee on River Valley Projects: MoEF has neither environment sense, nor guts: Unacceptable Committee

Press Statement                                                                                             September 7, 2013

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.

Ritwick Dutta (ritwickdutta@gmail.com, 09810044660, ERC and LIEF, Delhi)

Parineeta Dandekar (parineeta.dandekar@gmail.com, 09860030742, SANDRP, Pune)

Himanshu Thakkar (ht.sandrp@gmail.com), 09968242798, SANDRP, Delhi)

Manoj Mishra (yamunajiye@gmail.com, 09910153601, YJA, Delhi)


[2] http://environmentaljusticetv.wordpress.com/2013/02/25/greenpeace-india-protest-at-the-coal-ministry/

—

FOLLOWING LETTER HAS BEEN SENT ON SEPT 9, 2013:

9 Sept 2013

To,

Smt. Jayanthi Natarajan,

Union Minister of State (IC) of Environment and Forests,

Paryavaran Bhawan, Lodhi Road, New Delhi, jayanthi.n@sansad.nic.in

 

Dr V Rajagopalan,

Secretary,

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;

2. A participatory process be initiated for reconstitution of the EAC with the norms some of suggested in our letter to you dated June 29, 2013, see: https://sandrp.wordpress.com/2013/06/29/lessons-from-uttarakhand-disaster-for-selection-of-river-valley-projects-expert-committee/;

3. The EAC meeting slated for Sept 23-24, 2013 should be cancelled.

 

We will look forward to early reply from you.

 

Thanking you,

 

Prof. M. K. Prasad, Kerala Sastra Sahitya Parishad, Cochin prasadmkprasad@gmail.com

Ramaswamy R. Iyer, former secretary, Government of India, Delhi. ramaswamy.iyer@gmail.com

Madhu Bhaduri, former ambassador, Delhi. madhu.bhaduri@gmail.com

Ravi Chopra, People’s Science Institute and member NGBRA, Dehra Doon psiddoon@gmail.com

Ritwick Dutta, ERC and LIEF, Delhi.  ritwickdutta@gmail.com

Manoj Mishra, Yamuna Jiye Abhiyaan, Delhi yamunajiye@gmail.com

Prof. S. Janakarajan, Madras Institute of Development Studies, Chennai, janak@mids.ac.in

Vimal Bhai, MATU jansangathan, Uttarakhand bhaivimal@gmail.com

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, manthan.shripad@gmail.com

10. Latha Anantha, River Research Centre, Kerala latha.anantha9@gmail.com

Sujit Patwardhan, Parisar, Pune patwardhan.sujit@gmail.com

Debi Goenka, Conservation Action Trust, Mumbai debi1@cat.org.in

Souparna Lahiri, All India Forum of Forest Movements, Delhi. souparna.lahiri@gmail.com

Rohit Prajapati, Paryavaran Suraksha Samiti, Gujarat   – rohit.prajapati@gmail.com

Soumya Dutta, Climate & Energy Group, Beyond Copenhagen collective, Delhi soumyadutta_delhi@rediffmail.com

Joy KJ, Society for Promoting Participative Ecosystem Management, Pune joykjjoy2@gmail.com

Anurag Modi, Shramik Adivasi Sangathan, Betul, Madhya Pradesh sasbetul@yahoo.com

Dr Brij Gopal, Centre for Inland Waters in South Asia, Jaipur, brij44@gmail.com  

Rahul Banerjee, Dhas Gramin Vikas Kendra, Indore rahul.indauri@gmail.com

20. Subhadra Khaperde, Kansari Nu Vadavno, Indore subhadra.khaperde@gmail.com

Shankar Tadwal, Khedut Mazdoor Chetna Sangath, Alirajpur shankarkmcs@rediffmail.com

Samantha Agarwal, Chhattisgarh Bachao Andolan, Raipur, Chhattisgarh. samsnomadicheart@gmail.com

Dr V Rukmini Rao, Gramya Resource Centre for Women, Secunderabad. vrukminirao@yahoo.com

Tarun Nair, Researchers for Wildlife Conservation, Bangalore. tarunnair1982@gmail.com

Shankar Sharma, Mysore shankar.sharma2005@gmail.com

C.G. Madhusoodhanan, Research Scholar,Indian Institute of Technology Bombay madhucg@gmail.com

Pushp Jain, EIA Resource and Response Centre, New Delhi ercdelhi@gmail.com

Gopakumar Menon, Wildlifer, Bangalore. gopakumar.rootcause@gmail.com

Gopal Krishna, Toxics Watch Alliance, Delhi. gopalkrishna1715@gmail.com

30. Jai Sen, CACIM, New Delhi, jai.sen@cacim.net

Samir Mehta, International Rivers, Mumbai samir@internationalrivers.org

E Theophilus, Malika Virdi, K Ramnarayan, Himal Prakriti, Munsiari, Uttarakhand, etheophilus@gmail.com

Neeraj Vagholikar, Kalpavriksh, Pune, nvagho@gmail.com

PT George, Intercultural Resources, Delhi, ihpindia@gmail.com

Akhil Gogoi, President, Krishak Mukti Sangram Samiti, Assam, secretarykmss@gmail.com

Subir Bhaumik, Veteran Journalist and author of “Troubled Periphery: Crisis of India’s Northeast” (Sage, 2009), sbhaum@gmail.com

Ravindra Nath, Rural Volunteers Centre (RVC), Akajan, Dhemaji, Assam, rvcassam@gmail.com

Sanjib Baruah, Professor, Bard College, New York, baruah@bard.edu

Shashwati Goswami, Associate Professor, Indian Institute of Mass Communication, shashwati.goswami@gmail.com

40. Mrinal Gohain, ActionAid, Guwahati, mrinalgohain@gmail.com

Keshav Krishna Chatradhara, Peoples Movement for Subansiri & Brahmaputra Valley (PMSBV), Assam, pmsv_subansiri@yahoo.com

Girin Chetia, North East Affected Area Development Society, Jorhat, Assam, neadsjorhat@gmail.com

Azing Pertin, Echo of Arunachal, Arunachal Pradesh, azingp@gmail.com

Parag Jyoti Saikia, SANDRP, Delhi.

Parineeta Dandekar, SANDRP, Pune. parineeta.dandekar@gmail.com

Additional names in letter sent independently by CORE (namdithiu@coremanipur.org on 190913) :

46. Centre for Organisation Research and Education (CORE)

Reformed Education and Development Society (READS) Manipur

Forum for Indigenous Perspective and Action (FIPA)

Action Committee  Against Tipaimukh Project (ACTIP)

50. All Loktak Lake Areas Fishermen’s Union Manipur (ALLAFUM)

All Manipur Thanga People’s Welfare Association (AMTPWA)

Rural Education and Action for Change Manipur (REACH-M)

All Tribal Women Organisation(ATWO)

Weaker Section Development Council(WSDC)

Rongmei Luh Phuam (Assam, Manipur and Nagaland)

REACHOUT North East

River Basin Friends North East

58. Anthony Deb Barma of Borok Peoples’ Human Rights Organisation (BPHRO), Tripura

Himanshu Thakkar, South Asia Network on Dams, Rivers & People, c/o 86-D, AD block, Shalimar Bagh, Delhi)ht.sandrp@gmail.com

Disasters

Uttarakhand Floods disaster: Lessons for Himalayan states

Many in the media and outside are calling the current Uttarakhand floods disaster of huge but as yet unknown proportions as Himalayan Tsunami somewhat erroneously. By that very name, we connect the combined fate of all Himalayan states and lessons that are inherent that other Himalayan states need to learn from this tragedy.

Similarities between Uttarakhand and Himalayan state like Arunachal Pradesh In fact one article[i] has already been written that draws some parallels, predicting what Uttarkhand experiences today[ii], Sikkim may tomorrow and Arunachal day after. The article did not realize that Himachal Pradesh and Jammu & Kashmir are ahead of North East in this queue. Indeed there are a lot of similarities between the situation in Uttarakhand and Arunachal Pradesh in particular and Himalayan states in general:

A view of the under-construction dam tunnels at the site of National Hydroelectric Power Corporation's 2000 megawatt Subansiri Lower hydroelectric project in Arunachal Pradesh state, India, Friday, Aug. 21, 2009. It is the biggest hydroelectric power project in India, located on a disputed border between Arunachal Pradesh state and Assam state. (AP Photo/Anupam Nath)
A view of the under-construction dam tunnels at the site of National Hydroelectric Power Corporation’s 2000 megawatt Subansiri Lower hydroelectric project in Arunachal Pradesh state, India, Friday, Aug. 21, 2009. It is the biggest hydroelectric power project in India, located on a disputed border between Arunachal Pradesh state and Assam state. (AP Photo/Anupam Nath)
  • Both Himalayan hill states are fragile, part of new mountain that is prone to high intensity rainfall events, including cloud bursts. In fact the average rainfall in Arunachal Pradesh is much higher than that in Uttarakhand.
  • Both states are also prone to flash floods and landslides.
  • Both states are home to very large number of rapidly flowing silt laden rivers that can turn into ravaging, eroding, force of destruction if not handled carefully. Again Arunachal Pradesh has much large number of major rivers than Uttarakhand. Arunachal rivers are also known to carry more silt than Uttarakhand rivers.
  • Both states are in seismically active area in zone IV and V, with tectonic activities that can lead to impact on land, rivers, increasing the disaster potential.
  • Both states have very high proportion of area under forests, which is necessary for the sustained existence of the local environment, people and biodiversity. Livelihood and water security of people in both states majorly depends on these natural resources.
  • Both states are prone to climate change impacts in major way, Himalayas have already seen increase in temperature that are 2-3 times higher than the average global temperature rise of 0.9° C. These climate change impacts include greater frequency of high intensity rainfall, including cloud bursts that can also increase the potential of landslides and flashfloods.
Broken flood protection walls, Karcham Wangtoo a few km downstream of dam_10.11.2010
Broken flood protection walls, Karcham Wangtoo Hydel Project, Himachal Pradesh a few km downstream of dam. Photo: SANDRP Partners

Lessons from Uttarakhand tragedy Some of the lessons that Uttarakhand and other Himalayan states can draw from the current tragedy include:

  • Ensure credible environmental and social impact assessment of all activities including all dams and all hydropower projects of above 1 MW capacity, such assessments should also include how the projects can increase the disaster potential of the area, how they will affect the adaptation capacity of the local people in the context of climate change, how the projects themselves would be affected in changing climate, among other aspects. Currently, we do not have credible environmental and social impact assessment for any project.
  • Ensure credible environmental compliance mechanism in place for each project in which local people have a key role. Today we have NO credible environmental compliance in place.
  • No projects should be cleared until and unless there is credible cumulative impact assessment for all projects in any river basin and sub basin, which includes carrying capacity study. None of this was done in Uttarakhand and none is in place in any river basin of Arunachal Pradesh.
  • An urgent review of under construction and under planning projects should be taken up, stop projects awaiting such a review. The review should include various environment and river governance policies. Moratorium on dams and hydropower projects til above conditions are satisfied. 
  • Certain rivers and certain high risk zones should be declared as no project areas in each basin.
  • In any case, there should be at least 5 km of free flowing rivers between any two projects. At least 50% of river flows in lean season and at least 30% of river flows in monsoon should be released on daily changing as environmental flows as recommended by IMG recently, pending project and river specific studies. This should be applicable for all projects, including existing and under construction projects.
  • Put in place system of early warning, forecasting and dissemination for all kinds of disasters, particularly those related to rainfall and landslides. It is technologically feasible to predict even cloud bursts at least 3 hours in advance, a Doppler radar system was sanctioned for Uttarakhand since 2008 that would have enabled that, but due to lack of coordination between NDMA, IMD and Uttarakhand government, this was not in place.
  • Put in place a clearly defined monitoring system in place that will give prompt report of actual rainfall events even as the event starts so that the downstream area people and administration can be alerted. This again was absent in Uttarakhand.
  • Protection and conservation of rivers, riverbeds and flood plains, including aquatic biodiversity.
  • Do not allow encroachment of riverbeds and floodplains.
  • Prepare clearly defined space for rivers, have river regulation zone in place and remove all illegal encroachments in river beds and flood plains in a time bound manner urgently through legislative, followed by executive action.
  • Do not allow unsustainable mining of riverbeds.
  • Do not allow blasting for any development activity (Uttarakhand Disaster Management & Mitigation Centre made this specific recommendation after the Rudraprayag disaster of Sept 2012 that lead to death of 69 people) as such blasting leads to increase in landslides.
  • Protection of catchments including forests, wetlands and local water bodies that can play the role of cushion during high rainfall events.
  • All states, including those in North East must have an active state disaster management authority in place that will have key role in all development decisions.

While rainfall and cloud bursts are natural phenomena, the disaster potential of such events directly depends on what we have done on ground over the years. Uttarakhand, by, allowing indiscriminate building of roads, buildings and hundreds of hydropower projects without doing basic assessments and participatory decision making processes, have allowed the disaster potential of current high intensity rainfall in the state increase manifold. While some in the media are calling this as Himalayan Tsunami, many people of Uttarakhand are seeing it as a trailer of such Tsunami, if Uttarakhand does not wake up, much bigger tragedy may await the state.

Himachal Pradesh, Sikkim and Jammu & Kashmir have gone rather too far down that road, but still can wake up and review its development plans and policies and possibly reduce the disaster potential in the respective states. Similarly Arunachal Pradesh has signed over 150 MOUs for big hydropower projects, each of them will entail big dam, long and huge tunnels, blasting, mining, roads, townships, influx of people, transmission lines and so on, without any credible assessment in place. These projects are being pushed under one pretext of another, including the China bogey.

Hydropower Dams in various stages in Arunchal Pradesh. Photo Courtesy: International Rivers
Hydropower Dams in various stages in Arunchal Pradesh. Photo Courtesy: International Rivers

Other Himalayan states like HP, J&K, Sikkim, Meghalaya, Manipur and Mizoram are following the same footsteps. This is surely an invitation to major disaster that will engulf whole of Himalayan region. For Uttarakhand and all Himalayan states there is still time to learn all the lessons that the Uttarakhand experience offers. This is also applicable to neighboring Himalayan countries like Nepal, Bhutan, Pakistan and China (Tibet).

Teesta_Dam_1
Notice the extensive deforestation and unstability of land at an under construction Teesta Hydel Project in Sikkim

If these are not learnt, what could visit Himalayas could actually make the Uttarakhand disaster like a trailer.

Himanshu Thakkar (ht.sandrp@gmail.com)

Landslides in Sikkim in 2012, following earthquake in 2011. Locals blame these on extensive blasting, tunnelling and deforestation for Teesta Hydropower Projects. Photo: Live Mint
Landslides in Sikkim in 2012, following earthquake in 2011. Locals blame these on extensive blasting, tunnelling and deforestation for Teesta Hydropower Projects. Photo: Live Mint
Tunnel for Teesta VI HEP in Sikkim, blasted in the mountains. Photo: Smair Mehta, International Rivers
Tunnel for Teesta VI HEP in Sikkim, blasted in the mountains. Photo: Smair Mehta, International Rivers
Dams underconstruction and planning in Teesta Basin, Sikkim. Map by SANDRP
Dams underconstruction and planning in Teesta Basin, Sikkim. Map by SANDRP
Tunnelling at the 330 MW KishenGanga HEP, Gurez, Jammu and Kashmir Photo: Panoramia.com
Tunnelling at the 330 MW KishenGanga HEP, Gurez, Jammu and Kashmir Photo: Panoramia.com

 

Cumulative Impact Assessment · Dams · Hydropower · Ministry of Environment and Forests

Upper Ganga Report with Pro Hydro Bias does not do justice to its terms or to Ganga, people or environment

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.

utc20b-A4

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.

ChillaChannel

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.

DryGangaChilla

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
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
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
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
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
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
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
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
Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan

30. IMG on TOR 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.

C. Private sector has been given license for a large number of hydropower projects, not all the projects of Upper Ganga basin here are on IMG list, see for full list of projects being developed by IPPs in Uttarakhand: http://uttarakhandjalvidyut.com/Hydro%20Projects%20Being%20Developed%20by%20IPPs.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.

Himanshu Thakkar (ht.sandrp@gmail.com)

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

Endorsed by:
EAS Sarma, Former Union Power Minister, Visakhapattanam, eassarma@gmail.com

Vimal Bhai, Matu Jansangathan, Uttarakhand, bhaivimal@gmail.com

Malika Virdi, Himal Prakriti, Uttarakhand, malika.virdi@gmail.com

E Theophilus, Himal Prakriti, Uttarakhand, etheophilus@gmail.com

Ramnarayan K,  Save the Rivers Campaign Uttarakhand, ramnarayan.k@gmail.com

Dr Latha Anantha, River Research Centre, Kerala, rrckerala@gmail.com

Parineeta Dandekar, SANDRP, Pune, parineeta.dandekar@gmail.com

Samir Mehta, International Rivers, Mumbai, samir@internationalrivers.org

Tarini Manchanda, Independent film maker, Delhi,  mtarini@gmail.com

 

Current state of our National River at Haridwar  Photo: SANDRP
Current state of our National River at Haridwar Photo: SANDRP

[1] The author is thankful to Parineeta Dandekar, Shripad Dharmadhikary and Samir Mehta among others for providing comments on earlier drafts.

[2] Prof Bharat Jhunjhunwala provided the copy.

[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.

Cumulative Impact Assessment · Dams · Environment Impact Assessment · Hydropower · Ministry of Environment and Forests · Western Ghats

Comments on HLWG Report submitted to Ministry of Environment and Forests

This post is based on a submission made by SANDRP and our colleagues on the HLWG Report on Western Ghats. 20th May 2013 is the last date to submit comments on this. Comments need to be sent to: amit.love@nic.in. We request groups and individuals to make as many submissions as possible.

Comments on HLWG Report with a focus on Water issues

Date: May 20, 2013

To,

 

Mrs. Jayanthi Natarajan

Union Minister of State (IC)

Ministry of Environment and Forests

Government of India

Email: mosefgoi@nic.in, jayanthi.n@sansad.nic.in

 

Dr. V Rajagopalan

Secretary

Ministry of Environment and Forests

Government of India

Email: envisect@nic.in

 

Dr. Amit Love,

Deputy Director,

Ministry of Environment and Forests

Email: amit.love@nic.in

 

Dear Mrs. Jayanthi Natarajan and Dr. Rajagopalan,

 

SUB: Comments on the High Level Working Group Report with respect to water sector

This is in response to announcement posted on MoEF website about submitting comments on the HLWG report under the Chairpersonship of Dr. Kasturirangan. These comments mainly deal with water in Western Ghats: One of the most critical issues for Western Ghats States.

A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP
A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP

Unfortunately, we have to note that recommendations of the HLWG Committee in response to WGEEP Report as well as some of HLWGs omissions and commissions are detrimental to the well-being of rivers, wetlands and dependent communities in the Western Ghats and hence, for related sectors like ecology, water supply, irrigation, hydropower, etc. This is elucidated in the following points:

  1. HLWG does not comment on any other issue related to water except hydropower:

While the Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamilnadu are facing multiple issues with respect to rivers, drinking water, irrigation, loss of biodiversity and livelihoods, dam-induced displacement, etc., the only issue HLWG report has commented upon is Hydropower. The WGEEP report has dealt with a number of issues related to the water sector from democratic community driven bottom up governance, watershed development, opposition to large dams in ESZ I and II, drinking water, fisheries, etc. However, the HLWG does not comment on any of these recommendations of the WGEEP, nor does it offer its own position on these. This is a serious lacuna in the HLWG Report.

In the absence of such recommendations, we request that MoEF adheres to WGEEP recommendations.

Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP
Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP
  1. HLWGs recommendations about Hydropower are ad hoc, unscientific and misleading
  1. HLWG claims that all Hydropower is “renewable and clean.”

This is a completely incorrect statement and it’s surprising to see that it comes from HLWG. The world over, the myth of Hydropower as clean source of energy has been busted.[1],[2] Hydropower projects have huge impacts on environment, ecology, forests, rivers, biodiversity and livelihood security of the people. Studies have proved that methane emissions from reservoirs formed by hydropower dams in tropical countries can have significant global warming potential, methane being about 21 times more potent global warming gas than CO2. Dams emit methane at every draw down.[3] With tropical forests in the Western Ghats (WG) under submergence and otherwise destruction by such projects, this threat is even more serious. Already WG has some of the biggest hydropower plants in the country including the Koyna, Bhandardara, Ghatghat HEPs and three Tata HEPs in Maharashtra, Linganmakki, Gerisouppa, Bhadra, Tungabhadra, Upper Tunga, Talakalale, Kabini, Harangi, Chakra, Supa, Varahi, HEPs in Karnataka, Idukki, ldamalayar, Lower Periyar, Poringalkuttu, Sholayar HEPs in Kerala and Bhavani HEPs in Tamil Nadu. All these projects have not only contributed to greenhouse gas emissions, but have also adversely affected communities, forests, rivers and ecosystems in Western Ghats. There are numerous pending cases of rehabilitation from these dams (for example Koyna in Maharashtra) till date involving tens of thousands of people and communities in many areas are still suffering from erratic water releases from these projects (downstream communities near Jog Falls d/s Linganmakki).

Hydropower dams in WG are in many cases transferring water across the basin for power generation, making it unavailable of the original basin and its inhabitants (For example:  Interbasin transfers from Koyna and Tata Hydropower dams in Maharashtra). Every hydropower project has finite life. Thus, for the basin dwellers and everyone else, Hydropower not much renewable either.

 HLWG is not justified in giving a ‘clean and renewable’ certificate to hydropower.

Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP
Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP

 

  1. HLWG allows Hydropower projects in ESAs while not looking at performance of existing projects

While the WGEEP did not allow large dams and hydropower projects in ESZ I and II, HLWG has allowed hydropower projects in its demarcated ESAs. This is unacceptable. Western Ghats are already ravaged by dams and at least the areas of high biodiversity value should now be protected from the same onslaught. But the HLWG has rejected WGEEP recommendations about this. While doing so, they have not looked at the performance of the existing HEPs in WG. SANDRP has been studying performance of HEPS in India for some time now based on generation data from Central Electricity Authority. The performance of existing hydropower plants in WG is dismal as can be seen below:

  • In Koyna Basin, the per MW generation in 2010-11 has dropped by a huge 56.79% from the highest per MW generation achieved in the year 1994-95.[4]
  • In Kali Nadi projects, the per MW generation has dropped by 46.65% from the highest per MW generation achieved in 1994-95[5]
  • In Sharavathi Basin projects, per MW generation in 2010-11 has dropped by 37.60% from the highest per MW generation achieved in the year 1994-95[6]
  • Same situation is true for most other hydropower projects.
  • Most of these projects are performing far below the level at which the projects were given techno-economic clearances.
  • There is no assessment as to how much of the generation from such hydropower projects is during peaking hours. Nor is there any attempt at optimising the peaking power from these projects.

It is clear that there is huge scope to make the existing projects more efficient, rather than destroying ESAs in WG with more projects.

We request that in line with WGEEP report, large dams should not be permitted in ESAs of Western Ghats.

  1. Recommendation about mitigating impacts of Hydropower are extremely weak
  • The HLWG has recommended 30 % of lean season flow as the minimum flow throughout the year as a conditionality for allowing hydro power projects in the ESA. This is contradictory to the recommendation for ecological flows by the HLWG.  Ecological flows means trying to mimic the natural flow regime in the river as far as possible and that would include arriving at different seasonal flows based on studies and consultation with the river communities and other stakeholders, using the Building Block Methodology which even the Inter Ministerial Group on Ganga Basin has said is the most appropriate for India. Moreover, the IMG has recommended 50% releases in lean season flows, applicable for all existing projects. MoEF should accept these norms immediately for all existing projects.

The MoEF should be recommending ecological flows / environmental flows as in the WGEEP report and not minimum environmental flows and this should be determined through holistic methodologies like Building Block Methodology and local participation.

  • The HLWG recommendation of 3 km minimum distance between dams is totally ad hoc, arbitrary and hence unacceptable. Firstly, the HLWG should have mentioned min 3 km of flowing river between projects. The minimum distance is river specific and would depend upon a basin level study of the river including the altitudinal profile of the river, the riparian forest status, the aquatic habitats and biodiversity, the present dependability and many such criteria. More significantly, the cascade hydropower dam menace which is destroying rives in Himalayas need not be replicated in western ghats. We would like to reiterate that no large dams should be allowed in the ESA of WG.

The MoEF should recommend for arriving at river specific studies while accepting 5 km of free flowing river between projects as minimum distance of free flowing river between projects. The best case is not to allow any further large dams in Western Ghats.

 

No flows in Sharavathy downstream Linganmakki  Dam and Jog Falls. Photo: SANDRP
No flows in Sharavathy downstream Linganmakki Dam and Jog Falls. Photo: SANDRP

 

  1. The HLWG does not stress the need for Environmental Clearance for Mini hydel Projects

Hydro projects less than 25 MW are currently exempt from Environmental Clearance due to a dangerous omission in the EIA Notification 2006. WG is currently facing a severe threat due to a flood of these unplanned cascades of Mini Hydel Projects. Ecosystems and communities in rivers like Netravathi, Kumaradhara, Krishna and Cauvery are facing impacts of these projects, many of which are fraudulent.[7] Netravathi has more than 44 mini hydel projects planned and under operation. Kerala has plans to set up  around 100 mini Hydel projects on its rivers. The threat of these projects on river systems in Western Ghats is so high that in March 2013, the Karnataka High Court, has banned any new mini hydel projects in Karnataka Western Ghats[8].

WGEEP had recommended no mini hydel projects in ESZ I and II. HLWG has not done this. While the HLWG makes a rather vague statement “There is a need to redesign and reevaluate small hydropower projects – below 25 mw as these often have limited impact on energy generation and can lead to huge impacts on ecology’, it has not recommended that these projects should need an EIA and EC process, like it has said for Wind Energy. This is a very serious omission. SANDRP and many organizations have written about this to the MoEF several times.

The MoEF should amend the EIA Notification 2006 and include all hydel projects above 1 MW in its purview.

 

Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
  1. The HLWG does not stress the need of Environmental Clearance (EC) for Drinking Water and Industrial supply dams

HLWG has not looked at water as a sector, but has only confined itself to hydropower. This has resulted in several loopholes. Many dams are being constructed in Western Ghats for Drinking Water and Industrial water supply. These are also exempt from EC process as per the EIA Notification 2006. Dams like Kalu, Shai, Balganga, Khargihill, Pinjal, Gargai are set to submerge more than 6000 hectares of forest in ESAs and Protected Areas in Northern Western Ghats in Maharashtra.

WGEEP Report had recommended no large dams in ESZ I and II, but the HLWG does not talk about these dams at all. Their impacts on WG forests and communities are entirely ignored. This is another serious lapse of the HLWG report.

The MOEF should amend the EIA Notification 2006 to include all large dams, irrespective of the purpose, including drinking and industrial water supply dams in its purview. No large dams should be planned in ESA of Western Ghats.

 

Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP
Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP
  1. HLWG does not recommend eflows from existing projects

Several hundreds of Irrigation, water supply, hydropower dams have transformed the nature of rivers and dependent communities in Western Ghats. While the WGEEP Report mentioned maintaining eflows from existing projects, the HLWG does not make any recommendation for eflows from existing projects.

Hydropower projects in Karnataka like Kali, Linganmakki have affected communities and ecosystems in the region, have driven some species to extinction. There is an urgent need to restore eflows in all WG rivers.

The MoEF should recommend that eflows should be assessed with holistic and participatory methodology like BBM and recommend e-flows for all dammed rivers in Western Ghats with time limit of one year.

  1. HLWG does not apply its mind to dam decommissioning

The HLWG has chosen to ignore the recommendations on dam decommissioning. While the states have rejected the recommendation the MoP (Ministry of Power) and Central Electricity Authority has noted that dam decommissioning in a phased manner is worth considering.

There are several irrigation and hydropower dams in the Western Ghats which are severely underperforming or incomplete after two decades, or more than 100 years old, and/or unsafe. For example, several experts have opined than large irrigation projects in Konkan region of Maharashtra are severely underutilized. Tillari Interstate Project between Maharshatra and Goa which has come up affecting a wildlife corridor and which has still not rehabilitated its affected population, has a created irrigation potential of 7,295 hectares in Maharashtra of which farmers are utilizing just 162 hectares, according to the Govt Of Maharashtra’s 2012 White Paper on Irrigation Projects in Maharashtra. This underlines the redundancy of large irrigation projects in the WG.

The HLWG had an opportunity to relook at such projects, which it has not done. The HLWG could have noted that the state governments and the MoEF and MoP should start the process of evolving parameters / criteria towards the process of dam decommissioning.

The MoEF may please recommend the same.

Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror
Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror

 

  1. HLWG does not recommend free flowing rivers for WG

Rivers in Western Ghats are repositories of biological, ecological and cultural diversity. Rivers in WG harbor high endemism and diversity in freshwater fish. They also house several Sacred groves at river origins, river fish sanctuaries, etc., protecting rivers and fish. The freshwater biodiversity remains the most fragmented among all biodiversity and HLWG has taken no note of this state and further risks that freshwater biodiversity faces. The WGEEP had wisely followed a graded approach in tune with the ecological connectivity of river ecosystems. ln the HLWG approach, stretches of rivers would flow out of the natural landscape into the cultural landscape which is open to indiscriminate development and the chance for their restoration or protection would be completely lost out. A river cannot be protected in pieces like this.

Looking at the pressures from dams and water abstractions, there in an urgent need to conserve ecologically, culturally and socially important rivers in their free-flowing condition. This approach is well accepted globally and several countries have created specific legislations for protecting free flowing rivers[9]. It seems that the IMG Committee on Upper Ganga, in which Ms. Sunita Narain (Member of Kasturirangan Committee), was also a member has recommended that some six tributaries of Upper Ganga basin should be kept in pristine state. While rejecting WGEEPs recommendation about dam decommissioning or dam free rivers in the ESZs, HLWG has not recommended keeping even a single river in Western Ghats in its free flowing condition.

MoEF should identify ecologically, culturally and socially important rivers, based on community and ecological knowledge and conserve Heritage Rivers of Western Ghats in their free flowing condition for the current and future generations.

 

Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP
Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP
  1. HLWG allows Inter basin transfers in Western Ghats, without any justification or studies

The HLWG has agreed to inter basin transfers toeing the claims of some of the states. There are ample instances of failed interstate – inter basin transfers in the Western Ghats rivers which have turned into permanent scenes of conflicts like the famous Mullaperiyar,  Parambikulam Aliyar, Siruvani interstate inter basin transfers between Kerala and Tamil Nadu. The HLWG while acknowledging the need for ‘ecological flows assessment’ in rivers has failed to note that in all these inter basin transfers, the river / tributary has been completely diverted and has lost its ‘ecological flows’. The HLWG could have recommended a cumulative impact assessment of the existing inter basin transfers which would reveal the ground reality.

HLWG seems to have accepted the contention of states like Maharashtra: “This (stopping IBT) would be a problem, they explained, as many regions of the Western Ghats lie in the rain shadow area and need water to be diverted for irrigation and drinking.”

Reality is that, ALL the interbasin transfers happening in Maharashtra currently (through Koyna and Tata Hydro power projects, an amount more than 4 Billion Cubic Meters Annually) are transferring water FROM the rain shadow area of Krishna and Bhima basins TO water surplus regions in Konkan. If HLWG was concerned about water supply for rain shadow regions, it would have at least recommended that this transfer from deficit area to high rainfall area be immediately reviewed and reversed in a time bound manner. It has chosen not to, showing its complete ignorance of ground reality or its completely pro government and pro vested interests bias.

The MoEF should retain the recommendation for no more inter basin transfers as in the WGEEP report and ask for immediate review of transfer of water from deficit basins to high rainfall areas. 

 

  1. HLWG allows hydro projects in first and second order streams

The HLWG has not said no to hydro power projects in first and second order streams in ESA. Meanwhile the MoP, CEA and WAPCOS all agree that hydro power projects should not be permitted in these highly ecologically sensitive areas which are the ‘origin’ of Western Ghats Rivers.

The MoEF should retain the recommendation for no run of the river schemes in first and second order streams as in the WGEEP report.

  1. HLWG offers no comments of on several water sector recommendations of WGEEP which have been supported by State Governments

Kerala and Maharashtra have accepted many of the recommendations of the WGEEP in water sector (page 14 section 2.3 – point 9) like catchment area treatment plan, protection of high altitude valley swamps, water conservation measures, rehabilitation of mined areas, improved river flows etc. It is surprising to note that the HLWG is silent on these very important measures and has not even endorsed these acceptable recommendations which can significantly contribute towards improving water availability in the Western Ghats.

The MoEF should follow these recommendations of the WGEEP.

  1. HLWG takes an extremely biased stand about Athirappilly and Gundia Hydropower projects, rejected by the WGEEP

The WGEEP had categorically stated that the Athirappilly and Gundia Hydropower project should not come up in Western Ghats, looking at their huge impacts on biodiversity, several studies by local organisations and local opposition. However, ignoring all these, the HLWG has taken a very pro project stand on these projects, stating that they can be considered with some vaguely due process, which the state government would be happy to show they have followed it on paper. This is entirely unacceptable.

The MoEF should not allow Athirappilly and Gundia HEPs looking their impact on ecology and communities and in face of the strong local opposition that they are facing.

DSC02831
Athirappilly Waterfalls on the Chalakudy River Photo; SANDRP

The WGEEP process and report initiated a robust discussion about the paradigm of development and conservation in Western Ghats. Water and Rivers is a cross cutting issue connecting ecosystems and communities, rural areas and urban centers, providing goods and services and supporting freshwater biodiversity, which is most threatened currently.

A proactive position on conserving rivers in Western Ghats will go a long way in protecting and conserving myriad livelihoods and ecosystems that thus depend of them.

We hope the MoEF considers the recommendations made above about the WGEEP and HLWG Reports and helps conserving rivers of the Western Ghats for people and ecosystems urgently. The HLWG Report cannot be accepted the way it stands presently. As a step in this direction, we also suggest that WGEEP should get a formal chance to respond to the points raised about it in the HLWG.

Thanking You,

 

Yours Sincerely,

Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune (ht.sandrp@gmail.com , parineeta.dandekar@gmail.com)

Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (rrckerala@gmail.com)

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, Maharashtra (manthan.shripad@gmail.com)

Dr. T.V. Ramchandra, Energy & Wetlands Research Group, Centre for Ecological Sciences, IISc, Bangalore (cestvr@ces.iisc.ernet.in)

Janak Daftari, jalbirdari, Mumbai, Maharashtra (daffy@jalsangrah.org)

Sujit Patwardhan, Parisar, Pune, Maharashtra (patwardhan.sujit@gmail.com)

Dr. Nilesh Heda, Samvardhan, Vidarbha, Maharashtra (nilheda@gmail.com)

Nisarg Prakash, Nature Conservation Foundation and Nityata Foundation, Bangalore, Karnataka (nisargprakash@gmail.com)

Mrinalinee Vanarase, Iora Consultants, Pune, Maharashtra (ioraespune@gmail.com)

Shankar Pujari, President, Nivara Bandhkam Kamgar Sangh, Sangli, Maharashtra (shankarpujari16@gmail.com)

Damodar Pujari, SANDRP, Pune, Maharashtra (damodar.sandrp@gmail.com)

Saili Palande-Datar, Kalpavriksha, Pune, Maharashtra

Following Members from Energy and Wetlands Research Group, Centre for ecological Science, Indian Institute of Sciences: 

  • Dr. M.D. Subash Chandran
  • Dr. Prakash Mesta
  • Dr. Uttam Kumar
  • G R Rao
  • Mahima Bhat
  • Vishnu Mukri
  • Sreekanth Naik
  • Balachandran C
  • Boominathan M
  • Bharath H Aithal
  • Bharath Settur
  • Vinay S
  • Ganesh Hegde
  • Anindita Dasgupta
  • Arun D T
  • Vishnu Bajpai
  • Gouri Kulkarni
  • Sudarshan Bhat
  • Durga Madhab Mahapatra
  • Ashwath Naik
  • Sowmya Rao
  • Shwetmala

 

 


Hydropower · Ministry of Environment and Forests

Central Water Commission’s Dam Register: How much do we know about our dams and rivers?


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Central Water Commission is India’s technical organisation under the Union Ministry of Water Resources. It publishes National Register of Large Dams (NRLD), the latest version can be seen at: http://www.cwc.nic.in/main/downloads/New%20NRLD.pdf. This is a key document that provides information about large dams in India.

The latest NRLD seems to have been uploaded only this month, since for a number of states, it claims to have been updated till January 2013. The NRLD is certainly a useful document, the only list of large dams in India and it also gives a number of salient features of the large dams in India. SANDRP has been using this document and also been doing some analysis of the information available in the NRLD.

As per the latest edition, India has 5187 large dams (height above 15 m in most cases, height of 10-15 m case of some with additional criteria). 371 of these dams are under construction and rest have been completed. In case of 194 large dams in NRLD, we do not know the year of construction, which means most of such dams must have been built before independence.

NRLD is not an exhaustive list

NRLD follows the definition of large dams given by the International Commission on Large Dams for inclusion of dams in the NRLD. However, the NRLD is far from exhaustive list of large dams in India. Very significant number of large dams built for hydropower projects in Himachal Pradesh, Uttarakhand, North East India, among other states, do not figure in the list, even though all of these would come under the definition of large dams as given in the NRLD. To illustrate from Himachal Pradesh, following dams are all under construction as per Central Electricity Authority, many of them in advance stages, but they do not figure in NRLD: Allain Duhangan, Kashang, Sainj, Swara Kuddu, Shongtong Karcham, Sorang, Tangnu Romai, Tidong. It’s a dangerous situation for safety issues, since many of them are under construction by private companies. For example, in December 2012 heavy leakage was detected in the surge shaft of the 1000 MW Karcham Wangtoo Project on Sutlej River in Kinnaur district in Himachal Pradesh. The project had to be shut down and the repairs are still going on. Had there been a serious mishap at the project the impact would be also felt by the cascade of projects downstream, including the 1500 MW Nathpa Jakhri HEP (India’s largest operating hydropower project), 412 MW Rampur HEP, 800 MW Kol Dam HEP and the Bhakra complex further downstream.

The case of missing dams

Earlier in 2010 and 2011 we filed a number of applications with the CWC under the Right to Information Act to ask them how a very large number of dams that were listed in earlier NRLD of 1990, 2002 (both printed versions) did not figure in the NRLD 2009 and many of the large dams listed in 1990 also did not figure in NRLD 2002. The CWC response in most cases was to transfer our RTI application to the relevant states, stating that CWC is not responsible for the information in the NRLD, it only compiles the information given by the respective states.

This was far from satisfactory response from India’s premier technical water resources organisation. Was CWC acting only as a post box on even such a serious issue of listing of large dams? It was not applying its mind to the information supplied by the states, not raising any questions, nor clarifying the contradictions and gaps with respect to the earlier editions of NRLD? Needless to add, this reflects very poorly on the CWC. Here it should be added that CWC is also responsible for the monitoring policies and practices related to the safety of dams in India as also a number of other aspects. What kind of diligence can we expect from CWC under these circumstances? Our analysis then also showed that many dams that should have figured in the earlier versions (considering the date of completion stated in the subsequent editions of NRLD) were not there. Again our RTI applications in such cases were transferred to respective states. We did get some response from Central Water Commission and Maharashtra, which was far from satisfactory. In case of over a hundred dams, the CWC Director, Design and Research Coordination Directorate accepted the errors in NRLD and promised that “Data entry errors/ omissions as indicated above will be rectified”.

Where are our dams located?

A quick review of the latest NRLD raises some fresh questions of the NRLD. In this exercise we just wanted to check how many dams are there in different river basins/ sub basins. This is an important question from a number of perspectives including cumulative impacts, optimisation of dam operations, hydrological carrying capacity and cumulative dam safety issues, to name a few. We through this would be simple enough exercise. But when we started looking at the 5187 large dams of India listed in NRLD, we found that in most cases, there is no name for the river on which the dam is constructed. When counted, we were shocked that in case of 2687 or 51.8% of large dams of India, the NRLD does not mention the name of the river. In most cases they just write “local river” or “local Nallah” or the box under river is left blank. Under the circumstances, it is not possible to get a clear picture of any river basin, nor about the cumulative impacts or safety aspects or possibility of optimisation of the dams in any one river basin. The absence of such basic information reflects very poorly on the quality of NRLD, and on the CWC and respective states.

Worst states

India’s largest dam builder state, namely Maharashtra, has the largest number of dams for which it does not know the name or location of the rivers or tributaries. Out of 1845 large dams in Maharashtra, in case of 1243 dams, Maharashtra does not know the name of the rivers! That means in case of 67.37% of its dams, Maharashtra does not even know the names of the rivers. It is not just for the old dams, but even for 81 of the dams completed after 2000, Maharashtra does not know the names of the rivers. Even for relatively larger 61.19 m high Berdewadi dam (completed in 2001) and 48 m high Tarandale dam (completed in 2007), the names of the rivers are now known.

Madhya Pradesh is worse than Maharashtra, it does not know the names of the rivers for 90.17% of its dams (817 dams out of total of 906). In percentage terms, Chhattisgarh is worst as it does not know names of the rivers for 227 of its 259 large dams. These three states of Maharashtra, Madhya Pradesh and Chhattisgarh collectively do not know the names of the rivers for 2287 of dams in NRLD. Some of the other states that should also share the “honours” here are Gujarat (138 dams out of 666 for which names of rivers are not known), Andhra Pradesh (124 out of total of 337) and Rajasthan (71 out of 211 large dams).

It is a disturbing situation that the agencies that are responsible for our large dams do not even know the names of the rivers (every river in India has a name, so if someone were to argue that the rivers do not have names, it won’t be acceptable excuse) on which they are located. Without the names of the rivers and locations of the various dams on specific rivers, we cannot even start looking at the crucial issues like dam safety, cumulative social and environmental impacts, hydrological carrying capacity and optimum utilisation of the storages created behind the dams. We clearly have far to go to even start knowing our dams and rivers.

Himanshu Thakkar (ht.sandrp@gmail.com)

South Asia Network on Dams, Rivers & People (www.sandrp.in, an edited version of this published at: http://indiatogether.org/2013/mar/env-dams.htm) 

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Comments on MWR’s DRAFT HYDRO-METEOROLOGICAL DATA DISSEMINATION POLICY (2013)

 The Union Ministry of Water Resources has invited comments by March 31, 2013 (comments to be sent to: nwp2012-mowr@nic.in) on its Draft Hydro-Meteorological Data Dissemination Policy 2013 based on the document available at: http://mowr.gov.in/DraftHydrometlDataDisseminationPolicy_2013.pdf. This is indeed a welcome move. Since there has been no publicity of this notice, we assume that the policy has just been put up on the MWR website on March 7, 2013.

PREAMBLE The preamble to the policy should also mention that the National Water Mission of 2008 and the Draft National Water Policy 2012 (final version still not available on MWR website, typical of the MWR functioning) also require transparent data sharing policy.

LANGUAGE OF DRAFT POLICY AND PERIOD OF COMMENTS The three week period provided for comments is too brief and the policy is also not available in languages that majority of people of this country speak and understand. This is an issue that is of interest to majority of people of the country. Hence the draft policy should be translated into local languages and disseminated widely before setting a reasonable deadline for inviting comments.

UNCLASSIFIED RIVER BASIN INFORMATION The policy should mandate the MWR, CWC, CGWB, India Meteorological Department and all other organisations that are involved in such data collection to put all unclassified hydro-meteorological information promptly in public domain. This is also the requirement implied by the section 4(2) of the RTI act, which the draft policy quotes. United States Geological Society, the agency of USA that is in charge of gathering such data in the US is making this available to the mobile phone users through a publicly available application, see: http://www.enn.com/ecosystems/article/45658. The qualification now put in section 6.1 of the draft policy that the information even in unclassified basins only after “after validation and to the extent published in Water Year Book, Water Quality Year Book, Water Sediment Year Book, Ground Water Year Book” is clearly unacceptable. CWC takes years to publish its year books and the information cannot be held secret till CWC and CGWB find time to make their year books public. About the validation issue, the information promptly put up can say that this is unvalidated information and validated information an be put up after validation. This is even now standard practice adopted by number of agencies like Central Electricity Authority who put up the “tentative” monthly generation reports first and actual reports later on (see: http://www.cea.nic.in/monthly_gen.html).

CLASSIFIED BASINS INFORMATION It is good to see that there is no blanket ban on making public hydro-met information for the classified river basins and there is some application of mind to make some of it public. However, this is still far from sufficient. In the classified basins section, you can say that following categories of data should be made public:

(1) Data pertaining to any “public interest” project in the basin, public interest being defined as per say the Land Acquisition Act, any project where land is compulsorily acquired;
(2) Data related to any project that is defined as a public project under the RTI Act;

(3) Data related to any project being defined as Category A or B1 projects for EIA under the 2006 EIA Notification;

(4) Data related to any project that requires forest land;

(5) Data related to any irrigation, drinking water, flood control project and data related to any hydropower project as all of them are supposed to be public purpose projects. All information that is necessary for assessing and understanding cost benefit, social and environment impact assessment of hydropower projects, dams, diversions, information necessary for assessing and understanding disaster management plans including dam break analysis and such kind of information should be in public domain.;

(6) Data related to any project or intervention that can cause significant impact on the local populations or ecology, and

(7) Any data or information that is made available to any private developer or commercial interests.

(8) All information about the water flow at smaller sub basins of the classified basin should be in public domain, as this is very useful for all water related planning, decision making and analysis.

(9) All information shared with the neighbouring countries should be in public domain.

(10) Information about functioning of all transboundary cooperation projects, plans and committees should be in public domain.

INFORMATION SHARED BY NEIGHBORING COUNTRIES The policy should also make it clear that information shared by the neighbours with India, particularly relevant for people in terms of information related to floods, water flow and water quality etc should also be promptly available in public domain. What is the use of flood forecasting information if it is not available to those who are in the areas that are vulnerable to flood risks that this information is pertaining to?

ORGANISATIONS OTHER THAN CWC AND CGWB There are a large number of organisations besides CWC and CGWB that are also involved in collecting hydro-met information, including IMD, state government, BBMB, NHPC, NEEPCO, SJVN, THDC and private sector hydropower developers. The policy should be pertaining to all such organisations. All information gathered by IMD should be in public domain, in all basins.

METHODS OF DATA COLLECTION In addition to actual data, the methods of data collection should also be available in public domain, so that the information users can also understand the implications of such methods for the accuracy or otherwise of such data. The methods deployed related reports by CWC, CGWB, MWR and others in ensuring the accuracy of the data, including third party evaluation should also be in public domain.

GOOD OPPORTUNITY This is a good opportunity to make the functioning of the ministry of water resources also transparent, it would hugely help improve the image of the ministry. The National Water Mission and new Draft National Water Policy also talk about making available all relevant policy and document in public domain promptly. However, this is yet to happen. We hope you will give due consideration to these comments and accordingly change the policy.

Himanshu Thakkar, South Asia Network on Dams, Rivers & People (www.sandrp.in), ht.sandrp@gmail.com

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Letter to MoEF: Report on ‘Inviolate’ Forest Areas

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.

Ms. Jayanthi Natarajan

Minister of Environment and Forests

Email: jayanthi.n@sansad.nic.in

 

 2. Dr. V RAJAGOPALAN: Secretary(E&F)

Email: secy-moef@nic.in

 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.

Fragmentation Similarly, 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.

 Sincerely

Himanshu Thakkar (ht.sandrp@gmail.com)

South Asia Network on Dams, Rivers & People, 86-D, AD block, Shalimar Bagh, Delhi 110088 (www.sandrp.in)

Parineeta Dandekar (parineeta.dandekar@gmail.com)

SANDRP, Pune.

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Hilsa is India’s Salmon

Just like Salmon is special to the United States, Hilsa fish is special to Indians. Its declining rapidly. Causes of this decline are well know. Hilsa is anadromous fish and needs to complete its lifecycle from sea to river, which is now impossibles through the hurdle of dams. This article highlights the facts well, however, its sad to see that institutions like CIFRI and ICAR are still not ready or brave enough to tackle the main issue of dams. They are busy funding more research projects about Hilsa. The gap between research and burning reality is widening..

http://www.business-standard.com/article/opinion/surinder-sud-the-right-bait-to-catch-hilsa-113021101361_1.html

SANDRP worked on a report which uniequivocally proved that large dams and infrastaturye projects have been behind fishery collpases in many Indian Rivers: https://sandrp.in/dams/Impacts_of_Dams_on_Riverine_Fisheries_in_India_ParineetaDandekar_Sept2012.pdf

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Freshwater Biodiversity Conservation finds place in Indian Biodiversity Congress!

IBC Recommendation to MoEF: Safeguarding Riverine Biodiversity and ecosystem goods and services of rivers and inland water bodies

http://www.ibconline.co.in/files/IBC_REPORT_AND_RECOMMENDATIONS_2012.doc

Dams, hydropower projects, diversions and hydrological modifications to rivers and inland water bodies are having a huge negative impact on biodiversity and dependent livelihoods across India. Biodiversity Assessments for such projects is nonexistent or fundamentally inadequate or flawed including in in ecological hotspots like Himalayas and Western Ghats. Environmental Impact Assessments are severely flawed. Credible mitigation measures for endangered, threatened, endemic or rare fish and other biodiversity are not in place, even Endangered and iconic species like Ganges River Dolphins are under threat from absence of flows in the downstream and hydrological obstructions. Downstream impacts are neither part of social impact assessment nor part of resettlement and rehabilitation measures. All these  gaps are leading to incremental, cumulative negative impacts on biodiversity and local communities which depend on riverine biodiversity for their livelihoods.

IBC recommends that:

  • EIA notification 2006 should be amended urgently to include all hydel project above 1 MW capacity, all large dams including those for drinking water, industrial use, irrigation above 1000 hectares and flood control structures under its purview
  • Cascade of Hydropower dams in any river basin, including in the Indian Himalayas and Western Ghats should be reviewed, cumulative impact assessment including carrying capacity and river basin studies should be mandatory. No further projects should be considered before such studies in any basin having two or more projects. The studies should be done by credible independent agencies having no conflict of interest.
  • Recommendations of studies like Wildlife Institute of India’s report on Cumulative Impacts of Hydel Development on terrestrial and aquatic ecology of Alaknanda and Bhagirathi Basins should be accepted and 24 hydel projects should be immediately scrapped for their irreversible negative impacts on biodiversity, as recommended by the WII study.
  • Process of Environment Impact Assessments should be made stringent, consultants with conflict of interest should be blacklisted. More scientific inputs and peer reviews should be brought in these studies.
  • Participatory Studies about environmental flow requirements of rivers, free flowing distance of rivers between two dams (should be more than 5 km as suggested by additional chief secretary of Himachal Pradesh in a report to high court) and downstream impacts of dams should be undertaken by the MoEF with participation from scientists and communities across the country. In the absence of these studies, more projects should not be sanctioned.
  • Fish Diversity and dependent livelihoods of inland fisherfolk are being greatly jeopardized by current dam development, in the absence of any mitigation measures. We urge the MoEF to undertake studies about efficacy of current fish farms and hatcheries, studies on fish ladders and passes and impacts of dams on fish diversity in India and not sanction new dams in areas of great fisheries diversity like Western Ghats and Indian Himalayas in the absence of mitigation measures and studies
  • Dams affecting community conserved areas and conservation reserves should be scrapped like 780 MW Nyamjangchhu Project in Arunchal Pradesh affecting last wintering sites of Black-necked Cranes, a community reserve.
  • Free-flowing rivers of India need legal protection as reservoirs of rare biodiversity.
  • Ramsar and other wetlands should get legal protection from impacts due to upstream abstractions.
  • In every state and ecological zone, certain rivers should be left as no go zones for dams and hydropower projects.
  • Community conserved riverine stretches and community fish sanctuaries should get legal protection.
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National Plan for Conservation of Aquatic Ecosystems omits Rivers?

Image While the National Wetland Conservation Program and National Lake Conservation Program did not include rivers in their purview, even the newly announced 900 crores National Plan for Conservation of Aquatic Ecosystems seems to have ignored Rivers. The National River Conservation Program,under the MoEF includes hardly 35 polluted riverine stretches. That is the only specific protection rivers get apart from some failed plans like GAP and YAP.

While Rivers in India provide habitats to endangered biodiveristy, and provide numerous goods and services, they continue being overlooked and abused ..http://www.dnaindia.com/india/report_cabinet-nod-to-rs900-crore-wetlands-development-plan_1797394