Himanshu Thakkar of South Asia Network on Rivers, Dams and People (SANDRP) has been writing to environment minister Jairam Ramesh on the issue of the environmental impact assessment exemption for some dam and river projects. Thakkar counters the criteria for the exemptions saying that the locals are forced to put up with the projects without protest, bound by the ministry's oversight.

May 13, 2011

To
Shri Jairam Ramesh,
Union Minister of State (IC) for Environment and Forests,
New Delhi

Respected Sir,

The Sept 14, 2006 EIA notification lists "LIST OF PROJECTS OR ACTIVITIES REQUIRING PRIOR ENVIRONMENTAL CLEARANCE" under a schedule defined in the Notification. Section 1(c) of this schedule is for River Valley projects. This section includes only hydro projects above 25 MW and irrigation projects. Compare this with what was included in the EIA notification before 14.09.2006 under River Valley Projects: "River Valley projects including hydel power, major Irrigation and their combination including flood control." Thus, till 14.09.2006 all large dams and river related projects required environment clearance and hence EIA and also public hearings.

However, after 14.09.2006, following categories of dams and river related projects got excluded from the EIA notification:
1. All Dams meant not meant for irrigation or having hydro installed capacity below 25 MW. (The authors of the notification seem like complete illiterates on environment issues, since this excludes say the 10 MW Gumti dam on Tripura having massive submergence area of 4634 ha. The installed capacity of hydro power does not decide the quantum of impacts.)

2. All drinking water dams

3. All Industrial water dams

4. All flood control dams or embankment proposals.

These are shocking exclusions, since all these projects have massive impacts, both socially and environmentally. I had written to you about this anomaly earlier in June 2009 soon after you took over as minister. Earlier too, we had written to MEF to remove this anomaly.

To illustrate the absurd implications of this anomaly, there is a dam being proposed on Kalu river in a tribal area in Thane district in Maharashtra. This dam with storage capacity of 405 million cubic meters will have submergence area of over 2100 ha, including 1000 ha of forest land. However, the dam, being proposed for drinking and industrial water supply  to Mumbai, does not require EC, EIA or PH and the work on the dam has already started on massive scale, affecting the local people. But the local people cannot even raise a voice against the project since there are no EIAs, no PH  and no env clearance is required. The project authorities do not have forest clearance either, but they have started work on what they call non-forest land, and say that the forest clearance application is happening, but they have permission (from Irrigation Dept) to start work. The work in any case is illegal since work on non-forest land in a project requiring forest land cannot be started as per SC orders. Moreover the dam developers have felled trees from at least 100 ha, without any permission from anybody. Their JCBs and timber have been confiscated, but they are not bothered since they have started work on the dam.

I am marking a copy of this to my colleague Parineeta, who has just returned from a visit to the area.

In the same area, there is another massive dam under construction, called Shai dam. It again does not require EIA, PH or EC since it is a drinking cum industrial water supply dam, even though it is of masssive size and impacts.

To illustrate another absurdity of the anomaly of the projects excluded by current EIA notification, the controversial Renuka dam in Himachal too would not have required EIA, PH and EC if it were not affecting a portion of the Renuka sanctuary. Similarly, the embankment projects related to Polavaram project in Orissa and Chhattisgarh do not require EIA, PH and EC, the CWC and AP govt has argued. There are several such examples one can give.

To stop here, we request you to URGENTLY:
1. Amend the Schedule of EIA notification to bring back the pre 14.09.2006 definition of river valley projects into the schedule of projects requiring EIA, PH and EC.
2. Order that the illegal work on the Kalu and Shai dam be stopped immediately.

Awaiting your early response,

--
Himanshu Thakkar

South Asia Network on Dams, Rivers & People,
c/o 86-D, AD block, Shalimar Bagh,
Delhi, India

[email protected], [email protected]
www.sandrp.in