When EIAs Don’t Know River Lengths! Review of EIA/EMP of Simang I & II HEP on Simang River in Arunachal Pradesh

for the box 1The Simang River is a tributary of the Siang River which originates at an elevation of 2950 m. The river is 44 km long (as mentioned in the EIA/EMP reports done by consultant R S Environ Link). Total catchment area of Simang River is 554 sq km. There are two projects proposed on the Simang River.  The first one is Simang I with an installed capacity of 67 MW (3 x 22.33 MW) and catchment area of 494 sq km. The second one is the upstream project Simang II with an installed capacity of 66 MW (3 x 22 MW) and catchment area of 422 sq km. These two projects were jointly discussed in the 19th meeting of EAC in October 2008 for the first time. Then these projects were subsequently discussed in the 21st, 36th, 66th and 67th meeting of EAC. A diagram of the two projects on the Simang River is given below.

Diagram of Simang I & II projects on Simang River

Diagram of Simang I & II projects on Simang River

Troubled Figures of EIA/EMP

In order to prepare the above diagram EIA/EMP reports of both Simang I and Simang II has been consulted. A detailed analysis of the numbers and figures mentioned in the EIA/EMPs for the river shows serious inadequacies in both the EIAs and raises questions on the authenticity of the EIA studies being done on the river.

1. EIA Wrong about Length of Simang River: It is surprising to find that the EIA studies for the two projects cannot give the correct the length of Simang River and contradicts each other (e.g. paragrapgh 4 page 1.14 of EIA of Simang I). Even though the total length of the river has been mentioned as 44 km in EIA studies of both the projects, lengths of the river over different parts do not add upto that.

The EIA report of Simang I in map of ‘Figure 1.3: Project in Simang Basin’ of page 1.16 shows that the distance between the origin of the river and reservoir of Simang II HEP is 22.27 km. The EIA report of Simang II states that the distance between barrage axis of Simang II and Simang-Siang confluence is 19.66 km (paragraph 1 page 5.2). The stretch of the Simang River used by Simang II barrage is 1.05km (from page 4.6 paragraph 1 & 2 of Simang II EIA report). If we take the total of these three parts of the Simang River, the total length of the river will be 42.98km and not 44 km.

On the other hand if we take some other figures given for different parts of the river, then we get another length for the Simang River. The Simang I EIA shows that the distance between the barrage axis of Simang II and TWL of Simang I is 15.75 km (Figure 1.3). The distance between the TWL of Simang I and it’s confluence with Siang river is given as 3.29 km. From this the total length of the river comes out as 41.31 km excluding the Simang II reservoir area. The stretch of the Simang River used by Simang II reservoir is 1.05 km. So including this total length of the Simang River is 42.36 km, not 44 km.

This is a serious inadequacy on the part of the EIA studies since the studies are not clear even about the river length across different parts of the projects. Either the EIA consultants do not know the rivers or they are fudging figures. In either case, these EIA reports should not be accepted.

2. Incorrect Assessment of River Use for the Projects The EIA reports of both Simang I and II projects gives incorrect figures for stretch of river used for the projects. The stretch of the Simang River submerged by Simang II barrage is 1.05 km (from page 4.6 paragraph 1 & 2 of Simang II EIA report), stretch of river bypassed between Simang II barrage and TWL is 7.75 km. The EIA report of Simang I states that the stretch of river submerged by Simang I barrage is 1.48 km and stretch of river bypassed between Simang I barrage and TWL is 7 km. This concludes that the total length of the river used by the two projects is 17.28 km and not 15.75 km as claimed in the EIA reports. Not giving the correct information about the stretch of the river used for projects is a major lacunae on the part of the EIAs and hence these EIA should be rejected.

3. Incorrect Assessment Distance between Simang-Siang Confluence and Power House of Simang I: It seems the EIA/EMP consultant has no knowledge of the area since the distance stated between the Simang-Siang confluence and Power House also seems to be incorrect. The Simang I EIA in states that distance between barrage axis of dam and Simang-Siang confluence is 9.34 km. It also stated that the distance between barrage axis and power house is 7 km. This leaves the distance between the Simang-Siang confluence and Simang I power house as 2.34 and not 3.29 as shown in Figure 1.3 in page 1.16 of the EIA. This again proves that the EIA report prepared by the consultant is inadequate and it should not be accepted.

4. Assessment of river length for diversion is doubtful The diverted river length for Simang II HEP given as 7.75 km in the EIA seems to be doubtful. But tunnel lengths mentioned in the same document for Simang II are as follows:

Tunnel

Length (km)

HRT

7.4

Surge Shaft

0.017

Pressure Shaft

0.225

Penstock

0.056

TRC

0.202

Total

7.9

In fact the bypassed length of the river is likely to be longer than this length of the various tunnel components since rivers do not flow in straight lines, unlike the tunnels.

Critical Issues Not Addressed by EIA/EMP The projects on the Simang River were first considered for TOR in 2008 in the 19th EAC meeting. The proposal that time was to construct three hydro electric projects (HEPs) on the river. In reply to this the EAC had asked, “Secretary  (Power)  and  Secretary  (Environment)  of  Government  of Arunachal Pradesh  should  attend  the  next meeting to clarify the reason for allotting a series of hydroelectric projects on a river which subsequently flows only through tunnels and damage the aquatic ecology.” The Power secretary and Environment secretary attended the 21st meeting of EAC. Going through the minutes of that meeting, it becomes very obvious that Arunachal with its aim to generate more revenue was ready to dam every river or stream in the state. This strengthens the impression that the Simang I or Simang II HEPs are not going to be much beneficial for the local people, environment or the state.

After going through the EIA/EMP of both the projects we have found that there are several critical issues with these studies. There are several issues which are common in both the studies and several others which are particular to each project. Reading these documents thoroughly gives a feeling that the documents don’t have much of a difference from each other and lot of ‘copy-pasting’ has been done. Some of them are also mere replications (e.g. section 4.2 page 4.7 of Simang I EIA and section 4.1.8 in page 4.6 Simang II EIA). There are also many instances where names and words have been confused, e.g. in page 1.15 of Simang II EIA, in the title of the Table 1.1 “Simang I” has been mentioned instead of “Simang II’. This kind of issues raises question on the validity and authenticity of the EIA/EMP studies done. Some of the critical issues are listed below as an example, this is not exhaustive list.

1. EAC Recommendations not Followed: The EIA/EMP studies of these projects have not followed several of the EAC recommendations. EAC in its meetings had recommended the project proponent to address several important concerns but those were no followed.

“To maintain the aquatic life, a study to be conducted by National Institute of Hydrology, Roorkee. Methodology followed for measurement of water flow to be given.” (19th EAC Meeting)  – There is no mention of any study done on environment flows. The EIA/EMP report of both the projects does not give any details of how the environment flow was measured except mentioning what will be the environmental flow.

Between dam and power house how many streams/ tributaries join and what is their contribution in turn of water in the lean season and monsoon? (19th EAC meeting) – The EIA/EMP of none of the two projects responded to this. There are no accurate details about number the flow contribution of different streams or river joining Simang.

Seismic Studies, Slope Stabilization measures, Reservoir Rim Treatment should be included in the EIA/EMP studies.  (36th EAC meeting) – The EIA/EMP studies of the two projects do not have any details of seismic studies done in the project area.

Disaster Management Plan should be included in the EIA/EMP studies. (36th EAC meeting) – This is very surprising because none of the two projects in Simang River has any disaster management plan in their respective EIA/EMP documents.

Pareng Village located in the upstream of Simang I barrage Siteand near the power house of power house site Simang II HEP. Source: EIA/EMP report of Simang I & II

Pareng Village located in the upstream of Simang I barrage Siteand near the power house of power house site Simang II HEP. Source: EIA/EMP report of Simang I & II

2. Impact of Migration of Outside Workers on Local Communities not Assessed The EIA/EMP reports estimates that there will be migration of nearly 1000 persons for each project during the peak construction period to this very sparsely populated area. People who live in this area belong to several ethnic tribal groups with unique social, economic, political and cultural values. The EIA/EMP reports do not discuss what will be the impact of such migration on the social, political, economic and cultural lives of the people. Influx of such migration will also have impacts on their human rights as well on women. The EIA/EMPs make no mention of these impacts of migration and that is why the EIA/EMP report is incomplete. Besides, even though the projects had been considered together by EAC, no cumulative impact assessment of migration was done.

3. Shoddy Socio-economic Impact Study: The property surveys which the consultant claim to have done for both these projects are inadequate and shoddy socio-economic impact assessment studies. For Simang I a property survey of project affected families in 5 villages was done but it was found incomplete since it does not take into account two of the project affected villages. On page 6A-10 of the EIA report, these 5 villages are stated as Dosing, Lileng, Pareng, Rengo and Boleng.  But out of these villages, there are only three villages mentioned in the property survey – Pareng, Rengo and Boleng. The two villages Dosing and Lileng were not found in the list and instead there were two different villages mentioned in the list – Yingku and Sine.

But after reading through the EIA study of Simang II, it becomes clear that project consultant had done only one survey for both the projects. The two villages Yingku and Sine are also found in the property survey list for Simang II EIA with the same number of affected families (page 6A-16).

It is also surprising to see how the opinions can be exactly similar for both the projects when the affected families are different for each project (See page 16A-15 of Simang I HEP EIA and page 16A-17 of Simang II HEP EIA). Besides, in the list mentioned in page 6A-17 of Simang II EIA, village named Yingku is mentioned twice but there is no justification provided for that.

This brings to light how recklessly these EIAs had been prepared. In fact, the whole concept of property survey is questionable. It takes into account very limited concerns related with the projects ignoring many serious issues. One important aspect of what is the value of the river and other common property resources for the people of the area finds no mention in the property survey. Such property survey cannot be taken as a full proof socio-economic impact assessment and hence EIA/EMP is incomplete and cannot be accepted.

4. Options Assessment not Done The EIA/EMPs of the proposed projects have not done any options assessment study. For example, the option of sub megawatt micro hydro project for a sparsely populated and pristine area like this has not been assessed. For ethnic tribal communities with small population micro hydro project is a better option. The option of solar power generation has also not been assessed by the EIA/EMPs of the projects.  Options assessment is an important part of the EIA/EMP document and since this is not done the EIA/EMP reports are incomplete and cannot be accepted.

Intermediate zone near Sine Village between barrage and power house of Simang II  Source: EIA report Simang II

Intermediate zone near Sine Village between barrage and power house of Simang II
Source: EIA report Simang II

5. Environmental Flows Assessment not Done: The EIA/EMP reports of the two projects do not give any detail of how environment flow was calculated and how environment flow will be released. We have already mentioned that in the 19th EAC meeting, EAC had suggested that in order to  maintain  the  aquatic  life,  a  study  should be conducted  by  National  Institute  of Hydrology, Roorkee and the methodology followed for measurement of water flow should be made available in the EIA. But there is no mention about any such study in any of the documents.

EIA reports of both projects mentioned about the environment flow release exercise but that should have been done already and should have been a part of the EIA. Since the EIA reports do not mention about any study done on environment flow as asked by the EAC this EIAs cannot be taken as a complete impact assessment.

6. Socio-Economic Impacts of Reduced Flow Ignored:  None of EIA/EMP reports mention about the socio economic impacts of reduced flow in the intermediate stretch between the barrage axis and power house. Besides, in questionnaire of the primary survey/property survey which the EIA consultants claim to have done, there is no question on impacts of the reduce flow of water in the river. Besides, the EIA/EMP studies do not discuss the importance of the river for the local people. This proves that EIA report is inadequate and cannot be accepted.

Power house site of Simang II HEP  Source: EIA report of Simang II

Power house site of Simang II HEP
Source: EIA report of Simang II

7. Impacts of Non-monsoon Peaking Power Generation not Assessed:  EIA/EMP reports of the two projects do not assess how peaking power generation during non-monsoon period will impact the flow in the river downstream from power house. Peaking power generation will have significant impact in the downstream since there will be sudden flow of water in the river for a short period of the day and rest of times it will remain almost dry. This sudden release of water holds threat for the people living downstream as well as their livestock. There are many instances where large number of people and livestock dying due to sudden release of water from upstream dam. Most recently, on Oct 7, 2013, one person was washed away in Arunachal Pradesh due to sudden release of water from the Ranganadi HEP.[1] Besides, this fluctuation in river water on everyday basis will have severe impacts on aquatic bio diversity of the river and use of the river by the people. EIA study ignores all these issues and that is why this study cannot be accepted as a complete study.

8. Impact Assessment of changing sediment releases not Done The EIA/EMP reports do not talk about how sedimentation will impact the reservoir. The EIAs should have included detail analysis of two main impacts – 1.Impact of changing silt flows downstream from desilting chamber and 2. Impacts of silt flushing in monsoon season on the downstream areas. The EIA/EMP report should also do a cumulative study of reservoir sedimentation because the sediment released from the upstream reservoir will affect the reservoir downstream.

9. Socio-economic Impact Assessment of Quarrying not Done:  EIA/EMP of any of the two projects on Simang does not talk about the socio economic impact of quarrying on the local people and environment. EIA/EMP reports also have not assessed how the quarrying in a fragile hill range like Eastern Himalayas will increase the risk of landslide and disaster. Ignoring the disaster risk of quarrying in the hills can have disastrous impacts and the recent Uttarakhand disaster is a proof of that. Since EIA/EMP studies ignore all these issues, they cannot be accepted as complete and that is why EIA/EMPs of Simang I and II should be rejected.

10. False Claim about Height of the Dam: The claim made by the EIA/EMP of both the projects that 18 m high dam reservoir is “very low height” is misleading and false. In the 2nd paragraph of page 10.2, the EMP report of Simang I states “Because it is a run of the river hydro project with a small barrage with very low height (18 m), the inundation will be minimized during reservoir filling.” The same claim has been made in the same page of Simang II EMP. This claim is baseless because according to international standards any dam with a wall height of 15 m or above is a big dam.

11. Climate Change Assessment Not Done EIA/EMP studies of both the projects have not done any climate change impact assessment for the proposed projects. Today when climate change impact risks are increasing day by day, it is very essential for studies like these to do an assessment of possible climate change impacts on the project as well as impacts of the projects on local climate. In fact the word “climate change” is nowhere to be found in the EIA or EMP of the two projects. Without climate change risk assessment, an environment impact assessment cannot complete and that is why this report is unacceptable.

The EIA/EMP studies should also have done an assessment of methane release from the reservoir of the project. Since these important issues are not addressed by the impact assessment study, it cannot be accepted as a complete study.

12. False Claims about Flora and Fauna The EIA/EMP of the two projects makes a completely baseless claim that “There will be no negative impact on flora of region during the operation phase.” This cannot be accepted as truth since during the construction phase of Simang I and II, the forest area diverted will be 29.86 ha and 22.02 ha respectively. After such a diversion forest,   the impact on flora and fauna is inevitable because the area is covered by dense forest. The EIA report of Simang I states that forests constitute the predominant land use in the 10 km area which was studied for this project and 67.66% of this area is covered by dense forests. Besides, none of the two EIA studies provide any data on how many trees will be cut down for the project. These are serious lacunas on the part of EIA/EMP of these two projects and that is why this report cannot be accepted as a comprehensive study.

14. Barrage Location not Clearly Stated for Simang I The EIA report of Simang I is not clear about where the barrage of proposed Simang I HEP will be located. In page 1.5 the EIA report states “The reservoir created by the barrage located near Boleng town will operate between FRL 339 m and MDDL 334 m.” But the same report in page 5.2 says “The proposed Barrage axis is situated about 9.34 Km upstream of confluence of Simang river with Siang river. The river Simang joins the SiangRiver near Boleng township.” Besides, the maps show that Boleng area is located near the confluence of two rivers not near the barrage site. This is a significant error of the EIA study and hence this study is inadequate and cannot be accepted.

Barrage site Simang I HEP Source: EIA report of the Project

Barrage site Simang I HEP
Source: EIA report of the Project

15. Simang II does not assess the project impact on Protected Area EIA states that the distance between Mouling National Park and the reservoir tail at Subbung Nala and Simang River are 5.6 and 5.7 km respectively (page 1.2, paragraph 2). Being in so close proximity of a protected area there should have been impact assessment of the project on the protected area but the EIA/EMP does not mention any such assessment.

16. Threat to Nearly Threatened Mammals The Simang II HEP is a threat to some of the endangered mammal species listed in IUCN Red List. Common leopard (Panthera pardus) and Assamese macaque (Macaca assamensis) which falls in the “Near Threatened” and Gaur (Bos frontalis) falling in “Vulnerable” category of IUCN Red List are found in the project area of Simang II. There are 13 more species of mammals falling under the “Least concern” category of IUCN which are also found in the area. This has been stated in the EIA study of Simang II.

On the other hand, the EIA study of Simang I ignores some the species falling under IUCN Red List. Rhesus macaque, Indian Porcupine and Asiatic Brush Tailed Porcupine which are found in the area fall under the “Least concern” category of IUCN Red List but the EIA report completely ignores this.

The EIA/EMP reports of the two proposed HEP projects on Simang River have significant lacunas and those cannot be ignored. The EIA consultant also had not consulted the local people in preparing the EIA report. This is another significant lacuna on the part of the EIA because it is the local people who are more aware of the local environment and river as they have lived in that place for generations.  It is shameful that on the basis of such studies and reports, public hearing for the two HEPs was held without even announcing the Public hearing dates on the AP Pollution Control Board website. If these dams are constructed on the basis of such shoddy reports and flawed public hearings then it will invite an uncertain future for the people of the area and people have to live at the risk of disaster. The EAC should consider these issues seriously and must not accept these reports. The EAC should also consider recommending the black list of the consultants for the serious lacunae in the reports.

Parag Jyoti Saikia 

(with inputs from Himanshu Thakkar)

email: meandering1800@gmail.com


[1] Man drowns in Ranganadi, body recovered – http://www.arunachaltimes.in/oct13%2007.html

One Comment on “When EIAs Don’t Know River Lengths! Review of EIA/EMP of Simang I & II HEP on Simang River in Arunachal Pradesh

  1. Simang HEP hearing subverted by Adishankar PPL

    Azing PERTIN | ITANAGAR, Oct 1: In an unprecedented conduct of public hearings for Hydro Electric Power projects in the state and the nation, the project proponent of the 66MW Simang HEP II, Adishankar Power Private Limited deliberately concealed a vital public representation submitted in the hearing and totally sabotaged it.The public hearing for the Simang II HEP was conducted under DC East Siang, Nidhi Srivastava at Rengo village under Boleng sub-division on Sep 19, and was hailed as successful and positive.
    Around 10.30am of the same day, just as the public hearing had started, Gram Panchayat Member chairperson, Tapir Tatin reached the spot to submit a public memorandum to the chairperson of the hearing. A staff of Adishankar PPL, Sunil Kumar Choudhury, who is a surveyor with the company snatched the memorandum from the hands of Tatin and hid it the whole day till the hearing was completed. Later during the same night with the incident revealed, the agitated public turned up at the company office cum guest house at Boleng and found Sunil Choudhury to be absconding. Early next morning on Sep 20, the Adishankar PPL, President, Manoj Gupta returned back the representation to the public gathered at the residence of Superintending Engineer, Hydro Power department, Taki Tatin. Then the representation was submitted to the Additional Deputy Commissioner, Boleng, Taro Mize, whose response is still awaited.
    The representation which was to be submitted at the public hearing has been signed by 44 villagers and 6 panchayat members including all the Gaon Burahs of Sine village. The five point representation letter addressed to the Member Secretary, Arunachal Pradesh State Pollution Control Board categorically rejects the Simang II HEP, stating concerns on submergence of land and Wet Rice Cultivation fields, adverse impacts of quarrying due to the project in the area, drying of the Simang river and loss of grazing areas for livestock. It also appealed for taking up the concerns to the Ministry of Environment and Forests (MoEF) at New Delhi.
    The incident has raised serious concerns on the rights of the indigenous people of the state and the tactics used by the power companies to subvert the vital public hearing. The very essence of a public hearing has been violated by the concerned authorities, as it is the sole instrument by which the local affected people of a project can voice their concerns and reject or agree to a project in their area. Moreover, the Forest Rights Act 2006 which plays a crucial role in emphasizing the rights of the local tribals for making decision of their indigenous resources through the local panchayat has been totally bulldozed in the Simang II hearing. The representation was a genuine one of all the concerned panchayat leaders of the village with signatures of the Gram Panchayat Members and Anchal Samiti Member. On the contrary, State Pollution Control Board, member and also the All India Union of Forest Working People, president, Jarjum Ete is of the opinion that, in Arunachal the state is using FRA only for clearing projects as MoEF has made it mandatory to get clearances from Gram Sabhas, while the conventional ownership is being impinged by the state.
    Elsewhere, taking serious note of the incident, the Siang Peoples Forum, a local indigenous rights group has submitted complaints to the State Pollution Control Board for nullifying and cancellation of the public hearing conducted on Sep 19. Decrying the act of the company staff, SPF president, Ojing Tasing, said, this is the first instance that the deceit and unfair means adopted by the power companies in the state to fool the naive and gullible people has surfaced and shown its hideous motives. We will take it up with the MoEF, National Green Tribunal and to all concern for getting justice and rights of the indigenous people of the area, added Tasing. Further, he added that the ADC Boleng has not acted and turned a blind eye to the complaint submitted by the Sine villagers due to the political affiliations and personal vendetta. In the recently concluded panchayat election, the wife of the ADC had contested with an INC ticket for the ZPM seat in the area and lost with almost no vote from Sine village.
    In the lopsided local political milieu of Boleng area and generally in the entire state, the wholesome local support for the power projects might have made the Adishankar PPL staff to take the radical step. Unassumingly, the local MP and also the Union Minister of State for Minority Affairs, Ninnong Ering had also intensely advocated for early conduct of the public hearing of the Simang I and Simang II in the recent past, while it is no secret that local MLA Boleng-Pangin and Minister Industries, Tapang Taloh has always been loggerheads with the local people fighting for indigenous rights by opposing big hydro projects in the area. Natural justice calls for nullifying and cancelling the public hearing as per the accounts of the incident, but former examples illustrate that the babus in the state will wait till a court ruling or a high level order reaches from New Delhi.

    Published in Echo of Arunachal (http://www.echoofarunachal.com/?p=41110)

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