Manipulating Environment & Forest Clearances for Dibang ... · cultural museum at Roing and ITI at Anini etc. Besides this for downstream people, the main concern was pro-tection

Contact :Himanshu Thakkar,Parineeta Dandekar,Amruta Pradhan,Ganesh GaudDams, Rivers and PeopleC/o 86-D, AD Block, Shalimar BaghDelhi - 100 088, India.Ph: + 91 11 2748 4654/[email protected]://sandrp.wordpress.com/,www.facebook.com/sandrp.in,http://sandrp.in

1

Working for water resources development as if democracy, people and environment matter

Vol 12 | Issue 6-8 | July-Sept 2014Index

Manipulating Environment & ForestClearances for Dibang Project: A Deja vu of

LSHP: Will it be a tragedy or a comedy?

1 This is not to state that the UPA government that ruled India during the 2004-2014 decadewas in anyway more sensitive to environment or democratic concerns. In fact part of theEC and FC time line and some of the manipulations happened before May 2014 when thecurrent government took over. However, it is apparent that the current government hasindulged in much more violations and manipulations and pressurized the statutory bodies(including FAC & NBWL reconstitution).

1. Manipulating Environment& Forest Clearances forDibang Project: A Dejavu of LSHP: Will it be atragedy or a comedy? 1

2. Review of environmentlaws is necessary but theTSR Subramanian HLClacks credibility 11

3. J and K Floods: Howmuch of the disasterwas man made 14

4. Yettinahole DiversionProject DPR: NewAvtaar, Old Problems 17

5. Riverfront Developmentin India: Cosmetic makeup on deeper wounds 22

6. Varanasi’s GangaWastewater Management:Why has it remainedsuch an IntractableProblem?1 26

7. A Photo Essay on theimpacts of blasting &tunneling for hydropowerprojects in Chamba &Kinnaur districts inHimachal Pradesh 31

Every possible violation of norms,procedures, law and democratic gov-ernance is being committed in push-ing clearances for the India’s largestcapacity hydropower project, whichinvolves India’s highest dam proposedso far & North East India’s Largestcapacity reservoir: the 3000 MWDibang Multi Purpose Project inArunachal Pradesh. The players in-volved in these violations include theUnion government of NDA led by BJP(UPA earlier), including its cabinetand Union Ministry of Environment,Forests and Climate Change(MEFCC), Ministry of Power, Stategovernment, the project developercompany NHPC Ltd, the Expert Ap-praisal Committee (EAC) and ForestAdvisory Committee (FAC).

The project will need more than 4700hectares of biodiversity rich Forestarea with several Schedule I speciesin Arunachal Pradesh. It will alsohave significant downstream im-pacts on the people & environmentof Arunachal and Assam and DibruSaikhowa National Park. Most of itsimpacts have not been either prop-erly assessed or considered by thedeveloper, EIA agency or the EAC &MEFCC.

Déjà vu: We did the same forLower Subansiri HEP! It seemsthe government is indulging in thesame blunders that the previousNDA government1 indulged in overa decade ago while clearing thethen-largest capacity hydropower

Dibang River (Source – EMP)

2

Dams, Rivers & People July-Sept 2014

2 http://sandrp.wordpress.com/2014/01/31/six-years-after-pm-laying-foundation-stone-no-clearance-no-work-for-3000-mw-dibang-dam/

project: the 2000 MW Lower Subansiri HydropowerProject (LSHP), also in Arunachal Pradesh. Environ-ment clearance for LSHP came on July 16, 2003 andstage I forest clearance came on June 10, 2003. Ex-actly the same set of players were involved in manipu-lating LSHP clearances over a decade ago. The devel-oper is also the same: NHPC. The government at cen-tre is again led by NDA.

Aaranyak environmental group of Assam, in a letterdated May 16, 2002 to the then-Chief Justice of Indiahad highlighted the violations involved at various stagesin the decision making of LSHP including during publichearings, in conducting EIA, in giving environment, for-ests and wildlife clearances. Almost all the issues thatAranayak letter raised then are applicable in case ofDibang with even greater force. But it seems in thetwelve years since 2002 when that letter was written,our environmental governance has only degenerated.

The fate of the LSHP is a lesson in itself. After spendingover Rs 5000 crores (Rs 50 Billion), the work on theproject came to a standstill in December 2011. It hasremained stalled for 34 months since then, followingIndia’s biggest Anti dam People’s movement so far. Thisis unprecedented in India’s hydropower history. NHPCLtd has been trying every possible trick to resume theconstruction work on LSHP, without genuinely tryingto address the issues people’s movement has been rais-ing.

What Dr Mite Linggi, Representative of Kere AInitiative for Cultural and Ecological Security saidat the public hearing of Dibang Project on March13, 2013 was exactly that: “It is evident that the 2000MW Lower Subansiri Project is stalled since Dec 2011because the technical, environmental and social concernsof the people of Assam were not considered earlier… Ig-noring downstream concerns will only ensure that thisproject to will meet the same fate as Subansiri LowerProject (2000 MW and get stalled by people of Assam.”

It seems none of the players have learnt any lessonsfrom the blunders committed in LSHP’s decision mak-ing. If this is how Dibang Project is being pushed downthe throat of the people of Dibang Valley, ArunachalPradesh and the North East India, they will have nooption but to oppose the project and the Dibang Projectmay have the same fate as that of LSHP. Those whohave been involved in the decision making now will thenbe held accountable for the wrong decisions and manipu-lations.

THE DIBANG PROJECT

The foundation stone of 3000 MW Dibang MultipurposeProject on Dibang River was laid on 31st January 2008,by Prime Minister Manmohan Singh2 when the projecthad no clearances, showing utter disregard the formerPM had for statutory clearances or environment or af-fected people. The project affects Lower Dibang Valley

Dam site and the Dibang River Basin (Source – EMP)

3


Project in its 77th meeting on 16th Sept, 2014.

The Project was given TOR (Terms of Refence) clear-ance on 17.8.2009. Public hearings in Lower Dibang andDibang Valley districts were held on 11.3.2013 and13.3.2013 respectively, with huge protests from affectedpeople. The EAC earlier considered the project in 68th

meeting in Sept 2013, in 73rd meeting in March 2014, in74th meeting in May 2014 and now in 77th meeting inSept 2014.

Some key questions that arise as to how the EAC ar-rived at the positive recommendation:

1. Was there any Public Hearing in downstreamAssam? Was there proper public hearing inAruunachal Pradesh?

Although Dibang Multipurpose project will have impactsin the downstream Assam, as accepted by NHPC Ltd,WAPCOS and recorded in EAC minutes, no public hear-ing has been conducted in Assam, in complete violationof the EIA notification which clearly states that in allaffected districts public hearings must be held. The sub-missions from Assam were not discussed during EACminutes. The people of Assam have been completely ig-nored in the decision-making about a project that willaffect them. Several people who spoke at the DibangPublic Hearing in Arunachal Pradesh in March 2013raised this issue, but MEFCC and EAC failed to do any-thing about this even after SANDRP submissions to EACalso raised this issue.

Even in Arunachal, the public hearing process has seenseveral violations, leading people to oppose the projectand the public hearings, see the quotes from the publichearings given below. Consequently, the public hearingswere disrupted by the local people and had to be can-celled several times. The MEFCC, unfortunately, has noconcern for the quality of the whole consultation pro-cess and sees it as only a box to be tick marked. TheEAC does not even look at issues related to public hear-ings.

2. Were the issues raised at public hearing inMarch 2013 addressed?

No. As is clear from the report of the public hearing forthe project held at Roing and New Anaya on March 11and 13, 2014 respectively, the affected people raised alot of critical issues about the project, EIA, EMP andPublic hearing.

In the Minutes of the 68th meeting of EAC held in Sept2013 and the 73rd EAC meeting held in March 2014, thereis one paragraph (same para in both minutes) onpublic hearings: “Concerns Raised During PublicHearings It was explained that in general, the peoplewere satisfied with the EIA and EMP reports and pro-

and Dibang Valley districts of Arunachal Pradesh, andsignificantly, several districts in downstream Assam.

Considering the fact that Dibang has the largest installedcapacity for a project in India, involving highest dam inIndia and biggest reservoir in North East India so far,one expected the EAC to be much more diligent whileconsidering the project and even more so consideringthe experience of the LSHP. But that, it seems, was ex-pecting too much.

The first thing that would strike any one who goesthrough the EAC and FAC documents is that the basicparameters of the project are yet unclear even as theEAC and FAC have recommended clearances, within thespan of a week, under pressure from their political mas-ters. Unbelievably, these two committees functioningunder the same Ministry have recommended clearancefor differing capacities, differing heights, differing sub-mergence areas and so on!

This is because the NHPC knowingly misled the EAC inits meetings by presenting the 288 m height (above thedeepest foundation level) dam with 545 m elevation atFull Reservoir Level (FRL) and 3.75 Billion Cubic Meters(BCM) of storage capacity at FRL. The same NHPC, inFAC meeting on Sept 22, 2014 provided sensitive analy-sis with dam height reduced upto 40 m, but this was noteven mentioned before the EAC!

Let us review the how the EAC and FAC dealt with theproject.

A. ENVIRONMENTAL CLEARNACE FOR THEDIBANG PROJECT:

The Expert Appraisal Committee (EAC) of the MoEF,which holds the distinction of having a zero rejectionrate for the projects it appraises, recommended Envi-ronment Clearance to 3000 MW Dibang Multipurpose

View of One of the affected villages show the rich forest thatthe project will destroy (Source – EIA)

4


posed R&R plan and community and social developmentplan. R&R plan has been formulated in line with theState R&R Policy, 2008. They took keen interest in know-ing the R&R package and community and social devel-opment (CSD) plan. However, during public consulta-tion prior to public hearing and during public hearingsof Dibang Multipurpose Project, in addition to commu-nity and social development plan more infrastructuraldevelopment in both Lower Dibang Valley and DibangValley Districts were sought viz., up gradation of Dis-trict Hospitals in both districts, financial assistance forschools, colleges and polytechnic, and construction ofcultural museum at Roing and ITI at Anini etc. Besidesthis for downstream people, the main concern was pro-tection of downstream area in case of dam break / highflood. Keeping this in view, a lump sum provision of Rs.17100 lakhs has been proposed for consideration of MoEFfor mitigative measures at downstream and otherinfrastructural facilities as raised during public hear-ings in addition to R&R and CSD plan.”

The claim that “in general, the people were satisfied withthe EIA and EMP reports and proposed R&R plan andcommunity and social development plan” is a completelie, as we see from the quotes from the official publichearing minutes below.

It seems the EAC members have not bothered to readthe public hearing report, and they have willingly or

unwillingly been misled by the NHPC and EIA agen-cies. To illustrate the critical issues raised at the publichearings, we are giving below some quotes from the of-ficial public hearing report. Most of these reports remainunaddressed in the EIA-EMP submitted to the MEFCC,but MEFCC and EAC has not bothered to check this.

Shri Lokha Elapra, President, All Idu Mshmi Stu-dents Union: “Poor planning of mitigation from im-pacts during construction phase. Mitigation measuresfail to address issues of demographic impacts, socio-cul-tural concerns and preservation of traditional land andlivelihood… EMP does not have any provision to addressthis. EIA and EMP does not have any mitigation mea-sures to preserve nor compeansation for permanent lossof mithun grazing areas, fishing grounds and medici-nal plants thus endangering the loss of Mishmi Takin(rare Animal), Mishmi Monal (rare Bird) and MishmiTeeta (rare medicinal plant)… Flood control of Eze(Deopani River to protect Roing Township… A cumula-

tive impact study in the Dibang river basin must be un-dertaken.”

Shri Raju Mimi, Member, Mishmi Scholar’s Asso-ciation: “NHPC had undermined the seismic designparameters as recommended by the experts of IITGuwahati, Guwahati University and Dibrugarh Univer-sity in respect of the Subansiri Dam. In this regard can

Anxious affected people outside the public hearing Hall in March 2013 (Source – PH Report)

5


the community members of the affected areas be certainthat such careless disregard for dam safety be not re-peated by NHPC in this case? All the documents relatedto dam design and safety be made public. Also, the docu-ments should be peer reviewed by independent group ofscientists. Ecological concerns like extraction of bouldersfrom ecologically sensitive Important Bird Area (IBA).No impact assessment made regarding this in the EIAreport… Hence a cumulative impact study in the Dibangriver basin must be commissioned. Socio-economic con-cerns like the catchment area treatment (CAT) plan willrestrict land use resulting in loss of land and livelihood.NHPC must ascertain such losses and compensate thepeople affected by CAT… There is possibility of loss ofland by destabilization of soil due to the huge reservoir.What mechanisms will be implemented to address theselosses? “

Shri Kelo Pulu, President IMCLS: “EnvironmentMonitoring Cell to assess and review the various mitiga-tion measures as mentioned in the EMP is not convinc-ing. Therefore, the Government of Arunachal Pradeshshould immediately notify the formation of an indepen-dent Committee consisting of less than 5 members of lo-cal Idu Mishmi people.”

Shri Moba Riba: “Conduct Public hearing at DambukSub division.”

Shri Jibi Pulu: “Additional EIA-EMP must be under-taken to ensure the minimum impacts to the ecology ofDibang area. The Community people will lose an area of10390 ha that will be required for CAT plan. This areabeing grazing area of Mithun will be lost. The EIA doesnot have any data or estimate/ valuation of this resource.Without any compensation the livelihood rights cannotbe taken away from the community. EIA studies aboutwildlife conservation is inadequate. EIA studies carriedout regarding assessment of economic and medicinalplants is not project specific nor community focused. Itdoes not have any reference, assessment and compensa-tion of economically valuable plants like Piper mellusaand Paris polyphylla. The impact of 1950 earthquake of8.7 magnitude.. Is the dam axis and reservoir standingalong the seismic fault line? The impoundment of thedrainage system by building dam will have major ef-fect.. Hence, EIA studies on downstream impact particu-larly study of Deopani drainage and its siltation statusis absolutely necessary.”

Dr Mite Linggi: “As recommended by the PlanningCommission Committee we demand for a Dam safetydesign panel for an independent assessment of safety ofDibang Dam. There are lacunae in EIA-EMP reports.This must be rectified.”

Shri MartinLego: “Resistance capacity of the moun-tains which fall in the reservoir is not studied. Dam

should be able to withstand flashflood. Construction offlood protection works with RCC wall supported by veg-etative cover on both banks of Dibang River… Our de-mands must be fulfilled then only we will support.”

Shri Mibom Pertin, President Adi Bane Kebang(ABK): “Till date no initiative has been taken by the StateGovernment, the district administration or the NHPC toeducate the people… the EIA EMP must be modified/ rec-tified wherein safety measures and actions to be taken incase of dam break… Until and unless the above pointsare fulfilled the holding of this public hearing is stronglyopposed by ABK.”

Shri Jowar Moyang: “Demand to establish a familydossier of the entire downstream people… Downstreamnot reflected in the EIA/EMP and DRP therefore, a sepa-rate guideline be made to include the downstream withinthe defined local area. The demands placed above mustbe addressed to within three months of this hearing orelse will protest against the construction of the project.”

Shri Nun Pertin, President, Dibang Adi Students’Union (DASU): “Downstream people are unaware of theproject benefits, impacts and other issues which are man-datory to be known before the commencement of theproject. Therefore, public hearing in this regard must beconducted within blocks and subdivision of LowerDibang Valley. This must be furnished in written assur-ance form within one week’s time. “

Shri Anjite Menjo, Zilla Parishad Member, IduliAnchal Block and Shri Chiliko Meto, ZillaParishadChairperson: “Environment Monitoring Cell to assessand review the various mitigation measures as mentionedin the EMP is not convincing. Therefore, the Governmentof Arunachal Pradesh should immediately notify the for-mation of an independent Committee consisting of lessthan 5 members of local Idu Mishmi people… Hence acumulative impact study in the Dibang river basin mustbe commissioned.”

Dr Mite Linggi, Representative of Kere A Initia-tive for Cultural and Ecological Security (KICES):“It is evident that the 2000 MW Lower Subansiri Projectis stalled since Dec 2011 because the technical, environ-mental and social concerns of the people of Assam werenot considered earlier. Report of the Planning Commis-sion appointed Committee of Dr C D Thatte and M SReddy has raised several serious concerns about thedownstream impacts of the 2000 MW Subansiri LowerProject. Therefore, keeping this in mind, it is absolutelyimportant that public consultation in Assam is carriedout before the Dibang project gets environment clearance.Public consultation in Assam is not only necessary toaddress the concern of the people, but it is a pre-requisitefor the people of Dibang Valley in the upstream… Ignor-ing downstream concerns will only ensure that this

6


project to will meet the same fate as Subansiri LowerProject (2000 MW and get stalled by people of Assam.Rights of the people to use Catchment Area will be de-nied. Will compensation be included for them? Is it pos-sible for NHPC Ltd to formulate new criteria for all thosevillages perched atop to include within affected fami-lies?”

Shri Lokha Elapra, President, All Idu Mishmi Stu-dents’ Union (AIMSU): Raises most of the critical is-sues raised above including need for Cumulative Im-pact Asessment, inadequate EIA-EMP, Impacts of de-mographic changes, lack of assessment of loss of graz-ing land, fishing right. “We do not want to be refugees inour land.. We the Idu Mishmi have a way of living wherewe live independently. Past history is proof of it. We hadnever been ruled and can never be ruled under any cir-cumstance or vice versa. The plot which the NHPC Ltdclaim giving free of cost is by virtue forcefully asking usto live in that piece of land where the PAFs are not satis-fied.”

Shri Athupi Melo, Ex-ZPM, Anelih-Arju Block andRepresenting New Endoli village: “Public hearingon Dibang Multipurpose Project (3000 MW) was post-poned 10-14 times earlier as the consent of the publicwas not taken before preparing EIA and EMP reports.The NHPC Ltd had cheated the entire affected people byconcealing information and letting the awareness remainwithin the high reach people only. The NHPC Ltd as pertheir survey has shown 5 villages, 72 families, 243 per-sons, 938.8 ha of agriculture land as to be affected by theproject. Do they know that the storage reservoir will sub-merge the land mass which belongs to another 34 vil-lages of the valley?”

Shri Kupu Miku-ASM Arzoo and Representativeof Apako village: “Had been resisting NHPC Ltd forthe last ten years. Nothing was made known as to howmuch land would go and how much compensation wouldbe provided.”

Shri Rezina Mihu, General Secretary, All IduMishmi Students Union (AIMSU): “It has been sixyeas of resistance till this morning. The former Presi-dent of AIMSU sacrificed his life fighting against theDibang Project... the EIA-EMP is still not upto the mark.”

This selection of quotes from the Public hearing and read-ing of NHPC response, EIA-EMP and EAC minutes showthat not only NHPC has failed to satisfactorily respondto most of these issues, the EAC and MEFCC has noteven bothered to check the veracity of the claims ofNHPC and uncritically accepted the NHPC claims. In-adequate response to the issues raised at the public hear-ing means that environmental clearance given to theproject is legally untenable.

3. Has there been proper Environmental ImpactAssessment of the project?

NO. Kalpavriksh, SANDRP, affected groups from Assamand Arunachal have made several independent submis-sions to EAC on the inadequacies of the EIA (Environ-mental Impact Assessment). SANDRP itself sent fourdifferent submissions (dated Sept 20, 2013, April 2014,May 2014 and Sept 12, 2014) highlighting various inad-equacies of the EIA including:

• Lack of compliance with the Terms of Ref-erence of the EIA

• Lack of basin wide cumulative impact as-sessment

• Impact of mining of materials for theproject not assessed

• Lack of downstream impact assessment(more details below)

• Lack of assessment of how climate changewill affect the project and how the projectwill worsen the climate change impacts.

• Lack of options assessment

• Severe Impacts of Migration of Outsider onLocal Tribal Community not assessed

• Impact of the project on disaster potentialin the project area as well in the down-stream including Assam not assessed

• Impact of changing silt flows downstreamnot assessed

As noted above, large number of speakers at the publichearing also pointed out the inadequacies of the EIA-EMP.

Active Lanslide zone in submergence area ofDibang Project (Source – EIA)

7


4. Are downstream impacts on Assam &Arunachal Pradesh Studied?

No credible study of the impact of the dam, dam breakand peaking on Assam and Arunachal Pradesh in thedownstream has been done.

Several speakers at the public hearing raised this issueof inadequate downstream impact assessment, as canbe seen from the quotes from the public hearing listedabove.

It may be mentioned here that the biggest issue plagu-ing the LSHP is lack of downstream impact assessment,and the EAC, MEFCC, NHPC or the EIA agencies(WAPCOS, which by now is notorious for doing substan-dard studies and National Productivity Council). EvenAssam and Arunachal Pradesh state governments alsoseem least bothered. Also, it seems no lessons have beenlearnt after Larji mishap when 25 students were washedaway due to demand-driven water releases by upstreamhydropower project.

5. Has the impact of Peaking on DownstreamAssam & Arunachal Pradesh studied?

NO

This is despite the fact that submissions were sent tothe EAC from several organizations and individual alsofrom Assam, drawing their attention to impact of peak-ing in downstream Assam, especially in lean season (win-ter) when flow fluctuations will range from 111 cumecs(Cubic meters per second) to about 13 time rise in vol-ume at 1441 cumecs in a single day. Fluctuations canhappen twice or thrice in a single day.

6. Has the impact on Dibru Saikhowa NationalPark in the downstream Assam studied?

NO

The EAC has shown zero application of mid in this re-spect. There are several hydropower projects being con-structed on the three main tributaries of Brahmaputraupstream of Dibru Saikhowa National Park in Assam.All these hydropower projects will undertake peakingoperations. EAC has considered these projects sepa-rately, as a part of basin studies and as a part of down-stream impact studies on Dibru Saikhowa National Park.

In all these studies, the level fluctuation at theNational Park when the three major projects inthe upstream undertake peaking operations is dif-ferent, as per the convenience of the project pro-ponent! EAC has considered all these studies withoutraising any questions about this convenient differencein figures even when the contradictions were brought toEAC’s attention by SANDRP.

The EAC has recommended Clearance to Dibang Multi-purpose Project accepting the contention of the NHPCthat “water level fluctuation in Dibru SaikhowaNational Park (DSNP) will be less than one meter.”

• However, the same EAC has considered EIA ofLower Siang HEP (by WAPCOS) where the fluc-tuation at Dibru Saikhowa when all projects arepeaking is said to be 7.8 feet (2.38 meters)

• The Report on “Effect of Peaking power generationby Siang Lower HEP, Demwe Lower HEP andDibang Multipurpose HEP on Dibru Saikhowa Na-tional Park” also by WAPCOS states that level dif-ference when all three projects are peaking is esti-mated to be 2.34 mts i.e. 7.67 feet. (Page 26)

EAC did not question these glaring differences in thesemodels even when a submission highlighting these pointswas sent to the EAC on 13.09.14, before the 77th EACmeeting. The submission is not mentioned in the min-utes, neither discussed, also violating Hon. Delhi HighCourt Orders (Utkarsh Mandal Case).

7. EAC decision violates its mandate; MEFCC &NHPC guilty of misleading EAC.

During the entire appraisal process, the EAC has failedto pose any difficult questions to NHPC, has not taken astand supporting Assam, has not even initiated discus-sion in that direction, has turned blind eye towards sub-missions it received raising critical concerns, has over-looked contradictions, has overlooked precautionaryprinciple and welfare of people in the downstream Assamand has refused to learn any lessons from the LSHPexperience or the Larji Mishap.

While discussion about height reduction of Dibang upto40 meters were initiated in MEFCC/ NHPC since Feb2014, the MEFCC or the NHPC has not brought thisproposal to the attention of the EAC and the EAC hastaken absolutely no notice of this and has not even askedfor this 40 m height reduction. The only reference wecan find to the height reduction proposal is in the min-utes of the 73rd EAC meeting, where too there is refer-ence to only 10 m ht reduction. And yet, there is no men-tion of this in the minutes of the 77th EAC meeting wherethe EAC recommended clearance to the project.

This alone is sufficient to make the EAC decision legallyuntenable and make both MEFCC and NHPC guilty ofnot informing the EAC about these developments morethan six months after they were initiated.

The EAC on its part has not shown the will to ask for arealignment of the project to minimize its downstreamimpacts, peaking impacts and submergence impacts.Such biased conduct and the decisions of the EAC, side-lining genuine concerns are in complete violation of the

8


mandate given to EAC and extremely damaging to en-vironmental governance of the country and are a rea-son for increasing conflicts, delays, protests and strifeunderlining its callousness towards environmental im-pacts and local resistance.

The issues that FAC raised while rejecting the Forestclearance are the very issues that EAC should be con-cerned about since they are under their mandate. Butnot only EAC did not raise them on their own, but evenafter they were brought to the EAC’s attention bySANDRP, the EAC failed to even discuss those issues.

8. Issues on Dibang raised in earlier EAC meet-ing remains unanswered

The decision making paragraph of the minutes of theEAC meeting of Sept 16-17, 2014 on Dibang Projectreads: “After critically examining the proposal and con-sidering the response to various issues raised in the ear-lier EAC meetings, the project was recommended by EACfor accord of Environmental Clearance to Dibang Multi-purpose Project. However, EAC suggested that 20 cumecflow may be released towards e-flow in the 1.2 km di-verted stretch as 15 cumec gives just sufficient quan-tity. EAC noted that beyond this 1.2 km, adequate flowwill be available from TRT which will be minimum inthe order of 85 cumec at 80% rated discharge of one tur-bine.”

It is clear that this paragraph does not reflect any appli-cation of mind by EAC if the response provided by NHPCto the various issues raised by EAC and others’ submis-sions to EAC are adequate. Even in this paragraph, it isnot clear what is the basis of EAC decision to recom-mend 20 cumecs flow downstream of the dam and notthe norm that EAC is following for other projects (30%in monsoon, 20% in lean season and 20-25% in non mon-soon non lean season). Nor is it clear what is the basisand impact of operation of one of the (there are 12 tur-bines, each of 250 MW installed capacity in this project)turbine at minimum 80% capacity round the clock. Thisnon application of mind on the part of the EAC is thenorm of EAC and not an isolated incident.

In fact, reading through the minutes of all the EACmeetings since Sept 2013 where Dibang EC (Environ-ment Clearance) was discussed, it is clear that whileEAC has raised a large no of questions and reported someof the information submitted by NHPC, no where canwe find application of mind of the EAC where it is statedthat the information/ responses provided by NHPC isadequate or not. The uncritical acceptance by the EACabout the information/ responses provided by the devel-oper is another noteworthy feature of EAC decision.

Let us illustrate this. The minutes of the 73rd EAC meet-ing held in March 2014 says: “A detailed fisheries (alsoflora and fauna) survey was conducted by Centre for

Inter-Disciplinary Studies for Mountain and Hill Envi-ronment (CISMHE), Delhi University in the month ofDecember 2013.” Immediate question than arises is, whywere the fisheries and other surveys done only in onemonth and not across the year as is the normal prac-tice? What were the outcomes of the study? You will findneither critical questions, nor any answers in the EACproceedings.

Here is another example. The minutes of the 74th EACmeeting held in May 2014 says: “It was informed thatfluctuation in the water level at upstream of Dibang-Lohit confluence due to peaking operation will be about17 cm which is almost negligible considering the size ofthe river.” Shockingly, the EAC does not even ask: A. Ifthis estimate is sound and if it is consistent with conclu-sions of other studies; B. What will be the level fluctua-tion at different points along 60 km stretch of the riverupstream from this point to the project site and whatwill be the impact there of. EAC’s such uncritical accep-tance of apparently contradictory and inadequate re-sponses from the developer is the norm and not an iso-lated incident. Considering that EAC was consideringthe largest installed capacity project of India, highestdam of India and biggest reservoir in North East Indiaso far, one expected the EAC to be more diligent. Thiswas even more so considering the experience of theLSHP.

To further illustrate, the minutes of the 74th EAC heldin May 2014 says: “The point-wise reply to the two rep-resentations submitted by Kalpavriksh was submittedto MoEF and EAC members and the same was also pre-sented before EAC during the meeting.” Similarly, theminutes of the 73rd EAC meeting held in March 2014says: “point-wise replies to the issues raised by Shri ChowRajib Gogoi, Secretary, All Tai Ahom Student Union,Jorhat and Shri Pushp Jain, Director, EIA Resource andResponse Centre (ERC), New Delhi were also given”.But in both cases, there is not even a word as to whetherEAC discussed the NHPC response and if they did whatwas their conclusion about adequacy or acceptability ofthe NHPC responses.

As far as four separate submissions sent by SANDRP toEAC on Dibang Project are concerned, EAC neithermentioned them, nor did it seek NHPC’s response onthem.

Considering all this, the decision of the EAC to recom-mend EC to the Dibang Project is clearly wrong, basedon inadequate appraisal, in the absence of applicationof mind and legally untenable.

B. FAC DECISIONS ON DIBANG PROECT

It has been reported3 that the Forest Advisory Commit-tee of the MoEF has recommended clearance to 3000MW Dibang Multipurpose project in its meeting on Sept

9


22, 2014, though the minutes of the FAC meeting are asyet unavailable. This decision is reversal of FAC’s clearrejection to the project twice in past 2 years4 in additionto MEFCC’s rejection letter to the project as late as onthe 28th August 2014.

• MEFCC was pressurized by the Cabinet Commit-tee on Investment, Ministry of Power and even un-related Ministries like Ministry of Mine, Ministryof Steel and Ministry of Coal into clearing theDibang project. FAC itself was under pressure ofthe MEFCC minister and its highest officials toclear Dibang at any cost.

• Relevant papers regarding height reduction pro-posal by NHPC were not uploaded on FAC Websitein advance of the Sept 22, 2014 Meeting.

• It is unclear if even the FAC Members had thesedocuments, which form the basis of project consid-eration.

• The height reduction proposal was not available tothe EAC members a week earlier before EAC rec-ommended clearance to the project.

• FAC’s recommendation on Dibang project is clearlyan undemocratic and illegal decision in the absenceof prior information in public domain for all con-cerned, and when all the original objections raisedby FAC while rejecting the project twice remain un-addressed.

Let us look at the timeline of FAC decision mak-ing on Dibang Project:

12.06.13: FAC rejects Dibang FC (Forest Clearance)Proposal. Reasons: “huge forest area with very good for-est cover, irreparable and adverse impact on general eco-system of the area by felling of more than 3.5 lakhs oftrees, several other HEP have been proposed in the sameriver valley apart from Dibang HEP, unavailability ofstudy on cumulative impact of all the HEP, etc. The Com-mittee is also of the opinion that ecological, environmen-tal and social costs of diversion of such a vast track offorest land, which is a major source of livelihood of thetribal population of the State, will far outweigh the ben-efits likely to accrue from the project.”

13.08.2013: Meeting of Secretary, Ministry of Environ-ment and Forests and the Secretary, Ministry of Powerheld and it was decided that proposal will be consid-ered again after exploring the possibility to reduce therequirement of forest land for the project.

9.12.2013: Project discussed by the Cabinet Commit-tee of Investment which nearly ordered fast clearance

for Dibang Project. It stated: “Ministry of Environmentand Forests may grant the requisite clearance for diver-sion of forest land expeditiously.” Such direction fromCCI was clearly in violation of the Forest ConservationAct 1980 which clearly defines the process for forest clear-ance and where CCI has no role.

10.02.14: NHPC revises proposal and submits two al-ternatives, reducing height by 5 m and 10 meters re-spectively. Marginal decrease in submerge of forest landdue to 10 meters reduction. NHPC Officials say any fur-ther reduction will not be possible.

Revised Diversion proposal with reduction of 10 mtsheight and 445 hectares forest area submitted to MoEFwith new proposal for total diversion of 4577.84 hect-ares.

29th-30th April 2014: Revised proposal discussed in FACwith 10 meters reduction. The revised proposal was in-complete in many basic respects like absence of maps,CAT Pan, FRA compliance, identified land for Compen-satory afforestation, etc. In addition, the FAC noted thatthe region is home to Schedule I species, the reduction inforest loss due to decrease in height in minimal and willnot have substantial ameliorative impact, It said “Such amarginal reduction in requirement of the forest land forthe project may not be able to reduce the adverse impact ofproject on such a biodiversity rich mature forest ecosys-tem to the extent which could make the project environ-mentally as well as socio-economically viable in forestdependent tribal society of Arunachal Pradesh”. FAC alsonoted that impact of reduction of dam height on its eco-nomic feasibility was not put before the committee.

16.06.2014: Secretary Power writes to Secretary,MEFCC on 16.06.2014 to review the decision of FAC andaccord the Stage-I forest clearance. Such direction fromletter was clearly in violation of the Forest Conserva-tion Act 1980 which clearly defines the process for for-est clearance and where Power Ministry secretary hasno role.

19.06.2014: Joint meeting held between Ministry ofMine, Ministry of Steel, Ministry of EnvironmentForests and Climate Change and Ministry of Coal,attended by the Ministers and Secretaries of the respec-tive Ministries, as well as Secy, Ministry of Powerwherein it was decided that a report on sensitivity analy-sis of dam height reduction by 40 meters shall be sub-mitted to MoEF and action will be taken only after that.

24.06.2014: Secy, Ministry of Power writes to MEFCC& submitted a report on the sensitivity analysis on thedam height reduction upto 20 meters. However, MEFCCmaintained that that as decided in the meeting the sen-

3 http://indianexpress.com/article/india/india-others/6-years-2-rejections-later-indias-largest-hydro-project-cleared/99/#sthash.vNJo2nAs.dpuf

4 For details, see: http://sandrp.wordpress.com/2014/05/17/dibang-project-rejected-forest-clearance-for-the-second-time/

10


sitivity analysis report was not submitted by the projectproponent.

28.08.14: MEFCC sends letter rejecting Forest Diver-sion Proposal of Dibang Multipurpose Project on thebasis of 10 meters height reduction, rich forest, socialimpacts and also downstream impacts on Assam, includ-ing Dibru Saikhowa.

5.09.2014: MEFCC writes to (NHPC/ Min of Power) tosubmit sensitivity analysis of reduction by 40 meters.

08.09.14 (This letter of 08.09.14 was uploaded onMEFCC FAC website on the day of the FAC meet-ing, 22.09.14): NHPC submits letter to MEFCC aboutsensitivity analysis for height reduction from 5m-40meters. While it highlights the loss in installed capacity(780 MW) and loss in revenue due to 40 m reduction, itdownplays the fact that 40 mts reduction will bring downforest land requirement by 26%. It concludes, withoutsubstantiation that “Decrease in dam height and conse-quent sacrifice in power generation beyond 10 mts re-duction is not commensurate with saving forest land”and further recommends only 10 mts height reduction,which proposal the MEFCC had rejected in its Apr 29-30, 2014 meeting.

21.09.14: No sensitivityAnalysis uploaded onMoEF FAC Website.SANDRP sends a sub-mission urging FACnot to consider theproject in the absenceof this analysis in pub-lic domain as it vio-lates CIC orders.People affected by theproject have no idea ofthis analysis which isthe basis of decisionmaking in the nextday’s meeting.

22.09.14: Day of theMeeting: Suddenly Addi-tional Information docu-ment accessed (anddownloaded) on 21.09.14changes, with two addi-tional pages and letterfrom NHPC about sensi-tivity analysis is up-loaded ON THE DAYOF THE MEETING.

23.09.14: News that FAChas recommended clearance to Dibang was already pub-lic.

CONCLUSION As noted earlier, the Dibang Project isthe largest capacity hydropower project, the highest pro-posed dam and largest proposed reservoir of North EastIndia. One expected all concerned to be diligent in tak-ing decisions on such a project. However, it is clear fromthis narrative that the process of environment and for-est clearance for the Dibang Project is fundamentallyflawed, inadequate and in violation of all norms of demo-cratic and informed governance. Significantly, it is alsoillegal and untenable. Such manipulative decision-mak-ing has led to flawed decisions of environmental and for-est clearances in case of LSHP in 2003, with the projectstalled by people’s agitation since 34 months now. If theDibang Project, which is bigger than LSHP in every re-spect and with much greater impacts, is pushed in sucha manner, it is likely to face the same fate as that of theLSHP. We hope that the final decisions related to DibangProject will be more informed, diligent, democratic, un-biased and objective. Admittedly, such hope seems ratherfarfetched at this moment.

Parineeta Dandekar, Himanshu Thakkar

(This has been published at: http://sandrp.wordpress.com/2014/10/06/manipulating-environment-forest-clearances-for-dibang-project-deja-vu-lshp-history-repeated-will-it-be-tragedy-or-comedy/)

The affected people stopping the public hearing in 2008. Source:http://www.roingcorrespondent.in/this-circus-should-stop-no-public-hearing/

11


The Union Ministry of Environment, Forests and Cli-mate Change (MEFCC) in the BJP led new governmentat the centre has, through Office Memorandum (OM no22-15/2014-IA.III) dated Aug 29, 2014 constituted HighLevel Committee (HLC) under the chairpersonship offormer cabinet secretary TSR Subramanian, “to reviewvarious acts administered by Ministry of Environment,Forests and Climate Change”. Let us try and look atthis proposal on its merits.

Firstly, it should be noted that the HLC has a far-reach-ing mandate to review the core legislations that are sup-posed to protect India’s environment, including the En-vironment Protection Act (1986), the Forest Conserva-tion Act (1980), the Wildlife Protection Act (1972), theWater (Prevention and Control of Pollution) Act (1974)and the Air (Prevention and Control of Pollution) Act(1981). Considering that these acts are the back bone ofMEFCC’s environmental governance, the recommenda-tions of this committee can have far reaching impact onIndia’s environmental governance.

Secondly, there are no doubts that India’s environmen-tal laws and governance needs to be reviewed andstrengthened. While the industry and vested interestlobbies have been claiming that MEFCC’s work is a hin-drance to India’s development and growth, the reality isquite the opposite. MEFCC provides environment clear-ance (for projects covered under EIA notification of Sept2006, which is the current notification and which ex-cludes large number of projects from requirement ofenvironment clearance), forest clearance, wildlife clear-ance, coastal zone clearance and also certifies if theprojects applying for CDM (Clean Development Mecha-nism under the United National Frame Convention onClimate Change) are sustainable development projects.

The committee has been explicitly constituted for review-ing the five environmental laws. These laws need to bestrengthened so that there is inclusive, democratic, bot-tom up process in which people have a decisive role. Thegovernance related to the laws thus needs to be changedin this context so that there is greater transparency, ac-countability and participation and better compliance isachieved. This is what we mean when we say we need toimprove the environmental governance.

MEFCC’s zero rejection rate With respect to givingany of these clearances, the MEFCC has almost zerorejection rate in most crucial sectors. For example a re-view1 of the functioning of the Expert Appraisal Com-mittee on River Valley and Hydropower project showsthat the committee has not rejected almost any of theproposals that came its way in last seven years. The

MEFCC has not rejected any of the proposals that ap-plied for CDM status. Even in other sectors, the MEFCChas rejection rate below 3%, if at all and projects forwhich clearances have already been given like coal min-ing, are far from being implemented.

States already have enormous powers Some peoplehave been claiming that states do not have sufficientpowers in environmental decision making and hence thepowers need to be delegated to the states. The fact isthat the states already have enormous powers in envi-ronmental governance, including in all clearances. Thepollution control regime is completely under the states.The states are empowered to clear several categories ofprojects in the context of all the clearances. The statepollution boards are supposed to give consent to estab-lish and operate, before which no project can operate,they are also supposed to conduct public consultationseven for projects requiring central clearances. BeforeNational Wildlife Board clears a project, State WildlifeBoards need to clear the projects. Consent of Forest Of-ficials from the states is mandatory before Forest Clear-ance application is processed to higher levels. Whichstate in India has shown exemplary conduct to inspireconfidence that they are in a position to achieve neces-sary environmental governance? We do not know of any.Unless the capacity of states in this regard is increased,we cannot improve environmental governance in Indiaonly in the name of entrusting it in the hands of thestates.

Is MEFCC responsible for delays? This is anotherbogey raised against the MEFCC. The fact is that theEIA notification has clearly defined timelines that saysthat if MEFCC fails to respond within the timeline, theproject can be deemed to have secured the clearance.The fact of the matter is that no project has claimed orgotten such deemed clearance, since most project devel-opers are uninterested in fulfilling even the minimalistdemands of MEFCC. On the other hand, most dams andhydropower projects get delayed beyond the promisedtime frame even after getting the clearances! For anyobjective person, the claim that MEFCC is responsiblefor delays and lengthy procedures is clearly a bogey.

Do projects need too many clearances? Anotherargument made by some is that MEFCC needs too manyseparate clearances for the same project, which leads todelays. This is again not borne out by facts and clear-ances that are required now are bare minimum. Exceptenvironmental clearance, rest of the clearances does nothave any public consultation process. Even in case ofenvironment clearance, except the projects covered un-der EIA notification, rest of them do not need public con-

1 For details, see: http://sandrp.in/env_governance/TOR_and_EC_Clearance_status_all_India_Overview_Feb2013.pdf

Review of environment laws is necessarybut the TSR Subramanian HLC lacks credibility

12


sultations. The five clearances that MEF gives as listedabove are required under each specific law and it is com-pletely justified that separate appraisal process is re-quired for each of them as the issues considered andsectors affected are specific in each case, which cannotbe clubbed. We need to strengthen each one of theseappraisals, rather than weakening them or clubbingthem together.

EAC lacks credible independent members or chair-persons It is public knowledge that most of the peoplewho are appointed on the various committees that ap-praise the projects for clearances are those who are readyto toe the official line without raising too many uncom-fortable questions. There are known cases when thechairman of the EAC or member of FAC were found tohave direct conflict of interest with their involvement incompanies whose projects they were to consider for clear-ance. Recently, NGT has ordered that the chairs of theEAC cannot be generalist administrators but must havedomain knowledge and experience. The lack of credibleindependent members in these committees is a majorreason why the Ministry manages to clear almost any-thing that comes its way.

Poor quality impact assessments It is also well docu-mented how most of the environment & social impactassessments, environment management plans or thecumulative impact assessments are shoddy, inadequate,incomplete, cut paste or dishonest efforts. Even mediahas reported several cases, environment groups haverepeatedly sent detailed analysis and critiques of theseassessments, but the ministry and its committees havethe distinction of not rejecting any of such assessmentsor recommending punitive action against the agenciesthat are submitting such dishonest or problematic re-ports.

Public consultations in name sake Under the EIAnotification of Sept 2006, the projects are supposed tohave public consultations which include public hearingat each of the affected project districts. Here again therehave been several documented cases how the public hear-ings are hijacked by the project developers, they are con-ducted by partisan government officers and there is noapplication of mind from the MEFCC to ensure that theissues raised at the consultations are addressed. Sev-eral observers, including a former environment minis-ter has accepted that these consultations are largely fornamesake only, a box to be ticked. Even when all thepeople present at the public hearings have said that theydo not want the project, it has no impact on the decisionof giving clearance to the project.

Non-existent compliance All the clearances given areconditional, and the project developer is supposed to fol-low these conditions and implement environment man-agement plan. However, how is compliance to these con-ditions and management plans, a very crucial aspect, tobe achieved? The project developer is supposed to sub-

mit six monthly compliance reports, but there are noconsequences if they do not do that for years! The offi-cials at MEFCC or their regional offices do not have thetime to go through these reports and check if these indi-cate adherence to the required measures and norms pre-scribed. Neither do these agencies take steps when thecompliance reports do not follow the norms. They arenever known to have taken any steps in this regard. Themonitoring visits from regional offices of the MEFCCare always preplanned and the project developers getaway with window dressing at best. There are no sur-prise visits. Even after monitoring visits, the MEFCChas never taken any steps when MEFCC finds lack ofcompliance.

I have narrated this list of known problems to show howlax is our environmental governance and how necessaryit is to strengthen it rather weakening it. If the reviewis being done with a view to strengthen the environmentgovernance, it would be welcome.

Review of functioning of institutional set up inenvironmental governance The review of function-ing of institutional set up responsible for environmentalgovernance also becomes imperative after such a longperiod since these institutions were set up. For example,state and central pollution control boards were set upunder the Water Act of 1974, but we do not have experi-ence of a single river or even a tributary of a river hav-ing been cleaned up because of the efforts of the pollu-tion control institutions. This failure is a major reasonfor the state of our rivers today, including the Ganga.

New Issues In addition to the need for strengtheningthe environmental governance, the review of environ-mental laws and institutional architecture connectingwith their implementation is also necessary in view ofthe emerging new issues. For example issues like cli-mate change, need for cumulative impact assessments,need for environmental flows in the river, need to pro-tect, preserve and rejuvenate rivers (a proclaimed pri-ority of the current government) or assessment of im-pact of projects on disaster potential of the area werenot as important and urgent as they were when theselaws were formulated.

Current review What I have written above providessufficient ground for need for review of laws and insti-tutional set up for environmental governance in India.For this we need a credible independent team withclearly defined terms of reference and transparent, par-ticipatory and confidence inspiring process. Let us see ifthe review set up under the HLC qualifies to achievesuch a review.

Sinisterly ambiguous TOR Firstly, if we read the fourTerms of Reference (TOR) given to this committee un-der the above mentioned OM, the first TOR says thereview will assess status of implementation of the actvis a vis “the objectives”. But the TOR does not definewhat is meant by “the objectives”. The second TOR is

13


not problematic as it says the review will “examine andtake into account the various court orders and judicialpronouncements relating to these acts”. The Third TORis the most sinister. It says the HLC will recommendspecific amendments in the acts, “so as to bring them inline with current requirements and to meet objectives”.The trouble is, neither “current requirements” nor “ob-jectives” have been defined. Without defining them, theseare open to any interpretation that is suitable to thecommittee! Such ambiguous TORs which are open tomanipulation are completely unacceptable and do notinspire any confidence in this exercise.

Constitution of HLC The committee chaired by formercabinet secretary T.S.R. Subramanian has four members(including the chair) and two secretaries (both governmentofficials). The constitution of the committee and criteriafor selection of the members has remained completely nontransparent, which itself raises many questions.

Among the four members, two are former bureaucratsand two are with legal backgrounds. None of the mem-bers are either expert in environmental issues or envi-ronmental governance. None of the members (includingthe chair and the secretaries) are known to have foughtfor or campaigned for or worked for improving environ-mental governance in India. There are no credible, in-dependent non-governmental members or independentexperts here.

Viswanath Anand, one of the two former bureaucratmembers of the HLC and former environment secretary,does not inspire confidence due to his track record ei-ther as environment secretary (1997-2000) or as ViceChair of National Environment Appellate Authority(2002-2005). His tenure at NEAA was described by theDelhi High Court as “a one-man show” in the absence ofa chairman and three technical members of the author-ity.2 Media further reports: “Very few appeals were ad-mitted by Anand during his three-and-a-half-year stintat NEAA. In the Loharinag Pala case, he drew sharpcriticism from the Delhi High Court for “adopting a veryhyper-technical approach in rejecting the petitions” andoverlooking “that these petitioners deserve to be heardon merits”. The court quashed Anand’s order and rein-stated the appeal.” That says a lot. There are severalother narrations about the role played by Mr Anand atNEAA3. Mr Anand is also on Coca Cola India’s AdvisoryCouncil on Environment and Sustainability4, whichseems to be in conflict with his role in HLC.

Appointment of Mr Hardik Shah (one of the two secre-taries) as chairman of Gujarat Pollution Control Boardwas challenged in Gujarat High Court by RTI activistAmit Jethwa before he was killed.

Considering the non-transparency in its appointmentand known background of some of the members, the con-stitution of the committee too does not inspire any con-fidence that it will help improve environmental gover-nance in India.

Process of participation The MEFCC has said thatwithin a month, that is by Sept 27, 2014, people can sendsubmission to the committee in less than 1000 characters(or an email)! This is completely ridiculous and showshow non-serious the government and the HLC is aboutthe submissions. This article, with already more than13000 characters would clearly disqualify for submissionto the HLC! Besides the issue of length, there is not evena clearly defined process that tells the people what willhappen to their submissions and how are they sure toknow that their submissions will be even acknowledgedand responded to or even read. The process of participa-tion is completely unacceptable. The whole process limitsthe participation to only English speaking and writingpeople who have access to internet, leaving out vast ma-jority of the people out of the review process.

Conclusion It is clear from all accounts that the HLCdoes not carry any credibility or inspire in any confidencefor any objective person. The best course for the MEFCCis to dissolve the HLC and restart the process keeping inmind the comments from groups and individuals withoutvested interests. The government should in the first placeinstitute a credible independent review of the experiencewith environment laws, institutions and governance inIndia. The report of this exercise should than be madeavailable to al the gram sabhas in local languages. It isonly based on such a report that a review of the environ-mental laws, institutions and governance be taken up, inwhich than the people and groups on ground can partici-pate. At least 50% members of the review process shouldbe women, when today there are none.

We have looked at this process purely on its merit, with-out looking at what the new BJP led government at thecentre has done over the last four months. The govern-ment has been very busy diluting and dismantling what-ever little exists in terms of environmental governancein India. If we add that track record to this analysis,then the conclusion is loud and clear: The formulationof HLC is aimed at completely dismantling the laws andinstitutions related to environmental governance in In-dia. This is not a good sign for the future of this countryand her people.

SANDRPFor a related blog, see: http://sandrp.wordpress.com/2014/10/10/strengthen-and-not-dilute-environment-laws-submission-to-the-mefs-hlc-to-review-environ-ment-laws/

2 http://indianexpress.com/article/india/india-others/the-six-minds-that-will-look-afresh-at-environment-laws/#sthash.RMohoCW9.dpuf3 See for example: http://infochangeindia.org/environment/analysis/national-environment-appellate-authority-puppet-of-the-moef.html and

http://www.deccanherald.com/content/22796/tribunal-coming-justice-can-wait.html and http://indiatogether.org/neaa-environment4 http://www.coca-colaindia.com/sustainability/final-bios.html and http://www.coca-colaindia.com/sustainability/viswanath.html, accessed at

3.37 pm (IST) on Sept 26, 2014

14


From media to ministers to people on the street all overIndia and beyond are concerned as to what happenedsuddenly that plunged the state of Jammu and Kash-mir into this unexpected, unpredicted and unprec-edented flood disaster. It remains to be seen as to howdeep is the concern and what impact it will have. So farthe signs are not particularly promising.

Heavy rainfall was the immediate cause. As per datafrom India Meteorological Department (IMD), in theweek ending on Sept 3, 2014, the state received 55%above normal rainfall. During Sept 4-6 the state levelaverage rainfall was 250 mm (2212% of normal rainfallduring these three days), of which 106 mm fell just onSept 6, which is 3116% of the normal rainfall for thestate for that day. State level averages mask the loca-tion and time specific rainfall intensities. For example,during the week ending on Sept 10, Udhampur (605.5mm), Reasi (556 mm) and Kulgam (460.5 mm) districtsreceived much higher rainfall. Such heavy rainfall wasclearly going to lead to disastrous implications.Strangely, none of the local, state or central agenciescould see the implications of such heavy rainfall. Thisrainfall event started on Sept 3-4 (or earlier in somecases), and there was sufficient time before the waterreached Srinagar or other upstream areas of Jhelum ba-sin and Jammu areas in case of Chenab basin, but noagency could provide even a warning to these vulner-able areas.

Down to Earth reported1, “On the night of September 4,the Doodh Ganga, a tributary of the Jhelum flowingthrough Srinagar, breached its embankment followinga cloudburst in its catchment area. On September 5, thewater level in the Tawi and Chenab rivers in Jammurose dramatically. Flood control bunds were washedaway, bridges collapsed and agricultural land got sub-merged. Rains continued to lash the region in the nextfew days triggering landslides that disrupted highwaysand snapped power lines. Till the afternoon of Septem-ber 5, Srinagar residents were clicking photographs ofthe gradually swelling Jhelum to post on social media.”

On the night of September 5, the Jhelum too breachedits embankment at Padshahi Bagh in Srinagar. “In Sep-tember, rainfall in Srinagar crossed its 10-year-highmark—151.9 mm of rainfall in September 1992—within24 hours. This year, the city received 156.7 mm of rain-fall on September 5 alone. The average monthly rainfallfor Srinagar is 56.4 mm. The India Meteorological De-partment recorded more than 500 mm of rainfall in the

first week of September. The floodwater started reced-ing from September 11, but till September 13 more than70 per cent of Srinagar was still submerged, with tensof thousands of people stranded. The two distinct waterchannels flowing through the city—the Jhelum and theflood channel, an artificial outlet created in 1904 to drainout excess water from the Jhelum in case of flood—hadmerged into a big, brown lake. Some of the worst-af-fected areas include Allochi Bagh, Tulsi Bagh, WazirBagh, Rajbagh, Zero Bridge and areas along the rightbank of the Jhelum. Maisuma, Natipora, Lal Chowk andseveral localities in Civil Lines remained submergedunder two metres of water” said the report.

The discharge capacity of the Jhelum River passingthrough the Srinagar city is 35,000 cusecs (cubic feetper second) and has been reducing over the year. Theflow in Jhelum reached 1,20,000 cusecs, the highest everdischarge mark, on September 7. The Jhelum embank-ment in Srinagar had 22 major breaches from Kandizalto Chattabal, the points of entry and exit, during thefloods on September 6 and 7. Apart from the breaches,water overflowed river embankments at dozens of places.

The first failure in this disaster is of the IMD. It did notprovide actionable weather forecasts in advance of therainfall. Secondly, it failed to provide accurate and repre-sentative rainfall figures immediately after the rainfall.

In third major failure, the Central Water Commission2,India’s premier technical body in water resources, whicha mandate of forecasting floods in all flood-prone areas,miserably failed to provide any forecasts or even anyriver flow information that would have warned the down-stream areas.

The irrigation and flood control department of Jammuand Kashmir’s mandate is managing state water re-sources and flood control system, but this departmentseems to have completely failed in providing any riverflow data or any warning of impending floods to eventhe state capital, leave aside the rest of the state. It alsofailed in maintaining and monitoring the embankmentsor even providing any warning when the embankmentsfailed. This means that even in the state capital, peoplehad absolutely no warning till the water entered thehouses and colonies! (Its website (http://www.jkirfc.com/) has not been updated since 2011, except the tendersection!)

Pertinently, the Government of Pakistan Commissionerof Indus Waters Mirza Asif Baig said in a media inter-

J and K Floods: How much of the disaster was man made

1 http://www.downtoearth.org.in/content/i-did-not-have-government-36-hours

2 For details, see: http://sandrp.wordpress.com/2014/09/06/why-does-central-water-commission-have-no-flood-forecasting-for-jammu-kashmir-why-this-neglect-by-central-government/

15


view3 in the context of recent floods that affected bothcountries, “As far as the transmission of flood informa-tion is concerned, they (India) have very responsibly beentransmitting it to us.” If we go by this statement, Indiadid transmit some flood related information to Pakistanand Pakistan is happy with that, but what informationIndia transmitted to Pakistan is not clear, since it is notin public domain.

India is supposed to have elaborate disaster manage-ment institutions starting from National Disaster Man-agement Authority to State Disaster Management Au-thority to Divisional (in case of J&K) and District Disas-ter Management Authority under the 2005 act. How-ever, except the National Disaster Response Force(NDRF), which in any case is manned by para militarypersonnel, we see no impact of these institutions in ei-ther current disaster or earlier ones. The local adminis-tration and disaster management apparatus seemed tobe generally absent during the disaster. This means thateven if actionable information were available with thestate and local administration in advance of the disas-ter (as happened in Uttarakhand in June 2013, wherein spite of specific forecasts from Dehradun office of IMD,state failed to use the information to take necessary ac-tion), it may not have helped manage the disaster insignificantly better manner.

The encroachment of the river-beds & flood plains andthe destruction of the once-abundant local water systemslike lakes, wetlands, marshes, flood channels accentuatedthe proportions of the disaster. J&K had such remark-able flood management structures that it seems that the11th century flood management wisdom was better thantoday’s strait-jacketed engineering mindset. Even govern-ment agencies (local, state and central) have been foundguilty of constructing buildings over such areas, whichnot only made these buildings vulnerable, but also re-duced flood absorption capacity of the area, creatinggreater disaster for other areas. The Down to Earth re-port mentioned earlier said, “The wetlands of Nadru,Nambal, Narkara Nambal and Hokarsar that absorb rain-water have been replaced by residential colonies”.

Chenab and Jhelum basins are in for major interven-tions which will make the state even more vulnerable todisasters. These interventions include about 40 hydro-power projects each in Chenab and Jhelum basins,projects of various sizes and in various stages of devel-opment, including operating, under-construction, underclearance and planned projects. Each of these projectsinvolve dams, water storage, tunnels, blasting, diver-sion of rivers, deforestation, construction of roads, colo-nies, mining of materials, etc., on large scale and dump-ing of millions of cubic meters of muck from each large

project. Chenab basin is in fact home to the largest ca-pacity under-construction hydropower projects in Indiacompared to any other basin. Each of these projects willincrease the disaster potential of the state, but we donot have credible Environmental Impact Assessment,Environmental Appraisal, Environmental ManagementPlan or credible monitoring and compliance mechanism,not to speak of cumulative impact assessment or disas-ter potential assessment. This is not to say that no suchprojects should be constructed. But the way we are go-ing about these major interventions today, we are invit-ing greater disasters. Repeated representations to theUnion Ministry of Environment and Forests (MoEF) onthese issues have fallen on deaf ears. The new govern-ment at the centre is already destroying whatever littleenvironmental governance exists. The Prime Ministerdeclared at the Madison square garden in New York onSept 29, 2014 that he has set up a committee (underformer cabinet secretary T S R Subramanian) to removeenvironmental laws!

Scientists are telling us that in each such extremeweather events, whose frequency is already on the risein the Himalayas at a pace greater than global aver-ages, there is undeniable footprint of climate change. Inaddition to the reduced drainage capacity of our land-scape due to ill-conceived decisions of building on wa-terways and also increased concentration of populationsin vulnerable locations, such events are likely to increasethe scale of disasters in future years.

Although we hear a lot about climate change issues inthis context, there is little necessary action. The leastone had expected was that the government would rec-ognize climate change links in these disasters and de-mand justice for the victims of such disasters, from thosewho are primarily responsible for climate change. Gov-ernment also needs to identify populations vulnerableto climate change disasters and change its developmentplans and policies keeping in view this reality. We seelittle progress in any of these directions currently.

Sixteen months after the Uttarakhand disaster of June2013, we still do not have a post facto report that wouldtell us what happened there, who played (or did not play)what role and what lessons to learn from that experi-ence. For example, several of us wrote to the MoEF inJuly 2013, asking it to institute an enquiry into the roleplayed by hydropower projects in increasing the propor-tions of the disaster. In the absence of any governmentaction, it was left to the Supreme Court to order such anenquiry through its order of Aug 13, 2013. Subsequentreport by Ravi Chopra Committee vindicated our con-tention and showed how the existing and under-construc-tion hydropower projects had increased the scale of the

3 http://www.dawn.com/news/1135898/sound-bytes-scrapping-the-water-treaty-is-no-solution

16


4 http://www.tribuneindia.com/2014/20141007/j&k.htm#12

disaster. The way the Union and state governments arepushing ahead with massive Lakhwar and Vyasi Hy-dropower projects on Yamuna River in Uttarakhand,without even proper environment and social impact as-sessment and public consultation process, it is clear thatcentral and state government has not learnt any les-sons from the Uttarakhand disaster.

Solutions offered for Shrinagar Dr Shakil Romshoo,head of the Earth Sciences Department at the Univer-sity of Kashmir, according to media reports4, have saidthat the only long-term solution to prevent the kind offlooding Srinagar witnessed on September 7 was con-struction of an additional flood spill channel. This wasin addition to desilting and strengthening of embank-ments of the existing flood spill channel passing throughRajbagh and Rambagh. Then Chief Minister BakshiGhulam Mohammad had got it constructed after majorfloods in 1959. During a press conference on September29, Chief Secretary Mohammad Iqbal Khandey and Com-missioner Secretary of Flood Control Department PawanKotwal said the state government hoped that the Cen-tre would approve Rs 2,200-crore project for construc-tion of a second flood spill channel (from Sangam inAnantnag district to the outer periphery of the WullarLake in Bandipora district) to handle the water dischargein the future. The project was submitted to the Centrein 2007. The project proposed bypassing the Jhelum fromSrinagar in case of emergency to prevent inundation.Rs 97 cr was released by the Centre in 2010. Officialssaid it was used for dredging the flood channel to in-

crease discharge capacity by 9000 cusecs. Later, theproject was not pursued by successive state governments.

In case of the Jammu & Kashmir floods, the apex courtis already hearing a petition. We hope the apex courtwill order an elaborate enquiry into the reasons for andmanagement of the current disaster.

Himanshu Thakkar ([email protected]) is coordina-tor of South Asia Network on Dams, Rivers & People

(An edited version of this appeared at: http://www.thehindu.com/opinion/op-ed/chronicle-of-a-trag-edy-foretold/article6420015.ece)

Kashmiri residents use makeshift rafts to rescue flood-affectedpeople in Srinagar. Photo: India Today

Flood Forecast map of CWC has no sites to forecast floods in J & K

17


Like a many-headed serpent, Yettinahole (Netravathi)Ziversion Project refuses to die. Every time one of itshead is cut, it grows a new head.

Following criticism of the Project Report (based on whichKarnataka Government had already made budget pro-visions in 2013), a new DPR of the project has been pre-pared in December 2013 by EIT RIP JV which tries toamend blatantly illegal stands taken earlier. However,after scratching the surface, it is clear that the DPR isjust as illegal and dangerous as the interim Project Re-port was.

Yettinahole, or rightly the Netravathi Diversion Projecthas always been a political project, visualized to earnpolitical mileage and brownie points. Veerappa Moilyoriginally from Dakshin Kannada, moved toChikkaballpur constituency in 2009, from when hestarted pushing the project strongly. As the EnvironmentMinister, Moily also laid the foundation stone of theproject in Chikkaballapur, just before the LoksabahaElections in March 2014 [iii]. Strategically, the stone waslaid in Chikkaballapur and not in Hassan, from wherethe water actually be diverted. No political party hasopposed the project consistently.

Even before a complete DPR, Karnataka 12-14 Budgetof the Congress Government allocated nearly 2800 croresfor this scheme. The current govt lost no time and di-rectly awarded contracts worth nearly 1000 Crores toHindustan Construction Company, in a joint venturewith GVPRL, without any clearances or any public con-sultations.

Before the laying of the foundation stone of the project,SANDRP had presented a detailed analyses if the Project

Report proving how the project is violating Environmen-tal Protection Act by evading Environmental Clearance.A number of eminent personalities from Karnataka hadjointly written to the MoEF to appraise the Project forEC. In response to this, the MoEF had written to theKarnataka Govt and Karnataka Neeravari Nigam Lim-ited (KNNL), seeking clarifications on the nature of theproject. Although this move was triggered due to thesubmission made by SANDRP and other groups, wenever saw KNNL’s response despite specifically askingfor it. We only saw MoEF’s lame justification, bailingout KNNL and Karnataka Government and turning ablind eye to the huge impacts of the project.

When Karnataka CM Siddramaiah was about to lay thefoundation stone along with Mr. Moily, SANDRP wrotean open letter to him, as the Environment Minister, ask-ing a direct question as to how can he himself formallyinitiate a scheme which is blatantly violating laws gov-erned by his own Ministry. Following this, the ceremonywas cancelled, only to be held surreptitiously later.

During all this, there was huge and unprecedented op-position to the project from Dakshin Kannada andMangalore. Farmers, students, workers, women groupsall came together, united in their opposition against aproject that would divert their Netravathi. Peoplestopped trains, organized hundreds of dharnas, boycottedvoting, organised signature drives, etc. Leaders in allhues came together in a rare show of discontent. On theday of foundation stone laying, people in DakshinKannada voluntarily observed a strict Bandh. Funnilyenough, even the beneficiary district of Chikkaballpuropposed the project as the 2.82 TMC water that it wouldbe getting after so much of fanfare was too meager, in

Yettinahole Diversion Project DPR: New Avtaar, Old Problems

Vindicating SANDRP’s contention about illegali-ties in the Yettinahole Project Report, the newlymade Detailed Project Report has made an at-tempt to superficially cover these illegalities.

However, after scratching the surface, we findthe DPR of the Project is a seriously flawed docu-ment and the colossal 13000+ Crore Rs. projectwill lead to irreparable loss of Western Ghatsand Dakshin Kannada region, without signifi-cant benefits to the supposed beneficiary region.Kolar and Chikkaballapur will not receive evenhalf of the diverted water and more than 10 vil-lages may be submerged.

Protests against Yettinahole Project in Hassan Photo: The Hindu

18


the face of the grand promises of lush fields and no wor-ries.

The Government of Karnataka did not hold a singlepublic meeting in Dakshin Kannada, trying to under-stand and address people’s apprehensions. When emi-nent personalities from Dakshin Kannada planned tohold a National Consultation on Yettinahole Diversionin NIT Suratkhal in August 2013, the meeting was can-celled at the last minute due to political pressure on theorganizers.

As things stand now, the project does not have Environ-mental Clearance, Forest Clearance, Wildlife Clearance,has not started rehabilitation and resettlement of over10 villages that it will submerge, but its work can startat any moment.

SANDRP accessed the Detailed Project Report (DPR) ofthe Project from local activists, who obtained it underRTI. Analysis of the DPR reveals a number of issues.KNNL has drastically changed the initial Project Re-port, avoiding mention of contentious issues we hadraised like hydropower generation, irrigation component,etc., thus strongly vindicating the objections raised.However, going further, it is clear that these changesare cosmetic. Deeper problems and severe unstudiedimpacts of the scheme remain.

SANDRP analyzed 4 volumes of the DPR and Annexuresof the Project. What follows is some myth busting aboutthe Yettinahole Detailed Project Report.

1. What is the Current Project? Is it differentfrom the last Project Report?

While the Project Report of June 2012 was titled: ‘Schemefor diversion of flood water from Sakleshpura (West) toKolar/ Chikkaballapura Districts (East)’, the DPR datedDecember 2013 has taken out all the random stuff onKolar and Chikkaballapura and simple calls it as“Yettinahole Project”.

Current Project as per the DPR, is divided in Two Phases.

Phase I: 8 weirs will be built in the Western Ghats, onthe streams Yettinahole, Kerihole, Kadumanehole andHongadahalla. It also includes several pump houses next

to weirs, raising mains that run for several kilometersare nearly 5 kms wide, 3 Delivery Chambers (DC) and agravity canal taking waters from Weirs 3, 4 and 5 toDoddanagara (DC 3) in the Western Ghats forests.

From the weirs, 85 cumecs (Cubic Meters per second)water will be drawn 24*7 in the six months of June-November.

This will be delivered through 4 Delivery Chambers withthe last DC: DC 4 at Haravanahalli.

Phase II: From DC 4, water will be diverted to a canalrunning 274 kilometers, cutting across the ridge linedividing Cauvery and Krishna Basins and culminatingat a Balancing Reservoir at Byragondlu and Thumbadi,in Koratgere Taluk. Thumbadi Reservoir will store about3 TMC water and will submerge nearly 700 hectares ofland and three villages while Balancing Reservoir atByragondlu will store 5.7 TMC water and will submerge7 villages and an area of about 2000 hectares. The Res-ervoir at Devaranyadurga, which was proposed in theProject Report has been replaced by these two.

It includes construction of several storage tanks andreservoirs for en route water supply. It will also deliverywater to T.G. Halli and Hesarghatta Reservoirs, whichsupply water to Bangalore. It also plans to supply waterto Devanhalli Industrial Area.

The project envisages constructing 7 additional storagereservoirs and 10 major canals. Water will also be usedto fill more than 500 Minor Irrigation (MI) Tanks in manydistricts and taluks.

It is amazing how the project envisages filling MI Tanksto 50% capacity: The DPR says that water will be pumpedand released to the highest point and an additional sluicegate will be made to all MI tanks to let water flow intothe cascading MI tank. This sounds highly impracticaland is also againt the local rainwater harvesting spiritin which many of the old tanks were made.The projectalso includes constructing over 100 bridges in villagesand nearly 100 road brides on major roads.

Despite the unprecedented protests from theentire Dakshin Kannada District and in the faceof 2014 Loksabha Elections, foundation stonewas laid on a dais in Chikkaballapur. The daiswas burgeoning under the weight of several po-litical strongmen.

This event stands out as an example of undemo-cratic behavior for an elected government.

Left: People protesting by stopping trains Photo: News Karnataka

19


So although details have changed, the basic of the projectremain the same. There is no change in Western Ghats,except for the fact that not 24 TMC, but 47 TMC waterwill be pumped now!

2. What is the cost of this current Project? Canthe cost be borne easily by KNNL orKarnataka Government?

The cost of the Project as per DPR stands at nearly 13000Crore Rs. as per 12-13 price line. This exceeds the en-tire 13-14 years’ budget of the Karnataka Water Re-sources Department, which stands at 8007 Crores andis nearly five times the annual budget of KNNL, theimplementing agency.This is a colossal amount of moneyto spend to convey approximately 7 TMC water to Kolarand Chikkaballapur and other nonspecific projects.

3. Who are the main beneficiaries? Will Kolarand Chikkaballpur really get 24 TMC wateras promised?

The supposed beneficiaries of the project are severaltowns, villages, cities and industrial areas and No, Kolarand Chikkaballapur again lose out and get only about 7TMC water.

4. Then who will be getting this water?

The DPR puts out a diffuse list of beneficiaries includ-ing Bangalore urban area through TG Halli andHesarghatta Reservoir and the Devanhalli IndustrialHub. There are no population projections or future needcalculations for this region like all other regions and atno place does the DPR say that water will go to Banga-lore. However, TG Halli and Hesaraghtaa reservoirs areboth used by the Bangalore Water Supply and Sanita-tion Board [xii]for Bangalore City and in the last Bud-get, the government had itself stated that water will beused for Bangalore Urban Area’s needs.

A review of beneficiaries:

• Bangalore gets 3 TMC water: The DPR says thatabout 3 TMC water will be released to TG Halli andHesargahtta Reservoirs and for the Devanhalli Area.

• Minor Irrigation Tanks and hence irrigationgets maximum water at 9 TMC: Nearly 9 TMCwater will be used for filling more than 500 MI tanksupto 50% of their live storage capacity. This waterwill be supposedly used for “groundwater recharge”.There are several participatory, cheap and sustain-able ways for recharging groundwater, which seemto have been rejected in favor of long distance trans-fer. In any case, this groundwater recharge will beused for agriculture, as most of the agriculture theredepends on groundwater and hence, the project quali-fies for Environmental Clearance.

• The project is being pushed for the drought affectedtaluks in Kolar Chikkaballapur and Tumkur and evena brief glance at the calculation shows that even in2023-24, the drinking water demand of these placescumulatively will be just 12 TMC! Then why are wediverting 24 TMC water, double of the ten years’ es-timate?

5. What is the basis for diverting 24.01 TMC?

The report provides no justification about why 24 TMCis supposed to be diverted. In fact, after population cal-culations and making provisions for drinking water sup-ply for the beneficiary districts and villages, the DPRsimply states : “This has resulted in a balance availabil-ity of 8.9 TMC” . This is a strange statement to make.What is meant by “balance availability”? Is there com-pulsion for diverting 24 TMC by hook or by crook fromthe Western Ghats?

6. 24 TMC Diversion? No 47 TMC Diversion!

The project envisages diverting 85 cumecs (Cubic Metresper second) water, purportedly for six months of June-November. The DPR states that pumps will function 24*7during this period. Even a simple, back-of-the-envelopecalculation indicates that 85 cumecs diversion leads tonearly 47 TMC diverted over six months and not 24 TMC,as is claimed.

7. Was there a detailed hydrological study to ar-rive at 24 TMC diversion?

The proponents have no flow data from individualstreams. The 13,000 Crores project is to be based onshoddy hydrology data.

They have used gauge data from Bantwal acrossNetrvathi, which is approximately 60-70 kilometersdownstream and in a completely different eco-regionfrom the hills. This gauge data is simply extrapolatedbased on catchment area of each stream. This is highlyunscientific.

The earlier Project Report used an entirely differentmethod for calculating this yield, based in rainfall inindividual catchments. Interesting to see that althoughto different methods were used by two different reports,divertible yield is exactly the same to the last decimalpoint of 24.01 TMC!

The fact of the matter is that there have been no scien-tific studies to find out the level of safe diversion. TheDPR makes a fantastic statement in conclusion to theeffect that:

“According to the revised computations, the divertibleyield has been assessed as 22.14.TMC. However,Prof.Rama Prasad, who has conducted the Hydrologystudies has opined that the yield of 22.14 TMC at 50%

20


dependability is very much on a conservative side and24.01 TMC of divertible yield is available across thestreams. This has been taken note off and for the presentproposal, 24.01 TMC of water has been considered asthe divertible yield from the selected streams to pro-ceed further regarding finalization of the scheme in to-tal.”

This just shows the random way in which divertible yieldhas been fixed!

8. How about the downstream Impacts of thisdiversion, which was the main reason for pro-tests in Dakshin Kannada and Mangalore?Were the impacts studied?

There has been NO assessment of downstream waterneeds or impacts of this diversion on the downstreampeople or ecosystems. The DPR just ‘assumes’ that therewill not be any impact on downstream users of ecology!

This is evidently misleading. One example of the prob-lem in such assumption is that the flow data ofHongadahalla maintained by KPCL (given in Annex)indicates that flow in streams like Hongadhalla in Au-gust near the gauging point, has not exceeded even 20cumecs. However, the according to the DPR[xiv], ar-rangement has been made to divert a whopping 30cumecs from Hongadhalla from Weir 7 during June-November. This means that in the downstream, the rivu-let will be rendered dry.

9. Was Impact Assessment for Western Ghatsconducted?

The project proponent has not even clarified as to whatwill be forest land required for diversion. The section onImpact Assessment in the EMP deals largely with thebeneficiary region without dealing with impacts onWesetrn Ghats at all. There has been no study on eflowsas per the HLWG (High Level Working Group on West-ern Ghats/ Kasturirangan Committee Report)report, nostudy of estuarine fisheries, no study of drinking waterneeds.

10. Will there be profound impacts in the down-stream region?

Yes. Yettinahole Project will “divert” water out of thebasin and unlike most other irrigation or hydropowerprojects, the water will be permanently lost from thebasin. The ecosystem and livelihoods in the downstreamare closely linked to the hydrology of the Netravathi. Infact even in June, which is supposed to be a “peak sea-son” for diversion, Mangalore and other parts of DakshinKannada have been facing water shortages. In addition,there are several estuarine and riverine fishermen de-pendent on the Netravathi for their livelihoods. Thereare many industrial areas, SEZs coming up in Mangalore

which will be needing more water. While there has beena prospective study of the population and water demandgrowth of the beneficiary region in the DPR, there hasbeen not even a mention of Mangalore and its increas-ing needs in the future in the DPR, highlighting the biasof the proponents.

There are several functioning mini hydel projects on theindividual streams as well as tributaries which dependon the assured flow from upstream. They have not evenbeen consulted before this decision was taken.

11. Will there be a severe impact on Ecology andWildlife?

The project falls within 10 kms boundary of thePushpagiri Sanctuary, one of the specific World Heri-tage Sites in the Western Ghats. The entire region hasexceptional biodiversity. The project also affects theMysore Elephant Reserve.

The region has exceptional fish biodiversity, with sev-eral new species being discovered from the region. Therehave been efforts to declare this area as a specific fishsanctuary. Despite this, the Environmental ManagementPlan of the DPR states that the fish diversity in moststreams is “Poor”. This is a very irresponsible and mis-leading statement.

Man Animal Conflicts in Sakaleshpura are on a rise.Mega infrastructural activities envisaged in YettinaholeProject will worsen the situation further. There has beenno mention of this.

12. Considering the impacts and the strong op-position from Dakshin Kannada, were anypublic consultations held?

No. there has not been a single open public consultationheld by the proponents or the Karnataka Governmentin the affected region. This indicates lack of respect for

Severe downstream impacts and drying up ofstreams due to Yettinahole project reminds oneof the tale of Sage Durvasa, meditating on thebanks of the Tunga, not very far from DakshinKannada. Durvasa loved the river and wasknown for his short temper. As Bheema dammedthe flowing River, Durvasa was agitated to seedried up river bed in the downstream.Yudhishthira saw this and advised Bheema tobreak the dam himself, to avoid the wrath ofSage Durvasa. Bheema relented and broke thedam, to allow the free flow of the river once more.(One of India’s first decommissioned dams?)

21


democratic values and transparency. Shockingly to thequestion: “ Have-public debates about utility of projectsbeen held and the response thereof outlined in the Re-port?” has been answered as “Yes” in the DPR.

In fact there has been no such report in the DPR.

The DPR also states: 1.14: “Many public meetings havebeen held by the Govt. to make the people aware of theimportance of the scheme both in the initial reaches andthe end reaches of the project.”

This is entirely false as no such meeting has been heldon Dakshin Kannada where informed discussions canbe held.

To conclude:

Yettinahole diversion or Netravathi Diversion Project isan extremely costly ( 13000 Crores +) project of theKarnataka Government. It has been based on weak hy-drology, nonexistent impact assessment of the down-stream region, no Forest Clearance, no Wildlife Clear-ance and no public consultations. It is violating Envi-ronment (Protection) Act 1986, Forest (Conservation) Act1980 and Wildlife (Protection)Act 1972. As has beenproved by SANDRP, Karnataka has violated Environ-mental Laws in the recent past[xix].

The project provides no justification for diverting 24TMC, plans to divert more volume than that, most ofwhich is meant for urban areas and irrigation, withoutoptions assessment of cheaper and more sustainableoptions.

The project has illegally awarded tenders worth Rs 1000crores without clearances.

In the interest of ecology, downstream population ofDakshin Kannada, public resources, wildlife, WorldHeritage sites and even future generations, at least un-til we have basis for informed decisions including a cred-ible EIA, SIA, Options assessment and participatorydecision making process, Projects like Yettinahole needto be shelved. Already multiple PILs against the projecthave been filed in the High Court and routed to the NGT.We hope NGT will also take a strong view on the seriousissues involved here.

Let us hope that Netravathi flows unhindered and con-tinues to support human and non-humans alike like shehas been doing for centuries. Even for the areas claimedto be benefiting from the project, there are cheaper, sus-tainable and credible options available than this megaproject.

- Parineeta Dandekar([email protected])

(We are specifically thankful to Kishore KumarHongadhalla, from Hassan for all his help.)

References:[i] http://sandrp.wordpress.com/2013/09/18/yettinahole-diver-

sion-an-imprudent-rs-100-billion-proposition/[ii] This name/acronym of this consultant does not bring any

results on the internet[iii] http://www.coastaldigest.com/index.php/news/62505-

amidst-protests-siddaramaiah-moily-lay-foundation-stone-for-yethinahole-project

[iv] http://www.hccindia.com/news.php?news_id=35[v] http://sandrp.wordpress.com/2013/09/18/yettinahole-diver-

sion-an-imprudent-rs-100-billion-proposition/http://sandrp.wordpress.com/2013/09/10/complete-appraisal-needed-for-yettinahole-diversion-project-letter-to-moef/

[vi] http://sandrp.wordpress.com/2014/01/30/open-letter-to-dr-veerappa-moily-as-he-supports-foundation-stone-laying-of-yettinahole-diversion-project/

[vii] http://www.daijiworld.com/news/news_disp.asp?n_id=216104

[viii] Mallekavu, Dogganahalli & Gaurikallu[ix] Veerasagar, Lakkamuttanahalli, Belladahalli,

Gajamenahalli, Sugadahalli, Lakkenhalli, Garadagallu[x] h t t p : / / w a t e r r e s o u r c e s . k a r. n i c . i n / d o c u m e n t s /

Budget%20allocation%202013-14x.pdf[xi] Main beneficiaries of the Project:

• Kolar district comprising of all Taluks• Chickaballapura distrct comprisnig of all Taluks• Tumkur district comprising of areas in Palar and Pennar

basins including Chiknayakanahalli and Sira Taluksalong with selected villages in Tiptur and Gubbi Taluks.

• Hassan district comprising of villages in Arasikere taluk• Karnataka Neeravari Nigam Limited Yettinahole Project• Chikamagalore district comprising of selected villages

in Kadur taluk• Ramanagara district• Bangalore Rural district comprising of Nelamangala,

Doddaballapura, Devanahalli and Hoskote Taluks• Augmenting the water to T.G.Halli reservoir• Augmenting water to Hesaraghatta reservoir• Drinking water supply to Devanahalli Industrial area

and surrounding areas• Providing water for tank filling purposes to fill selected

M I Tanks to their 50 % capacity (average) in the M Itanks falling under Palar and Pennar basins andArasikere taluk

[xii] http://bwssb.org/water_source_schemes.html[xiii] Page 218, Volume I, Detailed Project Report[xiv] Detailed Project Report, Volume I, Page 197[xv] http://mangaloretoday.com/main/Precarious-water-situa-

tion-in-DK-MP-instructs-supply-in-tankers.htmlhttp://www.samachar.com/MRPL-shuts-down-all-units-due-to-water-scarcity-meujNDiibca.htmlhttp : / /www.thehindu.com/2005/04 /08 /s tor ies /2005040815460300.htm

[xvi] http://whc.unesco.org/en/list/1342/multiple=1&unique_number=1921

[xvii] http://wgbis.ces.iisc.ernet.in/biodiversity/pubs/ces_tr/TR122/introduction.htm

[xviii] http://www.iucnredlist.org/details/summary/169618/0[xix] http://www.thestatesman.net/news/70189-Maharashtra–

Karnataka-govts-accept-violating-green-act.html

22


There is a rush of riverfront development schemes inIndia. We have heard of Sabarmati Riverfront Develop-ment being drummed many times, followed by the pro-posed rejuvenation of Ganga and Yamuna, supposedlyon the lines of Sabarmati.

Concrete wall embankments, reclamation of the river-ine floodplains and commercialisation of the reclaimedland are innate components of these projects. Activitiespromoted on riverfronts typically include promenades,boat trips, shopping, petty shops, restaurants, themeparks, walk ways and even parking lots inside en-croached river beds!

This kind of riverfront development essentially changesthe ecological and social scape of the river transformingit into an urban commercial space.

The Sabarmati Riverfront Development inAhmedabad city, supposed to be designed on the lines ofthe Thames in London or Seine in Paris, was projectedas a pioneering project in riverfront development.

The project was proposed by Environmental PlanningCollaborative, an Ahmedabad-based urban planningconsultancy firm in 1997. The riverfront on either sideof the Sabarmati for 10.4 kms was proposed to be devel-oped, reclaiming about 185 ha of land by constructingembankments and roads, laying water supply lines andtrunk sewers, building pumping stations, and develop-ing gardens and promenades. Construction of the projectstarted in 2005.

The mainstay of the project was the sale of riverfrontproperty. 21 per cent of the 185 ha of reclaimed landwhich was developed by concretising the river bank wassold to private developers for commercial purpose. Ac-tivities hosted on this reclaimed land were recreationaland commercial activities in restaurants, shops, water-

front settlements, gardens, walkways, amusementparks, golf course, water sports etc. Some part of it wasutilised for public purpose, such as roads.

The sale of reclaimed land created by the project is ex-pected to cover the full cost of the project. The projectwas implemented through a Special Purpose Vehiclecalled the Sabarmati Riverfront Development Corpora-tion Ltd. The project cost was estimated to be in therange of Rs 11,520 million. Around two thirds of thisamount has already been spent.

Even though the project has been modeled as one of “bestpractice” by several financing institutions, it has alsodrawn severe criticism for poor rehabilitation of the dis-placed disrupting the nexus of shelter, livelihood andservices of urban poor, lack of transparency in the ex-ecution and for tampering with the carrying capacity ofthe river.

No Environment Impact Assessment of the project hasbeen conducted nor any credible public consultation pro-cess held.

Sabarmati channel has been uniformly narrowed to 275metres during the riverfront development project fromits natural width of about 350 metres, minimum widthbeing 330 metres. In this attempt of “pinching the river”,the original character of the river has changed com-pletely from a seasonally flowing river to an impoundedtank.

The water impounded in this stretch is not evenSabarmati’s water, but rather the waters of theNarmada, on which the city of Ahmedabad or Sabarmatihas no right. This water was justified and meant for thedrought prone areas of Kutch, Saurashtra and NorthGujarat.

Riverfront Development in India: Cosmetic make up on deeper wounds

A cursory glance at the existing river restora-tion/ improvement/beautification schemes indi-cates that the ‘rejuvenation’ discourse in thecountry revolves mainly around recreational andcommercial activities. It is more about real es-tate than river.

What does riverfront development entail? Is itriver restoration? Are the millions of rupeesspent on riverfront development schemes justi-fied? Will it help in saving our damaged rivers?These questions need to be explored before ac-cepting the current model of riverfront develop-ment as either replicable or laudable.

Untreated sewage and industrial effluent are discharged intoSabarmati River near Vasna Barrage downstream of

Riverfront project. Photo: Author

23


Narmada Canal waters being released into Sabarmatiupstream of Ahmedabad and the Riverfront

Development Project Photo: Author

In the entire process, there has been no cleaning of theriver either. The project has only transferred the pol-luted water, carrying untreated sewage and toxic efflu-ents from Ahmedabad city and district industries to theriver downstream from Vasna barrage.

The reclaimed land and the narrowing of the channelhave adversely affected the carrying capacity of the river.The project was stalled during August 2006 to March2007 due to heavy floods. Prior to the floods, the river’smaximum carrying capacity had been calculated at 4.75lakh cusecs on the basis of rainfall over the last 100 years.The floods however proved the calculation wrong.

The National Institute of Hydrology and the Indian In-stitute of Technology Roorkee re-evaluated the projectdesign. Their report said “the calculations did not takeinto account any simultaneous rainfall over the entirecatchment area”. The report also states that riverfrontdevelopment is “not a flood control scheme”, and thatthe municipal corporation will have to work out othermeasures to meet the impending challenge of floods.

The project has also been heavily criticised for the poorrehabilitation of the evicted slum population. A PublicInterest Litigation was filed in the Gujarat High Courtby the Sabarmati Nagarik Adhikar Manch, supportedby several other non-governmental organisations to en-sure justice and bring transparency to the process. Ac-cording to the High Court orders, at least 11,000 affectedfamilies were to be rehabilitated and resettled by theAhmedabad Municipal Corporation. Over 3,000 peoplehave been moved to a marshland in the outskirts of thecity with negligible compensation, little and infrequentaccess to drinking water and minimal sanitation facili-ties.

The Yamuna: Can one imperfect project inspire another?

Many rivers like the Yamuna, Ganga, Mithi,Brahmaputra etc. are now proposed to be ‘developed’ onthe lines of the Sabarmati by different government agen-cies.

Recently, the newly-elected BJP-led Central Governmentsent a team of bureaucrats to Gujarat to study the feasi-bility of replicating the Sabarmati Riverfront Develop-ment Project for cleaning the Yamuna. Despite the con-cerns about the flooding of the Yamuna, the team is ex-ploring ways of replicating the Sabarmati Model.

Reclaiming the floodplains to create a concrete riverfront,as in Ahmedabad, could be ecologically unsound and evendangerous for Delhi which is already vulnerable to floods.In fact the Inter-governmental Panel on Climate Changeput Delhi amongst the three cities at highest risk offloods, globally. The sediment load in Yamuna is veryhigh and the non-channelised river rises by over fourmeters during peak monsoon flooding. Risk of floodingwill increase several fold for a channelised river.

An expert committee appointed by the Ministry of Envi-ronment and Forests to examine the Yamuna River FrontDevelopment Scheme of the Delhi Development Author-ity recommended scrapping of the ambitious plan fordeveloping recreational facilities, parking lots and prom-enades. The committee was formed following an orderfrom the National Green Tribunal, drawn in response toa petition filed by activists and Yamuna Jiye Abhiyaanconvener Manoj Misra. The committee pointed out thatrecreational spots located in active floodplain areaswould kill the river and would reduce its flood-carryingcapacity, increasing flooding and pollution.

The city of Noida however has decided to go aheadwith the Rs 200-crore Yamuna Riverfront DevelopmentProject that Greater Noida Authority has planned. Theproject involves developing recreational facilities likeparks, yoga centres, picnic spots and sports centres, pologrounds, golf course etc. on Hindon and Yamuna flood-plains. Here again, the project has nothing to do withsustaining, cleaning, rejuvenation of the river.

Spare the Ganga!

The National Ganga River Basin Authority was shiftedfrom the environment ministry to the water resourcesministry recently. The new name for the Ministry ofWater Resources is Ministry of Water Resources, RiverDevelopment and Ganga Rejuvenation. Prime MinisterNarendra Modi assigned the specially-created ministryfor cleaning the Ganga to Uma Bharati, who was quotedin print media as saying, “If Sabarmati can be cleaned,all other rivers can also be made better.” But what UmaBharati seems to have missed is that the Sabarmati hasNOT been cleaned, it has merely transferred the pol-

24


luted water downstream of the 10.4 km stretch. So, canthe Sabarmati model be replicated at Ganga? And evenif it is replicated, will it help the cause or the river orriver rejuvenation?

A number of apprehensions have been raised in this re-gard. “The so-called Sabarmati model won’t work for theGanga. The Sabarmati has neither been cleaned norrejuvenated,” Himanshu Thakkar, SANDRP toldOpenindia News. He further points out that theSabarmati Model survives on water from the Narmadacanal in Ahmedabad city, which would not be possible inthe case of Ganga. Any “cosmetic treatments” will notwork for Ganga, just as they have not worked forSabarmati.

More about real estate than rivers

While there are experts opposing replication ofSabarmati Riverfront Project on Ganga and YamunaRiver, there are several other riverfront projects whichare inspired by the Sabarmati Project and which arebeing pushed without any kind of studies or impact as-sessment.

The Brahmaputra Riverfront De-velopment Project is an example.While on one hand Guwahati is strug-gling to cope with the flood prone na-ture of the Brahmaputra River, theAssam government plans to imple-ment ‘Brahmaputra Riverfront Devel-opment Project’ through theGuwahati Metropolitan DevelopmentAuthority (GMDA). The foundation ofthe project was laid by the Chief Min-ister Tarun Gogoi in February 2013.

The project plans to achieve maxi-mum possible reclamation. Theproject plan talks of revitalisation ofthe river ecology and strengtheningof riverbanks through soil bio-engi-neering on one hand, and on the otherinducts several urban features on itsagenda such as a promenade, ghats,

plazas and parks, conference facilities, parking lots, in-frastructure for floating restaurants, and many others.

Will such scale of real estate development leave any roomfor the river or its revitalisation?

Again, the Technical Bid Document released by theLucknow Development Authority for the GomtiRiverfront Development Project in Lucknow has nocomponent of water treatment or river restoration, evenas it projects a landscape-based development project,which will also look at “reclaiming” the river banks foractivities like shops, entertainment area, promenades,etc. Neither is there any mention of maintaining ad-equate flow in Gomti, treating its sewage, conservingits floodplains, or any other ecological angles.

The Pune Municipal Corporation, already noted forchronically polluting the Mula and Mutha rivers flow-ing through the heart of the city, has sanctioned thePune Riverfront Project, under the aegis of theJawaharlal Nehru National Urban Renewal Mission(JNNURM). The project envisages channelising the river,introducing barrages to maintain water levels, introduc-ing navigation, development of the riparian zone as en-tertainment and shopping areas, parking lots and so on.

This “improvement” project has not taken into consid-eration the once-in-a-hundred-years-flood in Pune, evenas it plans to constrict the river further, thus encroach-ing upon the riverbed. Creation of stagnant pools throughbarrages will result in backwater effect on the manynallahs that join the river. These Nallahs routinely floodthe adjoining areas during the rainy season and addi-tional backwater in these nallahs will worsen the situa-tion further. The project also does not say a word abouttreating water quality, but envisages building drainage

The priority for river rejuvenation is restoringits water quality, freshwater flow and notriverbank beautification. More than Rs. 20,000crore have been spent on cleaning the Ganga inthe past 28 years under the Ganga Action Plan.Even so, the water quality in the Ganga hasdeclined to the extent that it is now unfit evenfor irrigation or bathing.

Riparian vegetation on the banks of Godavari being destroyed for concretization ofbanks in flood prone zone Photo: Author

25


lines inside the riverbed and carrying the sewage out ofPune city limits. This hardly qualifies as river rejuve-nation or restoration. A case has been filed against thisproject in the National Green Tribunal.

In the Goda Park (Godavari Riverfront Project) inNashik, Maharashtra, the Nashik Municipal Corpora-tion (NMC) has been hankering after beautification ofGodavari’s banks through laser shows, musical foun-tains, rope-way, multi-purpose meeting hall, garden,water sports, canteens etc., ignoring the pressing issuesof water quality. The project has been handed over tothe Reliance Foundation by NMC without any publicconsultation or discussions.

After the catastrophic floods of 26 July 2005, when theMithi river flooded some of the most densely populatedareas claiming nearly 1000 lives, the Municipal Corpo-ration of Greater Mumbai (MCGM) and Mumbai Metro-politan Region Development Authority (MMRDA) havemade a plan to “restore” the river. The Mithi RiverfrontDevelopment involves desilting, beautification andbuilding of a retaining wall. MMRDA has planned tobeautify the stretch of 1.5 km (10 Ha) which lies rightamidst mangroves by developing a promenade on a PPP(Public Private Partnership) basis. Interestingly, theMukesh Ambani-led Reliance Foundation and StandardChartered bank have been selected for this project. Thisproject also falls in the Coastal Regulation Zones (CRZ)II and III. The CRZ authority in its 82nd meeting re-fused to allow any reclamation or construction activi-ties in this stretch and has asked MMRDA to take priorpermission of High Court if the proposal involves de-struction of mangroves.

The real impact of urbanising rivers

All riverfront projects discussed above are essentiallybank beautification and real estate development projectshaving little to do with restoration of the river. There isneither social or environmental impact assessment, norregulation or democratic and participatory decisionmaking process in the riverfront projects.

Such projects aim at commodifying rivers to developurban scapes; they ignore the ecological as well as socialsetting of Indian rivers and the fact that challenges hereare significantly different from the foreign models thatwe are aspiring to emulate. A blind replication will re-sult in further degradation of the rivers and wastage ofpublic funds, benefitting real estate players and a sec-tion of the urban middle class alone.

At the same time, none of the models seem to borrowthe increasingly eco-centric view of river restoration inthe west wherein rivers are given more room to flow,and river restoration is akin to riparian restoration andde-channelisation. River pollution governance is exem-plary there, storm water is retained and rechargedthrough innovative measures like storm water parks orgreen sponge areas and urban communities constitutean important stakeholder in the process.

It is time to recognise that our rivers too need genuinerejuvenation rather than ‘riverfront’ development. Try-ing to impose cosmetic layers on deeper wounds wroughtby drying up, encroachment, pollution and real estatedevelopment will achieve nothing.

- Amruta Pradhan ([email protected])

(An edited version of this article has appeared inIndia Together and SANDRP blog)

Godavari River with its bank vegetation intact. This will be destroyed for the riverfront project Photo: Author

26


Varanasi is newsworthy these days, situated symboli-cally and politically in the new Prime Minister’s agenda.In his victory speech, the PM-elect Narendra Modi vowedto clean the sacred river Ganga. After assuming the of-fice of Prime Minister, he reiterated the vow and pledgedrenewed efforts for Ganga cleanup.

Three months later, a skeptical Supreme Court reviewedthe new government’s Ganga Plan and remarked thatwith this approach the river will not be cleaned in 200years. The Supreme Court asked for the full details ofthe cleanup plan, and inserted its role as a monitor overcentral government plans. The government has report-edly submitted a new plan to the court, but no detailsare available yet in the public domain. However, frommedia reports, it seems the plan is not very differentfrom what has been done in the name of the Ganga Ac-tion Plan so far.

As residents and sympathetic outsiders know, the waste-water problem in this sacred, ancient city is seeminglyintractable. In order to implement lasting solutions tothe recurring river pollution scenario, we need to inves-tigate the current situation. I just completed a field tripto this special city that many call Banaras. I visited allthe existing and planned components of the wastewatercollection, treatment, and disposal system. In this ar-ticle I will try to create a visual map of the wastewaterinfrastructure and management problems and define thecurrent lines of command and control within the vastand overlapping water, environment, and public healthbureaucracies. This should help to identify systemicproblems in each that need to be addressed when chart-ing a new direction.

The seemingly intractable problems of Ganga clean up (re-juvenation will need so much more than just a clean up) inBanaras can be divided into three categories. First, thereare governance problems that are related to how decisionson technologies, scale, operators and siting are made. Theseinclude problems with the solicitation, selection, and imple-mentation of projects, especially the design and construc-tion and operation and maintenance of sewers, sewagepumping stations and sewage treatment plants. Second,there are serious infrastructure problems that are part ofthe complexity of this ancient city.

Third, there is a real electrical power supply problem.Securing continuous electrical power for sewage pump-

ing stations and wastewater treatment facilities is a lowpriority, and emergency standby generators are not usedwhen the grid-provided power is unavailable. As a re-sult, the intermittent operation of sewage pumping sta-tions and sewage treatment plants is ineffective in pro-tecting water quality in Ganga and in provisioning safedrinking water and sanitation in Varanasi.

When the sewerage infrastructure is operated intermit-tently, the treatment technology cannot treat the waste-water adequately, and the concentration of contaminantsand water quality indicators such as total suspendedsewage solids (TSS) and biological oxygen demand(BOD), heavy metals, toxic organic compounds, and theMost Probable Number (MPN/100ml) of fecal coliformbacteria—indicating the presence of enteric waterbornedisease pathogens in the treated effluent—remain high.So in a way providing partial power to a sewage treat-ment plant does not do the work and is therefore a largelyinoperable, non-functional, sunk cost.

Governance

The Government of India established the Ganga ActionPlan in 1986 to lead the way in river pollution controlprograms. In 2009, the Government declared the Gangaa national river and established the National GangaRiver Basin Authority. The National Mission CleanGanga (NMCG)—the implementing agency under thisAuthority—is now housed in the Ministry of Water Re-sources, River Development and Ganga Rejuvenationunder the Government of India. The Mission Director isthe chief executive of the NMCG.

At the state level in Uttar Pradesh, there is a state ProjectManagement Group (PMG) chaired by the Chief Minis-ter. It includes members from the State Ministries ofEnvironment and Irrigation, the Uttar Pradesh PollutionControl Board and the state water commissions. The StatePMG decides whom to select for work, and in most casesuses the Uttar Pradesh Jal Nigam (the state level sew-age engineers) to execute wastewater project work.

The State PMG can outsource consultancy work and al-locate projects to NGOs as well; although in all cases, ithas allocated the wastewater engineering work to theUttar Pradesh Jal Nigam. These layers of committeemembership create a vast water bureaucracy at the statelevel in addition to the committee memberships and of-

Varanasi’s Ganga Wastewater Management:Why has it remained such an Intractable Problem?1

Dr Kelly D. Alley ([email protected]), Auburn University, USA

1 A blog with more pictures can be found at: http://sandrp.wordpress.com/2014/09/25/varanasis-ganga-wastewater-management-why-has-it-remained-such-an-intractable-problem/

27


ficers at the Central level. They are not independentregulators, monitors and compliance officers (which areneeded) but contributors and benefactors of political andprofitable decisions in the ongoing issuing of contracts,clearances and other approvals.

This is a big problem because any contract for seweragework must pass through all these departments andboards, with money wasted on bids and approvals forspecific projects. In addition there is no other implement-ing agency in Varanasi so if the UP Jal Nigam’s work isshoddy or even fraudulent, then the Ganga River andthe whole city suffers without an alternative. This situ-ation is well known to Banaras residents who will com-plain daily that funds meant to improve the seweragesystem are simply eaten up by various agencies whilewastewater is diverted into the sacred river withouttreatment.

In addition, the foreign donor agency, the Japan Inter-national Cooperation Agency or JICA, has been presentin Varanasi for many years to advise and assist withcapacity building and technological cooperation for theGanga Action Plan. Apart from controlling the flow offunds, however, it appears that JICA has worked withinthe current lines of command and control, thereby help-ing to perpetuate rather than reform the system.

Infrastructure

So what is the current situation with the main waste-water drains? The main drains for the city are the Nagwadrain, located in the south and upstream of the maincity, and Khirki nallah, located in the north downstreamof the main bathing ghats. The Ganga flows northwardat Banaras (see map). The Varuna River enters fromthe west and circles the outer part of the older sacredcity complex before draining into theGanga at the downstream or northernend. In the last year the Varuna Riverhas turned into a wastewater pond up-stream of the barrage recently built un-der the Puranapul Bridge that crossesthe Varuna River. The Varuna riverbanks downstream of that barrage havealso become the dumping grounds for allforms of solid waste and the entire land-scape is hellish. One wonders how thecommunities in the vicinity can survive.

The existing wastewater managementfacilities include three sewage treatmentplants, five sewage pumping stationsalong the ghats, and one main sewagepumping station at Konia. The Koniapumps are supposed to pump up to 80million liters of sewage per day to theDinapur treatment plant located in the

trans-Varuna neighborhood of Dinapur village, if theywork at full capacity. However they rarely do.

For instance, only one screw pump was working on theday of my visit, so that means it was running at 1/3 itscapacity. This would also mean that the Dinapur treat-ment plant was receiving only 1/3 of the wastewater itis capable of treating, according to its nominal treatmentcapacity, and therefore it was running at 1/3 capacity.However to be exact one would have to know how manyhours the one pump operates each day of the week andthen the capacity factor can be calculated. For instance,if the pumping station runs at 1/3 capacity for only 6 ofthe 24 hours each day then the capacity factor would be1/12 or about 8%.

If capacity factors of the pumping stations and treat-ment plants are taken into account in a Life Cycle Costassessment then the cost per unit volume (ML) of treatedsewage would sky rocket. The UP Jal Nigam does notkeep a daily operational log with data like energy usagedata, and thus there are no metrics, no measures, andno good management practices. This adds up to a lack ofproper governance. Many monitoring committees havemade visits to site facilities but have failed to correctthe daily malfunctioning of the entire system. On mytrip to videotape the Khirki wastewater drain in lateJune, I said to the boatman taking me, “So they releasethis water into Ganga ji at night and in early morning,right? Like chup ke?” He replied, “No Madam not chupke. It is right there running wastewater all the time.Everyone can see it, and they are not even bothering tohide it!”

Below are current pictures of parts of the system thathave been damaged, destroyed or poorly maintained. Themap can be used to place these pictures in the city space.

Map of main infrastructure facilities in Varanasi

28


Khirki Nallah, just upstream from the confluence of the Varuna &Ganga rivers and downstream from the sacred city.

A drain in the trans Varuna region.

Solid waste dumpsites just downstream of the Puranapul bridge.

Another shot of Konia sewage pumping stationwith only one screw pump working

Low efficiency splasher aerators in the aeration basin

29


Power

We have to think about wastewater problems in the con-text of public health, environmental health, electricalpower supply and national and state priorities for powerdistribution. In the current scenario using existing tech-nologies and scales (there are better options for technol-ogy and scale), a significant amount of energy is requiredto pump and treat wastewater using sewage pumpingstations and the activated sludge treatment process. InIndia energy supplies are allocated to industrial andurban needs long before they are distributed to sewagetreatment plants. Looking at the current energy scenarioin India it is not hard to see that wastewater pumpingand treatment require continuous power and are notsustainable in the context of the current power deficit.Biological secondary treatment using the ActivatedSludge Process (ASP) uses a significant amount of elec-tricity to operate aeration equipment and mixers. An-other technology used in Kanpur, the Upflow AnaerobicSludge Blanket (UASB), is also a capital and energy in-tensive process. With other demands high on the agenda,it is unlikely that precious power will be available to

run all the existing and proposed sewage pumping sta-tions and sewage treatment plants on a daily basis nowand into the future if the existing technologies and scalescontinue to be used.

Take Away Points

If wastewater infrastructure is built, it is done with largegovernment investments of public funds, sometimes withcapital from international banks; there is little privateequity to drive the process. Instead the costs of building(and also poorly building) these facilities are absorbedacross a range of human services including public health,education, housing and infrastructure. The costs of op-erating and maintaining sewage pumping stations andtreatment plants are also high and operation and main-tenance of the facilities become a low priority after con-struction.

For instance, the sewage treatment plant laboratoriesare ill-equipped and this means that the UP Jal Nigamoperators are unable to monitor, measure, and reportoperational and water quality data. Due to the absenceof laboratory equipment, instruments and analytical

Treated wastewater—it looks “clean” but the fecal coliformcontent is usually in the range of 100,000 MPN/100ml to1,000,000 MPN/100ml. This is well above safe levels for

bathing and human consumption.

Konia sewage pumping station. Only one screw pump isworking.

30


capacity, they are not able to optimize the treatmentprocess. Generally the functional components of the sew-erage infrastructure - the sewage pumping stations andtreatment plants - are overwhelmed by the dysfunctionalcomponents and by the enormous pollution load. In thisway the functioning units in the system become impor-tant, not for effectively treating the waste but for pro-jecting a façade of functional infrastructure, especiallywhen site visits by monitoring agencies are underway.Yet the norm is that facilities are operated only periodi-cally and usually below capacity, and the result is thatuntreated wastewater is passed through open drains toagricultural fields or rivers. During rains and the mon-soon, wastewater combined with storm water flows di-rectly into the Assi, Varuna, and Ganga Rivers.

This sacred city requires a competent participatory au-thority to master plan, design, se-lect the right scales and technol-ogy, construct, operate and effec-tively maintain a comprehensivewastewater collection, treatmentand reuse system. Its governancerequires clearly defined norms oftransparency, accountability andparticipation.

A competent authority should con-nect central, state and municipallevels and be accountable to theresidents of the city not justthrough the municipal corporationand its elected officials, but alsodirectly through norms of partici-patory governance. These gover-nance reforms should includeclearly defined norms of transpar-ency, accountability and participa-tion that pertain to the entire sys-tem and to each component part—the pumping stations, sewage andwater treatment plants, sewersand associated facilities. A piece-meal approach with the Jal Nigamexclusively at the helm has notworked thus far and it has sunkcrores of rupees into poorly oper-ated and maintained infrastruc-ture, even in the face of nationaland global attention and numer-ous judicial interventions to thecause of Ganga cleanup. A carefulconstitution of accountable engi-neering agencies, a welcoming ap-proach in planning and implemen-tation to citizen contributions, anda vigilant monitoring of operations

and maintenance practices by concerned citizen groupscan go a long way to reforming the system. There is nodoubt that this cause runs deep in the hearts of everyBanaras resident.

Additional Information:

1) Video of the run off coming through the RajendraPrasad ghat pumping station after a heavy rain inJune 2014: https://www.youtube.com/watch?v=ujBB2FLYkZM

2) Video of Khirki Nallah in June 2014: https://www.youtube.com/watch?v=S0KUXEw7DRg

3) Video of Nagwa Nallah in June 2014:https://www.youtube.com/watch?v=7xraLNjdPg4&feature=youtu.be

Nagwa wastewater drain, near the confluence of the Assi and Ganga and upstream of Assighat and the raw (drinking) water intake point for the city. The non-functioning Nagwapumping station is in the background.

31


Tunneling for hydropower project using the blasting tech-nique can have massive impacts. It has a series of directand indirect impacts which have already been docu-mented. Among the most serious impacts is drying up ofthe natural drinking water springs and the reduction in

sub-soil moisture. This directly impacts the drinkingwater availability for the local villagers as well as agri-culture and horticultural produc-tivity, which is critically depen-dent upon the presence of sub-soilmoisture. Blasting for tunnels andother underground components ofhydroelectricity projects createsvibrations that have resulted incracks in houses situated nearthese components.

Importance of impacts of tunnel-ing and blasting becomes veryimportant since all run of the river(ROR) projects involve tunnelingand blasting. Proponents claimthat ROR hydropower projects areenvironment friendly, but mostpeople do not know that the tun-neling and blasting adds an addi-tional dimension to the impactsdue to ROR hydropower projectsand these can be very serious.

Most environmental and social impact assessments orcumulative impact assessments do not even assess theseimpacts. Many times the proponent get away claimingthat the impacts are not due to the projects, when inreality all evidence shows that these are very much

caused by the tunneling and blast-ing being done as part of the con-struction of these projects.

This photo essay documents theimpacts of tunneling and blastingfor hydropower projects mainly inChamba and Kinnaur district ofHimachal Pradesh. In Chamba,the impacts of Chamera III,Chanju, Ginni, A.T. hydropowerprojects and in Kinnaur districtKarcham Wangtoo and NathpaJhakri Hydropower projects werestudied. It is noteworthy that im-pacts are not only limited to largehydropower projects, but also towhat is defined as small hydro-power projects (projects below 25MW installed capacity). Thisshould also help puncture the mis-conceived notion that small hydro-power projects are environmentalbenign and they do not need envi-ronmental and social impact as-

sessment, public consultations, appraisal, monitoring orcompliance.

A Photo Essay on the impacts of blasting & tunneling for hydropowerprojects in Chamba & Kinnaur districts in Himachal Pradesh

In April 2012 there was a massive leakage in the 16 km long HRT of the 231 MW, Chamera IIIproject just above the Mokhar village in Chamba district leading to severe threat to the villagedownhill so much so that the 40 families residing there had to be evacuated. This picture is ofthe Adit 6 of the tunnel. The leakage occurred during testing of the generating units.

landslide near powerhouse of the Nathpa Jhakri project in Jhakri, 2014

32


Edited by Himanshu Thakkar at 86-D, AD Block, Shalimar Bagh, Delhi - 88.Printed at Sun Shine Process, B -103/5, Naraina Indl. Area Phase - I, New Delhi - 110 028

NOTE: Please note that we are continuing the publication of DRP as a non RNI publication, so this is forprivate circulation only. DRP is not for sale. Those who have subscribed will continue to get printed copies tilltheir subscription lasts. For any support towards continuing publication of DRP, please write to:[email protected].

This photo essay is indicative of thekind of impacts tunneling and blast-ing can have in the process of build-ing hydropower projects in theHimalayas. What it indicates if rel-evant not only for HimachalPradesh, but entire Himalayas andall projects that involve such tunnel-ing and blasting. We hope this photoessay opens the eyes of state govern-ments, Union Ministry of Environ-ment, Forests & Climate Change,Union Ministry of Power, UnionMinistry of Water Resources, Cen-tral Electricity Authority, state en-vironment departments, hydro-power developers, EIA consultants,chairman and members of ExpertAppraisal Committee on River Val-ley Projects, media, judiciary, civilsociety and all others concerned.

Landslide just above the tunnel of Karcham Wangtoo project at Rangle.This was activated during the 2013 monsoons

Sumit Mahar([email protected]),Him Dhara Environment

Research andAction Collective,

Himachal Pradesh

See Blogs at:Part 1: Impacts in Chambadistrict: http://sandrp.wordpress.com/2014/10/01/photo-essay-on-the-impacts-of-blasting-and-tunneling-for-hydropower-projects-in-chamba-district-in-himachal-pradesh-1/Part 2: Impacts in Kinnaurdistrict: http://sandrp.wordpress.com/2014/10/02/photo-essay-on-the-impacts-of-blasting-and-tunneling-for-hydropower-projects-in-kinnaur-district-in-himachal-pradesh-2/

Landslide in Nigulseri village. Locals claim that the tunnel of 1500 MW Nathpa JhakriProject had already disturbed the area which was further disturbed because of the

transmission tower construction for Baspa II and Karchham Wangtoo HEPs

Documents

Manipulating Environment & Forest Clearances for Dibang ... · cultural museum at Roing and ITI at Anini etc. Besides this for downstream people, the main concern was pro-tection