July 13, 2009
Mr. Jairam Ramesh,
Honorable Minister of State (Independent Charge), Environment & Forests,
New Delhi.
Sub: Illegal public hearing called for 3000 MW Dibang Multipurpose
project on August 6th; reject pre-construction clearance to project
Dear Mr. Ramesh,
Greetings from the Dibang Valley, Arunachal Pradesh! We write to you
on behalf of the Idu Cultural and Literary Society (ICLS) and the All
Idu Mishmi Students Union (AIMSU). ICLS is the apex body of the Idu
Mishmi community, while AIMSU is the students union. We would like to
bring to your notice a serious subversion of environmental norms by
NHPC and the Arunachal Pradesh state government while announcing the
public hearing for the 3000 MW Dibang Multipurpose project on August
6th.
As mentioned on the MoEF website, NHPC has applied for Scoping under
the Environment Impact Assessment (EIA) notification 2006 for the
Dibang project on May 28th, 2009. As per the EIA notification 2006 it
is clear that if the site is felt inappropriate on environmental and
social grounds, the MoEF based on recommendations of the EAC can
reject a project at this stage itself. The EAC may choose to conduct a
site visit in order to give its recommendations and could also choose
to give detailed Terms of Reference (ToR) for conduct of EIA studies
for the project and a clearance for pre-construction activities. It
is only after the MoEF conveys its decision to the project authority
after the Scoping stage that further steps such as ‘Public
Consultation’ may require to be taken up. That too only if
pre-construction clearance has been granted and necessary studies have
been conducted as per the ToR provided to the project authority as per
EIA 2006.
As per the MoEF website: “This proposal was considered by the EAC at
its meeting held on 16th June 2009. Additional information sought by
the committee.” Therefore it is clear that the EAC and MoEF are yet
to arrive at a final decision on whether to grant or reject
pre-construction clearance to the project. This is further confirmed
from the agenda for the upcoming July 24th EAC meeting uploaded on the
MoEF website which has the Dibang project listed as “Reconsideration
for ToR.” However, an advertisement has appeared on June 24th 2009 in
the Echo of Arunachal Pradesh, announcing a public hearing to be held
in the Dibang Valley district, on July 29th, 2009. This has been
subsequently been pushed ahead by ten days for August 6th. Therefore
a request for conduct of this public hearing would have gone from NHPC
to the Arunachal Pradesh State Pollution Control Board (APSPCB)
certainly before June 23rd, without any decision from the MoEF about
whether it plans to grant or reject pre-construction clearance! Even
if the MOEF was to grant pre-construction clearance at a later date,
studies will have to be undertaken as per the ToR granted by EAC. Such
completed studies will have to be available at least one month before
the public hearing to members of the public. However, both NHPC and
the APSPCB appear to have treated the Dibang project as a fait
accompli and announced the public hearing even before waiting to hear
from the MoEF about its final decision on the Dibang project at the
Scoping Stage! This is a serious subversion of environmental norms and
should not be allowed by your ministry. The public hearing scheduled
for August 6th should be cancelled with immediate effect.
Larger concerns
We believe that the public hearing process has become a mere cosmetic
step while granting rubber stamp environmental clearances and
appreciate the concerns you have raised in this respect recently. In
January 2008, NHPC and the Arunachal Pradesh state government misled
the PMO and got the Prime Minister to lay the foundation stone of the
Dibang project even before the public hearing processes and green
clearances were obtained. We are encouraged by the fact that you have
raised this issue (laying of foundation stones by project authorities
before green clearances) in a recent press conference held in New
Delhi.
One of the biggest threats to proper environmental decision-making on
Arunachal dams in recent times has been what you identified as a ‘MoU
virus’ in May 2008, in your earlier capacity as Minister of State for
Power. There has been a rapid signing of MoUs by Arunachal Pradesh,
both with the private sector and the public sector, even as it plans
to build 135 large hydel project. Each of these agreements is
accompanied by huge monetary advances to the government even before
the DPR is prepared, public consultations held and green clearances
obtained. For example, NHPC paid the Arunachal Pradesh government Rs.
225 crores while signing MoUs for three projects, including Rs. 150
crores for the Dibang project. How can we expect the EIA reports
commissioned by project authorities to give a honest picture when they
have already made huge investments upfront at the time of signing
MoUs? They are going to justify the project as ‘benign’ under any
circumstances. Similarly, the state government has already received
huge money upfront. This fact is going to clearly influence the
content of the forest clearance application it submits to the central
government or the manner in which it conducts public hearings under
the environmental clearance process.
The same saga continues at the stage of environmental appraisal. In
spite of Arunachal Pradesh being an ecologically and culturally
sensitive region (traversed by two global biodiversity hotspots:
Himalaya and Indo-Burma), as well as being seismically active, the
current EAC has granted clearances (pre-construction or environmental
clearance as the case may be) to every single project which come
before the committee! This is incredible! Although there are several
ministries looking at social justice issues (e.g. Ministry of Tribal
Affairs), the environmental clearance process handled by the MoEF is
the only space where detailed social impact assessment of large
development projects is supposed to be done (including public
consultations). Therefore, it assumes great significance for tribal
communities such as the Idu Mishmis. We are more than a little
surprised to see that even though these projects have mega impacts on
landscapes which are home to minority indigenous communities like
ours, there are no independent experts from the social sciences on the
EAC. While we respect the expertise of the current EAC members in
their respective disciplines, we would like to point out that the
current EAC is incompetent in assessing complex socio-cultural issues,
such as the impact of mega dams on the rights and livelihood of
indigenous communities like ours, as is evident from their
decision-making over the last two years in states such as Arunachal
Pradesh and Sikkim. We would urge you to ensure that both independent
social scientists as well representation from ministries such as
Tribal Affairs is necessary on the EAC. Since the Northeast is a
unique region and identified as a major area for new large hydro
projects, we would also like persons who understand the environmental
and social realities of the region to be part of such an expert
appraisal committee.
A public hearing was held for the Dibang project earlier in Roing,
Lower Dibang Valley district, in January 2008 (as per the earlier EIA
regime). During this hearing we had clearly pointed our opposition to
the destructive Dibang project and raised concerns about the shoddy
EIA reports prepared to justify the project. There is no point
holding public consultations when everything in the environmental
decision-making process until now seems to treat the Dibang project as
a fait accompli. Therefore, the people of the Dibang Valley have
boycotted/ blocked all subsequent attempts to hold a public hearing in
the Dibang Valley district. Except for a small political elite who
stand to gain personally from the mega investments in the Dibang dam,
the majority of people in the Dibang Valley have opposed this project
which stands to threaten our social and ecological security.
Scrap Dibang project at Scoping State itself
We urge the MoEF to take a precautionary principle approach and scrap
the Dibang dam at the Scoping Stage itself. We have already written
to you with a demand to declare the Dibang Valley an ecologically
sensitive area under the EPA, in which only ecologically and
socio-culturally sensitive development should be allowed, not large
dams. We want the Dibang river to flow free. By all counts the Dibang
Valley qualifies to be declared ecologically sensitive (details in our
application sent earlier). For example, renowned wildlife expert from
the Northeast, Dr. Anwaruddin Choudhury says: "Dibang and Lohit
valleys contain some of the last large contiguous tracts of tropical,
subtropical and temperate forests in the country. These forests have
potentially large populations of many rare species such as Hoolock
gibbon, Slow loris, Capped langur, Stump-tailed and Pig-tailed
macaques, Asiatic black bear, Malayan bear, Gaur, Takin, Leaf deer,
lesser cats, Clouded leopard and perhaps a good Tiger population. Also
many endemic and threatened birds. Many proposed dams in the area
means that no river basin has been spared to retain its pristine
glory. The downstream impact in the Brahmaputra plains could seriously
jeopardise common people's livelihood."
The population of the Idu Mishmi community is only 12,000. The kind
of development being proposed through multiple mega-hydel projects
involving the influx of a large number of outside labour (outnumbering
the locals) is contradictory to the constitutional and legal
safeguards provided to the small populations of culturally sensitive
indigenous communities of Arunachal Pradesh. The current safeguards
disallow land transfer to outsiders and regulate entry of persons in
our traditional homelands. But the current dams juggernaut will simply
dismantle this protection given to us.
We are putting down some of the issues which clearly indicate that a
precautionary principle approach is adopted and the Dibang project
scrapped at this stage itself:
Huge loss of forests and biodiversity: Over 5000 hectares of pristine
forests to be lost directly in the project. You are aware that the
Northeast is traversed by two of three global biodiversity hotspots
which cover India – Himalaya and Indo-Burma. Contrary to claims of the
company that no sanctuary is affected, there will be a major impact on
the Mehao sanctuary. The road to the dam site from Roing passes
through the Mehao sanctuary at certain places. Curently there is very
low traffic density on this road. The coming in of such a large
project will dramatically increase the flow of traffic of vehicles and
machinery for a long period of time (it is a long gestation project)
through the sanctuary. Such a massive dam involves the extraction of
approximately 32 lakh truckloads (193 lakh cubic metres) of boulders
and 16 lakh truckloads (96.5 lakh cubic metres) of sand from the river
bed (Dibang and some its tributaries). The river beds from where this
will be done are part of an Important Bird Area (IBA) – Dibang Reserve
Forest and adjacent areas - identified by the Bombay Natural History
Society (BNHS) as per international criteria. This IBA has also been
found to qualify to be a potential Ramsar site – a wetland of
international importance – by the BNHS in a recent publication on
potential Ramsar sites in the country.
Major demographic changes and socio-cultural impacts:
As indicated earlier the Idu Mishmi community is only 12,000 in
number. The old EIA report of the Dibang project states that 5800
people (labour and technical staff) will come in for the project
related activities. This seems to be a gross underestimate. The 2000
MW Lower Subansiri project being developed by the same company, NHPC,
is relatively smaller in all respects compared to 3000 Dibang MW –
height of dam, power generation, construction period etc. The EIA
report done for this project states that the total workforce (labour
and technical staff) during peak construction activity of 4-5 years
will be 15, 500 people. In a smaller project, the estimate was
15,500. How is it only 5,800 in Dibang? If one compares with Lower
Subansiri, the workforce in Dibang will be at the very least 25,000
(more than twice the population of the Idu Mishmis) staying for long
periods of time since this is a long gestation project. In addition,
the government is proposing a total of 17 large hydel projects in our
valley! Cumulatively, this will involve at least 150,000 outside
labour for long periods of time. The pressure on the rich forests of
the region due to such a large work force has to be accounted for too.
Despite fancy claims in project documents how fuel will be supplied to
the workforce, this is almost never complied with. A glaring example
is the 2000 MW Lower Subansiri project by NHPC. The pressure on the
surrounding forests (part of the Subansiri Important Bird Area) due to
illegal fuelwood collection by labour for the dam has also been
recorded in the monitoring reports of the MoEF’s regional office in
Shillong. Local green groups from North Lakhimpur have also reported
poaching by the labour force. In addition to the forests officially
diverted for the project, such pressures on surrounding areas will
also conflict with our traditional rights to these forests.
Project affected areas and persons is considerably higher than projected:
One of the major arguments made in favour of large hydroelectric
projects in Arunachal Pradesh is that there is relatively ‘small
displacement’ by submergence as compared to other parts of the
country. But a careful perusal of the ground situation indicates that
displacement is grossly underestimated both individually and
cumulatively. Shifting agriculture (jhum) is a dominant traditional
land use in the hills of Arunachal Pradesh and plays a critical role
in the livelihoods of people, maintaining agricultural biodiversity
and providing food security. Increasing pressures on land have
resulted in the shortening of jhum cycles (the length of the fallow
period between two cropping phases), thus impacting the ecological
viability of this farming system. The submergence of land by hydel
projects will further shorten the jhum cycle and enhance the pressure
on the surrounding areas, thus affecting the environment and the
livelihoods of jhum dependent communities over a much larger
landscape. In addition to the submergence, land use restrictions will
also apply in the Catchment Area of the reservoir as per mandatory
norms to reduce the siltation and increase the life of the reservoir.
The figures for the Dibang dam indicate that 4009 hectares will be
under submergence by the project. But the direct catchment area is
59,811.88 hectares (out of which 10, 281.64 hectares is degraded
forest/abandoned jhum and 3851.64 hectares is agriculture/current
jhum/habitation). The Catchment Area Treatment (CAT) will involve
land use restrictions in the direct draining catchment to reduce
siltation. What will be the population of people affected by this
restriction of land use in the direct draining catchment of 59, 811.88
ha? This is considerably larger than just the population affected by
loss of land in submergence zone.
Further, compensatory mechanisms required as per forest laws to
offset the loss of forests due to the project also lead to supposed
‘protection’ of other areas by change of tenure and access regimes to
land and resources. For example, conversion of Unclassified State
Forests (USFs) in AP, with currently greater access and control of
local communities, into Protected Forests, with greater state control.
Firstly, no compensatory afforestation can compensate the loss of
such a large area of biodiverse forest in the Dibang Valley.
Secondly, the compensatory afforestation will require twice the area
of forest land used directly in project (i.e. over 10,000 hectares) to
be converted from USFs to PFs, thus involving further acquisition of
rights from people.
Further, the whole issue of downstream impacts has been completely
ignored! Recent times have also seen grave concern being expressed
about the poorly studied downstream livelihood and ecological impacts
of large dams in both Arunachal Pradesh and neighbouring Assam. The
concerns include loss of fisheries, changes in beel (wetland) ecology
in the flood plains, agricultural losses, increased flood
vulnerability due to massive boulder extraction from river beds and
sudden water releases from reservoirs in the monsoons. But this issue
has been completely ignored by the MoEF and its EAC, although this has
been brought to the notice of the EAC repeatedly in the last two
years. All ToRs prescribed for Arunachal dams have been asked to
restrict their studies to only 10 km. downstream of the projects.
In the case of the Dibang project the extraction of 32 lakh truck load
of boulders (the first line of defence against floods) and 16 lakh
truck loads of sand will put the downstream areas at grave risk. It
will be judicious not to make such massive interventions in the
Eastern Himalayan rivers such as the Dibang.
As seen above, the impact on local communities and the environment is
well beyond what is being projected in the current decision-making
process.
Keeping the above issues in mind, we strongly urge you to scrap the
3000 MW Dibang Multipurpose project at the Scoping Stage itself.
Adoption of a precautionary principle approach is urgently required at
this point of time. We do not want the country’s tallest dam (288 m
high, approximately a 100 storey high building!) to come up in its
seismically most active region in our Dibang Valley. We cannot
compromise our social and ecological security under any circumstances.
While the MoEF considers this appeal to reject the pre-construction
clearance to the Dibang project, we hope you will call for an
immediate cancellation of the illegal public hearing announced for
August 6th.
Thanking you,
Sincerely,
Dr. Mite Lingi, General Secretary, Idu Cultural and Literary Society
Tone Mickrow, General Secretary, All Idu Mishmi Students Union
Raju Mimi, Information and Publicity Secretary, All Idu Mishmi Students Unio
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