Cumulative Impact Assessment documents not in public domain anymore? Letter to MoEF and CC

Even as the Ministry of Environment, Forests and Climate Change has been sanctioning cascades of hydropower projects on here-to free flowing rivers in the Himalaya and North East India, Cumulative Assessment of the Impacts of these projects became a crucial area of concern. Over 70 dams are planned one after other for the rivers of the Upper Ganga Basin, 44 dams across the Siang Basin in Arunachal Pradesh famed for its pristine forests and biodiversity, 12 dams across the Lohit Basin, 19 for Subansiri basin. These are bumper to bumper projects, one starting where the other ends.

The cumulative impacts of these projects on the hydrology, downstream flow, sudden water releases, deforestation, muck disposal, influx of migrant workers, seismicity of the region, etc., is huge as compared to individual impacts. The projects together stand to change the social and ecological fabric of these regions. Cumultive Impact Assessment (CIA) studies are a part of the Environment Impact Assessment Process under the EIA Notification (2006) and Environment (Protection) Act 1986. The documents of these CIAs have been uploaded on the Environment Clearance website in the past, as was required under number of laws. However, as the EAC is slated to consider whopping 4 CIAs in its upcoming meeting on the 8 and 9th Feb, not a single CIA-related document is available on the MoEF and CC website! We are told that these may not be made available in the future.

Amidst news like these Why Narendra Modi Govt needs to be transparent with its Environment Policy‘, such non-transparency does not bode well. In fact, the Prime Minister was at the iconic trijunction of Dibang, Siang and Lohit Rivers in Assam TODAY (Feb 5, 2016), where Brahmaputra takes shape. It is here that Cumulative Impact Studies are most critical and are used by masses. The PM says that the government is for “Sabke Saath Sabka Vikaas”. But where is the possibility of Sabkaa Saath if crucial information which can impact lives of millions is to be kept hidden?

A number of individuals and organizations have written to the MoEF and CC against this opaqueness today. See letter below:

February 5, 2016

To

  1. Shri Prakash Javadekar

Union Minister of State of Environment, Forests and Climate Change (I/C) pjavadekar@gmail.com, vinay.s@gov.in (PS)

  1. Shri Ashok Lavasa,

Secretary, MoEF&CC,secy-moef@nic.in

  1. Shri Bishwanath Sinha,

Joint Secretary, MoEF&CC, bnsinha@gov.in

Copy to:

  1. Dr B B Barman, Dir.-MoEF&CC & Member secretary of EAC – RVP & HEP Projects
  2. Chairman and members of EAC for RVP & HEP Projects

URGENT Subject: Non transparency in functioning of Expert Appraisal Committee for River Valley Projects: Agenda documents related to Cumulative Impact Assessment studies

Dear Sirs,

The next meeting of MoEF&CC’s Expert Appraisal Committee for River Valley & HEP Projects is to take place on Feb 8-9, 2016 and it has four agenda items for discussing the Cumulative Impact Assessments (CIAs) and Carrying Capacity Studies (CCS) for Dibang, Kameng basins in Arunachal Pradesh and Chenab and Sutlej basins in Himachal Pradesh. The Agenda can be seen at: http://environmentclearance.nic.in/writereaddata/Form-1A/Agenda/2016_2_2111122412121CopyofCopyofRV&HEPAgendaforthemonthofFebruary,2016.pdf. These agenda items were not part of the Agenda that was put up on January 21, 2016, but were added much more recently.

However, none of the draft CIA and CCS are available in the public domain on the Environment Clearance website of the MoEF&CC (http://environmentclearance.nic.in/). We understand that this has been the recent decision of the Ministry not to put these documents on the website. This is a clear departure from the past practice and clearly against the basic principles of transparent, participatory and democratic process.

Availability of these documents in public domain at least two weeks before the scheduled meeting of the EAC is crucial for all concerned to be able to study these document and share their views about the adequacy or otherwise of the studies with the EAC. By not making the draft reports available in public domain, the Ministry is clearly trying to negate this informed participation of all concerned in this process.

In fact the order from Central Information Commission (Decision No. CIC/SG/C/2011/001398/16936 in Complaint No. CIC/SG/C/2011/001398) dated 18.01.2012 specifically directed that all documents related to the EAC agenda must be in pubic domain, also required under Section 4 of RTI Act 2015 and specifically directed, “This order is prospective and will apply to all documents received by the Ministry from March 2012 onwards.” Not putting these documents in public domain in advance of the EAC meeting is thus also in violation of the CIC orders.

You will agree that CIA and CCS are very important part of the decision making about the river basins and projects in river basins. In the past the studies have left a lot to be desired and following inputs from many of us and others, the EAC has asked further work and studies in the CIA and CCS. In many cases, the project decisions and parameters have been changed following CIA and CCS Process and hence in the EC process under EIA notification, CIA and CCS are important studies.

Conditions of environment clearance also stipulate that the clearance is subject to the final CIA / CCS. It is hence also imperative that public participation in the approval of CIA and CCS is ensured.

The EIA notification of September 2006 specifically mentions CIA in section 9. The MoEF&CC Office Memorandum of May 28, 2013 about need for CIA and CCS also is crucial in this process. That OM was brought out in the context of EC process and clearly mentions how the EAC functions under specific statue and CIA-CCS are part of this process. In view of both, even under EIA notification, not putting up the draft studies in public domain would be in violation of the notified process.

In fact we have been urging the MoEF&CC to hold public consultations on CIA-CCS before they are considered by the EAC. This need flows directly from the EIA and EAC process and MoEF&CC needs to urgently make this mandatory. This is also fundamentally essential for transparent, participatory and democratic process.

We hence urge you to ensure that the draft CIA-CCS reports should be available in public domain at least two weeks before the EAC meeting and the agenda related to the CIA-CCS for the February 8-9, 2016 meeting be postponed till they have been made possible

We will look forward to your urgent attention and response on this.

Thanking you,

Yours Sincerely,

  1. Himanshu Thakkar, South Asia Network on Dams, Rivers & People, 86-D, AD block, Shalimar Bagh, Delhi 88 (ht.sandrp@gmail.com)
  2. Akhil Gogoi, Advisor, Krishak Mukti Sangram Samiti, Assam,
  3. K K Chatardahara, Peoples Movement for Subansiri and Brahmaputra Valley Gogamukh, Dhemaji, Assam
  4. Dr. Bharat Jhunjhunnwala, Uttarakhand
  5. R S Negi Himlok Jagriti Manch, Recongpeo Kinnaur, Himachal Pradesh,
  6. Shanta Kumar, Hangrang  Sangarsh Samiti, , Kinnaur, Himachal Pradesh
  7. Subodh, Tabo, Spiti, Himachal Pradesh
  8. Vinay Negi, Karcham Wangtoo Sangarsh Samiti, Kinnaur, Himachal Pradesh
  9. Jiya Lal, Zila Vandhikar Sangarsh Samiti, Kinnaur, Himachal Pradesh
  10. Nek Ram, Satluj Bachao Sangarsh Samiti, Karsog, Mandi, Himachal Pradesh
  11. Prakash Bhandari, Himdhara, Palampur, Himachal Pradesh
  12. Samir Mehta, River Basin friends, Mumbai
  13. Vimalbhai, Matu Jansangthan, Uttarakhand
  14. Malika Virdi, Himal Prakriti, Uttarakhand
  15. E Theophilus, Himal Prakriti, Uttarakhand
  16. K Ramnarayan, Himal Prakriti, Uttarakhand
  17. Parineeta Dandkear, SANDRP, Pune
  18. Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune
  19. Manoj Misra, Yamuna Jiye Abhiyaan, Delhi

SANDRP’s comments on past CIA’s

  1. Siang Basin Study: https://sandrp.wordpress.com/2014/02/18/cumulative-impact-assessment-study-of-siang-basin-in-arunachal-needs-urgent-improvement/
  2. Comments on the CIA Process, with a focus on Subansiri: https://sandrp.wordpress.com/2015/01/05/is-government-at-all-serious-in-addressing-the-issues-raised-by-movement-against-the-lower-subansiri-hydropower-project/
  3. Subansiri Basin Study: https://sandrp.wordpress.com/2013/09/25/subansiri-basin-study-another-chapter-of-environment-subversion-in-northeast/
  4. Lohit Basin Study: http://sandrp.in/rivers/Lohit_Basin_Study_by_WAPCOS_A_mockery_of_e-flows_and_cumulative_impacts.pdf
  5. Chenab Basin Projects: http://sandrp.in/hydropower/Dams_on_Chenab_How_many_are_too_many_Dec2012.pdf
  6. IIT Roorkee’s Cumulative Impact Assessment of Upper Ganga Basin Projects: http://www.sandrp.in/hydropower/Pathetic_Cumulative_Impact_Assessment_of_Ganga_Hydro_projects.pdf
  7. WII’s Cumulative Impact Assessment Study on Upper Ganga Projects:http://sandrp.in/hydropower/WII_Cumulative_Impact_Assessment_of_Ganga_hydel_projects_A_small_step_and_a_long_way_to_go.pdf

One Comment on “Cumulative Impact Assessment documents not in public domain anymore? Letter to MoEF and CC

  1. Pingback: Transparency in environment governance? Expert Meeting on River Projects does not have documents in open domain – COUNTERVIEW.ORG

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