Additional Representation to IWAI regarding NW-1

29.10.2014 | Bharat Jhunjhunwala

This representation is in continuation of earlier representation submitted to the Ministry of Shipping and the World Bank which we understand has been forwarded to IWAI.

1 Longitudinal Connectivity

ThThe Government of India has asked IIT Consortium (IITC) to make a Ganga River Basin Management Plan. One central recommendation of IITC is to maintain longitudinal connectivity:

Mission Aviral Dhara: For a given geological-climatic setting, alluvial rivers achieve stability through long-term balance between various parameters such as water and sediment flow rates, temporal variations of flow, terrain gradient, and seepage flow rates. “Aviral Dhara” emanates from this long-term balance of rivers. A direct violation of Aviral Dhara is due to dams and barrages, which snap the longitudinal connectivity in rivers and alter river water and sediment flows (Page iv, IITC Interim Report, attached).

Further IITC has stated that activities that break the longitudinal connectivity must not be implemented (Page 23, IITC Interim Report, attached). Therefore making of barrages should not even be considered.

2 Cost-Benefit Analysis

In compliance of an order of NGT, the Ministry of Environment had asked Indian Institute of Forest Management (IIFM) to frame guidelines for undertaking cost-benefit analysis. IIFM has given sector-specific guidelines. To the best of our knowledge, these guidelines have not been “accepted” or “rejected” by MOEF yet. Nevertheless, they indicate the range of costs that must be taken into account. The guidelines for irrigation and hydropower projects are relevant for the Waterway. The guidelines require the following costs to be monetized and taken into consideration.

  1. Human resettlement costs
  2. Environmental losses (ecosystem services of forests).
  3. Loss of potential value of land.
  4. Habitat fragmentation costs.
  5. Suffering to oustees.
  6. Loss of public infrastructure
  7. Economic costs of water borne diseases.
  8. Downstream costs (riverbank erosion, coastal erosion, groundwater, etc.). 
  9. Loss of aesthetic value of the river.
  10. Other activities required as a result of project activity (Such as terminals, jetties, etc,).
  11. Dam Removal costs. Impacts on terrestrial, aquatic and floral biodiversity.

It is submitted that these costs of the waterway project may be taken into account. Relevant extracts from IIFM Study are attached.

Impacts of upstream activities

The Government is committed to Ganga rejuvenation. At present nearly 100 percent water from the Ganga and Yamuna is abstracted at Narora and Hathnikund respectively. IITC has recommended E-flows of about 30-35% for the Ganga. Acceptance of this recommendation would lead to an increase in flow at Allahabad. In consequence the hydrological studies of depth available at present downstream of Allahabad will no longer be tenable.

It is necessary for IWAI to develop a scenario where such e-flows are released from the upstream and work out the DPR accordingly.

EIA before DPR

IWAI has already advertised seeking consultants for making EIA and EMP of NW-1. At the same time I was informed by the Project Director, NW-1, Shri Pravir Pandey that IWAI has rejected the DHI study suggesting making of 3 barrages between Allahabad and Ghazipur and IWAI is commissioned a fresh study de novo.

It is submitted that EIA is done for a project as specified in a DPR. EIA cannot be done if the project parameters are themselves uncertain. Therefore, the EIA study must be postponed until DPR is made and placed in public domain.

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