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Comments on Draft NWP & Request for extension of comment period by another 3 months for panchayats & districts

Written By Krishna on Wednesday, February 29, 2012 | 5:06 AM

Letter to Union Ministry of Water Resources


This is with reference to the draft National Water Policy, 2012 released on 31-January, 2012. It has been announced that citizens of India can comments till 29th February, 2012.

We submit that before putting the draft policy in front of National Water Board and National Water Resources Council for finalization and adoption, the comment period for draft policy must be extended by ate least another 3 months so that the policy can be discussed at till the panchayat and district level.

In the last fortnight I have visited Bihar and Jharkhand and have learnt that there isn’t any awareness about the draft policy in even in the state capitals.

We submit that the policy continues with the colonial legacy of treating land and water as separate issues although it is a universal fact that both co-exist. I submit that Section 1.2 of the draft National Water Policy is a sad commentary on the achievements of Ministry of Water Resources so far given the fact that after spending over Rs. 180,000 crores since 1991-92 the irrigated area remains stagnant to the status 2 decades ago.

In this context submit that the flood prone area of the country has increased from 25 million ha at the beginning of the plan period to nearly double that 49.82 mha in 2012. The lay out on flood control for the12th Five Year Plan is estimated at Rs. 55,440 crores.

We submit that Section 3.2 fails to define the norms for deciding the ecological flow and the authority who would do so.

We submit that Section 5.4 that deals with artificial recharging of ground water fails to fine-tune its policy with industrial and agricultural policy.

We submit that Section 5.5 is ecologically insensitive. It is akin to the ecologically disastrous plan to rewrite geography of India in particular and South Asia in general. This will disrupt river basins through diversion of rivers beyond river as has happened in the case of two Siberian rivers that led to drying up of Aral Sea.

It must be noted that Union Minister for Water Resources had informed the Rajya Sabha on September 5, 2011 that National Water Development Agency (NWDA) "has taken up works for preparation of DPR of 2 intra state links namely Kosi-Mechi Link and Burhi-Gandak -None-Baya- Ganga link of Bihar. He also informed that NWDA was set up under the Union Ministry of Water Resources "in 1982 for carrying out various technical studies to establish the feasibility of the proposals of for National Prospective Plan (NPP) for interlinking of Rivers and to give concrete shape to them." But by not informing the Rajya Sabha that National Prospective Plan (NPP) for interlinking of Rivers was rejected in September 1999 by a high powered National Commission on Integrated Water Resources Management, the ministry chose to keep the august house in dark.

We submit that on February 27, 2012, the bench of Chief Justice of India has been misled into passing seemingly executive orders for the execution of interlinking of rivers because the recommendations of the Report of the National Commission for Water Resource Development was not brought to his notice. The same happened in October 2002 when the initial order was passed on the basis of the flawed assumption that there is consensus among the states which got revealed through the Terms of Reference of the Task Force that was constituted for interlinking of rivers.

The policy feigns ignorance about the relevant recommendations of the two volume Report of the National Commission for Water Resource Development set up by the Union Ministry of Water Resources. Volume-I of the report says: “The Himalayan river linking data is not freely available, but on the basis of public information, it appears that the Himalayan river linking component is not feasible for the period of review up to 2050.” The report underlines that the problems are in the entire plan of linking the Himalayan rivers. It also shows that centre and the state government refuse to learn from the embankment disaster and drainage crisis in the Kosi basin.

It is germane to note that out of 30 links in the controversial national plan to network rivers through diversion there are six links in the Himalayan component which were related to Bihar, one of which has been rejected by National Council of Applied Economic Research (NCAER) in its study on “Economic Impact of Interlinking of Rivers Programme” in April 2008. These six links are: Kosi-Mechi Link Canal, Kosi-Ghaghara Link Canal, Sone dam-Southern tributaries of Ganga Link Canal, Chunar-Sone Barrage Link Canal, Brahmaputra - Ganga (Manas- Sankosh- Teesta- Ganga Link Canal and Gandak-Ganga Canal. Brahmaputra - Ganga (Manas- Sankosh- Teesta- Ganga Link Canal has been dropped as per NCAER study.

We submit that as per the 10th Plan document, there were 1,300 irrigation projects that have been taken up for implementation, out of which, only 900 have actually been completed. Even Shri Jairam Ramesh who later became Union Environment Minister and currently the Union Rural Development Minister contended in the Rajya Sabha saying, "in this country today, there are 400 irrigation projects being implemented at some critical levels of financing, and I think, really this reinforces the point that I want to make that it is really project implementation, projects under implementation, that need to be completed. You don't need a new category called 'projects under contemplation'". Both state and central project are 'projects under contemplation'. It seems to be a political escape route akin to Ostrich policy instead of proposing decentralized and workable projects with public consent.

The fact is that interlinking of rivers project is based on the flawed assumption that there are surplus and deficit rivers. It is claimed that 220 bcm of water can be usefully transferred. As per 11th Five Year Plan document, "there are apprehensions that the assessed surplus is somewhat illusory for many basins and future generations would actually need all the water." It takes congnisance of "reservations about the economic viability of such large projects. Environmental concerns would need to be addressed through the environmental appraisal process of each project."

We submit that Section 10.2 appears good as it envisages that part of the rehabilitation cost should be paid by the beneficiaries of the project but it is valid only when the stated objectives of the project have been met and the beneficiaries get the promised deal.

The draft policy failed to adopt a land-water policy but it is adopting such land-water related projects that will rupture rivers basins.

Yours faithfully

Gopal Krishna, convener, ToxicsWatch Alliance, New Delhi, Mb: 7739308480, 09818089660

Pushpraj, Journalist and author of Nandigram Diary, Patna, Mb: 09431862080

Shashi Sagar, Journalist, Patna, Mb:09308912720
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