Uttarakhand Deluge: How human actions and neglect converted a natural phenomenon into a massive disaster

Analysing a natural disaster is a complex task. Many a times, a natural disaster and its human impacts are a result of multiple things occurring together. At the same time, disasters like the one being faced by Uttarakhand currently highlight the stark anthropogenic reasons which contribute towards causing the disaster as well as increasing its impacts manyfold.

SANDRP has been trying to analyse the situation, and looking at number of causes which precipitated in the current tragedy. These include the absence of early warning system, absence of responsible and active disaster management of monitoring system. While the calamity is natural in the sense that the region did receive extreme heavy rainfall and cloud burst, the root causes which increased the human tragedy include unchecked and unplanned infrastructure development along the rivers and development of  hundreds of hydel projects in the fragile zone without proper checks and balances, transparent studies and decision-making processes.

A brief update on SANDRPs work on this issue as well a compilation of the numerous ways in which hydel projects in Uttarakhand are flouting norms of sustainability, transparency, participation or safety and what has been the response to this from the highest quarters: Prime Minister, Minster and Ministry of Environment and Forests as well as the state administration.

The first thing that strikes you when you analyse this disaster is that there was no specific and timely warning of impending disaster from the IMD or any other body (their claim to the contrary not withstanding). In fact we do not have a system in place to forecast cloud burst events, when technology is available to achieve that at approximate cost of Rs 15 crores, as informed to me by formed Director General of IMD, Dr S K Srivastava.

Secondly, even after the event of rainfall started and occurred, till date, six days after the event started on 15th, there is no account of how much rainfall occurred at what specific locations, and what was done to alert the populations that were at risk. This is again a failure of IMD and local administration. In fact it transpired that Kedarnath, one of the most affected area, has no raingauge, says Indian Express.

This shows how agencies like IMD, CWC, NDMA and SDMA have failed to put in place basic systems of warning, forecasting, monitoring and information dissemination that can greatly reduce disaster potential of any area.

In April 2013, a CAG report said that Uttarakhand state disaster management authority, which was formed in Oct 2007, has never met till date. Nor has it mandatory “rules, regulations, polices or guidelines”, first step for the authority to have functional existence. (for elaborate excellent information on this CAG report, see:, for CAG report, see:



From all accounts it is clear that areas around all four Pilgrimage centres (Gangotri, Yamunotri, Kedarnath and Badrinath) and the fifth one of Hemkunt Sahib have faced some serious floods this season. In addition, areas of Pithoragarh (Goriganga basin) and Himachal Pradesh (Kinnaur district, mainly Kashang area, a tributary of Sutlej) basin also faced floods during the same period. The rainfall event that lead to these floods started on June 15 and went on till June 16-17.  It seems strange to see such vast area facing simultaneous high intensity rainfall. IMD officials tried to explain this ( as collision of western disturbance with the upcoming monsoon clouds. It is also true, as Anupam Mishra ji explained to me that the catchments of all these basins in their uppermost ranges are not too far from each other. Incidentally, Tibetan area is also not very far from these region, it would be interesting to know if that area also faced cloud burst events in this period.

In an interview with Rediff Editor Sheela Bhatt, NDMA Vice Chair M Shashidhar Reddy accepted that there are no rain-gauges at Kedarnath and Badri nath and hence we may never know how much rainfall feel at those sites and we will never have full scientific explanation of what happened on June 16-17.

The best we have is weekly district wise rainfall in Uttarakhand districts for the week June 13-19, from India Meteorological Department:


13.06.2013 TO 19.06.2013




    % DEP



































































Events of June 16-17 at Kedar Nath Based on Media information, it seems Kedarnath shrine saw two massive flood events, one starting around 8.15 pm on June 16 and second at 6.55 am on June 17. The flood witnessed at the shrine (located at 3584 m above msl) originated from catchment that includes two mountain peaks: Kedarnath and Kedarnath Dome (6831 m elevation). Following torrential rains possibly triggered by cloude burst, huge boulders broke away from Kedar Dome and ruptured the downstream charbari lake reservoir, about 6 km upstream from the temple along the Mandakini river. This description seems to suggest that this was also an event of GLOF (Glacial Lake Outburst Flood), though no one seems to have used that term so far.

Another instance of GLOF in this Uttarakhand flood disaster could have happened at Hemkunt Sahib pilgrim centre (elevation 4632 m), where report suggest, the level of water in the lake surrounding the shrine suddenly “increased as glacier from the uphill came down.”

However, from all accounts, the massive rainfall and cloud burst events were happening at multiple places, including in Bhagirathi basin, Assiganga basin, Mandakini Basin, Badrinath region, other places in Alaknanda region, among others. The high rainfall started sometime on June 15 and went on till at least June 18. When I talked with Prof Bharat Jhunjhunwala staying at Devprayag along the confluence of Bhagirathi and Alaknanda, he said that the peak of the floods happened on the morning of June 17 (The Hindu reported this happened at 3 am on 17th), though massive flood event there in Alaknanda started the previous evening. He also mentioned that the massive amount of muck deposited on the Alaknanda riverbed by the under construction 330 MW GVK Srinagar Alaknanda Hydropower Prooject (the project has had no credible environmental impact assessment) accentuated the flood disaster in the downstream area. The Hindu reported ( that sudden release of water from the dam along with the illegally dumped muck in the river bed lead to disaster in downstream Srinagar town.

A Sphere India report said that in Rudraprayag (this is likely to be one of the Mandakini hydropower projects, either Phata Byuang or Singoli Bhatwari), “The local are saying the muck of the dam was deposited along the river which has diverted the course of water.” (

It is interesting to note that if these accounts are correct, the peak of flood event at Devprayag and Kedarnath (separated by about 150 km) happened on the morning of June 17, which possibly indicates that there were multiple could burst or very high intensity rainfall events in Alaknanda valley alone.

However, I had already received a detailed report from Uttarkashi Apda Prabanthan Jan Manch with photos of unfolding disaster on the evening of June 16, 2013, so the high rainfall event and beginning of flood  disaster at Uttarkashi began much earlier. The news channels were already showing live footage of the event unfolding in downstream Rishikesh and Haridwar on June 17, again indicating that the flood event in the upstream mountains must have started at least two days earlier.

Unfortunately we still do not have an accurate account of this whole episode from any of the official agency. When Vice Chairman of National Disaster Management Authority M Shashidhar Reddy was asked about this by me on NDTV INDIA badi khabar programme on June 21 evening (see:, he accepted we still do not have that account six days after the event. This shows the poor monitoring situation from all concerned.

UTTARAKHAND AND GLOFS The mention of GLOFs in the context of current Uttarakhand floods above should trigger other thoughts. In fact not many observers are mentioning GLOFs in current context. However, Climate scientists including ICIMOD has been mentioning increasing risks of GLOFs all across Himalayas.

This blog ( provides satellite images from Indian Space Research Organisation to explain the occurrence of GLOF in the current disaster at disaster and its consequences in the downstream Rambara area. Its Author Dave Petley, dean of research and global engagement, Wilson Professor of Hazard and Risk at DurhamUniversity in the United Kingdom, tries to explain the events around Kedarnath in an interview to Rediff editor Sheela Bhatt:

Similar images are also available on Down to Earth article ( and NRSC website (

Anupam Mishra ji in fact mentioned in NDTV INDIA discussion ( mentioned is 1977 article (see in Hindi: where he describes the 1970 floods and also the 1893 glacial dam burst, flood due to bursting of which was monitored and local people alerted by the then British government in collaboration with local people.

Chorbari Glacier The Chorabari glacier that played a role in current floods in Kedarnath lies between latitudes 30°44′50″N and 30°45′30″N, and longitudes 79°1′16″E and 79°5′20″E, from an altitude of approximately 6,000 m (20,000 ft) at the slopes of Kedarnath peak, to 3,800 m (12,500 ft). The glacier is around 7 km in length, while the basin area of the glacier is approximately 38 sq km and the glacier ice cover is 5.9 sq km. The glacier slope is around 11 degrees and faces south. The glacier has two snouts. It is hypothesized by R. K. Chaujar that an original single glacier covered the area, which while receding, split into two snouts. One of the snouts is the source of the Mandakini River at 3,865 m (12,680 ft). The other snout, at 3,835 m (12,582 ft), drains into the Chorabari Tal. (

DAMAGED HYDRO PROJECTS A large number of hydropower projects are likely to have suffered damage due to the flood disaster in Uttarakhand and Himachal Pradesh. Some of the projects that have suffered damage include:

  • According to the update from on June 27, 2013, the 520 MW under construction Tapovan Vishnugad HEP has suffered damaged by rains on June 16, 2013: “While construction of diversion tunnel was completed in April this year, the same was washed away due to heavy rains on June 16. Diversion dyke has washed away and damages have been observed in chormi adit approach road. In August last year, the flash floods had caused serious damages in the coffer dam of the project.”
  • 400 MW Vishnuprayag HEP of JP Associates has suffered serious, but as yet unassessed damage (–as-plant-shuts-down-in-uttarakhand/1133083/). As per MATU PR (, the project has also been cause of damage in Lambagad village, which was also flahsed on front page of TOI on June 25, 2013, though without mentioning the project.
  • 76 MW Phata Byung HEP of Lanco in Mandakini Valley in Uttarakhand
  • 99 MW Singoli Bhatwari HEP of L&T in Mandakini Valley in Uttarakhand NDTV India reported that the water level of the river has gone up due to the silt dumped by dams. This is likely to be due to the Phata Byung and Singholi Bhatwari HEPs.
  • Kali Ganga I, Kali Ganga II and Madhyamaheshwar HEP, all in Mandakini Valley, all of UJVNL, all hit by mudslides (
  • Assiganga I-IV projects on Assiganga river in Bhagirathi basin in Uttarakhand
  • Small HEP in Goriganga basin in Pithoragarh (name not known)
  • 65 MW Kashang HEP in Sutlej basin in Himachal Pradesh
  • 280 Dhauliganga Project of NHPC in Pithoragarh district of Uttarakhand (reports said the power house was submerged, but is now working, part of the township was submerged.)

It has been now reported in Business Standard ( that the 330 MW Srinagar project, a cause for downstream destruction, has itself suffered massive damages on June 17, 2013, with breach of its protective embankment. The report also mentions the damage to the L&T’s Singoli Bhatwari HEP on Mandakini river.

Down to Earth ( has given some details of damage to some of the hydropower projects, quoting UJVNL sources. It says: 19 small hydropower projects have been completely destroyed, while others have been damaged by the raging waters (see BOX)

Estimated losses from damage to hydropower projects on the Ganga
Project Location Capacity Estimated Loss
Dhauli Ganga Pithoragarh  280 MW Rs 30 crore (project completely submerged)
Kaliganga I Rudraprayag 4 MW Rs 18-19 crore (power house and 4 houses washed away)
Kaliganga II Rudraprayag 6 MW Rs 16 crore (power house and 4 houses washed away)
Sobla Pithoragarh 8 MW Rs 14 crore (completely washed away)
Kanchauti Pithoragarh 2 MW Rs 12 crore (totally washed away)
Chirkila Pithoragarh 1.5 MW Rs 20 crore (part of the project washed away)
Maneri Bhali I&II Uttarkashi 304+90 MW Rs 2 crore + Rs 5 crore (walls collapsed, silt in barrages)

In addition, a large  number of projects had to stop generation temporarily due to high silt content, including Maneri Bhali I and II, Tehri, Tanakpur, Nathpa Jakhri, Karcham Wangtoo, among others.

NO LESSONS LEARNT FROM PAST DISASTERS In fact in August 2012, Uttarkashi district saw similar tragedy that left 29 dead, many more missing and collapse of houses like card board boxes. The Uttarakhand State Diaster Mitigation and Management Centre report of this disaster in Oct 2012 concluded, “It is therefore highly important to strictly regulate developmental initiatives in close vicinity of streams and rivers. Appropriate legislative interventions would be required for formulating a policy in this regard and firm executive action in accordance with letter and spirit of this policy would be required to ensure compliance of the same.”


Similarly in Sept 2012, Okhimath in Rudraprayag  district (one of the epicentres of current tragedy) saw monsoon induced landslides killing 69 people among other damages. That state DMMC report of this tragedy in Oct 2012 made made recommendations to reduce the risks of landslides in landslide prone state, one of them read, “Use of explosives in the fragile Himalayan terrain for infrastructure developmental works introduces instability in the rocks and therefore use of explosives should necessarily be banned.” And “This provision would automatically ban habitation in the close proximity of seasonal streams and rivers. In case people are already residing in such areas provision has to be made for their timely relocation.”


In fact Rudraprayag has faced monsoon related major disasters SEVEN times in last 34 years, including in 1979, 1986, 1998, 2001, 2005, 2006 and 2012, each involving death and destruction.

If implemented, these recommendations could have saved many lives. Each of the hydropower project in the state involves MASSIVE blasting of MASSIVE scale, but there is no regulation in place about this even after clear warning from state DMMC.

Uttarakhand Floods and Climate Change That the vulnerability of already disaster prone Uttarakhand to such events is increasing is well known.  Secretary of Government of India Ministry of Earth Sciences Shailesh Nayak has now said that  the cloudburst that triggered flash floods in Uttarakhand read like a weather phenomenon brought about by warming. He also narrated how the high intensity rainfall is increasing while low and medium intensity events are decreasing. (See:

In this context, all developmental activities in such areas will need to factor in this increased vulnerability and how any intervention is going to affect the disaster vulnerability of the region. We have been writing to the Union Environment Ministry and its expert Appraisal Committee on River Valley Projects that the Environmental Impact Assessments of the hydropower and other projects need to include an assessment as to how the projects would affect the adaptation capacity of the local people in changing climate and how climate change would affect performance of such projects. There has been no change in the working of the ministry on this so far, but we hope this disaster will provide a wake up call to change that urgently.

Recommendation of National Himalayan Mission ignored National Mission of Sustainable Himalayas, one of the nine missions under National Action Plan on Climate Change, had made a recommendation for protection of areas around the four pilgrimage sites of Gangotri, Yamunotri, Kedarnath and Badrinath by creation of spiritual and ecological buffer zones around pilgrim places in the ecologically-sensitive region. The mission noted that construction of roads should be prohibited beyond at least 10 kms from protected pilgrim sites, which could have reduced the number of casualties. These areas, like national parks and sanctuaries, were to be maintained as special areas, where there would be minimal human interference. These measures could have lessened the extent of damage in these area suffered during current floods. However, the recommendations have been completely ignored and rampant construction were carried out at char dham, as tourist inflow boomed over the years. From 2.15 lakh in 2000, the number of Kedarnath pilgrims increased to 5.75 lakh last year. (

Geological fault lines ignored Prof KS Valdiya, an honorary professor at Bangalore’s Jawaharlal Nehru Centre for Advanced Scientific Research, said the heavy loss of life and property in the deluge was a result of “criminal oversight” over the decades of the state’s geological features and water channels by various authorities. These features are well-mapped and documented. But engineers and builders choose to overlook them, said Valdiya. The geologist identified four major ways in which constructions flouted scientific norms. First, he said, the seismic fault-lines of this earthquake-prone state were not kept in mind while building roads (and other infrastructure). “These tectonic fault-lines, which are active and see back-and-forth movements, have been cut in many places by roads. More dangerously, roads are built along the fault-lines at many places. As a result, tiny seismic movements in the fault-lines weaken the rocks at the base of the roads, making these stretches susceptible to cave-ins and slides,” Valdiya said.

The second area of rampant neglect, he pointed out, was drainage. “I have never seen road engineers provisioning for draining out all rainwater that can possibly enter the stretch. Where one to two metre bridges are required, they build small culverts. At places where drains have been provided for, these are usually filled with debris.” Buildings have been constructed over old drains and streams, blocking the natural pathways of rainwater, he said. “One of the reasons for the devastation at Kedarnath was that people had constructed houses on the west stream of the Mandakini river that had been dry for decades. When the river returned to its old course following the deluge, these constructions were washed away,” he added.

Valdiya said another type of transgression, similar to the previous one, was construction taking place on river flood ways. A flood way is the area covered by the river at the time of its biggest flooding in the past 100 years. “In places along Alakananda/ Ganga such as Karnaprayag and Rishikesh, constructions have taken place on the lower terraces which are part of the flood way. Sooner or later, water would get to these places,” the expert said.

Lastly, Valdiya said roads have been built over the debris of previous landslides because it’s costlier to build paths higher up on the hills where the rock is firmer. “Sadly, the department geologists are often no more than rubber stamps, okaying everything the engineers say. Independent geologists are never consulted,” he said. “Scientific engineering has very low priority in the state,” he lamented. Unfortunately, the state pays with human lives and huge property losses because authorities do not pay attention to basic scientific principles. (

SANDRP’s On-ongoing analysis of the Hydel Power Development in Uttarakhand

Flash Flood of Hydel Projects in Uttarakhand: Uttarakhand is witnessing unprecedented development of Hydel Projects along its rivers: mainly Alaknanda, Bhagirathi and their tributaries as well as Ganga, Gori Ganga, Kali Ganga etc. Though exact estimates are not available, activists like Ravi Chopra have said that there are close to 680 dams in various stages of commissioning, construction, planning in the hill state.

Some maps on the Uttarakhand river basins that contain location and details of the hydropower projects (as in 2011, the maps do not have all the projects, but only those for which we could find details when they were made):

Throughout their lifecycle, from construction, deforestation, blasting, mining, obtaining materials from river bed for construction, muck disposal, debris dumping, damming, altering hydrological cycle to allied activities like colonies, roads, infrastructure deevlopment, Hydel power plants have a profound impact on geology and hydrology of the region.

Dams in various stages in Alaknanda and Bhagirathi Basins in Upper Ganga, also affecting prtected areas. Map by SANDRP

In response to this unprecedented development ( most of these are private hydel projects), Central Empowered Committee (appointed by the Supreme Court) referred the Kotlibhel IA, 1B &  II projects back to the Forest Advisory Committee for reconsideration of Forest clearances issued under the Forest Conservation Act (1980). A sub-committee of FAC after visiting the area, recommended that a “thorough study of the carrying capacity of Ganga tributaries has to be undertaken.” MoEF hired The Alternate Hydro Energy Center of IIT Roorkee (AHEC IITR), without undertaking any bidding process.

MOEF commissioned two studies: Assessment of Cumulative Impact of Hydropower Projects in Alaknanda and Bhagirathi Basins which was given to AHEC, IITR &Assessment of Cumulative Impacts of Hydroelectric Projects on aquatic and terrestrial biodiversity in Alaknanda and Bhagirathi Basins, Uttarakhand, which was given to Wildlife Institute of India, Dehra Dun.

The supposed ‘Cumulative Impact Assessment Report’ conducted by IIT Roorkee is so pro dam, biased and unscientific that even the Expert Appraisal Committee of the MoEF (not known for any high standards) found plenty of faults in it.

SANDRPs analysis of the IIT R Report:

At that time too, organisations like SANDRP, Himal Prakriti and others had raised the issue that this study is not looking at cumulative impacts due to muck disposal, bad management practises, seismicity, etc.

Parallelly Wildlife Institute of India submitted its report in 2012 which clearly suggested that 24 projects from the 70 projects in Upper Ganga should be shelved due to their high impact on ecology. The report said that these projects are, together, affecting nearly 10,000 hectares of land in this small state, with more than 3,600 hectares of forests going under submergence. There were some limitations to this report too, but it was a huge improvement on the IIT R Report.

SANDRPs analysis of the WII Report:

It may be added here that the World Bank and Asian Development Banks are guilty of funding hydropower projects in Uttarakhand without adequate impact assessment in place.

Interministerial Group’s Report on Upper Ganga Projects: Continuing its modus operandi of appointing  a committee when one committee’s decisions are unpalatable, MoEF appointed the Interministerial Group on Upper Ganga Projects, to study reports of IIT R and WII under the chairpersonship of B. K. Chaturvedi. The Committee was overshadowed with bureaucrats with three non governmental members: Rajendra Singh, Dr.  Veerbhadra Mishra (who passed away) and Sunita Narain.

The report is largely biased towards hydro projects in Uttarakhand and does not say a word about WIIs recommendation of dropping 24 projects, without giving any explanations. The IMG report does not go at all into the issues of environmental destruction that such projects would cause and how they will increase the disaster vulnerability of the region, already prone to multiple disasters. IMG report did not even mention that the state is vulnerable to disaster in so many ways and how the projects would influence that.

IMG report also did not mention the increased vulnerability of the region to climate change and how the projects would affect the adaptation capacity and increase the disaster potential. CSE Director General Sunita Narian, member of the IMG, filed what she called “An alternate view” but closer scrutiny reveals that it is not much of an alternate view. It says adoption of three principles would make hydropower development in Ganga basin sound, but does not bother to apply two of the principles to the projects under review. She also does not mention the numerous environmental destruction this projects would cause, how it will impact the disaster potential, nor the increased vulnerability of the region to climate change. She is the member of the Prime Minister’s advisory committee on climate change and in that context, this is most glaring. She was also a member of the High Level Working Group Chaired by Dr Kasturirangan on Western Ghats and she signed on a report that certified all hydro projects as green and renewable. Something that most other countries wont do.


SANDRPs critique of the IMG Report:

Is MoEF truly assessing Hydel Projects in the Upper Ganga?

Despite all these reports, several represenattions from affected population, PILs in National Green Tribunal, submissions from various organisations, the Expert Appraisal Committee of the MoEF did not deny granting Environmental Clearance to ANY projects in the Upper Ganga. This was depsite the fact that for projects like 300 MW Alaknanda HEP by GMR, the Forest Advisory Committee had actually rejected Forest Clearance TWICE and WII had also written strongly against the project. Not only did the project get Environmental Clearance, the EAC (Expert Appraisal Committee) haggled with the private proponent (GMR) about eflows release in the river. It did not keep to its mandate or the powers it has been given to deny EC in case the impacts of the projects are severe. SANDRP and partner organisations had also raised this point with the EAC, to no avail.

More on this issue:

When it comes to granting TORs and Environmental Clearance to Hydropower and Irrigation Projects, EACs track record is so exceedingly poor that since its conception six years ago, it has not rejected a SINGLE project for Environmental Clearance. From an Expert Appraisal Committee, its seems to be an Expert APPROVAL Committee.

Report on EACs performance:

Consistent advocacy about impacts of dams on hydrology, communities: Numerous organisations, notably the Matu Jan Sangathan, Ganga Avhan, individuals like Bharat Jhunjhunwala, and even CAG has been raising questions about the impact of unbridled hydel power development in Uttarakhand. Their concerns have gone largely unaddressed till now. In 2009, CAG performed an audit of Hydel Projects in Uttarakhand and concluded that:

  • “Audit scrutiny of project records revealed that no specific measures had been planned/ designed in any project to cope with the risk of flash floods The adverse consequences of such floods are acute as they can not only damage the project structures but can cause loss of live in low-lying down stream areas. Civil construction in projects is required to factor in this natural threat. Also the bigger the project, the greater should be the efficacy of the preventive measures.”
  • “Given the current policy of the State Government of pursuing hydro-power projects indiscriminately, the potential cumulative effect of multiple run-of-river power projects can turn out to be environmentally damaging.[Paragraph 5.3.2]”
  • “Negligence of environmental concerns was obvious as the muck generated from excavation and construction activities was being openly dumped into the rivers contributing to increase in the turbidity of water. The projects seemed oblivious of the gross negligence of environmental concerns”
  • “The plantation activity was highly deficient, as 38 per cent of projects reported hardly any plantation; posing severe hazards both for natural ecology and stabilization of hill slopes”
  • “Audit analysis revealed that, negligence in applying appropriate construction norms and structuring the project without appropriate technical counter measures may expose projects to enhanced seismic vulnerability”

“In conclusion, the above also shows inadequate construction practices being followed by project developers who failed to cater for such eventualities which are common place in the region. Additionally, it also highlights the ineffective monitoring by the GoU and the nodal agency as a result of which the slapdash approach of the project authorities towards project execution has gone on unchecked”

CAG report on Uttarakhand Hydro power projects in 2011 again repeats many of these warnings, but none of them were heeded.

Some recent comments:

Himanshu Thakkar on Karan Thapar’s Last Word:


Himanshu Thakkar on The Last Word

“In a state like Uttarakhand, which is prone to disasters like cloud bursts, flash floods, land slides, the indiscriminate building of hundreds of hydropower projects in this state, each project entailing dam, tunnels that need to be blasted through, the roads, townships and deforestation, the disaster and damage potential goes up multi fold, particularly when there are no credible environment of social impact assessments at project or basin leve, nor any carrying capacity study, nor any credible compliance mechanisms. Even the wrong operation of projects can add to the disaster potential.”

“The South Asia Network on Dams, Rivers and People (SANDRP) says too many hydropower projects, underground tunnels, roads, encroachments of riverbeds by buildings coupled with deforestation could have worsened the impact of the flash floods.

“We do not have credible environmental-impact assessment of infrastructure projects on these highly ecologically sensitive areas,” says Himanshu Thakkar of SANDRP. “Neither is there any credible mechanism to assure compliance with environmental regulations. These are places where there is a heavy tourist influx. The collapse of buildings like a set of playing cards shows these were encroachments on the riverbed and floodplains.”

Thakkar says there have been seven similar flood-related disasters in Rudraprayag in the last 34 years. “The administration should have learnt,” he says. “This is not the first time such a disaster has hit us. Both Uttarkashi and the Chamoli-Rudraprayag-Kedarnath area faced monsoon disasters last year, killing several people. There are a few hundred hydropower projects, for instance, in the various tributaries of the Ganga here. These may all be legal projects approved by the environment and forests ministry but have a serious bearing on the flow of the river.”

In conclusion:

Managing disasters after they occur is at a huge human, ecological and economic cost. Predicting and controlling disasters transparently and swiftly is a crucial factor.It is clear that numerous organisations, groups, individuals, even government institutions had raised the issue of impacts of cascade hydel dams on Upper Ganga on Hydrology, Ecology and Communities in this fragile region. Most of the suggestions have been ignored.

Even gazette notification of 135 kms of Bhagirathi as an Eco sensitive Zone came in pretty late from the MoEF and is being opposed by the Uttarakhand Government.

The responsibility of the current calamity does not rest alone with Uttarakhand Government or Disaster Management unit. It lies squarely also with the MoWR, Ministry of Environment and Forests and the Prime Minister, who is the chairperson of the National Ganga River Basin Authority. Incidentally, the MoEF has been sitting on Draft River Regulation Zone Notification for more than 3 years now. The RRZ Notification could have helped in controlling infrastructure development like hotels and homes along the river.

At the cost of hundreds of lives, the current disaster is a bitter lesson for us. It is not a time to engage in a blame game of whether or not this is a man made disaster. The contributing reasons like Dams, tunnelling, blasting, mining are well known; History of projects on Assiganga and Dhauliganga is well know and so is the topographical, seismological, geological fargility of the region. It is now a time to act and actually implement recommendations given by so many committees and organisations since past many years.

Climate Change is no longer a distant, obscure event, it is in front of us now.

In keeping with all these factors, there is an urgent need to immediately stop the ongoing hydel projects in Uttarakhand, address pending issues raised by communities and groups, undertake transparent and true carrying capacity study of the region, scrap 24 projects mentioned by WII and more, considering geological impacts, monitor commissioned projects closely for compliance, decommission commissioned projects whihc flout environmental norms or have a severe downstream impact, manage 135 kms Ecosenstive zone on bhagirathi, have a similar one for Alaknanda and near all river origins in Uttarakhand.

When faced with a human toll that is feared to be close to a thousand, hydel power does not seem so bright or clean, green and sustainable like it is touted. It is not something for which India can risk the lives and well-being of its population or environment.

Himanshu Thakkar, Parineeta Dandekar

Useful Links:

1. For an account of Floods in Pithoragarh district of Uttarakhand, see:; images of the Goriganga floods:; Before and after images of 5 Motighat hydropower project:

2. For a photo feature on damage to Vishnuprayag HEP, see:

3. For an excellent account of how Uttarakhand is a model of disaster, see:

4. Uttarakhand Disaster Mitigation and Management Centre:

5. National Disaster Management Authority:

6. National Institute of Disaster Management:

7. India Meteorological Department:

8. Flood forecasting site of Central Water Commission:

9. Sphere India website, coordinating disaster management from non govt agencies:

10. People Science Institute:…html

11. Action Aid:

Naseeruddin Shah extends support to bold new film on the Ganga

Legendary actor Naseeruddin Shah has extended his support and presence in the film Return of the Ganga, a bold new 3-part documentary film that explores the recent ongoing mad chaotic tension between conservation and exploitation of our land, water and people.


At the heart of the film is the river Ganga being dammed extensively and dried up. The film explores the options we have to save Ganga from over 600 hydro-power projects being built on her. It introspects why for the first time in the 5000-year history of our civilisation, we are facing the death of our very lifeline. Return of the Ganga also explores our choices against the backdrop of vast sweeping global changes. It makes a strong case for clean and renewable energy options and how we can get out and get our act together to ensure good sustainable sense prevails all around and especially in the corridors of power.

Naseeruddin Shah connected with filmmakers Marthand and Valli Bindana and agreed to anchor and narrate in the film. He was moved and affected by the issue and consistent with his effort to support new adventurous filmmakers, extended his involvement. Marthand and Valli are first-time filmmakers and have been working on the project since October 2012. A largely self-funded venture, the film made by this incorrigible 2-person crew, is heading towards completion the end of September. The filmmakers are looking for distribution channels.

Return of the Ganga brings people living by the river in remote regions of the Himalayas, environmentalists, scientists,  renewable and solar energy experts, sadhus, politicians, Indian and international activists all together on a single platform discussing policies and demanding change. Change that will ensure conservation of our priceless natural habitats, and environments.

Featuring in the film are people who have been working in the field for decades – Himanshu Thakkar, Vandana Shiva, Rajendra Singh, MC Mehta, Harish Hande, GD Agarwal, Shivanand, Vinod Tare. International activists also throw in their weight behind this effort with Mark Dubois: River Activist, Tony Seba: author of Solar Trillions, Jason Rainey: Executive Director International Rivers and Brad Meikle: Expert on German clean energy policy. The crew is also trying to involve Union Ministers of Power, Environment and Renewables. Some have been reluctant to speak about this very hotly debated topic.

A short rough trailer can be seen here –

2012 Floods Displaced 6.9 Million in Northeast-IDMC: Staggering but Highly Exaggerated

According to a new report, the largest climate induced displacement in the world for the year 2012 happened

Cover of the IDMC Report on Disaster Induced Displacement

Cover of the IDMC Report on Disaster Induced Displacement

in two states of Northeast India, Assam and Arunachal Pradesh in June 2012 due to the monsoon floods which displaced 6.9 million people, constituting about 21.2% of the population of the two states[1]. This staggering fact was revealed in the report named “Global Estimates 2012 – People Displaced by Disasters” published by The Internal Displacement Monitoring Centre (IDMC) based in Geneva, Switzerland in May 2013. More people were displaced in India by natural disasters last year than in any other country, says the report. A closer scrutiny shows that the figure seems highly exaggerated, raising question mark over the accuracy of the work of IDMC and Norwegian Refugee Council (NRC), who jointly published the report.

IDMC is an international body monitoring internal displacement worldwide. This was established in 1998 by the NRC. IDMC defines displacement as a non volunteer nature of movement. People who are compelled to evacuate their homes in order to avoid the impacts or the threat of a disaster will come under this definition. But from this definition it is also clear that those people who are affected by any disaster but have not evacuated their place living will not be defined as displaced. IDMC states that majority of people who face displacement are internally displaced people (IDPs).[2]

Displacement by type of related hazard, 2012 and 2008-2012

Total displaced

Type of hazard






Storm/ Typhoon



Earthquake(Seismic activity)



Extreme Cold












Landslide (dry)



Extreme Heat




32 400 000

143 900 000

This report states that in 2012, an estimated 32.4 million people in 82 countries were newly displaced by disasters associated with natural hazard events. Over five years from 2008 to 2012, around 144 million people were forced from their homes in 125 countries. The majority of this displacement (98% in 2012 and 83% over five years) occurred due to climate and weather related hazards which include floods, storm, etc.

Disaster-induced Displacement Worldwide in 2012  Source:

Disaster-induced Displacement Worldwide in 2012

In the year 2012, twenty disaster-induced displacement events were recorded, which were induced by flood and storm related disasters.  Out of these, fourteen happened in Asia which includes the mass displacement in India, China and Philippines. Large scale flood displacements also happened in African countries of Nigeria, Chad, Niger and South Sudan. In fact the Nigerian floods also displaced over six million people.  Hurricane Sandy brought the disaster for the west which rendered 775,000 people homeless in America and 343,000 people in Cuba.

Why Disaster Induced Displacements are Increasing The report says that related and interconnected global changes like population growth, rapid urbanisation and the exposure of vulnerable communities, homes and livelihoods to hazards will increase the risk of global disasters. Even though increasing use of life saving drugs have brought down mortality rate related with weather related hazards, number of disaster survivors getting displaced will not decrease.

Global Disaster-Induced Displacement  Source:

Global Disaster-Induced Displacement

The analysis done in the report shows that disaster induced displacement takes a toll on both high income and low income countries.  However, it is the middle and low income countries where majority of the people were displaced.  The report states that for the year 2012, 96.09% of disaster induced displacement happened in the middle and low income countries, whereas for the period of 2008-2012 it was 98.27%.  The report also identifies that the South Asia region had the highest disaster related displacement (36.4%) for the year 2012. From 2008 to 2012, the highest disaster induced displacements have happened in China (49,782,000) which is followed by India (23,775,000) and Pakistan (14,991,000).

Risk of the Unseen – Climate Change The impact of climate change on disaster induced displacement has been emphasized in the report. The report states that climate change is an important concern which will impact extreme weather events which could lead to more displacement. Intergovernmental Panel on Climate Change (IPCC) published a report in March 2012, Managing the Risks of Extreme Events and Disasters to Advance Climate Change Adaptation (SREX) in which relationship between extreme weather or climate events (“climate extremes”) and displacement has been acknowledged, “Although data on climate change-forced displacement is incomplete, it is clear that the many outcomes of climate change processes will be seen and felt as disasters by the affected populations. For people affected by disasters, subsequent displacement and resettlement often constitute a second disaster in their lives.”[4] Evidence suggests that climate extremes are becoming more and more unpredictable due to the impact of climate change which has changed the frequency and magnitude of these climate extremes. This could be very serious issue considering the impact climate extremes can have on displacement. The report however fails to point out that while high income countries have been responsible for the climate change to the greatest extent, the impacts of their emissions are being felt by the poorest people in the low income countries and middle income countries.

Displacement in Northeast The report says that that around 900,000 people were evacuated in Arunachal Pradesh in June-July 2012; two thirds of the state’s population. In Assam, the report says, quoting Central Water Commission that as many as six million, 20 per cent of the state’s population, were forced to flee by rising waters. It says, officials claimed the 2012 floods were the worst since 2004 when eight times more houses were recorded as damaged than in an average year.

Rainfall in June 2012 does not corroborate IDMC claims – Monsoon rain is the reason for the floods in June 2012. The table below presents the rainfall figures of Assam and Arunachal Pradesh during June 2012.

1-13 June 14-20 June 21-27 June 28 June – 4 July
Arunachal Pradesh 191.6 (+1%) 64.1 (-47.1%) 249 (+78%) 66.2 (-51%)
Assam & Meghalaya 189.4 (-3.5%) 123.7 (-9%) 251.8 (+105%) 65.2 (-51%)

Note: Rainfall in mm, figures in bracket indicate the % departure from Normal, all figures from weekly and seasonal rainfall maps of India Meteorological department.

It is clear from the above table that rainfall in June 2012 in Assam and Arunachal Pradesh was normal or below normal in all weeks except during June 21-27, 2012. Even the excess rain in this period is not too high to cause unprecedented flood displacement. This raises some doubt about the figures in the IDMC report.

Assam suffers annually from flood disasters. The havoc of floods paralyses the state for several months every year.  International recognition of this problem is very important for the state. However, that seems to be some significant exaggeration in the figure of displacement in NE India due to floods in June 2012.

The total population Arunachal Pradesh is 1,382,611 according to 2011 census[5] and displacement of 900,000 people would mean displacement of massive 65% population of the state. But we could not find any report or news confirming displacement of this huge extent. There was news about floods in several districts in Arunachal Pradesh in June and July 2012, but none corroborated the displacement figure of 900,000. In fact displacement of 65% population of Arunachal Pradesh due to floods have never been heard of for even the worst ever floods in the state.

For Assam, the flood in June 2012 was recorded as the worst floods in last ten years. The flood in June 2012 was termed as unprecedented by Dr. Partha Jyoti Das, a senior researcher working on flood and environment related issues in Assam. He said that the flood occurred quite earlier than the previous years, i.e. in the first few weeks of June.[6]  However we found it difficult to find any document corroborating the displacement figure of six million in Assam due to floods in June 2012.

On the National Disaster Management website of Government of India ( the highest number of people affected during the month of June and July was 1,992,727 (reported on 2nd July 2012). The highest number of people evacuated during this time was 383,421 (reported on 4th July 2012). The highest number of people found in the relief camps was 484,555 (reported on 15th July 2012). The Assam State Disaster Management Authority also corroborated this figure as the highest number of people reported in the relief camps during that period. Two tables providing extent of damage (cumulative figures) and rescue and relief (provisional) are given in Annexure1 and Annexure 2.

A mahout moves an elephant to higher ground as villagers paddle with their belongings through flood waters in the Pobitora Wildlife Sanctuary, some 55 km from Guwahati, the capital city of Assam, India on June 28, 2012. Source:

A mahout moves an elephant to higher ground as villagers paddle with their belongings through flood waters in the Pobitora Wildlife Sanctuary, some 55 km from Guwahati, the capital city of Assam, India on June 28, 2012.  Source:

Figures from Oxfam India, one of the leading organizations providing flood relief in the state also validated the fact that the flood in June 2012 was unprecedented early flood and worst in last ten years. They maintained that due to this flood nearly 2.4 million people have been affected and half a million people have been displaced.[7] The IDMC report also refers to the information gathered from Sphere India and Inter Agency Group (IAG). We found that in a Joint Assessment Report of IAG Assam on Assam Flood 2012 (published on 6th July, 2012) the number of affected people was stated as 2,391,369 in 4,540 villages. In the same report 383,421 inmates were reported to be staying in 650 relief camps in 15 districts of the state.

We had written to IDMC (at the email address as provided in the document for any further information and referred documents) on June 13, 2013, for copies of the documents referred in end note 11 and in table A2.1, and also request to “provide any other report that provides details and support for the figure of 6.9 million people displaced by flood disaster in North East India in June July 2012”. Our email remains unanswered as we write this.

Dr. Arupjyoti Saikia, an environment historian working on northeast after seeing the report said that “I have no accurate estimate of the people being displaced. But equally the estimate provided by the IDMC seems little awkward. The numbers of people affected in AP is surely less for very natural reasons. Often IDMC reports are criticized for their over-reaction. Official figures matter a lot as this numbers help in procuring relief from the GOI as well as other agencies. I presume GOA reports will come closer to the truth.” Dr. Dulal Chandra Goswami, another senior scholar from northeast, said that the displacement figures for northeast, quoted in the report appear to be highly exaggerated. Dr. Partha Jyoti Das also expressed similar opinions saying that the figures mentioned in the IDMC report for northeast are overestimated. Many reporters may accept the figures in such reports uncritically and report them, which lead to spreading of wrong information. This was evident from the reports published in Down to Earth[8] and Thomson Reuters Foundation[9].

Moreover, displacement in Assam is not only induced by floods but also by erosion. The report does mention “Shelter needs were a primary humanitarian concern as the authorities encouraged IDPs to leave relief camps and return to water-logged villages, destroyed houses and eroded land”.  But this is not completely correct as erosion leads to permanent displacement of people from their original land. Floods lead to inundation of a certain area for a period of time displacing people temporarily from their homes. But erosion displaces people permanently from their land. In displacements induced by floods the displaced people have the option of going back to their houses. Erosion leaves no option for that. People who get affected by erosion have to shift their homes before the actual erosion happens. In 2007 it was stated in the State Assembly that in 15 out of 23 districts in the state 40,414.98 bighas of land was lost due to erosion.  10,075 families have lost their houses due to erosion in that year. Many people who get displaced due to erosion opt to live on the side of the embankments in poor living conditions for years due to their inability to buy new land. They might not come to relief camp during floods which may result in their non-recognition in official displacement figures.

Such kind of reports also need to recognise clearly that among the disaster induced displacement, it is the poor people who are most at risk even in a fast growing country like India and climate change is making them even more vulnerable. Hence there is an urgent need to ensure that the climate action plans address the vulnerabilities of the poor. Unfortunately, Indian government’s National Action Plan on Climate Change (NAPCC) does not even recognise the vulnerable classes of people. In fact NAPCC increases the vulnerability of the poor, since it basically follows the business as usual development path.

This report by IDMC is an important initiative to document the plight of the people who face displacement due to the disasters. Recording and documentation of displacement is very important for policy formulation as well as for all related discussions and debates. The numbers presented are shocking but are clearly unsubstantiated and exaggerated. However exaggerated facts will also not lead to healthy policy formulation. Besides, factual inaccuracies may lead to questioning the credibility of such reports. We hope that IDMC will acknowledge these errors and bring more factual accuracy in their future reports. Such reports also need to highlight the issue of climate justice.

Parag Jyoti Saikia and Himanshu Thakkar
South Asia Network on Dams, Rivers & People (

Email: /

Annexure 1: Extent of Damage (cumulative figures) (Provisional)

Name of States/


Date when updated

Population affected


No. of

human lives lost

No. of districts affected

No. of villages affected

No. of cattle/

Live- stock lost

Cropped area affected

(in ha)

No. of houses damaged

Fully Partially
15.06.12 13.06.2012 7 13 326
18.06.12 17.06.2012 66915 11 10 11783 07 02
28.06.12 27.06.2012 386762 14 19 23134.15 141 6592
02.07.12 01.07.2012 1992727 81 27 1564 657558.07
03.07.12 02.07.2012 1233970 95 27 1543 657558.07
04.07.12 03.07.2012 916801 104 27 1281 U/ Assesment
15.07.12 14.07.2012 2391369 125 30 4540 2.55
19.07.12 18.07.2012 2391369 126 30 4540 2.55 awaited awaited
24.07.12 23.07.2012 2391369 126 30 4540 2.55
31.07.12 23.07.2012 2391369 126 30 4540 0 2.55 0 0

Source: Flood Situation Report for June and July, 2012 available at


Annexure 2: Rescue and Relief (Provisional) 

Name of States/ UTs

Date when updated

No. of persons evacuated

No. of relief camps opened

No. of persons accommodated in the relief camps










































Source: Flood Situation Report for June and July, 2012 available at

[2] As defined by the 1998  Guiding Principles on Internal Displacement, internally displaced people (IDPs) are individuals or groups of people “who have been forced or obliged to flee or to leave their homes or places of

habitual residence […] and who have not crossed an internationally recognised state border.”

[3] This figure is clearly gross error. The total Disaster induced displacement in 2012 by all types of hazards is 32.4 million, so storm related disaster cannot displace 95.7 million people. We have used a corrected figure in the table here, based on total displacement subtracted by displacement by other (than storm) factors.

[4] SREX, p.80. Citing Oliver-Smith, 2009

Where is Maharashtra’s Raju Swami?

This is from, arguably, India’s most celebrated movie, where a reluctant, accidental swami is trapped into going on a fast-unto-death for bringing rains to a drought stricken place. His this fast achieves a string of miracles: uniting the swami with his mother (on the 6th day of the fast), his beloved Rosy (played by Waheeda Rehman, the most beautiful star of Indian Cinema. She falls to his feet just when a journalist asks swami if he has ever been in love) and his closest friend[1] and brings millions to a remote village temple.

It also brings rains.


In an interview to a foreign TV channel, the swami is asked if he believes it will rain due to his fast. The swami says, there are these thousands of people who believe in me and now I have started believing in their faith! This answer sounds a bit democratic, does it not?


Fact is, this reluctant swami did not even believe in God (at least till midway through the fast), as he says in one of his moments of self doubt. In another moment of self doubt, he grabs some bananas offered to the gods in the temple and is seen on verge of eating them.

Before the cruel drought and ensuing fast, swami narrates a story to the villagers, describing a drought that is akin to what the poorest in Maharashtra faced this summer: there has been thirst, hunger, riots, deaths and unrest. Politicians of Maharashtra are fond of saying (though rather incorrectly), that this drought is worse than the one in 1972, which was, not too long after the film was released.

Yes as you may have guessed it by now, the name of the film is Guide, one of the most remarkable films of Indian cinema worth recalling in this centenary year of Bollywood and name of this Swami in the film is Raju, played by the legendary actor Dev Anand.


The swami is in constant dialogue with Raju and in one doubting moment, Raju questions swami, do you really think there can be any relation between hunger of one person and the clouds? Have you too started believing in such things like these uneducated people? And the swami answers, “I do not know, Raju. I have started thinking of a lot of things that I never thought necessary. Question is not whether it will rain or not, question is not if I will live or die. Question is, is there someone who runs this place or not? If there is no one who runs this place, then it does not matter if I live or die. There is no point in living blindly in a blind world. And if there is someone, then it is to be seen if that some body listens to its poor subjects or not.”


This sounds like a search for a functioning and responding Maharashtra government, the search in real Maharashtra this year is yet to end. The drought, as we wrote earlier[2], is largely man-made and was completely avoidable, but there was no sign of a functioning or responsive government taking steps to avoid it. Like the Swami says, bigger question is if there is someone responsible for the avoidable disaster. It is this same question that has haunted drought stricken of Maharashtra.


In another sequence in the film, Rosy asks Raju, resting on her shoulder, have you gone to sleep? And he meaningfully answers, I was sleeping so far, but have started waking up.


The famous film of 1965 ends with the rains and death of the swami (even though it is unusual for a Hindi film hero to die).


Leaving the miracle (and other clichés of the film) aside, with monsoon round the corner, Maharashtra is close to that GUIDE moment which hopefully will end the misery of lakhs of people.  However, this end of misery in Maharashtra will not be due to specific efforts from anyone. For there seems to be no one in sight, ready to take the trouble, leave aside an extreme step like fast-unto-death.

Like Raju’s answer to Rosy, let us hope that people and the administration have indeed woken up to ensure that another man-made drought does not occur. With climate change on us, the frequency of such calamities is only going to increase. But this hope of Maharashtra waking up seems pretty filmy at the moment.

It seemed that the Maharashtra Chief Minister Prithviraj Chavan wanted to be the messiah of Maharashtra when he promised investigation into the irrigation scam and Maharashtra’s deputy Chief Minister Ajit Pawar had to resign. However, Chavan proved to be a fake messiah seeing his refusal to launch any credible investigation into the massive Rs 70 000 crore scam or any noteworthy action against the corrupt. Chavan’s initiative on June 9, 2013[3], inaugurating 1497 cement check dams across the 15 taluksa in drought prone areas of the state and declaring that “small dams are key for drought free Maharashtra” is a welcome step.

His promise of participation and transparency in the scheme will be realized or not is yet to be seen.

And till then, Maharashtra will be waiting for a Raju Guide of its own..

-Himanshu Thakkar

Dams as Pawns: Bhama Askhed, Pune

On 9 April, 2013, the Bombay High Court, in response to a PIL filed by Mohol Taluka Shetkari Sangh ordered the Water Resources Department (WRD) of the Government of Maharashtra to release ‘sufficient’ water to Ujani Dam (the largest dam in the Bhima Basin) within 24 hours to meet the drinking water needs of drought-stricken villages downstream Ujani.

In the 24 hours that followed, WRD zeroed in on the release of 3 TMC (Thousand Million Cubic Feet) water from Bhama Askhed and 1 TMC from Andra. The water releases from both the dams were ongoing as on 1 May 2013, when I visited the Bhama Askhed dam. By then, 2 TMC water had already been released. There are no credible reports about how much water from this release has reached Ujani, or how much will eventually reach. When the water was released on 10 April 2013, the Chief Engineer, Bhima Basin had reportedly said that it will take 6-7 days to reach Ujani backwaters, without mentioning the rate of release. 26 days later, the release is still on.


While water releases from a distance of over 205 kilometers for a region like Solapur, which has mismanaged its water to the hilt by using all its water for sugarcane and sugar factories even in this severe drought year, as well as the merits of the High Court decision can be debated, it is important to see the implications of such decisions from the perspective of those at the source: around Bhama Askhed Dam. The choice of Bhama Askhed and Andra Dams was not based on any participatory process, but was a closed-doors decision taken by the WRD, allegedly because it will be politically impossible to release water from dams reserved for Pune’s drinking water (Although Pune dams are still releasing water for downstream sugarcane).

How come the Bhama Askhed dam had 124 million cubic metres (57 per cent of live storage capacity) on April 8, 2013 (practically the end of the irrigation season) in a drought year? In fact, the live storage of the dam was filled up to 66 per cent on the same date in 2012 and 74 per cent in 2011. It seems the dam remains hugely underutilized. One key reason is that Bhama Askhed has no canals built for irrigation, as per the original plans even after 18 years of construction initiation.

Away from the media attention, the project-affected people of Bhama Askhed Dam were on a protest fast at the Dam wall for four days after the release of water from it for Ujani started. Their demand: they have not been rehabilitated even after 13 years of initiating dam filling in the dam. They should be rehabilitated first, should receive water for drinking and irrigation on priority and only then should the water be released for the downstream.

Let us take a look at Bhama Askhed as a representative of dam-centered water management in Maharashtra, a state with maximum dams in the country, to see the extent of fulfilment of the stated objectives of a dam and other underlying realities.

The Dam

Bhama Askhed Dam on Bhama River, a short tributary of Bhima River, received administrative sanction in 1992 with the explicit objective of providing irrigation to 37 villages in Khed, 18 villages in Haveli and 9 villages in Daund talukas of Pune district with a total command area of 29,465 hectares, as per the White Paper on Irrigation Projects brought out by the WRD. It was to have two canals: a right bank canal (RBC) of 105 kilometres and a left bank canal (LBC) of 14 kilometres. Construction on the dam started in 1995.

According to its last administrative sanction in 2012, the cost of the dam has now risen to Rs. 575.84 crore from its initial Rs 112.96 crores in 1992. The dam has a live storage capacity of 7.6 TMC. Canal-work has not been done even according to the claims of the WRD. Right Bank Canal is barely 18 kilometres complete, in patches. Left Bank Canal work is not even initiated. Of the intended 30,000 hectares to be irrigated, not a single hectare receives irrigation through canals, since the RBC work stops just about 200 mts from the dam site, before resuming after a distance, but this discontinuity means water cannot be taken to any of the command area.

Bhama Askhed Dam Pic: SANDRP

Bhama Askhed Dam Pic: SANDRP

Tragedy of the displaced

Bhama Askhed Dam submerged 2,259 hectares of land, affecting three villages completely and nearly 20 villages partially, displacing 1414 landholders, approximately 7000 people in all. When we had a meeting with some of these affected people, the Sarpanch of Roundhalwadi (a fully affected village) said that of the 1414 landholders, till date only 56 landholders have been rehabilitated in the command area of the dam. When affected people were paid compensation, there was a clause that they have to pay back 65 per cent of the compensation amount within 40 days to be eligible later for land in the command area of Bhama Askhed. When a majority among the people signed the compensation papers, this clause was not pointed out to them and most of them being uneducated were unable to read this.

Even among the 111 landholders who paid 65 per cent of the amount, only 56 received land in the command. In every village, there are nearly 20 per cent people who neither received land, nor money for the land and livelihoods that they lost. They eventually moved to the High Court in 2007 and the case is still pending. We met farmers who had lost all their land: fields as well as homes without receiving land compensation till now, and have sent rehabilitation claims four times or more, but have received no response.

As in the case of most dam projects, the rehabilitated villages such as Roundhalwadi, Parale, Anawale, Waki lack basic amenities, do not have fully functional drinking water sources, irrigation schemes, assured electricity or proper roads. Some villages like Kasari are surrounded by water on three sides without a proper road.

Affected villages also supported 25-30 settlements of landless tribals: Thakars and Katkaris who mainly depended on the forests and fishing for survival, without owning any land. They received no compensation for losing their livelihoods from fishing and forests. Once the dam was built, fishing contracts were awarded to a city-based contractor in five-year cycles and locals were not allowed to fish in the dam. No one knows what happened to these tribal settlements; they just vanished in thin air!

18 years from initiation of dam construction, the problems of project-affected communities are far from solved. Local farmers have organised protests in 2009, 2010, 2012 and now in 2013. Every time they are given assurances, but the problems remain. In the words of Devidas Bandal, an affected villager fighting the HC case, “We do not say no to releasing water to Ujani, we only ask that we, who lost our lands and livelihoods, also be given water for drinking and irrigation and basic amenities in rehabilitated villages. Is that too much to ask for?”

Water to the industries

In 2005, Chakan MIDC started coming up in a part of the command area of Bhama Askhed Dam, we were told. This was also the same land promised to farmers for resettlement. Now, the land prices here have skyrocketed and affected farmers say that administration will never resettle them here, though this area lies in the command. Letting MIDC encroach upon the command area of a dam already underway, that too on land which has been promised for rehabilitation, is unjustifiable. In addition, Chakan MIDC lifts water directly from Bhama Askhed Dam. This water allocation was never planned. Now, with expanding MIDC and a huge real estate boom in Chakan, the development moves closer and closer to the land reserved for the canals, which should have been ready many years back.

So, for whom has this dam been built?

When quizzed about canals, the WRD officials say that there is resistance for land acquisition for building canals. Some of the farmers in the downstream are lifting water from 26 KT weirs built by the WRD on Bhama and Bhima Rivers for utilising water releases from Bhama Askhed Dam. They seemed to have been encouraged to use the water from the weirs built by the same irrigation department that has not built the canals. Now some of them are naturally resisting land acquisition for canals, since they already have irrigation from the KT weirs, and the irrigation department is using this as a reason for not building canals in the planned command area. In the regions irrigated by weirs, sugarcane flourishes, increasing inequity again. A large part of the area now irrigated thus was not even part of the original command area.

Water for Pune Municipal Corporation

A huge reservoir storing 7.6 TMC water without canals is an attractive proposition for many. According to a Government Resolution (GR) dated December 2011, 1.2 TMC water from Bhama Askhed has been allocated to Pune Municipal Corporation (PMC) for drinking water purposes. In its explosive growth, Pune city wastes and pollutes water with impunity, has unchecked leakages and huge inequity in water supply. But having a source like Bhama Askhed makes it easy for Pune to forget these worries and simply buy water from the water resource department.

According to the same GR, PMC is supposed to pay Rs. 48.76 crore to WRD for re-establishing irrigation infrastructure. This is at the rate of 1 lakh rupees per hectare, which means that irrigation for 4876 hectares of command area is losing this water. Again, this has been an entirely non transparent and non-participatory decision. While the White Paper laments the funds crunch to take up canal work, it does not mention these unplanned diversions or this added revenue and how it plans to use this for either rehabilitation or the command area.

A dam, which was sanctioned on its claimed potential to irrigate nearly 30,000 hectares in a semi-arid area, is already built at a huge economic and social cost and is storing water earmarked for the command area that should receive this water. But the reasons behind the delay in starting canal works of Bhama Askhed are incomprehensible. The contractors, engineers, politicians, industrialists and even fish contractor have profited, but no benefits accrue to recognised or unrecognised affected population or intended beneficiaries as per the original plans. While unplanned sugarcane, Pune Municipal Corporation and Chakan MIDC have emerged as the unplanned beneficiaries of these dams, the farmers in command, for whom the dam was justified, and the project-affected people have been the losers in this game.

Bhama Askhed is not an isolated example showing water diversions from irrigation projects to non-irrigation uses. Notable examples are Hetawane Dam in Pen and Surya Dam in Dahanu, among many others.

It seems as if the dams have become pawns in the hands of engineers, bureaucrats and politicians, to be used as and when required for whatever ulterior motive they might serve – anything but their stated purpose. It is not a coincidence then that despite spending 70,000 crore rupees on irrigation in Maharashtra for ten years, the irrigated area is showing no net increase and thousands of villages are parched despite building multiple dams in the vicinity.

While participatory, transparent and accountable water management is crucial in all years, its importance is particularly highlighted in a drought year like 2012-13. Let us hope that all concerned, including farmers, media, civil society as well as the High Court look at the complete picture and are able to take collective action on this.

Parineeta Dandekar 
08 May 2013

REad the full artcile here:

NDMA Commissioned IIT Roorkee Study on Brahmaputra River Erosion: A Biased and Structural Solution Oriented Report?



Pic:  1  Erosion in Rohmoria in the Upstream of Dibrugarh. Source: The Assam Tribune

The National Disaster Management Authority (NDMA) has recently published a report named “Study of Brahmaputra River Erosion and Its Control”. NDMA had commissioned this study to the Department of Water Resources Development and Management of IIT Roorkee. NDMA is an apex body constituted under the Disaster Management Act, 2005 to prepare the country to face natural and human-made disasters. NDMA is headed by the Prime Minster of India. Under the natural disasters category it includes earthquake, flood, tsunami, land slide and avalanches while nuclear, chemical or biological disasters have been categorized as human-made disasters. This report provides a lot of information and data on the Brahmaputra and its tributaries. The information about erosion is also very much detailed and descriptive. The report can be found at


Pic:  2 Recent News Reports of Erosion in Subansiri River, One of the Largest Tributaries of Brahmaputra on the North Bank. Source: Dainik Janambhumi

ImagePic:  3 Houses on the side of the Old Embankment in Matmora. Source: Parag Jyoti Saikia

This reports deals with a very serious issue of erosion in the Brahmaputra river basin in Assam. Erosion should not be confused with floods even though both are annual phenomena in the Brahmaputra river basin. Erosion can be seen to have a more severe impact than floods because erosion leads to permanent loss of land and property. During floods land and houses are submerged for a period of time. But erosion displaces people from their land and property for good. Erosion inflicts severe damage to agriculture, economy and cultural relations of people. Erosion compels people to migrate to different places. Villages get eroded one after another and people living in those villages have to move to another location with their belongings. But this may not be possible and affordable for all those who lost their land in erosion. So for many of them, living on the side of embankments in very poor living conditions remains as the only option. Erosion also leads to migration of rural youths to urban areas in search of jobs. In the last few decades erosion has posed as a greater threat to the people of Assam than floods. The severity of erosion can be seen from the Table 7 of the report in which Satellite Based Estimation and Comparison of Area Eroded In Brahmaputra during the Period 1990 to 2007-08 and 1997 to 2007-08 have been presented.


Map of the Study Area from the Report

The study divides the river length into twelve segments from Dhubri to Dibrugarh and that is why there are 12 reaches mentioned in the table.  It is clear from this table that the while the erosion prone length of the river is 10% higher along the South Bank of Brahmaputra compared to the same along North Bank. Areas facing erosion is 123% higher in South bank during the last decade (1998-2008) of the study period. The highest erosion area/per km of erosion prone bank is upstream of Dibrugarh, where the river enters the plains from the hills.

Areawise division into 12 reaches in the river

North Bank

South Bank

Total Erosion Length

(in km)

1990 to 2007 – 08 (in sq. km)

1997 to 2007-08 (in sq. km)

Total Erosion Length

(in km)

1990 to 2007 – 08 (in sq. km)

1997 to 2007-08 (in sq. km)

1. Dhubri







2. Goalpara







3. Palasbari







4. Guwahati







5. Morigaon – Mangaldai







6. Morigaon – Dihing







7. Tezpur







8. Tezpur-Gohpur







9. Majuli-Bessamora







10. Majuli Sibsagar







11. Dibrugarh







12. U/s Dibrugarh














The Study Report:
There have been a lot of studies done on the river, to find a solution to the issue. But what comes as a surprise is the attempt to shy away with some of the crucial issues of the riverine eco-system in the northeast. But before going into crucial issues, a brief note about the report is provided.

The March 2012 study is divided into two phases. The first phase is named as ‘Sattelite Data Based Assessment of Stream Bank Erosion of Main Stem Brahmaputra and Its Major Tributaries’. In the second phase processing and analysis of the hydrological data of the Brahmaputra and its tributaries has been done.

In the first phase of the study information and data of 18 years (1990 to 2008) has been put together. The study pertains to a reach of 620 km on the main stem of Brahmaputra River, i.e., its entire course in Assam from upstream of Dibrugarh up to the town Dhubri near Bangladesh border.  23 major tributaries (13 northern and 10 southern) within India have also been considered. The data for this whole area was collected using an integrated mechanism of Remote Sensing and Geographical Information System.

In the second phase of the study a new method of analysis called Artificial Neural Networks (ANNs) has been used. The data processed through this analysis has been used for modeling the rainfall-runoff process and runoff-sediment process for the study area.

The report identifies inherent ‘sediment overloading’ of the river fluvial system as the main cause for river bank erosion vis-à-vis channel instability in Brahmaputra. The report recommends by proposing river training works for two pilot areas on Brahmaputra River. The first site is in Bhuragaon of Morigaon district and second one is near the Guwahati airport.

Critical issues:

The team of investigators for this study was led by Prof Nayan Sharma of the Department of Water Resources Development and Management at IIT Roorkee. This is a very descriptive report from the point of information and data about the river Brahmaputra and its tributaries. But even then there are several things that the report does not mention at all.

The report mentioned that inherent ‘sediment overloading’ as the prime cause for erosion in the river Brahmaputra. But another study named “River Bank Erosion and Restoration in the Brahmaputra River in India” has identified several other factors responsible for bank erosion.[1] That study states “The salient hydraulic and bank material factors responsible for bank erosion of the Brahmaputra system are i) rate of rise and fall of river water level, ii) number and position of major channel active during flood stage, iii) angle at which the thalweg approaches the bank line, iv) amount of scour and deposition that occurs during flood, v) variability of cohesive soil in bank material composition, vi) formation and movement of large bed forms, vii) intensity of bank slumping, and viii) progression of abandoned river courses to present-day channel.”

Identifying only ‘sediment overloading’ as the main reason for a dynamic river system like Brahmaputra seems an over simplification that overlooks the critical issues.


Pic:  4  A view of the Balijan Tea Estate Eroded by the Brahmaputra in Rohmoria in Dibrugarh district of Assam. Source: The Hindu

Even though the report identifies sediment overload as the prime cause of erosion, it has provided insufficient analysis as to why the sediment load is actually increasing in Brahmaputra. The report rightly states “Accelerated erosion has occurred in this region due to intensive deforestation, large – scale road construction, mining and cultivation on steep slopes.”

Pro Hydro Bias: Here the report completely ignores case of hydropower development in Arunachal Pradesh and its impact on Brahmaputra and its tributaries. The report nowhere mentions about the proposals for 168 hydroelectric dams in Arunachal Pradesh and its impact in the rivers in Assam. In the recent times, the state has witnessed mass protest against hydropower development in Arunachal Pradesh. In fact the report shows a pro-hydro bias when it laments that “less than 5% of the existing hydropower potential” have been put to use so far. At a time when people are demanding for cumulative impact assessment of dams on the rivers of Assam, reports like this attempt to create confusion among people. It is to be noted that when Assam was witnessing the mass protest against big dams, it was Dr. Nayan Sharma who appeared in the electronic media advocating for big dams.


Pic:  5  Erosion protection work at Nimatighat on the Brahmaputra in Jorhat District on May 5th 2013.       Source:[2]  

Bias for Structural Intervention: This report advocates for structural intervention for flood protection and reiterates the need for more embankments. Lots of analysis has been done on the ill effects and poor performance of embankments. Embankments essentially transfer the problems to the downstream. There are ample examples of how structural interventions made for erosion protection have failed. We can take the example of Rohmoria, located in the upstream of Dibrugarh town in this regard. There were a series of structural interventions made to control erosion but it failed.[3]

The embankments proposed in this report for the two pilot-study areas are proposed to be constructed using geo synthetic bags. The geo-synthetic bags will be put inside polymer rope gabions[4] and installed in the critical toe of the bank line. The efficacy of controlling erosion through geo-tube embankments still not established, but even then geo-tubes have become the buzz-word for flood protection in Assam. The Asian Development Bank has offered a loan of $12 million for erosion protection through construction of geo-tube embankments. But Assam government engineers working on Brahmaputra and its tributaries are critical of ADB’s programme of erosion control through geo-tube. In a report published in regional news paper on March 2010, it was stated that revetments like geo-bags cannot be successful in Brahmaputra because it creates a permanent deep channel along the existing river bank.[5] The report also stated that geo-synthetic bags which were installed for bank protection in Palashbari-Gumi area were washed away by Brahmaputra. This area is in the downstream of Saraighat Bridge and close to Guwahati airport area where one of the pilot projects has been proposed.

Impact of Structural Interventions Ignored: The report provides structural solution for erosion control but ignores erosions which were a result of structural interventions in the river. Studies on Brahmaputra basin have shown that during and after the construction of bridges in the river Brahmputra erosion and floods have increased in the downstream areas.[6] In the case of Saraighat Bridge, unprecedented flood and erosion was witnessed in Palasbari and Gumi area. Morigaona and Nagaon districts suffered the same after the construction of Koliabhomora Bridge. Construction of Naranarayan Setu, led to flood and erosion in Dakshin Salmara, Pancharatna and Mancachar.

Similar fears have been expressed for the fourth bridge on Brahmaputra which is under construction between Bogibeel of Dibrugarh district and Kareng Chapori of Dhemaji district. The river is nearly 9 km wide at this point. But for the construction of this bridge, the river had been shrunk to almost 5 km through the boulder spurs. This is posing a great threat of flood and erosion for the downstream areas which include famous river island Majuli and Matmora, where India’s first geo-tube embankment was constructed. Engineers who are involved in the construction of the dykes of the fourth bridge had been reported saying that Matmora area would come under severe threat due to the increased river pressure in the area. The report completely ignores all these facts and shows ‘sediment overloading’ as the cause of erosion.

Besides, the study gives a feeling that erosion in the river Brahmaputra operates in ceteris paribus[7]. The report made no mention about climate change and how it is going to impact a river like Brahmaputra which is flowing right from the Himalayan mountain range. At a time when impacts of climate change are taken into account for every possible environment related matters, ignoring this is another major lacuna of this report.

These critical lacunas put a question mark over the usefulness of the otherwise informative study. Credibility of IIT Roorkee reports have been questioned in the past too.[8] NDMA may keep this in mind and focus on more basic issues. For starters as monsoon sets in and rounds of floods start along Brahmaputra, NDMA’s flood forecasting links have stopped functioning for five days as we publish this in the 1st week of June 2013.

 Parag Jyoti Saikia 

South Asia Network on Dams, Rivers & People (


[4] Gabions are sausages made of Polymer ropes that are appropriately woven by a special process to fabricate the Gabions in various sizes. Gabions are generally available in a prefabricated collapsible form. Images of polymer rope gabions can be found here –

[6] Mahanta, C; Mahanta, A., ‘Bridge over The Brahmaputra’ Economic and Political Weekly, pp 579-581, 2006

[7] Ceteris paribus is a Latin phrase which can be literally translated as “holding other things constant” and usually rendered in English as “all other things being equal”

EAC’s norms for Eflows need to Change: Submission from civil society

The following submission has been sent to the Expert Appraisal Committee, River Valley and Hydro Power Projects, Ministry of Environment and Forests, India. The current norms recommended by EAC while clearing hydropower and irrigation projects are hardly leaving any water for the rivers (eflows), thereby destroying rivers as well as livelihoods.

  Norms on e-flows followed by EAC need to change

 Respected Chairperson and members,

As you know, the Inter ministerial Group on Ganga Basin was constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012. It has subsequently submitted its report to the MoEF in April 2013.

While there are several issues about IMG’s report and recommendations, some of the recommendations are the minimum, urgent stop gap measures that need to be implemented by the EAC. IMG’s recommendations are relevant for nearly all rivers across the country. All of the rivers have rich social and religious values and a large proportion of population depends on them for livelihood. Hence, the recommendations of IMG logically apply to all the rivers. In line with the IMG Report recommendations, we urge the EAC to modify its recommendations about eflows and environmental impacts as suggested below:

1.           Eflows

a.           Eflows to be based on daily uninterrupted flows, not seasonal flows

The IMG report states that: “An important component of the e-flows regime has to be mimicking of the river flows so as to keep it very close to the natural flows. Cumulative norms even on seasonal basis do not meet this objective. Daily inflow norms may, however, enable a sustained river flow as well as have large flows in the high season and hence are more suitable.” (emphasis added)

IMG has thus recommended that all dams and hydro projects should release water based on daily inflows, following the % releases recommended in each season, but the releases must change as per daily inflows.

 b.           Eflows as 30-50% of daily lean season flows

The IMG report recommends that releases should be 50% of lean season flows where average lean season flow is less than 10% of the average high season flow. Where average lean season flow is 10-15% of the average high season flows, the releases should be 40% of inflows and where 30% for the rest of the rivers.

In keeping with IMG recommendations, we urge that the EAC should be recommending 50% average daily flows in lean season as eflows.

c.           Independent, community-based monitoring of Eflows releases

Monitoring of eflows releases from operating projects is crucial, given the fact that it is currently entirely in the hands of the proponent without any monitoring of compliance by the MoEF. In such a situation, proponents are not releasing any eflows as pointed out by the one person Avay Shukla Committee Report, recent CAG report of Himachal Pradesh.

IMG recommends: The IMG has considered the need for an effective implementation of the e-flows as cardinal to its recommendations. It is recommended that the power developer must be responsible for developing a monitoring system which is IT-based and gives on a real time basis the flow of water in the river, both at the inflow and in the outflow after the river gates in the river stream. This should be

(a) monitored by an independent group

(b) reviewed yearly by the Ministry of Environment and Forests in the first five years and

(c) put in public domain the e-flows. This real time public monitoring of e-flows will be the key.

We urge that that EAC recommends similar monitoring norms for all projects. Effective monitoring cannot be done if local affected population is not a part of this process, hence, in addition to above points, EAC should recommend that eflows should be monitored by an independent group which has at least 50% participation of downstream communities facing the impacts of these projects.

d.           Assessing eflows only through participatory and true Building block Methodology (BBM)

The IMG states: “Considering environment, societal,  religious needs of the community and also taking  into taken in to account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirements on a long-term basis. This recognizes the fact that the riverine species are reliant on basic elements (Building Block) of the flow regime, including low flows, and floods that maintain the sediment dynamics and geo-morphological structure. It also includes an understanding of the functional links between hydrology and ecology of the river systems.”

However, the EAC is accepting any eflows assessment as BBM, simply looking at the label provided by EIA consultants, without applying its mind. We have pointed out that BBM purportedly used by consultants like WAPCOS in Lohit Basin Study is not BBM in any sense.

We urge the EAC to:

·                     Recommend methodology of BBM assessment clearly at the time of granting TORs (This is available from WWF or here: King, J.M., Tharme, R.E., and de Villers, MS. (eds.) (2000). Environmental flow assessments for rivers: manual for the Building Block Methodology. Water Resources Commission Report TT 131/100, Pretoria, South Africa. ),

·                     Recommend sectors which should be included in BBM study of a specific river (downstream users, fishermen, geomorphology experts, ecologists, etc.) clearly at the time of granting TOR. Downstream users should form a part of the BBM Group in all circumstances.

·                     Check whether these sectors are duly represented in flows studies

And only then accept the study as being based on BBM methodology. The current practice of EAC of accepting any shoddy assessment as BBM is serving neither the rivers, nor the communities, nor is it expanding India’s experience with BBM.

e. Release of Eflows

It is not just how much the releases are, but how the releases are made that decides if the releases are useful for the rivers, biodiveristy and the society. Unfortunately, EAC has given no attention to this issue.

In this context, one of the guideline of the IMG says, “Fish passes may be made an integral part of hydropower projects. Regular monitoring for their effectiveness be done by project developers.”

EAC should follow this and make well designed eflow release mechanism mandatory part of the EIA study and post-construction monitoring.

2. Free flowing river stretch between projects

Currently, the EAC has a very lax norm of recommending 1 km distance of the river between two projects. In many cases, the EAC is not following even this minimalist distance criterion. Nor is it following recommendations of civil society, or expert committees of having minimum 5 kms of free flowing river before it meets the downstream project/submergence.

In this regard, the IMG notes “There is a clear need to ensure that adequate river length is available to meet the societal needs and River gets adequate time during its flow to regenerate itself.” 

The EAC should include, as part of EIA and TOR a detailed study of:

·                     “Time” required by the river between two projects to rejuvenate itself and how much distance the river need to have such time to rejuvenate itself.

·                     Ecology (including livelihood fisheries) downstream of a project and how it will be affected by modified flows while granting TORs to hydro projects.

·                     Social and cultural use of the river downstream the project: presence of religious sites, river sanctuaries, etc. while granting TORs to hydro projects.

Based on this, the EAC should recommend distance of free flowing river that needs to be maintained downstream a specific project. This should be applicable even if this was not stated at the time of deciding TOR.

3.           Recommend Free flowing and Pristine rivers in all basins

World over, there exist norms and laws to protect free flowing rivers as “Pristine, Wild or Heritage Rivers”. EAC has been recommending damming most of the rivers in the country in the recent years. The EAC should recommend that some rivers should be maintained in their pristine, undammed (or with the current stage of development, no further) condition.

In fact, the IMG has specifically recommended: “ The River Ganga has over a period of years suffered environmental degradation due to various factors. It will be important to maintain pristine river in some river segments of Alaknanda and Bhagirathi. It accordingly recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, AssiGanga, Dhauli Ganga (upper reaches), Birahi Ganga and Bhyunder Ganga, should be kept in pristine form and developments along with measures for environment up gradation should be taken up.”

Unfortunately, currently the EAC is actually clearing projects when Cumulative Impact Studies or Basin Studies on such rivers are not completed or are on-going (Example: Chenab Basin Projects, Satluj Basin Projects, Lohit Basin Projects). We have pointed this out to the EAC on number of occasions, without any response.

We urge the EAC to recommend a few ecologically and socially important rivers in each basin as pristine rivers, to be protected from any projects at the time of clearing basin studies or cumulative impact assessment studies. At the same time, the EAC should analyse the present development stage of a basin while clearing specific projects and should recommend some rivers in pristine state. In places like North East India and western Ghats, certain river basins may need to be left in pristine state.

 4.           Recommendations to the MoEF about eflows from existing projects

The IMG has made a clear recommendation in this regard: “The suggested e-flows should be applicable to the existing power projects in operation in these States.” IMG has given maximum of three years for the projects to achieve e-flows.

We urge the EAC to make a recommendation to the MoEF to look at existing projects and recommend eflows norms on the same lines as those for new projects in time bound manner.

As the World Environment Day is drawing close, we are sure that the EAC will look at its role of protecting the Riverine environment and communities and will take proactive steps in this regard.

Looking forward to your point-wise response to the issues raised above.

Thanking you,

Yours Sincerely,


Himanshu Thakkar and Parineeta Dandekar, 

South Asia Network on Dams, Rivers and People (

Samir Mehta, 

International Rivers (

Dr. Latha Anantha, 

River Research Centre, Kerala (

Upper Ganga Report with Pro Hydro Bias does not do justice to its terms or to Ganga, people or environment

Summary A month after its submission to the Union Ministry of Environment and Forests, the Inter Ministerial Group on Upper Ganga basin Hydropower projects and Ganga river in general is yet to be put in public domain. A detailed perusal of the report shows that the report is hugely biased in favour of large hydropower projects, and has not done justice to the task given to it or to the Ganga river, people or environment. Out of the three non government members (out of total 15 members) on the Group, Dr Veer Bhadra Mishra expired during the working of the group. Rajendra Singh has given a dissent note, not agreeing with the report in its totality. The “alternative view” note from Sunita Narain, the third non-government member, is not much of an alternative and is not in the interest of the river, people or the environment. However, the fact that none of the non-government members have endorsed the report speaks volumes about the credibility of the report.


The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations.

A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. The report gives a list of positive aspects of the IMG report on which there is a lot of scope for positive action, which the MoEF should initiate, while rejecting the report.


1. The Inter Ministerial Group (constituted by the Union Ministry of Environment and Forests through an order issued on June 15, 2012) report has been submitted around April 22, 2013, but it is still not in public domain a month later. The report should have been promptly put in public domain as in the case of the HLWG report on WGEEP panel recommendation on the Western Ghats, which was made public the day after the submission of the report to MoEF. These comments[1] are based on the hard copy of the final report made available by a colleague[2].

2. The IMG final report has been endorsed by all members, except the dissent note by Rajendra Singh attached at Annexure X and a note on “alternate approach” from Sunita Narain, attached at Annexure XI. Shri Veer Bhadra Mishra, who was the third non-government member, expired during the period of functioning of the IMG group. The committee constitution was heavily loaded in favour of the government officers (ten of the fifteen members were government officials), so its independence was already in doubt. With none of the non-government members endorsing the report, the report has little credibility. This review tries to look at the report with an open mind.

3. While SANDRP as a group is critical of large, destructive and non participatory hydropower projects, it does not mean the group is against all hydropower projects. For example, if the projects were to be set up through a participatory and informed, decentralized, bottom up decision making process or if projects were to follow the recommendations of World Commission on Dams, such projects would certainly have greater public acceptance. That is not the case for any of the projects today.

4. The main TOR given to the IMG was to decide the quantum of environment flows for the upper Ganga basin rivers, keeping in mind the IIT (Indian Institute of Technology Roorkee, the report was basically from some individual of Alternate Hydro Electric Centre of IIT-R) and WII (Wildlife Institute of India) reports on cumulative impact assessment of the projects in these river basins. However, IIT (Roorkee) report has been found to be so flawed and compromised (for details see: that it should have been rejected by the MoEF and the NGRBA. Even the MoEF’s Expert Appraisal Committee on River Valley Projects has been critical of the IIT-R report. However, since a member of the IIT-R was present on the IMG, it may not have been possible for the IMG to take an objective view of the merits of IIT-R report. It is however, welcome that IMG has relied on WII rather than IIT-R report while accepting recommendations on e-flows. WII report was better in some respects, though still suffering from some basic infirmities. Moreover, to set up an IMG to decide on the course of action considering these two reports (and any other relevant reports) was compromised at the outset and was an invitation for further dilution of the environment norms, considering the track record of the most of the members of IMG.


Ganga river flowing through a channel, diverted for the 144 MW Chilla hydropower project

5. The recommendations of the IMG report are an exercise largely in supporting the interests of hydropower lobby in the name of balancing the power & development needs of the region and local people. The IMG has actually attempted to make 69 large hydropower projects in the Upper Ganga basin a fait accomplice when only 17 of them are under operation and 14 are under construction. In many cases IMG has reached unscientific and unfounded conclusions. Some of the recommendations are also contradictory in some fundamental nature. In many cases IMG has made statements, and implied recommendations that are bad in law. In general, the report shows that IMG has poor understanding of the science of the rivers. Even

where the IMG has sought to make some seemingly environment friendly recommendations, it is generally not serious about these recommendations. All of these points are further elaborated in this note.

6. Cancelled projects  & those on Bhagirathi Eco Sensitive Zone shown as under development Shockingly, even the projects like the Loharinag Pala, Pala Maneri and Bhairon Ghati that have been officially dropped are shown as under development by the IMG, see Annex VID! In fact in Table 12 and 13 IMG even calculates the reduction in power generation and increase in tariff at Loharinag Pala (among others) if the IMG recommended e-flows are implemented! The 140 MW Karmoli HEP on Bhagirathi, on a stretch that the MoEF has been declared as Eco Sensitive Zone, and on which the GOI has said no large hydro will be taken up, the IMG has actually suggested that the project can be taken up! The 50 MW Jadhganga project, very close to the Gangotri, is shown to be project under development by the IMG! These examples show how the IMG has played a role of supporter of the hydropower lobby.

7. Wrong classification of projects as under construction and under clearance projects IMG has divided the 69 hydropower projects in Upper Ganga basin (leaving our the Kotli Bhel 2, since it is on Ganga river and not on Bhagirathi or Alaknanda) in four categorie

s: Operating projects, under construction projects, under clearance projects and under development projects. It is here that IMG has done its biggest manipulation by classifying a number of projects as under construction when they are not and cannot be under construction. IMG classification of projects under clearances is equally problematic. IMG and even the “alternative View” by Sunita Narian says all these projects in first three categories can go ahead without any change, except the e-flows recommendations. This manipulation shows the stark pro hydro-bias of the IMG.


Dry Ganga river after the river is diverted for Chilla HEP. Photos by SANDRP

8. Manipulations about percentage length of river that the projects can destroy On the one hand, the IMG has recommended that “projects may be implemented so that not more then 60% of the length (of the river) may be affected.” There is no mention how they have arrived at this magic figure of 60%, what is the basis or science behind that magic figure. At the same time the IMG has said that if all the 69 projects were to be implemented than 81% of Bhagirathi and 65% of Alaknanda will be affected. Firstly these numbers are not correct if we taken into account the full length of the reservoirs and the bypassed river lengths by the hydro projects, in many cases the length of the submerged reservoir behind the dam has not been counted. Here we need to add the fact that the reservoir of the 70th Project on its list, the Kotlibhel 2 project will submerge parts of both Bhagirathi and Alaknanda rivers, which has also not been counted by the IMG. WII had to recommend 24 projects to be dropped, and even after that, WII assessed that 62.7% of the rivers would still be affected. However, the IMG has made no recommendation as to which of the projects need to be dropped (except vague review of the projects in Annex VI-D) to achieve that magic figure of 60%. This again shows how non serious IMG is, making this recommendation meaningless.

9. IMG double talk on distance criteria The IMG has said that “There is a clear need to ensure that adequate river length is available to meet the societal needs and River gets adequate time during its flow to regenerate itself” (emphasis added). This sounds good. But IMG has shown no will or interest in ensuring that this happens. In fact IMG exposes its understanding on this matter when it says, “the distance between two hydro projects should generally be such as to ensure that over-crowding is avoided”. What is over-crowding, how do you define it? This is a funny word IMG has used, not even bothering to define it. However, when it comes to implementation, dumping all these requirements, IMG has justified smaller distance (read zero distance) between projects where gradient is high. Now let us understand this: where gradient is high, if the distance left between the projects is less, will the time the river flows between projects be smaller or greater than if the gradient is low? Clearly, if gradient is high, for the same distance, the river will have less time to travel then if the gradient were low. It is in fact the time of free flow that is a crucial driving parameter for river to regenerate itself. So if the river were to have the same amount of time to flow between two points, with higher gradient, river will require more distance, not less. This again exposes the poor understanding of IMG members about science of the rivers.

The IMG even goes on to say that “distance will have to be smaller in view of technical requirement of the hydro power. This could result in continuity in some cases.” Firstly it is clear here again that IMG is basically catering to the hydropower lobby, it is completely non serious about the environmental issues. That is why after all those great sentences, it goes on to say that it is the technical requirement of the hydropower project that will be the decider! If technical requirements means no distance between two projects, then river can disappear, environmental issues do not matter! In case of many projects where the distance of free flowing river between projects is very little or nil and where the construction has not started or has not progressed much, there is today scope for change. For example in case of Vishnudgad Pipalkoti HEP on Alaknanda: the Full Reservoir Level of the VPHEP is same as the Tail Water Level of the upstream Tapovan Vishnugad HEP. This means that there is zero length of free flowing river between the projects. VPHEP does not have all the clearances and its construction has not started. Even for the upstream Tapovan Vishnugad HEP, the construction has not gone far enough and there is scope for change in both projects to ensure that there is sufficient length of free flowing river between the projects. IMG should have recommended change in parameters in this and other such cases, but it has done no such thing, it has shown no interest in any such matter! Even the “alternative approach” note in Annexure XI has not bothered to recommend such changes even while recommending 3-5 km free flowing river between two projects.

The IMG makes another unscientific statement in this context when it says, “With the recommendation of IMG for environment flow which will be available and which would have traveled throughout the diverted stretch, any significant gaps and large distance may not be required.” This is an unscientific, unfounded statement. Firstly where is the evidence that the environment flows that IMG has suggested would take care of the need for river to flow on stretches between the projects? Secondly, the need for river to flow between the projects to rejuvenate itself will also depend on the length of the rivers submerged by the reservoirs, and also depend on the biodiversity, the social, cultural and religious needs in addition to the ecological needs. By making such ad hoc unfounded statements devoid of scientific merit, the IMG has exposed itself.

While the IMG talks about the rich diversity of fish species and other aquatic diversity of the river, it has no qualms in saying that e-flows alone will address all the problems caused by bumper to bumper projects. As many including Government of India’s CIFRI (Central Inland Fisheries Research Institute) have concluded, Dams have been the primary reason for the collapse of aquatic diversity in India, not only because of the hydrological modifications and lack of e-flows, but also because of the obstruction to migration they cause, destruction of habitat during construction, muck disposal, trapping of sediments, destruction of terrestrial (especially riparian) habitats. But these concerns are not even considered by the IMG while saying that recommended e-flows will be able to solve all problems caused by bumper to bumper projects.

Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute

Dry Bhagirathi downstream Maneri bhali HEP Photo: Peoples science Institute

10. WII recommendation of dropping 24 HEPs rejected by IMG without any reason The IMG notes that WII has recommended that 24 hydropower projects of 2608 MW installed capacity should be dropped in view of the high aquatic and terrestrial biodiversity. However, IMG decides to dump this WII recommendation without assigning any reasons. This again shows the strong pro hydro bias of the IMG. WII report says that even after dropping these 24 projects, at least 62% of the river will be destroyed.

It is shocking that projects like Kotlibhel 1B and Alaknanda HEP, which have been rejected by WII and Forest Advisory Committee, is considered as “under development” by IMG, when they should have been rejected. While the IMG Report talks of unique biodiversity of the Ganga Basin, Valley of Flowers and Nanda Devi National Parks, it still supports projects which will be affecting these National Parks like the 300 MW Alakananda GMR HEP, which was also rejected by the WII and FAC (twice).

As a matter of fact, of the 24 projects that WII report recommended to be dropped, the IMG has shown 8 as under construction and 4 as “projects with EC/FC clearances”. This is sheer manipulation, in an attempt to make them a fait accomplice. Strangely, the “alternative approach” note in Annexure XI does not say anything about this manipulations and in fact says the projects in Annexure VI-B and VI-C can go ahead!

11. Non serious recommendation about keeping six tributaries in pristine state IMG (Para 3.70) “recommends that six rivers, including Nayar, Bal Ganga, Rishi Ganga, Assi Ganga, Dhauli Ganga (upper reaches), Birahi Ganga and Bhyunder Ganga should be kept in pristine form and developments along with measures for environment up gradation should be taken up. No new power projects should be taken up in these River Basins.” This sounds good, but turns out to be like a joke, since firstly, IMG recommends construction of projects on these rivers that yet to be constructed! If these rivers are to be kept in pristine state then IMG should have asked for immediate stoppage of under construction projects and also time bound decommissioning of the operating projects on each of these rivers. In stead, the IMG report shows that projects are under construction on rivers like Assi Ganga (stage I and stage II projects each of 4.5 MW), Birahi Ganga (24 MW stage I project), Bal Ganga (7 MW stage II project listed in Annex VI B of IMG report, in addition to the 1 MW Balganga and 5 MW Balganga I project are also under construction as per IIT Roorkee report) and Bhyunder Ganga (24.3 MW stage II project) and IMG has (implicitly) recommended that these projects be allowed to continue, on rivers that IMG says it wants to remain pristine! Moreover, Rishi Ganga (13.2 MW project) and Birahi Ganga (7.2 MW) have operating projects on these rivers to be kept pristine! In addition, on Assi Ganga the 9 MW stage III project, is considered by the IMG as ready for development since it has some of the clearances.

Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu

Rishiganga HEP Photo: Ashish Kothari, Courtesy The Hindu

The IMG has noted that 70 MW Rishi Ganga Stage-1 and 35 MW Stage II Project are under development on Rishi Ganga (IIT-R report mentioned another project on Rishi Ganga, namely the 60 MW Deodi project, it is called Dewali project by WII report; WII report also mentions 1.25 MW Badrinath II existing project on Rishi Ganga) and 24 MW Birahi Ganga-II project is under development. But the IMG does not recommend dropping of these projects.

So at least five of the six rivers that the IMG claims it wants to stay in pristine state are no longer pristine! They have multiple projects, most of them under construction or yet to be developed and the IMG has not said that any or all of these projects should be stopped, cancelled and those under operation be decommissioned in time bound manner. Even on Nayar, the sixth small tributary that IMG said should be kept in pristine condition has a 1.5 MW Dunao project under development by UJVNL, as per the UJVNL website. It’s clear how non serious IMG is about its own recommendation. IMG has included Dhauli Ganga (upper reaches) in this recommendation, but has not even bothered to define which stretch of the Dhauli Ganga this applies to, again showing the non-seriousness of IMG.

In para 4.22 IMG says, “Specifically, it is proposed that (a) Nayar River and the Ganges stretch between Devprayag and Rishikesh and (b)… may be declared as Fish Conservation Reserve as these two stretches are comparatively less disturbed and have critically important habitats for long-term survival of Himalayan fishes basin.” If IMG were serious about this, they would have also said that Kotli Bhel II project should be cancelled since it is to come in this very stretch.

IMG’s claim that not having any more projects on these six streams will mean loss of generating capacity 400 MW is also not backed by any sort of information or list of projects to be dropped, it seems IMG is in the habit of making such claims and does not feel the need to back them.

12. IMG on environmental impacts of Hydropower projects One of the key TORs given to IMG was “to make a review of the environmental impacts of projects that are proposed on Bhagirathi, Alaknanda and other tributaries of river Ganga and recommend necessary remedial action.” What has the IMG done about this TOR? IMG wrongly claims (Para 4.18), “The environment impact of proposed 69 hydropower projects has been considered by IMG.” It has done absolutely no justice to this very crucial TOR. First thing IMG has done in this regard is to dump the WII recommendation to cancel 24 hydropower projects, without giving any justifiable reasons. The IMG has produced a set of guidelines for the hydropower projects, which have almost nothing new, they are certainly not comprehensive or legally binding. They miss the most important issues of inadequate environment impact assessment, inadequate public consultation process, inadequate appraisal, lack of accountable governance and compliance.

What is required is certainly not new set of guidelines. MoEF already has a long list of environment and forest clearance conditions, environment management plans and manuals. But there is no interest, will or willingness to achieve compliance in MoEF. IMG is obviously aware of this state of affairs. Yet they have happily prepared a new set of five page guidelines just to show they have done something about this TOR. The “alternative approach” in Annex XI also has nothing to offer on this score.

Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan

Muck Disposal directly into the Alaknanda river by Srinagar Project Photo: Matu janSangathan

13. Unwarranted conclusion about BBM methodology The IMG has said, “Considering environment, societal, religious needs of the community and also taking into account the status of river Ganga as national river, the IMG recommends adoption of Building Block Methodology (BBM) for assessing the e-flow requirement”. This is good and needs immediate and credible implementation.

However, IMG says this will be applicable only “in situation where the required conditions are satisfied and resources, time and data are available.” The only basis for this conclusion by IMG is the fact that WWF took three years to do a study of environment flow requirements of three sites along Ganga involving large number of experts. This is clearly an unwarranted conclusion since WWF was only doing it first time and has much less resources at its disposal than the government have. By arriving at this unjustified conclusion that has no basis, the IMG implies is that BBM methodology is required and is justified, but Indian rivers including the Ganga won’t get it since IMG (wrongly) thinks that “required conditions” are not satisfied. This is clearly wrong and unwarranted conclusion. The BBM can and must be applied in all cases immediately, including for all existing and under construction projects and cumulative impact assessments.

Also, while stating multiple times that BBM for three locations for Ganga took three years, the IMG does not go into the details of what caused this delay. One of the important reasons stated by WWF itself is that required data was not made available to them, which contributed to the delay. So it is the government itself that was part of the reason for the delay in WWF study, and now IMG uses that delay to suggest that BBM is not practicable for Ganga! If the Government has the will to implement a more holistic methodology like BBM, it can be done and IMG conclusion is unwarranted and wrong.

14. Unjustified pro hydro bias of the IMG The IMG has shown its pro hydro bias at several places. At one place it says that a balanced approach needs to be taken as “It is important to see that the flows do not result in exorbitant cost of power which the people of the region may not be able to afford. This would make these power projects uneconomic and un-implementable”. Firstly, as far as people in immediate neighbourhood of the projects are concerned, history of grid connected hydropower projects in India shows that local and particularly the affected people almost never get power benefits from projects but they surely suffer all the negative impacts. IMG is wrong as far as this section of the people is concerned.

Secondly as far as the people of Uttarakhand in general are concerned, where all the projects in Upper Ganga basin are situated, the state would get 12+1 % of free power. Since most of the projects are in central or private sectors, the rest of the electricity would mostly go outside the state. As far as this 13% free power is concerned, since it is supposed to be free, there will be no impact of e-flows on the tariff of such projects, except some marginal reduction in quantum of power.

Lastly, is it the bottom line of the IMG that projects must be economic and implemented at all costs, by hook or by crook, as is apparent from the above quoted sentence? How can that be the bottom line of IMG considering its TORs? Moreover, by making the projects economic and implementable by hook or by crook, the IMG seems to be saying that irrespective of the social, environmental, cultural, religious and even economic costs, the projects must go on. Thus what IMG is suggesting is that artificially low cost electricity must be produced for the cities and industries irrespective of any concerns of costs and impacts on people, environment, future generations and rivers including the national river! This is clearly a plea to export the water, livelihood and environment security of the people for the short term economic prosperity of far off city dwellers and industrialists. Is this acceptable?

15. What is environment flow? IMG should have provided a definition of what is meant by river and environment flow. Since it is linked with enabling the river to perform its various roles and services in the downstream area, it cannot be just limited to water flow downstream. The downstream river also needs silt and nutrition from the upstream and the biodiversity and geomorphology in the river crucially depends on such flows of nutrition and silt. However, IMG has said nothing on this count.

Dry River at Uttarkashi Photo: Open Magazine

Dry River at Uttarkashi Photo: Open Magazine

16. Environment flows = aviraldhara? The IMG has said, “Environment flows in the river must lead to a continuous availability of water (aviraldhara) in the river for societal and religious needs.” This equation of aviral river with continuous flow of water is clearly flawed, since by that token even a pipeline has aviraldhara, but a pipeline is not the same as aviral River. For a river to be flowing aviral, continuous flow of water is a necessary but not a sufficient condition. A river means so much more.

17. No attempt at assessment of social, religious, cultural needs The IMG keeps talking about social, religious and cultural perspective and needs of the society from the river and so on. However, there has been no attempt to assess what exactly this means in terms of river flow, quality, content of flow across the time and space. More importantly, how is all this to be decided and who all are to be involved in the process. IMG just assumed that this has already been done by IITR and WII, which is flawed assumption, since WII or IIT-R has clearly not done any such assessment. So in stead of giving standard monthly flow release percentage across the rivers (releases to vary based on daily flow variations, this recommendation of daily changing flow is certainly an improvement from IMG), IMG should have asked for actual assessment of such needs across the rivers and IMG should also have given the process for arriving at such decisions. But while deciding social, religious or cultural needs, the IMG sees no role for the society, religious groups or cultural institutions.

In this context it may be added that the IMG has also not taken note of the legal stipulations like the order of the Allahabad High Court that says that no project can divert more than 50% of river flows existing at the point of diversion.

DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia

DevPrayag: Confluence of Alaknanda and bhagirathi Threatened by Kotli Bhel I A, IB and II Projects. Photo: Wikimedia

18. IMG recommendation during High Flow Season (May-Sept) The IMG has recommended 25% of daily uninterrupted (no clear definition is given how this will be arrived at) flow, with the stipulation that the total inflow in the river would not be less than 30% of the season flows. This is same as 30% of mean seasonal releases recommended by WII (para 8.3 of WII report, para 4.11 of IMG report) and also used by even Expert Appraisal Committee on River Valley Projects currently. The recommendation of releases based on daily flow is an improvement compared to the earlier situation, but its implementation is in serious doubt considering the weak compliance requirements from IMG.

It should be added here that IMG has not mentioned how the environment flow will be released. Just dropping it from the top of the dam won’t help, the flow must be allowed to flow downstream in an environmentally sound manner that is as close as possible to the flow of the river and helpful for the biodiversity in the river to link up from downstream to upstream and vice versa. Moreover, while deciding flows, IMG has largely followed the recommendations of the WII. However, WII conclusion of classifying Upper Ganga basin under EMC class C itself is flawed. IMG should have corrected this flaw, before concluding on environment flows.

19. IMG recommendation during Lean Flow season (Dec-March) The IMG has recommended (Para 3.48) release of 30% of daily uninterrupted river flows, this will go up to 50% where the average monthly river flows during lean season (Dec-March) is less than 10% of average monthly river inflows of the high flow season (May-Sept) and to 40% (however, Para 3.51 does not mention this 40% norm) where this ratio is 10-15%. While this is an improvement in the current regime, this remains weak considering that IMG has not done project wise calculations where 30, 40 and 50% stipulation is applicable, which it could have easily done at least for the existing and genuinely under construction projects.

20. IMG recommends lower flow for India’s national river compared to what India promises Pakistan in Jhelum basin The IMG has recommended 30-50% winter flows for all projects as described above. This in case of a river everyone recognizes as the heart and soul of India, a river that has such an important social, religious, spiritual significance and it has been declared as the national river. Let us compare this with what e-flows Indian government has promised to Pakistan downstream of the Kishanganga Project in Jhelum river basin in Kashmir. In a case before the Permanent (International) Court of Arbitration (PCA), Indian government has assured that India will release more than 100% of the observed minimum flow from the dam all round the year, and now in fact the government is considering even higher than 100% of the observed minimum flow all round the year. The PCA is yet to decide if what India has proposed will be sufficient or more water flow is required. So, as against the assurance of more than 100% of minimum flow at all times on another river, for the river flowing into another country; for the national river Ganga, for India’s own people and environment, all that the IMG recommends is 30-50%. On most winter days, KishengangaRiver downstream of the hydropower project, flowing into Pakistan, thus will have higher proportion of its daily flows than what Bhagirathi or Alaknanda will have.

Dry Ganga at Haridwar in August 2012 Photo: SANDRP

Dry Ganga at Haridwar in August 2012 Photo: SANDRP

21. Monitoring and compliance of Environment Flows The IMG has said that effective implementation is cardinal part of its recommendations. This is good intention. However, by asking the power developer to be responsible for the implementation, the IMG has made the recommendations ineffective. IMG has chosen to ignore the fact that there is clear conflict of interest for the power developer in assuring e-flows, since the e-flows would reduce the power generation and profits of the developer. Its faith in IT based monitoring is also completely untested and there is no evidence to show that such monitoring will be free of manipulation. Secondly, to ask the MoEF to do annual review, that too only for first five years ignores the track record of MoEF in such matters where MoEF has shown no will, capacity or interest in achieving post-clearance compliance of the environment laws of the country. Thirdly, to require this only for projects above 25 MW shows the lack of understanding of IMG as to how important the smaller streams are for the water, ecology and livelihood security of the community in hills. Its recommendation of monitoring by an independent group is welcome, but lacks credibility in the absence of sufficient involvement of local community groups in such a mechanism.

22. Baseless assumption of low water requirement for fish in the Himalayan region The IMG has assumed that in the Himalayan region, the water requirement for fish in the river is less and hence the rivers here will not require as much water as the rivers do in the plains. This is completely unscientific, flawed and baseless assumption. The amount of e-flows needed has to be assessed not only based on the requirement of fish (IMG has not done even that assessment), but entire aquatic and connected terrestrial biodiversity across the seasons, in addition to the water needs of a river for providing the social and environmental services.

23. Suggestions that are bad in Law The IMG report shows several projects as “Under Construction” (Annex VI B) category, when they do not even have statutory clearances and hence cannot even legally start the work. This is a ploy to make these projects a fait accomplice when these projects are perfectly amenable to review and rejection since the project work has not started. In fact to categorise such projects without having all the statutory clearances (e.g. Vishnugad Pipalkoti does not have forest clearance) as under construction project is plain illegal.

24. Wrong representations The IMG has shown several projects in Annex VI C, as “Hydropower projects with EC/FC Clearances and others”, basically a ploy to push the projects that do not even have all the statutory clearances. None of these projects have all the statutory clearances and are certainly not in position to start construction and hence these projects are the ones where dropping of the projects or modifications in dam location, dam height, FRL, HRT length, e-flows, capacities etc are still possible. But IMG did not do it for any of the projects. As mentioned above, four of these projects have been recommended by WII to be dropped, and IMG should have recommended dropping these or should have categorized them as ‘to be reviewed’.

25. No mention of impact of peaking operation of hydropower projects The IMG has missed many crucial environmental impacts. One crucial one that it has missed is the issue of peaking operation of hydropower projects on the downstream people, environment, flood plains, geo morphology, biodiversity and other aspects of the river. This is very important since one of the Unique Selling Proposition (USP) of hydropower projects is supposed to be that they can provide peaking power. However, peaking operation means sudden changes of huge magnitude of flows in downstream river, having far reaching impacts including those on safety of people, flood plain cultivation, impacts on cattle and property, impact on ecology, amongst many others. The IMG has completely missed this, which is very strange since this is a huge issue being taken up by people and campaigns in the North East against large hydropower projects there.

26. IMG cannot see through poor work of IIT-R It is well known that IIT-R report on Ganga basin study is of poor quality. In the IMG report there is an attempt to respond to only a couple of the criticism of IIT-R report, but IMG could not even see through the wrong facts presented by IIT-R report. For example, IMG report says, “The requirement of flushing during monsoon is not required in both rivers as all hydro projects except Tehri reservoir are run of river types where silt is not stored.” This is completely wrong. All the projects, even if run of the river, have storage behind the dam where the coarser silt will settle down and will need to be flushed out periodically. The dams are being provided with bottom sluices to facilitate this. A quick perusal of the EIA reports of some of the hydropower projects in the region shows that Vishnugad Pipalkoti, Srinagar, Kotli Bhel 1-A, Kotli Bheal 1-B, to name only a few all have proposed to provide bottom sluices for periodic release of silt accumulated behind the dam. Thus the contention that most projects do not need flushing is wrong. In any case, for all projects, the de-silting chambers would be releasing silt laden water and there is no attempt to assess the cumulative impacts of such actions. IMG’s attempt to provide scope for some defense for the IIT-R has clearly back fired on IMG! Moreover, even in case of Tehri, the biggest project in the region under review, IMG report has nothing at all, about it social, environmental impacts and performance, about its power generation, irrigation, water supply, flood control performance or even its silt management performance.

The contention that all projects except Tehri are ROR is entirely wrong and misleading. Even as per the WII report, out of the 69 projects, a whopping 13 projects are storage projects. This includes the biggest and most problematic projects like Srinagar, KotliBhel IB, KotlibhelIA, Koteshwar, Vishnugad Pipalkoti, Devsari, etc.

27. IMG on Srinagar HEP and Dharidevi Temple The IMG was also asked to “review the impacts of the Alaknanda (GVK) Hydro Power Project on flow of the River and the issues related to the temple relocation.” The IMG gave an interim report on this issue, which was so disappointing that Rajendra Singh and Late Shri Veer Bhadra Mishra both members of the IMG, gave a dissenting note, Rajendra Singh also suggested shelving the project. The IMG rejected the suggestion of its own members without giving any justifiable reasons.

DhariDevi Temple threatened by submergence

DhariDevi Temple threatened by submergence

28. Time bound action plan for E-flows from existing projects The IMG says that the existing projects should also follow the suggested e-flows and this should be achieved in three years (Para 3.52). However, IMG should have been more clear about the role of different agencies (MoEF, state government, developers, state electricity regulatory commissions and power purchases) and what is the legal backing such a step will have.

29. Lack of understanding of conflicting projects and public protests The IMG report, Annex VI B shows 12.5 MW Jhalakoti (wrongly) as under construction project. In fact the Jhalakoti project has been recommended by WII to be dropped. The IMG seems to have no clue that Jhalakoti project is being strongly opposed by the local communities and no work has started on the project. The under construction status given by IMG for this project is clearly wrong. If the Jhalakoti HEP comes up then the existing 40 KW Agunda micro HEP will no longer be able to function. Many of the other projects including the Devsari and Vishnugad Pipalkoti HEP are also facing strong opposition, but the IMG has not taken note of these or any of the social impacts of the projects in the Upper Ganga basin.

Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan

Peoples protests against Large dams on Ganga. Photo: Matu Jansangathan

30. IMG on TOR on pollution abatement in Ganga It is good to see that IMG has suggested that “all users must be forced to plan for water needs based on what the river can spare, not what they can snatch.” However this should not mean an advocacy for more big dams and storages on the rivers. This seems to be the case when we read the IMG recommendation that says, “The government then has a choice to build storages to collect monsoon water for dilution within its territory or to ‘release’ water to rivers and make other choices for use in agriculture, drinking or industry”. Storages can come in many forms and sizes and IMG should be careful not to recommend more big storages on the rivers. The suggestion that “there will be a clear conditionality in Central government funding, which is matched to the quantum of ecological flow released by the state in the river” is welcome. Linking of JNNURM-II and National Mission for Clean Ganga to the above norm, incentivisation of use of innovative bioremediation and in-situ drain treatment are also welcome. However, IMG has shown no interest in understanding or tackling the real problem in river pollution: Lack of participatory, democratic governance in urban water and pollution control regime.

IMG has recommended in Para 6.7(i), “Ecological flow will be mandatory in all stretches of the river.” This is welcome. IMG goes on to suggest some norm for the urbanized stretches of rivers, but no norms are suggested for the non urbanized stretches of river in the lower river basin.

31. Report does not reflect the discussions in IMG? The dissent note by Shri Rajendra Singh, a member of IMG says that on several aspects, IMG report does not reflect what transpired in the IMG meetings. This is a very serious charge that puts a big question mark on the IMG report and its recommendations, particularly since Rajendra Singh is the lone independent voice in the IMG after the sad demise of Shri Veer Bhadra Mishra[3].

32. Incomplete project list The IMG does not seem to have full information about the existing, under construction and planned hydropower projects in the Upper Ganga basin in Uttarakhand. Some of the projects not listed in the IMG report include:

A. Operating projects under 1 MW: According to the website of UJVNL (Uttarakhand Jal Vidhyut Nigam), the state has 12 such projects with total capacity of 5.45 MW, see for details: Most of these projects are in Upper Ganga basin, though it is not clear how many.

B. UJVNL has larger list of schemes under development by UJVNL including in the Upper Ganga basin, not all of them are included in the IMG list, see:

C. Private sector has been given license for a large number of hydropower projects, not all the projects of Upper Ganga basin here are on IMG list, see for full list of projects being developed by IPPs in Uttarakhand:

D. There is another “full list” of hydropower under development in Uttarakhand including sub-MW size projects, see: Some of the projects here in Upper Ganga basin do not figure on IMG list.

One would expect better information base of the IMG than what they have shown.

33. No specific recommendation to save the prayags There are five holy prayags (confluence of rivers) along Alaknanda river in Uttarkhand, including Deoprayag, Vishnuprayag, Karnaprayag, Rudraprayag and Nandprayag.

Vishnuprayag has already been destroyed by the 400 MW existing Vinshnuprayag HEP of Jaiprakash Associates, rest would be destroyed by the projects listed by IMG. The IMG keeps talking about cultural importance of the rivers, but has not said a word about how it plans to save these culturally important confluences and how it plans to rejuvenate the Vishnuprayag already destroyed.

34. “Alternative View” in Annexure 21: How much of an alternative is it? In Annexure XI of IMG report, a note authored by one of the IMG members, Sunita Narian of Centre for Science is given, it is titled: “TOR (ii): Alternative View: Environment flow”. The Annexure opens with the line “The recommendations of this IMG report are not acceptable.” It is not clear if this sentence applies to all the recommendations of the IMG or about environment flows mentioned in the title or it applies to TOR (ii) that applies to all environmental aspects, not just environmental flows. The Annexure also deals with some issues besides environment flows, so one assumes this “alternative view” is about environmental aspects of hydropower projects.

The Annexure XI seems to give an impression that, principles of distance between dams, ecological flow and limit on % of river than can be “affected” will lead to “sound hydropower development, balanced for energy and environment”.

One of the three principles listed in the note says: “Distance between projects: 3-5 km”. The note does not say how this distance has been arrived at or how this distance is to be measured, the least the note should have mentioned was that this is not distance between projects but distances of flowing river between the Tailwater level of upstream and full reservoir level of downstream project.  No elaboration is given about this criterion at all. Most importantly, there is not even any attempt to apply this criterion to the projects that IMG is supposed to look into. On the contrary, the note says that “The projects under construction can be built” (point 7(ii)) and “projects with EC and FC clearances can be taken up for construction” (point 7(v)). So in fact there is absolutely no application of the criterion to the projects on hand. The conclusion that this is half baked and non serious criterion is inescapable.

Another of the three principles listed in Annexure XI is: “Maximum intervention allowed in river length: 50-60 per cent”. Again there is no elaboration as to how these figures are arrived at, why there is a range, what is meant by “intervention”, which lengths it will apply and so on. Again, the note does not bother to apply this criterion to the rivers under review and actually says in point 7(ii) and 7(v) described above, that projects in Annexure VI (B) and VI(C) can go ahead without even checking if in that case this criterion will be violated or not. Again the conclusion that this is also a half baked and non serious criterion is inescapable.

The whole of the Annexure XI is basically devoted to application of the third principle: “Ecological flow regime: 30/50 per cent (high and lean period)”. About this, the annexure says: “The engineering design of the uninterrupted flow would take into account the need for sediment and fish transfer”, not clear how this will be achieved. The Annexure does not suggest any new measure of achieving compliance with its recommendations. The note mentions “design changes incorporated to maximize energy generation during high discharge season” but does not elaborate what these would mean.

Annexure XI says that IIT-R tried to suggest that e-flows must be low and in this effort did “big and large manipulation of data”. This is good. However, it would have been better if the full data and notes from IIT-R were annexed here to illustrate how the manipulation was done.

Bullet point 3 in Annexure XI reads, “It is important to consider that water of a river is similar to the coal or gas as raw materials used in thermal plants”. This statement needed to be qualified that the impact of taking out coal or gas from its source is not comparable to taking out water from the river, the latter’s impact is much more severe, since river is not equal to just water flowing in it.

Since Annexure XI does not raise objection to any other conclusions and recommendations of the IMG except the three principles mentioned above, it would not be incorrect to assume that author agrees to the rest of the IMG report. This, when taken together with the fact that at least two of the three principles in the alternative view note have not been applied to the projects under review, leads to the conclusion that there is not much of an alternative in “alternative view”  note and this won’t help the cause of the river, people, environment or even sustainable and sound development.

35. Conclusion A broad conclusion is inescapable that the IMG report (except the dissent note by Shri Rajendra Singh) is largely an exercise in deception, with a pro-hydropower bias. While this note points out key negative aspects of the IMG report, the IMG report is not without some positive aspects. One of the positive aspect of this report is that possibly for the first time heads of central organizations like CWC and CEA have sat with some non government members to discuss some important subjects that have remained contentious for these official agencies.

However, as noted above, on most positive aspects, while IMG has been less than sincere, there is a huge potential to take the environment flow movement forward.

The MoEF and NGBRA should, considering all the above points, take some positive aspects forward. Some of the positive retrievable aspects of the IMG report include the following, on each of which there is a lot of scope for serious action:

  • Ensuring at least 50% E-flows in non monsoon months in all rivers.
  • Keeping some rivers in pristine form, stopping all ongoing and planned projects on suggested rivers and time bound decommissioning of existing projects on such rivers that are to be in pristine form. This should be immediately implemented on the rivers recommended by IMG and also in other selected rivers in all river basins.
  • Rejecting planned and under construction projects which have high impact on terrestrial and aquatic biodiversity, as per score developed by WII Report as well as projects which irreversibly impact spiritual and religious places like rivers, prayags, places of worship and ghats.
  • Give deadline of one year and maximum of two years for all the existing dams, diversions and hydropower projects across the Ganga basin (& other rivers) to achieve the suggested e-flows with clear inbuilt mechanisms for monitoring and compliance with participation of river basin communities, as a first step.
  • Accepting BBM as the standard methodology for E-flows assessment, e-flows to mimic the river flows and involving communities as an important stakeholder in this methodology.
  • Ensuring Aviraldhara.
  • Ensuring rivers have adequate free flow time between projects to regenerate itself. Mandating at least 5 km free flowing river between any two projects as an immediate measure pending site specific studies and reviewing all under construction, under clearance and under development projects in the basin keeping this in mind.
  • Releases based on daily flows rather than monthly or seasonal averages in all rivers. Define uninterrupted flows to arrive at uninterrupted daily flows.
  • Monitoring of e-flows and other environmental compliance by independent group involving at least 50% of the monitoring group from local communities.
  • Assuring that e-flows through well designed fish passages (taking consideration of Guideline 7, Annex IX).
  • The IMG has recommended that a technical group may be made to study alternatives including the alternative suggested by Prof Bharat Jhunjhunwala that only partial dams across rivers may be allowed. This should happen expeditiously. The proposed projects should be stopped till this is done.

Himanshu Thakkar (

South Asia Network on Dams, Rivers & People (

Endorsed by:
EAS Sarma, Former Union Power Minister, Visakhapattanam,

Vimal Bhai, Matu Jansangathan, Uttarakhand,

Malika Virdi, Himal Prakriti, Uttarakhand,

E Theophilus, Himal Prakriti, Uttarakhand,

Ramnarayan K,  Save the Rivers Campaign Uttarakhand,

Dr Latha Anantha, River Research Centre, Kerala,

Parineeta Dandekar, SANDRP, Pune,

Samir Mehta, International Rivers, Mumbai,

Tarini Manchanda, Independent film maker, Delhi,


Current state of our National River at Haridwar  Photo: SANDRP

Current state of our National River at Haridwar Photo: SANDRP

[1] The author is thankful to Parineeta Dandekar, Shripad Dharmadhikary and Samir Mehta among others for providing comments on earlier drafts.

[2] Prof Bharat Jhunjhunwala provided the copy.

[3] One of the members of the IMG started discussing the report in public domain through her writings even before the report was in public domain, see: and This can create misleading impression about the report, when the readers do not have benefit of cross checking what the report is actually saying. The articles in any case are full of serious errors, for example it said: “Most of the proposed projects are run-of-the-river schemes, which are seemingly benevolent as compared to large dams”, not understanding that EACH of the so called run of the river schemes ALSO involves a dam, most of them are large dams as per international definition. It incorrectly said, “Run-of-the-river projects, which used flowing water as the raw material for energy”, in reality NONE of the so-called ROR projects generate power from flow of the water in the river, they all dam and divert the water away from the river to produce power. It also tried to dilute the impact of the projects on rivers (akin to killing of rivers) by saying projects “affect” rivers. It misleadingly wrote, “The hydropower engineers argued for 10 per cent e-flow” without mentioning that the EAC of MoEF is prescribing 20-30% of mean season flows. The article claimed that figures of water flow and tariffs were modified by IIT-Roorkee, but in the entire IMG report, (except the Annexure XI written by author of the articles), there is no mention of any of these. The article talks about engineers’ claims that “this source provides power during peak demand hours”, but as we noted above the IMG has not even looked at the impact of peaking generation. There is not even an attempt to understand how much of the current generation from hydropower projects is happening during peaking hours, or what is the generation performance of hydropower projects, issues that SANDRP has been raising for many years.

Comments on HLWG Report submitted to Ministry of Environment and Forests

This post is based on a submission made by SANDRP and our colleagues on the HLWG Report on Western Ghats. 20th May 2013 is the last date to submit comments on this. Comments need to be sent to: We request groups and individuals to make as many submissions as possible.

Comments on HLWG Report with a focus on Water issues

Date: May 20, 2013



Mrs. Jayanthi Natarajan

Union Minister of State (IC)

Ministry of Environment and Forests

Government of India



Dr. V Rajagopalan


Ministry of Environment and Forests

Government of India



Dr. Amit Love,

Deputy Director,

Ministry of Environment and Forests



Dear Mrs. Jayanthi Natarajan and Dr. Rajagopalan,


SUB: Comments on the High Level Working Group Report with respect to water sector

This is in response to announcement posted on MoEF website about submitting comments on the HLWG report under the Chairpersonship of Dr. Kasturirangan. These comments mainly deal with water in Western Ghats: One of the most critical issues for Western Ghats States.

A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP

A lady collecting drinking water from a sacred grove in Western Ghats Photo: SANDRP

Unfortunately, we have to note that recommendations of the HLWG Committee in response to WGEEP Report as well as some of HLWGs omissions and commissions are detrimental to the well-being of rivers, wetlands and dependent communities in the Western Ghats and hence, for related sectors like ecology, water supply, irrigation, hydropower, etc. This is elucidated in the following points:

  1. HLWG does not comment on any other issue related to water except hydropower:

While the Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamilnadu are facing multiple issues with respect to rivers, drinking water, irrigation, loss of biodiversity and livelihoods, dam-induced displacement, etc., the only issue HLWG report has commented upon is Hydropower. The WGEEP report has dealt with a number of issues related to the water sector from democratic community driven bottom up governance, watershed development, opposition to large dams in ESZ I and II, drinking water, fisheries, etc. However, the HLWG does not comment on any of these recommendations of the WGEEP, nor does it offer its own position on these. This is a serious lacuna in the HLWG Report.

In the absence of such recommendations, we request that MoEF adheres to WGEEP recommendations.

Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP

Fishing in Vashishthi Estuary, Western Ghats. Photo: SANDRP

  1. HLWGs recommendations about Hydropower are ad hoc, unscientific and misleading
  1. HLWG claims that all Hydropower is “renewable and clean.”

This is a completely incorrect statement and it’s surprising to see that it comes from HLWG. The world over, the myth of Hydropower as clean source of energy has been busted.[1],[2] Hydropower projects have huge impacts on environment, ecology, forests, rivers, biodiversity and livelihood security of the people. Studies have proved that methane emissions from reservoirs formed by hydropower dams in tropical countries can have significant global warming potential, methane being about 21 times more potent global warming gas than CO2. Dams emit methane at every draw down.[3] With tropical forests in the Western Ghats (WG) under submergence and otherwise destruction by such projects, this threat is even more serious. Already WG has some of the biggest hydropower plants in the country including the Koyna, Bhandardara, Ghatghat HEPs and three Tata HEPs in Maharashtra, Linganmakki, Gerisouppa, Bhadra, Tungabhadra, Upper Tunga, Talakalale, Kabini, Harangi, Chakra, Supa, Varahi, HEPs in Karnataka, Idukki, ldamalayar, Lower Periyar, Poringalkuttu, Sholayar HEPs in Kerala and Bhavani HEPs in Tamil Nadu. All these projects have not only contributed to greenhouse gas emissions, but have also adversely affected communities, forests, rivers and ecosystems in Western Ghats. There are numerous pending cases of rehabilitation from these dams (for example Koyna in Maharashtra) till date involving tens of thousands of people and communities in many areas are still suffering from erratic water releases from these projects (downstream communities near Jog Falls d/s Linganmakki).

Hydropower dams in WG are in many cases transferring water across the basin for power generation, making it unavailable of the original basin and its inhabitants (For example:  Interbasin transfers from Koyna and Tata Hydropower dams in Maharashtra). Every hydropower project has finite life. Thus, for the basin dwellers and everyone else, Hydropower not much renewable either.

 HLWG is not justified in giving a ‘clean and renewable’ certificate to hydropower.

Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP

Jog Falls on Sharavathy: Dried and diverted by the Linganmakki HEP in Karnataka Western Ghats. Photo: SANDRP


  1. HLWG allows Hydropower projects in ESAs while not looking at performance of existing projects

While the WGEEP did not allow large dams and hydropower projects in ESZ I and II, HLWG has allowed hydropower projects in its demarcated ESAs. This is unacceptable. Western Ghats are already ravaged by dams and at least the areas of high biodiversity value should now be protected from the same onslaught. But the HLWG has rejected WGEEP recommendations about this. While doing so, they have not looked at the performance of the existing HEPs in WG. SANDRP has been studying performance of HEPS in India for some time now based on generation data from Central Electricity Authority. The performance of existing hydropower plants in WG is dismal as can be seen below:

  • In Koyna Basin, the per MW generation in 2010-11 has dropped by a huge 56.79% from the highest per MW generation achieved in the year 1994-95.[4]
  • In Kali Nadi projects, the per MW generation has dropped by 46.65% from the highest per MW generation achieved in 1994-95[5]
  • In Sharavathi Basin projects, per MW generation in 2010-11 has dropped by 37.60% from the highest per MW generation achieved in the year 1994-95[6]
  • Same situation is true for most other hydropower projects.
  • Most of these projects are performing far below the level at which the projects were given techno-economic clearances.
  • There is no assessment as to how much of the generation from such hydropower projects is during peaking hours. Nor is there any attempt at optimising the peaking power from these projects.

It is clear that there is huge scope to make the existing projects more efficient, rather than destroying ESAs in WG with more projects.

We request that in line with WGEEP report, large dams should not be permitted in ESAs of Western Ghats.

  1. Recommendation about mitigating impacts of Hydropower are extremely weak
  • The HLWG has recommended 30 % of lean season flow as the minimum flow throughout the year as a conditionality for allowing hydro power projects in the ESA. This is contradictory to the recommendation for ecological flows by the HLWG.  Ecological flows means trying to mimic the natural flow regime in the river as far as possible and that would include arriving at different seasonal flows based on studies and consultation with the river communities and other stakeholders, using the Building Block Methodology which even the Inter Ministerial Group on Ganga Basin has said is the most appropriate for India. Moreover, the IMG has recommended 50% releases in lean season flows, applicable for all existing projects. MoEF should accept these norms immediately for all existing projects.

The MoEF should be recommending ecological flows / environmental flows as in the WGEEP report and not minimum environmental flows and this should be determined through holistic methodologies like Building Block Methodology and local participation.

  • The HLWG recommendation of 3 km minimum distance between dams is totally ad hoc, arbitrary and hence unacceptable. Firstly, the HLWG should have mentioned min 3 km of flowing river between projects. The minimum distance is river specific and would depend upon a basin level study of the river including the altitudinal profile of the river, the riparian forest status, the aquatic habitats and biodiversity, the present dependability and many such criteria. More significantly, the cascade hydropower dam menace which is destroying rives in Himalayas need not be replicated in western ghats. We would like to reiterate that no large dams should be allowed in the ESA of WG.

The MoEF should recommend for arriving at river specific studies while accepting 5 km of free flowing river between projects as minimum distance of free flowing river between projects. The best case is not to allow any further large dams in Western Ghats.


No flows in Sharavathy downstream Linganmakki  Dam and Jog Falls. Photo: SANDRP

No flows in Sharavathy downstream Linganmakki Dam and Jog Falls. Photo: SANDRP


  1. The HLWG does not stress the need for Environmental Clearance for Mini hydel Projects

Hydro projects less than 25 MW are currently exempt from Environmental Clearance due to a dangerous omission in the EIA Notification 2006. WG is currently facing a severe threat due to a flood of these unplanned cascades of Mini Hydel Projects. Ecosystems and communities in rivers like Netravathi, Kumaradhara, Krishna and Cauvery are facing impacts of these projects, many of which are fraudulent.[7] Netravathi has more than 44 mini hydel projects planned and under operation. Kerala has plans to set up  around 100 mini Hydel projects on its rivers. The threat of these projects on river systems in Western Ghats is so high that in March 2013, the Karnataka High Court, has banned any new mini hydel projects in Karnataka Western Ghats[8].

WGEEP had recommended no mini hydel projects in ESZ I and II. HLWG has not done this. While the HLWG makes a rather vague statementThere is a need to redesign and reevaluate small hydropower projects – below 25 mw as these often have limited impact on energy generation and can lead to huge impacts on ecology’, it has not recommended that these projects should need an EIA and EC process, like it has said for Wind Energy. This is a very serious omission. SANDRP and many organizations have written about this to the MoEF several times.

The MoEF should amend the EIA Notification 2006 and include all hydel projects above 1 MW in its purview.


Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP

Pristine Forests set for submergence under the 24 MW Kukke Mini hydel Plant in Dakshin Kannada, Karnataka. Photo: SANDRP

  1. The HLWG does not stress the need of Environmental Clearance (EC) for Drinking Water and Industrial supply dams

HLWG has not looked at water as a sector, but has only confined itself to hydropower. This has resulted in several loopholes. Many dams are being constructed in Western Ghats for Drinking Water and Industrial water supply. These are also exempt from EC process as per the EIA Notification 2006. Dams like Kalu, Shai, Balganga, Khargihill, Pinjal, Gargai are set to submerge more than 6000 hectares of forest in ESAs and Protected Areas in Northern Western Ghats in Maharashtra.

WGEEP Report had recommended no large dams in ESZ I and II, but the HLWG does not talk about these dams at all. Their impacts on WG forests and communities are entirely ignored. This is another serious lapse of the HLWG report.

The MOEF should amend the EIA Notification 2006 to include all large dams, irrespective of the purpose, including drinking and industrial water supply dams in its purview. No large dams should be planned in ESA of Western Ghats.


Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP

Ravines of Vaitarna already submerged by the Middle Vaitarna Dam near Mumbai Photo: SANDRP

  1. HLWG does not recommend eflows from existing projects

Several hundreds of Irrigation, water supply, hydropower dams have transformed the nature of rivers and dependent communities in Western Ghats. While the WGEEP Report mentioned maintaining eflows from existing projects, the HLWG does not make any recommendation for eflows from existing projects.

Hydropower projects in Karnataka like Kali, Linganmakki have affected communities and ecosystems in the region, have driven some species to extinction. There is an urgent need to restore eflows in all WG rivers.

The MoEF should recommend that eflows should be assessed with holistic and participatory methodology like BBM and recommend e-flows for all dammed rivers in Western Ghats with time limit of one year.

  1. HLWG does not apply its mind to dam decommissioning

The HLWG has chosen to ignore the recommendations on dam decommissioning. While the states have rejected the recommendation the MoP (Ministry of Power) and Central Electricity Authority has noted that dam decommissioning in a phased manner is worth considering.

There are several irrigation and hydropower dams in the Western Ghats which are severely underperforming or incomplete after two decades, or more than 100 years old, and/or unsafe. For example, several experts have opined than large irrigation projects in Konkan region of Maharashtra are severely underutilized. Tillari Interstate Project between Maharshatra and Goa which has come up affecting a wildlife corridor and which has still not rehabilitated its affected population, has a created irrigation potential of 7,295 hectares in Maharashtra of which farmers are utilizing just 162 hectares, according to the Govt Of Maharashtra’s 2012 White Paper on Irrigation Projects in Maharashtra. This underlines the redundancy of large irrigation projects in the WG.

The HLWG had an opportunity to relook at such projects, which it has not done. The HLWG could have noted that the state governments and the MoEF and MoP should start the process of evolving parameters / criteria towards the process of dam decommissioning.

The MoEF may please recommend the same.

Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror

Leaking Khadkhad dam Mahrashtra Western Ghats Photo: Pune Mirror


  1. HLWG does not recommend free flowing rivers for WG

Rivers in Western Ghats are repositories of biological, ecological and cultural diversity. Rivers in WG harbor high endemism and diversity in freshwater fish. They also house several Sacred groves at river origins, river fish sanctuaries, etc., protecting rivers and fish. The freshwater biodiversity remains the most fragmented among all biodiversity and HLWG has taken no note of this state and further risks that freshwater biodiversity faces. The WGEEP had wisely followed a graded approach in tune with the ecological connectivity of river ecosystems. ln the HLWG approach, stretches of rivers would flow out of the natural landscape into the cultural landscape which is open to indiscriminate development and the chance for their restoration or protection would be completely lost out. A river cannot be protected in pieces like this.

Looking at the pressures from dams and water abstractions, there in an urgent need to conserve ecologically, culturally and socially important rivers in their free-flowing condition. This approach is well accepted globally and several countries have created specific legislations for protecting free flowing rivers[9]. It seems that the IMG Committee on Upper Ganga, in which Ms. Sunita Narain (Member of Kasturirangan Committee), was also a member has recommended that some six tributaries of Upper Ganga basin should be kept in pristine state. While rejecting WGEEPs recommendation about dam decommissioning or dam free rivers in the ESZs, HLWG has not recommended keeping even a single river in Western Ghats in its free flowing condition.

MoEF should identify ecologically, culturally and socially important rivers, based on community and ecological knowledge and conserve Heritage Rivers of Western Ghats in their free flowing condition for the current and future generations.


Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP

Seetha Nadi, free flowing river in Karnataka Western Ghats. Photo: SANDRP

  1. HLWG allows Inter basin transfers in Western Ghats, without any justification or studies

The HLWG has agreed to inter basin transfers toeing the claims of some of the states. There are ample instances of failed interstate – inter basin transfers in the Western Ghats rivers which have turned into permanent scenes of conflicts like the famous Mullaperiyar,  Parambikulam Aliyar, Siruvani interstate inter basin transfers between Kerala and Tamil Nadu. The HLWG while acknowledging the need for ‘ecological flows assessment’ in rivers has failed to note that in all these inter basin transfers, the river / tributary has been completely diverted and has lost its ‘ecological flows’. The HLWG could have recommended a cumulative impact assessment of the existing inter basin transfers which would reveal the ground reality.

HLWG seems to have accepted the contention of states like Maharashtra: “This (stopping IBT) would be a problem, they explained, as many regions of the Western Ghats lie in the rain shadow area and need water to be diverted for irrigation and drinking.”

Reality is that, ALL the interbasin transfers happening in Maharashtra currently (through Koyna and Tata Hydro power projects, an amount more than 4 Billion Cubic Meters Annually) are transferring water FROM the rain shadow area of Krishna and Bhima basins TO water surplus regions in Konkan. If HLWG was concerned about water supply for rain shadow regions, it would have at least recommended that this transfer from deficit area to high rainfall area be immediately reviewed and reversed in a time bound manner. It has chosen not to, showing its complete ignorance of ground reality or its completely pro government and pro vested interests bias.

The MoEF should retain the recommendation for no more inter basin transfers as in the WGEEP report and ask for immediate review of transfer of water from deficit basins to high rainfall areas. 


  1. HLWG allows hydro projects in first and second order streams

The HLWG has not said no to hydro power projects in first and second order streams in ESA. Meanwhile the MoP, CEA and WAPCOS all agree that hydro power projects should not be permitted in these highly ecologically sensitive areas which are the ‘origin’ of Western Ghats Rivers.

The MoEF should retain the recommendation for no run of the river schemes in first and second order streams as in the WGEEP report.

  1. HLWG offers no comments of on several water sector recommendations of WGEEP which have been supported by State Governments

Kerala and Maharashtra have accepted many of the recommendations of the WGEEP in water sector (page 14 section 2.3 – point 9) like catchment area treatment plan, protection of high altitude valley swamps, water conservation measures, rehabilitation of mined areas, improved river flows etc. It is surprising to note that the HLWG is silent on these very important measures and has not even endorsed these acceptable recommendations which can significantly contribute towards improving water availability in the Western Ghats.

The MoEF should follow these recommendations of the WGEEP.

  1. HLWG takes an extremely biased stand about Athirappilly and Gundia Hydropower projects, rejected by the WGEEP

The WGEEP had categorically stated that the Athirappilly and Gundia Hydropower project should not come up in Western Ghats, looking at their huge impacts on biodiversity, several studies by local organisations and local opposition. However, ignoring all these, the HLWG has taken a very pro project stand on these projects, stating that they can be considered with some vaguely due process, which the state government would be happy to show they have followed it on paper. This is entirely unacceptable.

The MoEF should not allow Athirappilly and Gundia HEPs looking their impact on ecology and communities and in face of the strong local opposition that they are facing.


Athirappilly Waterfalls on the Chalakudy River Photo; SANDRP

The WGEEP process and report initiated a robust discussion about the paradigm of development and conservation in Western Ghats. Water and Rivers is a cross cutting issue connecting ecosystems and communities, rural areas and urban centers, providing goods and services and supporting freshwater biodiversity, which is most threatened currently.

A proactive position on conserving rivers in Western Ghats will go a long way in protecting and conserving myriad livelihoods and ecosystems that thus depend of them.

We hope the MoEF considers the recommendations made above about the WGEEP and HLWG Reports and helps conserving rivers of the Western Ghats for people and ecosystems urgently. The HLWG Report cannot be accepted the way it stands presently. As a step in this direction, we also suggest that WGEEP should get a formal chance to respond to the points raised about it in the HLWG.

Thanking You,


Yours Sincerely,

Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune ( ,

Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (

Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, Maharashtra (

Dr. T.V. Ramchandra, Energy & Wetlands Research Group, Centre for Ecological Sciences, IISc, Bangalore (

Janak Daftari, jalbirdari, Mumbai, Maharashtra (

Sujit Patwardhan, Parisar, Pune, Maharashtra (

Dr. Nilesh Heda, Samvardhan, Vidarbha, Maharashtra (

Nisarg Prakash, Nature Conservation Foundation and Nityata Foundation, Bangalore, Karnataka (

Mrinalinee Vanarase, Iora Consultants, Pune, Maharashtra (

Shankar Pujari, President, Nivara Bandhkam Kamgar Sangh, Sangli, Maharashtra (

Damodar Pujari, SANDRP, Pune, Maharashtra (

Saili Palande-Datar, Kalpavriksha, Pune, Maharashtra

Following Members from Energy and Wetlands Research Group, Centre for ecological Science, Indian Institute of Sciences: 

  • Dr. M.D. Subash Chandran
  • Dr. Prakash Mesta
  • Dr. Uttam Kumar
  • G R Rao
  • Mahima Bhat
  • Vishnu Mukri
  • Sreekanth Naik
  • Balachandran C
  • Boominathan M
  • Bharath H Aithal
  • Bharath Settur
  • Vinay S
  • Ganesh Hegde
  • Anindita Dasgupta
  • Arun D T
  • Vishnu Bajpai
  • Gouri Kulkarni
  • Sudarshan Bhat
  • Durga Madhab Mahapatra
  • Ashwath Naik
  • Sowmya Rao
  • Shwetmala



Prof. Madhav Gadgil writes to Dr. Kasturirangan

Open Letter sent by Prof. Madhav Gadgil to Dr. Kasturirangan on the High Level Working Group Report on WGEEP and Western Ghats. 


17 May 2013
Dear Dr. Kasturirangan,

JBS Haldane, the celebrated 19h century scientist and humanist who quit England protesting its imperialistic invasion of Suez to become an Indian citizen has said: Reality is not only stranger than we suppose, but stranger than we CAN suppose! I could never have imagined that you would be party to a report such as that of the High Level Working Group on Western Ghats, but, then, reality is indeed stranger than we can suppose!

In our report to the Ministry of Environment & Forests, based on our extensive discussions and field visits, we had advocated agraded approach with a major role for grass-roots level inputs for safeguarding the ecologically sensitive Western Ghats. You have rejected this framework and in its place, you advocate a partitioning amongst roughly one-third of what you term natural landscapes, to be safeguarded by guns and guards, and two-third of so-called cultural landscapes, to be thrown open to development, such as what has spawned the 35,000 crore rupees illegal mining scam of Goa. This amounts to attempts to maintain oases of diversity in a desert of ecological devastation. Ecology teaches us that such fragmentation would lead, sooner, rather than later, to the desert overwhelming the oases. It is vital to think of maintenance of habitat continuity, and of an ecologically and socially friendly matrix to ensure long term conservation of biodiversity rich areas, and this is what we had proposed.

Moreover, freshwater biodiversity is far more threatened than forest biodiversity and lies largely in what you term cultural landscapes.  Freshwater biodiversity is also vital to livelihoods and nutrition of large sections of our people. That is why we had provided a detailed case study of Lote Chemical Industry complex in Ratnagiri district of Maharashtra, where pollution exceeding all legal limits has devastated fisheries so that 20,000 people have been rendered jobless, while only 11,000 have obtained industrial employment. Yet the Government wants to set up further polluting industries in the same area, and has therefore deliberately suppressed its own Zonal Atlas for Siting of Industries.

Your report shockingly dismisses our constitutionally guaranteed democratic devolution of decision making powers, remarking that local communities can have no role in economic decisions. Not surprisingly, your report completely glosses over the fact reported by us that while the Government takes absolutely no action against illegal pollution of Lote, it had invoked police powers to suppress perfectly legitimate and peaceful protests against pollution on as many as 180 out of 600 days in 2007-09.

India’s cultural landscape harbours many valuable elements of biodiversity. Fully 75% of the population of Lion-tailed Macaque, a monkey species confined to the Western Ghats, thrives in the cultural landscape of tea gardens. I live in the city of Pune and scattered in my locality are a large number of Banyan, Peepal and Gular trees; trees that belong to genus Ficus, celebrated in modern ecology as a keystone resource that sustains a wide variety of other species. Through the night I hear peacocks calling, and when I get up and go to the terrace I see them dancing. It is our people, rooted in India’s strong cultural traditions of respect for nature, who have venerated and protected the sacred groves, the Ficus trees, the monkeys and the peafowl.

Apparently all this is to be snuffed out. It reminds me of Francis Buchanan, an avowed agent of British imperialism, who wrote in 1801 that India’s sacred groves were merely a contrivance to prevent the East India Company from claiming its rightful property.

It would appear that we are now more British than the British and are asserting that a nature friendly approach in the cultural landscape is merely a contrivance to prevent the rich and powerful of the country and of the globalized world from taking over all lands and waters to exploit and pollute as they wish while pursuing lawless, jobless economic growth. It is astonishing that your report strongly endorses such an approach. Reality is indeed stranger than we can suppose!

With warm personal regards,

I remain,

Yours sincerely,