August 13, 2015

Shri Arnab Bandopadhyay

The World Bank

New Delhi

My Dear Arnab:

We write in continuation of our earlier interactions regarding NW-1. We thank you for providing us with the TORs issued for ESIA and Sector Development Strategy (SDS). We find that the TORs do not conform to the WB OPs, at least, on the following counts:

Precautionary Principle

OP: Table B1. Use a precautionary approach to natural resources management to ensure opportunities for environmentally sustainable development.

This OP is violated on following counts:

  1. The impact of dredging and making of barrages, if any, on erosion is not covered in the ESIA TOR.
  2. The impact of making of barrages, if any, on reduced capacity of the river for flood conveyance is not covered in the ESIA TOR.

Ecosystem

OP: 4.07 - Water Resources Management: (d) Restoring and preserving aquatic ecosystems and guarding against overexploitation of groundwater resources, giving priority to the provision of adequate water and sanitation services for the poor.

This OP is violated on following grounds:

  1. The impact of dredging, and making of barrages, if any, and fragmentation of habitat of aquatic life is not considered.
  2. The impact of dredging, and making of barrages, if any, on the floral ecosystem is not even mentioned in the TORs.
  3. Creation of anaerobic conditions in the reservoirs is not examined.
    1. The IIT Consortium has pointed out that dredging leads to adverse impacts on ecological system. The TORs do not require this to be assessed.

Table A2. Assess potential impacts of the proposed project on physical, biological, socio-economic and physical cultural resources, including transboundary and global concerns, and potential impacts on human health and safety.

This OP is violated because the TORs do not require an assessment of impacts on health of the people, due to increase in water-borne diseases in particular.

Critical Natural Habitats and Non-use values

OP 4.04, Annex A - Definitions   1 (a) All natural habitats have important biological, social, economic, and existence value. (There is specific mention of rivers here.);

1b (ii) Such sites may include areas recognized by traditional local communities (e.g., sacred groves)…

This OP is violated on following counts:

  1. The Ganga has a huge spiritual and cultural value for the people of India. Modification of its flow due to dredging; modification of its aesthetic value due to running of large barges; and dredging will impact the cultural values negatively.
  2. The four Shankaracharyas are on record that no dams should be made on the Ganga. This is violated if NW-1 involves making of barrages.
  3. Creation of anaerobic conditions in the reservoirs is not examined.

OP 4.00 Environmental and Social Safeguard Policies—Policy Objectives and Operational Principles: G2. As part of the EA, as appropriate, conduct field based surveys, using qualified specialists.

  1. The aesthetic or non-use values of free flow of the Ganga are huge. In our previous representations regarding Vishnugad Pipalkoti Project the WB Management had ignored these values saying that “robust” estimates for these values were not available. It was appropriate to commission field based surveys to make “robust” estimates of these values now. However, the TORs do not even mention these values,

Risk Analysis

OP 9.0 A NEW INSTRUMENT TO ADVANCE DEVELOPMENT EFFECTIVENESS: PROGRAM-FOR-RESULTS FINANCING. 8 The environmental and social systems assessment seeks to make sure that the potential environmental and social impacts and risks are adequately addressed. These assessments will identify measures to enhance performance, build capacity, and mitigate key risks, and will be reflected in an integrated risk assessment.

This OP Is violated on following counts:

  1. The impact of possible disasters such as sinking of barrages carrying, among others, hazardous material is not required to be studied.

Comprehensive Cost-Benefit Analysis

Table B1. Determine if project benefits substantially outweigh potential environmental costs.

OP 4.00 A9. Provide measures to link the environmental assessment process and findings with studies of economic, financial, institutional, social and technical analyses of a proposed project.

OP 4.00 B1. Determine if project benefits substantially outweigh potential environmental costs.

OP 10.04 - Economic Evaluation of Investment Operations: For every investment project, Bank staff conduct economic analysis to determine whether the project creates more net benefits to the economy than other mutually exclusive options for the use of the resources in question.

The above OPs are violated because the TORs do not require a comprehensive CBA (including economic and environmental costs and benefits) to be done.

OP 10.04 - Economic Evaluation of Investment Operations: 2. The basic criterion for a project's acceptability involves the discounted expected present value of its benefits, net of costs.

This OP is violated because the TOR does not specify whether future benefits are to be discounted at all; and the rates of discount to be used. It is to be noted that IIFM has suggested that as per international norms the commercial benefits are to be discounted at bank rate while environmental costs are to bi discounted at 3-4%.

Stakeholder Analysis

OP 10.04 - Economic Evaluation of Investment Operations: 3. The project design is compared with other designs involving differences in such important aspects as choice of beneficiaries…

This OP is violated because the TORs do not require an assessment of impact of the project on poor and rich separately.

Alternatives

OP 4.00: A4. Provide for assessment of feasible investment, technical, and siting alternatives, including the "no action" alternative, potential impacts, feasibility of mitigating these impacts, their capital and recurrent costs, their suitability under local conditions, and their institutional, training and monitoring requirements associated with them.

This OP is violated because the TORs do not require an assessment of “no action” alternative.

OP 4.00: B3. Where projects adversely affect non-critical natural habitats, proceed only if viable alternatives are not available, and if appropriate conservation and mitigation measures, including those required to maintain ecological services they provide, are in place. Include also mitigation measures that minimize habitat loss and establish and maintain an ecologically similar protected area.

OP 4.01 - Environmental Assessment: 8(a) Category A:  A proposed project is classified as Category A if it is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented.  These impacts may affect an area broader than the sites or facilities subject to physical works.  EA for a Category A project examines the project's potential negative and positive environmental impacts, compares them with those of feasible alternatives (including the "without project" situation), and recommends any measures needed to prevent, minimize, mitigate, or compensate for adverse impacts and improve environmental performance.  

This OP is violated because the TORs do not require an assessment of viable alternatives such as increased transport by rail or road; or by smaller ships on NW-1. It is also violated because TORs do not require valuation of the ecological services provided by River Ganga.

This OP is also violated because the TORs do not require an assessment of impact of break in longitudinal connectivity due to making of barrages, if any. The IIT Consortium has strongly recommended that longitudinal connectivity should not be broken.

OP 4.04, Annex A – Definitions: 1 (e) Appropriate conservation and mitigation measures remove or reduce adverse impacts on natural habitats or their functions, keeping such impacts within socially defined limits of acceptable environmental change. Specific measures depend on the ecological characteristics of the given site. They may include full site protection through project redesign;

This OP is violated because the TORs do not require the Consultants to provide suggestions for project redesign such as transport by smaller ships.

OP 10.04 - Economic Evaluation of Investment Operations: 3. Consideration of alternatives is one of the most important features of proper project analysis throughout the project cycle.

These OPs are violated because comprehensive CBA including commercial and environmental costs and benefits of alternatives such as (1) locating thermal plants on the sea coast; (2) increased transport by rail or road; and (3) shipping by smaller ships; are not required to be done.

Transboundary Impacts

Table A2. Assess potential impacts of the proposed project on physical, biological, socio-economic and physical cultural resources, including transboundary and global concerns, and potential impacts on human health and safety.

This OP is violated because the TORs do not require assessment of impact of the project on Bangladesh.

ESIA before DPR

The entire exercise is vitiated because the Pre Feasibility Report has not been provided to various stakeholders including the undersigned signatories. It is not clear from the two TORs whether the PFR has been approved by the World Bank and IWAI at all. In the result, the undersigned, in part, are shooting in the dark.

It appears, moreover, that IWAI is proceeding with the ESIA study without obtaining scoping clearance from MOEF under EIA Notification 2006, hence the entire process is illegal.

Request

In view of above submissions we request:

  1. A meeting may be called by the World Bank to enable us place our concerns before yourselves.
  2. Provide us with PFR of the project.
  3. Provide us with contact details of the Consultants for the TORs enable us interact with them. We have requested IWAI to provide these details but are unsure whether they will supply the same.

Yours truly,

Bharat Jhunjhunwala, on behalf of himself and

L V Kumar

Bharat Lal Seth

V N Sharma

Debadityo Sinha

Paritosh Tyagi


Important Documents

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

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