Himachal Pradesh · Himalayas · Hydropower

The Socio-Ecological Impacts of Small Hydropower Projects in Himachal Pradesh Part-2

-Prof J. Mark Baker (JMark.Baker@humboldt.edu), Humboldt State University, Arcata, CA, USA


This post is the second of a two part summary of the results of a study on the socio-ecological impacts of privatized, small, run-of-the-river hydropower projects in Himachal Pradesh.[1]  The study is based on field research conducted in 2012 on all 49 completed small hydropower projects in the state.[1]  Part one, posted here on 8 June, reviews the implementation of the Himachal Pradesh power policy governing privatized small hydropower development and examines the local social and environmental effects of commissioned small (defined as 5 MW or less) hydropower projects.  This part will address two of the claimed local benefits of small hydropower development, namely monetary contributions by the project developer to local community development projects through the Local Area Development Authority (LADA) and local employment generation.  After a brief discussion of the relationship between small hydropower projects and carbon credits through the Clean Development Mechanism, the article reviews two promising institutional models for small hydropower development and concludes with a set of recommendations.

Local Area Development Authority– Implementation and Accountability Challenges

The 2006 Hydropower Policy includes provisions for tangible local benefits, in part to foster local support for power projects.  One primary mechanism is the requirement that project developers deposit one percent of the project cost into an account with the district commissioner.  These funds, known as Local Area Development Funds, are to be allocated by the Local Area Development Authority (LADA) to support local development activities, particularly related to infrastructure and services.[2]

In our survey of the 49 commissioned small hydropower projects we found that the LADA program was not working as well as intended.  Inconsistent record keeping by district authorities, the lack of clearly defined project affected areas, and uneven levels of awareness among local pradhans about the program have enabled some project developers in Himachal to avoid fulfilling their obligations to local communities.  The district revenue department office in Kangra was the only district office that maintained a comprehensive record of LADA obligations and tracked how much the project developer had paid and how much was still owed.  Without such a record, officials in the remaining six districts found it extremely difficult to hold the project developer accountable for their LADA payment obligations.  For example, in District Chamba, ten small hydropower projects together owe Rs 247 lakhs.  However, as of the summer of 2012 they had paid only Rs 70 lakhs and the developers of three projects had contributed nothing at all.  District administrators seem to have little authority or recourse, beyond personal persuasion, to compel the project developer to make the required contributions.

There are also challenges with defining the Project Affected Area (PAA) and Project Affected Zone (PAZ), which is important because 70% of the LADA funds are earmarked for projects in the PAA and 30% for projects in the PAZ.  Very few small hydropower projects have defined PAAs and none had defined a PAZ.  The lack of clearly defined affected areas raises questions about whether or not the authorized development projects actually reach those households and hamlets most affected by the hydropower project.

A related concern is the unevenness of awareness about the LADA program among village pradhans.  Several village pradhans, especially in the remote areas of the state, had never heard of the LADA program, even though one or more small hydropower projects were located within their panchayat boundaries.  Where the program was functional, there are sometimes disputes between the LADA committee and the district commissioner concerning which projects to fund and whether to prioritize projects oriented towards strengthening local employment generation or hard infrastructure development.

We did encounter one example of a panchayat in which the LADA program was working as intended.  The pradhan of the panchayat, located in District Kangra, was a retired military officer.  Well aware of the LADA obligations of the small hydropower project developers in his panchayat, he maintained close communication with the district commissioner’s office in order to ensure that the required deposits were made.  The pradhan also pressured the LADA committee to identify potential projects in a timely fashion and he followed up with the district commissioner to ensure that the expenditure of the requisite funds was authorized.  As a result, in this panchayat LADA funds had been used to construct a cricket playing field, veterinary dispensary, and a handsome hall for village meetings and social functions (figures 1 and 2).  Furthermore, in part due to the effective implementation of the LADA program and the fact that the small hydropower project did not annex cultivated areas, local opposition to the projects was virtually nonexistent.  This example suggests that the LADA can offer tangible local benefits if accurate records are kept, if the project developers are compelled to contribute the requisite amounts, if village pradhans know about the program and their entitlements under it, and if the district administration supports program implementation.



Employment Generation –Unrealized Potential for Secure Jobs

In addition to requiring project developers to contribute to the Local Area Development Authority, the 2006 Hydropower Policy seeks to generate local benefits by stipulating that 70% of the project’s workers be from Himachal Pradesh.  Because the lack of local employment opportunities is one of the primary drivers of migration from hill areas, the provision of permanent jobs through small hydropower projects could be a significant benefit.  In addition to a steady income, permanent regular employees participate in government-approved pension plans, receive compensation for work-related accidents and injuries, and are protected from arbitrary dismissal.  The project developer is also required to register all workers with the Labour Department and the local police station on a monthly basis.

While the 49 commissioned small hydropower projects in the state generate significant employment, more than half of project developers evade complying with labor law.  All told, the 49 projects employ a total of 951 people, 603 of whom come from the panchayat(s) in which the project is located.  On average, a 5 MW project employs approximately 20 people.  While the total employment these projects generate is substantial, only 22 project developers have registered their employees with the state Labour Department as regular employees.  These workers do receive the protections and benefits of the state’s labor laws, and some of them (in three projects) are also provided subsidized lodging and meals.  However, the workers in the remaining 27 small hydropower projects, while doing the same work as regular employees in other projects, are hired on a daily wage basis and are thus excluded from the benefits and security of regular employment.  A further disjuncture arises from the fact that only 11 project developers have established provident fund contributions for their employees, the remaining 38 have not.  For the majority of workers in small hydropower projects, one of the most important potential local benefits – secure employment – has not been realized.

Given the significant risk of injury or death in this sector, it is of particular concern that unregistered workers are less likely than registered workers to receive compensation should an accident occur.  While we did not develop comprehensive information about accidents and injuries, we did confirm worker deaths, the great majority of which occurred during the project construction phase due to tunnel collapses, falling rock, landslides, and tractor accidents.  A total of 40 people died in accidents related to the construction of the commissioned small hydropower projects in the state, 18 were Himachali and 22 were from neighboring states or from Nepal.  Only three of the families of the forty workers who died in fatal accidents received some form of compensation.  The lack of proper registration and the general absence of compensation suggests the extent to which project developers and their contractors treat workers as a disposable labor force.

The common practice of contracting out project construction work to subcontractors who hire large numbers of employees challenges the ability of unions to advocate for project workers.[3]  Questions arise concerning who is ultimately responsible for following the relevant labor laws and protections – the project developer or the developer’s subcontractors (figure 3)?  Project developers can evade accountability through the use of subcontractors or by creating subsidiary companies.  For example, in District Kangra in May, 2010 the local construction worker union notified a small hydropower project developer of its intent to strike due to violations of labor laws and working conditions.  In a letter the developer responded that the strike was “totally illegal and off the mark” as the developer was not the owner of the plant but was “merely the contractor.”  Furthermore the developer noted that the project was “generating power in the interest of the public of Himachal Pradesh,” and was “a property of the State and a national asset,” and thus the calling of the strike was “illegal from all perspectives.”  While it is true that the developer to whom the labor union had sent the notice of intent to strike is not the company listed as the owner of the project in the state of Himachal Pradesh’s records, it is also true that the listed company is actually a subsidiary of the developer, whose address is the same as the developer and whose website leads directly to that of the developer.  Furthermore, the power project is showcased on the developer’s website as one of four small hydropower projects they have constructed and are currently operating in District Kangra.  The developer’s attempt to evade accountability for labor law violations by creating a fictitious subsidiary demonstrates the challenges unions face when they seek redress for labor law violations and demand worker rightsMArk3NEW


Payments to Developers for Renewable Energy Production

Part One of this article discussed the economics of small hydropower development.  Clearly, the primary source of income developers receive is the guaranteed purchase price that the Himachal Pradesh State Electricity Board provides.  A second, and much smaller, source of revenue for some projects derives from the sale of carbon credits through the Clean Development Mechanism of the Kyoto Protocol, administered under the United Nations Framework Convention on Climate Change (UNFCCC).  The Clean Development Mechanism allows countries in the global south to sell carbon credits in the form of Certified Emission Reductions (CERs) to countries in the global north that need to purchase such reductions in order to meet emissions reduction limits that the Kyoto Protocol has imposed.  Projects in the global south may be eligible for registration under the Clean Development Mechanism if it can be demonstrated that their implementation will prevent carbon (measured in metric tons of carbon dioxide equivalents) from entering the atmosphere.  The resulting emission reductions can then be sold by the project developer to a carbon generating entity in the global north that needs to purchase such carbon credits.  In the context of small scale hydropower projects, developers argue that if they did not produce electricity using hydropower, the equivalent amount of electricity would be generated primarily through the burning of fossil fuels.  Thus, by producing electricity through hydropower, they are “preventing” a measureable amount of carbon from going into the atmosphere.  If their projects are registered under the Clean Development Mechanisms, then project developers may sell credits to entities in the global north.

Of the 49 commissioned small hydropower projects, approximately 27 are registered under the Clean Development Mechanism.[4]  According to documents relating to these 27 projects on the UNFCCC Clean Development Mechanism website, these hydropower projects are credited with generating 447651 metric tons of carbon dioxide emissions reduction equivalents per year.  Project developers may sell these emissions reductions equivalents (carbon credits) to entities in the global north.  There are at least three points worth noting about these carbon credits.  Firstly, the value of carbon credits has dropped precipitously in the last few years, from a high of approximately rupees 760 in 2008 to its current price of less than rupees 50 per metric ton of carbon equivalent (redd-monitor.org 2013).[5]  The essential collapse of the international carbon credit market has been attributed to an oversupply of credits and weak demand (Singh 2014).  Secondly, there are serious concerns about the ethics of generating marketable carbon equivalents from projects that severely disrupt the livelihoods of communities as described in part one of this post.  Thirdly, there are questions about the integrity of the calculations and procedures employed to calculate the carbon equivalents of such projects and to justify project inclusion in the UNFCCC registry.  One of these questions centers on the requirement of additionality.  Additionality, as the Kyoto Protocol specifies, is the principle that projects are eligible for international support through the Clean Development Mechanism only if they would be uneconomical without such support.  Thus, a small hydropower project that is economically viable without the revenue from selling carbon credits is in principal barred from participating in the carbon credit program.  On the other hand, private sector loan officers will not approve financing for projects that are not economically viable.  At least some project developers resolve this contradiction by developing two sets of project documents.  As one project manager told me, “we prepare two DPRs (Detailed Project Reports), one for CDM and one for the banks.”

In light of the poor remuneration developers receive from the sale of carbon equivalents, at least some project developers expressed the desire to participate in the Government of India’s Renewable Energy Certificate (REC) program, which has its roots in the 2003 Electricity Bill and is part of the country’s renewable energy policy (Carbon Credit Capital 2011).  By becoming designated as “eligible entities” within the REC program, developers would receive one renewable energy certificate for every megawatt hour (MWh) that they sell to the state electricity grid.  Purchasing electricity produced by an eligible entity enables state utilities to meet their Renewable Purchase Obligation, which is the proportion of electricity they purchase that must come from renewable sources.  Eligible entities may trade renewable energy certificates on one of India’s two electricity exchanges.  As of 2012, no small hydropower developer had become an eligible entity within the REC program.  Several developers were interested in joining this program, however the fact that they already have power purchase agreements to sell electricity to the HP State Electricity Board renders them ineligible for the REC program.

Two Alternative Institutional Models for Future Small Hydropower Development

The track record of the 49 commissioned small hydropower projects in Himachal Pradesh is cause for concern.  Patterns of disruption to farmer-managed irrigation systems as well as water mills (gharats), environmental and infrastructural damage from landslides in some regions (especially Chamba District), negative effects on fisheries and the livelihoods that fish farming and sport and subsistence fishing activities support, systemic problems with the Local Area Development Authority, significant uncompensated worker deaths during project construction and on-going concerns regarding labor relations, all comprise the local track record of small hydropower development in the state.  Leaving aside the broader question of whether or not small hydropower projects should be developed, it is clear that if they are going to be developed, then an alternative institutional framework is called for.

Two institutional models for small hydropower development exist that have the potential to realize more sustainable, effective and equitable hydropower outcomes.  These models are represented by the Sai Engineering Foundation (figure 4) and the Churah Cooperative Floriculture Society (figure 5).  Inspired by the teachings of the religious leader Bhagwan Sri Sathya Sai Baba and the religious ideals of Gandhian social service, Sai Engineering Foundation is a registered charitable foundation that promotes social welfare.  They have been involved with hydropower development since the first India Hilly Hydel demonstration projects in the 1990s.  They both own and manage their own projects and provide consulting services for other private power developers.  They invest the revenue from hydropower production in social service and welfare programs in Himachal Pradesh.  These activities include medical and blood donation camps, financial assistance to low income students, community-based welfare programs, working with government programs to deliver services to low income communities, and promoting cooperative societies in the field of power generation, construction, and floriculture (Sai Engineering Foundation 2011).  Because of the social service ideology that informs this organization, when the Sai Foundation develops small hydropower projects, it does so in a manner that prevents or mitigates the negative impacts on local livelihood strategies and is responsive to local concerns and issues.

The second alternative institutional arrangement is the Churah cooperative society.  Although the 2006 Hydropower Policy specifically addresses the need to prioritize working with cooperative societies, and despite repeated calls by community members for more support for local cooperative society involvement in hydropower development, our research revealed only one community-based cooperative society working on small hydropower development.  Since 1996 the Churah Valley Fruits, Vegetables, and Flowers Growers Marketing and Development Cooperative Society (Churah Floriculture Cooperative Society) has worked to promote the economic development of low income families in the Churah Valley, a remote area in Chamba District, not far from the border with Jammu and Kashmir.  The cooperative’s initial and on-going work involves developing floriculture using greenhouses, and marketing cut flowers to cities in north India, as well as off-season vegetable production in neighboring Pangi Valley.  Interestingly, they are also working to develop a small hydropower project under the framework of the 2006 Hydropower Policy.  Four hundred Below Poverty Line (BPL) households, all members of the cooperative society, are involved in this effort.  In order to qualify for the necessary loans, each household is putting up their house and land as collateral.  The cooperative society is currently securing the necessary funding and moving ahead with efforts to secure the required No Objection Certificates.  The revenue from the small hydropower project, once it is commissioned, will be shared among the participating families.



Both the Sai Engineering Foundation and the Churah Floriculture Cooperative Society represent viable alternatives to the current approach, which emphasizes corporate ownership of small hydropower facilities.  Both of these organizations are accountable to local concerns and interests and prioritize local social and environmental sustainability.  However, both the Sai Engineering Foundation and the Churah Floriculture Society face an uphill battle to get their projects approved and the requisite NOCs obtained.  Both organizations have fewer financial resources to offer in exchange for obtaining NOCs than do private companies; they are thus at a disadvantage when competing with private corporations for bureaucrats’ attention and willingness to provide NOCs.

Concluding Recommendations

Insights from this study provide the basis for proposing concrete steps that together could help small run-of-the-river hydropower projects realize their purported, but not realized, benefits.  Three broad categories of recommendations exist.  Firstly, the process through which potential hydropower sites are identified must include key elements of the agrarian landscape as well as the cumulative effects of multiple projects along a common stream reach; furthermore, when negative social and environmental effects are anticipated, they should be adequately mitigated.  Settlements, networks of kuhl irrigation systems, strings of gharats along streamcourses, irrigated and unirrigated cultivated areas, and proximity to adjacent projects, in addition to hydrological information, should be incorporated into the site evaluation and identification process.  Using this information to avoid siting projects in densely managed landscapes, or too close to each other, would help eliminate many of the negative project impacts on local livelihoods and communities.  In cases where projects do negatively affect local livelihoods, e.g. when a project renders gharats defunct, disrupts a community-managed irrigation system, or disturbs grazing or cultivated areas, then adequate compensation should be provided through a government-facilitated process.  Similarly, negative environmental effects should be mitigated, for example by requiring manual cleaning of desilting tanks, installation of fish-friendly diversion weirs, adequate water (quality and quantity) to support ecosystem needs, and effective muck management approaches.

Secondly, policy implementation and enforcement need to be strengthened.  While the 2006 HP Power Policy and state labour laws contain important safeguards for local communities and workers, implementation and enforcement need strengthening.  For example, district authorities need to be required and empowered to collect the mandatory developer contributions to the Local Area Development Authority.  LADA funds should be allocated in a manner that maximizes local benefits for project-affected households and communities. Similarly, labour laws requiring that workers doing regular work should be hired on a permanent, not a daily wage, basis should be enforced, and workers should receive the perquisites concomitant with regular employment, including compensation in the event of injury or death.  Projects that disrupt local livelihoods and generate unmitigated negative environmental effects should not qualify for carbon credits under the Clean Development Mechanism.  Greater policy and bureaucratic support also needs to be directed towards supporting alternative institutional models for small hydropower development, such as cooperative societies and social service foundations

Thirdly, governance measures that strengthen small hydropower projects’ accountability should be developed.  The record of negative social and environmental effects and the extent of local opposition, attests to the unsustainable nature of the current approach to small hydropower development.  Identifying and implementing governance measures to minimize these negative socio-ecological effects will likely provide a more informed and democratic basis for decision-making.  Measures such as requiring Environmental Impact Assessments, along with the requisite public hearings, as well as obtaining environmental clearance from the state, would go a long way to improving the sustainability of small hydropower in Himachal Pradesh.  If developers, after completing such assessments and hearings, and receiving clearance, were able to more easily obtain the necessary No Objection Certificates, then project delays would also be reduced.

Clearly, alternatives do exist for advancing institutional approaches to small hydropower development that are accountable to local communities and environmental concerns.  Whether or not the state of Himachal Pradesh (and other states since this is likely to be equally applicable to other states where such projects are taken up) chooses to embrace these approaches remains to be seen.  If the next 450 planned or under-construction small hydropower projects in the state generate a track record similar to the first fifty, then regional society and environment will be much the poorer for it.  However, if civil society mobilizations and resistance are sustained, and governance measures strengthened, then power developers will be held more accountable for the local impacts of their activities.  If the state government chooses to offer more support and capacity building resources for entities like cooperative societies and Sai Engineering Foundation, or at least removes some of the barriers they currently face, then these alternate institutional approaches to power development may proliferate.  And if in response to electoral pressures within the state, Himachal Pradesh decides to put more teeth into its currently progressive, but not enforced, power policy, then perhaps the future will be brighter than the recent past.

Please see Part I of the piece here:https://sandrp.wordpress.com/2014/06/08/the-socio-ecological-effects-of-small-hydropower-development-in-himachal-pradesh/


Carbon Credit Capital (2011) “India’s Renewable Energy Certificate Market” (New York).  Viewed on 9 June 2014.  Website: http://carboncreditcapital.com/dev/wp-content/uploads/resources/InFocus8.pdf

Newing, Helen (2011): Conducting Research in Conservation: Social Science Methods and Practice (New York: Routledge).

Redd-Monitor.org (2013) “Clean development mechanism: zombie projects, zero emissions reductions and almost worthless carbon credits”.  Viewed on 9 June 2014.  Website: http://www.redd-monitor.org/2013/07/12/clean-development-mechanism-7000-projects-zero-emissions-reductions-almost-worthless-carbon-credits-and-zombie-projects-increasing

Sai Engineering Foundation (2011): “Karmayoga”, Quarterly Newsletter of Sai Engineering Foundation, 1(11) (New Shimla, Himachal Pradesh).

Singh, Namrata (2014) “Companies holding carbon credits stare at ‘real loss’”.  Times of India.  Viewed on 9 June 2014.  Website: http://timesofindia.indiatimes.com/business/india-business/Companies-holding-carbon-credits-stare-at-real-loss/articleshow/31803387.cms

United Nations Framework Convention on Climate Change (2014). “Project Cycle Search.” Viewed on 9 June 2014.  Website: http://cdm.unfccc.int/Projects/projsearch.html.


1] This study is based on six months of mixed methods, qualitative and quantitative field research that I and two research assistants.  After an initial exploration of the relevance of this topic in 2009, field research commenced in January, 2012.  We began by meeting key state level bureaucrats in Shimla and collecting secondary documents concerning all of the 49 commissioned small hydropower projects from the Himurja (Himachal Pradesh Energy Development Agency) office in Shimla.  We then turned to the district and project level research.  In each district where commissioned small hydropower projects were located, we interviewed district officials and collected secondary information concerning the projects.  We met with district commissioners, sub-division magistrates, tehsildars, and other concerned district officers.  We informed officials of our research, garnered key insights about small hydropower development from them, and collected relevant information and project related records and documents.  We then focused our research efforts on each commissioned small hydropower project.  At each project location, we interviewed project representatives (generally the project manager and occasionally the project owner) and the panchayat pradhans of affected panchayats.  We conducted structured and semi-structured survey interviews with project-affected households and other key informants.  We checked all the information we obtained using between-subject, cross-method, and cross-researcher triangulation (Newing 2011).  We ground truthed what we learned through meetings, surveys and interviews by walking transects from the diversion weir down to the tail race of every commissioned project.  We also photocopied key documents such as petitions, correspondence, court documents, and judicial papers.  Near the completion of the fieldwork, I met the same state level officers and bureaucrats with whom I had met at the beginning of the fieldwork in order to share preliminary research findings and conclusions.

[2] The Local Area Development Authority is a committee, comprised of the sub-district magistrate, other subdivisional officers, affected area panchayat pradhans, and a representative of the project developer.  The committee identifies and prioritizes potential projects, and then submits the prioritized list of projects to the district commissioner, who is to then approve and authorize the necessary expenditure.  Examples of projects include a veterinary dispensary, ayurvedic dispensary, cremation ground, village meeting hall, furniture for meeting hall, irrigation system (kuhl) repair, culverts and road repair, footbridges and playing field for youth.

[3] The labor-intensive project construction process lasts at least two years and often significantly longer.  To accomplish specific tasks, subcontractors hire large numbers of workers.  The majority of these workers live in temporary tin shed housing located along the banks of the stream or river from which the project diverts water.  These “labor camps” often house one hundred or more workers.  The fuelwood consumption for cooking and heating (notwithstanding attempts to provide LPG cylinders) associated with these camps poses a significant environmental concern, as does the fact that most of these labor camps do not have adequate provision for wastewater and sewage.  Consequently the adjacent stream, which is invariably used downstream for washing, irrigation and other purposes, and stream bank, are severely contaminated.  While this research focused on already constructed projects, local residents nevertheless often complained about the negative environmental, health, and social impacts of these labor camps.

[4] This is based on a comprehensive review of the Project Cycle Search webpages of the Clean Development Mechanism segment of the UNFCCC website, accessed on 9 June 2014.


[5] http://www.indiawaterportal.org/articles/irrigation-systems-himachal-threatened-hydropower-projects



Dams, Rivers & People

Dams, Rivers & People – October-November, 2013 Vol 11, Issue 9-10

The October – November, 2013 edition of SANDRP’s magazine ‘Dams, River and People‘  is now available online. This is the 9-10th issue of magazine in its 11th volume. Like its previous issues, this issue too is packed with indepth analysis of matters concerning dams, river as well as larger environment. The contents magazine are mentioned in the list below. The  magazine in pdf format is available here — https://sandrp.in/DRP_Oct_Nov_2013.pdf.  Several of the articles are also available in SANDRP’s blog and they can be viewed just by clicking on the name in the list. Enjoy reading.

Contents Page No
Ten Times Bigger Mohanpura Dam in Madhya Pradesh 1
Bansujara Dam: Another Shoddy EIA by WAPCOS 5
Community Fish Sanctuaries protect the fish and their rivers 9
Mah ignores Riverine Fisheries 11
E-flows in India – groping in darkness 12
MEF Committee on UKD Hydro: Need full mandate 14
A different COP that actually addresses climate change 15
New Publication: Yamuna Manifesto 16
Kasturirangan Report – a blueprint for political polarization in Kerala? 17
Gujrat builds Garudeshwar weir, Statue of Unity Without Clearances 20
“Address Impacts of Small Hydel Projects” 21
Media Hype Vs Reality 23
Hydro power projects violating SC order in greenest state of India 25
North East India Update 29
New Flood Forecasting System from Bangladesh 31
SANDRP’s Short Film on “Flood Ravage and the Dams of Uttarakhand” 32
Ministry of Environment and Forests · Uttarakhand · Western Ghats

Affected communities, scientists, experts urge the MoEF: “Address Impacts of Small Hydel Projects”

47 experts and organisations from across the country have written to the Ministry of Environment and Forests, including the Minister Ms. Jayathi Natarajan to include hydel projects between 1-25 MW under the purview of EIA Notification 2006. A similar letter has been sent to the Ministry of New and Renewable Energy and Minister Dr. Farooq Abdulla, to address the impacts of these projects which are governed by the MNRE.

Those who have written include eminent personalities like Former Water Resources Secretary: Dr. Ramaswamy Iyer, Former Ambassador of India: Ms. Madhu Bhaduri, Former Secretary of Power and Principle Advisor to Planning Commission: Dr. EAS Sarma, Former member of MoEF’s Forest Advisory Committee: Dr. Ullas Karanth, Head of IISC’s Centre for Ecological Sciences: Dr. TV Ramachandran, Head of People’s Science Institute: Dr. Ravi Chopra, experts from energy field, as well as activists, fisheries experts, scientists and importantly, representatives from affected communities

Letter sent to MoEF is below:

1. Smt. Jayanthi Natarajan,

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

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

2. Dr. V Rajagopalan,


Union Ministry of Environment and Forests, New Delhi, vrg.iyer@nic.in

 3. Mr. Maninder Singh

Joint Secretary,

Ministry of Environment and Forests, New Delhi, jsicmoef@nic.in

4. Mr. Ajay Tyagi

Joint Secretary,

Union Ministry of Environment and Forests, New Delhi a.tyagi@nic.in

5. Mr. B. B. Barman

Director (IA) River Valley Projects,

Union Ministry of Environment and Forests, New Delhi, bidhu-mef@nic.in

Please include Small Hydel Projects (1-25 MW) under the purview of EIA Notification 2006, considering their serious impacts on ecosystems and communities.

 Respected Madam Minister and office bearers of the MoEF,

We want to record our concern about serious impacts of small hydro projects on communities and ecosystems. Several groups from us have written to you in the past to urgently amend the EIA Notification 2006 and to include Small Hydel Projects in its ambit. Looking at the serious impacts of these projects, MoEF could have suo motto taken this initiative. But that has not happened, despite several amendments in the EIA Notification down the years.

SHPs can have and are having severe impacts on communities and ecosystems. This is significant as SHPs are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restrict itself to projects above 25 MW. The local communities are specifically affected as they do not have a platform to voice their concerns.

To highlight some of the impacts of SHPs:

Þ      70 SHPs in Karnataka under scanner following HC orders Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of SHPs on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats[1], bringing at least 70 SHPs under scanner, 40 in Hassan district, the rest in Mandya, Chamarajanagar and Uttara Kannada districts.

Gangani Small Hydro project in Uttarakhand across Yamuna which resulted in loss of lives and property during Uttarakhand floods. Photo: Yamuna Jiye Abhiyan

Þ      Karnataka HC no to SHPs in W Ghats In Feb 2013, the Karnataka High Court banned SHPs in Western Ghats[2], following a petition filed by Western Ghats Forum.

Þ      Uttarakhand Uttarakhand had earlier cancelled as many as 56 SHPs due to irregularities.

Þ      Western Ghats reports Considering the impacts of small hydro projects, the Madhav Gadgil Panel on Western Ghats recommended that in Ecologically sensitive zone 1, only projects below 10 MW with max height of 3 m and not involving forest land be taken up. In ESZ 2, projects upto 25 MW can be taken up only if dam height is below 15 m. This shows the nuanced approach that is required for small hydro projects. The panel also recommended that WGEA should include small hydro projects under EIA notification. Even the Kasturirangan committee has recommended that hydropower projects, including SHPs be allowed only on condition that 30% eflows are released, less than 50% of the river length is destroyed and there is 3 km free flowing river between projects. It has also recommended that hydropower projects, including small hydro projects should required environment clearance in the Ecologically Sensitive Area.

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

Þ      Bhagirathi ESA In the notified Bhagirathi ESA in Uttarakhand, the MoEF itself has implied that Hydro projects only of below 2 MW installed capacity can be taken up.

Þ      BWSSB asks for stoppage of SHPs In March 2013, Bangalore Water Supply and Sanitation Board (BWSSB) asked the Karnataka Power Corporation Limited (KPCL) to stop power generation from four mini hydel projects on Cauvery River as it was affecting drinking water supply to Bangalore.[3]

Most Small Hydro projects (1-25 MW) are grid connected, and local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitats and submergence.

Some examples in this regard are given here:

Þ      In Himachal, communities have protested strongly against 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests.

Protesst against 4.5 MW Hul project in Himachal/ Photo: Saal Ghati Bachao Samiti
Protesst against 4.5 MW Hul project in Himachal/ Photo: Saal Ghati Bachao Samiti

Þ      Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely bio-diverse forests, plantations and houses. This is being strongly opposed by local communities.

Þ      Greenko’s Perla and Shemburi Projects, Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects with a common dam. In the latter case, villagers assumed that the power canal is actually an irrigation canal for their fields. They only realised that they were alienated from their river after they were banished from approaching the canals.

Blatant violations in 24.75 MW Perla MHP and 24.75 MW Shemburi MHP across Netravathi. The common, huge barrage can be seen for two supposed seperate projects. Photo SANDRP
Blatant violations in 24.75 MW Perla MHP and 24.75 MW Shemburi MHP across Netravathi. The common, huge barrage can be seen for two supposed seperate projects. Photo SANDRP

Þ      Maruthi Gen projects, also in Karnataka, were not only clubbed together, but also hid their significant impact on forest land.

Þ      Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands. 24.75 MW Thangarabalu SHP on Krishna in Karnataka entails a dam of more than 22 meters in height, but has not divulged any data of submergence to villagers or Forest Department.

Þ      3 MW Beedalli MHP in Karnataka is on the boundary of the Pushpagiri Sanctuary and will severely affect wildlife, but does not envisage eflows release, fish passage or environmental mitigation measures

Þ      15 MW Barapole MHP in Kerala is affecting reserve forests in Karnataka. An earlier such project which was affecting Brahmagiri Sanctuary was opposed and cancelled due to pressure from conservation groups in Karnataka.

Þ      String of more than 98 mini hydel projects in various stages of operation, commissioning, construction and planning on the Cauvery in Karnataka has affected elephant corridors and movement.

Þ      Many mini hydel projects along the Cauvery in Karnataka are adjoining the Cauvery Wildlife Sanctuary, violating the 10 km buffer zone, while also encroaching on forest land.

The lovely bharachukki falls on Cuavery, also shackeled by many mini hydel projects. Photo: SANDRP
The lovely bharachukki falls on Cuavery, also shackeled by many mini hydel projects. Photo: SANDRP

Þ      In Himachal Pradesh, several hydel projects have been built on streams that are on ‘negative list for hydel projects’. Fisheries department wanted in-situ conservation of fish in these streams.

Þ      The 15 MW Om Power project near Palampur in Himachal Pradesh has caused extensive loss of forest cover and has disrupted irrigation and drinking water supply to downstream areas due to indiscriminate muck dumping.

Þ      The 1.5 MW Pakhnoj Nala Power project would impact the flourishing apple economy of 19 villages in Kullu District of Himachal Pradesh by disrupting irrigation supplies. The local people have been strongly opposing the project and the matter is pending in the court.

MoEF and NCDMA: National CDM Authority is under the MoEF and has been giving Host Country Approvals to CDM applications of several small hydel projects. Many of us have been writing to NCDMA and MoEF, providing clear evidence of the sham in CDM applications of projects and their validation reports. But the MoEF has never taken a notice of this. In fact, the MoEF certifies that these projects have positive impact on sustainable development without checking the ground situation, when the impacts of some of these projects on sustainable development are negative.

World over, it is being recognised that impact of small hydel projects is in fact comparable with large hydro projects and hence has to be assessed and mitigated.[4] Countries like Vietnam have cancelled 338 small hydel projects as their assessment indicated that environmental and social impacts of these projects is not commensurate with their benefits.[5]

We would be willing to present the problems from the ground to the MoEF. A holistic and truly sustainable approach can help boost renewable energy development in our country.

We are sure MoEF is committed to protecting environmental impacts, irrespective of the installed capacities of projects and will amend the EIA Notification to this effect urgently. Till such a credible regulatory system is in place, we request the MoEF to stop providing Host Country Approvals to Small Hydel Projects.

Some links and additional information related small hydro projects and their impacts can be found at:

Þ      http://www.himdhara.org/wp-content/uploads/2012/09/hul_comments-for-unfccc.pdf

Þ      http://www.thehindu.com/opinion/op-ed/neither-small-nor-green/article5045672.ece

Þ      https://sandrp.in/hydropower/PR_Halt_Mini_Hydel_Projects_in_Karnatka_pending_regulation_and_review_080812.pdf

Þ      http://www.downtoearth.org.in/content/karnataka-cancels-leases-two-mini-hydel-projects-western-ghats

Þ      http://www.daijiworld.com/news/news_disp.asp?n_id=124076,http://www.daijiworld.com/news/news_disp.asp?n_id=124443

Þ      Himdhara’s Report on Mini Hydel Projects in Himachal Pradesh: http://www.himdhara.org/2012/09/09/small-hydropower-big-impact-a-discussion-on-issues-facing-local-communities-in-himachal-pradesh/

Þ      Meeting on Mini hydel projects in Karnataka:  https://sandrp.in/hydropower/PR_Halt_Mini_Hydel_Projects_in_Karnatka_pending_regulation_and_review_080812.pdf

Þ      https://sandrp.wordpress.com/2013/03/16/impact-of-62-mini-hydel-projects-on-cauvery-on-bangalores-water-supply/

Þ      Comments on some of the CDM proposals for SHPs: https://sandrp.in/hydropower/

Looking forward to your response to the issues raised above.

Thanking You,

Yours Sincerely,

  1. Ramaswamy Iyer, Former Secretary, Ministry of Water Resources, New Delhiramaswamy.iyer@gmail.co
  2. EAS Sarma, Former Secretary, Ministry of Power, eassarma@gmail.com
  3. Madhu Bhaduri, Ambassador of India, ( Retd), madhu.bhaduri@gmail.com
  4. Dr. Ullas Karanth, Former member, Forest Advisory Committee, MoEF, Director for Science-AsiaWildlife Conservation Society and Director, Centre for Wildlife Studies, ukaranth@gmail.com
  5. Dr. Ravi Chopra, Director, People’s  Science Institute, Dehra Doon, Uttarakhand, psiddoon@gmail.com
  6. Dr.Bharat Jhunjhunwala, Uttarakhand, bharatjj@gmail.com
  7. Manoj Misra, Convener, Yamuna Jiye Abhiyaan, Delhi, yamunajiye@gmail.com
  8. Sharadcchandra Lele, Member, Elephant Task Force, Bangalore, Karnataka, sharad.lele@gmail.com
  9. Dr. T.V. Ramachandra, Head, Energy & Wetlands Research Group, Centre for Ecological Sciences, Indian Institute of Sciences, Bangalore
  10. Dr. Bijukumar, Associate Professor and Head, Dept. of Aquatic Biology & Fisheries University of Kerala, Thiruvananthapuram 695 581, Kerala, abiju@rediffmail.com/ bijupuzhayoram@gmail.com
  11. Neeraj Vagholikar, Kalpavriksh, Pune, nvagho@gmail.com
  12. Emmanuel Theophilus, Himal Prakriti, Pithoragarh, Uttarakhand,etheophilus@gmail.com
  13. Ramnarayan K, Himal Prakriti, Pithoragarh, Uttarakhandramnarayan.k@gmail.com,
  14. Malika Virdi, Himal Prakriti, Pithoragarh, Uttarakhand malika.virdi@gmail.com
  15. Dr. Latha Anantha, River Research Centre, Kerala, rrckerala@gmail.com
  16. Samir Mehta, River Basin Friends, Guwahati International Rivers, Mumbai, samir@internationalrivers.org
  17. Dr. Jagdish Krishnaswamy, Eco hydrologist, Bangalore, jagdish.krishnaswamy@gmail.com
  18. Dr. Shrinivas Badiger, Fellow, ATREE-Bengaluru, sbadiger@atree.org
  19. Dr. Bhaskar Acharya, ATREE, Bangalore, bhaskar.acharya@atree.org
  20. Dunu Roy, Hazards centre, Delhi, qadeeroy@gmail.com
  21. Sankar Ray, Journalist with specialisation in environmental issues, Kolkata sankar.ray@gmail.com
  22. Meher Engineer, mengineer2003@gmail.com
  23. Manshi Asher, Himdhara Collective, Himachal Pradesh, manshi.asher@gmail.com
  24. Rahul Saxena, Himdhara Collective, Himachal Pradesh, lokvigyankendra@gmail.com
  25. Prasad Chacko, Human Development and Research Centre, Ahmedabad, prasad.chacko@gmail.com
  26. Girin Chetia, North-East Affected Area Development Society (NEADS), Village & P.O.- DhekiakhowaDist.- Jorhat (Assam), neads_jorhat@yahoo.co.in; girin_neads@yahoo.co.in
  27. Ashwin Gambhir, Prayas Energy Group, Pune, ashwin@prayaspune.org
  28. Falguni Joshi, Gujarat Forum for CDM, Ahmedabad, gujaratforumoncdm@gmail.com
  29. Madhusoodhanan C.G., Research Scholar, IIT Bombay, madhucg@gmail.com
  30. Neethi Mahesh- Independent researcher, International collaborator- Mahseer Trust.neeti.mahesh@gmail.com
  31. Kedar Nadolli Gogate, Urumbi Ankattu Pratirodh Samiti, Hosmata, Karanataka, kedarnadoli@gmail.com
  32. Karunakar Gogate, President, Urumbi Ankattu Pratirodh Samiti, Hosmata, Karanataka
  33. Dr. Beerathadaka Rajesh, Kutrupady, Hosmata, Dakshin Kannada, drrajeshb23@gmail.com
  34. Beni Prasad (Chairperson) Jan Jagaran evam Vikas Sanstha, Village Sarsei, PO Haripur, Tehsil and District Kullu, Himachal Pradesh.
  35. Dr. Pushpal Thakur (General Secretary), Jan Jagaran evam Vikas Sanstha, Village Sarsei, PO Haripur, Tehsil and District Kullu, Himachal Pradesh.
  36. Lal Chand Katoch, Sanyojak, Jal Jangal Jameen Bachao Sangharsh Samiti (Majhat), Village Batahar, PO Haripur, Tehsil and District Kullu, Himachal Pradesh.
  37. Rahul Banerjee, Dhas Gramin Vikas Kendra, Indore. rahul.indauri@gmail.com
  38. Subhadra Khaperde, Kansari nu Vadavno, Khargone subhadra.khaperde@gmail.com
  39. Shankar Tadwal, Khedut Mazdoor Chetna Sangath, Alirajpur shankarkmcs@rediffmail.com,
  40. Dr. AK Malhotra – Trustee, SAI (Save Animals Initiative) Sanctuary Trust, Kodagu District, Karnataka, saisanctuary@gmail.com
  41. Gopakumar Menon, Nityata Foundation, Bangalore, gopakumar.rootcause@gmail.com
  42. Nisarg Prakash, Nityata Foundation,Bangalore, nisargprakash@gmail.com
  43. Tarun Nair, Researchers for Wildlife Conservation, tarunnair1982@gmail.com
  44. Dr Shambu Prasad, Chebrolu, Bhubaneshwar, shambuprasad@gmail.com
  45. Anush Shetty, Bangalore, anushshetty@gmail.com
  46. Himanshu Thakkar, SANDRP, New Delhi, ht.sandrp@gmail.com
  47. Parineeta Dandekar, SANDRP, Pune, parineeta.dandekar@gmail.com

Small Hydro, MNRE and environmental impacts: Nero’s fiddle playing

Ministry of New and Renewable Energy (MNRE), Government of India recently published a report on ‘Developmental Impacts and Sustainable Governance Aspects of Renewable Energy Projects’. Around the same time, Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of Small Hydro Projects (SHPs) on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats[i]. SHPs are hydel projects between 2 MW-25 MW installed capacity. Looking at the unaddressed impacts of SHPs, such a report by MNRE was sorely needed and was looked at as a welcome initiative.

Unfortunately, the MNRE Report has entirely excluded the small hydel sector from its assessment.

Agitation against 4.5 MW Hul HEP in Himachal Pradesh as it is affecting forests, irrigation channels, mills and drinking water sources of villagers. Source: Sal Ghati Bachao Andolan
Agitation against 4.5 MW Hul HEP in Himachal Pradesh as it is affecting forests, irrigation channels, mills and drinking water sources of villagers. Source: Sal Ghati Bachao Andolan

SHPs can have and are having severe impacts on communities and ecosystems. They fall under the MNRE and are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restricts itself to projects above 25 MW. They get subsidies, tax rebates, tax holidays from the MNRE, apart from other benefits and preferential tariffs from states. Most of the SHP sector is crowded with private investors, wanting to make a quick buck from rivers, without any regulations. The rush is most prominent in Uttarakhand, Himachal Pradesh, Karnataka, Odisha and now Kerala, where cascades of such dams are coming across pristine rivers.

Despite MNRE’s supposed intention, most SHPs are not supplying electricity to any “remote and inaccessible areas”.[ii] Most projects are grid connected, so the local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitat loss, submergence and fraudulent practices.

Following a petition from Western Ghats Forum, Karnataka High Court has ordered a ban on SHPs in Western Ghats, Uttarakhand High Court had cancelled as many as 56 SHPs. In Himachal, communities fought a long and lonely struggle against the 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests. [iii]Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely biodiverse forests, plantations and houses.[iv] Greenko’s Perla and Shemburi Projects[v], Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects on the same river with a common dam. Maruthi Gen projects, also in Karnataka were not only clubbed together, but also hid their significant impact on forest land[vi] . Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands.

The issues are serious and have been raised by many. As the projects are outside the purview of EIA Notification, none of their impacts are studied; neither do the communities get a platform to record their protests. Hence, a study on the environmental impacts of renewable energy projects was needed to address these issues.

Considering these serious aspects, it is very surprising that MNRE Report on impacts of Renewable Energy projects has chosen not to look at this sector at all.  The report does not assess impacts of any such projects, neither does it offer any recommendations for this sector under MNRE. It only makes a sketchy study of wind and solar energy projects. The report makes incorrect statements like: “All hydroelectric power projects have to get environmental clearances which under two categories: category B if capacity of projects is between 50 to 25 MW”, effectively refusing to acknowledge hundreds of SHPs, under the purview of MNRE not requiring any environmental regulation.It states incorrect facts like “There are institutions and processes governing every operational aspect of RE project development and local institutions, in the form of democratic bodies, to safeguard micro level ecological and social concerns.” This is patently untrue for SHPs, which are highly unregulated and non-participatory.

The TORs of the study stress assessment of impacts of solar and wind projects, but do not exclude hydel projects. While TORs should have stressed on impacts of SHPs, looking at the number of protests and inherent problems, that does not warrant report writers’ complete neglect of this sector. Executive Summary states that this study has been done in response to WGEEP and HLWG report recommendations. Despite the fact that WGEEP specifically banned SHPs in Ecologically Sensitive Zone I, this report has chosen to turn a Nelson’s eye to the sector.

Even with regards to solar and wind projects, the report seems inadequate. For primary data, the authors visited 6 wind energy farms and 1 solar energy site. At the solar energy site, interaction was exclusively with project management and engineers. Social and environmental impacts cannot be understood through interviews with project management alone. While the report documents the devastation around wind energy farms in Maharashtra, it is not reflected in conclusions and recommendations.

The report is entirely silent on Clean Development Mechanism applications of SHPs, which are routinely full of lies and incorrect information. CDM credits give project additional pocketable profits, while the affected communities get only unaddressed impacts. Considering the forest land submerged by Small hydel Projects, and their impacts on adaptation and mitigation potential of local communities, they are also problematic from perspective of climate change.

The report ends with unacceptable conclusions and recommendations, most surprising being: “The RE project development is regulated by environmental and social governance system. The current regulatory mechanism is strong… No new changes are required in the legal framework or the governance structure to mitigate environmental and social impacts.” It even pushes for a “fast channel for quick clearances”.

The report says that environmental impacts of RE projects “are not significant” and social impacts of are “not negative”. Report writers need to visit SHPs in Himachal, Uttarakhand and Karnataka where people have lost irrigation channels, water mills, plantations and even lives, when sudden water was released from projects like Perla-Shemburi in Bantwal[vii], Karnataka.

Sweeping conclusions and recommendations for the entire RE sector is highly problematic, especially when there are several examples of unaddressed impacts, which depend on specific site and project.

The report does include some welcome recommendations. These include: siting policy for projects including zonation and increased participation of local communities in planning and decision making about natural resources, affected by the projects. It recommends issuing clear guidelines such that community welfare is not compromised due to RE projects and about proponent’s responsibilities in the zone of influence of the RE project. The report recommends zonation of projects in go-green (no objection), go slow and no go areas for RE project development. These need to be implemented by the MNRE. If the report would have looked at the entire RE sector, it could have made some valuable observations and recommendations.

There is a very urgent need to bring projects between 1 – 25 MW under the purview of EIA Notification 2006. Several representations and evidences later, it is clear that MoEF does not have the will to do so. It was expected that MNRE will raise these issues, but if this report is an indication, MNRE too is not willing to accept the challenges of SHP development, or regulating the impacts.

Lower installed capacity does not always mean lower social or environmental impacts. Targeted efforts are needed to assess, address and mitigate impacts. For this, the first step will be to acknowledge impacts, not brush them under the carpet. World over, impacts of small hydro projects are being highlighted.

As India is looking at expanding its renewable energy sector, it needs to be truly sustainable and clean, not just an assumption. Hence, MNRE’s effort at addressing environmental and social impacts of renewable energy projects is a welcome move. But by refusing to acknowledge the impacts of Small Hydel Projects in its report, MNRE reminds one of Nero, playing his fiddle, when the forests around are being submerged or destroyed in the name of clean energy.

Parineeta Dandekar