River basin studies: A half-hearted attempt

By M H Ahssan

Impact assessment studies to understand the consequences of large dam projects have been de-linked from the actual implementation of the projects, thus diluting their value.

The Expert Appraisal Committee (EAC) on River Valley and Hydroelectric Projects of the Ministry of Environment and Forests of the Government of India has recently approved the Terms of Reference for conducting basin level studies of the Bichom and Lohit river basins in Arunachal Pradesh. The EAC has been constituted under the EIA notification 2006 to examine projects that apply to the Ministry for environmental clearance.

According to the TOR, the basin studies envisage "providing optimum support for various natural processes and allowing sustainable activities undertaken by its inhabitants". The Bichom and Lohit basins are among the river basins in the Himalayas where massive plans for building large dams and developing hydropower are being rolled out. More than a hundred projects with installed capacities totalling to 54,000 MW are at various stages of planning and implementation just in the state of Arunachal itself.

Often, a large number of dams are planned on single rivers or in single basins. For example, in the Lohit basin, a cascade of six projects totalling to 7918 MW are being planned, all within a length of 86 kms.

Such cascade-type development or a number of dams in a single basin raise the critically important issue of cumulative impacts. Often, the impact of all projects taken together is much greater than the sum of impacts of individual projects. Unfortunately, cumulative impacts are hardly ever assessed, as individual projects are planned and evaluated separately. One of the strongest criticisms against the recent plans of dam building has been the complete lack of any assessment of the carrying capacity - what level of development, and in particular the number of dams a basin can sustain - and of the totality of impacts of the number of dams and projects in the basin.

Indeed, when the impact assessment of even individual projects is patchy at best and often farcical, it would be too much to expect a proper cumulative impact assessment.

Against this background, the decision to undertake basin level studies in the Lohit and Bichom are welcome steps in the right direction. The TORs of the basin studies indicate that wide-ranging and extensive examination has been called for, as is necessary for any such study. The TORs call for "inventorisation and analysis of the existing resource base and its production, consumption and conservation levels, determination of regional ecological fragility/sensitivity based on geo-physical, biological, socio-economic and cultural attributes, review of existing and planned developments as per various developmental plans, and evaluation of impacts on various facets of environment due to existing and planned development."

The studies are to then assess the stress/load due to various activities and suggest environmental action plans that can involve preclusion or modification any activity and measures. Unfortunately, the good part ends with this. The way the studies have been structured ends up defeating the very purpose of carrying them out.

First and foremost, the basin studies have been effectively de-linked from the implementation of the projects as there is no requirement that the projects be conditional to the findings of the basin studies. Neither is there any explicit stay on the consideration and implementation of any of the projects pending the studies.

Logically, the basin studies should suggest what level of development, including hydropower projects, the basin can sustain. The projects should be planned based on this. However, the current planning and decision making turns this on its head. The numbers, locations, capacities, types and other details of the projects have already been decided. Many of these projects have already been allotted to (mostly) private developers who already have or would soon be approaching the Ministry for environmental clearance. In Bichom basin, the 600 MW Bichom (or Kameng) project is already under construction.

It is clear that the Expert Appraisal Committee understood this issue. The Minutes of its meeting dated 15 and 16 December 2008 record that "The committee noted that the study will be completed in two years and M/s WAPCOS has been entrusted with the job. In case, any project on this basin is submitted during this study period for environmental clearance, how the outcome of the study will help to take a decision could not be clarified." The obvious solution is to put on hold the projects till the studies are done. However, what the Committee decided is that "the report may be submitted within six months by reducing the TOR and the study should focus only on hydroelectric projects."

Thus, studies that would need about two years are to be done in six months (later this was extended to nine) with reduced TORs. How the outcome of such truncated studies would help rational environmental decision making is a question. It is clear that the environmental objectives have been sidelined with an eye to build as many dams as possible.

The TOR for the studies does state that they can recommend the "preclusion of any activity", which presumably means that they can call for any or some of the hydropower plants not to be built. In reality, such an outcome is highly unlikely, as is seen from the reluctance to explicitly put on hold the projects in the basin pending the results of the study. While the Committee has from time to time discussed with concern the possible impacts of large number of projects in a single basin, it has fallen shy of taking the right, but hard decision when actually dealing with the problem.

For example, the Lohit basin study was originally envisaged and put forward as a condition while granting clearance for pre-construction activities to the Upper and Lower Demwe projects in March 2008. But the Minutes of the EAC meeting of July 2008, while discussing the basin study note that "Environmental Clearance to Demwe Upper and Demwe Lower HE Project should not be linked up with the completion of basin study." These two projects add up to 3430 MW, a full 43 per cent of the total 7918 MW planned in the basin.

Further, considering that the studies are to be paid for by the project developers - in proportion to the size of the projects they have been allotted - the conflict of interest is clear.

An earlier such basin study - to determined the carrying capacity of the Teesta basin in Sikkim, initiated in 2001 - at least had a condition that no project will be considered for environmental clearance till the carrying study is completed. That study took over five years. However, the MoEF violated its own condition and accorded clearance to several projects even before the study was completed. On the other hand, based on the recommendations of the study, the MoEF has asked the Sikkim Government to drop five hydropower projects above Chungthang, and restrict the height of those below it. This shows that findings of such studies are likely to require significant rethinking of dam building plans in the river basins.

Neeraj Vagholikar, who is with the environmental organisation Kalpavriksh and has studied dam projects in the North-East since 2001 says about the Bichom and Lohit studies: "The reluctance to put on hold individual project clearances till comprehensive river basin studies are completed puts a question mark on the utility of the entire exercise. Moreover, the river basin studies will now be much shorter exercises instead of the comprehensive ones envisaged earlier, which are necessary for proper environmental decision-making. It appears that the Bichom and Lohit studies are more likely to be used to create a justification for the large scale hydropower development already planned than protect the ecological integrity of these river basins. One of the two key outcomes proposed for the studies - to provide sustainable and optimal ways of hydropower development - is a clear indication that the environmental objectives are of secondary importance."

The silver lining to this is that the second key outcome specified by the TOR is to "assess requirement of environmental flow during lean season with actual flow, depth and velocity at different level". It is significant that the Committee has recognised the importance of environmental flows, the flows necessary to maintain the ecological existence of the river, an issue that is increasingly being acknowledged as critical to sound river basin planning. One has to wait and see if the studies would have the independence to recommend preclusion or modifications to some of the hydropower projects if this is found necessary to maintain environmental flows, and if so, whether such recommendations could be implemented.

While there are several other important issues with the basin studies not discussed here, there is one that is essential to point out. The TORs for the basin studies lay out in detail many parameters that need to be studied, field data that needs to be collected, but fail to require that the local communities be consulted and involved in the process. This is a major shortcoming, and an indicator that the studies are reinforcing the technocratic approach instead of a participatory one that is the essence of environmental decision-making.

The basin studies for Bichom and Lohit are examples of a good initiative gone awry. The Committee's recognition of the need for basin studies is a welcome step. It is clear that this is an acknowledgement of issues of cumulative impacts and carrying capacity that activists, researchers, academics, dam affected people and others have been consistently raising for the last many years. At the same time, it does not go to the logical conclusion and hence has become self-defeating.

What the Committee needs to do is to re-define the TORs for the studies allowing them the two years that the committee itself feels are necessary, and redesigning them to require meaningful participation of local communities and civil society. Meanwhile it should put the projects in the basin on hold, and make them conditional to the findings of the study. If this is done, it will be a significant step in the direction of environmentally sustainable and holistic approach to development.