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.
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.
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.⊕
08 May 2013
REad the full artcile here: http://www.indiatogether.org/2013/may/env-water.htm
|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 http://ndma.gov.in/ndma/latestdisasterupdates/NDMA%20Final%20Report%20Brahmaputra%20River.pdf
Pic: 2 Recent News Reports of Erosion in Subansiri River, One of the Largest Tributaries of Brahmaputra on the North Bank. Source: Dainik Janambhumi
|Pic: 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
Total Erosion Length
1990 to 2007 – 08 (in sq. km)
1997 to 2007-08 (in sq. km)
Total Erosion Length
1990 to 2007 – 08 (in sq. km)
1997 to 2007-08 (in sq. km)
|5. Morigaon – Mangaldai||
|6. Morigaon – Dihing||
|10. Majuli Sibsagar||
|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.
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. 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.
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.
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 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. 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. 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. 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. 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 (www.sandrp.in)
 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 – http://www.garwareropes.com/polymer_rope_pro_g.htm
 Mahanta, C; Mahanta, A., ‘Bridge over The Brahmaputra’ Economic and Political Weekly, pp 579-581, 2006
 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”
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:
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.
Himanshu Thakkar and Parineeta Dandekar,
International Rivers (firstname.lastname@example.org)
Dr. Latha Anantha,
River Research Centre, Kerala (email@example.com)
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 are based on the hard copy of the final report made available by a colleague.
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: http://www.sandrp.in/hydropower/Pathetic_Cumulative_Impact_Assessment_of_Ganga_Hydro_projects.pdf) 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.
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.
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.
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.
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.
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.
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.
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.
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.
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: http://www.uttarakhandjalvidyut.com/cms_ujvnl/under_operation1.php. 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: http://uttarakhandjalvidyut.com/bd2.pdf.
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: http://uttarakhandjalvidyut.com/Hydro%20Projects%20Being%20Developed%20by%20IPPs.pdf.
D. There is another “full list” of hydropower under development in Uttarakhand including sub-MW size projects, see: http://uttarakhandjalvidyut.com/bd5.pdf. 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:
Himanshu Thakkar (firstname.lastname@example.org)
South Asia Network on Dams, Rivers & People (http://sandrp.in)
EAS Sarma, Former Union Power Minister, Visakhapattanam, email@example.com
Vimal Bhai, Matu Jansangathan, Uttarakhand, firstname.lastname@example.org
Malika Virdi, Himal Prakriti, Uttarakhand, email@example.com
E Theophilus, Himal Prakriti, Uttarakhand, firstname.lastname@example.org
Ramnarayan K, Save the Rivers Campaign Uttarakhand, email@example.com
Dr Latha Anantha, River Research Centre, Kerala, firstname.lastname@example.org
Parineeta Dandekar, SANDRP, Pune, email@example.com
Samir Mehta, International Rivers, Mumbai, firstname.lastname@example.org
Tarini Manchanda, Independent film maker, Delhi, email@example.com
 The author is thankful to Parineeta Dandekar, Shripad Dharmadhikary and Samir Mehta among others for providing comments on earlier drafts.
 Prof Bharat Jhunjhunwala provided the copy.
 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: http://www.downtoearth.org.in/content/training-engineers-not-ganga and http://www.downtoearth.org.in/content/ganga-saga-part-ii-redesign-dams-not-rivers. 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.
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: firstname.lastname@example.org. 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,
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.
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:
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.
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., 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. 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.
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:
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.
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 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.
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. 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.
WGEEP had recommended no mini hydel projects in ESZ I and II. HLWG has not done this. While the HLWG makes a rather vague statement “There 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.
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.
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.
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.
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. 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.
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.
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.
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.
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.
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.
Himanshu Thakkar, Parineeta Dandekar, South Asia Network on Dams, Rivers and People, New Delhi and Pune (email@example.com , firstname.lastname@example.org)
Dr. Latha Anantha, River Research Centre, Thrissur, Kerala (email@example.com)
Shripad Dharmadhikary, Manthan Adhyayan Kendra, Pune, Maharashtra (firstname.lastname@example.org)
Dr. T.V. Ramchandra, Energy & Wetlands Research Group, Centre for Ecological Sciences, IISc, Bangalore (email@example.com)
Janak Daftari, jalbirdari, Mumbai, Maharashtra (firstname.lastname@example.org)
Sujit Patwardhan, Parisar, Pune, Maharashtra (email@example.com)
Dr. Nilesh Heda, Samvardhan, Vidarbha, Maharashtra (firstname.lastname@example.org)
Nisarg Prakash, Nature Conservation Foundation and Nityata Foundation, Bangalore, Karnataka (email@example.com)
Mrinalinee Vanarase, Iora Consultants, Pune, Maharashtra (firstname.lastname@example.org)
Shankar Pujari, President, Nivara Bandhkam Kamgar Sangh, Sangli, Maharashtra (email@example.com)
Damodar Pujari, SANDRP, Pune, Maharashtra (firstname.lastname@example.org)
Saili Palande-Datar, Kalpavriksha, Pune, Maharashtra
Following Members from Energy and Wetlands Research Group, Centre for ecological Science, Indian Institute of Sciences:
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,
A fantastic documentary shattering the myths of Large Dams as sources of clean energy, Damocracy takes a documentary to the next level. It talks about two dams, separated by thousands of kilometers, united by people’s struggle against destructive and illegal large dams. It traces the story of the Bel Monte Dam on Xingu River in the Amazon Basin of Brazil and the Ilisu Dam on the Tigris River in Turkey.
It takes us through a maze of lies, government repression, plight of communities, strengths and struggles of local communities against these projects which have gone on for decades. While Bel Monte Dam threatens over indigenous tribes and native fish in Brazil, Ilusu Dam, under construction even without an EIA will submerge 300 archeological sites including eth entire city of Hasankeyf.
Dr. Philip Fearnside talks about the popular jingle of Hydropower being ‘clean, green source of energy’. He says “People have heard this myth so many times, that they believe it, because they’ve never heard anything else.” He talks about the impact of Methane on global warming, which is many times more than carbon di oxide.
The film ends with a diverse group of dam activists from all corners of the world actually dismantling a wall built across the Xingu… working together in the scorching Amazon sun to undo work of machines for months. In the end, the XIngu flows again..though symbolic, it a powerful message.
In the words of one of the elated activists seeing the river flow finally “If a small united group could do this, imagine what a united world can do against monster dams.”
An inspiring fim in many ways. A must watch for sure.
more on the campaign: http://damocracy.org/
Expert Appraisal Committee, MoEF refuses to consider 2 VIDC projects from Buldhana for Environment Clearance siting violations
During its last meeting on 22-23rd March 2013, Expert Appraisal Committee of the MoEF has rejected considering two projects from Buldhana for violating EIA Notification (2006) and Environment (Protection) Act 1986. (see minutes here: http://environmentclearance.nic.in/writereaddata/Form-1A/Minutes/57_65thEACMiutes.pdf)
2 Irrigation Projects from Buldhana: Ar Kacheri Irrigation Project and Alegaon Irrigation Project, Vidarbha Irrigation Development Corporation (VIDC), were discussed for granting Terms of Reference (TORs). However, on the ground, both the projects have started work without an Environmental Clearance and this work was stopped only after strong local protests and even litigation. This was pointed out by the EAC and admitted by Vidarbha Irrigation Development Corporation. Together, both projects are set to submerge 436 hectares of forest and irrigated, cultivated land. Although 80% of the land under submergence is cultivated and irrigated by ground water, the Pre-feasibility reports (PFR) of the projects say that they will not cause submergence or affect population. EAC has pointed out this discrepancy too.
Alewadi project is just 1.75km from the core boundary of Melghat Tiger Reserve while Ar-Kacheri is 4.75km from the same. The projects have also received Stop Work order from the Forest Department in 2012.
Despite all these serious issues, the project proponent chose to hide these facts from the EAC. SANDRP had sent a submission to the EAC prior to the meeting, highlighting many issues and saying: “Considering the violations by both the project developers of EIA notification 2006 by starting work without the required clearances, the EAC should first recommend an enquiry into these violations and ask the responsible officials to be held accountable before even considering any clearance.”
The EAC has observed that both the projects have indulged in violations. According to the EAC: “Such cases are to be dealt in terms with the MoEF OM No. J-11013/41/2006-IA.II (I) dated 12.12.2012. Accordingly, the project proponent is required to submit an affidavit with an undertaking not to execute works without obtaining environmental clearance and furnish photographs of the site from all four sides of the project.” The OM also states for such violations, the State Government will have to take necessary legal action against the violations as per the Environment Protection Act. In case of serious violations, the MoEF reserves the right to reject projects all together.
Even as the White Paper on Irrigation Projects points fingers at Green Clearances as one of the reasons for time and cost overruns of irrigations projects in Maharashtra, the functioning of Water Resource Department itself has been responsible for these delays and irregularities. Without an Environmental Clearance, work on the project cannot start as per the EIA Notification 2006 and EPA 1986.
However, all Irrigation Development Corporations in Maharashtra have been breaking this law with impunity many times over. This was observed in case of Konkan Irrigation Development Corporation for several projects, Maharashtra Krishna Valley Development Corporation for numerous lift Irrigation schemes on Ujani and Vidarbha Development Corporation, for Lower Painganga Project.
With this decision, there is hope that VIDC and other IDCs in Maharashtra become less callous about issues relating to environment and affected communities.
–Parineeta Dandekar email@example.com
Himanshu Thakkar, firstname.lastname@example.org
South Asia Network on Dams, Rivers and People
Through an unfortunate and short sighted decision, the Forest Advisory Committee of the Ministry of Environment and Forests has gone back on its decision of rejecting Forest Clearance to Kalu Dam that it took on 2nd April 2012. It reconsidered the project and in its last meeting on 3rd-4th April 2013, and has actually recommended the Kalu Dam project for FC, involving 1000 hecatres of Forests in the Western Ghats. It has done this when all the illegalities and irregularities from the proponent still stand today, entirely unaddressed.
Ms. Jayanthi Natarajan,
Minister of State (IC) for Environment and Forests,
Ministry of Environment and Forests, New Delhi
Subject: Request not to grant Forest Clearance to Kalu Dam in Maharashtra due to several procedural and legal irregularities on the part of the Project Proponent and also the Forest Advisory Committee.
Respected Madame Minister,
This is to express our utter shock and dismay at FAC’s decision of recommending Forest Clearance to Kalu Dam falling in Western Ghats area in Murbad, Thane District, Maharashtra as seen in the minutes of the FAC meeting of April 3-4, 2013.
Just one year ago on the 2nd of April 2012, the Forest Advisory Committee had rejected this proposal, raising substantial points against the proposal and closed the file. This was a respite for the communities facing displacement, community groups working on the issue, for the Western Ghats ecology and the forests. We had then thanked FAC for this decision of April 2012.
On 4th of April 2013, the same Forest Advisory Committee (now with a changed constitution) went back on its decision and recommended Forest Clearance (FC) to Kalu Dam even when nothing has changed on ground and all of the objections based on which FC was rejected in the first place still stand today. The Project Proponent (PP): KIDC, Maharashtra Water Resource Department, has not been able to respond in credible way to any of the points raised by the FAC, Chief Conservator of Forests (Central), State Forest Department, affected villagers or civil society organisations.
We strongly condemn this decision by the FAC of recommending Forest Clearance for diverting nearly 1000 hectares of Forests in the Western Ghats. We urge you (i) not to recommend FC for Kalu Dam; (ii) request you to take steps to make Forest Advisory Committee more transparent, responsive and accountable to issues of communities and forests; specifically, all the documents from the project proponent, including all the annexures of the Form A and gram sabha resolutions for the projects on FAC agenda must be on FAC website at least ten days in advance as per CIC orders and as also assured by you in public; (iii) We also urge you to direct action against those responsible for illegal construction of the Kalu dam as noted by the FAC minutes; (iv) urge you ask FAC to hence forth recommend strict action against such violations.
Major issues about recommending FC to Kalu Dam:
Non-transparent decision making in violation of CIC Orders: None of the documents submitted by the project proponent about the Kalu Project were available in full with all the annexures on the MoEF website even a week before FAC meeting on the 3rd and 4th of April. This is a blatant violation of the CIC orders and we had pointed this out to the FAC through our letter dated March 25, 2013, but the FAC chose to ignore this. As a Minister, you had taken a strong stand against this and had said in October 2012 “These actions and decisions of the officials are unacceptable to me. The forthcoming meeting of the FAC will be postponed, and I shall resolve these (violation of CIC orders and non-compliance of FRA) issues.”
Considering that the lives and livelihoods of about 18000 people will be affected by this project, and when they have the first and foremost right to have all the information on decision making around this project, such irresponsibility on the part of FAC is unacceptable and it is also bad in law. Petition against Kalu Dam is in the High Court of Bombay currently and this point will be raised there.
Complete reliance on Project Proponent’s (PP) claims While recommending FC, the FAC has relied entirely on claims of the proponent, without checking the veracity of the claims or applying its mind. FAC has not even mentioned the numerous submissions made by communities and community-based organisations raising pertinent points against PP’s claims. The FAC needed to keep in mind that the same proponent has gone against its word many times earlier and each time, it has been pointed out to the FAC. It has wilfully violated the Forest Act by starting construction of the project in the absence of FC when the project is to submerge nearly 1000 hectares of land in a biodiversity hotspot, it has gone against its written word when it said that ‘no new project will be required for Mumbai until 2031”, in the process of seeking Stage I Forest Clearance for Shai Project, barely 20 kilometres from Kalu Project.
But the FAC, instead of taking any strict action against the proponent in this regard, has simply accepted its claims, which are again misleading and false.
Grounds for rejection of Kalu Project in 2nd April 2012 by FAC: The FAC minutes state:
· Submergence of 18 villages and their connectivity,
· Initiation of construction without Forest Clearance,
· Breach of commitment given by the Project Proponent during Stage I clearance of Shai Dam,
· Location of the dam within 7 kms of Protected Area
· Location of the project in eco sensitive Western Ghats
· Non-furnishing of: Rehabilitation Plan, Environment Impact Assessment report, Technical Report on Wildlife Status, Gram Sabha resolutions about compliance of Forest Rights Act
NONE of the issues stated above are resolved through the PP’s responses as clarified below:
· No Gram Sabha Resolutions Passed supporting the project: Misleading the Forest Advisory Committee: PP has claimed that it has secured Gram Sabha Resolutions from 8 villages out of the 11 villages that will be fully or partially submerged by the dam. In fact, Shramik Mukti Sangathana has letters from 10 Gram Panchayats out of these 11 that they have not issued any such resolutions at any stage. The last resolution in this regard that they passed was AGAINST the project. These were sent to the FAC on 16.11.11.
If the Project Proponent has the resolutions as claimed, why have they not put these up on the FAC website with the necessary documentation from the PP?
Why did the FAC not see the need to ascertain this even when it was pointed out by us in our letter dated 29.10.12 and again in 25.03.13 that no such resolutions exist?
· Clear violation of the Forest Conservation Act (1980): The proponent accepts that it violated the Forest Conservation Act (1980) by starting work before an FC, but states that it stopped AFTER High Court Orders. High Court Orders were in response of a PIL filed by Shramik Mukti Sangathana against the illegal nature of the work. So, stopping AFTER HC orders is no justification for committing the illegality. Before the High Court orders, Shramik Mukti Sangathana had written several letters about this violation to the Collector, Chief Secretary and Forest Department and had also served a notice to the PP. It did not stop work then.
Considering this, the Forest Advisory Committee ought to have penalised the project proponent for violation of Forest Conservation Act (1980), not recommend the same project for clearance.This only gives out a signal that no action will be taken by the MoEF even after it knows that violation of Forest Act is happening, that too by a state agency.
· Continued violation of the Forest Rights Act (2006) It has been pointed out several times to the FAC that Kalu Project is violating the Forest Rights Act (2006) as community and individual claims are yet to be settled. The Forest Rights Act was passed to safeguard historical injustice on Forest-dependent communities, but the FAC itself is encouraging the PP to violate FRA, PESA, Rehabilitation Policy and Forest Conservation Act. You, as a Minister, had reasserted MoEF’s commitment to implementation of Forest Rights Act.
· No Rehabilitation Plan has been submitted at the time of recommending Forest Clearance There is no such plan available in public domain, nor has there been any participatory process of approval of the plan with the affected people. A claim of a rehabilitation package of Rs 68.75 Crore does not constitute a Rehabilitation Plan. This point was raised several times by community organisations, State Forest Department, Chief Conservator of Forests as well as the FAC. Villages to be affected by Kalu Dam fall in Tribal Subplan and attract PESA. Without any legally mandatory process, just the claim of rehabilitation package of Rs 68.75 crore seems good enough for FAC. It was clearly wrong on the part of the FAC to recommend FC based on such claims.
· Konkan Irrigation Development Corporations letter that “it is not necessary to construct any new water source till 2031”: This was submitted to the MoEF while seeking Stage I Forest Clearance for Shai Dam, less than 25 kms from proposed Kalu dam in 2010-11. FAC recommended Stage I Clearance to Shai Dam based on that assurance. In less than 3 years, the proponent feels that Shai dam, whose clearance was obtained on such a claim, will not be sufficient till 2031. This is unjustifiable and tantamount to misleading the FAC with false assurances.
· No Environment Impact Assessment (EIA) Conducted The Kalu Dam falls in ecologically sensitive Western Ghats. The Western Ghats Expert Ecology Panel had categorised the region in ESZ I where no large dams should be permitted. Even as per the Kasturirangan Committee Report, more than 5 villages affected by Kalu Dam are falling in the ESA.
The State forest Department, Chief Conservator of Forests (Central), community groups have all urged that EIA as well as a Cumulative Impact Assessment of the Project has to be done before granting Forest Clearance. In fact, this was one of the conditions laid by the State Forest Department. Looking at the ecologically sensitive location of Kalu Dam and submergence of nearly 1000 hectares of Western Ghats Forest Land, this was a reasonable expectation.
Despite these clear conditions, the PP argues that EIA is not required. And despite this, the FAC recommends FC to this project!
In this context, Section 2.3 (ii) of FCA (1980) read, “Notwithstanding the above, if in the opinion of the Ministry or the Advisory Committee, any proposal should be examined from the environmental angle, it may be required that the project proponent refer the case to the Environment Wing of the MOEF.” So irrespective of the requirement of EIA notification, the FAC has been provided powers to refer to an such project to the environment wing of MoEF or EAC for examination of the project from the environment angle, but FAC failed to do this just under the claim of the PP that EIA is not required under EIA notification.
FAC recommendation that Cumulative Impact Assessment has to be undertaken for drinking water projects around Mumbai is welcome but again, it could have been done before considering this project for clearance and not after recommending clearance. Similarly their recommendation to the MoEF to amend the EIA notification to ensure that such dams are included for environmental impact assessment is welcome, but they could have waited for MEF response rather than recommending Forest Clearance.
In this regard we urge you: (i) immediately change the EIA notification to include Kalu and all such large dams under the ambit of the EIA notification, irrespective of the purpose of the project; (ii) Direct specifically that Kalu Dam require EIA and Env clearance, using the above mentioned part of the Forest Conservation Act, 1980 and EPA, 1986; (iii) Order a cumulative impact assessment of all the projects in the western ghats region around Kalu dam, as recommended by FAC and (iv) direct that FC for Kalu will NOT be considered till all these requirements are fulfilled.
· Forest Conservation Act requires Gram Sabha clearance Moreover, section 2.1(vii)(4) of the Forest Conservation Act, 1980 clearly states: “Therefore, whenever any proposal for diversion of forest land is submitted, it should be accompanied by a resolution of the ‘Aam Sabha’ of Gram Panchayat/Local Body of the area endorsing the proposal that the project is in the interest of people living in and around the proposed forest land except in cases wherever consent of the local people in one form or another has been obtained by the State or the project proponents and the same is indicated in the proposal explicitly. However, it would be required where the project activity on forest land is affecting quality of life of the people residing in nearby areas of the site of diversion; like mining projects, displacement of people in submergence area, etc.” This provision is particularly applicable to a project like Kalu that has not had EIA or public hearing as stated in the same section in FCA, 1980. Recommending FC for Kalu Dam project without fulfilling this requirement is clearly a violation of the FCA, 1980 by the FAC.
We urge you to direct the project proponent to get gram sabha resolutions on the lines mentioned above in FCA Section 2.1(vii)(4) and direct FAC consider the project only after these have been received.
· Distance from Protected Area: The submergence of the project is less than 10 kms from Kalsubai Sanctuary. Considering the fact that no EIA is conducted, no report on Wildlife Status exists, this makes ecological impacts of Kalu Dam on Western Ghats ecosystem even more serious. Considering all these issues, FC should have been rejected on this ground alone. In fact the PP goes ahead to say: “No rare or endangered flora or fauna has been reported from this site” How can this be stated when no EIA has been conducted and no wildlife report exists?
· The PP states that only “44566” and “44611” that is ‘only’ 89177 tress will be felled during and the rest ‘may be’ saved. Ninety thousand trees in Western Ghats is a huge number. But it seems FAC does not see any objection in this. The claim that the rest of the 60 000 trees can be saved is of doubtful credibility. Similarly the claim in the FAC meeting minutes that “No rare or endangered species of flora and fauna has been reported in the area” is also without any credible basis.
· We would like to reiterate that no options assessment about water supply options to Mumbai has been done. No consideration of rainwater harvesting, using saline water for some uses, grey water recycling, demand management, water use efficiency, and conjunctive groundwater use has been done. The FAC minutes notes this, but from the minutes it seems it has not applied its mind to these issues and recommended FC as a matter of blind support for the project. The mention of the letter from the Chief Minister in the minutes only adds to the suspicion that the FAC has cleared the project without looking into merits of the issue.
· Contradictions in FAC conditions? The FAC has recommended FC to the project, with some additional conditions, one of the additional conditions states: “The User agency will abide by all conditions by Regional Office, Bhopal and State Government during inspection of the project.” So the PP has to adhere to all the conditions imposed by the Regional Office, Bhopal and the State forest Department while inspecting the project.
One of the conditions imposed by the Regional office, Bhopal included: “…the State Govt. may be directed to stop all the construction related activities till all the legal formalities and forest, wildlife and environment related studies are completed and a well-considered decision regarding forest diversion is taken based on proper scientific documentation and studies.”
We seem to be in a funny situation now. The FAC, while recommending FC, put a condition that says that decision of FC should not be taken without “proper scientific documentation and studies”, but FAC has done just that! In any case, one implication of this is that the project should not get even first stage FC without the studies recommended by Regional Office, Bhopal, including EIA has been done.
Similarly the State forest department too has asked for (i) Rehabilitation Plan (ii) EIA (iii) technical report from WII on impact of project on wildlife in and around the project area (iv) gram sabha resolutions from all affected villages under FRA. The project should not thus be given even stage I clearance without satisfaction of all these conditions.
Most of these issues have been brought to the attention of the FAC time and again by us, Shramik Mukti Sangathana and other community groups. However, the FAC still went ahead with the incomprehensible decision. Hence, we are writing to you with the hope that after looking at all the points raised above, you will definitely not recommended Forest Clearance to Kalu Dam. We also hope that MoEF will punish violators of FC and FRA Acts to send a strong signal and will take steps to make the present Forest Advisory Committee more transparent, accountable and responsive to issues ailing our forests and forest-dependent communities.
We will look forward to detailed response on this from you. Thanking you for your attention,
Indavi Tulpule: Shramik Mukti Sangathana, Murbad, Thane
Affected Villagers of the Kalu Dam:
Anil Kantaram Kawate: Parchonde (Upsarpanch)
Ganpat Deu Mengal: Zadghar (Gram Panchayat Member)
Navsu Shiva Wagh: Shisewadi
Mrs. Sonibai Shiva Wagh
Nama Shankar Shida: Banachi wadi
Maloji Alo Mengal: Bhoirwadi
Mrs. Tulibai Wakh: Diwanpada
Bhagawan Bhala: Dighephal
Budjhaji Songwan: Wakalwadi
Anil Waman Wakh: Tejwadi (Phangane)
Shivram Lakhu Hilam: Talegaon
Harbhau Raut: Kasole
Popatrao deshmukh: Jadai
Devram Darwade: Khutal
Ashok Pathare: Khutal
Tulshi Bhau Wagh: Zadghar
Moreshwar Bhala: Zadghar
Brian Lobo, Shramik Kashtakari Sanagthana: Dahanu
Surekha Dalawi, Shramik Kranti Sangathana: Raigad
Neema Pathak, Kalpavriksha: Pune
Parineeta Dandekar, Himanshu Thakkar, South Asia Network on Dams and People: Pune and Delhi