Public Pressure Leads to Changes in Kerala Dam Operation

Kerala Govt Agrees to Change Operation of Chalakudy River Hydropower Project:

Public Pressure Leads to Changes in Dam Operation

The decision to increase off-peak generation at Poringalkuthu Left Bank Hydro Electric Project (PLB HEP) in Chalakudy River, taken at a meeting convened by the Hon Chief Minister of Kerala in the fourth week of April (PRD – Thrissur, 25-04-13) was a partial success to the sustained campaign for dams re-operation at Chalakudy river. The meeting was attended by the Ministers for water resource and power, River Basin MLAs and officials of state electricity board and irrigation department. The decision however falls short of the demand for reverting the operation of PLB HEP into base load.

Chalakudy River Basin Physical Map

Chalakudy River Basin Physical Map

Normaly the summer water availability in the river below Poringalkuthu HEP should be between 1.3 – 1.5 MCM / day. The failure of both monsoons in 2012 and violation of Kerala-Tamil Nadu interstate Parambikulam – Aliyar agreement (1970) condition that the Kerala Sholayar reservoir shall be kept at full reservoir level by Tamil Nadu on the 1st of February every year (Sch. II.3 – PAP Capture 1Agreement), reduced the water availability in 2013 summer to less than 1 MCM per day resulting in severe water stress in the river basin. On top of the water shortage, intra-day as well as inter-day flow fluctuations in tail-race discharge from PLB HEP had worsened the situation. Anticipating water shortage the river basin MLAs as well as Local Self Government (LSG) heads had been demanding action from the State Government since December 2012.

Background: The river – dams and flow regime Chalakudypuzha (ChalakudyRiver), the fifth largest river in Kerala with a length of 144 kms and catchment area of 1704 Sq.kms is one of the heavily utilised rivers in the state. Major tributaries of this west flowing river originate from the Anamalai hills, Parambikulam Plateau and Nelliyampathy hills of Southern Western Ghats. The river/ its tributaries have been dammed at six places. The dams and diversions have completely altered the natural hydrological regime in the river. The river is the life line of about 30 Local Self Governments (LSGs) and about ten lakh people. Apart from the dams and diversion structures, numerous drinking water schemes and lift irrigation schemes are also dependent on the river. The table below provides details of existing major projects on the river.

Existing dams/ diversions in Chalakudypuzha

Sl. No. Project Commissioning Year Purpose Storage MCM Developer
1 Poringalkuthu LB HEP 1957 Hydro Power 32 Kerala SEB
2 Thunakadavu (PAP)* 1965 Diversion 15.77 Tamilnadu
3 Kerala Sholayar (PAP) 1966 Hydro Power 153.49 Kerala SEB
4 Parambikulam (PAP) 1967 Diversion 504.66 Tamilnadu
5 Peruarippallam (PAP) 1971 Diversion 17.56 Tamilnadu
6 TN Sholayar (PAP) 1971 Hydropower + diversion 152.7 Tamilnadu
7 ChalakudyRiver Diversion Scheme 1959 ** Irrigation 0,218 Kerala-Irri Dept
8 Idamalayar Augmentation Scheme 1990s Diversion NA Kerala SEB

*PAP- Parambikulam Aliyar Project    **Partially operational since 1952

Almost 75 percent of the catchments of the ChalakudyRiver were forested at the turn of 20th century. Hence the river had a fairly Capture 2healthy flow even during summer months. However, at present, the natural summer flow in the river has reduced drastically due to forest degradation and dams and diversions. Consequently, the present river flow in non-monsoon months is almost entirely dependent on the storage at Kerala Sholayar and Poringalkuthu reservoirs. The downstream major irrigation project, the Chalakudy River Diversion Scheme (CRDS) does not have storage of its own. It is completely dependent on the tailrace discharge from the PLB – HEP. Over the last two decades, the daily flow fluctuation due to the semi-peaking operation of the PLB-HEP is affecting the functioning of CRDS. Incidentally, the campaign against the proposed Athirappilly hydroelectric project (AHEP) had first brought this issue into focus. One of the major issues with regards to AHEP, a peaking power station, was the downstream impacts of drastic intra-day flow fluctuation (to the tune of 1:17).

Incidentally, Western Ghats Ecology Expert Panel had recommended not to give clearance to the project after conducting field visits and detailed and transparent consultations. However, the High Level Working Group formed to look into the WGEEP report acted in a non-transparent manner. They conducted a field visit with the project proponent (The Kerala State Electricity Board – KSEB), without informing the public, press or the Grama Panchayath and not providing opportunity for the organisations opposing the project to present their case before the committee. The HLWG recommended that the project proponent can approach the Ministry of Environment and Forest (MoEF) for fresh clearance, if it so desired, after some studies despite identifying the project location as ecologically sensitive area.

Analysis of hydrological data for AHEP as well as debates on the issue revealed the existing flow fluctuations due to changed operation pattern of PLB HEP since early 1990s. As the capacity of the PLB HEP was enhanced from 32 MW (8 MW X 4) to 48 MW with the commissioning of a 16 MW generator in 1999, the peak generation and the resultant flow fluctuation increased. The field assessment in the CRDS command area had confirmed the impacts due to the flow fluctuations.

As part of an action research done by the Kerala State Centre of Forum for Policy Dialogue on Water Conflicts in India, an attempt was made to find possible solutions to the conflict of interest between power generation and downstream needs. The conflict between CRDS and other downstream uses due to total diversion of water at its head works at Thumboormuzhi was also taken up. An alternate reservoir operations management (ROM) strategy that aims at sustainable and equitable sharing of available water resources was prepared as part of the study. Capture 3

ROM strategy for Chalakudy River The ROM strategy tried to synchronise the operations of Kerala Sholayar and PLB HEPs with the downstream requirements. Secondary data regarding the river flow, rainfall etc. was collected from concerned agencies like KSEB, Water Resources Department etc. Issues with respect to the present flow regime were assessed through field surveys and stakeholder consultations.  After analysing the available data and assessing downstream irrigation needs through people’s perception and based on the suggestions/ comments by the experts, the draft reservoir operations strategy was prepared. ROM strategy is attempted for water available to the basin after diversions to Tamil Nadu and Idamalayar with focus for non-monsoon months.

In the proposed ROM strategy, the summer water availability for the downstream needs is suggested to be increased through modifications in the operation pattern of Kerala Sholayar and Poringalkuthu HEPs. At Kerala Sholayar, the total utilisable quantity of water is fixed as per the PAP agreement. The monsoon discharge is proposed to be reduced by about 15 % of the average flow (data period – 1979 to 2006) so that the non-monsoon water availability can be enhanced. At Poringalkuthu, the ROM strategy proposes that the water level in the reservoir shall be kept at close to the full reservoir level up to the end of January. The change in the operation of the two HEPs is expected to ensure water availability of not less than 1.5 MCM/ day for the downstream uses. The ROM strategy proposes to operate the Poringalkuthu HEP, the lower dam, that discharges water into the main river as a base load station (as it was operated before 1990s) in non-monsoon months. This can ensure a steady discharge of over 17 m3/sec.

Peringal Dam Photo: CPSS

Peringal Dam
Photo: CPSS

At present the entire flow reaching Thumboormuzhi weir, the head works of CRDS is being diverted to the canals, except for some overflow during peak hours. This is affecting the downstream areas including the ecological functions of the river. The ROM strategy proposes a minimum flow of not less than 2 m3/sec to be released from Thumboormuzhi weir in to the river. This may be increased later after improvement in natural summer river flow through eco-regeneration of the upper catchments and by reducing the irrigation demand through adoption of ‘more crop per drop’ approach in the CRDS command.

The revised operation pattern is not expected to have significant impact on the power front. The non-monsoon power generation from the river basin is expected to slightly increase, whereas, the peak power generation will be reduced by 8 MW to 16 MW, which is about 0.25-0.5 % of the present summer peak demand of Kerala of about 3400 MW.

Building public awareness and public pressure The ROM strategy was widely discussed with the LSGs and other stakeholders. As the LSGs, farmers and Irrigation and Agriculture departments were active partners in the action research (2008 – 2012) they Capture 4readily accepted the proposed ROM strategy. Many LSGs demanded the state government to implement this, through resolutions. With the shortage in rainfall during 2012 monsoons, severe water stress was anticipated and a series of steps were taken to put pressure on the state government for dams re-operation so that the summer water shortage for downstream areas can be reduced.

  • A meeting of the LSG representatives organised by Chalakudy Puzha Samrakshana Samithi (CPSS) before the start of irrigation season discussed the anticipated scenario for the 2012-13 season and decided to step up campaign for changing the operation pattern at PLB HEP.
  • The project advisory committee meeting of CRDS, in December 2012 also took a similar decision.
  • In December 2012, five MLAs of the ChalakudyRiver basin, cutting across party lines, jointly demanded the Chief Minister to convene a meeting of the concerned ministers, MLAs, LSG heads and officials to discuss the issues with regards to the summer water availability in the river basin. This was the result of a series of interactions with these MLAs by the CPSS team.
  • In the second week of January 2013, 25 LSG heads gave a submission to the CM demanding action by the government to ensure water availability at Kerala Sholayar as per the PAP agreement and changing the Poringalkuthu HEP to base load station.
  • Even as no action was taken by the state government and the situation was becoming grim, the project advisory committee meeting of CRDS decided that a delegation must go to Thiruvananthapuram and meet the CM and other concerned ministers. A meeting of LSG heads organised jointly by CPSS and Chalakudy basin Block Panchayaths also decided to take necessary actions.
  • On March 19th 2013,   four MLAs and 10 LSG heads from ChalakudyRiver basin met the Chief Minister and Minister for Water Resources. Rajaneesh from CPSS was also part of the team. The people’s representatives wanted the Govt to take necessary steps to ensure better water availability for Chalakudy basin. The main points raised were regarding violation of Parambikulam – Aliyar Agreement condition and ensuring steady flow from Poringalkuthu HEP for the downstream needs. The CM agreed to convene a meeting of all concerned immediately. However, the meeting was delayed by more than one month and when the meeting finally took place, the LSG representatives were not invited for the same.
  • Meanwhile a detailed discussion was held with the KSEB Chairman in the first week of April 2013. The Chairman promised to look into the issue.
  • All along the campaign, the print as well as visual media reported these developments and published / telecast stories on the issue.

Partial re-operation The daily average generation at Poringalkuthu in January 2013 was 0.4481 MU (Million Units, as per Kerala State Load Despatch Centre website) and the corresponding discharge was about 1.2 MCM per day. Due to the non-compliance of PAP agreement condition, the combined storage at Kerala Sholayar and Poringalkuthu reservoirs on the 1st February was only around 115 MCM against an anticipated volume of 160 -170 MCM. Consequently, the generation was less in the following months. The average generation and discharge in February, March and April were 0.3457 MU / 0.93 MCM, 0.3237MU / 0.87 MCM and 0.3343 MU / 0.9 MCM respectively. The semi-peaking operation at PLB HEP continued resulting in intra-day fluctuations. The off-peak generation was mostly limited to 8 MW with a corresponding discharge of around 6.5 m3/sec, which is highly insufficient to meet the irrigation demand of the CRDS command. There were also instances of practically no generation during off-peak hours, especially during night times.

Upper Sholayar Dam Photo: CPSS

Upper Sholayar Dam
Photo: CPSS

Apart from the intra-day fluctuation the inter-day flow fluctuations was also a major cause of worry. The situation was particularly bad in the second half of March and first half of April. On 4 days between March 21st and April 10th, the generation was between 0.158 MU and 0.182 MU. The corresponding discharge was less than 0.5 MCM. On a few other days, the generation was between 0.2 -0.3 MU.

Since the decision of the meeting convened by the CM, the situation has slightly improved. The inter-day fluctuation was less since 25th of April with the discharge of 0.9 -1 MCM on most days. More importantly, the off-peak generation was at least 16 MW (except on a couple of days). The average discharge since the last week of April has also slightly increased in comparison to the previous months.

The change in operation pattern does not seem to have had any negative impact on power front. Initially the KSEB had increased off-peak generation without reducing peak generation. The generation figures as per the SLDC website shows the generation at PLB HEP on 25th, 26th and 27th April (after the decision at Ministry level meeting) as 0.425 MU, 0.402 MU and 0.412 MU respectively, corresponding to discharge of around 1.1 MCM. Later only one machine was available and the peak as well as total generation reduced.  The average generation during this period was around 0.35 MU corresponding to a discharge of about 0.95 MCM. The generation figure shows that the station was running continuously as a base load station (by default?) for two weeks. Even though the rate of discharge was less than the actual requirement, we have requested the irrigation officials to assess the effect of steady inflow at CRDS.

The decision for increasing off-peak generation is significant since it is acknowledgement by the government that the downstream requirement should be given priority over power generation. However, the long delay in taking such a decision even after the river basin MLAs and LSG heads unanimously demanded for the same cannot be justified. Also, the steps taken so far are not sufficient. The storage position as on 27-04-2013 at Kerala Sholayar and Poringalkuthu reservoirs (33.78 MCM and 9.23 MCM respectively) could have supported a daily discharge of upto 1.3 MCM till May 31st, especially since the catchments traditionally get good pre-monsoon rains and an inflow of 100 cusecs from Tamil Nadu Sholayar was anticipated, on the basis of inter-ministerial discussion on PAP agreement.

The campaign / advocacy for further changes in operation will have to be continued as the present decision is of a temporary nature. Until and unless the non-monsoon discharge from Poringalkuthu HEP is enhanced to around 17 m3/ sec, sufficient river discharge from CRDS head works is not likely to materialise. (The suggested discharge rate from Poringalkuthu HEP as per the ROM strategy, based on anticipated water availability, is 17.25 m3/ sec and the corresponding generation will be 24 MW.) The fact that the Chalakudy MLA protested against closing down all generators of old powerhouse together since May 7th shows that the people’s representatives are now more vigilant on the issue and this should help in stepping up the campaign. Moreover, a collective of Local Self Government heads is emerging for the cause of the river and this collective, if it becomes active, can really help take forward the efforts for the revival of ChalakudyRiver.

S P Ravi (

Uttarakhand Floods of June 2013: Curtain Raiser on the Events at NHPC’s 280 MW Dhauliganga HEP

box 2Days after walking down the Gori, we go to the Sub-Divisional Magistrate of Dharchula sub-division, Pramod Kumar, who is busy coordinating rescue and relief on a war-footing, but still has the courtesy to meet. On being asked by me regarding the sudden release of water by the 280 MW National Hydro-Power Corporation (NHPC) Dhauliganga Hydro-Electric Project (HEP, see below the layout of the project given on NHPC website) at Chirkila and the ensuing damage downstream, he confirms that he received an emergency call on the night of 16th June, 2013 from the NHPC, asking that they be permitted to release the impounded water in their reservoir, because it was in danger of breaching. Under normal circumstances they do not need his permission. He also confirms that he had refused, because the water level in the Mahakali main-stem was already flowing at danger-mark. NHPC went right ahead and opened their gates at full on the night of 16th June, without authorization or any prior warning to anybody[1] but their own office-residence complex 20 km downstream, at Dobat.

Map of Dhauliganga Dam Source: NHPC

Map of Dhauliganga Dam
Source: NHPC

Was this really an emergency, or was this purely opportunistic on the part of NHPC to take this opportunity early in the season to flush their reservoir that had been filled almost to half with bed-load and silt? We went looking for clues and information. I went to the NHPC office complex at Dobat, and met Bhuvan Chand Joshi, their Public Relations Officer. After giving me the spiel on how safe, and how green this so called run-of-the-river (ROR) project was, constructed by no less than the Japanese, the Germans and the Koreans put together[2], he admitted that their underground power-station was entirely flooded. Housed in a gigantic underground cavern about 100 meters long, four-storeys high at 40 meters and about 16 meters wide, river water had filled it right upto the control-room on the fourth floor. I had already been told by Kesar Singh Dhami, taxi owner of Dharchula, that on the 16th June itself, when he was ferrying the first batch of Kailash yatris to the road-head on their way up to Tibet, he had noticed the reservoir was filled high already with flood-waters, with large uprooted trees and other woody debris floating at the damsite. He confirms that water was being released, but only a small release, despite the dam being fuller than he had ever seen it.

I was also told by another employee of NHPC (who did not wish to be named) that what had gone wrong was that despite the high flows on the 15th and 16th June, the power-station continued with production of electricity as usual. In what seems to be an unbelievably short-sighted and poor design, the Tail-race Tunnel, from where water is released back into the river after having turned the turbines, is flushed into a tributary stream, the Ellagad. It was when Ellagad also pulsed, that it sent a train of bed-load debris down its lower reaches, effectively blocking the exit of the Tail-race Tunnel coming out of the powerhouse. The power house continued to take in water from the Head-race Tunnel intake to work their turbines, unaware that the exit for water had been blocked. It is only when the water blocked in the Tail-race Tunnel surged back up, burst through the turbine units and began flooding the powerhouse, that NHPC even know that something was wrong. It was then that the massive curved steel gates of the intake were slid shut, and the powerhouse evacuated. This was further confirmed by Joshi, PRO, who also said that the ‘matter was under investigation’ by their own team for organizational detail. The General Manager and the Chief Engineer of the Dhauliganga HEP had meanwhile been transferred out. It is not clear yet how soon after the powerhouse was flooded, that they opened the sluice gates at the bottom of the reservoir. Draining it was clearly beneficial for NHPC, but catastrophic for roads, bridges and habitations downstream, both in India and Nepal.

Dhauliganga before the disaster, with zero water flow downstream from the dam, killing a perennial river. Source: Author

Dhauliganga before the disaster, with zero water flow downstream from the dam, killing a perennial river. Source: Author

If you look closely enough, there are two separate events here. The flooding of the powerhouse, and the ’emergency’ release of reservoir water. The powerhouse was not flooded because of too much water in the reservoir, but because it was in operation when its tail-race exit seven km downstream, is blocked-off because of poor short-sighted design[3]. They are then forced to close the gates of the intake, and abandon the powerhouse where water has reached the control-room on the fourth floor. The intake gates are now shut, but the flood waters continue to fill the reservoir further. They have already allowed the dam fill to a very high level, and here is the other curious factor.

The design of the Dhauliganga dam, is such that the dam has no provision for water to ‘overflow’ the dam safely, should undesired (even if foreseeable) levels be reached as they did this year. Or say if giant boulders block the narrow sluice gates at the bottom of the reservoir. Or in the real-time situation of what actually happened this year, the blocking of the tail-race tunnel leading to flooding of the powerhouse, hence requiring the shutting off of the intake, and losing the option of reducing reservoir levels more gradually and safely through two simultaneous releases. They then open the flood-gates. Clearly, one of two things have led to this decision:

One, letting the reservoir fill to a very high level is not out of the ordinary for NHPC; they do it every monsoon, as they had done on 16th June as well. It is not for many months in the year that they have enough water to run all four turbines. Despite the run-of-the-river label, Joshi confirmed that they were unable to let any water to continue to flow un-diverted in the river-channel during the winter-spring months (we have photographic evidence of this as well), or they would not have water to turn even one turbine! The mandatory requirement that every hydro-power dam in Uttarakhand be required to release at least 10% of the river’s minimum flows at all times (as greatly insufficient as such a small flow is for downstream life), it seems neither a consideration while justifying the economics of such projects, and neither is it complied to here. The use of the term run-of-the-river here, is plain deception.

The Dhauliganga Hydro-power dam, after being flushed of bed-load sediment Source: Author

The Dhauliganga Hydro-power dam, after being flushed of bed-load sediment
Source: Author

Their regular annual schedule for flushing the reservoir of bed-load and sediment is normally the 15th of July and the 31st of July every year. Here again, when the reservoir is full, and there is enough water to provide the pressure for increased and accelerated flow to flush the reservoir on a twice-annual basis. Both flushing schedules follow each other closely at peak-flow season, so that the flushing is as complete as possible, and there is enough of a monsoon season ahead to fill the reservoir up again before the winter-lean. The probable reason for preponing the flushing could be the chance of flushing some of the unusually high accumulation of bed-load debris that had come down in this years flood. What this meant to the efficiency of the power-station is one thing, but what it means to all life in and along the river, is quite another.

Two, that the faulty design of the dam, both in location of its tail-race exit as well as no provision for over-topping, in combination with the carelessness of allowing the reservoir to fill to such levels at the start of the monsoon, was responsible for the ’emergency’ catastrophic release.

Stitched photo of the bed of the drained Dhauliganga reservoir  Source: Author

Stitched photo of the bed of the drained Dhauliganga reservoir
Source: Author

The Dhauliganga HEP is located on the Darmayangti river, re-christened the Dhauliganga  river, just a couple of kilometers upstream of the confluence with the Mahakali at Tawaghat. In these two kilometers, the rivers flows (twice a year when it is allowed to, for a few hours) down steeply to the confluence which it meets at right-angles. With the Mahakali already in spate, coupled with the sudden release of more than 6 million cubic meters of stored water (Gross Storage Capacity), plus the flow of the river in flood (steadily increasing from 398 cubic meters a second on 15th June), as well as millions of tonnes of bed-load boulders and sediment, the damage downstream is clear to see. If you look at the fresh scour-level on the banks downstream of the dam, it is in places more than 15 meters higher than the flood-level flow of the DhauliRiver. The river added thousands of tonnes of even more debris when, because of the flood level it reached, it tore through, plucking high at the talus-cones on either bank, and at every turn. At the confluence at Tawaghat, there must have been something of a back-flood for some time (a common flood phenomenon where the high-flowing main-stem creates a temporary water-dam), because the water-level seems to have risen very high, taking away the bridge that connects the entire Kuti valley and the trade route to Tibet,   tearing away almost the entire village-market complex at Tawaghat, and destroying the road as well. The flood waters had clearly reached the top of the road because of the deposition of river-sand on it. When I walked this section days later, the river was only less than a meter below danger mark. Even so, it was flowing about 12 meters below the road! Further downstream, the destruction was more serious.

In order to understand the magnitude of this flood event, I ask Joshi of NHPC for flow-data of the Dhauli river between the 12th and the 18th of June. He goes off for some time and returns with a sheet of paper that has hand-scrawled 6 hourly flow volumes from 12th June, but stops short at 15th June. All the flow volumes between the 12th and the 15th were below 150 cubic meters a box 1second (cumecs), and at 12 am, on the night of the 15th June it jumps up to 389.92 cumecs. This is just the start of the flood. Joshi seems to balk right here, and says that they have not received data for the 16th June yet (the day I speak to him was the 8th of July), and that he may get it after a week or so. And anyway, he says, the powerhouse was abandoned from the night of the 16thJune, so getting data beyond that would be out of question. It is clear that Joshi was unwilling to give me flow-data for the duration of the flood-pulse. He had only minutes before informed me of how automated the whole operation was, and that it was possible for them to even operate the power-house sitting in their Dobat office-complex itself. The real scenario will be clear when we get flow data for the 16th and 17th of June.

According to NHPC, the Peak Flood Design for the Dhauliganga HEP is 3,210 cumecs, at a return interval of 100 years. That is the flow volumes that the dam is designed to be able to take without damage, at flood levels expected at least every hundred years. It is unlikely that flow volumes had reached almost 10 times the flow volumes of the flood on the 15th June at the damsite (389.92 cumecs). NHPC gets its flow data from an automated level-gauge at the reservoir, so it did not require anyone to take readings manually, even prior to abandoning the station. If unprecedented levels had indeed been reached, then why had they held on to water in the reservoir right till the night of the 16th June?  Please see the accompanying photographs, of the dam reservoir, empty of water. You can see at least two levels of cut-away terraces. The lower ones are alluvial terraces, consisting clearly of coarser gravels and cobbles deposited by the flowing river. The higher terraces, more visible high on the upper true-left bank in the photo, are remnant lacustrine (lake-bed) terraces, consisting of finer silts and sand, deposited by the stilled waters in the reservoir when it was full. This was the highest point of sediment accumulation in the reservoir prior to being flushed out. Clearly, at least 45% the reservoir was full of debris and sediment before NHPC flushed it. And if you look at the brown line on the concrete face of the dam, you see the level that the reservoir was allowed to fill upto, marked by the ‘bath-tub ring’ of floating bark and woody debris stuck there after draining.

Joshi tells me that when a delegation of people from Nepal came to NHPC to talk about the possible role that NHPC’s sudden release of water might have had on the flood that devastated Khalanga bazar at Darchula, he had told them that to the contrary, the dam had saved Nepal from great damage. “See how much debris is still behind our reservoir!” This was bare-faced misinformation. There are two aspects being denied here. One, that great masses of debris were actually flushed out from the lower-end of the reservoir on the night of 16th June, leading to greatly increased flood levels as well as erosive potential downstream, especially on the Nepal bank at Darchula, which bore the brunt of flushed debris centrifuged on the curve. As is evident from the photo of the dam-site above, most of the debris that has been flushed, is from the front-end of the reservoir only. And two, that all dams and reservoirs, despite some being able to flush out debris from a section of the reservoir, do actually hold back a great deal of bed-load as well as suspended sediment in the upper end of the reservoir. They impede the very essential flow of sediment down to the oceans. Look now at the geometry of bed-load debris in the stitched photo. Distortions from the wide-angle lens apart, it clearly shows a gradual slope, and a filling up of the bed-rock channel to form a wide, sloping flood-plain. Had it not been for the dam, the bed-load would have continued to fill up the bed-rock channel downstream at about the same angle, slowing the entire flow of water and entrained debris. It would not have been washed down catastrophically all the way down to Darchula, without the force of an additional 6 million m³ of stored water released suddenly.

Emmanuel Theophilus (

[1]    NHPC never gives warning of sudden releases. There is a notice painted on a board at Tawaghat, the first river-side habitation downstream, that warns people not to go anywhere near the river, because water may be released anytime.

[2]    Kajima Construction Corporation Ltd of Japan, Daewoo Engineering and Construction Company of Korea, and Bauer Maschinen of Germany.

[3]    How a tail-race exit could be planned on the Ellagad stream which is very steep and unstable, full of debris from a service tunnel, and highly ‘flashy’, is indicative of poor design and of lax design approval mechanisms.

Subansiri Basin Study – Another Chapter of Environment Subversion in Northeast

The Study The study has been done by IRG Systems South Asia Private Limited (, a subsidiary of US based IRG Systems) and[i]. It is supposed to be a Cumulative Impact Assessment of 19 HEPs planned in the basin, out of which PFRs of 7 are available, DPR of two, and one of which, the 2000 MW Subansiri Lower HEP is under construction.

Subversion of Environment Governance in the Subansiri basin While looking at this basin study, the subversion of environment governance in Subansiri basin this very millennia should be kept in mind. A glimpse of it is provided in Annexure 1. In fact, one of the key conditions of environmental clearance to the 2000 MW Lower Subansiri HEP was that no more projects will be taken up in the basin upstream of the Lower Subansiri HEP, which essentially would mean no more projects in the basin, since LSHEP is close to the confluence of the Subansiri River with Brahmaputra River. That condition was also part of the Supreme Court order in 2004. The need for a carrying capacity study was also stressed in the National Board of Wild Life discussions. We still do not have one. In a sense, the Subansiri basin is seeing the consequences of that subversion.

Map of Subansiri RIver Basin  Source:

Map of Subansiri RIver Basin

Information in public domain not known to consultants The report does not even state that Middle Subansiri dam have also been recommended TOR in 41st EAC meeting in Sept 2010. This project will require 3180 ha of land, including 1333 Ha forest land, and 2867 ha area under submergence. Even about Upper Subansiri, the consultants do not know the area of forest land required (2170 ha). So the consultants have not used even the information available in public domain in EAC meetings.

Study based on flawed and incomplete Lohit Basin Study The Study claims that it is based on Lohit Basin Study done by WAPCOS. Lohit Basin Study is an extremely flawed attempt and does not assess cumulative impacts of the cascade projects. Civil society has written about this to the EAC and the EAC itself has considered the study twice (53rd and 65th EAC Meetings), and has not accepted the study, but has raised several doubts. Any study based on a flawed model like Lohit Basin Study should not be acceptable.

A house in the upstream of Subansiri River  Source:

A house in the upstream of Subansiri River

No mention of Social impacts Major limitation of the study has been absolutely no discussion on the severe social impacts due to cumulative forest felling, flux of population, submergence, livelihoods like riparian farming and fishing, etc. Though this has been pointed out by the TAC in its meeting and field visit, the report does not reflect this.

Some key Impacts Some of the impacts highlighted by the study based on incomplete information about HEPs are:

Þ    The length of the river Subansiri is 375 km up to its outfall in the Brahamaputra River. Approximately 212.51 km total length of Subansiri will be affected due to only 8 of the proposed 19 HEPs in Subansiri River basin.

Þ    Total area brought under submergence for dam and other project requirements is approx. 10, 032 ha of eight proposed HEPs. The extent of loss of forest in rest of the 9 projects is not available.

Þ    62 species belonging to Mammals (out of 105 reported species), 50 Aves (out of 175 reported species) and 2 amphibians (out of 6 reported species) in Subansiri Basin are listed in Schedules of Wildlife Protection Act, 1972 (as amended till date).

Þ    99 species belonging to Mammals (out of 105 reported species), 57 species belonging to Aves (out of 175 reported species), 1 Reptilian (out of 19 reported species), 2 Amphibians (out of 6 reported species), 28 fishes (out of 32 reported species), 25 species belonging to Odonata of Insecta fauna group (out of 28 reported species) are reported to be assessed as per IUCN’s threatened categories.

Even this incomplete and partial list of impacts should give an idea of the massive impacts that are in store for the basin.

Cumulative impacts NOT ASSESSED Specifically, some of the cumulative impacts that the report has not assessed at all or not adequately include:

1. Cumulative impact of blasting of so many tunnels on various aspects as also blasting for other project components.

2. Cumulative impact of mining of various materials required for the projects (sand, boulders, coarse and fine granules, etc.)

3. Cumulative impact of muck dumping into rivers (the normal practice of project developers) and also of also muck dumping done properly, if at all.

Subansiri River in the Upper Reaches  Source: Lovely Arunachal

Subansiri River in the Upper Reaches
Source: Lovely Arunachal

4. Changes in sedimentation at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof.

5. Cumulative impact on aquatic and terrestrial flora and fauna across the basin due to all the proposed projects.

6. Cumulative impact of the projects on disaster potential in the river basin, due to construction and also operation at various stages, say on landslides, flash floods, etc.

7. Cumulative dam safety issue due to cascade of projects.

8. Cumulative change in flood characteristics of the river due to so many projects.

9. Cumulative impacts due to peaking power generation due to so many projects.

10. Cumulative sociological impact of so many projects on local communities and society.

11. Cumulative impact on hydrological flows, at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof. This will include impacts on various hydrological elements including springs, tributaries, groundwater aquifers, etc. This will include accessing documents to see what the situation BEFORE project and would be after. The report has failed to do ALL THIS.

12. Impact of silt laden water into the river channel downstream from the dam, and how this gets accumulated across the non-monsoon months and what happens to it. This again needs to be assessed singly and cumulatively for all projects.

13. Impact of release of silt free water into the river downstream from the power house and impact thereof on the geo morphology, erosion, stability of structures etc, singly and cumulatively.

14. Impact on Green House Gas emissions, project wise and cumulatively. No attempt is made for this.

15. Impact of differential water flow downstream from power house in non-monsoon months, with sudden release of heavy flows during peaking/ power generation hours and no releases during other times.

16. Cumulative impact of all the project components (dam, tunnels, blasting, power house, muck dumping, mining, road building, township building, deforestation, transmission lines, etc.,) for a project and then adding for various projects. Same should also be done for the periods during construction, operation and decommissioning phases of the projects.

17. Cumulative impact of deforestation due to various projects.

18. Cumulative impact of non compliance of the environment norms, laws, Environment clearance and forest clearance conditions and environment management plans. Such an assessment should also have analysed the quality of EIA report done for the Subansiri Lower hydropower project.

Wrong, misleading statements in Report There are a very large number of wrong and misleading statements in the report. Below we have given some, along with comment on each of them, this list is only for illustrative purposes.

Sr No

Statement in CIA


1 “During the monsoon period there will be significant discharge in Brahmaputra River. The peaking discharge of these hydroelectric projects which are quite less in comparison to Brahmaputra discharge will hardly have any impact on Brahmaputra.” This is a misleading statement. It also needs to be assessed what will be the impact on specific stretches of Subansiri river. Secondly, the projects are not likely to operate in peaking mode in monsoon.
2 “However, some impact in form of flow regulation can be expected during the non-monsoon peaking from these projects.” This is not correct statement as the impact of non-monsoon peaking is likely to be of many different kinds, besides “flow regulation” as the document describes.
3 “Further, during the non-monsoon period the peaking discharge release of the projects in upper reaches of Subansiri basin will be utilized by the project at lower reaches of the basin and net peaking discharge from the lower most project of the basin in general will be the governing one for any impact study.” This is again wrong. What about the impact of such peaking on rivers between the projects?
4 “The construction of the proposed cascade development of HEPs in Subansiri basin will reduce water flow, especially during dry months, in the intervening stretch between the Head Race Tunnel (HRT) site and the discharge point of Tail Race Tunnel (TRT).” This statement seems to indicate that the consultants have poor knowledge or understanding of the functioning of the hydropower projects. HRT is not one location, it is a length. So it does not make sense to say “between HRT and the discharge point of TRT”.
5 “For mature fish, upstream migration would not be feasible. This is going to be the major adverse impact of the project. Therefore, provision of fish ladder can be made in the proposed dams.” This is simplistic statement without considering the height of the various dams (124 m high Nalo HEP dam, 237 m high Upper Subansiri HEP dam, 222 m high Middle Subansiri HEP dam), feasibility of fish ladders what can be optimum design, for which fish species, etc.
6 “…water release in lean season for fishes may be kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20% water flow in lean season may be maintained at Hiya and Nyepin HEP for fish migration.” This conclusion seems unfounded, the water release suggested is even lower than the minimum norms that EAC of MoEF follows.

Viability not assessed The report concludes: “The next steps include overall assessment of the impacts on account of hydropower development in the basin, which will be described in draft final report.”

One of the key objective of the Cumulative Impact assessment is to assess how many of the planned projects are viable considering the impacts, hydrology, geology, forests, biodiversity, carrying capacity and society. The consultants have not even applied their mind to key objective in this study. They seem to assume that all the proposed projects can and should come up and are all viable. It seems the consultant has not understood the basic objectives of CIA. The least the consultant could have said is that further projects should not be taken up for consideration till all the information is available and full and proper Cumulative impact assessment is done.

The consultants have also not looked at the need for free flowing stretches of rivers between the projects.

Section on Environmental Flows (Chapter 4 and 9): The section on Environmental flows is one of the weakest and most problematic sections of the report, despite the fact that the Executive summary talks about it as being one of the most crucial aspects.

The study does not use any globally accepted methodology for calculating eflows, but uses HEC RAS model, without any justification. The study has not been able to do even a literature review of methodologies of eflows used in India and concludes that “No information/criteria are available for India regarding requirement of minimum flow from various angles such as ecology, environment, human needs such as washing and bathing, fisheries etc.”

This is unacceptable as EAC itself has been recommending Building Block Methodology for calculating eflows which has been used (very faultily, but nonetheless) by basin studies even like Lohit, on which this study is supposedly based. EAC has also been following certain norms about E flow stipulations. CWC itself has said that minimum 20% flow is required in all seasons in all rivers. BK Chaturvedi committee has recently stipulated 50% e-flows in lean season and 30% in monsoon on daily changing basis.

The assumption of the study in its chapter on Environmental Flows that ‘most critical reach is till the time first tributary meets the river” is completely wrong. The study should concentrate at releasing optimum eflows from the barrage, without considering tributary contribution as an excuse.

First step of any robust eflows exercise is to set objectives. But the study does not even refer to this and generates huge tables for water depths, flow velocity, etc., for releases ranging from 10% lean season flow to 100% lean season flow.

After this extensive analysis without any objective setting, the study, without any justification (the justification for snow trout used is extremely flawed. Trouts migrate twice in a year and when they migrate in post monsoon months, the depth and velocity needed is much higher than the recommended 10% lean season flow) recommends “In view of the above-said modeling results, water release in lean season for fishes maybe kept between 10-15% for migration and sustaining ecological functions except Hiya and Nyepin HEP. Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at all HEP for fish migration and ecological balance.”

The study does not recommend any monsoon flows. Neither does it study impact of hydro peaking on downstream ecosystems.

Shockingly, the study does not even stick with this 20-25% lean season flow recommendation (20-25% of what? Average lean season flow? Three consecutive leanest months? The study does not explain this). In fact in Chapter 9 on Environmental Flows, the final recommendation is: “Therefore, it is suggested that the minimum 20-25% water flow in lean season may be maintained at Hiya and Nyepin  HEP or all other locations for fish migration.” (emphasis added)

So it is unclear if the study recommends 20-25% lean season flows or 10-15% lean season flows. This is a very flawed approach to a critical topic like eflows.

The study keeps mentioning ‘minimum flows’ nomenclature, which shows the flawed understanding of the consultants about e-flows.

The entire eflows section has to be reworked, objectives have to be set, methodology like Building Block Methodology has to be used with wide participation, including from Assam. Such exercises have been performed in the past and members of the current EAC like Dr. K.D. Joshi from CIFRI have been a part of this. In this case, EAC cannot accept flawed eflows studies like this. (DR. K D. Joshi has been a part of a study done by WWF to arrive at eflows through BBM methodology for Ganga in Allahabad during Kumbh: Environmental Flows for Kumbh 2013 at Triveni Sangam, Allahabad and has been a co author of this report)

Chocolate Mahseer in Subansiri  Source:

Chocolate Mahseer in Subansiri

Mockery of rich Subansiri Fisheries Subansiri has some of the richest riverine fisheries in India. The river has over 171 fish species, including some species new to science, and forms an important component of livelihood and nutritional security in the downstream stretches in Assam.

But the study makes a mockery of this saying that the livelihoods dependence on fisheries is negligible. The entire Chapter on Fisheries needs to be reworked to include impacts on fisheries in the downstream upto Majuli Islands in Assam at least.

No mention of National Aquatic Animal! Subansiri is one of the only tributaries of Brahmaputra with a resident population of the endangered Gangetic Dolphin, which is also the National aquatic animal of India (Baruah et al, 2012, Grave Danger for the Ganges Dolphin (Platanista ganegtica) in the Subansiri River due to large Hydroelectric Project

Shockingly, the Basin Study does not even mention Gangetic Dolphin once in the entire study, let alone making recommendations to protect this specie!

Gangetic Dolphin is important not only from the ecological perspective, but also socio cultural perspective. Many fisher folk in Assam co-fish with the Gangetic River Dolphin. These intricate socio ecological links do not find any mention in the Basin study, which is unacceptable.

Agitation Against Lower Subansiri Dam in Assam Source: SANDRP

Agitation Against Lower Subansiri Dam in Assam
Source: SANDRP

Lessons from Lower Subansiri Project not learnt A massive agitation is ongoing in Assam against the under construction 2000 MW Subansiri Lower HEP. The people had to resort to this agitation since the Lower Subansiri HEP was going ahead without studying or resolving basic downstream, flood and safety issues. The work on the project has been stopped since December 2011, for 22 months now. In the meantime several committee have been set up, several changes in the project has been accepted. However, looking at this shoddy CIA, it seems no lessons have been learnt from this ongoing episode. This study does not even acknowledge the reality of this agitation and the issues that the agitation has thrown up. There is no reflection of the issues here in this study that is agitating the people who are stood up against the Lower Subansiri HEP. The same people will also face adverse impacts of the large number of additional projects planned in the Subansiri basin. If the issues raised by these agitating people are not resolved in credible way, the events now unfolding in Assam will continue to plague the other planned projects too.

Conclusion From the above it is clear that this is far from satisfactory report. The report has not done proper cumulative assessment on most aspects. It has not even used information available in public domain on a number of projects. It does not seem to the aware of the history of the environmental mis-governance in the SubansiriBasin as narrated in brief in Annexure 1. For most projects basic information is lacking. Considering the track record of Central Water Commission functioning as lobby FOR big dams, such a study should have never been given to CWC. One of the reasons the study was assigned by the EAC to the Central Water Commission was that the CWC is supposed to have expertise in hydrological issues, and also can take care of the interstate issues. However, the study has NOT been done by CWC, but by consultants hired by CWC, so CWC seems to have no role in this except hiring consultant. So the basic purpose of giving the study to CWC by EAC has not been served. Secondly the choice of consultants done by the CWC seems to be improper. Hence we have a shoddy piece of work. This study cannot be useful as CIA and it may be better for EAC to ask MoEF for a more appropriate body to do such a study. In any case, the current study is not of acceptable quality.

South Asia Network on Dams, Rivers & People (


Set Conditions to be waived Later – The MoEF way of Environmental Governance

In 2002, the 2,000 MW Lower Subansiri hydroelectric project on the Assam-Arunachal Pradesh border came for approval to the Standing Committee of the Indian Board for Wildlife (now called the National Board for Wildlife) as a part of the Tale Valley Sanctuary in AP was getting submerged in the project. The total area to be impacted was 3,739.9 ha which also included notified reserved forests in Arunachal Pradesh and Assam.  The Standing Committee observed that important wildlife habitats and species well beyond the Tale Valley Sanctuary, both in the upstream and downstream areas, would be affected (e.g. a crucial elephant corridor, Gangetic river dolphins) and that the Environmental Impact Assessment studies were of a very poor quality. However, despite serious objections raised by non-official members including Bittu Sahgal, Editor, Sanctuary, Valmik Thapar, M.K. Ranjitsinh and the BNHS, the Ministry of Environment & Forests (MoEF) bulldozed the clearance through in a May 2003 meeting of the IBWL Standing Committee. Thus a project, which did not deserve to receive clearance, was pushed through with certain stringent conditions imposed (Neeraj Vagholikar, Sanctuary Asia, April 2009).

Lower Subansiri HEP Source: The Hindu

Lower Subansiri Dam
Source: The Hindu

The EC given to the project was challenged in Supreme Court (SC) by Dr L.M Nath, a former member of the Indian Board for Wildlife. Nath pleaded, these pristine rich and dense forests classified as tropical moist evergreen forest, are among the finest in the country. Further the surveys conducted by the Botanical Survey of India and the Zoological Survey of India were found to be extremely poor quality. The Application mentions that the Additional DG of Forests (Wildlife) was of the view that the survey reports of the BSI and ZSI reports were not acceptable to him because these organisations had merely spent five days in the field and produced a report of no significance.

The SC gave its final verdict on 19-4-2004, in which the Court upheld the EC given by MoEF to NHPC but with direction to fulfill some important conditions. Out these conditions there were two conditions which were very significant – “The Reserve Forest area that forms part of the catchment of the Lower Subansri including the reservoir should be declared as a National Park/ Sanctuary. NHPC will provide funds for the survey and demarcation of the same.”, and “There would be no construction of dam upstream of the Subansri River in future.” These conditions were also mentioned in the original EC given to the project in 2003.

In May 2005, two years after the EC was given the Arunachal Pradesh govt and NHPC approached the SC to waive or modify the above two conditions. The state government calimed that following these conditions would imply loss of opportunity to develop 16 mega dams in the upstream of Lower Subansiri (this including 1,600 MW Middle Subansiri and 2,000 MW Upper Subansiri to be developed by NHPC). The SC sent it back to National Board for Wildlife to review the conditions.

The petition was done strategically. “The strategy of the dam proponents is simple. They raised no objection to the terms until the construction of the Lower Subansiri project had proceeded beyond a point when it could have been cancelled. Armed with this fait accompli, they asked for a review of the clauses on the very basis on which the original clearance – laid down by members who were subsequently dropped from the wildlife board – was granted.”[ii]

Then nonofficial members of NBWL expressed their dissent to the proposal. In a May 2008 communication to the Chairman of the NBWL Standing Committee, member Dr. Bibhab Talukdar observed: “If the Standing Committee agrees to waive the conditions, we would be setting a dangerous precedent and sending a wrong signal regarding the credibility of decision-making by us. This would mean that projects impacting rich wildlife habitats can receive clearances based on stringent conditions, only to be up for review later. Such an approach is undesirable both from a perspective of good governance as well as the long-term interest of wildlife in the country.”

Dr. Asad Rahmani of the BNHS, who was part of a sub-committee of the NBWL Standing Committee conducting a site visit to the project area, stated in his report: “Under no circumstances should new projects be allowed in the Subansiri river basin until an advance cumulative assessment of proposed projects and a carrying capacity study of the Subansiri river basin are completed.”

In the December 12 2008 meeting of NBWL Standing Committee, even after these dissenting opinions from nonofficial members MoEF managed to do a dilution of the above two conditions. Assam that time was witnessing a major protest concerning the downstream impacts of Lower Subansiri HEP but it was not even consulted. Shockingly the “no dam upstream” condition was removed and it was decided that “any proposal in the upstream of the SubansiriRiver would be considered independently on its merit by the Standing Committee as and when submitted by the proponents”.

Now the Arunachal Pradesh government needs to declare a smaller area of 168 sq. km. as a sanctuary and “make serious efforts” to bring an additional 332 sq. km. reserved forest under the category of Conservation Reserve (CR) in consultation with the MoEF. The latter part of the condition (declaration of CR) is non-enforceable because of the choice of words. Even the demand to at least conduct an advanced cumulative impact assessment of proposed projects and a carrying capacity study of the Subansiri river basin has been ignored[iii].

As Bittu Sahgal, Editor, Sanctuary Asia says, “The Lower Subansiri is one such, where the PMO has placed a very dubious role in forcing clearances, agreeing to clearance conditions and then starting the project, only to loosen the environmental conditions. In this whole scam the Zoological Survey of India and the Botanical Survey of India have been co-conspirators that have suppressed the ecological value of the forests to facilitate the building of the dam, which will drown pristine elephant, tiger and clouded leopard forests and cause havoc downstream as well.”

The above sequence of events are very pertinent to remember as we see the Subansiri basin study.


[i] Website says: “More than 200 successful environmental Impact Assessment Clearance from Ministry of Environment & Forests, Government of India for Industry, Infrastructure & Construction projects” Sounds strange from an EIA consultant.

[iii] For more details please see – “Forest Case Update”, Issue 1, June 2004 and “The Subansiri Subversion” by Neeraj Vagholikar published in Sanctuary Asia, April 2009 issue

Uttarakhand Rainfall: Since 1901 and in light of the 2013 disaster

During the tragic Uttarakhand disaster, one of the most discussed but the most elusive topics has been rainfall. Uttarakhand, though having experienced frequent extreme weather events, has a poor distribution of rain gauge stations and weather monitoring. The worst hit districts like Rudraprayag, Chamoli and Pithoragarh have especially dismal distribution of monitoring stations, making it impossible for us to understand the intensity of rainfall in places like Kedarnath when the disaster struck. (

According to the Indian Meteorological Department (IMD) June 2013 rainfall was over thrice the normal amount between June 1 and 21. The highest figure quoted by IMD was 370 mm a day at Dehradun, which was said to be ‘a record not seen for five decades’. IMD has also said that in the week of 13th to 19th June, the entire state of Uttarakhand received 847% excess rainfall, and that this has no precedent.[1] However, according to experts, this generalisation of a very diverse state does not depict the true picture.

Nonetheless, it is worthwhile to string together whatever data we have on Uttarakhand’s rainfall in order to get a clearer picture of rainfall trends, and also underline the fact that Uttarakhand and all the other Himalayan States need a much denser network on weather monitoring stations, representation all altitudes, river basins & sub-basins and climatic zones. Only then will the data be a useful tool in planning and forecasting.

In this piece, we have tried to analyse rainfall datasets of the hundred years (1901-2000) for some of the worst affected and vulnerable districts of Uttarakhand. This data has been obtained from Indian Meteorological Department. Districts analysed include Uttarkashi, Rudraprayag, Haridwar, Chamoli, Tehri Garhwal, and Pithoragarh.

While we have rainfall data from 1901-2000 (with some gaps), there is a gap in the data during 2000-2008. Then again we have data from 2008-2012 and 2013 till 25th September 2013. (All figures from IMD – India Meteorological Department –

What we have attempted here is:

1.     Identification of Top 5 Maximum and Minimum rainfall events in the selected 7 districts in the past 100 years. Comparison of these values with 2013 Maximum monthly rainfall

Interesting to note that the only time when 2013 monthly (approximate, as we have weekly figures from IMD, not monthly ones) features in top 5 monthly rainfall is for Chamoli, in July 2013! 537.9 mm rainfall it received in July 2013 was the second highest recorded rainfall in the district since 1901-2000 and 2008-2013.

2.   100 year monthly monsoonal and annual rainfall for selected 7 districts, 2008-2012 monsoonal and annual rainfall for selected 7 districts.

3. 2013 weekly rainfall collated in respective months for June, July and August for the seven districts.


1.             Dehradun: 

  • Maximum monthly rainfall in last 100 years during monsoon months (Same for all districts below): 1271 mm in August 1943
  • Minimum rainfall in last 100 years during monsoon months: 20.4 mm in June 1965
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In August 2013 it received 676.7 mm rainfall which was maximum for the district in 2013 monsoon.

However, this did not figure amongst the top 5 values for monsoon rainfall in the period considered.

  • Rainfall during the week 13-06-13 to 19-06-13: 565.4 mm
  • Departure from normal for the same week – 1436%



2. Uttarkashi:

  • Maximum rainfall in last 100 years: 800.8 mm in August 1963
  • Minimum rainfall in last 100 years: 36.8 mm in June 1987 
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In 2013, 529.9 mm received in June was the highest for the 2013 monsoon season.

However, this does not feature among the top 5 values for monsoon rainfall in the period considered.

  • Rainfall during the week 13-06-13 to 19-06-13: 375.6 mm
  • Departure from normal for the same week: 1356%


3. Tehri Garhwal-

  • Maximum rainfall in last 100 years 1097 mm in September 1995
  • Minimum rainfall in last 100 years- 0 mm in September 1997
  • Comparison of 2013 max rainfall with the previous 5 maximum: In 2013, 453.4 mm rainfall received in June was the highest for the 2013 monsoon season.

However, this does not feature among the top 5 values for monsoon rainfall in the period considered.

  • Rainfall during the week 13-06-13 to 19-06-13: 327.7 mm
  • Departure from normal for the same week – 390%Tehri Garhwal_ReshapedTehri Garhwal_100_Years

4. Haridwar-

  • Maximum rainfall in last 100 years: 848.2 mm in September 1924
  • Minimum rainfall in last 100 years: 0 mm in September 1971
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In 2013, 426 mm rainfall received in August was the highest for the 2013 monsoon season.

However, this does not feature among the top 5 values for monsoon rainfall in the period considered.

  • Rainfall during the week 13-06-13 to 19-06-13: 298.8 mm
  • Departure from normal for the same week – 1283%



5. Rudraprayag

  • Maximum rainfall in last 100 years 914.6 mm in August 1925
  • Minimum rainfall in last 100 years 0 mm, in September 1971
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In 2013, 664 mm rainfall received in June was the highest for the 2013 monsoon season.

However, this does not feature among the top 5 values for monsoon rainfall in the period considered.

  • Rainfall during the week 13-06-13 to 19-06-13:366.3 mm
  • Departure from normal for the same week – 580%


6. Pithoragarh-

  • Maximum rainfall in last 100 years 1057 mm in August 2000
  • Minimum rainfall in last 100 years 22 mm in June 1901
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In 2013, 471.9 mm rainfall received in July was the highest for the 2013 monsoon season.

However, this does not feature among the top 5 values for monsoon rainfall in the period considered.

  • Rainfall during the week 13-06-13 to 19-06-13: 246.9 mm
  • Departure from normal for the same week – 238%


7. Chamoli

  • Maximum rainfall in last 100 years860.7 mm in September 1924
  • Minimum rainfall in last 100 years– 0 mm in 1998
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In 2013, 537.9 mm rainfall received in July was the highest for the 2013 monsoon season.

It was a second maximum recorded rainfall since 1901-2000 and 2008-2013.

  • Rainfall during the week 13-06-13 to 19-06-13: 316.9 mm
  • Departure from normal for the same week – 1302%



8. For Uttarakhand state-

  • Maximum rainfall in last 100 years685.6 mm in August 1922
  • Minimum rainfall in last 100 years 28.1 mm in September 1907
  • Maximum rainfall of 2013 compared with the 5 previous maximums: In 2013, 510.4 mm rainfall received in June (June 1 to July 3) was the highest for the 2013 monsoon season.

However, this does not feature among the top 5 values for monsoon rainfall in the period considered.



In conclusion While presenting data for entire districts, we realise that there have been major variations in rainfall experienced within a district, for example, parts of Pithoragarh received extremely high rainfall during 15th-19th June, but the average rainfall for Pithoragarh District in June 2013 (Period between 06.06.13-03.07.13) is only 418.4 mm. The week between 13 June 2013-19th June 2013 shows only 238% departure from normal rainfall, when the higher reaches of Pithoragarh received some of the heaviest rainfall in Uttarakhand in June 2013.

As per researcher Emmanuel Theophilus, from Himal Prakriti at Munsiyari, Pithoragarh, the rainfall data with IMD for the entire Pithoragarh Districts  is  only from 2 stations in  the mid altitude areas, where it hardly rained much. Hence, the discrepancy, of Pithoragarh having only a 238% departure from normal, whereas the NASA maps show one of the darkest blue spots in Pithoragarh as well. In addition, he says: “IMD has only a very few stations scattered sparsely over the state, and what they have, are located in central district and sub-division office locations. Sure this makes for easy gathering of data, but is of little use for understanding any particularities, even at the sub-basin scale. In just the Gori sub-basin (Pithoragarh) for example, rainfall can vary from 15 cm annually, (spread over ~28 rainy days a year, and not counting snow) in the higher alpine Trans-Himalaya reaches, to as much as 4 meters, yes meters, of rain annually (spread over ~152 rainy days a year, and again not counting snow) just 50 km downstream, in the Greater Himalaya. Therefore, statements such as ‘the entire state of Uttarakhand received 847% excess rainfall’, can be misleading.”

After the Uttarakhand Disaster of unprecedented proportions, let us hope that now IMD, Uttarakhand Government, heavily funded programs like National Climate Mission, Universities, research institutes[2], etc can come together to create reliable and representative weather monitoring stations in the vulnerable state. Only through such data will a robust forecasting system be supported.

Damodar Pujari and Parineeta Dandekar


[1] From Emmanuel Theophilus: A River Pulse. A discussion paper on the flood-events in June 2013, Mahakali basin, Uttrakahand. Himal Prakriti, Sept 2013

[2] Here it may be noted that some institutes have their own automatic and other rain-gauge stations, but data from such stations is not in public domain. For example, Wadia Institute of Himalayan Geology ( is supposed to have at least two automatic weather stations at Chorabari lake upstream of the worst impacted Kedarnath, but the data from these stations was not put up in public domain promptly or even now. Such data can be of great use for disaster forecasting, management and other purposes, but cannot be put to use without the data being in public domain.

Lower Kopili HEP: Oustanding issues that must be resolved before EAC can consider the project

The Lower Kopili Hydro Electric Project(HEP) will be considered for TOR clearance in the forthcoming Expert Appraisal Committee(EAC) meeting on September 23-24, 2013. This project was first discussed in the 63rd EAC meeting held on 12-13th October, 2012. It was again discussed in the 65th meeting of the EAC held on 26-27th December, 2012 for approval of Terms of Reference (TOR) for the Environmental Impact Assessment (EIA). EAC had sent back the project proposal seeking additional information/clarification on several issues. There were several critical issues which were not raised by the EAC. We have made a submission to EAC pointing out issues which need urgent attention.

Background of Hydroelectricity Generation on Kopili River

The Kopili River: Kopili is a south bank tributary of Brahmaputra which originates in the Borail range mountains in Meghalaya at an altitude of about 1600 m and has a total length of 290 km up to its confluence with Brahmaputra. Its basin is bound by the Jaintia Hills in the west and the South Cachar and Mikir Hills in the east. Kharkor, Myntriang, Dinar, Longsom, Amring, Umrong, Longku and Langkri are its major tributaries in its upper reaches.

After entering Assam the Kopili separates the Karbi Anglong district from the Dima Hasao North Cachar Hills district up to its confluence with Diyung River on its right at 135 km. After the confluence with Diyung, Kopili flows into the Nagaon district in a north-westerly direction. The Jamuna River with a catchment of 3960 km2 flows to the Kopili at Jamunamukh. The river then flows in western direction, and further downstream, the Umkhen-Borapani River which rises in the Shillong plateau and drains an area of 2038 km2 joins Kopili at a distance of 254 km from the left. The Killing River, known as Umiam in its upper reaches draining an area of about 1445 km2, flows into Kopili from the left at about 280 km. The Kopili River finally flows to Kalang, a spill channel of Brahmaputra, near Hatimukh after traversing a distance of 290 km2. The total catchment of Kopili River is about 16,421km2.

Kopili HEP: The Kopili Hydro Electric Project (HEP) has two dams, one on the Kopili River and one on its tributary Umrang stream. This project was developed by NEEPCO (Northeast Electric Power Corporation Ltd.). The first dam with 66 m height on the Kopli River is known as Khndong dam and the second one with 30 m height is known as Kopili dam located at Umranso.  Water from the Khandong reservoir is utilised in the Khandong power station through a 2852 m long tunnel to generate 50 MW (2 X 25 MW) of power. The tail water from this powerhouse is led to the Umrong reservoir. The water from Umrong reservoir is taken through a 5473 m long tunnel to the Kopili power station to generate 200 MW (4 X 50 MW) of power. An additional 25MW was added to the Khandong dam in the Stage two of the Kopili HEP, making the total power generation 275 MW. Both Khandong and Kopili dams are concrete gravity dams. The first unit of this Kopili HEP was commissioned in March 1984. Additional unit under stage two was commissioned in July, 2004.

Proposed Lower Kopili HEP: The proposed Lower Kopili HEP is coming up in Boro Longku village in Dima Hasao district. The project is developed by Assam Power Generation Corporation Limited (APGCL). The Lower Kopili dam will be a concrete gravity dam with 70.13 m high dam wall. This project will also have two power houses and the first power house, or the main power house will have an installed capacity of 110 MW (2X55MW). An auxiliary Power House with an installed capacity of 10 MW (2×2.5 MW+1×5 MW) has been planned  at  the  toe  of  the  dam  for  utilizing  the  mandatory  releases  for  ecological purposes, making the total installed capacity 120 MW. The Head Race Tunnel(HRT) of the project will be 7.25 m in diameter and 3.6 km long. The total land required for this project will be 1577 ha out of which according to the revised PFR and Form-I 552 ha will fall under submergence. But the old PFR and Form-I had mentioned the size of the submergence area as 620ha. The  free flowing river  stretch  between  Full Reservoir Level  (FRL) of  Lower  Kopili  HEP  and  Tail Water Level (TWL) of upstream  Kopili  HEP  is  about  6  km.

The water available at Lower Kopili dam site will consists of the following components:

1.   Tailrace releases from Kopili Power Station (4 x 50 MW)

2.   Inflow from intermediate catchment between Khandong and Longku Dam site

3.   Spill from Khandong and Umrong Reservoir.

Projects in Cascade on Kopili River

Projects in Cascade on Kopili River

Some Key Issues Requiring Urgent Attention

After thoroughly going through Pre Feasibility Report (PFR) and Form-I of the proposed Lower Kopili HEP we have found that following issues have not been adequately dealt with by the project authorities. Infact some of them have not even been mentioned at all. EAC should not give TOR clearance to the project without satisfactory resolution of these issues.

Dam induced Flood: Experiences of the people living in downstream suggest that floods have become more recurrent after construction of the dam. The Kopili dam has changed the character of flood in the river downstream for the worse. Before the construction of Kopili dam, floods occurred mainly during monsoon season. Increase in water volume due to heavy rains used to be the reason for flood. These were normal floods which occurred not more than two or three times a year. But after the construction of the dam, number of artificial floods occurring in a year has gone upto 5- 6 times. These floods mainly occurred from the month of August to the first one or two weeks of November. Government of Assam never made an attempt to investigate the source of these floods (this information is from a field visit done to the area). 

In the catastrophic floods of 2004, out of 140 revenue villages of Kampur circle of Nagaon district 132 were affected by floods with area of 135.12 sq. miles. Due to these floods 1,92,000 people were temporarily displaced. These floods also took the lives of 4 people. Even government had confirmed that the main reason for the devastation in these Nagaon and Morigaon districts was the release of the water from the NEEPCO’s Kopili project. The team that was deputed by the government found that water level of the Khandong reservoir went up to 727.70 meters against the FRL of 719.30 meters on 18th July 2004, which rolled down and led to catastrophic disaster. Flood release from the dam happened without prior warning and affected the whole valley. Kampur is one of the towns located in the downstream of Kopili dam where people were give only 2 hours to evacuate the area and move to nearby relief camps.  July 18 is less than midway through the monsoon and questions arise why was the dam allowed to be filled up so soon which had led to such disaster. Had the dam operations were conducted properly the disaster could have possibly been avoided.

The issue of flash floods in Kopili River was raised in the Assam state assembly. On 8th November, 2010 former Chief Minister of Assam Mr. Prafulla Kumar Mahanta, an MLA from Nagaon district made a call attention motion in the Legislative assembly on the issue flash floods in Kopili. He stated the NEEPCO is responsible for the flash floods in the Kopili River.[1] Then Water Resource Minister Prithvi Majhi in his reply accepted this claim by saying that “the government would take up the matter of providing prior warning before release of excess water with the NEEPCO authorities.”  From the above experiences of flood in Kopili River, it is clear that after the construction of the Kopili HEP (Hydroelectric Project) flood ferocity had increased in the downstream. In such situation construction of another dam in the immediate downstream of previous dam can worsen the flood scenario.

Besides, The Kopili reservoir of the Khandong dam is located at 82.5 km downstream from the origin of Kopili River. A major tributary Myntang with 512 sq kmcatchment joins Kopili at 86 km from origin[2]. This is one of the tributaries in the upstream of proposed Longku dam site. In rainy season excess of rains in the catchment of these streams can also lead to spillovers in the proposed dam itself. The PFR does not look into the cumulative impact of the operation of the two dams on the downstream riverine area.

Spillway Capacity Inadequate at Lower Kopili HEP: As per the PFR, the design spillway capacity of the proposed Lower Kopili project with catchment of 2106 sq km is 16110 cumecs. Compare this with the spillway capacity of the upstream Khandong dam on the same Kopili river with catchment area of 1256 sq km being 15471.3 cumecs. It is clear that the design spillway capacity of the proposed Lower Kopili Project is inadequate.

Acid Contamination due to Opencast Mining threatens Viability of Lower Kopili: In the item 9.9 of the Form-I it has been mentioned that the acidic mine discharge in the upper reaches of the Kopili catchment is posing serious threats to the existing Kopili HEP. The PFR states “The identified acid mine discharge has been reported to cause constant erosion/ corrosion of critical hydropower equipments leading to frequent outages of the power plants under Kopili HEP.” The minutes of 9th TCC (Technical Coordination Committee) & 9th North East Region Power Committee Meetings held on 11-12th August, 2010, stated “The Kopili HE Plant has faced an extraordinary and unprecedented situation owing to acidic nature of the reservoir water. Prima facie, the acidification of the reservoir water is caused due to unscientific coal mining in the catchment area as revealed by study through GSI, NER, Shillong. The increased wear and tear on the underwater metal parts of the Plant due to corrosive action of the acidic water has led to the increase in the number of breakdowns.” The minutes also mentioned “It is pertinent to mention here that, although massive repairing work has been carried out by NEEPCO as temporary measures; an integrated, interdisciplinary approach for preventing / tackling acidification at source must be opted for survival of the Plant.” The acidic contamination due to open cast mining is such that no living organisms could be found in the downstream of Kopili river up to Kheroni.[3] The situation is quite alarming as the PH value of the water has come down from 5.5 to 3.2 due to acidic contamination which is unfit for human consumption. State Power Minster was very much aware of the situation and expressing concerns over this he had asked the center to take up this issue with Meghalaya.[4] The PFR should have given detailed account of implication of this on the proposed Lower Kopili HEP and further downstream, but has not done that.

PFR overlooks Kopili Fault Line: The PFR of the proposed Lower Kopili HEP does not mention about the Kopili fault line[5]. In recent studies done in the Kopili river basin it has been found that the Kopili fault extends  from  western  part  of  Manipur  up  to  the  tri-junction  of  Bhutan,  Arunachal Pradesh  and Assam, covers  a  distance  of about  400 km. During the last 140 years, the Kopili fault has experienced 2 earthquakes of magnitude greater than 7 in R.S., three of magnitude 6 to 7 in R.S. and several of magnitude 4.5 to 6 in R.S.[6]   The study concludes that the North East region, more specially the Kopili Fault area is a geologically unstable region, surrounded by faults and lineaments and seduction zones in the east.  But the PFR of Lower Kopili, overlooking this issue states that there are only two minor faults in this area and both of them are much beyond the project area. This clearly wrong and misleading on the part of Lower Kopili PFR.

Besides, some of the EAC statements are not complete and stand in contradiction to each other. The EAC said that as the site specific seismic study had been completed by IIT Roorkee and considered it appropriate for 120 MW project. But it also mentioned “The project specific geo-morphological and neo-tectonic mapping has not been done so far. As the project area falls under the active seismic zone where the Disang-Naga Thrust and Dhauki fault merge which triggers high seismic risk, the proponent is to monitor the MEQ studies by installing a 3-4 seismograph network for a period of one year.” When EAC is aware of these site specific details, allowing an additional big dam in the area will only to increase disaster potential in the area. EAC needs to keep this in mind while considering this new dam.

Issues Tribal Land Relations: In the item 2.1 of the Form 1 the project authorities have stated that the 620 ha that will be submerged due to this project consists of medium to high density vegetation, scrubs open and barren land etc. But Dima Hasao people have expressed their fears of not getting proper rehabilitation.[7] The project seems to ignore this fact in the form 1. There can another reason also for the stating the submerged land as government land because the land holdings may not same as the ‘patta’ lands.[8] Besides, the area which has been considered for the construction of the dam is inhabited by Dimasa people who mainly depended on the system of shifting cultivation.[9] It is to be noted that in shifting cultivation there a cultivator cannot exercise permanent ownership over the land.

Defining ‘Other Forests’: The project as stated in item 1.1 of form 1 will also submerge 65 ha cultivation land. In the same item it is mentioned that an area of 585 ha will be submerged and this area has been mentioned as ‘other forests’. But the Form 1 did not define what this ‘other forests’ are or what they consists.

Impact on the Local People: In a memorandum submitted jointly by the Karbi Students’ Association (KSA), Sominder Kabi Amei (SKA) and Karbi Nimso Chingthur Asong (KNCA), to the State Power Minster Mr. Praduyut Bordoloi, the association demanded first preference in terms of employment should be given to the locally affected people. But the track record of dam building companies is very poor in this regard. The local people did not get promised employment and other benefits the in the Kopili project which came up in 1970s, 1980s and 1990s. On 20th March 2012, the Dimasa Students’ Union, Dimasa Welfare Association, Karbi Students’ Association and Sengia Tularam Club called for a 48 hours Umrangso bandh seeking “60 per cent of technical and non-technical posts in the project should be reserved for the local tribal populace, 100 per cent reservation for local tribal youths for Grade III and Grade IV posts, free electricity for locals, free treatment facilities in NEEPCO-run hospitals and so on.”[10] This is very crucial issues but surprisingly it finds no place in the PFR document.

Why the size of forest area significantly reduced: In the revised Form I and PFR, submitted on 23 August 2013, Section 1.1 mentioned that out of 1577 ha which is the total land required for the project, 552 ha will fall under submergence and 340 ha forest land will  be submerged in the reservoir. But the previous Form I and PFR, submitted on 14th November 2012, stated in the same section that the land falling under submergence and land converted into reservoir area is same i.e. 620 ha. The revised document does not give any rationale for reducing size of submergence area and reservoir area. It is also surprising to note that in the revised document, under the section “Impacts due to damming of river” in page 55, the old figures of submergence has been reiterated – “The  damming  of  river  Kopili  due  to  the  proposed  hydroelectric  project  in  creation  of  620  ha  of submergence  area.” So the new documents submitted in Aug 2013 have serious contradictions.

Issues Need to be Included in EIA report

Since several critical issues were not included in the previously submitted document, we have listed out the following issue which should be included in the Environment Impact Assessment (EIA) study of the proposed Lower Kopili HEP. Without detail analysis of all these issues EIA cannot be considered as complete.

Downstream Impact Assessment:  Downstream impact assessment is a burning problem in Assam. The state has already witnessed huge protests against dams due to lack of proper downstream impact assessment. In case of proposed Lower Kopili HEP, the EIA document should do a proper downstream impact assessment. In order to do a thorough downstream impact assessment, the EIA will have to go beyond the 10 km radius and assess the full downstream area. In case of Lower Kopili, going beyond 10 km downstream becomes all the more significant because major part of the Kopili river basin is in the downstream of the dam. The downstream impact assessment should specifically focus on the impacts of the dam on fisheries and livelihood of the people who are dependent on fisheries, change in character of flood and impacts thereof, change in sedimentation and impacts thereof, change in geomorphological issues, change in groundwater recharge, among others. The EIA should find which section of people will be affected the most by the dam and how to compensate those people.

It has been reported that bank erosion by the Kopili River has increased after the construction of the Kopili dam. The EIA report of Lower Kopili HEP, should do an analysis to find what will be impacts of the new project on river bank erosion.

Impacts Peaking Power Operations: The EIA should do a detail assessment of impacts of peaking power operation during non-monsoon months. Due to peaking power generation in non-monsoon months the river stretch downstream from power house will have very little water for most hours of a day with sudden flows in the river only for a few hours. This flow fluctuation leads to many severe impacts including on aquatic bio-diversity, on safety, on river bed cultivation, on erosion, among others. This has severe socio economic impacts along with issues of safety of the people and their livestock in this stretch of the river. Therefore the EIA should do a detail assessment of impacts of peaking power generation.

Assessment of Optimum Reservoir Operation: The EIA should do an assessment to prepare an optimum reservoir operations plan for the project in order to minimize the downstream impacts if a disaster occurs. It is also highly recommended that the local people should be made a part of the reservoir operations process. Then only the dam authorities can be expected to be more responsible to in reservoir operations.

Impacts of Silt Management operations: The EIA should include detail analysis impact of changing silt flows downstream from desilting chamber, from silt flushing in monsoon, on the downstream areas. The EIA study should give detailed account of how the silt from the dam will be flushed out annually and what will be the impact of this in the downstream. The EIA should also include how the desilting chamber will be operated and what will be its impacts.

Detailed and Thorough Options Assessment: The EIA should do a thorough options assessment for the project. There can be several other cost effective options for power generation in that area and options assessment should look into al those.

Here we can take the case of solar power. A recent example of proposed 1000 MW solar power generation in Rajastan[11] has showed that for 1 MW installed capacity only 2 Ha of land is required and the cost per megawatt installed capacity will be 7.5 crores and electricity will be provided at Rs 6.5 per unit. Another proposed 25 MW solar power project in Assam[12] has similar figures.

At this rate, for a 120 MW (the target capacity of the proposed Lower Kopili HEP) solar power plant, the land required will be 240 ha. But for Lower Kopili HEP the land required is 1557 ha of land out of which nearly 900 ha will be used for the project even if we subtract 680 ha projected to be used for compensatory afforestation. This implies that for 1 MW installed capacity for the proposed dam the land requirement will be about 7.5 ha, about 3.75 times the land required for solar project of same capacity. Besides, the total cost for the Lower Kopili project is expected to be Rs. 1489.64 crores implying cost per MW installed capacity will be Rs. 12.41 crores, compared to Rs 7.5 cr for solar plant. Even if we were to put up 240 MW installed capacity of solar project, it would require 480 ha land, will not have impacts on the river, on people’s livelihoods, on forests, on climate change, and so on.

Increased Costs: It is important to note here that EAC in its 65th meeting in March 2013 discussing this projects had noted “In  comparison  to  other  HEPs  being  examined  recently,  the  cost  per  unit  of installed capacity of this project is almost double!” and this was said when the cost per megawatt installed capacity was Rs. 9.79 crores. Now in the revised document, the cost has gone up further to Rs 12.41 cr, the project proponent need to explain this further escalation from the earlier already high cost.

Groundwater Depletion in Downstream areas: People in the downstream of Kopili dam have reported that there has been depletion of groundwater in the downstream areas of Kopili dam. From a field visit done in the downstream areas of Kopili dam, it was reported that the ground water level at certain areas had reduced to 140 feet. River like Borapani, Kopili and Nisari dry up in the winters affecting the winter cultivations. Besides, wetlands which are known as Beel or Duba locally have disappeared. The reduction in groundwater can also be due to reduced groundwater recharge due to the dam. Impact of the dam on groundwater recharge should be a part of the EIA study.

Impacts of Tunneling and Blasting: The EIA should analyze the impacts of tunneling and blasting as these activities can increase in risk of landslide and disaster in a hilly area. Blasting in hilly area also will have impacts on water and people. These impacts should be thoroughly assessed by the EIA of the proposed project.

Impacts of Mining: The project will require large quantities of sand, coarse and fine granules and boulders. These are likely to be mined from the nearby areas. The EIA should include a study on the impacts of mining on the people as well on the local environment. Mining for the project will be done in the nearby areas and it will have severe impact on people as well as on the river, bio-diversity, hills, flora-fauna and aquatic bio-diversity etc. The study on the impacts of mining should include all these issues.

Impacts of Backwater Effects: The PFR of proposed Lower Kopili HEP states that Maximum Water Level (MWL) of the river is 229.60m where as the FRL of the reservoir is 226.0m. The MWL is thus 3.6m higher than FRL and this will have serious back water effects during the times of monsoon. The EIA must do an assessment of the submergence at MWL level and backwater effect measured at MWL and follow it up with an impacts analysis.

Detailed analysis about the existence of wetlands, watercourses and other water bodies: The revised PFR in page 17 under section ‘Environment Sensitivity’ states that there are no wetlands, watercourses and other waterbodies reported within the 15 km of the project. This statement seems incorrect. The EIA should do a detailed and thorough analysis regarding the existence wetlands, watercourses and other water bodies within 15 km of the project site.

 Impacts of Climate Change: The EIA of the proposed Lower Kopili dam should do a study of  possible impact of the climate change on the dam as well as on the Kopili river. Besides, it should also include the impacts of the dam on adaptation capacity of the local people.

Smaller Size Documents should be Uploaded for Public Dissemination: The EIA and other documents which would be uploaded on the internet should be about the size of 10 MB or less. The Revised Form I and PFR which uploaded on the MoEF website was 114 MB and it was difficult to download such a huge document even in a metropolis. These heavy documents will nearly be impossible to download from a small town or a village. The MoEF should insist from projects proponents that PP should be careful about this and should reduce the size (less than 10MB) documents for uploading from next time.


Parag Jyoti Saikia

with inputs from Himanshu Thakkar and Pooja Kotoky

Email –

South Asia Network on Dams, Rivers & People (

[2] Patowary, A., “The Kopili Hydroelectric Project, Downstream People Rise in Struggle” published in “Water Conflicts in Northeast India – A Compendium of Case Studies” edited by Das, Partha J. et. all, 2013

[5] Mahanta,  K. and et all (2012): “Structural Formation & Seismicity of Kopili Fault Region in North-East India and Estimation of Its Crustal Velocity” International Journal of Modern Engineering Research,Vol.2, Issue.6, Nov-Dec. 2012 pp-4699-4702

[6] ibid

[8] It is to be noted that in many of the tribal areas of Assam and India’s north eastern states, the tribal law of land is community of ownership of land and there are no government ‘patta’ system.

Yettinahole Diversion: An imprudent, Rs.100 Billion proposition

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

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.


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


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.


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.


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)

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

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

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

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

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 ( 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 engandgered Mahseer fish at Yenekal Fish Sanctuary, Kumaradhara RIver downstream proposed Yettinahole diversion. Photo: SANDRP

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:

  1. 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
  2. Affect downstream flows and riverine ecology of the Gundia, Kumaradhara & Netravathi Rivers
  3. It will submerge nearly a 1200 hectares of land, 50% forest land and 2 villages  for reservoir to be constructed at Devaranyadurga
  4. 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
  5. 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.

A joint letter has been issued by more than 14 organisations and individuals across Karnataka, urging the MoEF to appraise this project completely. Signatories include former Forest Advisory committee Member Dr. Ullas Karanth, Praveen Bhargav from Wildlife First, institutes like IISc, amongst many other. ( Reports on the Submission:,,

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 and Yettinahole Projects SANDRP

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 Kolar District during 1901-2001 Data Source: IMD, Graph: SANDRP

Annual Rainfall in Chikkaballapur District during 1901-2001 Data Source: IMD, Graph: SANDRP


Annual Rainfall in Kolar District during 1901-2001 Data Source: IMD, Graph: SANDRP

Kolar District, especially was once rich in water tanks and local harvesting measures. Average rainfall in Kolar is 750 mm, which is not low. According to the Karnataka Gazetteer, the district had, in 2012, only 2,095 tanks from the 35,783 tanks in 1968. Most of the tanks were a victim of siltation, encroachment and neglect.[5] Organisations like Gramvikas and Dhan Foundation have demonstrated how desilting and management of tanks in Kolar can secure water for drinking as well as for irrigation, cattle rearing, etc.[6] Some groups have worked on highlighting the positive impact of applying reservoir silt to crops, as an option to fertilisers and to facilitate desilting. Indian Institute of Sciences (IISc) has demonstrated that desilting these tanks in Kolar can not only help water security, but it can also reduce the incidence of fluorosis.[7]

River Rejuvenation: Long distance water diversion is not an answer to drying and dying rivers Rivers like Arkavathy are dying due to persistent pollution from industries and urban areas and also due to catchment degradation. How will waters from Yettinahole revive this situation? Local efforts, sound environmental and water governance however, can help this situation. But this is not being explored sufficiently.


Long-distance water transfer: problems and prospects

(From: Prof. Asit Bisaws, Long-Distance Water Transfer United Nations University, 1983)

If many of the past and present experiences on long-distance water transfer are reviewed critically, the following major issues emerge:

(1)                Mass transfer of water is often justified by considering only the direct cost of transporting water. Seldom are the values of services foregone by the exporting region due to reduction of their water availability, i.e. the opportunity costs of exported water analysed.

(2) Various other feasible alternatives to interbasin water transfer are often not investigated. There is a tendency within the engineering and economic professions to opt for technological solutions-“soft” options tend to be neglected. Since water resources development is dominated by these two professions, there is a tendency to opt for technological fixes before all viable alternatives are explored. Among possible options are:

-more efficient use of available water;

-re-use of waste water;

-better management of watersheds;

-improved integration of surface and groundwater supplies;

-changing cropping patterns.


Climate Change and Western Ghats:

Climate change Assessments like 4X4 Assessment of INCA have indicated that rainfall in southern Western Ghats, which also includes Netravathi and Gundia catchment is expected to fall in the coming years. This will affect water resource projects, crops, fisheries, etc. (×4-report-and-beyond/)

We cannot ignore these signals while planning expensive schemes at the cost of ecology and sociology which might prove to be inviable in a few years in face of climate change. Keeping all these factors in mind Karnataka needs to proceed extremely cautiously on Yettinahole diversion scheme.


VII.              In Conclusion

Environment and Social Assessment are basic prerequisites for a project of such massive dimensions.

All in all, looking at several serious issues associated with Yettinahole Diversion Project, it is urgently needed that:

  1. Project should undergo complete  Environment appraisal and Clearance scrutiny, as laid down by the  EIA notification, 2006
  2. Recommendations of the Western Ghats Expert Ecology Panel about avoiding inter-basin transfers in the Western Ghats should be adhered to.
  3. Options Assessment and cost benefit analysis, including the ecological costs of the diversion should be carried out and put in public domain.
  4. Downstream affected communities, including cities like Mangalore and estuarine fisher folk should be consulted during public hearings.
  5. 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.
  6. 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.
  7. 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.
  8. 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.

-Parineeta Dandekar, SANDRP  (

[1] Volume II, Part B, Estimates, Section: Estimates for implementation of the scheme: Drawings

[2] Minutes of the Meeting, 63rd EAC Meeting, MoEF held on 12-13th October 2012. Agenda Item 2.11 (B)

[3] Pteridophytes are plants from the fern family that reproduce by spores.

[4], Ichthyological Exploration of Freshwaters, Vol. 23, Number 4

Open letter to Rahul Gandhi as he lays foundation stone of Parwan Dam: A Dam meant for thermal power projects

Reports[1] indicate that Congress leader Rahul Gandhi is to lay foundation stone for the controversial Parwan Irrigation Project in Jhalawar district in Rajasthan (see the map above, taken from Down to Earth), before speaking at public meeting in Baran district on Tuesday, Sept 17, 2013. Detailed analysis of official documents and other reliable accounts indicate that this unnecessary dam is seemingly being pushed to supply water to some of the proposed thermal power projects in Baran and Jhalawar districts.


The project will require 12248 ha of land including submergence of massive 9810 ha of land as per conservative government estimates, displacing about 100 000 people[2] from at least 67 villages of Baran and Jhalawar districts in Hadauti region of Rajasthan. It will require at least 1835 ha of forest land, and will affect at least 2 lakh trees only on this forest land, lakhs of trees on non forest land will also stand destroyed. Most of the 1.31 lakh Ha of land in Baran, Jhalawar and Kota districts that is supposedly to get irrigation is already irrigated. These districts have average rainfall of 842 mm (Baran[3]), 923.5 mm (Jhalawar[4]) and 804 mm (Kota[5]), which is high by Rajasthan standards. If there is adequate harvesting of this rainwater, groundwater levels would certainly rise and remain sustainable with appropriate cropping pattern. This has happened in neighbouring Alwar and Jaipur districts.

This Rs 2000 crore dam with huge impacts is certainly not required for this purpose.

From all accounts, in reality the dam seems to be pushed for thermal power projects like the 1320 MW Kawai coal based thermal power project of Adani[6], 1320 MW coal based Chhabra[7] thermal power project of Rajasthan Rajya Vidyut Utpadan Nigam Ltd and the 330 MW gas based thermal power project of RRVUN at the same location. Very strangely, these projects applied for environmental clearance based on water supply from Parwan dam, even when Parwan dam does  not have all the required statutory clearances, and when work its yet to start. The MoEF should have refused to sanction these thermal power projects before Parwan dam was in place.

This action of the MoEF speaks volumes about poor environmental governance due to which the TPS were cleared based on water from a project that is yet to see even foundation stone or all necessary clearances! The allocation for thermal power projects has increased[8] from earlier 40 Million Cubic meters (MCM) to 79 MCM to 87.8 MCM and this is likely to increase further considering these allocations did not take into account the transmission and evaporation losses.

Manipulated clearance process In fact the Parwan dam still does not have all the necessary statutory clearances. A quick look at the way Parwan got various clearances:

Þ    Environmental Impact Assessment From the minutes of the 40th and 45th meetings of the Expert Appraisal Committee on River Valley Committee held in August and December 2010 it is clear that the EIA of the project did not have: Full social impact assessment, Full R&R Plan with Categories of Project affected persons and land for each category, Proper Dam break analysis, proper command area development plan with cropping pattern or necessary irrigation intensity (Only 14% kharif irrigation intensity provided as noted by EAC) and drainage plan, muck disposal plan. The basic facts in the EIA were wrong and the EAC should have rejected the EIA.

Þ    Contradictions in EIA The EIA is full of contradictory information. For example it says the forest land coming under submergence is 1608.59 ha when the FAC form A[9] says that submerging forest land is 1731.48 ha. This is a very big difference by any standards.

Þ    R & R Plan Firstly, there is such huge difference in the figures of displaced and affected people in various documents; it is clear there has been no credible social impact assessment. For example, EAC notes that 2722 houses to be submerged, 3002 (2142 in FAC factsheet in 0413) families to be affected, of which 461 tribal families. No R&R for non tribal families, which is completely unjust. Even for the tribal families there is no adequate provision of agricultural land. FAC sub committee accepts: “Most of these families do not belong to the notified Scheduled Tribes and also do not have any documentary evidence to prove that they are in possession of the forest land for a continuous period of minimum 75 years.” So most of the people will not even be eligible for resettlement or rehabilitation.

Þ    How many people are affected? About 1401 families with population of 8650 persons will be displaced fully while 741 families with 4172 persons will be displaced partially. The ST population comprises 340 families with population of 1524 persons fully displaced and 121 families population 882 persons are partially displaced. However, independent sources are saying that the project will affect more than a lakh of people. This is a huge difference. Track record of past projects shows that official figures are always gross under estimates.

Þ    EAC recommendation However, even when the responses to EAC’s fundamental concerns were not available, EAC recommended clearance to the project in December 2010. This showed how the EAC basically works as a rubber stamp.

Þ    Environment clearance After EAC’s recommendation, the MEF is supposed to issue Environmental clearance. However, a visit to MEF website[10] on September 16, 2013 shows no information about clearance to the project. We learn from other sources that the MEF issued clearance to the project in 2011, but since it is not put up on the MEF website as required under EIA notification and NGT orders, the project will remain open to legal challenge with 30/90 days of MEF putting up the clearance letter on MEF website.

Þ    Wildlife clearance The Standing Committee of the National Board of Wildlife in its 22nd meeting[11] held on April 25, 2011 considered the project. This was the infamous meeting[12] chaired by the then Union Minister of state (Independent Charge) of Environment and Forests Jairam Ramesh pushed 59 projects in two hours (average two minutes per project). He reportedly[13] said later that this was done under pressure, but the damage was done.

Þ    Dr M.K. Ranjitsinh[14] and Dr Divyabhanusinh Chavda[15] submitted dissent notes, but the minister had predetermined objective and did not listen to any argument. The NBWL decided to clear the project even without knowing if the Shergarh  wildflife sanctuary will be affected, how much water the downstream river will need, what will be the impact of the project on Jawahar Sagar Sanctuary, Rana Pratap Sagar Sanctuary or Chambal River Sanctuary or the project even had done basic options assessment or impact assessment.

Þ    Location with respect to Shergarh WLS One of the key issues about this project is the location of the project with respect to Shergarh Wild Life Sanctuary. As noted by the FAC sub committee, the Parwan Doob Kshetra Hitkari and Jangal Bachao Samiti has been saying that the dam site is right inside the Sanctuary. However, if the project were to affect the WLS, it would require a Supreme Court clearance. To avoid this, manipulations have been going on.

The Site Inspection Report[16] of Forest Advisory Committee noted this issue and conducted a joint inspection in June 2012. The SIR said after this exercise that the proposed dam is 150 m in the upstream of the boundary of the WLS. However, the Parwan Doob Kshetra Hitkari and Jangal Bachao Samiti have contested this conclusion and said there was manipulation in this exercise.

But the EIA of the project, as noted by the 40th and 45th EAC meeting said that the project is five km away from the Shergarh WLS (this itself shows how poor is the EIA and how poor is the appraisal by EAC. Shockingly, even the Environment Clearance letter of 2011 also reportedly says that the project is 5 km away from the WLS, another reason why the EC will remain open to legal challenge.) In June 2013 there was another attempt at resolving this dispute, but again due to heavy rains could not be resolved. Funnily, the NBWL, which should be most concerned about this issue, has shown no concern. Until this issue is satisfactorily resolved, the project cannot go ahead, it will remain open to legal challenge.

Þ    Recommendation of 25 cusecs release The NBWL condition that 25 cusecs (cubic feet per second) water should be released for the environment is not based on any assessment of water requirement for the river and biodiversity in the downstream, since such an assessment has never been done. It seems like another manipulation, based on the fact that Shergarh weir, 10 km downstream from the dam site, has storage capacity of 16 MCM, which is equal to release of 25 cusecs water!

Þ    Gram Sabha resolutions The FAC factsheet[17] agrees that there are contradictory gram sabha resolutions, one set against the project and another submitted by the project authorities in favour of the project. The resolutions submitted by the opposing committee, which is without vested interests, is likely to be correct. There should be an inquiry about the correctness of the gramsabha resolutions by an independent body.

Þ    Forest Advisory Committee The FAC considered the project in its meetings in Sept 2012 and April 2013 and recommended clearance in April 2013 meeting when all the fundamental issues remained unresolved.

Þ    FAC sub-committee A sub committee of FAC visited the project in March 2013. Their report accepts a number of serious anomalies. For example, it says: “FAC sub committee report says: “It (is) a fact that a major part of the command area of the project is presently irrigated by using tube wells… Though there is no mention in the EIA report and other documents, about 79 MCM water from the dam is proposed to be utilized for 1,200 MW and 2,520 MW thermal power plants being constructed at Kawai and Chhabra respectively, in Baran district… It has been accepted by the project proponent that approach road to the historic Kakoni temple will be submerged. Submergence of the approach road will hinder free movement of devotees to the said temple, which may result in public resentment.”

Þ    Forest Clearance After the FAC recommended forest clearance for the project in April 2013 in questionable circumstances, the MEF is supposed to issue in principle forest clearance and than after fulfillment of conditions in the in-principle clearance, it can issue final clearance. A perusal of the MoEF FC website[18] on Sept 16, 2013 shows that the site does not display any of the clearance letters. Our letter to the concerned MoEF officers on Sept 15, 2013 remains unanswered. We came to know through independent sources that in principle forest clearance has been issued in middle of August 2013, final forest clearance will take a long time.

Þ    Compensatory Afforestation Plan Full plan and maps of CAP have not been submitted, says FAC factsheet. It is not even known if the land for CA is free of encroachment, the DFO says it will be ensured when the possession taken, as reported in Factsheet in April 2013. CA land is in 32 villages in at least 32 pieces, the DFO has not even visited all the lands to ascertain if it is suitable for CA and yet DFO has given certificate that it is suitable for CA. This seems like typical case where CA has no chance of success as noted by CAG audit report on CA in Sept 2013. It is completely illegal of CCF, PCCF, state forest department, FAC or MoEF to consider the project without full CAP with all the required details verified on ground.

Þ    CWC clearance The Central Water Commission’s Technical Advisory Committee is supposed to clear all major irrigation projects. This TAC appraisal is supposed to happen only after all the final clearances are given as TAC recommendation is the basis for Planning Commission’s investment clearance. Since the Parwan project does not have the final forest clearance, it cannot be considered by the TAC of CWC. However, we learn that on Friday, Sept 13, 2013, TAC met and cleared the project.

Þ    Planning Commission Investment clearance Project cannot have the Planning Commission Investment Clearance since it does not have all other clearances in place. Without this clearance no funds can be allocated for the project from state or central plans.

Þ    Big irrigation projects not delivering As even Planning Commission and CAG has noted and as SANDRP has been showing through analysis for so many years, since 1992-93, net irrigated area by Major and Medium Irrigation Projects at National level has not seen any increase. There is little sense in spending massive amounts on such projects without understanding this reality. We hope Planning Commission, CWC, Rajasthan government and people concerned with this issue will take heed of this. Unless of course, if the intention is to create reliable reservoirs of water for thermal power projects, as seems to be case here, while pushing projects in the name of irrigation for Rajasthan farmers.

What all this means is that Rs 2332.52 crore project with Rajasthan’s fourth largest reservoir (after Bisalpur, Rana Pratap Sagar and Mahi Bajaj Sagar) is being planned without a proper appraisal or legally supportable clearances. Bull dozing ahead with such a  project which has huge social, environmental and economic costs is not only bound to keep it open to agitations, legal challenges and delays, but is also not likely to have justification in public eye. It can even be politically counter productive. Nehruvian era of trying to win elections through such so called temples of modern era is gone, and our politicians need to learn this fast.

It is hoped that better sense prevails and Mr Rahul Gandhi will ask the project to go through due process rather than laying foundation stone of this controversial project that has more questions than answers.

Himanshu Thakkar (

South Asia Network on Dams, Rivers & People (


[12] ““The NBWL members note that in their last meeting during Jairam Ramesh’s tenure as environment minister they were forced to clear most of the 59 proposals to start projects in protected areas – wildlife sanctuaries and national parks – in only two hours… Yet another fact of the same meeting was that 39 clearance proposals were received only two days prior to the meeting leaving very little time, and no working day, for the members to even glance through the proposals.” The NBWL members who have signed the letter include Biswajit Mohanty from the Wildlife Society of Orissa, Asad Rahmani of the Bombay Natural History Society, T R Shankar Raman of the Nature Conservation Foundation, Bivabh Talukdar of Aranyaak, M K Ranjit Sinh, Divyabhanusinh Chavda, Brijendra Singh, Valmik Thapar, Prerna Bindra, Bittu Sehgal, Mitali Kakkar and Uma Ramakrishnan.”

[13] “Jairam Ramesh later made public the fact that such clearances were “under pressure”.”

[14] “The Parvan major irrigation project, Rajasthan, which will submerge 81.67 of the Shergarh Wildlife Sanctuary and what is more, will result in the destruction of approximately 186443 trees, in a tree deficit State like Rajasthan. Furthermore, even though 25cusecs of water is proposed to be continuously released into the Chambal from the proposed dam, this project will result in a major diversion of water from the Chambal, which has already been identified as deficient in water flow to support the last viable populations of the endangered Gharial and the Dolphin, in the April 2011 report prepared by the Wildlife Institute of India at the instance of the MoEF. The report specifically recommends that no further diversion of water from the Chambal should take place if the future survival of the endangered aquatic species mentioned above, is to be secured. There is also no EIA of the project, with regard to the impact upon the aquatic life and ecology of the downstream Jawahar Sagar Sanctuary, Rana Pratap Sagar Sanctuary and the National Chambal Sanctuary”.

[15] “With regard to Parvan major irrigation project in Rajasthan, please record that I had pointed out at the meeting that nearly 2 lac trees need to be inundated/chopped for the purpose. Though I did not mention it then, I feel very strongly that proper EIA of the project must be done.”

CAG Review of Flood Control measures in Bihar: When will Auditors learn about ecology?

CAG Review of Flood Control measures in Bihar:

When will the auditors learn about Ecology?


Recently tabled CAG (Comptroller and Auditor General of India) audit report on Bihar contains a performance review of implementation of flood control measures[i] in this most flood prone state. Most of the rivers in North Bihar originate in the Himalayan range in Nepal and cause floods in downstream Bihar with recurrent frequency. 73 percent of geographical area in Bihar is said to be under the threat of flood every year and 16.5 percent of total flood affected areas of India is located in this state.

On reading this performance review, one gets an idea of how CAG audit teams’ knowledge base on flood issue in Bihar relied heavily on Ganga Flood Control Commission (set up by Government of India in April 1972) recommendations, Bihar Flood Management Rules of 2003, Guide on Flood Management Programmes issued by Govt of India etc. However, the performance audit fails to draw upon the numerous writings by Dinesh Mishra of Barh Mukti Abhiyan (Freedom from Floods campaigns) and others. The performance audit also fails to draw upon the recommendations in the civil society fact finding mission following the massive floods due to Kosi embankment breach at Kusaha in Nepal[ii], Kosi Deluge: the Worst is Still to Come.

So when a performance audit report fails to draw upon the writings from ecologists and environmental historians, what recommendation flows from it? The same that would have flowed from the various official Ganga Flood Control Commission (GFCC) reports: build high dams in Nepal to trap the silt, at Barah Kshetra and on the tributaries of the river Kosi, a reservoir with adequate flood cushion at Noonthore on the Bagmati river, three dams over the river Gandak and a multipurpose reservoir at Chisapani on the river Kamla Balan. It is out of this blind faith in looking at high dams as providing flood control and flood cushion solution that CAG audit raised an audit observation that Bihar had failed to prepare even the Detailed Project Report on these proposed dams. The reply that state flood control department filed in November 2012 stated that a Joint Project Office was established at Biratnagar (Nepal) to study the feasibility of proposal of dam on Bagmati, Kamla Balan and Kosi rivers and the DPR of dam at Barah Kshetra was expected to be prepared by February 2013. The audit could have raised the question about the appropriateness of spending money on such futile exercise.

Misplaced faith in structural solutions Dinesh Mishra responds to this fallacy of the auditors stating, “The CAG report repeats what is told to it by the Govt. of Bihar (GoB) as the long term plan that was proposed for the first time in 1937 and nearly eight decades later the proposal is still under ‘active’ consideration of the two governments. Neither the GoB nor the CAG brings out this fact that there is massive resistance to any dam building in Nepal and more so if it is done by India. That is the reason why it has taken 16 years to work on the DPR so far without getting the same ready for any negotiation.” Dinesh Mishra adds, “There is no talking about seismicity, downstream impacts of large dams and strategic defence of the dam itself. We are not sure whether these structures would ever be built, but it is a carrot dangled before the flood victims of the state as if once the dam is built, all the flood problems of the state will be solved” (emphasis added).

No review of reasons for the Kosi disaster of 2008 Also missing from performance review are references to reasons for massive floods in the year 2008 following the breach in Kosi embankment at Kusaha and the pending recommendations by the still ongoing enquiry committee of Kosi High Level Commission. The audit fails to go indepth into how improper maintanance of the embankment lead to this flood disaster, who were responsible for improper maintanance and what system is needed to ensure such blunders are not repeated in future. The audit could have also gone into the role played by GFCC, Kosi High Level Committee and others in the Aug 2008 Kosi flood disaster. The audit continues to display an understanding that looks at more and more embankments straight jacketing the river, or unproved technological remedies such as Intra Linking of Rivers as potential solutions. Hence it raises questions on the non-completion of DPRs on Intra-linking of rivers and on completion of only 61.47 kms embankment against the target of 1535 kms as envisaged in the 11th Five Year plan.

Need to audit CWC’s flood forecasting performance The audit report does however mention those long term non-structural measures, such as flood plains zoning bill and establishment of flood forecasting units at field levels in upstream Nepal that were also recommended in 2004 by GFCC. The audit scrutiny showed that the state water resource dept had failed to enact flood plain zoning bill as well as in establishing flood forecasting units at field levels in all 16 test checked divisions out of 60 flood control divisions. The Audit should have also looked at the quality and use of flood forecasting by the state government and central agency like the Central Water Commisssion. CWC’s flood forecasting and its role in other aspects of flood management in Bihar also need a performance appraisal urgently. The Role played by Farakka Dam in creating backwater effect in Bihar, thus prolonging the flood duration in Bihar and also increasing the height of floods is another aspect that needs scrutiny.

Non implementation of Flood Plain Zoning Bill The flood plain zoning bill would have provided framework for regulation of development activities with the help of flood management maps. In November 2012, replying to this audit observation, department sought to justify its inaction by arguing that flood plain zoning is “impracticable and hindrance in the pace of development of state”. In the wake up of recent disaster in Uttarakhand, Bihar as well as other states would do well to give up on this misconceived tactic of shooting down any advocacy for environmental regulations by terming it as arresting ‘the pace of development’.

Bihar evaluating detention basin DPRs? The audit also pointed out that the suggestion of creating detention basins, i.e. adapting natural depressions/ swamps and lakes for flood moderation was not implemented by the dept as they had neither identified any sites nor released any funds to any divisions to undertake this work during 2007 to 2012. When this was pointed out by CAG auditors, the dept replied in August 2012 claiming that the DPRs of detention basins was under evaluation and final plans would be prepared by December 2012. However, till February 2013, no further progress on this was communicated by dept.

The audit also observed very serious deficiencies in financial management by the department. During the five year period 2007 to 2012, the dept had failed to utilise 11 to 44 percent of the available funds mainly due to delayed/ non-sanctioning of the schemes, delay in land acquisition, opposition by local people and non-passing of bills by the treasuries. Worse still, audit scrutiny showed that the dept had made 30 allotments amounting to Rs 47.47 crore to divisions on the last day of financial year.

Audit scrutiny of flood protection scheme revealed that the contract management of the dept was deficient as was evident from the cases of non-publicity of tender, allotment of works to ineligible contractor, loss to government owing to undue favour extended to a particular contractor and loss of Rs 103 crore due to non-availing of the benefit of competitive bidding in execution of Bagmati extension scheme. Audit also noticed other deficiencies such as non adherence to flood calendar in 44 percent of test-checked works, infructuous expenditure worth Rs 68.50 crore in four test-checked divisions and excess payment of Rs 6.25 crore in two test-checked divisions. Audit also pointed out that dept had incurred an unfruitful expense of Rs 20.21 crore due to abandoning, closure/ postponement of zamindari bandh in two test-checked divisions.

The office of CAG of India has indulged in lot of talk around the idea of environmental auditing. An International Centre for Environment Audit and Sustainable Development was inaugurated at Jaipur in May 2013 and the office of the CAG of India has held a few consultations on environment auditing in recent past. However, performance reviews such as this one clearly points out the need for CAG auditors to equip themselves better in the realm of understanding the ecological aspects around flood, flood plains and flood management; rather than simply drawing up from the reports in official domain such as Ganga Flood Control Commission etc. Will the newly appointed head of India’s Supreme Audit Institution devote his labour to this urgent tak?

Himanshu Upadhyaya

(Author is a research scholar at Centre for Studies in Science Policies, JNU, New Delhi.)

Huge Impacts, but no assessment? Groups urge MoEF to correct its blunder on Yettinahole

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.



Smt. Jayanthi Natarajan,

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

Paryavaran Bhawan, Lodhi Road, New Delhi,


Dr V Rajagopalan,


Union Ministry of Environment and Forests, New Delhi,


Maninder Singh

Joint Secretary,

Union Ministry of Environment and Forests, New Delhi,

Mr. B. B. Barman

Director (IA) River Valley Projects,

Union Ministry of Environment and Forests, New Delhi,


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.

  1. 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.
  2. 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.
  3. 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.
  4. Gravity Canal from Harvanahalli (Sakaleshpur) to Tumkur will require a minmum of 400 hectares land
  5. 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.


Thanking you,


Yours Sincerely,

Niren Jain, Kudremukh Wildlife Foundation, Mangalore, Karnataka (

Dr. Ullas Karanth, Director, Centre for Wildlife Studies, Bangalore

Praveen Bhargav, Trustee, Wildlife First, Bangalore

Kishore Kumar Hongadhalla, Malanada Janapara Horata Samiti, Sakaleshpura, Karnataka

Panduranga Hegde, Parisara Sanmrakshana Kendra, Appiko Movement, Sirisi, Karnataka

Dr. T.V. Ramachandra, Energy and Wetlands Group, Centre for Ecological Sciences, Indian Institute of Science, Bangalore, Karnataka

Vishwanath Srikantaiah, Water and Rainwater Harvesting Expert, Bangalore, Karnataka)

Dr. Jagdish Krishnaswamy, Eco-hydrologist, Bangalore, Karnataka

Dr. Shriniwas Badiger, Water and Irrigation Expert, Bangalore, Karnataka

Dr. Bhaskar Acharya, Bangalore, Karnataka

Dr. Sharad Lele, Atree, Bangalore, Karnataka

Nachiket Kelkar, Wildlife researcher, Bangalore, Karnataka

Vidyadhar Atkore, Fisheries Scientist, Bangalore Karnataka

Neeti Mahesh, Mahseer Trust, Karnataka

Parineeta Dandekar (,09860030742), andHimanshu Thakkar (, 09968242798) South Asia Network on Dams, Rivers and People, Delhi and Pune



Reconstituted Expert Appraisal Committee on River Valley Projects: MoEF has neither environment sense, nor guts: Unacceptable Committee

Press Statement                                                                                             September 7, 2013

Reconstituted Expert Appraisal Committee on River Valley Projects:

MoEF has neither environment sense, nor guts: Unacceptable Committee

On Sept 5, 2013, Union Ministry of Environment and Forests came out with “Re-constitution of Expert Appraisal Committee (EAC) for River Valley & Hydro Electric Project” (see: Mr Alok Perti, former Coal Secretary, has been made chairperson of the committee that appraises all major irrigation projects, dams, hydropower projects and river valley projects for Environment clearances at two stages (TOR and final). It is shocking to see that Mr Perti who has absolutely no environment credentials, who has been known to be anti environment, who has been accusing the environment ministry to be in road block of coal mining and who has shown his ignorance of environment issues on several occasions has been selected as chair person, putting aside basic environmental sense. This reconstituted EAC on RiverValley and Hydropower projects is completely unacceptable.

It is equally disturbing to see that the committee has no woman representation, no sociologist, no one from non-government organisations. All ten members are either from government, government organisations or government funded academic organisations. This means that none of them would be in a position to take a stand independent of the government stand. The committee also has no river expert, climate change-water expert or disaster management expert, all of which are crucially important issues for a committee like this that decides the fate of India’s rivers, even more so after the Uttarakhand disaster. P K Chaudhuri, one of the members of the new committee also has had nothing to do with rivers, water or environment. Hardip S Kingra, who was involved in Commonwealth games organisation and also chairman of National Scheduled Castes Finance and Development Corporation has had no work related to rivers or environment.

Specifically, Mr Alok Perti, who has been senior functionary, including secretary of currently controversial Coal Ministry from Oct 2009 to earlier this year and before Oct 2009 in ministries like defense and family welfare, clearly has had no background on environment or rivers. As coal secretary, he had accused MoEF for stalling the growth by not giving clearances to coal mining projects automatically. The Economic Times quoted Perti as saying in a report[1]: “India has to decide whether she wants electricity or tigers.” Such simplistic statements reflect he has absolutely no understanding of environment, biodiversity, leave aside rivers. Perti’s anti civil society stance was also exposed when he refused to discuss issues with activists and asked them to go and file RTIs[2]. These are only a couple of examples we are giving here, there are many others. By appointing such a person as chairman of the EAC on RVP, the MoEF has shown it has no guts or interest in protecting the environment or forests which is supposed to be its mandate. This committee is clearly unacceptable and will also not stand legal scrutiny.

Ritwick Dutta (, 09810044660, ERC and LIEF, Delhi)

Parineeta Dandekar (, 09860030742, SANDRP, Pune)

Himanshu Thakkar (, 09968242798, SANDRP, Delhi)

Manoj Mishra (, 09910153601, YJA, Delhi)



9 Sept 2013


Smt. Jayanthi Natarajan,

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

Paryavaran Bhawan, Lodhi Road, New Delhi,


Dr V Rajagopalan,


Union Ministry of Environment and Forests, New Delhi,


Maninder Singh

Joint Secretary,

Union Ministry of Environment and Forests, New Delhi,


Mr. B. B. Barman

Director (IA) River Valley Projects,

Union Ministry of Environment and Forests, New Delhi,


Subject: Urgent concerns about reconstituted Expert Appraisal Committee on River Valley Proejcts


Respected madam and sirs,


On Sept 5, 2013, Union Ministry of Environment and Forests came out with “Re-constitution of Expert Appraisal Committee (EAC) for River Valley & Hydro Electric Project” (see: Mr Alok Perti, former Coal Secretary, has been made chairperson of the committee that appraises all major irrigation projects, dams, hydropower projects and river valley projects for Environment clearances at two stages (TOR and final). It is shocking to see that Mr Perti who has absolutely no environment credentials, who has been known to be anti environment, who has been accusing the environment ministry to be in road block of coal mining and who has shown his ignorance of environment issues on several occasions has been selected as chair person, putting aside basic environmental sense. This reconstituted EAC on River Valley and Hydropower projects is completely unacceptable.


It is equally disturbing to see that the committee has no woman representation, no sociologist, no one from non-government organisations. All ten members are either from government, or from government organisations or government funded academic organisations. This means that none of them would be in a position to take a stand independent of the government stand. The committee also has no river expert, climate change-water expert or disaster management expert, all of which are crucially important issues for a committee like this that decides the fate of India’s rivers, even more so after the Uttarakhand disaster. P K Chaudhuri, one of the members of the new committee also has done no work with rivers, water or environment, going by his CV. Hardip S Kingra, who was involved in Commonwealth games organisation and also chairman of National Scheduled Castes Finance and Development Corporation has had no work related to rivers or environment.


Specifically, Mr Alok Perti, who has been senior functionary, including secretary of currently controversial Coal Ministry from Oct 2009 to early 2013 and before Oct 2009 he has been in ministries like defense and family welfare, clearly has had no background on environment or rivers. As coal secretary, he had accused MoEF for stalling the growth by not giving clearances to coal mining projects automatically. The Economic Times quoted Perti as saying in a report[1]: “India has to decide whether she wants electricity or tigers.” Such simplistic statements reflect he has absolutely no understanding of environment, biodiversity, leave aside rivers. Perti’s anti civil society stance was also exposed when he refused to discuss issues with activists and asked them to go and file RTIs[2]. By appointing such a person as chairman of the EAC on RVP, the MoEF has shown it has no interest in protecting the environment or forests which is supposed to be its mandate. This committee is clearly unacceptable and will also not stand legal scrutiny.


Under the circumstances, we demand that:

1. The notification (No. J-12011/EAC /2010-IA-I dated Sept 5, 2013) of reconstitution of the EAC be cancelled;

2. A participatory process be initiated for reconstitution of the EAC with the norms some of suggested in our letter to you dated June 29, 2013, see:;

3. The EAC meeting slated for Sept 23-24, 2013 should be cancelled.


We will look forward to early reply from you.


Thanking you,


Prof. M. K. Prasad, Kerala Sastra Sahitya Parishad, Cochin

Ramaswamy R. Iyer, former secretary, Government of India, Delhi.

Madhu Bhaduri, former ambassador, Delhi.

Ravi Chopra, People’s Science Institute and member NGBRA, Dehra Doon

Ritwick Dutta, ERC and LIEF, Delhi.

Manoj Mishra, Yamuna Jiye Abhiyaan, Delhi

Prof. S. Janakarajan, Madras Institute of Development Studies, Chennai,

Vimal Bhai, MATU jansangathan, Uttarakhand

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune,

10. Latha Anantha, River Research Centre, Kerala

Sujit Patwardhan, Parisar, Pune

Debi Goenka, Conservation Action Trust, Mumbai

Souparna Lahiri, All India Forum of Forest Movements, Delhi.

Rohit Prajapati, Paryavaran Suraksha Samiti, Gujarat   –

Soumya Dutta, Climate & Energy Group, Beyond Copenhagen collective, Delhi

Joy KJ, Society for Promoting Participative Ecosystem Management, Pune

Anurag Modi, Shramik Adivasi Sangathan, Betul, Madhya Pradesh

Dr Brij Gopal, Centre for Inland Waters in South Asia, Jaipur,  

Rahul Banerjee, Dhas Gramin Vikas Kendra, Indore

20. Subhadra Khaperde, Kansari Nu Vadavno, Indore

Shankar Tadwal, Khedut Mazdoor Chetna Sangath, Alirajpur

Samantha Agarwal, Chhattisgarh Bachao Andolan, Raipur, Chhattisgarh.

Dr V Rukmini Rao, Gramya Resource Centre for Women, Secunderabad.

Tarun Nair, Researchers for Wildlife Conservation, Bangalore.

Shankar Sharma, Mysore

C.G. Madhusoodhanan, Research Scholar,Indian Institute of Technology Bombay

Pushp Jain, EIA Resource and Response Centre, New Delhi

Gopakumar Menon, Wildlifer, Bangalore.

Gopal Krishna, Toxics Watch Alliance, Delhi.

30. Jai Sen, CACIM, New Delhi,

Samir Mehta, International Rivers, Mumbai

E Theophilus, Malika Virdi, K Ramnarayan, Himal Prakriti, Munsiari, Uttarakhand,

Neeraj Vagholikar, Kalpavriksh, Pune,

PT George, Intercultural Resources, Delhi,

Akhil Gogoi, President, Krishak Mukti Sangram Samiti, Assam,

Subir Bhaumik, Veteran Journalist and author of “Troubled Periphery: Crisis of India’s Northeast” (Sage, 2009),

Ravindra Nath, Rural Volunteers Centre (RVC), Akajan, Dhemaji, Assam,

Sanjib Baruah, Professor, Bard College, New York,

Shashwati Goswami, Associate Professor, Indian Institute of Mass Communication,

40. Mrinal Gohain, ActionAid, Guwahati,

Keshav Krishna Chatradhara, Peoples Movement for Subansiri & Brahmaputra Valley (PMSBV), Assam,

Girin Chetia, North East Affected Area Development Society, Jorhat, Assam,

Azing Pertin, Echo of Arunachal, Arunachal Pradesh,

Parag Jyoti Saikia, SANDRP, Delhi.

Parineeta Dandekar, SANDRP, Pune.

Additional names in letter sent independently by CORE ( on 190913) :

46. Centre for Organisation Research and Education (CORE)

Reformed Education and Development Society (READS) Manipur

Forum for Indigenous Perspective and Action (FIPA)

Action Committee  Against Tipaimukh Project (ACTIP)

50. All Loktak Lake Areas Fishermen’s Union Manipur (ALLAFUM)

All Manipur Thanga People’s Welfare Association (AMTPWA)

Rural Education and Action for Change Manipur (REACH-M)

All Tribal Women Organisation(ATWO)

Weaker Section Development Council(WSDC)

Rongmei Luh Phuam (Assam, Manipur and Nagaland)


River Basin Friends North East

58. Anthony Deb Barma of Borok Peoples’ Human Rights Organisation (BPHRO), Tripura

Himanshu Thakkar, South Asia Network on Dams, Rivers & People, c/o 86-D, AD block, Shalimar Bagh, Delhi)