26th October 2015
To
The EAC
River Valley Projects
Ministry of Environment and Forests
New Delhi
India
Subject: Objections regarding three HEPs: 210 MW Purthi Hydro Electric Project, Purthi,TehsilPangi , Distt.-Chamba and 104 MW Lara Sumta HEP and 130 MW Sumte Kothang HEP in District Kinnaur Himachal Pradesh in Satluj basin for ToR
Dear Sir,
With regard to the consideration of three projects for Terms of reference from Himachal Pradesh 210 MW Purthi Hydro Electric Project, Purthi Chamba in Chenab Basin and 104 MW Lara Sumta HEP and 130 MW Sumte Kothang HEP in District Kinnaur Himachal Pradesh in Satluj basin. In this light we would like to highlight the following issues:
The CEIA (Cumulative Environment Impact Assessment) process for Satluj basin is in process and yet to be completed. The ICFRE who conducted CEIA with other organizations has submitted a draft report to the Directorate of Energy. The DOE, the nodal agency for CEIA, has conducted various public hearings in Satluj basin and asked for comments from individuals and organization for the final report. The ICFRE has to submit its final report with all the comments and suggestions it has received on the draft report.
In the summary of draft report there are some important recommendations which will have far reaching impacts on location, capacity and on the fate of projects that have been planned by the state in Satluj basin. Following are some of the recommendations from Executive summary draft report (Annexure-1- Cumulative Environmental Impact Assessment (CEIA) Studies of Hydro Electric Projects of Sutlej River Basin in Himachal Pradesh for Directorate of Energy, Government of Himachal Pradesh, Shimla, India) which are likely to have impact on the final decisions regarding the individual projects on the Satluj River Basin:
NO-GO RIVERS (Recommendation- 9. on page 50 of 57 of CEIA Executive Summary)
In many countries, river fragmentations by hydropower development have contributed to the approach of leaving few rivers /tributaries in their natural state within the basin. WWF emphasis, that the governments should designate some of the remaining unregulated rivers in areas of high conservation value as “no-go” areas for hydropower schemes.
Accordingly, in the study area while optimizing: River Spiti and upper Kinnaur that falls in trans Himalaya; few stretches that influence with the protected area in the middle Sutlej basin and lower Sutlej basin where the fish has good habitation should be considered to declare as no-go area for hydropower project development and undertake conservation measures.
As two of the projects are in upper Kinnaur that falls in ecologically and fragile trans Himalaya which is a cold desert area. The Purthi project is also in Pangi which is in the upper reaches of the Chenab River Basin where the process of the preparation CEIA is underway.
2. DIVERTED AND SUBMERGED LENGTH (Recommendation-2: 8.15 on page 47 of 57 of CEIA Executive Summary)
The criterion that is to be considered while deciding the minimum distance between two projects is whether the river would be able to recover to its normal status before encountering with another HP. The criterion such as water quality, biotic life in the river, depth and velocity shall be considered for determining the distance between two consecutive HPs.
General recommendation may be adopted for HP projects located above 2000 m MSL, a distance of 500 m, between 2000 – 1000 m MSL, a distance of 1.0 km, between 1000 – 500 m MSL, 2.0 km and for below 500 m MLS, a distance of over 3.0 km.
If this recommendation is adopted it will impact the project location and site.
3. ENVIRONMENT FLOW (Recommendation-3: 5.4 Page 27 of 57 and 46 & 47of 57)
In the executive summary report certain Environment Flow Rate (EFR) has been suggested, two options of EFR for fish zone and for rest projects three options.
For Fish Zone EFR – I means discharge required to maintain hydraulic depth of 15 cm and velocity for fish during lean months (Dec – Feb), 30% cumulative discharge during the month of monsoon (June – Sept), higher of 20% of inflow or discharge required as for non monsoon and non lean months (March – May and Oct – Nov).
For Fish Zone EFR – II means discharge required to maintain hydraulic depth of 20 cm and velocity for fish during lean months (Dec – Feb), 30% cumulative discharge during the month of monsoon (June – Sept), higher of 20% of inflow or discharge required as for non monsoon and non lean months (March – May and Oct – Nov).
For No Fish Zone EFR – I means discharge during lean months (Dec – Feb) 20% of average inflow of lean months, 30% cumulative discharge during the month of monsoon (June – Sept), 20% of inflow for non monsoon and non lean months (March – May and Oct – Nov).
For No Fish Zone EFR – II means discharge during lean months (Dec – Feb) 30% of average inflow of lean months, 30% cumulative discharge during the month of monsoon (June – Sept), 20% of inflow for non monsoon and non lean months (March – May and Oct – Nov).
For No Fish Zone EFR – III means discharge during lean months (Dec – Feb) 10% of mean annual flow, 30% cumulative discharge during the month of monsoon (June – Sept), 10% of mean annual flow for non monsoon and non lean months (March – May and Oct – Nov).
The environmental flow reported is based only on water available for the aquatic life considering depth and velocity. The various water users should be considered while preparing individual EIA/EMP reports based on the site-specific requirement such as domestic, irrigation, wild life, forest and agriculture crops and the hydropower schemes.
These recommendations, if analysed critically and taken on board, are likely to require changes in the capacity of the upcoming and existing projects in a major way. In the light of these recommendations in the CEIA report there is a high level of uncertainty vis a vis the feasibility of the planned projects. We appeal to the EAC to keep in mind that it makes no sense to consider or recommend individual projects for both the Satluj and Chenab River Basins because the entire CEIA process’s validity will be made questionable.
Please also consider that a CEIA, approved in democratic manner is a prerequisite, as per MoEF order of May 28, 2013. Secondly, on E Flows, the MoEF-MOWR (https://sandrp.wordpress.com/ ) committee also needs to be looked into, and Secy, MoWR has asked CWC recently not to approve any dams till the report of this sub committee is ready.
It is very critical for the EAC to bear in mind that in recent years several environmental issues have come to light vis a vis Hydropower projects in the Himalayan region. There is now substantial documentation of the alterations in the landscape, slope destabilisation, disturbance of environmental flows and hydrological regimes, deforestation that is being caused across the region due to these projects. A clear evidence of this is the local opposition to these projects both in Kinnaur and its upper reaches as well as in the Chenab River Basin.
Please see the following article
http://indianexpress.com/ article/india/india-others/ govt-apathy-fanning-protests- against-hydro-projects- himachal-experts-panel/
which reports on the views of the Panel of Environment and Social Experts set up by the Department of Energy Himachal Pradesh. The report has examined the reasons for the local opposition to hydropower projects and highlights that the government needs to address the environmental and social impacts of these projects and the demands of the local people.
We are also attaching here the full report for your perusal.
The same local opposition to projects on environmental grounds exists in the Pangi and Lahaul regions of the Chenab River Basin. This is evident in the protests faced at the CEIA consultations held in the region. Please see the following articles: http://www.tribuneindia.com/ 2014/20141111/himachal.htm#11
http://www. internationalrivers.org/blogs/ 328-21
It is imperative that the EAC RVP is aware of the issues at the local level and takes cognisance of the same while taking any decisions regarding projects in these regions of Himachal Pradesh. We appeal for not granting any scoping or final environmental clearances until and unless the river basin studies have been thoroughly debated and considered.
Sincerely
Shanta Kumar; Hangrang Ghati Sangarsh Samiti, Kinnaur
R S Negi, Himlok Jagiriti Manch, Kinnaur
Manshi Asher, Himdhara, Environment Research and Action Collective
Himanshu Thakkar, South Asia Network on Dams Rivers and People
