The Environmental Impact Assessment (EIA) report prepared by the National Environmental Engineering Research Institute (NEERI) on the proposed barrage on Narmada river at Bhadbhut in Bharuch district has gone controversial. Farmers and fisherfolk walked out, en mass, from the environmental public hearing on the EIA report at Bhadbhut on July 19, 2013. Himanshu Thakkar of the South Asia Network on Dams, Rivers and People (SANDRP) comments on the EIA report:
The objectives of the proposed Bhadbhut barrage project on river Narmada stated in the EIA are four-fold: (1) Protection of water quality of Narmada river from salinity due to tidal influence and checking the problems of salinity ingress and deterioration of ground water quality in the upper reaches of Narmada river; (2) Storage of the regulated release of water from the Sardar Sarovar Project (SSP) and runoff from free catchment for irrigation, domestic and industrial water supply; (3) Flood protection of about 400 sq km low lying area covering 17 villages on the left bank of river Narmada; and (4) Road connectivity between left and right banks, shortening route from Surat/Hajira to Dahej region.
The EIA has uncritically accepted these objectives, without assessing if the barrage with low water storage can really fulfill the second and the third objectives. It also fails to clarify that considering the low salinity level reported by the EIA (mainly based on data provided by the project authorities, again uncritically accepted by NEERI), if the first is objective relevant.
The fact that the Kalpsar department played such an important role and the fact that it is public knowledge that the barrage is part of the propose Kalpsar project should have been taken note by NEERI. NEERI should have also questioned as to why is this small part of the larger Kalpsar project is applying for such piecemeal clearances, which is actually in violation of Supreme Court orders.
It should be added here that the Kalpsar project had applied for the terms of reference (TOR) clearance from the Ministry of Environment and Forests (MoEF), Government of India. The project came up before the MoEF’s Expert Appraisal Committee (EAC) on River Valley Projects. The SANDRP had then sent a letter to the EAC, saying that based on information provided, the project should not be considered for clearance. In its 41st meeting in Sept 2010, the EAC declined to give TOR clearance to the project, saying that the documentation provided are highly inadequate and need to be more holistic and up to date pre-feasibility report needs to be provided. The project thereafter has not gone back to EAC.
However, a small part of that same project, the Bhadbhut barrage, is now proposed before the Gujarat State Environment Impact Assessment Authority (SEIAA).
Hydrological viability assessment not done: The EIA does not do any proper hydrologic assessment of how much water will actually reach the barrage site in non-monsoon months once the Sardar Sarovar Project (SSP) command area is fully developed and the Narmada Valley command area in upstream is also fully developed. Once these command areas are fully developed and Narmada water is fully utilized and Garudeshwar weir is also functional downstream from SSP dam as planned, almost no water is likely to reach the barrage in non-monsoon months. Even in the initial part of the monsoon months when the upstream reservoirs are still getting filled, very little water will be coming downstream. In such a situation, which is likely to be the case in not too long distance a future, the EIA should have done the analysis of viability of the project.
Impact of concentrated pollutants not done: Bharuch district has large number of industrial estates including those in Ankleshwar, Jambusar, Vagra, among others. In addition there are urban areas like Bharuch and Ankleshwar and large number of villages in the upstream. The domestic and industrial effluents from all these areas would be coming to Narmada, and with very little freshwater in the river, the effluents will be highly concentrated and also laced with toxic chemicals from the industrial estates. How will all this impact the functioning of the barrage, should have been analyzed by the EIA, which has not been done properly.
Inadequate assessment of downstream impacts: The project notes that a large number of people depend on the aquatic, deltaic and marine fisheries downstream from the proposed barrage. It says (p E-10), “The total number of fishermen’s families residing in 21 villages is 2,520 with a population of 12,638.” However, the EIA does not assess the impact of the project on these people and on the aquatic, deltaic and marine fisheries in the downstream areas. It concludes (p E-15), “After construction of the barrage, there can be apprehension that the inter-habitat movement of the fishermen as also of the fishery species (Hilsa, fresh water and prawn fish) may be obstructed. However, the fresh water storage in upstream of the barrage will provide a favourable environment for intensive fresh water fishery and provision of fish ladder with shiplocks would enhance the fishery activities and fetch greater economic benefits to the people.”
This is clearly unwarranted and not based on any study. The project in fact will have huge impact on the downstream fisheries and fisheries dependent communities.
Fish ladder functioning not assessed: The EIA makes a statement (page E-15), “However, the fresh water storage in upstream of the barrage will provide a favourable environment for intensive fresh water fishery and provision of fish ladder with shiplocks would enhance the fishery activities and fetch greater economic benefits to the people.” This reflects that the EIA agency has not looked at in detail the functioning of the fish ladder. While the provision of fish ladder is a welcome proposal, the EIA does not properly assess how much water will be required to be released through the fish ladder for its effective functioning, how such releases will impact the benefits of the barrage, and how will it be ensured that indeed such water is released.
More importantly, upstream of fish ladder there will be a still water reservoir and not flowing water of the river. So this will be a completely different environment for the riverine fish and it is not assessed how this will impact the fisheries. Moreover, even if fish breeding is done upstream of barrage, the fish that can be bred in the still water of the reservoir will be of different species, and how this will work for the riverine fish is also an issue of assessment that EIA has not done with any comprehensiveness. Similarly, how the concentration of pollution in the upstream and downstream affect the fish has not been studied by the EIA. The release of water downstream also has to be done in a manner that will facilitate for the fish eggs and juveniles to travel downstream as part of their life cycle, How this will be achieved is also not assessed in the EIA.
Impact on mangroves: The mangroves in coastal areas are very important for protection of the coastal area from various hazards. The EIA should have done comprehensive assessment of the impact of the project on the mangroves, which has not been done.
Flood management: The EIA says (p E-15), “Understandably, by prudent operation of the gates, the flood can be managed without any effectual damage.” However, it is not mentioned how this prudent operation of the gates will be achieved. Experience of dam operations across India, including in Gujarat (e.g. Ukai in Aug 2006), shows that in absence of transparent and participatory decision making, this is not possible to achieve. There is no mechanism in place to show that this will be achieved in case of Bhadbhut barrage.
The statement (p 1.3), “the discharge will be only from free-catchment area downstream of SSP and virtually no discharge except regular release from hydropower units and that as environment flow from SSP will be there”, shows that the project is making most shocking assumptions.
Demand for barrage from people?: The EIA makes a strange but unsubstantiated statement (page E-17) when it says, “It may be worthwhile to mention that the proposed barrage project has been a result of demand of the local people”. It is clearly wrong for the EIA agency to make such unsubstantiated statements that also shows the pro-project bias of the EIA agency.
No adverse environment impact?: The executive summary of the EIA ends with this statement, “The project will not have any significant adverse repercussion on the environmental quality in the surrounding region, if the suggested mitigation measures as described in the EMP are implemented.” This is very strange claim and shows the highly inadequate understanding of NEERI about the project and its impacts.
Cumulative river basin wide impact assessment: The project is located at the end of the river basin that has very large number of big dams, industrial and urban activities, water diversions, discharge of effluents, deforestation on massive scale and so on. However, the river basin has not seen any cumulative impact assessment. This is clearly against the basic environmental norms. This additional project should not be sanctioned without a comprehensive and credible cumulative impact assessment across the river basin, including the carrying capacity assessment.
Track record of NEERI on EIA of river valley projects: The EIA report is in line with the poor track record of NEERI on EIA of river valley projects. NEERI’s EIA of 1000 MW Karcham Wangtoo project, on Sutlej river in Himachal Pradesh, was critiqued by SANDRP in 2003. It seems from a review of the Bhadbhut barrage EIA, that a decade later, there is no improvement in NEERI’s performance.
Incomplete statements: The EIA seems to contain a lot of careless, incomplete statements. For example, it says (p 1.3), “Narmada river flood is the most significant. At the highest flood level of 8.31 metres observed at Bhadbhut in 1970, low maximum flood discharge of 27 lakh cusecs was estimated.” The first sentence in this quote and the word “low” before maximum does not make any sense.
Conclusion: It is clear from the above comments, which are only indicative and not exhaustive, that NEERI has done a very poor job of the EIA and this kind of EIA is clearly not acceptable. The Environment Impact Assessment Authority should reject the EIA.