Chenab · Cumulative Impact Assessment · Environment Impact Assessment · Expert Appraisal Committee · Himachal Pradesh · Hydropeaking · Hydropower · Ministry of Environment and Forests

Sach Khas Hydro project in Chenab Basin: Another example of WAPCOS’s shoddy EIA

Even after multiple appeals by various experts, organizations and local people, Expert Appraisal Committee (EAC) set up by Ministry of Environment & Forest (MoEF) has once again chosen to ignore alarms of changing climate such as disaster of Uttarakhand in 2013 and has continued to consider Hydro Power Projects on Chenab Basin for Environmental Clearance (EC) before the Cumulative Impact Assessment of Chenab Basin has been accepted by MoEF. While on one hand the State Government of Himachal Pradesh has promptly appointed a committee headed by Chief Secretary to supervise and monitor all the progress and to “sort out” problems of getting various clearances “without delay in single window system”[i], on the other hand overall transparency of the Environmental Clearance Process has been steadily decreasing.

Sach Khas HEP (260 + 7 MW) (located in Chamba District of Himachal Pradesh) was considered by EAC in its 76th meeting held on August 11, 2014. Even though the project was considered for EC, no documents were uploaded on the website. Website does not even list the project under “Awaiting EC” category. This is in clear violation with MoEF norms, basic norms of transparency and Central Information Commission (CIC) orders. There are no fixed guidelines for documents to the uploaded, the time by when they should be uploaded and rules that project cannot be considered if the documents are not uploaded.

SANDRP recently sent a detailed submission to EAC pointing out several irregularities of the project. The comments were based on reading of the Environmental Impact Assessment (EIA) report available on the HP Pollution Control Board Website (which cannot be substitute for putting up the documents on EAC website). Environmental Management Plan (EMP) of the project is not accessible at all! Non availability of EMP on the HP Pollution Control Board website too is a violation of EIA notification 2006.

The EIA report which is prepared by WAPCOS is another example of a poorly conducted EIA with generic impact prediction and no detailed assessment or quantification of the impacts. Moreover since EMP is not available in the public domain, there is no way to assess how effectively the impacts have been translated into mitigation measures. Violations of Terms of Reference (TOR) issued by EAC at the time of scoping clearance is a serious concern.

Project Profile

Sach Khas HEP is a Dam-toe powerhouse scheme. The project has a Concrete Dam & Spillway with Gross storage of 25.24 MCM, Live Storage of 8.69 MCM and Reservoir Stretch at FRL of 8.2 km (approx.) Three intakes each leading to 5.8m diameter penstocks are planned to be located on three of the right bank non-overflow blocks. Three penstocks offtaking from the intakes are proposed to direct the flows to an underground powerhouse on the right bank of the Chenab river housing 3 units of 86.67 MW turbines with a total installed capacity of 260 MW. The project also proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project.

Sach Khas Dam Site

Sach Khas Hydro Electric Project was considered before completion of Cumulative Impact Assessment of Chenab Basin

Chenab basin may have one of the highest concentrations of hydropower projects among all basins in India[i]. The basin has over 60 HEPs under various stages of planning, construction and commissioning in states of Himachal Pradesh (HP) and Jammu and Kashmir (J&K). 49 of these projects are planned or under construction in Chenab in HP and of which 28 projects of combined generation capacity of 5,800 MW are at an advanced stage of obtaining (Environment Ministry) clearances[ii]. MoEF sanctioned TORs for Cumulative Impact Assessment (CIA) of the HEPs on Chenab in HP in February 2012 however the project specific ECs were delinked from the CIAs[iii].

MoEFs Office Memorandum dated May 28 2013 states, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.”

We had pointed out in our submission against Kiru & Kwar projects in Jammu & Kashmir that CIA of all the proposed, under construction and operational projects and carrying capacity assessment (CCA) of the Chenab River basin to see if it can support the massive number of HEPs in safe and sustainable way is one of the first steps before considering clearances to HEPs in this region. Looking at the fragility of the Himalayan ecosystem, considering any hydropower project in the basin without these studies will be an invitation to disaster[iv]. This fact has been repeatedly highlighted by multiple organizations and experts including SANDRP.

Sach Khas EIA Study: Gross violation of TOR

The EIA violates several stipulations of TOR issued on Feb 22, 2013, which also included the stipulations of EAC in Sept 2012 and Nov 2012 meetings where the project TOR was considered and also Annexure attached with the TOR. This has severely affected the overall quality of the EIA report.

About assessing the impacts of the project on wild life the TOR said: “Reaching conclusion about the absence of such (Rare, Endangered & Threatened) species in the study area, based on such (conventional sampling) methodology is misleading” as such “species are usually secretive in behavior”, “species specific methodologies should be adopted to ascertain their presence in the study area”, “If the need be, modern methods like camera trapping can be resorted to”. None of this is shown to be done in any credible way in EIA.

TOR also recommends intense study of available fish species in the river particularly during summer (lean) months with help of experimental fishing with the help of different types of cast and grill nets. There is no evidence in EIA of any such intensive efforts detailed here. In fact the field survey in summer moths was done in May June 2010, years before the EAC stipulation.

TOR (EAC minutes of Sept 2012) state “Chenab river in this stretch has good fish species diversity & their sustenance has to be studied by a reputed institute.” This is entirely missing. TOR (EAC minutes of Sept 2012) states “During the day, the adequacy of this discharge (12 cumecs) from aquatic biodiversity consideration needs to be substantiated”. This again is missing. TOR said 10 MW secondary station may be a more desirable option. This is not even assessed. TOR said Impacts of abrupt peaking need to be assessed. This is also not done. Site specific E-Flow studies and peaking studies stipulated by TOR are missing. TOR states that Public Hearing / consultations should be addressed & incorporated in the EIA-EMP. However there is no evidence of this in the report.

TOR also required following to be included in EIA, but many of them found to be missing: L section of ALL upstream, downstream projects; Project layout showing all components with A-3 scale of clarity and 1: 50000 scale; drainage pattern map of river upto project; critically degraded areas delineated; Demarcation of snowfed/ rainfed areas; different riverine habitats like rapids, pools, side pools, variations, etc;

Contradictions in basic project parameters

The EIA report provides contradictions in even in basic parameters of the project components: So section 2.1 on page 2.1 says, “The envisaged tail water level upstream of the Saichu Nala confluence is 2150 m.” This i s when the TWL is supposed to 2149 m as per diagram on next page from the EIA. Section 2.3 says: “River bed elevation at the proposed dam axis is 2145m.” At the same time, the tail water level is 2149 m. How can Tail water level of hydropower project be higher than the river bed level at the dam site? This means that the project is occupying the river elevation beyond what HPPCL has allocated to it. Page 23 of EIA says: “…the centerline of the machines in the powerhouse is proposed at 2138.00m…” So the Centre line o the power house is full 11 m BELOW the tail water level of 2149 m? How will the water from power house CLIMB 11 m to reach TWL level?

EIA report unacceptable on many fronts

Dam ht of 70 m was stated in TOR, however the report states it to be 74 from river bed. The submergence area, consequently has gone up from 70 ha at TOR stage to 82.16 ha, as mentioned in Table 2.2 of EIA. Total land requirement which was 102.48 ha as per TOR ha has now increased to 125.62 ha, with forest land requirement going up to 118.22 ha. This is a significant departure from TOR that should be requiring fresh scoping clearance. Part of the field study has been done for the project more than four years ago and rest too more than three years ago. There are not details as to exactly what was done in field study. EAC had noted in their meeting in Sept 2012, while considering fresh scoping clearance for the project, “EIA and EMP should be carried out afresh keeping in view the drastic changes in the features due to increase in installed capacity of the power house.” (Emphasis added.) The EIA report is thus unacceptable on multiple fronts.

No cognizance of Cumulative Impacts

CIA of the entire Chenab basin including HP and J&K is not being considered, which itself is violating MoEFs Office Memorandum dated May 28 2013. The OM states that all states were to initiate carrying capacity studies within three months from the date of the OM No. J-11013/I/2013-IA-I. Since this has not happened in case of Chanab basin in J&K, considering any more projects in the basin for Environmental clearance will be in violation of the MoEF OM.

On Cumulative Impact Assessment, the OM said, “While, first project in a basin could come up without insisting on cumulative impact study, for all subsequent hydro-power projects in the basin, it should be incumbent on the developer of second/ other project(s) to incorporate all possible and potential impacts of the other project (s) in the basin to get a cumulative impact assessment done.” The EIA of both the projects does not include the cumulative impacts.

The project is located between Purthi HEP upstream and Duggar HEP downstream. Elevation difference between TWL of Purthi (2220m) and FRL of Sach Khas (2219m) is barely 1 m. The horizontal distance between them is as less as 117m. This is clearly unacceptable and in violation of the minimalist EAC-MoEF norms.

Elevation difference between TWL of Sach Khas (2149m) and the FRL of Duggar (2105 m) is 44 m and the horizontal distance is 6 km. This is thus a cascade of three among many other projects in the basin.

Cascade of three projects

Purthi HEP Site

Dugar HEP Site

Even so the report does not even mention the other two projects. EIA study is project specific and no cumulative impacts are assessed along with the other two projects. The EIA does not provide a list of all the HEP projects taken up in the Chenab basin in HP state[i]. The MoEF sanctioned TORs for conducting Cumulative Impact Assessment (CIA) of Chenab In February 2012. EAC considering any further project in Chenab basin before completion of the CIA study of the basin by a credible agency (not WAPCOS) and finalised in a participatory way will be in violation of the MoEF order of May 2013.

EIA report completely misses out on the detailed analysis of cumulative impacts in terms of disaster potential of the area and how the project will increase that; impacts on flora, fauna, carrying capacity, livelihoods; cumulative downstream impact, cumulative impact of hydro peaking. impacts on springs and drainage pattern; impacts of forest diversion on environment, hydrology and society and implementation of the Forest Rights Act; changing silt flow pattern in different phases, impacts of mining, tunneling, blasting etc. Impact of reduction in adaptive capacity of the people and area to disasters in normal circumstance AND with climate change has not been assessed. Project makes no assessment of impact of climate change on the project even when over 60% of the catchment area of the project is snow-fed and glacier fed. Options assessment in terms of non dam options as required under EIA manual and National Water Policy are missing.

Generic impact prediction

Impact prediction is too generic with no detailed assessment, which is what EIA is supposed to do. Impacts have not been quantified at all. The EIA report merely states the likely impacts in 2 or 3 sentences. Several important impacts have gone missing. None of the serious impacts have been quantified. For an informed decision making and effective mitigation and EMP quantification of impacts is essentially a pre requisite. Following are some such incidences:

Impacts of blasting & tunneling: TOR for the impacts on “Socio-economic aspects” says, “Impacts of Blasting activity during project construction which generally destabilize the land mass and leads to landslides, damage to properties and drying up of natural springs and cause noise pollution will be studied.”(p.196 of EIA Report). The total area required for Underground Works is 2.44 Ha. The project proposes underground power house with an installed capacity of (260+7). There are three TRTs proposed of length 99.75m, 113.13m, and 132.35m. Even so the impacts of blasting for such huge construction are simply disregarded in the EIA report by stating that “The overall impact due to blasting operations will be restricted well below the surface and no major impacts are envisaged at the ground level.” (p.165). While assessing the impacts of blasting on wild life the report states that direct sighting of the animals has not been found in the study area and the possible reason could be habitation of few villages. No attempt has been made to assess impacts of blasting like damage to properties, drying up of springs etc. This is a clear violation of TOR.

Impacts of Peaking & diurnal flow fluctuation: In the lean season during peaking power generation the reservoir will be filled up to FRL. As stated in report, this will result in drying of river stretch downstream of dam site of Sach Khas hydroelectric project for a stretch of 6.0 km, i.e. upto tail end of reservoir of Dugar hydroelectric project. The drying of river stretch to fill the reservoir upto FRL for peaking power will last even upto 23.5 hours, after which there will continuous flow equivalent to rated discharge of 428.1 cumec for 0.5 to 2 hours. Such significant diurnal fluctuation with no free flowing river stretch will have serious impacts on river eco system. There is no assessment of these impacts. Instead the report projects this as a positive impact stating “In such a scenario, significant re-aeration from natural atmosphere takes place, which maintains Dissolved Oxygen in the water body.” This is absurd, not substantiated and unscientific.

International experts have clearly concluded that: “If it is peaking it is not ROR”[ii]. In this case the EIA says the project will be peaking and yet ROR project, which is clear contradiction in terms.

Impacts on wild life: EIA report lists 18 faunal species found in the study area. Out of them 8 species are Schedule I species and 8 Schedule II species. Even so while assessing the impacts of increased accessibility, Chapter 9.6.2 b(I) of the report mentions “Since significant wildlife population is not found in the region, adverse impacts of such interferences are likely to be marginal.” If the project has so many schedule I and II species, the impact of the project on them must be assessed in the EIA. Moreover, massive construction activities, the impacts of long reservoir with fluctuating levels on daily basis, high diurnal fluctuation and dry river stretch of 6km on wild life could be serious. But the report fails to attempt any assessment of the same.

Impacts on geophysical environment are missing: The project involves Underground Works of 2.44 Ha. This involves construction of underground powerhouse, three headrace tunnels and several other structures. This will have serious impacts on the geophysical environment of the region and may activate old and new landslides in the vicinity of the project. The report makes no detailed assessment of this. Generic comments like “Removal of trees on slopes and re-working of the slopes in the immediate vicinity of roads can encourage landslides, erosion gullies, etc.” (p.176) have been made throughout the report. Such generic statements can be found in every WAPCOS report. Such statements render the whole EIA exercise as a farce. Project specific, site specific impact assessment has to be done by the EIA. Considering that the project is situated between Purthi HEP upstream and Duggar HEP downstream, a detailed assessment of the geophysical environment and impact of all the project activities is necessary. Further since the EMP is not at all available in public domain, it is difficult to assess what measures are suggested and how effective measures to arrest possible landslides have been suggested.

Downstream view of Sach Khas

Right Bank Drift at Sach Khas

No assessment for Environmental Flow Releases

TOR states that the minimum environmental flow shall be 20% of the flow of four consecutive lean months of 90% dependable year, 30% of the average monsoon flow. The flow for remaining months shall be in between 20-30%, depending on the site specific requirements (p.192). Further the TOR specifically states that a site specific study shall be carried out by an expert organization (p.193).

The TOR also mandated, “A site specific study shall be carried out by an expert organisation.” However completely violating the TOR, the EIA report makes no attempt for the site specific study to establish environmental flows. Instead it proposes to construct 2 units of 7 MW each to be installed to utilize the mandatory environmental releases. This completely defeats the basic purpose of the environmental flow releases. Such flows will help neither the riverine biodiversity, nor fish migration nor provide upstream downstream connectivity.

Socio-economic profile of the study area and Rehabilitation & Resettlement Plan are missing

TOR specifies a detailed assessment of socio-economic profile within 10 km of the study area including demographic profile, economic structure, developmental profile, agricultural practices, ethnographic structure etc. It also specifies documentation sensitive habitats (in terms of historical, cultural, religious and economic importance) of dependence of the local people on minor forest produce and their cattle grazing rights in the forest land. As per the TOR the EIA report is required to list details of all the project affected families.

Report however excludes assessment of socio economic impact of the study area. The total land required for the project is 125.62 ha, of which about 118.22 ha is forest land and the balance land 7.4 ha is private land. There are cursory mentions of habitations in the study area. Chapter 8.7 ‘Economically Important plant species’ states that in study area the local people are dependent on the forest produce such as fruits, timber, fuel wood, dyes and fodder for their livelihood. However the EIA report does not even estimate the population displaced due to land acquisition and impact of the various components of the project on livelihood of the people. Further detailed study is then out of question. This is again gross violation of TOR.

Indus Water Treaty

Chenab basin is international basin as per the Indus Water Treaty. A recent order of the international court has debarred India from operating any projects below MDDL and has disallowed provision for facility to achieve drawdown below MDDL in any future project[i] (for details, see: https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/). The EIA described gate opening in this project for silt removal, which stands debarred by international court. The EIA thus is in violation of the verdict of international Court.

The EIA says (p. 21 bottom), “Five low level sluices with crest at 2167m of size 7.5m width and 12.3m height are proposed for flood passage. Drawdown flushing of the reservoir shall be carried out through these sluices for flushing out of the sediment entrapped in the reservoir. Detailed studies on sedimentation and reservoir flushing can be taken up at detailed planning stage.” The MDDL of the project is 2209.3 m as mentioned in the same para. This means the project envisages sediment flushing by drawdown to 2167 m (sluice crest level, the sluice bottom level wll be 12.3 m below that), about 42.3 m below the MDDL. This is clearly not allowed under PCA order cited above on Indus Treaty.

Impact of 3.5 MW Chhou Nala HEP to be constructed for the project not assessed

The EIA mentions (p 2.19) that the HP government has allocated 3.5 MW Hydropower project on Chhou Nala in the project area to the project authority, so this is integral part of the project. But the EIA does not contain any impacts of the SHP. The stream on which this is planned is extremely important for the people as drinking water schemes, irrigation Kuhls and gharats of Rai, Chhou and Thandal villages are located on this stream in the proposed project area. Thus the project will have huge impacts, but there is no assessment of these impacts. This is another glaring omission of EIA. It was shocking to read that the resident commissioner said at the public hearing that this question is not part of Environmental Public hearing, when it is very much part of it.

Public hearing report

At several places either no information is given or misleading information has been presented. For example the project representatives mis-informed the people at PH that 15-20% water will be released, when minimum water they need to release is above 20%. DFO said that soil will be spread over the muck disposal site for tree planting over it, but there is no provision of this in EIA-EMP. Many questions were provided with vague answers or no answers at all. No clear answer was given when asked if the muck dumping sites have been decided in consultation with the local people, implied answer is clearly that local people have NOT be consulted. When asked about agreements to ensure that the company implements EMP and Social Management Plan as required, there was no promise that such an agreement will be signed with the village gram sabhas. The affected people raised the issue of erosion impact of diversion tunnel, but no specific response was provided in response to this issue. When a resident of Chhou village raised the issue of vulnerability of the village to the landslides, no clear answer was given by the project developer. When the same person asked that our cremation ground is going under submergence, what is the company planning about it, the project developer replied that IF the cremation ground goes under submergence, we will think about this. This only shows that the project developer and EIA consultant have not even done an assessment of such basic aspects. The PH report accepts that close to 100 workers are already working without even basic sanitation facilities, this is clear violation of EIA notification further the EIA Agency fails to mention this.

EIA is full of cut and paste, generic statements, no actual assessments

Out of nine chapters of EIA, only the last chapter is about impacts assessments! So out of 170 pages of nine chapters, only 31 pages of chapter 9 is supposedly about impact assessment and there too mostly there is no real impact assessment, mostly only generic statements that can be included in any EIA. There are several unnecessary sections in the EIA like chapter 3 on “Construction Methodology” which is unnecessary in EIA. In most other sections too, the information is just cut and paste from DPR. By way of impact prediction, the EIA report is only listing them doing absolutely NO ASSESSMENT and no quantification of impacts is attempted. Further since the EMP is not available in the public domain, it is impossible to assess if the measures provided in the EMP are effective. Such EIA is definitely not acceptable.

No proper referencing The EIA does not provide references to the specific information, without this it is difficult to cross check which information is from which secondary sources and how credible it is and which information is from primary survey.

Conclusion

This is another most shoddy piece of EIA by WAPCOS.

Moreover, as we can see the EIA has not done several impact assessments, has violated large no of TORs on several counts, the EIA-EMP are not available on EAC website, the project parameters have undergone changes necessitating fresh scoping clearance as mentioned in TOR but that has not happened, baseline study is 3-4 years old, EAC stipulation of fresh EIA-EMP has been violated, Project is using larger riverine stretch than given by HP govt, there is no proper referencing, hydrology is weak, EMP is not available on HPPCB website in violation of EIA notification, among several other issues listed above. Every conceivable serious problem can be found in this EIA of WAPCOS.

It is full of generic statements that can be pasted in any EIA without any attempt at project specific impact assessment. SANDRP has been pointing to EAC and MoEF about such unacceptable EIA by WAPCOS for several years, but neither EAC, nor MoEF has taken any action in this regard. SANDRP has once again urged to EAC and MoEF to reject this EIA and recommend blacklisting of WAPCOS and to issue fresh scoping clearance for the project as mentioned in the TOR since the project parameters (dam height, submergence area, land requirement, etc) have gone through significant changes.

We sincerely hope the EAC will not only take serious cognition of these and not recommend clearance to the project, but also direct the project proponent and EIA consultant to implement other recommendations made above.

 Amruta Pradhan (amrutapradhan@gmail.com), Himanshu Thakkar (ht.sandrp@gmail.com)

[i] https://sandrp.wordpress.com/2013/12/23/international-court-asks-india-to-release-more-water-and-rejects-plea-to-re-interpret-february-verdict-on-kishanganga/

[ii] See for example https://sandrp.in/basin_maps/Hydro_%20Electric_Projects_in_Chenab_River_Basin.pdf

[iii] https://sandrp.wordpress.com/2014/07/01/if-its-peaking-its-not-an-ror-interview-with-dr-thomas-hardy-iahr-and-texas-state-university/

[iv] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[v] https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

[vii] https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

[viii] Refer to SANDRP studies on Chenab

– https://sandrp.wordpress.com/2013/07/01/pm-kick-starts-850-mw-ratle-project-in-jk-without-full-impact-assessment-invitation-to-another-disaster-in-chenab-basin/

– https://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf

– https://sandrp.wordpress.com/2014/05/06/massive-hydropower-capacity-being-developed-by-india-himalayas-cannot-take-this-onslought/

[ix] http://northgazette.com/news/2013/04/25/special-committee-to-monitor-hydro-projects-in-hp-cm/

Environment Impact Assessment · Expert Appraisal Committee

Shoddy EIA by WAPCOS Tries to Push Unjustifiable Bansujara Irrigation Project in Madhya Pradesh

The EIA of the Bansujara Multipurpose Project (BMP) dated May 2013 by WAPCOS has been submitted for Environment Clearance of the project before the Expert Appraisal Committee on River Valley Projects, in Nov 2013. WAPCOS is known to do very shoddy job of Environment Impact Assessments, this one is no different. In what follows I have given a few instances of wrong facts, contradictory facts, wrong calculations or assumptions, incomplete assessments, instances that shows it is cut and paste job and lack of options assessment by the 564 page EIA document. The conclusion is inescapable that the EAC and MoEF must reject this EIA and recommend black listing and other measures against WAPCOS. The project should be asked to get a fresh EIA done by a credible agency. 

Location Map of Bansujara Irrigation Project
Location Map of Bansujara Irrigation Project

WRONG FACTS The EIA provides several completely wrong facts, here are a few instances:

1. River description On p 1-1 the EIA says: “The Bansujara Dam Project lies in Dhasan sub-basin of Betwa basin, River Betwa is a tributary of Yamuna river, rises in district Bhopal district at an elevation of 472 m. After traversing a length of 365 km, it joins Yamuna river in Uttar Pradesh. The river runs for nearly 240 km in Madhya Pradesh, 54 km along common border of Madhya Pradesh and Uttar Pradesh and 71 Km in Uttar Pradesh state before its confluence with Yamuna river near Hamirpur town in Hamirpur district of Uttar Pradesh.” This is actually the description of River Dhasan and not Betwa! It is exactly same as the description of river Dhasan given on the next page and several other places subsequently.

2. Land required for Canals In Table 2.3 it is stated that canals will require 44 ha land, this is clearly gross under-estimate considering even 49.9 km of main canal.

3. Private land under required for project The SIA says on page 1-2, “About 935.11 ha of culturable area, 57.49 ha of forest land and 4209.118 ha of other land including road, nallah, river, etc. will be affected.” This is blatantly wrong figure. On page 1-3/4 of SIA it is stated: “About 2935.11 ha of revenue/government land and 2894.37 ha of private land is to be acquired.” This again is wrong.

As the MoEF factsheet for the Forest clearance for the project says, “Apart from the 57.495 hectares of forest land proposed to be diverted, the project involves submergence of 287.951 hectares of government land and 4,856.276 hectares of private land.” Thus the suggestion by the SIA that only 935.11 ha of culturable land is going under submergence is clearly wrong since most of the private land is under cultivation in these villages.

4. How many families will be affected The MoEF Factsheet for the project says: “The project involves submergence of 21 villages. 2628 houses, 773 wells, 5082 trees, and 2628 families with population of 13,142 are getting affected due to submergence.” These figures are at variance with the figures mentioned in the EIA. For example, the SIA (p 1-4, repeated on page 4-1) says: “Over all 748 families of 9 Abadi Villages will be affected”. This when the project will be taking away 2628 houses as per the Fact sheet, is clearly gross wrong reporting of figures. Because of use of wrong figures, their R&R plan and R&R costs are also all wrong and gross under estimates. Moreover, now the R&R plan and costs should be as per the new Land Acquisition Act Passed by the Parliament, which has not been done in the EIA-SIA. As per the new Act, land has to be provided to each losing farmer, and this must be followed.

5. Completely impossible figures of crop yields A look at table 4.3 of SIA (repeated in table 7.1 of CADP) shows that the consultants have given crop yields before project (e.g. paddy 7 t/ha, wheat 18 t/ha, groundnut 10 t/ha and gram 10 t/ha) which are much higher than the average of even Punjab crop yields and they are expecting to double that post project! These are clearly impossible figures. This shows that the consultants are plain bluffing and seem to have no clue about possible crop yields and in any case do not seem to have done any surveys, but are only cooking up data. Amazingly, they are claiming that with 211% increase in crop yield, the profits from crops will go up by 318%! All this simply shows the manipulations they are indulging in to show the project is economically viable.

CONTRADICTORY FACTS
1. Main canal length Page 2-2 says main canal length is 90 km, the salient features on next page says Main canal length is 49.9 km.

2. Command area Tehsils and villages Section 10.2 of EIA (and again section 2.7 of the CADP) says: “The Command area of the proposed Bansujara Major Irrigation project lies within the district Tikamgarh in jatur and Baldeogarh tehsil” and than goes on to give details of these tehsils, but the rest of the document (e.g. section 6.1) says: “A total of 124 villages are likely to be benefitted by the project. 80 villages are located in Tehsil Khargapur of district Tikamgarh. About 13 villages are located in tehsil Jatara of district Tikamgarh. The remaining (31) villages are located in tehsil Palera of Chattarpur district.” Chapter 6 in fact provides full list of 124 villages in the command area. The subsequent details of the command area given in chapter 10 thus does not match with what is given say in chapter 6.

Contradicting this, page 1-4 of SIA says: “The Bansujara Multipurpose Project will benefit almost 132 villages in districts Tikamgarh and Chattarpur.” Amazingly, the SIA says Palera tehsil is in Tikamgarh district and not in Chattarpur district and that additional ten villages of Badamalhera tehsil of Chattarpur district will also be in command area!

Number of beneficiary villages in Palera tehsil are given as 31 in page 44 (chapter 6) and 30 on page 141 (chapter 11), with even names differing, e.g. Banne Khurd and Bastaguwan mentioned in chapter 6 are missing in chapter 11, village Bargram mentioned in chapter 11 is missing from the list in chapter 6.

All this is most callous and shocking. This fact alone should be sufficient to REJECT this callous EIA and recommend blacklisting and other punitive measures for WAPCOS as consultant.

3. Command area population Section 10.2.1 of EIA says: “As per 2001 Census the total population of the command area is about 38,000. The male and female population is 20,181 and 17,828”. However a look at the 10.2 that follows this sentence shows that these figures are for Jatara tehsil and not command area. Another sign of callousness.

4. Submergence villages Table 11.3 of EIA gives list of Project affected families, which is at variance with the list given in tables 10.8-10.14. Firstly, chapter 10 tables say that 14 villages of Tikamgarh Tehsil are affected, but table 11.3 lists only 13 villages. More shockingly, tables in chapter 10 say 6 villages of Bada Malhera tehsil of Chhatarpur district are affected, whereas the name of this tehsil given in chapter 11 is Bijawar. All this shows shocking callousness of WAPCOS.

5. Storage Capacity Page 11-10 says: “The storage capacity of Bansujara Reservoir is 539.42 Mm3.” This is clearly wrong, the figures for gross and live storage capacity given in salient features and elsewhere are: 313.1 MCM and 272.789 MCM respectively.

6. Water Availability As per Table 5.8, water availability at the project site from MP catchment (2788 sq km) alone is 843 MCM. Strangely, this reduces to 588.68 MCM in table 11.6 for whole of catchment (3331.776 sq km) at dam site. No explanation is given for these figures.

7. Submergence area While most of the document gives submergence area as 5201.71 ha. However, in section 2.7 of EMP, it says, “The submergence area of Bansujara Irrigation Project is 7476 ha.” This is amazing kind of contradiction.

WRONG CALCULATIONS/ ASSUMPTIONS
1. Field channel length grossly underestimated The p 6-6 of EIA says: “The Bansujara Dam Project envisages irrigation over a CCA of 54000 ha. In the areas where irrigation is proposed no field drainage, land shaping of field channels exist and used to be constructed. From general experience and existing practice, it is assessed that a length of 1600 m of field channels will be required to serve a chak of 40 ha of CCA. On this basis, an approximate network of total length of 180 km of field channels will be required for 50% of CCA proposed for irrigation.” Simple calculation suggests that the field channel length for 50% of CCA would be 1080 km (54000 ha / 40 ha per 1.6 km divided by 2 for 50% CCA).

2. Drainage requirement under estimated Section 6.9 (p 6-7) of EIA says, “The command area is being traversed by a large number of nallahs and drains, therefore field drainage should not pose any problem.” This is clearly wrong assumption since additional irrigation will certainly require additional drainage and cost calculations based on such flawed assumptions are bound to be wrong.

3.  Baseless assumption about waterlogging Similarly about the assumption in section 6.13 (p 6-8): “Even after construction of Bansujara Dam Project the area will not face any waterlogging problem.”

4. Wrong claims about no floods The conclusion about flood and back water impacts is completely unfounded in section 6.14 (p 6-8): “As per information gathered from the Collectorate Tikamgarh there is no village affected due to back-water of Dhasan and Ur rivers. The existing drainage system in the command is adequate. The statistics gathered from collectorate Tikamgarh show that there is no flood affected area. The command has fairly good flood disposal capacity and not special measures are called for.” This when the Maximum water level of the dam is full 1.4 m above the FRL, the back water level is found to be high. This is also particularly relevant in flood prone basin like Betwa-Dhasan.

5. Drainage characteristics of clayey soils ignored The assumption in section 7.1 (p 7-1) shows complete lack of understanding on the part of EIA consultants: “The area is sloping gently and near its outfall into Betwa river, the slope is of the order of 0% to 3%. It is traversed by small drainage channels at short distances and they help in draining excess water efficiently. Hence, no provision for drainage has been made. The soil is generally clayey.” It is well known that clayey soils are inefficiently draining soils and to make such assumption for clayey soils is clearly wrong.

6. Unrealistic assumption of irrigation efficiency System irrigation efficiency of 54% assumed in Table 11.10 is clearly wrong, no project in India has achieved such high efficiency. The water loss will surely be much higher than the assumption of 105 MCM on page 11-14. The conclusion on that page that: “The quantum of water not being utilized is quite small and is not expected to cause any significant problem of waterlogging” is clearly wrong and baseless, since water logging also depends on many other factors including drainage, soil structure, underground geology, among other factors.

7. No industries, but 19.4 MCM for industries! The CADP (page 5-7) clearly states: “At present there is no industrial requirement in the area.” And yet the project allocates 19.4 MCM water for industries. This again shows that the project is being pushed even though there is no need for it.

INCOMPLETE ASSESSMENT
1. Dependence on fisheries incomplete It is not clear what is the area from which fisheries assessment done as reported in section 9.11.6. How many people depend on fish, what is the production market and economy of the same is also not reported.

2. Hydrology figures without basis Chapter 11 (Table 11.6) assumes that “For use on u/s of Bansujara dam for environmental and ecological balance and Misc. uses by surface water” is 10 MCM and “Quantity of water reserve for d/s release for environmental and ecological balance” is 15.18 MCM and that groundwater available upstream of dam site will be 58.86 MCM (10% of surface water). No basis is given for any of these and all these (and many other) figures given in the water balance are clearly ad hoc, unfounded assumptions. The groundwater availability is typically 40% of total water availability, so around 67% of surface water availability. Why should it be 10% in case of the Dhasan basin is not explained and in any case does not seem plausible.

However, in Table 2.2 of EMP, the environment flow suggested in monsoon months is 12.8 cumecs. This would mean that the project would need to release 132 MCM of water in four monsoon months as environment flows, when they have assumed in hydrology that only 15.18 MCM water is required for this!

3. Incomplete SIA SIA says (SIA page 1-7) that it has selected certain of the 21 villages facing submergence due to the project. Actually the SIA should have done full survey of all the villages not a sample of villages.

4. Impact of loss of river not assessed It is expected that the SIA will assess the impact of loss of river for the people in submergence and downstream zone, but no such assessment has been done. Even in section 4.4 of SIA on “Impacts of Socio-Cultural Environment”, there is no mention of impact of river (or forest or other natural resources) on the people.

5. Full Canal details not given The EIA or CADP report does not provide the full lengths of main canals, distributaries, minors, field channels and field drains, including their width, land requirements, protection measures like canal like plantations etc. Without these basic details, the EIA or the CADP cannot be considered complete.

6. Command area coinciding with command area of Ken Betwa Link canal and other such projects? A perusal of the Command area of the Ken Betwa River Link Project (TOR approved by EAC in its 45th meeting in Dec 2010) shows that all the three Tehsils (namely Baldeogarh or Khargapur in Tikamgarh district, Jatara Tehsil in Tikamgarh district and Palera Tehsil in Chhattapur district) are also benefiting from Ken Betwa Link Canal. A look at the map of the command area of Ken Betwa link canal and that of the Bansujara shows that some area are certainly common. The EIA of Bansujara should have pointed this out and also if the proposed command area is to benefit from any other such projects, but it has not done that.

CUT AND PASTE JOB? Several parts of EIA raises the suspicion that they are cut and paste from other documents. This suspicion is proved correct when we see this sentence in Table 12.2 in Disaster Management Plan (Chapter 12 of EMP): “All staff from dam site, power house & TRC outlets alerted to move to safer places”, since the Bansujara project has no power house or TRC (Tail Race Channel). The consultants forgot to remove these irrelevant aspects while doing the cut and past job[1], it seems. This is just by way of illustration.

Similarly, the title of the section 2.6 of the Command Area Development Plan says it all: “2.6 FOREST TYPES IN THE MOHANPURA PROJECT AREA”. Here again it is clear that while doing cut and paste from another EIA, the consultants forgot to change the details! There is also the sentence “Tehsil Shajapur has maximum population density of 238 persons per sq.km. (2001 Census data)” on page 2-6 of CADP, but there is no mention of any such Tehsil in the area!

NO OPTIONS ASSESSMENT The EIA does not contain any options assessment. In fact section 10.2.4 shows that 19174 ha of the 48157 ha of cropped area in the command is already irrigated. This means a substantial 40% of the command area is already irrigated.

On page 3-5 of SIA it is mentioned that out of 318 land holding respondents in the SIA survey (in submergence villages), only 4 had unirrigated land. This shows that land of over 99% of respondents is already irrigated.

Very shockingly, the report does not mention what are the levels and trends of groundwater in the catchment and command of the project. When Groundwater is India’s mainstay for all water requirements, not give this full picture of groundwater makes the report fundamentally incomplete.

The area has average rainfall of around 1100 mm and thus more area can get irrigated with better use of this rainfall and such a huge dam with such huge submergence (5202 ha) and land requirement (5887 ha, gross underestimate considering that land for canals are not properly assessed), over 25000 people displacement (at least and that too only from submergence area) and other impacts is not the best option.

CONCLUSION What is listed above is not an exhaustive list. Nor are these some typographical errors, but these show serious incompetence, callousness and worse. The conclusion is inescapable that the EAC and MoEF must reject this EIA and recommend black listing and other measures against WAPCOS. The project should be asked to get a fresh EIA done by a credible agency. The EAC in the past have failed to apply its mind about such shoddy EIAs even when this was shown to EAC through such submissions. Most recent such case is that of the Mohanpura Irrigation Project in MP, in which case too the EIA was done by WAPCOS. It is hoped that EAC will apply its mind to this issue and make appropriate recommendations.

 

Himanshu Thakkar (ht.sandrp@gmail.com)


[1] Seems like this has been cut and paste from the EMP for the Kangtangshri HEP in Arunchal Pradesh also done by WAPCOS, see: http://apspcb.org.in/pdf/23072013/EMP%20Report-Kangtangshiri.pdf