Major Concerns with EIA of 3097 MW Etalin HEP (6 X 307 MW at Dri Limb + 4 X 307 MW at Tangon Limb + 19.6 MW + 7.4 MW) by RS EnviroLinks EIA of the biggest Hydropower Project to be considered by MoEFCC, the 3097 MW Etalin HEP in Dibang Valley District, Arunachal Pradesh has been uploaded on the Arunachal Pradesh PCB Website (apspcb.org.in/etalin_hydro_electrical_project.htm). Public Hearing for the project will be held on the 12th December. There are major issues with the EIA of the project (done by RS Environlinks which has worked on several EIAs in Arunachal Pradesh, see here: rset.co.in/projects2.html), in the manner in which it assesses baseline information about the biodiversity rich and culturally rich region as well we its prediction of impacts. SANDRP has assessed the EIA Report and our Chapter-wise comments are below. EIA of 3097 MW Etalin HEP done by RS Envirolinks is a shockingly inadequate document for a project of this scale. The study is biased towards the project and does not even attempt to perform any options assessment and accepts the project as fait accomplii from the beginning. This does not qualify for a sound EIA. The study also seriously underplays biodiversity of the region. It also underplays impacts of this project and does not deserve to be discussed at the Public Hearing unless major issues are resolved. Some problematic points of the EIA are outlined below. Comments on the Eflows report will be sent separately. 1. Cumulative Impacts of Dibang Valley Projects need to be assessed before Public Hearing of individual projects According to 68th EAC Meeting in September 2014, 14 projects are planned in the Dibang Valley, in addition to projects below 25 MW. All these projects together will require thousands of hectares of forest land, will affect local livelihoods, increase downstream impacts, raise severe safety concerns, affect biodiversity, wildlife, hydrology, local culture, geology and seismicity of the region and its downstream. Before clearing any individual projects (3000 MW Dibang Project has already been recommended for EC), CIA of the basin is a must to assess issues like preclusion of projects, decrease in capacity, protection of biodiversity-rich rivers as free-flowing rivers without projects, cumulative impacts of projects on local communities and the downstream, etc. No public hearing for individual projects can be conducted in the meanwhile as the local communities and affected stakeholders will not have an idea of the cumulative impacts of such projects. Local communities are affected not only by individual projects, but cumulatively by all hydropower project related developments in the basin. Thus, holding a Public Hearing for a mega project like Etalin, which is the largest hydropower project being considered by EAC, even as TORs for Cumulative Impact Assessment Study of the same basin have been issued, is making a mockery of both CIA and Public Hearing process. CHAPTER MAJOR ISSUES Chapter 2: Project description and Infrastructure • FALSE Labels: The Project is not a Run of the River Project as claimed. EIA should not label the project as ROR. The project involves high dams ( 101.5 m on Dri and 80 m on Tangon), 4 coffer dams of which 2 are large dams more than 20 mts high, large scale diversion of 16.5 kms in Dri River and 18 kms in Tangon River and its land requirement higher than one thousand hectares of biodiversity rich forest land. The project will undertake peaking and it does not fit into the definition of ROR which is not supposed to change hydrograph of the river at any time scale ( Federal Energy Regulatory Commission (FERC), defines ROR as projects where instantaneous inflows equal instantaneous outflows) • FALSE Claims: Chapter 2 (2.4.14) states that the project will need 27 MW Power and will generate this through 7 Diesel Generating sets. This is false as the project has already applied for Forest Diversion for 22 MW AnonPani Project on the Tangon River to “contribute towards construction power needs of the 3097 MW Etalin Project”. (Form A submitted to MoEF attached.) Thus the EIA is misleading public and needs to be rejected in its entirety. Chapter 3: Methodology • Methodology does not comply with the TORs which say: “The entire area should be divided in grids of 5km X 5km preferably on a GIS domain. Thereafter 25% of the grids should be randomly selected.” • The Baseline Environmental Information (Chapter 7) is flawed, biased and limited due to haphazard methodology followed. The EIA has to redone, following prescribed methodology as per TORs. Chapter 4: Hydrology • This Chapter in the EIA is Annexure IV. Annexure IV is done not by the EIA Agent but by SNC Lavalin Engineering India. SNC Lavalin has been debarred by World Bank for ten years following bribing charges (Also from India re. HEPs). In addition, the firm which did these studies is not on the QCI accredited Lists of Moef dated 7 Nov 2014 . Their studies cannot form Chapters of EIA Document. (qcin.org/nabet/EIA/documents/Accredited%20consultants.pdf) • The GLOF Section of this study is very inadequate as it does not provide any history to past GLOFs, the scale of risk, the existing glacial lakes in the region, their distance from dam sites, etc. In the Climate Change scenario, such neglect of GLOF phenomenon is unacceptable. Chapter 5: Geology and Seismotonics • This Chapter in the EIA is Annexure V. Annexure V is done not by the EIA Agent but by SNC Lavalin Engineering India. SNC Lavalin has been debarred by World Bank for ten years following bribing charges (Also from India re. HEPs). In addition, the firm which did these studies is not on the QCI accredited Lists of Moef dated 7 Nov 2014 . Their studies cannot form Chapters of EIA Document, especially this chapter as it delas with downstream saftery issues. (qcin.org/nabet/EIA/documents/Accredited%20consultants.pdf) • Seismic and landslide risks are underplayed: The project region falls in highest seismic Zone V, and maximum intensity earthquake that can occur here can be at 8.5 Richter Scale. The region is located near and on the Eurasian Plate, making the region specifically earthquake prone. The 1950 Medog earthquake badly affected both the Dibang and Lower Dibang Valleys with nearly 70% causalities. Again on 2 June 2005, a 5.7magnitude earthquake hit the Upper Dibang Valley district. This information is not highlighted in the EIA Report. The region suffers from constant landslides. What will be the impact of huge infrastructure, including more than 50 kms of roads, blasting, mining on this region? Etalin HEP envisages construction of two dams of height 101.5m and 80m, respectively. Head Race Tunnel for diversion of Dri River is of 11 KM length and 11.3m dia and for diversion of Tangon River 3 tunnels of length 925m, 851m and 777m and of 6m dia for diversion of Tangon river. There will be six units of 307MW each in the common underground powerhouse for Dri dam complex and four units of 307MW each in the common underground powerhouse for Tangon dam complex. For project of such massive scale the geological & seismic impacts are severely underplayed. Recent Landslides not even mentioned: The section does not mention many well-known landslides in the region which have occurred at Etalin just in the last couple of years. 2010: nhrc.nic.in/display.asp?fno=13/2/1/2010 2012: arunachaltimes.in/wordpress/2012/06/07/dibang-valley-remains-cut-off-for-5-days/ 2013:ndtv/article/cities/landslide-triggered-by-heavy-rains-in-arunachal-pradesh-351219, 2014: sentinelassam/arunachal/story.php?sec=2&subsec=7&id=134902&dtP=2014-08-05&ppr=1 NHPC’s PFR itself says the region is “highly seismic” and landslide prone and there are number of landslides in the reservoir area powermin.nic.in/whats_new/PFR/AP/ETALIN.pdf • The EIA does not deal with necessary studies or recommendations in this regard, does not clearly spell out what are the precautions taken and how blasting, tunneling, deforestation, road construction, fluctuations in reservoir levels will affect landslide activity or how seismicity may impact the downstream population and impact the downstream Dibang Multipurpose project. The current EIA is thus unacceptable. Chapter 6: ENVIRONMENTAL BASELINE STATUS: PHYSICO-CHEMICAL PARAMETERS • Inadequate baseline data: Through the EIA report claims to be using the data collected from 2009 to 2014, it does not provide details of collected baseline data for important parameters such as physical-chemical characteristics of soil & water , Noise levels, Traffic data etc. The chapter gives just a single reading for each parameter. It is unclear how this single figure has been arrived at. E.g. about air quality single reading for each parameter for each season has been given for every monitoring location as follows Such kind of data makes a poor basis for impact prediction. Chapter 7: Environmental Baseline Status: Biological resources • The Chapter is entirely unacceptable as it hides and negates the ecological richness of the region. • It claims that only 447 plant species with 29 pteridophytes, only 17 species of orchids. With only one endangered plant species, that too, the report claimed can be only “rare” and that it was not encountered in quadrat surveys, • Mammals: It says that during survey only 5 mammal species were encountered. Total list is restricted to 26 mammal species, only 3 endangered Species, 5 in Schedule I. Reasons for threat human conflicts and poaching • Avifauna is represented only 33 species, with only 2 Schedule I species and I Near threatened species (Great Hornbill) • Reptiles represented by 11 species • Amphibians represented by 5 species • 45 species of Butterflies • Fishes diversity of Dri and Tangon Rivers stated to be comprised of just 12 species. This information is entirely misleading and incorrect. This region is a part of Mega Biodiversity hotspot and also Eastern Himalayan Biodiversity hotspot for fish diversity. It is estimated that there are about 6000 plant species, 100 mammal species and about 700 bird species in the Mishmi Hills region, and more can be discovered with additional efforts. There are also a large number of butterflies and insects, several news species being discovered each year. Tiger, common Leopard, Clouded Leopard, Snow Leopard, Golden Cat, Jungle Cat, Marbled Cat, Red Panda, Hoolock Gibbon, Mishmi Takin, Serow, Musk Deer, Himalayan Black Bear and the Leopard Cat are found in the region, which find no mention in the EIA. In a recent study, about 300 species of butterflies have been recorded in Dibang Valley District, including new species being recorded. SANDRP has discussed with several experts working in Dibang Valley region who confirm that the baseline biodiversity presented in the EIA report is severely compromised. The EIA is entirely biased on this front and presents incorrect, compromised information. The EIA Agent should be blacklisted for this bias and a fresh EIA needs to be constituted, Public Hearing cannot be held in the absence of a comprehensive EIA. Chapter 8 : Assessment of Impacts This is the weakest chapter of the EIA and fails to do any comprehensive and project specific Impacts Prediction • Impacts during Construction Phase: No mention of impacts of blasting an tunneling on the geology, landslide and disaster potential of the region • No assessment of impact on RET species. The EIA says that RET Mammals live in dense forests in upper catchments, but the project site itself is dense forest region! • The report also states that: “Since significant wildlife population is not found in the region, no major adverse impacts are anticipated on this account. This is an irresponsible claim to be made on the basis of flawed biodiversity baselines. • The EIA suggests that migratory fish “may be affected” this is height of biased reporting. The study only considers impact on one specie, that is Snow Trout and does not even bother to assess impacts on or presence of other species. • The EIA states that fish will get “adapted” to changed hydrology and can use tributaries. No assessment of planned projects on tributaries, or mention of additional projects like Anon Pani HEP and its impacts of fish species mentioned. • The EIA dismisses any downstream impacts on communities saying communities don’t depend on the river. No assessment of impact of deforestation, muck disposal, compensatory afforestation, loss of species on local communities done. • No impact assessment of impact of blasting and tunneling on water sources of communities done, although adits and tunnels pass drainages and streams on which communities directly depend. • During Operation Phase: No study of reservoir emissions done • No mention of impacts of peaking on biodiversity, sediment regime, bank stability, downstream safety done. • The EIA states that in operation sate there will be positive impact on Land Environment due to restoration activities! This is humbug as restoration, even if done ideally ( which is not observed in case of hydropower projects in India) will lead to degradation of land environment and not enrichment! • EIA mentions that there will be no impact on flora and fauna during operational stage. This is false as peaking will severely affect flora and fauna as well as raise safety concerns. Animals are not expected to understand peaking sirens! No mention of Sirens or any alarms has been made in any case! • Socio Economic Impacts: The EIA states that Socio economic levels will improve in the region. This is contrary to available information on hydropower projects. Even the recent CIA of Sutlej Basin Hydropower projects highlights how local communities emerge as losers in case of hydropower impacts. Hence, Public Hearing of 3097 MW Etalin project should be deferred until a comprehensive and participatory Cumulative Impacts Assessment of the Dibang Valley is not conducted and accepted by local communities and affected stakeholders. It is clear that the EIA report of 3097 MW Etalin Project which envisages huge and irreversible impacts on the region affecting the disaster potential of the region (as accepted by MoEF CC on affidavit in front of Supreme Court on 8th December 2014 in case of Uttarakhand projects) is performed without due care, concern or seriousness about the issue at hand. The EIA will not be accepted at the Public Hearing and local affected communities are sure to reject such a simplistic study, especially in the absence of a cumulative impact assessment study of Dibang Valley Projects. The EIA needs to be redone by an unbiased expert agency and cumulative Impact Assessment of Dibang Valley projects too needs to be completed by a expert consortia, including local communities. In the absence of unbiased and transparent information sharing and impact assessment, further appraisal of Etalin Projects cannot hold ground. - Parineeta Dandekar, Amruta Pradhan, SANDRP (parineeta.dandekar@gmail, amrutapradhan@gmail) SANDRP, December 2014
Posted on: Wed, 17 Dec 2014 05:19:42 +0000