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Comments on the proposal of interlinking for Ken Betwa rivers inside the Panna Tiger Reserve

Written By Gopal Krishna on Wednesday, November 04, 2015 | 4:29 AM

ToxicsWatch Allinace (TWA)


NBWL Standing Committee

Government of India
New Delhi

November 4, 2015
Subject-Comments on the proposal of interlinking for Ken Betwa rivers inside the Panna Tiger Reserve


This is with reference to the meeting of the NBWL standing committee which is to consider the proposal of interlinking for Ken Betwa rivers inside the Panna Tiger Reserve on November 4, 2015.
We submit that the MOU for DPR for interlinking of Ken Betwa rivers was signed in August 2005, but there is no progress so far after that in terms of interstate agreement. Its EIA shoddy and the public hearings involved violations.
We submit that academicians and economists like Prof. Kanchan Chopra of Institute of Economic Growth have also questioned the rationale of the Ken-Betwa link. Even Prof. Y K Alagh, former Union Minister has written how Ken Betwa project has been allowed because government is giving in to a loud lobby although it’s a terrible project to be signed. It needed examination by an independent committee.
We submit that while looking at benefits the interest of both the rivers and their ecosystem also needs to be factored in.
We submit that under the circumstances, NBWL should not even be considering this and they should send it back to Madhya Pradesh State Board on Wild Life (SBWL) to reconsider after satisfactorily responding to the environmental concerns being raised.

We wish to draw your attention towards the detailed dissenting note submitted by Field Director of Panna Tiger Reserve and a member of 4 member committee set up by the NTCA in 2013 to review the Ken Betwa Proposal. It would not be proper for the NBWL to consider the proposal without consideration of this detailed dissent note by these official agencies and satisfactory response. It is noteworthy that Shri H S Panwar, Padma Bhushan, former director of Project Tiger (1981-85) & former director of WII (1985-1994) has written a detailed note why this project should not be considered till there is a proper and credible Environmental Impact Assessment. He has inferred that the current EIA is not credible at all.  We submit that J Van Gruisen and R.S. Chundawat of Baavan – bagh aap aur van has written a detailed note explaining how poor, and flawed the EIA is. Their conclusion is valid for NBWL too. The current EIA has failed to adequately assess the impact of the project on the Panna Tiger Reserve or the Ken Ghariyal Wildlife Sanctuary.

We submit that this project KBP will also affect the Ken Ghariyal Wild Life Sanctuary. This impact will certainly be there due to the hydrological changes that will happen due to the construction and operation of the project. It is noteworthy that it has not even been properly assessed.
It is quite shocking that according to the project DPR of April 2010, one of the components of the project is "A 850 m long barrage with crest level of 181 m across Ken River about 1.0 km d/s of existing Bariyarpur pick up weir". This is from the NWDA's latest available DPR.  But instead of relying on it the EIA only mentions the DPR of 2008, which did not include this proposal. This clearly establishes that the EIA is based on an outdated DPR and does not even consider full project components.
This creates a logical compulsion to order fresh EIA for the project in question. Given the fact that Interlinking of Rivers (ILR) project is a cumulative project, isn’t it logically compelling to undertake cumulative environment and forest impact assessment prior to seeking clearances?  The practice of seeking “environment and forest clearances” admittedly “for individual link Project” shows deep insensitivity towards environment and forests. Thus, it is deeply flawed.
We submit that project proponent fails to adopt river basin approach because it strikes a balance between the existing natural functions of the river system and societal expectations for livelihoods, industry, recreation, nature management, and agriculture. This approach maximizes the economic and social benefits derived from water resources in an equitable manner while conserving and, where necessary, restoring freshwater ecosystems. It factors in doctrine of riparian rights that emphasizes recognition of equal rights of water use by all owners of land subject to non-interference with rights of other riparian owners and the territorial integrity theory or theory of natural water flow wherein every lower riparian is entitled to natural flow of river without interference from upper riparian. It adopts the doctrine of community of interest implying that a river passed through states is deemed to be one unit and should be developed as such. The approach of seeking “environment and forest clearances” admittedly “for individual link Project” is quite parochial, dated and is caught in a time warp.

We submit that project proponent cannot even attempt to defend the indefensible without the cumulative impact assessment of the ILR project. So far it has completely failed to do so. It is relevant to recall that a partial, unsuccessful and biased attempt was made to undertake cumulative impact of assessment of hydropower projects in Alaknanda and Bhagirathi Basins. For the ILR project, cumulative impacts must assess changes in sedimentation at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof. It should assess cumulative impact on aquatic and terrestrial flora and fauna across the basin due to ILR project. It should assess cumulative impact on hydrological flows, at various points within project, at various points within a day, season, year, over the years and cumulatively across the basin and impacts thereof. This should include impacts on various hydrological elements including springs, tributaries, groundwater aquifers, etc. This assessment must provide a picture of what is the situation before undertaking the ILR project and what would be the situation.  After the implementation of the project. It should account for cumulative green house gas emissions. It should assess the cumulative impact of mining of sand, boulders, coarse and fine granules etc required for the ILR project. It should assess the cumulative impact of blasting of so many tunnels. It should assess cumulative impact of improper and proper muck dumping into rivers. It should assess cumulative impact of silt laden water into the river channel downstream from the dam, and how this gets accumulated across the non monsoon months and what are its implications. It should assess cumulative impact of release of silt free water into the river downstream from the power house and impact thereof on the geo morphology, erosion, stability of structures etc. It should assess cumulative impact of differential water flow downstream from power house in non monsoon months, with sudden release of heavy flows during peaking/ power generation hours and no releases during other times. It should assess cumulative impact of all the project components (dam, tunnels, blasting, power house, muck dumping, mining, road building, township building, deforestation, transmission lines, submergence etc) for the ILR project. This should be done for the periods during construction, operation and decommissioning phases of the projects.

We submit that contention of the project proponent that “the ILR projects are green projects and these link projects under ILR Programme have been formulated by exercising all caution and considering all engineering parameters required for the project” ignores the glaring fact of South Asia’s biggest ecological crisis due to construction of embankments in Kosi basin in Bihar and Nepal. These misplaced engineering interventions have created unprecedented drainage congestion crisis even as NWDA and its sister organizations keep claiming that it was “formulated by exercising all caution and considering all engineering parameters required for the project.” Its contention ignores the lessons from the drying up of Aral Sea, the world biggest ecological catastrophe because of diversion of Siberian rivers in former USSR.

We submit that some 60 years ago Aral Sea basin was a richly forested eco-system fed by two of the longest rivers in Asia. It stretched 266 miles from its northern port, Aral'sk, to the port on its southern delta, Muynak. The lake was fed in the north by the Syr-Dar'ya River, flowing from its headwaters in Kyrgyzstan through Uzbekistan and Tajikistan, then north through Kazakhstan into the lake. The Amu-Dar'ya River begins near Khyber Pass in Afghanistan, flowing along the border between Turkmenistan and Uzbekistan before forming a delta at the southern end of the Aral Sea. After the collapse of USSR, Kazakhstan borders the Aral Sea in the north, while Uzbekistan lies on the south shore. After the collapse USSR, scientists discovered that the Aral Sea was missing. At present the Aral Sea has lost three-fourths of its former volume and two-thirds of its former surface area. The water level has dropped by almost seventy feet, and the salinity of the lake is triple the level of forty years ago. The former sea has split into two parts with a diminishing trickle of water between them. There are projections about its complete disappearance in near future.

We submit that quite like the proposed ILR project, Soviet government had launched a massive irrigation project. In late 1930s when it was decided to drain the rivers of the Aral basin to irrigate wide expanses of desert disregarding the advice and prediction of Soviet scientists about its adverse consequences for the Aral Sea and its ecosystem if the Amu-Dar'ya and Syr-Dar'ya were exploited as planned, but their advice was ignored. As a result, water from the two rivers stopped reaching the sea much of the time, and not at all in dry years. The Amu-Dar'ya stopped reaching the sea due to drought, and water from the Syr-Dar'ya did not reach the sea during the summer when needed for irrigation, coming instead in the winter and causing floods, exacerbating the ecological situation. The sea began drying up within years after introduction of the plan, but the USSR government argued that "the disappearance of the sea would be good, because then more cotton fields could be planted on the seabed." The desertification of the Aral Sea was not a natural process; it was deliberate process akin to the proposed ILR project.

We wish to point out what Shri Mikhail Gorbachev, formerly President of the USSR said in this regard. He said, “After the extent of the Aral Sea tragedy became known, we stabilized the unsustainable irrigation schemes which were cutting off the water supply to the Aral Sea, and halted a project which had been planned by engineers to divert two major Siberian rivers.” He added, “The most important lesson is that the developments in science and technology of the past century bring with them not only huge benefits, but also great responsibility, as human mistakes or mismanagement can now cause irreversible damage to the environment, immeasurable human suffering and threaten the very habitability of large parts of our precious planet.”

We submit that claim of the project proponent that “The ILR projects will provide boost in every sphere of life including job creation, greenery, tourism and ultimately helps in food production and thus increase food security of the nation” is an exercise in empty posturing. It does not provide any figures for such claims. It does not disclose the quantum of agricultural land that will be submerged and how much of such land will be put to non-agricultural purposes while making unsubstantiated claims about “food production” and “food security”. Unless it provides figures for how food production will suffer and impact food security due to submergence and diversion of agricultural land such claims are manifestly misleading.

We submit that the proposed Interlinking of Rivers (ILR) project will kill the rivers and their basins. It will destroy groundwater recharge system. The fact is that surface water projects are not delivering, they only seem to involve scandals.

We wish to draw your attention towards a book ‘Free the CBI’ by Late Shri B R Lall, former Joint Director, Central Bureau of Investigation (CBI) wherein there is a reference author’s letter to Shri K Vijaya Rama Rao, the then Director, CBI in August 1995. In this letter he mentions that he strove for complete investigation into the power sector, which is draining the country. In the book it is mentioned that kickbacks may be 3 to 10 % of the project cost, but up-valuation is anything between 40 to 100 % of the real project cost. He had sent a report on Chamera project to Director, CBI where against an estimated cost of Rs 1393 crores in 1992, the negotiations for allotment are on for Rs 3300 to 3600 crores i.e.@ Rs 12 crores per MW whereas world over rate of only around Rs 6 crores per MW is  considered reasonable for hydro electric projects. In the letter it is reasoned that even if this figure were to be Rs 2000 crores for 300 MW Chamera project, shouldn’t it be examined when Rs 1000 to 1500 crore of the nation is being squandered for kickbacks of Rs 100 crore. The Director CBI never permitted this probe.

We demand a high level probe in the hydro power and irrigation sector before pursuing the ILR project which entails such projects as well.

We submit that as per the Planning Commission’s Tenth Plan document, there are 383 ongoing major and medium projects awaiting completion, 111 of which are pending since pre-fifth Plan period i.e. more than 26 years. All these can be completed within five to eight years, yielding an additional potential of about 14 million hectares at a cost of Rs 77,000 crore as estimated by the plan task force, now raised to Rs 100,000 crore.

The second component listed in the Plan is development of minor irrigation, mostly in the eastern and northeastern regions. The total potential assessed is 24.5 million hectares with a total investment of Rs 54,000 crore, of which the government is expected to provide only Rs 13,500 crore, the balance coming from beneficiary farmers and institutional loans. The cost per hectare is only Rs 20,000 and gestation period almost nil, against a cost of Rs 100,000 and 12 years' gestation in case of major and medium projects.

The third equally beneficial scheme mentioned in the Plan is the groundwater recharge master plan prepared by the Central Ground Water Board needing Rs 24,500 crore to trap 36 billion cubic metres of water annually.

We submit that these measures are quite clearly better than the project of networking of rivers. The concerned judges would serve the ecological interest of the subcontinent better if they could pay heed to these proposals of the Plan document. Judges at all levels have, by and large, justified the confidence reposed in them. But there is scope for improvement in several spheres and it is up to the judiciary itself to rectify the defects in its role and prove to the public that as long as there is an efficient, impartial, independent and incorruptible judiciary, democracy in India will be safe from the tyranny of the executive and also the judiciary.

We submit that the proposal of networking Peninsular and Himalayan rivers emerges from a lack of rigorous evaluation of the ecological impacts which would prove disastrous not only to the fishery, but also to the biodiversity and biotic processes that have evolved over the past hundred of millions of years.

We must remember if water scarcity is the perennial question, there better answers like the groundwater recharge master plan available with the government. Water can be made to “Reach to All Homes, Farms and Factories” by adopting this plan as well at a minimal cost. It submitted that whenever there is conflict between financial gains  and rivers, the latter must get priority over monetary benefits because by any yard stick economic value of a free flowing river is bigger than dammed and mutilated rivers.  The capitalist, communist and colonial legacy of treating rivers as material flow that flow through pipelines must be abandoned and rivers must be treated as living beings that nourished our civilization for centuries and can nourish all the coming generations if cannibalistic tendency of diverting waters in bottles, dams and banks is stopped.
We submit that the project proponent is under structural compulsion to push these ecologically destructive projects envisaged in 1970s to justify their continued existence. NCAER, NWDA and their promoters remain trapped in pre-climate crisis era wherein “taming of rivers”, dams were temples and not outcome of disease of gigantism and conquest over nature was considered part of scientific temper with which rivers could be murdered with impunity.

We submit that in 1715 India accounted for 25 % of world industrial output. India’s share in the world’s industrial output became possible without engineering the landscape and replumbing the river valleys of the sub continent which is already demonstrably earth quake prone.

We submit that project proponent seems to suffer from a gross materialist and technocentric bias wherein water flow is deemed material flow alone and not the flow of life that sustains life. They must appreciate the pearls of wisdom from Mahabharata that describes the Divine Being saying, “The mountains are his bones. The earth is his fat and flesh. The oceans are his blood. Space is his stomach. The Wind is his breath. Fire is his energy. The rivers are his arteries and veins. Agni and Soma, otherwise called the Sun and the Moon, are called his eyes. The firmament above is his head. The earth is his two feet. The cardinal and subsidiary points of the horizon are his arms,” the government should reject the idea of “inter-linking of rivers based on feasibility”. This is narrated by Bhishma in conversation with Yudhishthira while referring to the reply of sage Bhrigu to sage Bharadwaja. This verse occurs in the Shanti Parva of Mahabharata. The project proponent fails to recognize that Interlinking of rivers project is an exercise in delinking because it entails mutilation of the veins and arteries of the divine nature. Rivers shape the terrain and lives of people by its waters which are always in a dynamic state. Breaking this dynamic would unleash forces of uncontrolled change and invite the ‘law of unintended consequences’.
In view of the recent earth quakes, unpredictable rainfall and changing weather pattern, we are under logical compulsion to reiterate that for the sake of sanity and humanity, Interlinking of Rivers project should be abandoned.
 We would be happy to meet you as a delegation and share relevant documents in this regard.

Thanking you in anticipation

Yours faithfully
Gopal Krishna
ToxicsWatch Alliance (TWA)
Mb: 09818089660, 08227816731
Hon’ble Members, NBWL Standing Committee

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