Year-end provides a wonderful opportunity for us to take stock of siatuations. If we look at India’s water sector, the above-average rainfall in 2013 monsoon would mean good agricultural production.
But the water sector as a whole is showing increasing signs of trouble.
Let us take few examples. The most striking crisis of 2013 was the unprecedented flood disaster in Uttarakhand in June where thousands perished. Experts and media called it a man-made disaster with a significant role played by existing and under construction hydropower projects and other unsustainable infrastructure. (SANDRPs Report) The Supreme Court order of Aug 13, 2013 directed the Union Ministry of Environment and Forests to set up a committee to look into the role played by existing and under construction hydropower projects in the disaster and also directed that no further clearance to any hydropower projects be given till further orders. This order was possibly the only hopeful sign since Uttarakhand government, other Himalayan states or the central agencies including NDMA and MoEF, seem to have learnt no lessons from the disaster.
Destroyed Vishnuprayag HEP on Alaknanda . Courtesy: Matu Jan Sangathan
Earlier in 2012-13 we saw triple crisis in Maharashtra in the form of worst drought in 40 years, worst irrigation scam in independent India and agitation against diversion of huge quantity of water from agriculture to non agriculture sector without any participatory process. In Andhra Pradesh too, a massive irrigation scam was exposed by the CAG report. In fact inequity in the distribution of costs and benefits related to water sector project lies at the heart of the bifurcation of the troubled state.
Dry Seena River in Madha in March 2013. Madha has a dense concentration of Sugar Factories. Photo: SANDRP
In Chhattisgarh and downstream Orissa, thermal power plans of massive capacities are going to impact the water situation so fundamentally that big trouble is likely to erupt there, which may impact several other sectors. Madhya Pradesh government is on a big dam building spree in all its river basins, including Narmada, Chambal and also the water scarce Bundelkhand. All of these projects are for canal irrigation when canal irrigation has failed to add any area to the total net irrigation at national level for over two decades now. We could see a new massive irrigation scam in MP in coming years, in addition to agitations and interstate disputes. Gujarat too saw a very bad drought in 2012-13, and there is increasing perception that Gujarat government is by design not building the distribution network to take the Narmada Dam waters to Kutch and Saurashtra, for whom the project was justified and built.
In North East India it is now two years since massive agitation has led to stoppage of work at ongoing 2000 MW Lower Subansiri hydropower project. This is India’s largest under construction hydropower project on which over Rs 5000 crores have been spent without putting in place basic studies or participatory decision making process. Similar fate awaits if the government goes ahead with other hydropower development projects in the region without learning lessons from this episode. During the year, Forest Advisory Committee’s rejection to grant forest clearance to 3000 MW Dibang and 1500 MW Tipaimukh projects in the region was a good sign, so is the stoppage of work at Maphithel dam in Manipur by the National Green Tribunal.
Breathtaking floodplains of the Lohit River, an important tributary of the Brahmaputra, threatened by the 1750 MW Lower Demwe Dam. Photo: Neeraj Vagholikar
But we have seen no sign of improvement in environment governance. The year saw the questionable appointment of former Coal Secretary as chairman of the Expert Appraisal Committee on River Valley Committee, by Union Ministry of Environment and Forest. In fact, several of the new appointees in the committee do not have any background in environmental issues. The year also began on the wrong note with the environment clearance to the 620 MW Luhri hydropower project in Himachal Pradesh, designed to destroy the last flowing stretch of SutlejRiver in the state. In April 2013, the Forest Advisory Committee took the most shocking decision of approving the completely unjustifiable Kalu dam for Mumbai Metropolitan Region, without any assessments. The same FAC had rejected the proposal one year back and the reasons for that rejections stand even today.
In Western Ghats, the decision of the Union government of dumping the Western Ghats Expert Ecology Panel Report (Gadgil Report) and instead in principle accepting the-much criticized Kasturirangan committee Report has already led to full blown crisis in Kerala and is threatening to engulf more areas. This crisis was completely avoidable if the MoEF, in stead had used last two years to encourage public education on the need for implementing the Gadgil panel recommendations.
While relatively poorer states like Rajasthan, Madhya Pradesh, Chhattisgarh and Orissa has shown big jump in agriculture growth rates in recent years, these have come at the cost of huge depletion in groundwater levels. As Vijayshankar of Samaj Pragati Sahyog said at a conference in Delhi recently, in Rajasthan, the level of groundwater development (ratio of annual groundwater draft to annual utilizable recharge) increased alarmingly from 59% in 1995 to 135% in 2009, indicating that Rajasthan is now in the overexploited category. Of the 236 blocks in Rajasthan, massive 164 (69%) were in over exploited category in 2009. In Madhya Pradesh, while the state groundwater use has moved from 48 to 56%, about 89 blocks out of total 313 (28%) are using unsafe levels of groundwater.
This fresh news of groundwater depletion in new areas is bad sign in medium and long range. “Over the last four decades, around 84 per cent of the total addition to the net irrigated area has come from groundwater. India is by far the largest and fastest growing consumer of groundwater in the world. But groundwater is being exploited beyond sustainable levels and with an estimated 30 million groundwater structures in play, India may be hurtling towards a serious crisis of groundwater over-extraction and quality deterioration”, said Planning Commission member Mihir Shah at a recent meeting in Delhi. 12th Five Year Plan has started the new scheme of mapping groundwater aquifers of India, which is a useful step, but we have yet to crack the puzzle of how to regulate groundwater use to ensure its equitable and sustainable use for priority sectors.
The state of our rivers as also the reservoirs and other water infrastructure is deteriorating but our water resources establishment has shown little concern for that. The IIT consortium report on the Ganga River Basin Management Plan is due soon, but if the pathetic interim report is any sign, there is little hope there.
The year 2012 ended with the National Water Resources Council approving the National Water Policy 2012. At the end of 2013 we have yet to see a credible plan in place for implementing the policy provisions. The year saw proposal from Union Ministry of Water Resources for a new Draft National Water Framework Law, Draft River Basin Management Bill and draft National Policy Guidelines for water sharing/ distribution amongst states. None of them have reached finality and all of them are likely to be opposed by states as an encroachment on their constitutional domain. In fact the interstate Mahadayi River conflict has reached a flashpoint with upstream Karnataka and Maharashtra starting dams in the basin without even statutory clearances from the centre or consent from downstream state of Goa.
While all this looks rather bleak, increasing agitations and informed protests all over India on water issues is certainly hopeful sign. More community groups are challenging inadequately done environmental impact assessments, cumulative impact assessments, basin studies, downstream impact assessments, concepts like eflows etc, raising very informed and pertinent questions. Most of these studies have been the monopoly of select, fraudulent EIA agencies. Critical questions indicate that these studies cannot be done excluding local communities, their knowledge and their concerns. Among other hopeful signs include some of the decisions of the National Green Tribunal on Yamuna and other rivers.
The underlying theme of these events is the increasing trend of state in India working for the interest of the corporate interests to the exclusion of people, environment and democracy. It is a challenge for us all to see how to reverse this trend.
The year 2013 also marks the end of the current term of the Union government. While there is little to hope from the two main political parties ruling the centre and the states mentioned above, perhaps the emerging political alternative in Delhi will grow and move in right direction. Let us hope for the best.
River Kali, before it enters Dandeli in Karnataka is a breathtaking sight..
Its waters are emerald green, flowing steadily. Its banks are thickly forested with a continuous canopy. Endemic species like Malabar Giant Squirrel, Malabar Pied Hornbills, Malabar Gray Hornbills are a common sight here. Down the river, a monitor lizard is stretched across a branch, low over the waters. Fishing eagles and several kinds of Kingfishers look for fish. Fisher folk hover along the banks in beautiful coracles, laying hooks in the riparian vegetation.
During our visit to the Kali, my six-year-old swam in the river and could not believe that the river back in his home-town was once as clear as this!
Emerald waters of the Kali Photo: Author
It’s hard to imagine that it was a touch-and-go for this stretch of Kali…
If it were not for some brave, timely advocacy and strong local action, most of this stretch would have been submerged. Rest of the river would have been diverted through a tunnel or silenced in a steady pool of a reservoir: the way many Indian rivers are silenced. There would have been no river, no riparian forests and possibly no swimming.
Malabar Pied and Malabar Gray Hornbills on the banks of Kali Photo: Author
Dams on Kali: Kali has seen far too much damming. According to Kali Bachao Andolan, a network of organizations working to protect Kali River, more than 5 dams across the river have already submerged 32,000 acres of forests in the Western Ghats. According to Karnataka Power Corporation website, “The west flowing Kalinadi has its origin at an elevation of 900 m, near the DiggiVillage in the Western Ghats of Karnataka. Its 180-km long journey ends at the Arabian Sea near Karwar.”
After its origin, it’s dammed at Supa in Joida Taluk of the Uttara Kannada District. The submergence of Supa Dam is a site to behold. Stretching endlessly like an ocean, this dam submerged more than 24 villages and hundreds of hectares of forests. One of the dam evictees, an old, frail man now tells me, “Even now in summers, when the waters recede, I can see my village and my temple. We try to go there some times. I can see all my past life there, for a brief period, before it all goes under water again”.
Extensive submergence of the Supa Dam Photo: Author
Downstream the 101 m-high Supa Dam (100 MW), the river flows down through Dandeli town, taking huge pollution from West Coast Paper Mills on the way. From here it is dammed at Bomanhalli Pick up Dam, from where it is diverted to Nagazhari Powerhouse (870 MW), then to Kodasalli Dam and powerhouse (120 MW) and then at Kadra Dam and powerhouse (150 MW). If we look at the flow chart of Kali Nadi Dams, the river seems to be flowing from one reservoir into the next, with nearly no free flowing river stretch between two dams. Its main tributaries Kaneri and Tatihalla have been dammed too.[1] The power generation performance of Kali dams for the last 27 years is shown in the graph above.
There is a stretch downstream the Supa dam to Bomanhalli Pick up dam, where the Kali still flows. This again is controlled flow, regulated by the Supa Dam. But this is the precise stretch which was also targeted to be dammed in 2000’s. An 18 MW project by Murudeshwar Power Corporation Limited (MPCL) was proposed to come up at Mavlangi village downstream Supa Dam. According to Kali Bachao Andolan, it would have meant submergence of 210 hectares of land, including 70 hectares of forest land, next to the Dandeli Sanctuary. Kali Bachao Andolan, including Parisar Samrakshana Samiti, Sirsi and Environment Support Group (ESG), Bangalore, highlighted that Uttar Kannada District only needed 17 MW electricity (in 2000) while it was producing more than 1200 MW electricity and one more dam at a huge social and ecological costs cannot be justified. More importantly, ESG exposed that the Rapid EIA (Environment Impact Assessment) report done by reputed consultancy Ernst and Young for the proponent, was in fact a copy-paste of a different EIA, done by a different agency for a different river! A strong campaign was built around this, which garnered public and media support.
Guide from one of the homestay-resorts, a resident of Dandeli Photo: Author
In 2006, the Forest Advisory Committee of the MoEF rejected Forest Clearance for this project. The project was also strongly opposed internally within the Karnataka Government by the Department of Tourism. Surprisingly, MoEF did not book the EIA agent (Ernst and Young) or the proponent (MPCL) for submitting an entirely false report! Even more shockingly, this EIA was later done by TERI (The Energy Research Institute), which also completed the study in one month and came up with a dubious report based on secondary data. However, strong opposition from local groups, ESG, and even within Karnataka Government resulted in rejection of the proposal by a number of authorities, including the Department of Industries and Collectorate of Uttar Kannada. Since then, the project has tried to raise its head again, only to be opposed strongly.[2]
Fishing along the Kali in the early morning Photo: Author
Around 10 years down the line, what does this small stretch of free flowing river mean?
I traveled in Uttara Kannada as a tourist in November 2013. A thriving tourism industry now exists on the banks of Kali and the river is now world-renowned as one of the best rivers for white-water rafting in India. There is boating, canoeing, kayaking, swimming, fishing along this stretch of the river. Pools and islands in the river provide perfect habitats for various species as well as for naturalists and bird watchers. The range of recreational activities that take place along the river are endless. Fishermen still lay their nets across this stretch and catch some fish (though I was told that fish greatly reduced after Supa Dam was commissioned in 1985). Along the banks of the river in this stretch, a thick riparian forest flourishes, providing habitat and corridor to several species.
But more importantly, this tiny stretch is a reminder of how this great river once was. A humbling reminder.
According to Lal, now a boatman and guide from Dandeli, the river stretch which could have been dammed, now provides tourism related employment to around 1000 people from around the region. The region supports around 8 resorts and several homestays. It has created multiple employment opportunities for locals like naturalists, guides, white-water trainers, etc. Some of the locals are descendants of the Supa Dam evictees. One of them says, “The relocated colony of Supa evictees is called Ramnagara, actually it is Vanvasanagara. If it were not for the tourism, I would have migrated to Goa or Belgaon. We saw the fate of Supa dam displaced and would not allow one more dam, no matter how small or big, to affect us again.”
Many ways to enjoy a flowing river: Rafting, canoeing, swimming Photo: Author
The struggle against 18 MW mini hydel has been significant in a number of ways. EIA and public hearing for the project were the two events where protests were recorded. It was through these platforms that the extent of the impacts of the projects was known and could be opposed. However, after this, a newer version of EIA Notification was adopted in Sept 2006 which excludes hydel projects below 25 MW from its ambit! This has been a ecologically senseless move as projects which have severe impacts on the ecology do not even need a public hearing and an EIA now! We, and several experts and organizations, have raised this point a number of times with the MoEF, but MoEF is yet to respond.
One more strong point of the struggle was a more than 20-year-old order by Karnataka government categorically stating that since the Kali river is so heavily dammed (five major dams on this short 186 kilometre long river, destroying most of its forests and displacing thousands of tribal and forest dwelling communities), no more dams, big or small, shall be allowed further across this river. This has been a very significant order.
Even today, when more and more bumper to bumper dams in the Himalayas and Western Ghats are killing our rivers, our Ministry of Environment and Forests does not have a clear guideline for protecting certain stretches of rivers from dams or declaring them as no-dam stretches. There exists no such order protecting over-dammed, collapsing rivers.The only report which actually recommended that 24 dams in the Upper Ganga basin should be dropped due to their impact on ecosystems, has not been complied with by the MoEF. Dams are coming up in cascades, without leaving any free-flowing riverine stretch between two projects. Nothing is being done about this. The MoEF’s Expert Appraisal Committee on River Valley Projects now has a weak norm of leaving a bare kilometer of flowing river between projects. But this norm too gets twisted and violated.
Avay Shukla committee appointed by Himachal Pradesh High Court recommended that projects should have at least 5 kilometers of free flowing river between them. But MoEF does not seem to support this. In fact, a flowing river seems to have no value in our governance system.
However, as the Kali experience shows, a flowing river is good for ecology and is good for the people too.
Let us take this opportunity to thank the Kali Bachao Andolan and the local communities for protecting the last remaining free flowing stretch of Kali… so that we can catch a glimpse of how a free-flowing river looks like!
– Parineeta Dandekar
Local children rafting along the Kali Photo: Author
Background Karnataka has been mulling over diverting waters of the west flowing rivers to the east for many years. Netravathi-Hemavathy Link was proposed by the National Water Development Agency (NWDA) as a part of peninsular component of the River linking project. In the meantime, Karnataka appointed a committee under the leadership of Dr. G. S. Paramshivaiah which worked on a plan to divert waters from west-flowing rivers including Netravathi to 7 districts of Bayaleseeme region including Kolar, Bangalore, Tumkur, Ramanagara, Chikmagalore, Chikkaballapur, etc.
River Gundia, formed by Yettinahole and other streams which are to be diverted by Yettinahole Diversion Project Photo: SANDRP
But currently, the Karnataka Government is seriously considering Yettinahole Diversion Project which plans to divert head waters of the Gundia River ( a tributary of the Kumardhara, which is a tributary of the Netravathi) in the west and transfer this water to the other end of the state, in the east. It has been reported that tenders for this project have been floated already. Its Project Report (June 2012 version) is titled as ‘Scheme for diversion of flood water from Sakleshpura (West) to Kolar/ Chikkaballapra Districts (East)’.
NOTE, SANDRP: 4 Sept 2014:
Following the efforts of several groups, including SANDRP, Yettinahole Project was strongly opposed, though advocacy and on-ground struggle. In response, the Karnataka government has made substantial changes in the DPR of the Project which was completed in late 2013/early 2014. Several elements have been changed cosmetically, to counter our valid points, thus vindicating the points raised below. SANDRP has published a detailed assessment of this DPR. It can be found here: Yettinahole DPR: New Avtaar, Old Problems. https://sandrp.wordpress.com/2014/09/18/yettinahole-diversion-dpr-new-avataar-old-problems/
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In Karnataka Budget Part I, February 2012, Rs 200 Crores have been allocated for making DPR and initial works while Rs 2670 Crores have been sanctioned and Rs 850 Crores allocated in 2013-14 for lift works upto Harvanahalli in Sakaleshpura.[1] All these allocations have been made without a Detailed Project Report, cost benefit assessment, options assessment or environmental and social appraisal of the scheme, or any statutory clearances. This is highly problematic as this assessment indicates that this energy intensive project will have profound impact on Western Ghats biodiversity, wildlife and livelihoods
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SANDRP analyzed the Project Report (PR) which was obtained under RTI by Mr. Kishore Kumar Hongadhalla, who had specifically asked for a ‘Detailed’ Project Report. The total cost of the project as per the PR is 8323 Crores. But the estimate does not include many costs like Rehabilitation and Resettlement (R & R), complete land acquisition, construction of reservoirs on Palar Basin as mentioned in the Project Report, pipeline to 337 tanks, Forest NPV, etc. If these are included, cost of the project will certainly go beyond Rs 10000 crores /Rs 100 billion.
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Purpose of this scheme is stated as drinking water supply to Kolar and Chikkaballapur Districts. However, analysis of the Project Report indicates that drinking water to be supplied to Kolar and Chikkaballapur will be a bare 2.81 TMC or 11.7% of the 24.01 TMC diverted. If water is supplied to Bangalore (urban) as is said in the Budget, but not the Project Report, then water supplied to Kolar and Chikkaballapur will be even less, possibly nil.
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Analysis of the Project Report and site visits to Yettinahole and surrounding catchments indicate that this project is economically, socially and technically inviable and will have a massive impact on the ecology of the Western Ghats and eastern plains. The analysis also assesses the claim of providing drinking water to Kolar and Chikkaballapur: whether it is viable, desirable and optimal option.
I. The Project
The project involves construction of 8 dams in 2 phases at the head waters of Gundia River basin, a tributary of Kumaradhara, which in turn is a major tributary of the West flowing Netravathi River, the lifeline of Mangalore and Dakshin Kannada districts. The Project Report insists on calling these as weirs, but the drawings[1] indicate the height these dams as 15 meters from deepest foundation, making them large dams, as per the definition of International Commission on Large Dams {ICOLD}.
Dams and rising mains in Western Ghats: 2 dams are planned across Yettinahole stream, 2 on its tributaries, 2 across Kadumanehole stream, 1 across Kerihole stream and 1 across Hongadhalla stream. All these streams are rivulets which join at various points to make river Gundia. Rising mains (large pipelines that transport water under pressure) from these projects will pump water into 3 delivery chambers. From the delivery chambers, water will be lifted to an intermediate pumping station at Doddanagara in Sakaleshpur. From Doddanagara, water will be lifted again and conveyed to Delivery chamber 4 located near Harvanahalli in Sakaleshpura.
Schematic Representation of pumping involved in Yettinahole Diversion Project. From: KNNL Project Report Volume I)
233 kms long Gravity canal: From Harvanahalli, water will flow through a gravity canal of 233 kms (Proponent says 250 kms in MoEF Meeting) in length to Tumkur.
Devaranya Durga Reservoir: From Tumkur, again the water will be lifted through a rising main and will culminate into a reservoir to be built at Devaranyadurga. This reservoir will have a height of 68 meters and gross storage capacity of 11 TMC. It will submerge approximately 980.4 hectares of land, including forests.
When this project was discussed in the Expert Appraisal Committee meeting of the Ministry of environment and Forests, the proponents have claimed that Devaranyadurga Reservoir will submerge 1200 hectares of land, of which 50% will be forest land and will also submerge at least 2 villages.[2]
From here, two rising mains of 80 kms and 55 kms will again lift and convey water to Chikkaballapura and Kolar respectively. In Chikkaballapura and Kolar, the rising main will feed various streams and rivers and will have dedicated pipelines to feed Minor Irrigation (MI) and Zilla Parishad (ZP) tanks. Scheme envisages feeding 198 tanks in Chikkaballapur and 139 tanks in Kolar District.
The scheme envisages providing 14 TMC for Hassan, Chikkamagalore, Tumkur and Bangalore rural and 10 TMC for Kolar and Chikkaballapur, through the dam at Devaranyadurga. So, the claims that Kolar and Chikkaballapur will get 24 TMC water is false. The project report is titled ‘Scheme of diversion of floodwaters to Chikkaballpur and Kolar’ but these districts seem to be getting less than 50% of the diverted water. As we see in later sections, of this 10 TMC barely 2.81 TMC is earmarked for drinking water supply.
Locations of Dams/Weirs of Yettinahole Project SANDRP
New Reservoirs planned
Chikkaballapur District:
New reservoir across Kushavathy River at Gudibande.
A new reservoir At Timassandra across Palar river
Kolar District: Bethmangala Tank to be used as an important reservoir
At Tanadihalli on Palar River North to store 2.20 TMC water
Electricity needed: As per the project Report, the scheme will require massive 370 MW of electricity.
Yettinahole River Photo: SANDRP
Volume of water to be diverted: 24.01 TMC water is proposed to be diverted between June-November from a catchment area of 89.66 sq kilometers (8966 hectares). It has to be noted that 24.01 TMC water is available at 50% dependability. So, in 50% years under consideration, 24.01 TMC volume would not be available for diversion. The structures and conveyance system has also been designed at 50% dependability. This may imply several things:
The scheme can work beyond June-November
The scheme can divert more than 24 TMC waters from Yettinahole
The scheme can be used later for diverting waters of other rivers.
This further warrants a serious look at the entire project.
II. Environmental Impact of the Project on Western Ghats and other regions
Impact on Forest Land and Wildlife
The exact extent of revenue, private, agriculture and forest land required for the scheme is not known from the PR. The report (Volume II, Estimates) mentions a head ‘clearing of thick forest by burning’ under costs for laying rising mains from dams to pumping stations. According to these estimates, 107.27 hectares of thick forests will have to be cut or burnt for the rising mains alone.
Yettinahole Catchment and surrounding forests Photo: SANDRP
The forest land involved in submergence of dams, approach roads, workers colonies, muck dumping sites, electrical substations, mining of materials for the project, destruction due to blasting, etc. will be additional. The project report does not provide any of these details.
Most of the forests in the vicinity of Yettinahole, Kadumane hole, Kerihole and Hongadhalla are not only reserved forests, but important wildlife corridors. When IISC studied this region it recorded 119 trees species, 63 shrubs and climbers, 57 herbs and 54 pteridophytes[3], 44 species of butterflies, 4 dragon and damsel flies, 23 species of amphibians including the threatened Gundia Indian Frog, 32 reptiles, 91 birds and 22 mammals including Tiger, Lion Tailed Macaque, Elephant, Slender Loris and Gaur.
Elephant dung at a KPCL survey in Hongadhalla region, to be affected by Yattinahole Diversion Project. Photo: IISc
The region is witnessing rising man animal conflicts due to destruction and degradation of habitats. During 2002-2012-13, 34 people have died and 17 elephants have been electrocuted in Sakaleshwar Taluk alone (http://www.thehindu.com/news/national/karnataka/elephant-encounter-is-an-everyday-affair-for-them/article4874172.ece). The Karnataka Elephant Task Force has acknowledged the impact of mini hydel projects in Sakaleshpur on Elephant corridors and has given strong recommendations about reviewing clearance and canceling projects which affect elephant distribution areas negative and do not comply with existing laws.
Dams, roads, blasting, muck disposal, workers colonies, sub stations, increased traffic in this region will have a pronounced impact on the wildlife, including the elephants. Any more stress on these regions will precipitate in furthering of conflicts and disturbance.
Environmental Flows As per the working tables, all inflow from the headwaters will be diverted for the most of June, parts of July and August and all of September, October and November. The streams will be completely dry for most days during this period. (Project Report Vol. I, Page A 21) There has been no provision made for environmental flows. This will be extremely damaging for the downstream ecology, wildlife and forests. This issues needs urgent attention and studies.
The scheme may look inviable if eflows are released, as they must be, from the dams/ dams into the downstream river.
Impact on fish assemblages and fish sanctuaries Kumaradhara and Netravathi are home to some rare community conserved fish sanctuaries. Fish sanctuaries exist at Kukke Subramanya, Nakur Gaya and Yenekal, all of which are downstream from the proposed diversion. The fish assemblages, their feeding and breeding patterns are highly affected by flow. Any drastic changes in flow regime will affect these species.
Gundia River itself has several rare and endangered fish species. 3 new fish species have been discovered and 1 rediscovered in Kumardhara river basin between 2012-13[4]
Congregation of the endangered Mahseer fish at Yenekal Fish Sanctuary, Kumaradhara River downstream of proposed Yettinahole diversion. Photo: SANDRP
Blasting using dynamite The project report and estimates state that hard rock will need to be blasted extensively with dynamite. Dynamite blasting will have severe negative impact on the wildlife of the region. Blasting also has documented harmful effects on groundwater aquifers and can affect the existing water sources and water holes of the wildlife.
Muck generation and disposal As per the project report, muck generated for laying the rising mains alone will be to the tune of 13,02,837 cubic meters. All of this muck will be generated close to the rivers, in forest areas. Dumping of this muck will have a huge negative impact on water quality, forests and wildlife. Uttarakhand disaster in June 2013 highlighted the how muck is routinely disposed into rivers and the havoc this causes in the downstream.
Additional muck will be generated during dam/ dam construction, approach, colonies, substations, etc. The impact of this will be compounded.
Approach roads, workers colonies All the dams/ dams, rising mains, electric substations will require approach roads which will pass through forests, further impacting forests and wildlife. Workers colonies and waste disposal will again have additional impacts on the region.
Diverting entire rivers and not just floodwaters The scheme purports that it is diverting only the flood waters of these rivers. However, the yield of all the rivers at 50% dependability between June-November is 28.94 TMC, out of which 24.01 TMC will be diverted. This leaves just 4.93 TMC for the downstream. This is maximum diversion of the rivers and not just ‘flood waters’ or overflow.
Also, even when rainfall is low, the scheme will divert all available water till it gets its share of 24.01 TMC, which will then dry the rivers completely in the downstream.
These are monsoon-fed rivers. Only source of water for these rivers is the monsoon, which also replenishes groundwater, which constitutes the base flow in non-monsoon months. This diversion in monsoon months will have a huge impact on water availability in non-monsoon months also in these rivers and which in turn will have impact on the biodiversity and livelihoods.
III. Supposed Beneficiaries: Contradictions between Budget and Project Report
As stated (verbatim) in the Project Report, following are the beneficiaries of the project (Project Report Volume I: Section 4.7, Page 52)
Selected parts in Hassan District
Selected towns in Chikmagalur, Chitradurga by feeding Vedavathi river
Tumkur, Madhugiri, Pavagada and Koratagere Taluk
Chamrajsagar reservoir
Water to Devanhalli Industrial Area
Augmentation of Hesarghatta tank
Water to Chikkaballpur and Kolar District
In addition, water will be used to rejuvenate Rivers like Arkavathy (Cauvery Basin), Palar, (Independent basin) Jayamangli, Kushavathy, Uttara and Dakshin Pinakini, Chitravathi and Papagni rivers (Pennar Basin) (Project Report Volume I: Section 4.9, Page 52)
The project report makes no mention of supplying water to Bangalore urban area or BBMP (Bruhut Benguluru Mahananagara Palike). However, the Karnataka Budget 2012-14 specifically mentions providing water to these areas.
How much water will this be? What are the options of water supply to Bangalore? If water is supplied to voracious Bangalore and Devanahalli Industrial area, will there actually be water for Kolar, Chikkaballapur and other drought affected areas?
River Rejuvenation: Long distance transfer of water involving huge ecological, social and financial costs seems to be a poor way of rejuvenating rivers. Experts claim that rejuvenating rivers like Arkavathy can be achieved with rainwater harvesting, demand side management, pollution control and releasing treated water in rivers like Arkavathy and Vrishabhavati, not interbasin transfers.
Priority to Drinking water for Kolar and Chikkaballapur? Doesn’t seem so
Of the 10 TMC to be provided to Kolar and Chikkaballapur, the Project Report mentions that drinking water needs of Kolar and Chikaballapur Districts are 6 TMC. Rest of the 4 TMC will be used to fill up 337 MI and ZP Tanks in the districts.
The project report proposes to fill these tanks at 60% live storage capacity. According to Table 2 and 3 in Project Report Volume 1, Page 7, this proposed 60% filling requires 4.08 TMC water in Chikkaballapur District and 3.11 TMC water in Kolar District. So together, as per the Project Report, the proposed filling of MI tanks needs 7.19 TMC water.
This leaves bare 2.81 TMC water for drinking purposes of these districts!
If out of 24.01 TMC transferred, only 2.81 TMC will be supplied for drinking water to Kolar and Chikaballapur, this is clearly not a drinking water supply project for these districts, as claimed.
So undecided is the Project Report about supplying drinking water that it says further “alternatively if water is to be used fully for drinking, then it will require 4 new storage tanks”. The Project Report does not conclude on whether these tanks will be built.
IV. Escaping Environmental Clearance by false claims
This scheme will:
Destroy hundreds of hectares of pristine biodiversity rich and unexplored forests, wildlife habitats, habitats of critically endangered species, reserved and protected forests in the Western Ghats
Affect downstream flows and riverine ecology of the Gundia, Kumaradhara & Netravathi Rivers
It will submerge nearly a 1200 hectares of land, 50% forest land and 2 villages for reservoir to be constructed at Devaranyadurga
Main gravity canal which will be 250 kms long and 16 mts wide (as stated in EAC meeting by proponent) will require a minimum of 400 hectares of land
It involves Interbasin water transfer, which is not prudent or viable as per the Western Ghats Expert Ecology Panel Report
Clearly, the scheme requires detailed scrutiny for its impacts by undergoing participatory environment and social impact assessment and undergoing a thorough Environmental Appraisal.
The scheme has escaped this by wrongly claiming that it is a purely drinking water supply scheme. The proposal was considered by the Expert Appraisal Committee of the MoEF in its 63rd meeting in October 2012. In the meeting, the EAC noted that ‘there appear to be some environmental and R and R issues which should be addressed” but recorded its inability to consider this project as drinking water projects do not fall in the purview of EIA Notification 2006.
The minutes note that: “The project neither proposes any hydro-electric power generation component nor comprises of any irrigation component and thus has no command area.”
However, this is a wrong claim for the following reasons, among others:
A. Irrigation Component: The EAC says that there is no irrigation component. However, the command areas of 337 minor irrigation tanks in Kolar and Chikkaballapur, as mentioned in the Project Report (Voulme I, Annex 3) come to 29,182 hectares, all of which will benefit from the project. This is higher than command area of 10,000 hectares; hence the project comes under the purview of EIA Notification 2006 and will have to be considered for Environmental Clearance by Expert Appraisal Committee of the MoEF under EIA notification 2006.
B. Hydropower Generation: The project claims that it can generate 125-150 MW of power through gravity canals. Location details are also made available in the Project erport (Page 59, Volume I). As the total capacity is higher than 25 MW, the project comes under the purview of EIA Notification 2006 and will have to considered for Environmental Clearance by the Expert Appraisal Committee of the MoEF.
It is clear that the EAC’s decision that the project does not fall under the purview of EIA notification is incorrect technically. Furthermore, it is unacceptable to exclude any large dam or project which has such significant impact on land and ecology from the purview of EIA notification and EIA notification needs urgent amendment.
V. Yettinahole & Gundia HEP (Phase I: 200 MW, Phase II: 200 MW) overlap
While the Karnataka Neeravari Nigam Limited is making Project Reports, DPRs and has even earmarked budget in 2013-14 session, Gundia HEP has been planned on the same catchments and same rivers by Karnataka Power Corporation Limited (KPCL).
Gundia HEP proposes to divert flows from Yettinahole, Kerihole, Hongadhalla and Kadumanehole (Phase II) through maze of tunnels to generate 200 MW power in phase I and 200 MW in Phase II. KPCL has completed an Environment Impact Assessment for this project (which is of a poor quality). KPCL has also made presentations to the Western Ghats Expert Ecology Panel about the project.
Power generation is based on water yield from the catchment, which will be intercepted by Yettinahole Diversion Project. In fact, dams of Gundia HEP and Yettinahole HEP are placed close to each other. Both the projects, by the Karnataka Government are working in isolation and cross purposes as if the other project does not exist.
Locations of weirs and dams of Gundia Hydel Project (GHEP) and Yettinahole Projects SANDRP
Shockingly, both projects have also been considered within three months by the EAC of the MoEF for appraisal. The Expert Appraisal committee of the MoEF in its 59th Meeting in July 2012 considered Gundia HEP and in its 63rd Meeting in October 2012 Yettinahole Diversion Project. EAC has recommended Environmental Clearance to Gundia (another wrong decision), whereas it has indicated that Yettinahole Diversion Project does not require an Environmental Clearance. In doing so, the EAC has not considered that both these projects plan to divert waters from the same catchments. This also says a lot about application of mind by the Expert Appraisal Committee. At the same time, it also raises questions about the coordination and work of Karnataka Government.
VI. Options Assessment
The project raises pertinent questions about water management and water sharing: Is diverting water from west flowing rivers, at a huge social, ecological and economical costs the only option to provide drinking water to Kolar and Chikkaballapur regions? Is there no other optimal solution? Did the Karnataka government undertake an options assessment study to arrive at such a conclusion?
An analysis of rainfall for the one hundred years between 1901-2001 indicates that rainfall in Kolar and Chikkaballapur has not shown significant fall.
Annual Rainfall in Chikkaballapur District during 1901-2001 Data Source: IMD, Graph: SANDRPAnnual Rainfall in Kolar District during 1901-2001 Data Source: IMD, Graph: SANDRP
Kolar District, especially was once rich in water tanks and local harvesting measures. Average rainfall in Kolar is 750 mm, which is not low. According to the Karnataka Gazetteer, the district had, in 2012, only 2,095 tanks from the 35,783 tanks in 1968. Most of the tanks were a victim of siltation, encroachment and neglect.[5] Organisations like Gramvikas and Dhan Foundation have demonstrated how desilting and management of tanks in Kolar can secure water for drinking as well as for irrigation, cattle rearing, etc.[6] Some groups have worked on highlighting the positive impact of applying reservoir silt to crops, as an option to fertilisers and to facilitate desilting. Indian Institute of Sciences (IISc) has demonstrated that desilting these tanks in Kolar can not only help water security, but it can also reduce the incidence of fluorosis.[7]
River Rejuvenation: Long distance water diversion is not an answer to drying and dying rivers Rivers like Arkavathy are dying due to persistent pollution from industries and urban areas and also due to catchment degradation. How will waters from Yettinahole revive this situation? Local efforts, sound environmental and water governance however, can help this situation. But this is not being explored sufficiently.
_____________
Long-distance water transfer: problems and prospects
(From: Prof. Asit Bisaws, Long-Distance Water Transfer United Nations University, 1983)
If many of the past and present experiences on long-distance water transfer are reviewed critically, the following major issues emerge:
(1) Mass transfer of water is often justified by considering only the direct cost of transporting water. Seldom are the values of services foregone by the exporting region due to reduction of their water availability, i.e. the opportunity costs of exported water analysed.
(2) Various other feasible alternatives to interbasin water transfer are often not investigated. There is a tendency within the engineering and economic professions to opt for technological solutions-“soft” options tend to be neglected. Since water resources development is dominated by these two professions, there is a tendency to opt for technological fixes before all viable alternatives are explored. Among possible options are:
-more efficient use of available water;
-re-use of waste water;
-better management of watersheds;
-improved integration of surface and groundwater supplies;
We cannot ignore these signals while planning expensive schemes at the cost of ecology and sociology which might prove to be inviable in a few years in face of climate change. Keeping all these factors in mind Karnataka needs to proceed extremely cautiously on Yettinahole diversion scheme.
_______________
VII. In Conclusion
Environment and Social Assessment are basic prerequisites for a project of such massive dimensions.
All in all, looking at several serious issues associated with Yettinahole Diversion Project, it is urgently needed that:
Project should undergo complete Environment appraisal and Clearance scrutiny, as laid down by the EIA notification, 2006
Recommendations of the Western Ghats Expert Ecology Panel about avoiding inter-basin transfers in the Western Ghats should be adhered to.
Options Assessment and cost benefit analysis, including the ecological costs of the diversion should be carried out and put in public domain.
Downstream affected communities, including cities like Mangalore and estuarine fisher folk should be consulted during public hearings.
Unbiased assessment about the water stress in Kolar and Chikkaballapur should be carried out with members from groups which have been working from the region, to evolve a holistic water management policy for the region.
Options for reviving rivers and tanks in Kolar-Chikkaballapur need to be explored using traditional and appropriate technology practices. Appropriate cropping pattern and cropping methods should be a part of this exercise.
A review of rain water harvesting, efficient water supply, demand management, lake revival, groundwater recharge, grey water and sewage recycling for cities including Bangalore should be carried out prior to allocating more water from distant sources to such cities.
A democratic bottom up exercise has to be taken up on such proposals both in the Western Ghats areas as well as the projected benefiting areas.
It will not be the interest of the ecology in Western Ghats, Eastern regions or communities in Dakshin Kannada, Hassan, Kolar, Tumkur, Bangalore and Chikkaballpur if a project of such massive proportions, with devastating social and environmental impacts is taken up for short term political or financial gains, bypassing proper credible appraisal and democratic decision making.
Kolar and Chikkaballapur regions have been facing severe water crisis, leading to hardships to local communities. But, for a long term and sustainable solution to these problems, Yettinahole Diversion does not look like a viable option, we do not even know how much water will reach these regions. But the project has the potential to exacerbate ecological degradation, fuel man animal conflicts and further water conflicts between regions.
Drought affected regions may have better options, including better operation and maintenance of existing water infrastructure, more appropriate cropping and water use pattern, revival of existing water harvesting structures, recycle and reuse of water, among others. Attention needs to be paid to these options, rather than ‘diverting’ it.
Hidden costs of projects like Yettinahole Diversion are too big to be actually hidden.
Yettinahole Diversion Project is being planned in the Western Ghats and Eastern Plains of Karnataka, by the Karnataka Neeravari Nigam Limited (KNNL) purportedly as a drinking water supply scheme to supply 24 TMC water to Kolar and Chikkaballapur Districts. The scheme involves 8 dams in Western Ghat forests, 250 kms long canals, 80 and 50 kms long raising mains, a reservoir that will submerge 1200 hectares of land and 2 villages. A closer look at the Project Report of the scheme indicates that of the 24 TMC to be diverted, assured drinking water to Kolar and Chikkabalapur is just 2.81 TMC! Rest is planned to be allocated for uses like river and tank rejuvenation, irrigation, industries, urban supply etc.
Gundia River, formed of headwaters of Yettinahole, Kerihole, Hongadhalla and Kadumanehole which will be diverted for the Yettinahole Diversion Project Photo: SANDRP
The Project has escaped appraisal by the Expert Appraisal Committee of the MoEF, claiming that it is a drinking water scheme ( as per the EIA Notification 2006, Drinking Water Supply Schemes are exempt from Appraisal and Environmental Clearance process.)
But analysis of the Project report indicates a different picture.
More than 14 individuals, mainly from Karnataka have written to the Union Environment Minister, Secretary, MoEF and Director, Impact Assessment, River Valley Projects Division to appraise the Yettinahole Diversion Scheme entirely. Signatories include Dr. Ullas Karanth, former non-official member of the Forest Advisory Committee, MoEF, Praveen Bhargava from Wildlife First, Dr. T.V. Ramchandra from Indian Institute of Sciences, noted rainwater harvesting expert Vishwanath Srikataiah, Niren Jain of Kudremukh Wildlife Foundation, amongst others. While the signatories support long term and sustainable solutions to legitimate drinking water demands of drought affected regions in Karnataka, as the letter clarifies, Yettinahole Diversion Project does not seem to be an answer to that.
To,
Smt. Jayanthi Natarajan,
Union Minister of State (IC) of Environment and Forests,
Union Ministry of Environment and Forests, New Delhi, vrg.iyer@nic.in
Maninder Singh
Joint Secretary,
Union Ministry of Environment and Forests, New Delhi, jsicmoef@nic.in
Mr. B. B. Barman
Director (IA) River Valley Projects,
Union Ministry of Environment and Forests, New Delhi, bbbdx.dy@gmail.com
Subject: Appeal for fresh Appraisal of the Yettinahole Diversion Project in Karnataka and withdrawal of the Letter/NOC which has been issued by the MoEF on the basis on inaccurate/insufficient information.
Respected Madame and Sirs,
In the 63rd meeting of the EAC for River Valley and Hydropower projects, the committee considered Yettinahole Diversion Project by Karnataka Neeravari Nigam Limited, Government of Karnataka (Agenda Item: 2.11 (b) “Clarification on Drinking Water Supply Scheme to Tumkur, Bangalore (Rural), Kolar & Chikaballapur Districts by M/s. Karnataka Neeravari Nigam Ltd, Government of Karnataka for applicability of EIA Notification, 2006.)
The EAC concluded (emphasis added): “In view of the above, the EAC expressed its inability to consider the project for the purpose of TOR/EIA/EMP etc as this does not fall within the preview and mandate of the EAC although, there appear to be some environmental and R&R issues involved which may be appropriately addressed. Outcome of the WGEEP report may also have to be factored. The drinking water schemes, in fact, do not attract the provisions of EIA Notification, 2006 and its subsequent amendment, 2009… The project neither proposes any hydro-electric power generation component nor comprises of any irrigation component and thus has no command area.”
The EAC also recommended: “The Ministry of Environment & Forests may write to Karnataka Neeravari Nigam Ltd (KNNL), Government of Karnataka that the instant project does not attract the provisions of EIA Notification, 2006 and its subsequent amendment, 2009.” We understand the MoEF sent a letter to KNNL on these lines.
This recommendation of the EAC and MoEF decision are both incorrect. Looking at the facts mentioned below, the scheme is Category A project and needs to be appraised by the EAC not only because it falls under the purview of the EIA Notification 2006, but also due to serious ecological and social impacts. This letter is based on a site visit to the region, discussions with local communities, perusal of the Project Report of the scheme as well as the minutes of 63rd EAC Meeting.
EAC considered the project only on the basis of the proponent’s statements, without studying the Project Report.
An analysis of the Project Report (Version June 2012, prior to EAC Meeting) it is clear that:
1. Irrigation Component: The project aims to supply water to 337 minor irrigation tanks and Zilla Parishad Tanks in Kolar and Chikkaballapur. The command areas of these 337 minor irrigation tanks, as mentioned in the Project Report (Voulme I, Annex 3) come to 29,182 hectares. This is higher than command area of 10,000 hectares; hence this is a Category A project which comes under the purview of EIA Notification 2006 and will have to be considered for Environmental Clearance by Expert Appraisal Committee of the MoEF.
2. Hydropower Generation: The Project Report claims that it can generate 125-150 MW of power through gravity canals. Location details are also made available in the Project erport (Page 59, Volume I). As this is higher than 25 MW, the project comes under the purview of EIA Notification 2006 and will have to be considered for Environmental Clearance by the Expert Appraisal Committee of the MoEF.
Thus, the Project comes under the purview of EIA Notification 2006 and should be considered by the EAC, urgently taking back any letter sent to Karnataka Government to the effect that the project does not require an EC as per EIA notification 2006.
In addition to technicalities about qualifying under the EIA Notification 2006, the project has severe socio ecological impact, which cannot be sidelined by the EAC and the MoEF.
Majority of the project falls in Ecologically Sensitive Zone I as per the WGEEP, where any large infrastructure project is banned. In addition, WGEEP bans any inter-basin transfer of water. MoEF has as yet not decided on WGEEP recommendations. In the absence of this, the MoEF cannot provide any letter to the state about not requiring an Environmental Clearance. MoEF will need to consider the WGEEP Report while making its recommendations, as also directed by NGT, which MoEF has not done.
The project plans to divert 24.01 TMC water from 4 streams in Western Ghats, without making any study of eflows for the downstream Eco Sensitive Zone.
The project does not divulge forest land required. Only by estimating heads under ‘cutting thick forests’ in its estimates, it will require 107.27 hectares land with thick forest cover only for laying raising mains. The Hon’ble Supreme Court has formulated Guidelines in the Lafarge Judgment which mandate that projects that require both forest and environment clearance must first secure forest clearance. This has not been complied with.
Gravity Canal from Harvanahalli (Sakaleshpur) to Tumkur will require a minmum of 400 hectares land
Reservoir at Devarnyadurga will require 1200 hectares of land, including 50% forest land and will submerge at least 2 villages.
Though the project claims to be a scheme for drinking water of Kolar and Chikkaballapur Districts, actual dedicated drinking water allocation of these districts is only 2.81 TMC of the 24.01 TMC diverted which works out to less than 10%. Rest will go for irrigation, river rejuvenation, urban areas, industrial areas, etc. Signatories support long term and sustainable solutions to drinking water crisis. While provision of drinking water to the said districts is a legitimate necessity that we do not object to, what we are questioning is the justification of this ill conceived project whose cost-benefit analysis is extremely skewed and the ecological and social impacts are horrendous.
Alternative and feasible proposals that will provide the 2.81 TMC feet of water for the said districts have, in our considered view, not been explored. Furthermore, the feasibility of large-scale land acquisition required for the project must be considered in the context of the amendments to the Land Acquisition Bill that has just been passed by Parliament.
Considering all these serious issues, the EAC’s appraisal of this project has been incorrect technically as well as wrong on facts and law.
We urgently request the MoEF to:
1. Withdraw any letter/NOC etc., that it may have sent to Karnataka Government in this regard as the current decision of the EAC and MoEF may not stand the test of legal scrutiny and may lead to some wholly un-necessary litigation.
2. Direct the State of Karnataka to present a detailed project report that includes the plans for phase II and III that are sure to follow.
3. Ensure that the EAC considers the DPR and appraises project for Environmental Clearance in its entirety.
Looking forward to your response and appropriate action to points raised above.
Parineeta Dandekar (parineeta.dandekar@gmail.com,09860030742), andHimanshu Thakkar (ht.sandrp@gmail.com, 09968242798) South Asia Network on Dams, Rivers and People, Delhi and Pune
“No country in the world is as vulnerable, on so many dimensions to climate change as India. We need to build our own independent and credible research capacity on these issues.”
-Jairam Ramesh, erstwhile Union Environment Minister in Preface to CLIMATE CHANGE AND INDIA: A 4X4 ASSESSMENT: A SECTORAL AND REGIONAL ANALYSIS FOR 2030s
As India is struggling to cope with the extent and scope of the Uttarakhand Disaster[1], it is high time that we take the very real and urgent challenges of Climate Change seriously. India has several regions and communities significantly vulnerable to climate change. Himalayan glaciers are receding faster than global averages, precipitation across India is becoming more intense and unpredictable, biodiversity is under stress, sea levels are rising affecting thousands of coastal communities. And despite all this, destructive development in fragile regions is happening with utter disregard to this reality.
Maximum impacts of climate change are being faced by local poor communities and ecosystems.
With this in mind, we take a look at 4X4 Climate Assessment report (4X4 Report for short), brought out in 2010 by Ministry of Environment and forests (MoEF) which assessed Climate Change impacts by 2030 on four ecologically sensitive sectors: the Himalayan region, Western Ghats (WG), Coastal areas and North-east regions of the country and four issues: Agriculture, Forests, Human health and Water together. We also look at other reports on climate change in Western Ghats and compare these with actual challenges faced by WG. Till date this report remains the only official and definitive report about assessment of impact of climate change in India, to the best of our information (Readers, please let us know if there are other relevant reports in this regard).
The report is prepared by Indian network on Climate Change Assessment (INCCA)[2], which consists of 120 Indian Institutes and research laboratories, geared towards data analysis and impact predictions of the climate change scenarios. The network was launched by MoEF on 14th October 2009. 4X4 Report was published in November 2010 when Mr. Jairam Ramesh was the Union Minister for Environment and Forests.
A1 B Scenario Predictions
The climate change impact predictions need the to assume of socio-economic context for which predictions are made. IPCC has classified socio-economic scenarios under A & B categories with further sub-divisions under each of them. 4X4 Report uses the A1B prediction scenario for India. This scenario assumes significant innovations in energy technologies, which improve energy efficiency and reducethe cost of energy supply with a balance across all sources. A1B assumes drastic reductions in power generation costs through the use of solar, wind, and other modern renewable energies and end use products.[3],[4].
Ironically, this assumption of A1B scenario for 2030 seems baseless when we look at the current dependence on non-sustainable energy sources like coal based thermal and large hydro.
PRECIS (Providing Regional Climates for Impact Studies)[5] tool used in this report considers data from large time scale of 5-7 decades in order to predict impact for coming 3-4 decades.
We look at Water in Western Ghats and what the Report predicts for this most populated biodiversity hotspot in the World.
1. Western Ghats: The Water Tower of Peninsular India
Western Ghats (WG) are one of the oldest mountain ranges– older than the Himalayas- occupying around 6 % of Indian landmass. According to High Level Working Group Report on Western Ghats (HLWG/Kasturirangan Committee Report), geographical area of WG is over 1,64,280 sq. km. WG harbor high degree of endemism with more than 78% of amphibian and about 41% fish species[6] and similar high RET (Rare, endemic and Threatened) floral and faunal groups. They also support numerous tribal and forest dwelling communities. In 2012 UNESCO has declared 38 sites from Western Ghats as World-heritage sites. Most of the Peninsular east flowing or west flowing rivers originate from Western Ghats making it the water tower of peninsular India. Millions depend on these rivers like Krishna, Godavari, Cauvery, Malaprabha, Ghataprabha, Bhima, Tungabhadra for water and ecosystem goods and services. West flowing rivers are shorter and swifter. Examples include Vaitarna, Ulhas, Kali, Sharavati, Chalakudy, Pamba, Bharatpuzha, Nethravathy, Hemavathy, Bhawani etc. There are many complex community- water relationships which could be found in the region.
Rivers from Western Ghats drain almost 40% of Indian drainage. Therefore, it is essential to understand the impacts of the climate change on water resources in Western Ghats.
Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
2. Predictions from 4X4 Report for Water and Western Ghats for 2030s
2.1 Precipitation and temperature:
In the Western Ghats, annual temperatures are likely to increase to 26.8 °C–27.5 °C in the 2030s. The rise in temperature with respect to the 1970s will be between 1.7° C and 1.8° C. The mean annual rainfall is likely to vary from 935± 185.33mm to 1794±247mm, which is an increase of 6%–8% with respect to the 1970s. The minimum temperatures may rise by 2.0 °C to 4.5° C, with minimum increase in those parts of Karnataka that lie in the Western Ghats. Within the region bordering the state of Kerala, the maximum temperature is likely to rise by 1° C–3° C.
The number of rainy days are likely decrease along the entire Western coast, including in the Western Ghats.
The intensity of rainfall is likely to increase by 1-2 mm/day.
2.2 Water yield, sedimentation the predictions for Western Coastal region, including the Western Ghats:
The west coast region exhibits a wide variability in the change in precipitation under the 2030s scenario. The northern portion of the west coast, consisting of areas of Gujarat and Maharashtra, shows an increase in precipitation for the 2030s scenario, and the increase varies from 4% to over 25%. However, areas of Karnataka and Kerala show a marginal decrease upto 4%.
The west coast region shows a general reduction in Evapotranspiration (ET), which varies from a very nominal value to about 5% for the 2030s scenario. Areas of Gujarat and Maharashtra, which had shown an increase in precipitation, still show a reduction in ET perhaps because of high intensity of the rainfall.
The reduction in water yield for Karnataka and Kerala is up to about 10%. Gujarat and Maharashtra areas see an increase in water yield[7], and the magnitude is up to about 50%.
The west coast region also shows a considerable increase inthe sediment yield for majority of the areas. Even those areas that are expected to receive less precipitation show an increase in sediment yield of up to 25%. The increase in sediment yield in these areas can possibly be explained due to an increase in the intensity of precipitation. This will have major impacts on water resource projects.
It is also seen that there is an increase in the moderate drought development for Krishna, Pennar, and Cauvery basins, which have either predicted decrease in precipitation or have enhanced level of evapo-transpiration. The maximum water withdrawal takes place from Godavari and Krishna river basins in Western Ghats in all the years[8]
2.3 Flood Analysis According to 4×4 Report, all the regions show an increase in the flooding varying between 10 to over 30% of the existing magnitudes. This has a very severe implication for the existing infrastructure such as dams for the areas and shall require appropriate adaptation and dam safety and operation measures to be taken up.
2.4 Impacts on crops:
a. Coconut: Coconut yields are projected to increase by up to 30% in majority of the region. Increase in coconut yield may be mainly attributed to projected increase in rainfall (~10%) and relatively less increase in temperatures. However, some areas like south-west Karnataka, parts of Tamil Nadu and parts of Maharashtra, may lose yield up to 24%.
b. Rice: Productivity of irrigated rice in Western Ghats region is likely to change +5 to –11% depending upon the location. Majority of the region is projected to lose the yield by about 4%. However, irrigated rice in parts of southern Karnataka and northern-most districts of Kerala is likely to gain. In the case of rain-fed rice, the projected change in yield is in the range of –35 to +35% with a large portion of the region likely to lose rice yields up to 10%.
c. Maize and sorghum: Climate change is likely to reduce yields of maize and sorghum by up to a whopping 50% depending upon the region.
The entire Western Ghats region is covered by 54 grids, out of which 10 (18%) are projected to undergo change. 18% forested grids in the region are projected to be vulnerable to climate change. The projection of the NPP (Net Primary Productivity) for the Western Ghats region is projected to have approximately 20% increase in NPP on an average.
2.6 Temperature Humidity Index (THI) and its possible impact on biodiversity: While the report uses this index for studying analyzing impacts on livestock, its conclusions can also be used for biodiversity and fisheries. The report predicts “A severe thermal discomfort and stress is expected in most parts of Western Ghats and the Coastal region in the month of May.” This will not only affect the biodiversity, but also fisheries. However, the report makes no such correlation.
Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP
3. Limitations and Way Forward:
The report accepts its limitation in terms of data sources, details which have been gathered, lack of integration of existing data, etc. The authors seem aware that the report in this form is of little use to policy makers or communities.
4. Conclusions:
While the report has its severe gray areas, and there are variations within Western Ghats, it is clear that for Western Ghats:
Precipitation will be more intense with less rainy days
Temperatures will see a gradual increase
Crops will be affected
Forests (and dependent biodiversity) will be made more vulnerable
Sedimentation will increase sharply
Incidence of floods and droughts will rise sharply
5. Problems with 4 X 4 Assessment:
Apart from the limitations admitted by INCAA, the report suffers several other limitations.
It does not offer any recommendations for policy makers.
Neither does it hold any recommendations for communities. In fact in its way forward, when it mentions that cooperation has to be sought from several departments and organizations, it does not even mention local communities who will face major impacts!
In the task of assessing impacts and devising solutions to mitigate and adapt to impacts of climate change, local communities have proved to be extremely adept. At the same time, the impacts of climate change affect these communities the most and hence they have to be made a part of ongoing research. 4 X 4 Report does not even attempt this.
Some big questions:
The report says that “Thenorthern portion of the west coast, consisting of areas of Gujarat and Maharashtra, shows an increase in precipitation for the 2030s scenario, and the increase varies from 4% to over 25%. Gujarat and Maharashtra areas see an increase in water yield, and the magnitude is up to about 50%. As per the maps, this region also includes the Western Ghats.
Now Northern Western Ghats is exactly the same region where Indian Institute of Tropical Meteorology (IITM, also a part of INCA) has said that there have been drastic, ongoing reductions in rainfall!
In fact, Centre for Climate change, IITM has said that in the last 110 years (1901-2011) rainfall in Mahabaleshwar, origin of five rivers in northern Western Ghats has decreased by 800 mm! In northern Westenr Ghats of Maharashtra, rainfall has decreased at the rate of 2% per decade while the rate of decrease is lower in Southen Western Ghats for Kerala at 1%.[9]
This aspects needs some more clarity.
No reference to the ongoing destructive development in Western Ghats: Western Ghats are facing severe threat from Mining, Hydropower projects, Irrigation Projects, mini hydel projects, which affect water cycle, sedimentation, forests and biodiversity of the region and displacement and impoverishment of very large number of people. However, the report does not dwell on any of these practical problems and their impact in compounding climate change challenges.
Mining in Goa Photo: Damodar Pujari
No reference to biodiversity, freshwater fisheries: The report has no predictions or recommendations to offer for biodiversity in Western Ghats. While there is a section on coastal fisheries, there is no mention of rich freshwater fisheries in Western Ghats!
A1B Scenario: There is no evidence that India is adopting the A1B scenario which considers growth through a mix of energy sources like solar and wind, etc. We still depend heavily on non-sustainable energy sources like Thermal and large hydro. Hence, this assumption itself is flawed and predictions based on this assumption cannot be considered seriously. In fact, the actual predictions, looking at India’s and Western Ghat’s track record, (with over 10 coal based thermal power plants, several other nuclear power projects, ports and large dams coming up in Maharashtra, concentrated and non-sustainable mines in Goa) could be much more severe.
6. Impacts of climate Change on Western Ghats from Western Ghats Expert Ecology Panel report and High Level Working Group on Western Ghats Report:
Western Ghat Expert Ecology Panel Report: WGEEP does not refer to 4 X 4 Report. It considers A2 and B2 scenarios, and concludes that northern region of Ghats is more sensitive to climate change than southern region. Though the report does not deal with climate change in detail, the recommendations of WGEEP are extremely climate friendly.
High Level Working Group Report: HLWG report has considered 4×4 Report in its analysis and includes a Chapter on Climate Change. This chapter is more effective in dealing with ground challenges than the 4×4 report. However there are some major problems in this.
The HLWG Report states:
a. “Biodiversity: In the Western Ghats, climate change is expected to increase species losses. Changes in phenology are expected to occur for many species. Ecosystems dominated by long-lived species (like forests in WG) will be slow to show evidence of change and slow to recover from the climate related stress
b. Water, Irrigation and Hydro Power: Impacts of climate change and climate variability on the water resources are likely to affect irrigated agriculture, installed power capacity, environmental flows in the dry season, and higher flows during the wet season, thereby causing severe droughts and flood problems. “It is seen that there is an increase in the moderate drought development for Krishna, Pennar, and Cauvery basins, which have either predicted decrease in precipitation or have enhanced level of evapo-transpiration. The maximum water withdrawal takes place from Godavari and Krishna river basins in Western Ghats in all the years.”
c. Hydro capacity “is expected to increase, but its share decreases from the total installed capacity by 2100. The slow growth in capacity is due to barriers of high investment requirements and long gestation periods. A number of socio-environmental issues are related to dam construction, flooding of areas, damages to the ecology, and resettlement and rehabilitation of the population.”
Though HLWG dedicates an entire chapter to Climate Change Impacts on Western Ghats, it still does not comment on destructive hydropower projects and such other plans which decrease resilience and adaptation capacities of ecosystems and communities and in fact contributes to climate change by deforestation and methane emissions! In fact, by not opposing projects like 163 MW Athirappilly and 200 MW Gundia, the HLWG report supports projects which have huge potential on increasing climate change impacts[10],[11],[12]
Shockingly, the HLWG report certifies all hydro as green and renewable source of energy, something that even developed countries or UNFCCC does not do.
According to the Second National Communication on Climate Change (NATCOM, 2012), the Western Ghats is expected to experience increase in temperature regimes, rainfall and extreme events due to climate change. There is also a high probability of significant decrease in the duration of the precipitation (NATCOM, 2012). The projected changes in the precipitation may induce changes in the hydrological regimes especially increase in evapo-transpiration and increased runoff .
7. Way Forward of Water, communities and ecosystems in Western Ghats
India has been witnessing several climate related disasters in the recent years. Instead of going into a ‘climate change or no climate change’ debate, it is time to adopt no-regrets strategies and build climate resilience of communities and ecosystems. Unfortunately, we do not see evidence of decreasing emissions or adopting climate friendly strategies from India, or even other developed countries which support and fun destructive projects in India. The Clean Development Mechanism introduced by UNFCCC has in fact been supporting and pushing destructive projects in developing countries, while legitimizing pollution in developed countries.
Some possible measures:
Natural ecosystems are resilient in coping with climate change challenges: natural ecosystems like rivers, streams, forests need to be protected for their resilience to climate change impact as well as the goods and services they provide to local communities, who are most vulnerable and least able to cope with the climate change implications.
Free flowing rivers are more resilient than their dammed counterparts: Free flowing rivers in western Ghats need to be protected on priority
Fragmented Forests are more vulnerable to climate change impacts: Deforestation and fragmentation of forests in Western Ghats should be avoided at all costs. Large Hydro power, irrigation projects, mini hydel, mines, hills station projects affecting forests should be dropped urgently. Local projects should be considered only with free, prior and informed consent of the communities. All projects related t the mega Inter Linking of Rivers in the western Ghats should be dropped, including Par Tapi Narmada, Damanganga Pinjal, Nethrawati, Hemawati, Pamba, Achankovil, among others.
Old and unsafe large dam projects like the Mullaperiyar and others should be considered for decommissioning as recommended by WGEEP.
The diversion of east flowing rivers to the west in Maharashtra should be reversed in a time bound manner and no more such projects should be considered.
All projects in Western Ghats: large or small should be brought under the ambit of environmental clearance which should look specifically at climate change impacts on these projects and should also require FPIC.
Community water harvesting systems, traditional water harvesting systems, watershed measures need to be encouraged. Western Ghats is rich in these examples
Efficient and water saving measures like System of Rice Intensification should be adopted for the entire Ghat region.
Recommendations of WGEEP need to be implemented urgently
Most importantly, communities need to be made an integral part of decision making surrounding natural resources. Currently, mega projects like Athirappilly, Gundia, Talamba and Tillari dams in Maharashtra, drinking water dams near Mumbai, etc. completely neglect community concerns. Communities will not only face direct impacts of displacement and losing rights, the long term impacts on adaptation and mitigation capacities of communities will also be jeopardized due to destructive projects.
[6] Western Ghats Ecology Expert Panel Group: WGEEP
[7] Water yield (water crop or runout). The runoff from the drainage basin, including ground-water outflow that appears in the stream plus ground-water outflow that bypasses the gaging station and leaves the basin underground. Water yield is the precipitation minus the evpotranspiration. (http://water.usgs.gov/wsc/glossary.html)
Through this series, will be trying to publish issues related to dams in the World Heritage site of Western Ghats. The dilemma of Conservation Vs Development of this ‘most populated biodiversity hotspot in the world’ has been highlighted with the WGEEP and HLWG Report. Through this series, we will try to look at the way in which rivers, forests and communities in the Ghats are being affected by dam construction and to what extent do these dams contribute to development of teh region whihc suffers the impacts.
1. Nardawe Dam, Sindhudurga District, Northern Western Ghats, Maharashtra
Introduction
Nardawe dam is being built on GadRiver in Kanakavali taluka of Sindhudurg district by Konkan Irrigation Development Corporation (KIDC), under the Water Resources Department, Maharashtra. Gad is a small west flowing river originating from the Western Ghats, meeting the Arabian Sea. According to the White Paper on Irrigation Projects in Maharashtra brought out by the Water Resource Department (WRD) in December 2012, Administrative approval for Nardawe Dam was granted in 1989 for Rs. 32 Crores. Due to a number of delays, the project could not be started for more than a decade. By the third administrative approval in 2007, the sanctioned cost shot up to ₹ 446 Crores.
Rice sowing at Nardawe Photo: Damodar Pujari
A brief reading of the White Paper and actual situation in Maharashtra indicates that this is a typical tale of most dams, where cost and time estimates have been escalated multiple times.
By June 2012, the KIDC has spent ₹ 311 Crores on this project. Costs have escalated despite the fact that canals in the original proposal have been cancelled and converted into 16 ‘Kolhapur Type’ gated weirs (KT Weirs).Its Command area (after the dam completion) is supposed to be 12, 530 ha, through 16 KT weirs.It will store 123.74 Million Cubic Meters (MCM)water .Total submergence of Nardawe Dam is625 hawhich will affect3849 people from 967 families.1 village is completely affected (Jambhalgaon) and 4 (Naradawe, Yavateshwar, Bhairavgaon, Durganagar) villages are partially affected. 34.13 ha of identified forests will have to be diverted for the project
Actualwork on the project started in 2001.
According to white paper, 61% work on the dam is complete, which includes the earthen dam wall and 10 KT weirs.
This project finds itself mired in violations of several kinds That it is coming from KIDC comes as no surprise. This section of the WRD Maharashtra has been a regular in violating several norms while pushing its projects. KIDC was also found to have indulged in corruption in the case of Konadhane Dam in Raigad, has started work on Dams like Kalu and Balganga without Forest Clearances or rehabilitation plans.
Illegal Work without Environment Clearance The project has a command area more than 10,000 hectares and hence, requires an Environmental clearance according to the EIA Notification of 1994 which was in effect when the construction work for the dam started. Legally, work cannot start on the dam without an Environmental Clearance. In Nardawe, work has been 61% complete even without an Environment Impact Assessment or Public Hearing.
Work at Nardawe Dam. Photo; Damodar Pujari
Executive Engineer of the Project, Mr Godse, while speaking to SANDRP on the 7th July 2013 accepted that the project has just applied for Terms of Reference (TORs) with the Ministry of Environment and Forests (MoEF) and had started work without an Environment Impact Assessment, Public Hearing or Environmental clearance.
Forest Clearance The project affects 34 ha of identified forest land (वन संज्ञा क्षेत्र) and hence requires Forest clearance from Divisional Forest Office, Bhopal. It does not have final forest clearance. Violating the Forest Conservation Act 1980, work on the project went on, even in Forest area.
Work at Nardawe Dam Photo: Damodar Pujari
The Executive Engineer, while speaking to SANDRP stated that a number of queries have been raised by the Forest Office, Bhopal, one of which is that the project is in vicinity of Radhanagari Wildlife Sanctuary and may need clearance from National Board for Wildlife too.
Forest Rights Act: Individual and community Rights of people dependent on Forest areas are not yet settled. This is serious as these are private forest lands and there is a strong dependence of people on these forests.
High Level Working Group (HLWG) and Western Ghats Expert ecology Panel (WGEEP) Reports All of the affected villages fall under Ecological Sensitive Areas as per the HLWG report and entire Kanakavali Taluka was considered as Ecologically Sensitive Zone (ESZ) – I by WGEEP. WGEEP Report has recommended that no large dams should be built in ESZ 1. According to HLWG Report, peoples’ consultation and resolution are a must prior to starting work in Ecologically Sensitive Areas.
These committees were formed after work on the Nardawe Dam started. However, these reports highlight the high ecological richness of the area. If KIDC had conducted a credible Environment Impact Assessment, as it is legally bound to conduct, these issues could be highlighted before starting work. Current ecological and related social loss could have been avoided.
Officials agree to violations, say that it is more of a norm When SANDRP talked with the Executive Engineer of the project, Mr. Godse on 7th July 2013, he agreed that work on the project is in advanced stage without an Environmental Clearance or Forest clearance in place. As a justification, he said that many projects in Maharashtra indulge in these violations! He said that the project has just applied for TORs for Environmental Clearance with the Ministry of Environment and Forests’. However, the project is yet to come up before the Expert Appraisal Committee of MoEF on River Valley Projects.
Dubious role of EIA Agencies While the Executive Engineer himself agrees that the project has progressed without an Environmental and Forest Clearance in place, The EIA agency for this project, namely Science and Technology Park, Pune[i] did not bat an eyelid while agreeing to do an EIA for this project. They did not point it out to KIDC that applying for an Environmental Clearance when the work is supposedly 61% complete is illegal, neither did they refuse to be a party of such a violation. When SANDRP talked with official from Science and Technology Park involved in this work, he admitted that have visited the region and know that work is at advanced stage. He also agreed that this is a violation and there is little meaning in doing an EIA in such a case. This same agency has worked on EIA Reports of other dams in Konkan region as well.
KT Weirs instead of Canals Letter written by Upper Secretary, Irrigation Department dated 23rd November 1994, claims that the proposal of building RBC (85 km) and LBC (45 km) can generate less irrigated area compared to their length and hence appear to be inefficient in terms of cost as well as irrigation potential. The letter further asks the executive engineer to change the cropping pattern to arecanut and floricultural crops in the command area which require less water which could be supplied from gated barrages through lift irrigation. With this letter as support, canals have been cancelled and KT weirs are being installed, at an increased cost.
Abandoned site office of the Nardawe Dam at Nardawe Photo: Damodar Pujari
Issues of rehabilitation and resettlement When a survey was conducted in 1997, it concluded that 967 families were affected by Nardawe Dam. Sixteen years after the survey, villagers say that the number of affected families has grown to 1245. This means that more than 6000 people may be affected by this project. The villages where resettlement will take place are nothing but sections of hill slopes, as I saw for myself.
Figure 5. Santosh Sawant. One of the affected people and non-governmental member on rehabilitation committee at district administration level
Currently, No resettlement has taken place and villagers are not moving out of their homes.
In a bid to force the affected families out from their homes, administration has stopped construction and repairing of basic civic facilities in the affected villages since 2001.No new water connections, repairing of roads and even ZP schools has taken place in the affected villages in order to push the residents accepting lands in resettlement villages.
Response of the administration has been to assert that local opposition has been the main reason behind the delay in the project. Actually, work on the project has been going on irrespective of local protests, morchas or sit-ins, in complete disregard of the local demands and concerns.
In Conclusion According to villagers, KT weirs built downstream the dam are largely unused because of the cropping pattern, which depends mainly on monsoon and availability of groundwater. Before the KT weirs too, the river was used for some seasonal irrigation.
Time and again it has been proved that major and medium irrigation projects are not a solution for Konkan’s agriculture. According to the White Paper, while the ‘Created’ Irrigation potential of a large dam ‘Tillari’ in Sindhudurga is 7,295 hectares, the actual irrigation potential utilized is just 162 ha!
According to Economic Survey Report of Sindhudurg District in 2012 (Please see table below), large and medium projects have performed dismally. Of the total command area of 49878 hectares, the area actually irrigated by major projects is a mere 158 hectares that is 0.31% and for medium projects with command area of 40821 hectares, area irrigated is an unbelievable 82 ha that is 0.2%!
As against this, minor projects seem to have done better with 4619 hectares irrigated in command of 12851 hectares (around 36%).
Performance of water resources projects in Sindhudurg
No
Taluk
Small
Medium
Large
Command area
Actual irrigated area
Command area
Actual irrigated area
Command area
Actual irrigated area
1
Devgad
1205
533
0
0
0
0
2
Vaibhavwadi
770
114
9027
0
0
0
3
Kankavali
2697
453
20652
82
0
0
4
Malvan
2650
1201
0
0
0
0
5
Vengurla
942
313
0
0
0
0
6
Kudal
3298
1218
0
0
26285
0
7
Sawantwadi
904
598
11142
0
0
0
8
Dodamarg
385
189
0
0
23654
158
Total
12851
4619
40821
82
49939
158
Source- District Economic Survey of Sindhudurg, 2012
The region receives more than 2500 mm of rainfall and decentralized rainwater harvesting, watershed management, revival and renovation of traditional irrigation systems like temple tanks and paats can be cost effective, ecologically sustainable, equitable and efficient solution for this region. The entire Sindhudurg district has several small, decentralized traditional irrigation systems like paats. There exist intricate conflict resolution and water sharing arrangements at the community level about using these paats. Sindhudurg is also rich in irrigation through Temple tanks. TempleTanks in Dhamapur and Nerur stand testimony to the fact that even today, these systems are being utilized.
So then, why are projects like Nardawe, which are costly, unviable, ecologically destructive and stemming unrest in the region being pushed and promoted?
The primary motive behind these irrigation project does not seem to be irrigation or public welfare, for which number of benign options are available. These projects are an easy source profits for contractors, engineers and politicians. Issues like sustainability, efficiency and equity do not seem to matter for the KIDC or Water Resources Department in Maharashtra.
Nardawe Dam is just one example of the large dam centric water management prevalent in Maharashtra. The Irrigation scam which is still unfolding, has demonstrated how hollow this dependence on large infrastructure projects is. If we weigh the meager benefits of these projects against the ecological, social and economic losses to the local communities, environment and public exchequer, it becomes clear that specifically in Konkan region, large dams like Nardawe have no case.
Damodar Pujari, SANDRP
[i] According to its website (http://www.scitechpark.org.in/): “The Science and TechnologyPark is an institute set up jointly by Department of Science and Technology, Ministry of Science and Technology, Govt. of India and University of Pune in the year 1988.”
Maharashtra’s Chief Minister Prithviraj Chavan was the Chief Guest for one day symposium regarding water management in Maharashtra organised by the Gokhale Institute of Politics and Economics in Pune on the 2nd of July 2013.
In his address, the CM raised a number of important topics about water management in Maharashtra. Some of his thoughts were encouraging. He talked about the problems and expense of large irrigation projects, their underperformance and underlined the need for decentralised water management systems. He mentioned that the 2000 crores spent on tankers and animal shelters during 2013 drought was an avoidable expense, if we had developed decentralised water sources. He highlighted the problems of water regulatory authorities like MWRRA. He also mentioned that improper dam operation is a reason behind many disasters like the floods in Surat in 2006 due to Ukai Dam, Sangli floods due to mismanagement of Almatti Dam and stressed that Maharashtra should be concerned about this.
Significantly, he mentioned that while we are assessing the economic costs and efficiency of large dams, we are not looking at their social and ecological and that such assessments should take place. He also said that there should be an in-depth study on the ecological costs of these projects. This is a very welcome statement.
In reality, there has been a huge gap on what he said and what is happening on the ground.
The most blatant example of this is the Kalu Dam where work has stopped currently due to a stay order by the Hon. Bombay High Court. This dam is coming up in the Murbad block of Thane District and falls entirely in the tribal sub plan area and ecologically sensitive region of the Western Ghats. It is set to submerge 1000 hectares of Western Ghats forests and will affect more than 18000 primarily tribal population. The dam, being built by the Konkan Irrigation Development Corporation (KIDC,) has not done any Social Impact Assessment as per the National Rehabilitation Policy. Nor has it undertaken an Environmental Impact Assessment or Cumulative Impacts Assessment of its impact on the Forests. The individual and community Forest Rights have not been settled, in violation of the Forest Rights Act, 2006. Despite all this, the construction started illegally, without a Forest Clearance and is halted only because of a petition filed in the High Court by Shramik Mukti Sangathana.
Illegal Work on Kalu Dam Site by FA Constructions Photo: SANDRP, May 2011
The Forest Clearance of this dam was rightfully rejected in 2012 by the Forest Advisory Committee (FAC) of the Ministry of Environment and Forests (MoEF). But exactly a year later the Forest Advisory Committee went back on its decision and gave Forest Clearance to this project unjustifiably.
One of the important reasons as, stated by the FAC in in its minutes is that
“(The FAC) also noted that Hon’ble Chief Minister of Maharshtra has specifically requested for a review of the decision of the Forest Advisory Committee” (FAC Minutes 3-4th April 2013)
How is it that the CM actually pushed for a Forest Clearance which would destroy over one lakh trees in Western Ghats, without any studies or options assessment?
When we asked this to the CM after this meeting, he replied that there is no law which says that EIA study for a drinking water supply dam is needed. While this is true and attributed to the erroneous omission in the EIA notification 2006, there is no law which says that such studies should not be conducted! Especially for a dam which is going to submerge 1000 hectares of forests and affect 18000 tribals! A Chief Minister with vision would in fact ask for such studies suo motto.
Dams around Mumbai which are mainly for drinking and industrial water supply can together submerge more than 6000 hectares of Forest. Even the State Forest Department under the Chief Minister himself has said that EIA of Kalu Dam is necessary. Chief Conservator of Forests, Central Circle has said that Cumulative impact Assessment of Dams coming up around Mumbai is necessary.
In this scenario, rather than urgently demanding for such a study the CM has in fact pressurised the FAC into giving a Forest Clearance to Kalu Project, WITHOUT any assessments.
Forests in Tansa Wildlife Sanctuary. 750 hectares of these primer forests will be submerged for the Gargai Dam. Photo: SANDRP
During his speech, the CM said how important afforestation is. He said that he has asked all departments to undertake afforestation. “The issue is so important that even tanker water should be given for afforestation”. When afforestation is so important, why are we submerging last remaining forests of Western Ghats without any studies?
Misrepresentation of Western Ghats Expert Ecology Panel (WGEEP) Report: The CM also said that WGEEP Report has banned all development from Gujarat to Kerala and that the on-going laterite stone mining in Sindhudurga-Ratnagiri districts is a result of WGEEP which will hamper development in these places. It has laid a blanket ban on development.
CM seems to be entirely misinformed on this count. Firstly the laterite stone mining ban has nothing to do with WGEEP Report, but is in place due to a Supreme Court Order. This point has been reiterated several times and it is surprising to see the CM still claiming this. Secondly the WGEEP has not banned developmental activities, but has said that local communities should be in the driving seat while taking decisions affecting their regions. This is also upheld by several laws including the Forest Rights Act. So CMs statement about the WGEEP is clearly ill informed.
It was great to see the CM mention Climate Change, its impacts, need for advanced weather monitoring, etc. It was also good to hear from him about ecological importance for rivers and their flow. It will be good if environmental flows are released from dams of Maharashtra, as also upheld by the Krishna Water Disputes Tribunal. This is currently not happening.
The CM seems to have progressive opinions about water and natural resource management. Hence, we are sure that the CM will demand for an Environment Impact Assessment, Social Impact Assessment and Cumulative Impact Assessment of dams coming up around Mumbai, especially Kalu Dam and will take a critical look at dams coming up across Western Ghats in Konkan being undertaken by KIDC, breaking laws like Forest Conservation Act, Forest Rights Act, Environment Protection Act, National Rehabilitation Policy with impunity. In fact he should see that KIDC and contractors which started work illegally are brought to the books.
We hope that the CM walks his talk about decentralised water management and valuing ecology.
This post is based on a submission made by SANDRP and our colleagues on the HLWG Report on Western Ghats. 20th May 2013 is the last date to submit comments on this. Comments need to be sent to: amit.love@nic.in. We request groups and individuals to make as many submissions as possible.
Comments on HLWG Report with a focus on Water issues
SUB: Comments on the High Level Working Group Report with respect to water sector
This is in response to announcement posted on MoEF website about submitting comments on the HLWG report under the Chairpersonship of Dr. Kasturirangan. These comments mainly deal with water in Western Ghats: One of the most critical issues for Western Ghats States.
A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP
Unfortunately, we have to note that recommendations of the HLWG Committee in response to WGEEP Report as well as some of HLWGs omissions and commissions are detrimental to the well-being of rivers, wetlands and dependent communities in the Western Ghats and hence, for related sectors like ecology, water supply, irrigation, hydropower, etc. This is elucidated in the following points:
HLWG does not comment on any other issue related to water except hydropower:
While the Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamilnadu are facing multiple issues with respect to rivers, drinking water, irrigation, loss of biodiversity and livelihoods, dam-induced displacement, etc., the only issue HLWG report has commented upon is Hydropower. The WGEEP report has dealt with a number of issues related to the water sector from democratic community driven bottom up governance, watershed development, opposition to large dams in ESZ I and II, drinking water, fisheries, etc. However, the HLWG does not comment on any of these recommendations of the WGEEP, nor does it offer its own position on these. This is a serious lacuna in the HLWG Report.
In the absence of such recommendations, we request that MoEF adheres to WGEEP recommendations.
Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP
HLWGs recommendations about Hydropower are ad hoc, unscientific and misleading
HLWG claims that all Hydropower is “renewable and clean.”
This is a completely incorrect statement and it’s surprising to see that it comes from HLWG. The world over, the myth of Hydropower as clean source of energy has been busted.[1],[2] Hydropower projects have huge impacts on environment, ecology, forests, rivers, biodiversity and livelihood security of the people. Studies have proved that methane emissions from reservoirs formed by hydropower dams in tropical countries can have significant global warming potential, methane being about 21 times more potent global warming gas than CO2. Dams emit methane at every draw down.[3] With tropical forests in the Western Ghats (WG) under submergence and otherwise destruction by such projects, this threat is even more serious. Already WG has some of the biggest hydropower plants in the country including the Koyna, Bhandardara, Ghatghat HEPs and three Tata HEPs in Maharashtra, Linganmakki, Gerisouppa, Bhadra, Tungabhadra, Upper Tunga, Talakalale, Kabini, Harangi, Chakra, Supa, Varahi, HEPs in Karnataka, Idukki, ldamalayar, Lower Periyar, Poringalkuttu, Sholayar HEPs in Kerala and Bhavani HEPs in Tamil Nadu. All these projects have not only contributed to greenhouse gas emissions, but have also adversely affected communities, forests, rivers and ecosystems in Western Ghats. There are numerous pending cases of rehabilitation from these dams (for example Koyna in Maharashtra) till date involving tens of thousands of people and communities in many areas are still suffering from erratic water releases from these projects (downstream communities near Jog Falls d/s Linganmakki).
Hydropower dams in WG are in many cases transferring water across the basin for power generation, making it unavailable of the original basin and its inhabitants (For example: Interbasin transfers from Koyna and Tata Hydropower dams in Maharashtra). Every hydropower project has finite life. Thus, for the basin dwellers and everyone else, Hydropower not much renewable either.
HLWG is not justified in giving a ‘clean and renewable’ certificate to hydropower.
Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP
HLWG allows Hydropower projects in ESAs while not looking at performance of existing projects
While the WGEEP did not allow large dams and hydropower projects in ESZ I and II, HLWG has allowed hydropower projects in its demarcated ESAs. This is unacceptable. Western Ghats are already ravaged by dams and at least the areas of high biodiversity value should now be protected from the same onslaught. But the HLWG has rejected WGEEP recommendations about this. While doing so, they have not looked at the performance of the existing HEPs in WG. SANDRP has been studying performance of HEPS in India for some time now based on generation data from Central Electricity Authority. The performance of existing hydropower plants in WG is dismal as can be seen below:
In Koyna Basin, the per MW generation in 2010-11 has dropped by a huge 56.79% from the highest per MW generation achieved in the year 1994-95.[4]
In Kali Nadi projects, the per MW generation has dropped by 46.65% from the highest per MW generation achieved in 1994-95[5]
In Sharavathi Basin projects, per MW generation in 2010-11 has dropped by 37.60% from the highest per MW generation achieved in the year 1994-95[6]
Same situation is true for most other hydropower projects.
Most of these projects are performing far below the level at which the projects were given techno-economic clearances.
There is no assessment as to how much of the generation from such hydropower projects is during peaking hours. Nor is there any attempt at optimising the peaking power from these projects.
It is clear that there is huge scope to make the existing projects more efficient, rather than destroying ESAs in WG with more projects.
We request that in line with WGEEP report, large dams should not be permitted in ESAs of Western Ghats.
Recommendation about mitigating impacts of Hydropower are extremely weak
The HLWG has recommended 30 % of lean season flow as the minimum flow throughout the year as a conditionality for allowing hydro power projects in the ESA. This is contradictory to the recommendation for ecological flows by the HLWG. Ecological flows means trying to mimic the natural flow regime in the river as far as possible and that would include arriving at different seasonal flows based on studies and consultation with the river communities and other stakeholders, using the Building Block Methodology which even the Inter Ministerial Group on Ganga Basin has said is the most appropriate for India. Moreover, the IMG has recommended 50% releases in lean season flows, applicable for all existing projects. MoEF should accept these norms immediately for all existing projects.
The MoEF should be recommending ecological flows / environmental flows as in the WGEEP report and not minimum environmental flows and this should be determined through holistic methodologies like Building Block Methodology and local participation.
The HLWG recommendation of 3 km minimum distance betweendams is totally ad hoc, arbitrary and hence unacceptable. Firstly, the HLWG should have mentioned min 3 km of flowing river between projects. The minimum distance is river specific and would depend upon a basin level study of the river including the altitudinal profile of the river, the riparian forest status, the aquatic habitats and biodiversity, the present dependability and many such criteria. More significantly, the cascade hydropower dam menace which is destroying rives in Himalayas need not be replicated in western ghats. We would like to reiterate that no large dams should be allowed in the ESA of WG.
The MoEF should recommend for arriving at river specific studies while accepting 5 km of free flowing river between projects as minimum distance of free flowing river between projects. The best case is not to allow any further large dams in Western Ghats.
No flows in Sharavathy downstream Linganmakki Dam and Jog Falls. Photo: SANDRP
The HLWG does not stress the need for Environmental Clearance for Mini hydel Projects
Hydro projects less than 25 MW are currently exempt from Environmental Clearance due to a dangerous omission in the EIA Notification 2006. WG is currently facing a severe threat due to a flood of these unplanned cascades of Mini Hydel Projects. Ecosystems and communities in rivers like Netravathi, Kumaradhara, Krishna and Cauvery are facing impacts of these projects, many of which are fraudulent.[7] Netravathi has more than 44 mini hydel projects planned and under operation. Kerala has plans to set up around 100 mini Hydel projects on its rivers. The threat of these projects on river systems in Western Ghats is so high that in March 2013, the Karnataka High Court, has banned any new mini hydel projects in Karnataka Western Ghats[8].
WGEEP had recommended no mini hydel projects in ESZ I and II. HLWG has not done this. While the HLWG makes a rather vague statement “There is a need to redesign and reevaluate small hydropower projects – below 25 mw as these often have limited impact on energy generation and can lead to huge impacts on ecology’, it has not recommended that these projects should need an EIA and EC process, like it has said for Wind Energy. This is a very serious omission. SANDRP and many organizations have written about this to the MoEF several times.
The MoEF should amend the EIA Notification 2006 and include all hydel projects above 1 MW in its purview.
Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP
The HLWG does not stress the need of Environmental Clearance (EC) for Drinking Water and Industrial supply dams
HLWG has not looked at water as a sector, but has only confined itself to hydropower. This has resulted in several loopholes. Many dams are being constructed in Western Ghats for Drinking Water and Industrial water supply. These are also exempt from EC process as per the EIA Notification 2006. Dams like Kalu, Shai, Balganga, Khargihill, Pinjal, Gargai are set to submerge more than 6000 hectares of forest in ESAs and Protected Areas in Northern Western Ghats in Maharashtra.
WGEEP Report had recommended no large dams in ESZ I and II, but the HLWG does not talk about these dams at all. Their impacts on WG forests and communities are entirely ignored. This is another serious lapse of the HLWG report.
The MOEF should amend the EIA Notification 2006 to include all large dams, irrespective of the purpose, including drinking and industrial water supply dams in its purview. No large dams should be planned in ESA of Western Ghats.
Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP
HLWG does not recommend eflows from existing projects
Several hundreds of Irrigation, water supply, hydropower dams have transformed the nature of rivers and dependent communities in Western Ghats. While the WGEEP Report mentioned maintaining eflows from existing projects, the HLWG does not make any recommendation for eflows from existing projects.
Hydropower projects in Karnataka like Kali, Linganmakki have affected communities and ecosystems in the region, have driven some species to extinction. There is an urgent need to restore eflows in all WG rivers.
The MoEF should recommend that eflows should be assessed with holistic and participatory methodology like BBM and recommend e-flows for all dammed rivers in Western Ghats with time limit of one year.
HLWG does not apply its mind to dam decommissioning
The HLWG has chosen to ignore the recommendations on dam decommissioning. While the states have rejected the recommendation the MoP (Ministry of Power) and Central Electricity Authority has noted that dam decommissioning in a phased manner is worth considering.
There are several irrigation and hydropower dams in the Western Ghats which are severely underperforming or incomplete after two decades, or more than 100 years old, and/or unsafe. For example, several experts have opined than large irrigation projects in Konkan region of Maharashtra are severely underutilized. Tillari Interstate Project between Maharshatra and Goa which has come up affecting a wildlife corridor and which has still not rehabilitated its affected population, has a created irrigation potential of 7,295 hectares in Maharashtra of which farmers are utilizing just 162 hectares, according to the Govt Of Maharashtra’s 2012 White Paper on Irrigation Projects in Maharashtra. This underlines the redundancy of large irrigation projects in the WG.
The HLWG had an opportunity to relook at such projects, which it has not done. The HLWG could have noted that the state governments and the MoEF and MoP should start the process of evolving parameters / criteria towards the process of dam decommissioning.
The MoEF may please recommend the same.
Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror
HLWG does not recommend free flowing rivers for WG
Rivers in Western Ghats are repositories of biological, ecological and cultural diversity. Rivers in WG harbor high endemism and diversity in freshwater fish. They also house several Sacred groves at river origins, river fish sanctuaries, etc., protecting rivers and fish. The freshwater biodiversity remains the most fragmented among all biodiversity and HLWG has taken no note of this state and further risks that freshwater biodiversity faces. The WGEEP had wisely followed a graded approach in tune with the ecological connectivity of river ecosystems. ln the HLWG approach, stretches of rivers would flow out of the natural landscape into the cultural landscape which is open to indiscriminate development and the chance for their restoration or protection would be completely lost out. A river cannot be protected in pieces like this.
Looking at the pressures from dams and water abstractions, there in an urgent need to conserve ecologically, culturally and socially important rivers in their free-flowing condition. This approach is well accepted globally and several countries have created specific legislations for protecting free flowing rivers[9]. It seems that the IMG Committee on Upper Ganga, in which Ms. Sunita Narain (Member of Kasturirangan Committee), was also a member has recommended that some six tributaries of Upper Ganga basin should be kept in pristine state. While rejecting WGEEPs recommendation about dam decommissioning or dam free rivers in the ESZs, HLWG has not recommended keeping even a single river in Western Ghats in its free flowing condition.
MoEF should identify ecologically, culturally and socially important rivers, based on community and ecological knowledge and conserve Heritage Rivers of Western Ghats in their free flowing condition for the current and future generations.
Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP
HLWG allows Inter basin transfers in Western Ghats, without any justification or studies
The HLWG has agreed to inter basin transfers toeing the claims of some of the states. There are ample instances of failed interstate – inter basin transfers in the Western Ghats rivers which have turned into permanent scenes of conflicts like the famous Mullaperiyar, Parambikulam Aliyar, Siruvani interstate inter basin transfers between Kerala and Tamil Nadu. The HLWG while acknowledging the need for ‘ecological flows assessment’ in rivers has failed to note that in all these inter basin transfers, the river / tributary has been completely diverted and has lost its ‘ecological flows’. The HLWG could have recommended a cumulative impact assessment of the existing inter basin transfers which would reveal the ground reality.
HLWG seems to have accepted the contention of states like Maharashtra: “This (stopping IBT) would be a problem, they explained, as many regions of the Western Ghats lie in the rain shadow area and need water to be diverted for irrigation and drinking.”
Reality is that, ALL the interbasin transfers happening in Maharashtra currently (through Koyna and Tata Hydro power projects, an amount more than 4 Billion Cubic Meters Annually) are transferring water FROM the rain shadow area of Krishna and Bhima basins TO water surplus regions in Konkan. If HLWG was concerned about water supply for rain shadow regions, it would have at least recommended that this transfer from deficit area to high rainfall area be immediately reviewed and reversed in a time bound manner. It has chosen not to, showing its complete ignorance of ground reality or its completely pro government and pro vested interests bias.
The MoEF should retain the recommendation for no more inter basin transfers as in the WGEEP report and ask for immediate review of transfer of water from deficit basins to high rainfall areas.
HLWG allows hydro projects in first and second order streams
The HLWG has not said no to hydro power projects in first and second order streams in ESA. Meanwhile the MoP, CEA and WAPCOS all agree that hydro power projects should not be permitted in these highly ecologically sensitive areas which are the ‘origin’ of Western Ghats Rivers.
The MoEF should retain the recommendation for no run of the river schemes in first and second order streams as in the WGEEP report.
HLWG offers no comments of on several water sector recommendations of WGEEP which have been supported by State Governments
Kerala and Maharashtra have accepted many of the recommendations of the WGEEP in water sector (page 14 section 2.3 – point 9) like catchment area treatment plan, protection of high altitude valley swamps, water conservation measures, rehabilitation of mined areas, improved river flows etc. It is surprising to note that the HLWG is silent on these very important measures and has not even endorsed these acceptable recommendations which can significantly contribute towards improving water availability in the Western Ghats.
The MoEF should follow these recommendations of the WGEEP.
HLWG takes an extremely biased stand about Athirappilly and Gundia Hydropower projects, rejected by the WGEEP
The WGEEP had categorically stated that the Athirappilly and Gundia Hydropower project should not come up in Western Ghats, looking at their huge impacts on biodiversity, several studies by local organisations and local opposition. However, ignoring all these, the HLWG has taken a very pro project stand on these projects, stating that they can be considered with some vaguely due process, which the state government would be happy to show they have followed it on paper. This is entirely unacceptable.
The MoEF should not allow Athirappilly and Gundia HEPs looking their impact on ecology and communities and in face of the strong local opposition that they are facing.
Athirappilly Waterfalls on the Chalakudy River Photo; SANDRP
The WGEEP process and report initiated a robust discussion about the paradigm of development and conservation in Western Ghats. Water and Rivers is a cross cutting issue connecting ecosystems and communities, rural areas and urban centers, providing goods and services and supporting freshwater biodiversity, which is most threatened currently.
A proactive position on conserving rivers in Western Ghats will go a long way in protecting and conserving myriad livelihoods and ecosystems that thus depend of them.
We hope the MoEF considers the recommendations made above about the WGEEP and HLWG Reports and helps conserving rivers of the Western Ghats for people and ecosystems urgently. The HLWG Report cannot be accepted the way it stands presently. As a step in this direction, we also suggest that WGEEP should get a formal chance to respond to the points raised about it in the HLWG.
Thanking You,
Yours Sincerely,
Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune (ht.sandrp@gmail.com , parineeta.dandekar@gmail.com)
Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (rrckerala@gmail.com)
Open Letter sent by Prof. Madhav Gadgil to Dr. Kasturirangan on the High Level Working Group Report on WGEEP and Western Ghats.
17 May 2013 Dear Dr. Kasturirangan,
JBS Haldane, the celebrated 19h century scientist and humanist who quit England protesting its imperialistic invasion of Suez to become an Indian citizen has said: Reality is not only stranger than we suppose, but stranger than we CAN suppose! I could never have imagined that you would be party to a report such as that of the High Level Working Group on Western Ghats, but, then, reality is indeed stranger than we can suppose!
In our report to the Ministry of Environment & Forests, based on our extensive discussions and field visits, we had advocated agraded approach with a major role for grass-roots level inputs for safeguarding the ecologically sensitive Western Ghats. You have rejected this framework and in its place, you advocate a partitioning amongst roughly one-third of what you term natural landscapes, to be safeguarded by guns and guards, and two-third of so-called cultural landscapes, to be thrown open to development, such as what has spawned the 35,000 crore rupees illegal mining scam of Goa. This amounts to attempts to maintain oases of diversity in a desert of ecological devastation. Ecology teaches us that such fragmentation would lead, sooner, rather than later, to the desert overwhelming the oases. It is vital to think of maintenance of habitat continuity, and of an ecologically and socially friendly matrix to ensure long term conservation of biodiversity rich areas, and this is what we had proposed.
Moreover, freshwater biodiversity is far more threatened than forest biodiversity and lies largely in what you term cultural landscapes. Freshwater biodiversity is also vital to livelihoods and nutrition of large sections of our people. That is why we had provided a detailed case study of Lote Chemical Industry complex in Ratnagiri district of Maharashtra, where pollution exceeding all legal limits has devastated fisheries so that 20,000 people have been rendered jobless, while only 11,000 have obtained industrial employment. Yet the Government wants to set up further polluting industries in the same area, and has therefore deliberately suppressed its own Zonal Atlas for Siting of Industries.
Your report shockingly dismisses our constitutionally guaranteed democratic devolution of decision making powers, remarking that local communities can have no role in economic decisions. Not surprisingly, your report completely glosses over the fact reported by us that while the Government takes absolutely no action against illegal pollution of Lote, it had invoked police powers to suppress perfectly legitimate and peaceful protests against pollution on as many as 180 out of 600 days in 2007-09.
India’s cultural landscape harbours many valuable elements of biodiversity. Fully 75% of the population of Lion-tailed Macaque, a monkey species confined to the Western Ghats, thrives in the cultural landscape of tea gardens. I live in the city of Pune and scattered in my locality are a large number of Banyan, Peepal and Gular trees; trees that belong to genus Ficus, celebrated in modern ecology as a keystone resource that sustains a wide variety of other species. Through the night I hear peacocks calling, and when I get up and go to the terrace I see them dancing. It is our people, rooted in India’s strong cultural traditions of respect for nature, who have venerated and protected the sacred groves, the Ficus trees, the monkeys and the peafowl.
Apparently all this is to be snuffed out. It reminds me of Francis Buchanan, an avowed agent of British imperialism, who wrote in 1801 that India’s sacred groves were merely a contrivance to prevent the East India Company from claiming its rightful property.
It would appear that we are now more British than the British and are asserting that a nature friendly approach in the cultural landscape is merely a contrivance to prevent the rich and powerful of the country and of the globalized world from taking over all lands and waters to exploit and pollute as they wish while pursuing lawless, jobless economic growth. It is astonishing that your report strongly endorses such an approach. Reality is indeed stranger than we can suppose!
Through an unfortunate and short sighted decision, the Forest Advisory Committee of the Ministry of Environment and Forests has gone back on its decision of rejecting Forest Clearance to Kalu Dam that it took on 2nd April 2012. It reconsidered the project and in its last meeting on 3rd-4th April 2013, and has actually recommended the Kalu Dam project for FC, involving 1000 hecatres of Forests in the Western Ghats. It has done this when all the illegalities and irregularities from the proponent still stand today, entirely unaddressed.
We have sent a submission condemning this decision on behalf of Shramik Mukti Sangathana as well as villagers to be affected by Kalu Dam to the Forest Advisory Committee and Minister of Env and Forests Ms. Jayanthi Natarajan. (see below)
You can support the communities and Forests in Kalu by sending similar letters to MoEF Minister and Forest Advisory Commitee.
Illegal Work on Kalu Dam Site by FA Constructions Photo: SANDRP, May 2011
To,
Ms. Jayanthi Natarajan,
Minister of State (IC) for Environment and Forests,
Ministry of Environment and Forests, New Delhi
Subject: Request not to grant Forest Clearance to Kalu Dam in Maharashtra due to several procedural and legal irregularities on the part of the Project Proponent and also the Forest Advisory Committee.
Respected Madame Minister,
This is to express our utter shock and dismay at FAC’s decision of recommending Forest Clearance to Kalu Dam falling in Western Ghats area in Murbad, Thane District, Maharashtra as seen in the minutes of the FAC meeting of April 3-4, 2013.
Just one year ago on the 2nd of April 2012, the Forest Advisory Committee had rejected this proposal, raising substantial points against the proposal and closed the file. This was a respite for the communities facing displacement, community groups working on the issue, for the Western Ghats ecology and the forests. We had then thanked FAC for this decision of April 2012.
On 4th of April 2013, the same Forest Advisory Committee (now with a changed constitution) went back on its decision and recommended Forest Clearance (FC) to Kalu Dam even when nothing has changed on ground and all of the objections based on which FC was rejected in the first place still stand today. The Project Proponent (PP): KIDC, Maharashtra Water Resource Department, has not been able to respond in credible way to any of the points raised by the FAC, Chief Conservator of Forests (Central), State Forest Department, affected villagers or civil society organisations.
We strongly condemn this decision by the FAC of recommending Forest Clearance for diverting nearly 1000 hectares of Forests in the Western Ghats.We urge you (i) not to recommend FC for Kalu Dam; (ii) request you to take steps to make Forest Advisory Committee more transparent, responsive and accountable to issues of communities and forests; specifically, all the documents from the project proponent, including all the annexures of the Form A and gram sabha resolutions for the projects on FAC agenda must be on FAC website at least ten days in advance as per CIC orders and as also assured by you in public; (iii) We also urge you to direct action against those responsible for illegal construction of the Kalu dam as noted by the FAC minutes; (iv) urge you ask FAC to hence forth recommend strict action against such violations.
Major issues about recommending FC to Kalu Dam:
Non-transparent decision making in violation of CIC Orders: None of the documents submitted by the project proponent about the Kalu Project were available in full with all the annexures on the MoEF website even a week before FAC meeting on the 3rd and 4th of April. This is a blatant violation of the CIC orders and we had pointed this out to the FAC through our letter dated March 25, 2013, but the FAC chose to ignore this. As a Minister, you had taken a strong stand against this and had said in October 2012 “These actions and decisions of the officials are unacceptable to me. The forthcoming meeting of the FAC will be postponed, and I shall resolve these (violation of CIC orders and non-compliance of FRA) issues.”[1]
Considering that the lives and livelihoods of about 18000 people will be affected by this project, and when they have the first and foremost right to have all the information on decision making around this project, such irresponsibility on the part of FAC is unacceptable and it is also bad in law. Petition against Kalu Dam is in the High Court of Bombay currently and this point will be raised there.
Complete reliance on Project Proponent’s (PP) claims While recommending FC, the FAC has relied entirely on claims of the proponent, without checking the veracity of the claims or applying its mind. FAC has not even mentioned the numerous submissions made by communities and community-based organisations raising pertinent points against PP’s claims. The FAC needed to keep in mind that the same proponent has gone against its word many times earlier and each time, it has been pointed out to the FAC. It has wilfully violated the Forest Act by starting construction of the project in the absence of FC when the project is to submerge nearly 1000 hectares of land in a biodiversity hotspot, it has gone against its written word when it said that ‘no new project will be required for Mumbai until 2031”, in the process of seeking Stage I Forest Clearance for Shai Project, barely 20 kilometres from Kalu Project.
But the FAC, instead of taking any strict action against the proponent in this regard, has simply accepted its claims, which are again misleading and false.
Grounds for rejection of Kalu Project in 2nd April 2012 by FAC: The FAC minutes state:
· Submergence of 18 villages and their connectivity,
· Initiation of construction without Forest Clearance,
· Breach of commitment given by the Project Proponent during Stage I clearance of Shai Dam,
· Location of the dam within 7 kms of Protected Area
· Location of the project in eco sensitive Western Ghats
· Non-furnishing of: Rehabilitation Plan, Environment Impact Assessment report, Technical Report on Wildlife Status, Gram Sabha resolutions about compliance of Forest Rights Act
NONE of the issues stated above are resolved through the PP’s responses as clarified below:
· No Gram Sabha Resolutions Passed supporting the project: Misleading the Forest Advisory Committee: PP has claimed that it has secured Gram Sabha Resolutions from 8 villages out of the 11 villages that will be fully or partially submerged by the dam. In fact, Shramik Mukti Sangathana has letters from 10 Gram Panchayats out of these 11 that they have not issued any such resolutions at any stage. The last resolution in this regard that they passed was AGAINST the project. These were sent to the FAC on 16.11.11.
If the Project Proponent has the resolutions as claimed, why have they not put these up on the FAC website with the necessary documentation from the PP?
Why did the FAC not see the need to ascertain this even when it was pointed out by us in our letter dated 29.10.12 and again in 25.03.13 that no such resolutions exist?
· Clear violation of the Forest Conservation Act (1980): The proponent accepts that it violated the Forest Conservation Act (1980) by starting work before an FC, but states that it stopped AFTER High Court Orders. High Court Orders were in response of a PIL filed by Shramik Mukti Sangathana against the illegal nature of the work. So, stopping AFTER HC orders is no justification for committing the illegality. Before the High Court orders, Shramik Mukti Sangathana had written several letters about this violation to the Collector, Chief Secretary and Forest Department and had also served a notice to the PP. It did not stop work then.
Considering this, the Forest Advisory Committee ought to have penalised the project proponent for violation of Forest Conservation Act (1980), not recommend the same project for clearance.This only gives out a signal that no action will be taken by the MoEF even after it knows that violation of Forest Act is happening, that too by a state agency.
· Continued violation of the Forest Rights Act (2006) It has been pointed out several times to the FAC that Kalu Project is violating the Forest Rights Act (2006) as community and individual claims are yet to be settled. The Forest Rights Act was passed to safeguard historical injustice on Forest-dependent communities, but the FAC itself is encouraging the PP to violate FRA, PESA, Rehabilitation Policy and Forest Conservation Act. You, as a Minister, had reasserted MoEF’s commitment to implementation of Forest Rights Act.
· No Rehabilitation Plan has been submitted at the time of recommending Forest Clearance There is no such plan available in public domain, nor has there been any participatory process of approval of the plan with the affected people. A claim of a rehabilitation package of Rs 68.75 Crore does not constitute a Rehabilitation Plan. This point was raised several times by community organisations, State Forest Department, Chief Conservator of Forests as well as the FAC. Villages to be affected by Kalu Dam fall in Tribal Subplan and attract PESA. Without any legally mandatory process, just the claim of rehabilitation package of Rs 68.75 crore seems good enough for FAC. It was clearly wrong on the part of the FAC to recommend FC based on such claims.
· Konkan Irrigation Development Corporations letter that “it is not necessary to construct any new water source till 2031”: This was submitted to the MoEF while seeking Stage I Forest Clearance for Shai Dam, less than 25 kms from proposed Kalu dam in 2010-11. FAC recommended Stage I Clearance to Shai Dam based on that assurance. In less than 3 years, the proponent feels that Shai dam, whose clearance was obtained on such a claim, will not be sufficient till 2031. This is unjustifiable and tantamount to misleading the FAC with false assurances.
· No Environment Impact Assessment (EIA) Conducted The Kalu Dam falls in ecologically sensitive Western Ghats. The Western Ghats Expert Ecology Panel had categorised the region in ESZ I where no large dams should be permitted. Even as per the Kasturirangan Committee Report, more than 5 villages affected by Kalu Dam are falling in the ESA.
The State forest Department, Chief Conservator of Forests (Central), community groups have all urged that EIA as well as a Cumulative Impact Assessment of the Project has to be done before granting Forest Clearance. In fact, this was one of the conditions laid by the State Forest Department. Looking at the ecologically sensitive location of Kalu Dam and submergence of nearly 1000 hectares of Western Ghats Forest Land, this was a reasonable expectation.
Despite these clear conditions, the PP argues that EIA is not required. And despite this, the FAC recommends FC to this project!
In this context, Section 2.3 (ii) of FCA (1980) read, “Notwithstanding the above, if in the opinion of the Ministry or the Advisory Committee, any proposal should be examined from the environmental angle, it may be required that the project proponent refer the case to the Environment Wing of the MOEF.” So irrespective of the requirement of EIA notification, the FAC has been provided powers to refer to an such project to the environment wing of MoEF or EAC for examination of the project from the environment angle, but FAC failed to do this just under the claim of the PP that EIA is not required under EIA notification.
FAC recommendation that Cumulative Impact Assessment has to be undertaken for drinking water projects around Mumbai is welcome but again, it could have been done before considering this project for clearance and not after recommending clearance. Similarly their recommendation to the MoEF to amend the EIA notification to ensure that such dams are included for environmental impact assessment is welcome, but they could have waited for MEF response rather than recommending Forest Clearance.
In this regard we urge you: (i) immediately change the EIA notification to include Kalu and all such large dams under the ambit of the EIA notification, irrespective of the purpose of the project; (ii) Direct specifically that Kalu Dam require EIA and Env clearance, using the above mentioned part of the Forest Conservation Act, 1980 and EPA, 1986; (iii) Order a cumulative impact assessment of all the projects in the western ghats region around Kalu dam, as recommended by FAC and (iv) direct that FC for Kalu will NOT be considered till all these requirements are fulfilled.
· Forest Conservation Act requires Gram Sabha clearance Moreover, section 2.1(vii)(4) of the Forest Conservation Act, 1980 clearly states: “Therefore, whenever any proposal for diversion of forest land is submitted, it should be accompanied by a resolution of the ‘Aam Sabha’ of Gram Panchayat/Local Body of the area endorsing the proposal that the project is in the interest of people living in and around the proposed forest land except in cases wherever consent of the local people in one form or another has been obtained by the State or the project proponents and the same is indicated in the proposal explicitly. However, it would be required where the project activity on forest land is affecting quality of life of the people residing in nearby areas of the site of diversion; like mining projects, displacement of people in submergence area, etc.” This provision is particularly applicable to a project like Kalu that has not had EIA or public hearing as stated in the same section in FCA, 1980. Recommending FC for Kalu Dam project without fulfilling this requirement is clearly a violation of the FCA, 1980 by the FAC.
We urge you to direct the project proponent to get gram sabha resolutions on the lines mentioned above in FCA Section 2.1(vii)(4) and direct FAC consider the project only after these have been received.
· Distance from Protected Area: The submergence of the project is less than 10 kms from Kalsubai Sanctuary. Considering the fact that no EIA is conducted, no report on Wildlife Status exists, this makes ecological impacts of Kalu Dam on Western Ghats ecosystem even more serious. Considering all these issues, FC should have been rejected on this ground alone. In fact the PP goes ahead to say: “No rare or endangered flora or fauna has been reported from this site” How can this be stated when no EIA has been conducted and no wildlife report exists?
· The PP states that only “44566” and “44611” that is ‘only’ 89177 tress will be felled during and the rest ‘may be’ saved. Ninety thousand trees in Western Ghats is a huge number. But it seems FAC does not see any objection in this. The claim that the rest of the 60 000 trees can be saved is of doubtful credibility. Similarly the claim in the FAC meeting minutes that “No rare or endangered species of flora and fauna has been reported in the area” is also without any credible basis.
· We would like to reiterate that no options assessment about water supply options to Mumbai has been done. No consideration of rainwater harvesting, using saline water for some uses, grey water recycling, demand management, water use efficiency, and conjunctive groundwater use has been done. The FAC minutes notes this, but from the minutes it seems it has not applied its mind to these issues and recommended FC as a matter of blind support for the project. The mention of the letter from the Chief Minister in the minutes only adds to the suspicion that the FAC has cleared the project without looking into merits of the issue.
· Contradictions in FAC conditions? The FAC has recommended FC to the project, with some additional conditions, one of the additional conditions states: “The User agency will abide by all conditions by Regional Office, Bhopal and State Government during inspection of the project.” So the PP has to adhere to all the conditions imposed by the Regional Office, Bhopal and the State forest Department while inspecting the project.
One of the conditions imposed by the Regional office, Bhopal included: “…the State Govt. may be directed to stop all the construction related activities till all the legal formalities and forest, wildlife and environment related studies are completed and a well-considered decision regarding forest diversion is taken based on proper scientific documentation and studies.”
We seem to be in a funny situation now. The FAC, while recommending FC, put a condition that says that decision of FC should not be taken without “proper scientific documentation and studies”, but FAC has done just that! In any case, one implication of this is that the project should not get even first stage FC without the studies recommended by Regional Office, Bhopal, including EIA has been done.
Similarly the State forest department too has asked for (i) Rehabilitation Plan (ii) EIA (iii) technical report from WII on impact of project on wildlife in and around the project area (iv) gram sabha resolutions from all affected villages under FRA. The project should not thus be given even stage I clearance without satisfaction of all these conditions.
Most of these issues have been brought to the attention of the FAC time and again by us, Shramik Mukti Sangathana and other community groups. However, the FAC still went ahead with the incomprehensible decision. Hence, we are writing to you with the hope that after looking at all the points raised above, you will definitely not recommended Forest Clearance to Kalu Dam. We also hope that MoEF will punish violators of FC and FRA Acts to send a strong signal and will take steps to make the present Forest Advisory Committee more transparent, accountable and responsive to issues ailing our forests and forest-dependent communities.
We will look forward to detailed response on this from you. Thanking you for your attention,
SANDRP 