Comments on TOR for NW-1 Studies Submitted to Inland Waterways Authority of India
DR BHARAT JHUNJHUNWALA
Lakshmoli, PO Maletha, Via Kirti Nagar, Dt Tehri UK 249 161
August 13, 2015
Shri Pravir Pandey, Project Director
Jal Marg Vikas Project
Inland Waterways Authority of India
A-13 Sector 1, NOIDA 201301
Dear Shri Pandey:
We write in continuation of the following representations:
1 Representation submitted to the Secretary, Ministry of Shipping dated 26.8. 2014 that has been forwarded to you.
2 Additional Representation dated 29.10.2014.
3 Suggestions by G N Kathpalia dated 9.11.2014.
4 Comments on studies dated 1.12.2014.
We have seen the TOR issued by IWAI for:
1 ESIA TOR: Environmental & Social Impact Assessment (ESIA), Environmental Management Plan (EMP) and Resettlement Action Plan (RAP) for ‘Capacity augmentation of navigational infrastructure of National Waterway-1’ between Haldia to Allahabad (Jal Marg Vikas Project)
2 SDS TOR: "IWT Sector Development Strategy and Business Development Study for Capacity Augmentation of National Waterway-1 from Haldia to Allahabad” (Jal Marg Vikas)
We are aware of Hon’ble Minister Shri Nitin Gadkari’s statement in the Parliament in March 2015 that no barrages will be built between Varanasi and Haldia. However, Para 8.0 of your ESIA TOR states that impact assessment of barrages shall be made.
Moreover, the Hon’ble Minister’s statement only speaks of the stretch between Varanasi and Haldia and leaves open the stretch between Allahabad and Varanasi for the construction of barrages. It is also to be noted that statement made by the Hon’ble Minister in the Parliament is not legally binding.
We wish to draw your kind attention to the fact that many suggestions provided by us for the assessment of the NW-1 project have not been taken on board. We are giving a list of these omissions without elaborating on the contents of the same that have already been provided to you in our previous representations.
This representation is made in two parts. Part 1 gives our comments on the studies irrespective of whether barrages are made or not. Part 2 gives our comments on the impacts of barrages, should these be made.
Part 1: Comments on NW-1 Studies irrespective of whether Barrages are made or not
1 Floral biodiversity: Dredging and conversion of free-flowing river into reservoirs will lead to negative impact on floral biodiversity, that, in turn, will impact faunal life. This is not mentioned in the TORs. (Please see our representation dated 26.8.2014 for more details).
2 Cultural Impacts: The four Shankaracharayas are on record that no obstruction should be made to the free flow of the Ganga. Free flow of the Ganga has huge use and non-use values. (Please see our representations dated 26.8.2014 and 1.12.2014 for more details).
Your TOR, however, ignores this important aspect altogether. Only heritage sites are mentioned at Para 5.1 of ESIA TOR.
3 Social Impacts: The Ganga is worshipped by people across India and even the world. However, ESIA TORPara B.11 and C.2 has reduced social impacts to people residing on the banks of the Holy River. The “National River” status of the Ganga has been ignored.
Your SDS TOR Para 4.2.6 only speaks of “social and environmental benefits” and assumes that there are no costs.
4 Water Quality: The self-purifying quality of the Holy Ganga is hugely dependent on the unique coliphages that are found in the Ganga as shown by NEERI. These coliphages are adsorbed into the sediments. Dredging and making of barrages disturbs the sediment regime and thereby the dynamics of the coliphages. This critical aspect does not find mention in your TORs.
Recent research indicates that water molecules form clusters in varied shapes and these may be the repository of the ability of the Holy Ganga to carry spiritual charges. Please see Jhunjhunwala, Bharat, Water: Impact of Dams on its Qualities, Kalpaz, 2014 for more details.
Your ESIA TOR Para 5.2.2 only requires monitoring of water quality as per NMCG targets. The abovementioned factors have been ignored.
The ESIA TOR Annex A.B.6.2 requires assessment of impact of the improvement of navigation facilities in the waterway on the river water quality by using suitable empirical/model studies but does not specify the parameters to be used for assessing the impact.
We had submitted the water behind the barrages may become anaerobic due to stagnation (Please see our representations dated 26.8.2014 and 1.12.2014 for more details). The ESIA TOR does not requires assessment of the same.
5 Disasters: The impact of the disasters like sinking of ships has been ignored. (Please see our representation dated 26.8.2014 for more details).
6 Declining Flows in the Ganga: Recent studies indicate a huge decline in water in the Ganga due to deforestation. This trend is not examined in the TOR.
7 Sampling: Collection of ground water samples at I sample per 50 km is grossly inadequate.
8 Affected Area: At Para B3.5 and several other places it is mentioned that baseline data up to 2 km from high bank of river is to be collected. This is inadequate. 15 km radius is considered for EIA and for cumulative EIA.
9 Cost-Benefit Analysis: The framework of CBA made by IIFM lists the factors that must be considered for undertaking a CBA analysis of river valley projects such as irrigation and hydropower. These are mutatis mutandis applicable to navigation projects. (Please see our representations dated 26.8.2014, 29.10.2014 and 1.12.2014 for more details).
The ESIA or SDS TORs nowhere require the Consultants to undertake a comprehensive CBA of all benefits and costs of the Jal Marg Project. ESIA Para 5.2.1 only mentions the need to undertake CBA of storage projects without specifying factors to be included. The SDS TOR Paras 4.2.6 and 4.4.13 require reporting of only the socio-economic-environmental benefits of the project and do not require reporting of costs of the project.
The following impacts enumerated in the IIFM framework are missing from the TORs:
- Project costs and benefits to be discounted @10% pa while environmental costs and benefits to be discounted at 3-4%.
- Benefits to consumers to be assessed in terms of consumer surplus.
- Benefits of employment to be assessed after deducting opportunity cost of labour.
- Costs of habitat fragmentation of human, aquatic and terrestrial wildlife.
- GHG Emissions.
- Economic costs of increase in water borne diseases.
- Costs of upstream and downstream erosion (as seen at upstream Farakka in case of dredging; and downstream Farakka in case of barrage).
- Loss of aesthetic value of river.
- Dam removal costs.
- Monetized value of impact on terrestrial and floral biodiversity.
These various costs have not been specified in the CBA to be done by the consultants.
10 Strategic Impact Assessment: The NW-1 proposal is predicated on the assumption that the overall CBA of NW-1 is better than rail and road. This assumption need to be scientifically verified by undertaking a comprehensive CBA of the three alternatives. (Please see our representations dated 26.8.2014 and 1.12.2014 for more details).
The examination of alternatives in the ESIA TOR Annex A.B.1.i has been reduced to alternative layouts.
Similarly SDS TOR Para 3.1 reduces comparison with road and rail to review of “transportation cost competitiveness including comparative analysis with road and rail.” Market-based comparison of competitiveness does not factor in the less environmental costs of rail and road; and the huge environmental costs of NW-1.
11 The IIT Consortium has strongly recommended that longitudinal connectivity of the riverbed be maintained. (Please see our representations dated 29.10.2014 for more details). ESIA TOR Para 5.1 mentions collecting data from IIT Consortium but ignores this crucial recommendation of IIT Consortium.
12 Previous studies commissioned by IWAI have focussed on the employment generated and fuel savings affected by dredging operations . (Please see our representation dated 1.12.2014 for more details). The negative impacts of dredging have been noted by IIT Consortium. These are required to be taken on board.
13 It appears that the ESIA is being undertaken without obtaining approval from MOEF as required under EIA Notification 2006. It may be that IWAI has commissioned this ESIA for obtaining the loan from World Bank and not for obtaining Environment Clearance. However, the World Bank Operational Policies explicitly require adherence to the national legal framework. Hence, bypassing the EIA Notification is not justified.
14 International Experience: The TORs do not require a review of international experience with dredging, jetties, hubs, etc. at Mississippi, Rhine and Danube Rivers. Let us not make the mistakes done by others. The TOR must include a detailed examination of international experience, developments in rivers with alluvium beds with high flows variations.
Part 2: Comments on NW-1 Studies on impacts of Barrages
15 Sedimentation of Reservoirs: Sediment deposition in the reservoirs will lead to raising the bed level in the reservoir. This will lead to huge problem of erosion as seen at Farakka; and also to less capacity of flood conveyance (Please see our representations dated 26.8.2014 and 1.12.2014 for more details).
The TORs make no mention of the need to assess the problems of Farakka and the Mississippi Waterway.
Your ESIA TOR only mentions assessment of dredging and bottom sediments at Paras 5.2.1 and Annex A.B.33. These do not account for raising of bed level of the reservoir other than the dredged portions.
16 Experience of Farakka Barrage: In Para 2.2 it is stated that flow is “now hydro-modified following construction of the Farakka barrage – it does contain numerous short radius bends. These conditions constrain year-round navigation by larger modern vessels that could deliver competitive advantage over other modes of transport.” The ESIA and SDS studies do not require examination of why similar impacts will not take place due to the proposed barrages. The river bed profile upstream of Farakka barrages should be mapped to analyze and correlate impact of new barrages .
17 Fragmentation of habitat of aquatic life: Para 5.1 of ESIA TOR mentions the need of mapping of “Known breeding and nesting grounds for aquatic species (as per Schedule I of Indian Wildlife Act).” But there is no mention of assessing the impact of dredging and making of barrages on aquatic life. (Please see our representations dated 26.8.2014 and 1.12.2014 for more details).
18 International Experience: The TORs do not require a review of international experience with navigation barrages at Mississippi, Rhine and Danube Rivers. Let us not make the mistakes done by others. The TOR must include a detailed examination of international experience.
Sir, in the light of above, We request you to:
1 Revise the ESIA and SDS TORs to include above factors.
2 Provide us copy of the Technical Feasibility Report mentioned at Annex A.B.0.
3 Provide us with names and contact details of your consultants so that we may interact with them in keeping with the spirit of public consultation mentioned in the TOR at Para 3.1.B.iii and Annex A.B.2.
4 Clarify whether the present ESIA and SDS studies are pursuant to EIA Notification; and, if not, why is IWAI bypassing the norms set by the MOEF for conducting EIA studies?
5 We request you to kindly acknowledge the receipt of this letter and inform us the actions proposed to be taken by you on this representation within three weeks of receipt of this letter failing which we shall be constrained to assume that you have not taken cognizance of this representation and take further action as may be appropriate.
Bharat Jhunjhunwala, on behalf of himself and
L V Kumar
Bharat Lal Seth
V N Sharma
The same representation was also sent to
 Water Quality Of Bhagirathi/Ganga River In Himalayan Region, National Environmental Research Institute, Nagpur, July 2011.
Terms of Reference (ToR) for Environmental & Social Impact Assessment (ESIA), Environmental Management Plan (EMP) and Resettlement Action Plan (RAP) for ‘Capacity augmentation of navigational infrastructure of National Waterway-1’ between Haldia to Allahabad (Jal Marg Vikas Project) [Uploaded on this website on 24th August, 2015] Download
Terms of Reference for "IWT Sector Development Strategy and Business Development Study for Capacity Augmentation of National Waterway-1 from Haldia to Allahabad” (Jal Marg Vikas) [Uploaded on this website on 24th August, 2015] Download
REQUEST FOR PROPOSAL Selection of Consulting Services for: Detailed Feasibility Study for Capacity Augmentation of National Waterway-1 and Detailed Engineering for its Ancillary Works and processes , Issued [9th December, 2014] Download