On conclusion of five month long Narmada Sewa Yatra, Prime Minister Narendra Modi is today ( May 15, 2017) launching a road-map for steps to be taken for the conservation of the Narmada river. The MP state assembly has also recently declared river Narmada a living entity. Even otherwise quiet on rivers environment minister Anil Madhav Dave has expressed concerns for Narmada.
Contrary to all this, the Central Govt and 3 states of MP, Maharashtra and Gujarat have begun a process towards sanctioning completion of the Sardar Sarovar Dam, with closure of the 17 meters high gates. It is a countdown towards impounding waters in the 214 km land stretch where more than 40,000 families are residing till date. There are standing crops and massive plantations; thousands of pakka houses, schools, other public and private services erected; hundreds of temples, tens of mosques (as opposed to three temples claimed by the authorities), adivasi gods and worship places, all of which will be submerged. In protest thousands of people from Narmada valley, to be affected by Sardar Sarovar Project created a Human Chain on the borders of living village communities and on the banks of the river, protesting against any decision to close the dam gates.
Tamil NaduA people’s initiative to restore a river’s gloryThe Noyyal River Restoration Federation will launch ‘Noyyalai Nokki’ (Towards Noyyal), a people’s initiative to restore the Noyyal river system on 26 March. Social activist Anna Hazare will launch the project at Kooduthurai in Alandurai in Coimbatore district. The river originates in the Western Ghats and runs through the four districts to join the Cauvery at Noyyal village. Known as Jungle stream, in olden times as many as 34 streams used to feed water into it and the river would flow throughout the year with two or three annual flood spell. But now, just 4 or 5 streams feed the river. In many places, the river is encroached upon, sewage is let into it, or the river needs to be desilted. The river is all set to regain its glory with the ‘Noyyalai Nokki’ initiative. What is encouraging is the willingness of the public to be part of it. The project proposes to divide the river into segments of 500 metres for restoration and maintenance. Ownership groups will be formed for every 500 metres and it will consist of the local people, experts and patrons (divide-distribute-develop model).
We are happy to publish full text of an Open Letter written by Dr. T.V. Ramchandra, Center for Ecological Sciences, Indian Institute of Science, to Karnataka CM Shri. Siddaramaiah. The letter transparently questions Yettinahole Project, while strongly rebutting Karnataka Neeravari Nigam Limited’s (KNNL) propaganda against IISC Report which has established that Yettinahole Catchment does not have the 24.01 TMC water as per KNNL DPR, but only about 9 TMC water, which is used by the basin residents. (https://sandrp.wordpress.com/2015/05/21/yettinahole-diversion-project-literally-holds-no-water/). He does not limit himself to hydrology and ecology, but with detailed rainfall analyses, also debunks the fact that Kolar and Chikkaballapur face acute water scarcity. He staunchly bats for rainwater harvesting, rejuvenating lakes and tanks and afforestation with native species as cheaper and more reliable method to ensure water availability.Continue reading “Scientist’s Open Letter to Karnataka CM: “Yettinaholé project is ecologically disastrous and economically unviable””→
Above: The modest Yettinahole Stream, close to location of proposed weir. Photo: Parineeta Dandekar
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Debate over Yettinahole Diversion Project has been raging in Karnataka for more than two years now. While Dakshin Kannada has been rightly raising issues of unassessed social and ecological impacts of the project on this region, fresh information now available, including a study by scientists of the Indian Institute of Science – Bangalore, and other experts proves that Yettinahole Diversion Project just does not have the water that the project developers claim it does, taking out the very hydrological foundation of the project.Continue reading “Yettinahole diversion Project (literally) holds no water”→
River Netravathi in the upper reaches Photo: Parineeta Dandekar, SANDRP
Like a many-headed serpent, Yettinahole (Netravathi) Diversion Project refuses to die. Every time one of its head is cut, it grows a new head.
Following criticism of the Project Report [i](based on which Karnataka Government had already made budget provisions in 2013), a new DPR of the project has been prepared in December 2013 by EIT RIP JV [ii] which tries to amend blatantly illegal stands taken earlier. However, after scratching the surface, it is clear that the DPR is just as illegal and dangerous as the interim Project Report was.
Yettinahole, or rightly the Netravathi Diversion Project has always been a political project, visualized to earn political mileage and brownie points. Veerappa Moily originally from Dakshin Kannada, moved to Chikkaballpur constituency in 2009, from when he started pushing the project strongly. As the Environment Minister, Moily also laid the foundation stone of the project in Chikkaballapur, just before the Loksabaha Elections in March 2014 [iii]. Strategically, the stone was laid in Chikkaballapur and not in Hassan, from where the water actually be diverted. No political party has opposed the project consistently.
Even before a complete DPR, Karnataka 12-14 Budget of the Congress Government allocated nearly 2800 crores for this scheme. The current govt lost no time and directly awarded contracts worth nearly 1000 Crores to Hindustan Construction Company, in a joint venture with GVPRL, without any clearances or any public consultations[iv].
Before the laying of the foundation stone of the project, SANDRP had presented a detailed analyses if the Project Report proving how the project is violating Environmental Protection Act by evading Environmental Clearance.[v] A number of eminent personalities from Karnataka had jointly written to the MoEF to appraise the Project for EC. In response to this, the MoEF had written to the Karnataka Govt and Karnataka Neeravari Nigam Limited (KNNL), seeking clarifications on the nature of the project. Although this move was triggered due to the submission made by SANDRP and other groups, we never saw KNNL’s response despite specifically asking for it. We only saw MoEF’s lame justification, bailing out KNNL and Karnataka Government and turning a blind eye to the huge impacts of the project.
Students protesting against Yettinahole Project Photo: DaijiWolrd
When Karnataka CM Siddramaiah was about to lay the foundation stone along with Mr. Moily, SANDRP wrote an open letter to him[vi], as the Environment Minister, asking a direct question as to how can he himself formally initiate a scheme which is blatantly violating laws governed by his own Ministry. Following this, the ceremony was cancelled[vii], only to be held surreptitiously later.
During all this, there was huge and unprecedented opposition to the project from Dakshin Kannada and Mangalore. Farmers, students, workers, women groups all came together, united in their opposition against a project that would divert their Netravathi. People stopped trains, organized hundreds of dharnas, boycotted voting, organised signature drives, etc. Leaders in all hues came together in a rare show of discontent. On the day of foundation stone laying, people in Dakshin Kannada voluntarily observed a strict Bandh. Funnily enough, even the beneficiary district of Chikkaballpur opposed the project as the 2.82 TMC water that it would be getting after so much of fanfare was too meager, in the face of the grand promises of lush fields and no worries.
More Protests against the Project Photo: The HinduProtest in Hassan against Yettinahole Photo: The HinduProtesters stopping a train Photo: News Karnataka
Despite these unprecedented protests and in the face of 2014 Loksabha Elections, foundation stone was laid on a dais in Chikkaballapur. The dais was burgeoning under the weight of several political strongmen.
This event stands out as an example of undemocratic behavior for an elected government.
Foundation Stone laying Ceremony Photo: The Hindu
The Government of Karnataka did not hold a single public meeting in Dakshin Kannada, trying to understand and address people’s apprehensions. When eminent personalities from Dakshin Kannada planned to hold a National Consultation on Yettinahole Diversion in NIT Suratkhal in August 2013, the meeting was cancelled at the last minute due to political pressure on the organizers.
As things stand now, the project does not have Environmental Clearance, Forest Clearance, Wildlife Clearance, has not started rehabilitation and resettlement of over 10 villages that it will submerge, but its work can start at any moment.
SANDRP accessed the Detailed Project Report (DPR) of the Project from local activists, who obtained it under RTI. Analysis of the DPR reveals a number of issues. KNNL has drastically changed the initial Project Report, avoiding mention of contentious issues we had raised like hydropower generation, irrigation component, etc., thus strongly vindicating the objections raised. However, going further, it is clear that these changes are cosmetic. Deeper problems and severe unstudied impacts of the scheme remain.
SANDRP analyzed 4 volumes of the DPR and Annexures of the Project. What follows is some myth busting about the Yettinahole Detailed Project Report.
1. What is the Current Project? Is it different from the last Project Report?
While the Project Report of June 2012 was titled: ‘Scheme for diversion of flood water from Sakleshpura (West) to Kolar/ Chikkaballapura Districts (East)’, the DPR dated December 2013 has taken out all the random stuff on Kolar and Chikkaballapura and simple calls it as “Yettinahole Project”.
Current Project as per the DPR, is divided in Two Phases.
Phase I: 8 weirs will be built in the Western Ghats, on the streams Yettinahole, Kerihole, Kadumanehole and Hongadahalla. It also includes several pump houses next to weirs, raising mains that run for several kilometers are nearly 5 kms wide, 3 Delivery Chambers (DC) and a gravity canal taking waters from Weirs 3, 4 and 5 to Doddanagara (DC 3) in the Western Ghats forests.
From the weirs, 85 cumecs (Cubic Meters per second) water will be drawn 24*7 in the six months of June-November.
This will be delivered through 4 Delivery Chambers with the last DC: DC 4 at Haravanahalli.
Phase II: From DC 4, water will be diverted to a canal running 274 kilometers, cutting across the ridge line dividing Cauvery and Krishna Basins and culminating at a Balancing Reservoir at Byragondlu and Thumbadi, in Koratgere Taluk. Thumbadi Reservoir will store about 3 TMC water and will submerge nearly 700 hectares of land and three villages[viii] while Balancing Reservoir at Byragondlu will store 5.7 TMC water and will submerge 7 villages [ix]and an area of about 2000 hectares. The Reservoir at Devaranyadurga, which was proposed in the Project Report has been replaced by these two.
It includes construction of several storage tanks and reservoirs for en route water supply. It will also delivery water to T.G. Halli and Hesarghatta Reservoirs, which supply water to Bangalore. It also plans to supply water to Devanhalli Industrial Area.
The project envisages constructing 7 additional storage reservoirs and 10 major canals. Water will also be used to fill morethan 500 Minor Irrigation (MI) Tanks in many districts and taluks.
It is amazing how the project envisages filling MI Tanks to 50% capacity: The DPR says that water will be pumped and released to the highest point and an additional sluice gate will be made to all MI tanks to let water flow into the cascading MI tank. This sounds highly impractical.
The project also includes constructing over 100 bridges in villages and nearly 100 road brides on major roads.
So although details have changed, the basic of the project remain the same. There is no change in Western Ghats, except for the fact that not 24 TMC, but 47 TMC water will be pumped now!
Survey markings in Sakaleshpur on peoples homes. People had no idea why the survey was carried out and no information was given. Photo: Parineeta Dandekar
2. What is the cost of this current Project? Can the cost be borne easily by KNNL or Karnataka Government?
The cost of the Project as per DPR stands at nearly 13000 Crores as per 12-13 price line. This exceeds the entire 13-14 years’ budget of the Karnataka Water Resources Department, which stands at 8007 Crores and is nearly five times the annual budget of KNNL, the implementing agency.[x] This is a colossal amount of money to spend to convey approximately 7 TMC water to Kolar and Chikkaballapur and other nonspecific projects.
3. Who are the Main Beneficiaries? Will Kolar and Chikkaballpur really get 24 TMC water as promised?
The supposed beneficiaries of the project are several towns, villages, cities and industrial areas[xi] and No, Kolar and Chikkaballapur again lose out and get only about 7 TMC water.
4. Then who will be getting this water?
The DPR puts out a diffuse list of beneficiaries ( see Annex below) including Bangalore urban area through TG Halli and Hesarghatta Reservoir and the Devanhalli Industrial Hub. There are no population projections or future need calculations for this region like all other regions and at no place does the DPR say that water will go to Bangalore. However, TG Halli and Hesaraghtaa reservoirs are both used by the Bangalore Water Supply and Sanitation Board [xii]for Bangalore City and in the last Budget, the government had itself stated that water will be used for Bangalore Urban Area’s needs.
How Bangalore treats its local water bodies Photo: The Alternative
A review of beneficiaries:
Bangalore gets 3 TMC water: The DPR says that about 3 TMC water will be released to TG Halli and Hesargahtta Reservoirs and for the Devanhalli Area.
Minor Irrigation Tanks and hence irrigation gets maximum water at 9 TMC: Nearly 9 TMC water will be used for filling more than 500 MI tanks upto 50% of their live storage capacity. This water will be supposedly used for “groundwater recharge”. There are several participatory, cheap and sustainable ways for recharging groundwater, which seem to have been rejected in favor of long distance transfer. In any case, this groundwater recharge will be used for agriculture, as most of the agriculture there depends on groundwater and hence, the project qualifies for Environmental Clearance.
The project is being pushed for the drought affected taluks in Kolar Chikkaballapur and Tumkur and even a brief glance at the calculation shows that even in 2023-24, the drinking water demand of these places cumulatively will be just 12 TMC! Then why are we diverting 24 TMC water, double of the ten years’ estimate?
5. What is the basis for diverting 24.01 TMC?
The report provides no justification about why 24 TMC is supposed to be diverted. In fact, after population calculations and making provisions for drinking water supply for the beneficiary districts and villages, the DPR simply states : “This has resulted in a balance availability of 8.9 TMC” . This is a strange statement to make. What is meant by “balance availability”? Is there compulsion for diverting 24 TMC by hook or by crook from the Western Ghats?
6. 24 TMC Diversion? No 47 TMC Diversion!
The project envisages diverting 85 cumecs (Cubic Metres per second) water[xiii], purportedly for six months of June-November. The DPR states that pumps will function 24*7 during this period. Even a simple, back-of-the-envelope calculation indicates that 85 cumecs diversion leads to nearly 47 TMC diverted over six months and not 24 TMC, as is claimed.
7. Was there a detailed hydrological study to arrive at 24 TMC diversion?
The proponents have no flow data from individual streams. The 13,000 Crores project is to be based on shoddy hydrology data.
They have used gauge data from Bantwal across Netrvathi, which is approximately 60-70 kilometers downstream and in a completely different eco-region from the hills. This gauge data is simply extrapolated based on catchment area of each stream. This is highly unscientific.
The earlier Project Report used an entirely different method for calculating this yield, based in rainfall in individual catchments. Interesting to see that although to different methods were used by two different reports, divertible yield is exactly the same to the last decimal point of 24.01 TMC!
The fact of the matter is that there have been no scientific studies to find out the level of safe diversion. The DPR makes a fantastic statement in conclusion to the effect that:
“According to the revised computations, the divertible yield has been assessed as 22.14.TMC. However, Prof.Rama Prasad , who has conducted the Hydrology studies has opined that the yield of 22.14 TMC at 50% dependability is very much on a conservative side and 24.01 TMC of divertible yield is available across the streams. This has been taken note off and for the present proposal, 24.01 TMC of water has been considered as the divertible yield from the selected streams to proceed further regarding finalization of the scheme in total.”
This just shows the random way in which divertible yield has been fixed!
8. How about the downstream Impacts of this diversion, which was the main reason for protests in Dakshin Kannada and Mangalore? Were the impacts studied?
There has been NO assessment of downstream water needs or impacts of this diversion on the downstream people or ecosystems. The DPR just ‘assumes’ that there will not be any impact on downstream users of ecology!
This is evidently misleading. One example of the problem in such assumption is that the flow data of Hongadahalla maintained by KPCL (given in Annex) indicates that flow in streams like Hongadhalla in August near the gauging point, has not exceeded even 20 cumecs. However, the according to the DPR[xiv], arrangement has been made to divert a whopping 30 cumecs from Hongadhalla from Weir 7 during June-November. This means that in the downstream, the rivulet will be rendered dry.
9. Was Impact Assessment for Western Ghats conducted?
The project proponent has not even clarified as to what will be forest land required for diversion. The section on Impact Assessment in the EMP deals largely with the beneficiary region without dealing with impacts on Wesetrn Ghats at all. There has been no study on eflows as per the HLWG (High Level Working Group on Western Ghats/ Kasturirangan Committee Report)report, no study of estuarine fisheries, no study of drinking water needs.
Cornered Wildlife in Sakaleshpur, leading to crisis Photo: News 24 7
10. Will there be profound impacts in the downstream region?
Yes. Yettinahole Project will “divert” water out of the basin and unlike most other irrigation or hydropower projects, the water will be permanently lost from the basin. The ecosystem and livelihoods in the downstream are closely linked to the hydrology of the Netravathi. In fact even in June, which is supposed to be a “peak season” for diversion, Mangalore and other parts of Dakshin Kannada have been facing water shortages[xv]. In addition, there are several estuarine and riverine fishermen dependent on the Netravathi for their livelihoods. There are many industrial areas, SEZs coming up in Mangalore which will be needing more water. While there has been a prospective study of the population and water demand growth of the beneficiary region in the DPR, there has been not even a mention of Mangalore and its increasing needs in the future in the DPR, highlighting the bias of the proponents.
There are several functioning mini hydel projects on the individual streams as well as tributaries which depend on the assured flow from upstream. They have not even been consulted before this decision was taken.
Drying Thumbe Dam which supplies water from Netravthi to Mangalore town Photo: The Hindu
11. Will there be a severe impact on Ecology and Wildlife?
The project falls within 10 kms boundary of the Pushpagiri Sanctuary, one of the specific World Heritage Sites in the Western Ghats[xvi]. The entire region has exceptional biodiversity. The project also affects the Mysore Elephant Reserve.
The region has exceptional fish biodiversity, with several new species [xvii]being discovered from the region. There have been efforts to declare this area as a specific fish sanctuary.[xviii]Despite this, the Environmental Management Plan of the DPR states that the fish diversity in most streams is “Poor”. This is a very irresponsible and misleading statement.
Man Animal Conflicts in Sakaleshpura are on a rise. Mega infrastructural activities envisaged in Yettinahole Project will worsen the situation further. There has been no mention of this.
Canara Pearlspot, an endangered fish of many such species found in Netravathi Photo: Arkive.org
12. Considering the impacts and the strong opposition from Dakshin Kannada, were any public consultations held?
No. there has not been a single open public consultation held by the proponents or the Karnataka Government in the affected region. This indicates lack of respect for democratic values and transparency. Shockingly to the question: “ Have-public debates about utility of projects been held and the response thereof outlined in the Report?” has been answered as “Yes” in the DPR.
In fact there has been no such report in the DPR.
The DPR also states: 1.14: “Many public meetings have been held by the Govt. to make the people aware of the importance of the scheme both in the initial reaches and the end reaches of the project.”
More protest Marches in Mangalore Photo: Daiji World
This is entirely false as no such meeting has been held on Dakshin Kannada where informed discussions can be held.
To conclude:
Yettinahole diversion or Netravathi Diversion Project is an extremely costly ( 13000 Crores +) project of the Karnataka Government. It has been based on weak hydrology, nonexistent impact assessment of the downstream region, no Forest Clearance, no Wildlife Clearance and no public consultations. It is violating Environment (Protection) Act 1986, Forest (Conservation) Act 1980 and Wildlife (Protection)Act 1972. As has been proved by SANDRP, Karnataka has violated Environmental Laws in the recent past[xix].
The project provides no justification for diverting 24 TMC, plans to divert more volume than that, most of which is meant for urban areas and irrigation, without options assessment of cheaper and more sustainable options.
The project has illegally awarded tenders worth Rs 1000 crores without clearances.
In the interest of ecology, downstream population of Dakshin Kannada, public resources, wildlife, World Heritage sites and even future generations, at least until we have basis for informed decisions including a credible EIA, SIA, Options assessment and participatory decision making process, Projects like Yettinahole need to be shelved. Already multiple PILs against the project have been filed in the High Court and routed to the NGT. We hope NGT will also take a strong view on the serious issues involved here.
Severe downstream impacts and drying up of streams due to Yettinahole project reminds one of the tale of Sage Durvasa, meditating on the banks of the Tunga, not very far from Dakshin Kannada. Durvasa loved the river and was known for his short temper. As Bheema dammed the flowing River, Durvasa was agitated to see dried up river bed in the downstream. Yudhishthira saw this and advised Bheema to break the dam himself, to avoid the wrath of Sage Durvasa. Bheema relented and broke the dam, to allow the free flow of the river once more. (One of India’s first decommissioned dams?)
Let us hope that Netravathi flows unhindered and continues to support human and non-humans alike like she has been doing for centuries. Even for the areas claimed to be benefiting from the project, there are cheaper, sustainable and credible options available than this mega project.
Tumkur district comprising of areas in Palar and Pennar basins including Chiknayakanahalli and Sira Taluks along with selected villages in Tiptur and Gubbi Taluks.
Hassan district comprising of villages in Arasikere taluk
Chikamagalore district comprising of selected villages in Kadur taluk
Ramanagara district
Bangalore Rural district comprising of Nelamangala, Doddaballapura, Devanahalli and Hoskote Taluks
Augmenting the water to T.G.Halli reservoir
Augmenting water to Hesaraghatta reservoir
Drinking water supply to Devanahalli Industrial area and surrounding areas
Providing water for tank filling purposes to fill selected M I Tanks to their 50 % capacity (average) in the M I tanks falling under Palar and Pennar basins and Arasikere taluk
The February – March 2014 edition of SANDRP’s magazine ‘Dams, River and People’ is now available online. This is the 1st-2nd issue of magazine in its 12th volume. The contents magazine is mentioned in the list below. This edition of the magazine covers varied but very significant issues related with dams, rivers and environment in India. This issues brings together detailed reports on a river protection rally in Western Ghats, blatant violation of environmental laws for construction Yettinahole Diversion Project in Karnataka, impacts of hailstorm on Maharashtra farmers and state’s ‘Inaction’ plan on climate change, a reality check on Narmada Kshipra pipeline project in Madhya Pradesh and a detailed critique of cumulative impact assessment study of Siang river basin in Arunachal Pradesh. The magazine in pdf format is available here — https://sandrp.in/DRP_Feb_Mar_2014.pdf. Several of the articles are also available in SANDRP’s blog and they can be viewed just by clicking on the name in the list. Enjoy reading.
Subject: Issues about the laying of Yettinahole Diversion Project’s foundation Stone
Respected Dr. Moily,
We learnt about your announcement and support for laying the foundation stone of the controversial Yettinahole Diversion Project on January 31, 2014 in your parliamentary constituency of Chikkaballapur, from several media reports[i]. The project has not conducted any impact assessment study and does not have any statutory clearance from your ministry. This is in complete violation of several norms and laws and is shocking, to say the least.
Dr. Moily, our assessments based on local interactions, site visits, study of the Project report (the DPR for the project is still not ready) indicate that the project involves eightdams inside the Western Ghats, deforestation of more than 100 ha of forests inside the Western Ghats eco-sensitive region, water diversion without any ecological studies, 370 MW of power for pumping, a canal of 250 kms length, 1200 ha submergence near Devaranyadurga including submergence of 2 villages and 600 ha forest land. [ii]
The foundation stone laying ceremony is supposed to take place on the 31st January 2014 at Muddenahalli, Chikkaballapur, which also happens to be your current constituency. It is clear why you chose Chikkaballapur to lay the foundation stone, and not Sakaleshpur, from where the water will be diverted, or Dakshin Kannada, which will face most of the impacts of the project. In Sakaleshpur and entire Dakshin Kannada, (which was your constituency in the past) there is a huge and mounting opposition to Yettinahole Diversion and also to your decision.
Just in the last two weeks, there have been attempts to a stop train in protest, numerous dharnas, hunger strikes, letters in opposition and a Satyagraha in Netravathi River to oppose this project.[iii]
Rail Roko protest against Yettinahole Diversion Photo: Daiji World
Despite this growing discontent, you, as an MP from Chikkaballapur and the Union Environment Minister, or the Karnataka Government did not feel the need to initiate a dialogue with the people of this region. Has the government learnt no lessons from Delhi as to what happens when local voices are ignored and unheeded?
Protest in Hassan (in addition to Dakshin Kannada) against Yettinahole Diversion. Photo: The Hindu
Why has the Karnataka Government or the Union Ministry of Environment and Forests, which you now head, not thought it necessary to assess and address the serious ecological impacts of this project? Why have you supported the fraudulent tactics of this project to escape environmental clearance? Our letter to the Ministry in his regard dated 10 Sept 2013, which was endorsed by several experts remains unanswered till date[iv].
As the Minister of Environment and Forests, it is your duty to see that projects with significant impacts on ecology and dependent communities are assessed. Why are you escaping that duty?
Why is the Karnataka Government and the MoEF, under you leadership, hiding behind weak technical clauses of the EIA Notification 2006 to claim that the project does not qualify for Environment appraisal?
In fact the EIA Notification 2006 requires that there is thorough appraisal of the project. We have sent you a letter in this regard again on the 28th of January 2014, with scanned pages from the project report proving this.
How can you support foundation stone laying ceremony when RTI reveals that Forest Department has not even assessed the forest area affected by this project?
How can a Minister of Environment and Forests of India indulge in an illegal act of formal initiation of a project that does not have environmental or forest clearances?
The project will come to the Ministry of Environment and Forests, headed by you, for Forest Clearances. But you have supported the foundation stone for this project already, giving a signal that forest clearance is a foregone conclusion.
If this is not conflict of interest, what is?
And all this for 2.8 TMC drinking water for Kolar and Chikkaballpur Districts. Has the government conducted any studies to prove that project with Rs 100 Billion cost and severe environmental impacts is the least-cost option to get drinking water for Kolar and Chikkaballapur in whose name the project is being pushed?
Dr. Moily, as the Union Environment Minister, it is you duty to address these questions before you support the foundation stone laying of Yettinahole Diversion Project.
Not doing so is in violation of environmental norms and legal stipulations.
We are looking forward to getting a point-wise response from you.
Sincerely,
Parineeta Dandekar, Himanshu Thakkar, SANDRP, Pune and Delhi
Dr. T. V. Ramchandra, Energy and Wetlands Group, Centre for Ecological Sciences, Indian Institute of Science, Bangalore, Karnataka
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.
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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.
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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
SANDRP 