Concerned Citizens and Environment Action groups of Palampur have submitted detailed objections on the proposal by OM Power Project to claim Carbon Credits under the Clean Development Mechanism (CDM), to the United Nations Framework for Climate Change Convention’s (UNFCCC) Executive Board highlighting the serious damages caused by the 15 MW project to the Neogal river valley and the water supply systems on it.
Located in the Kangra Valley of Himachal Pradesh, the Neogal is a perennial tributary of the Beas river. It originates from the Dhauladhar hills and is a snow and rain fed river, forming the Neogal Watershed comprising of riverine terraces and plains fields as well. The key characteristic of the river is the heavy dependence on it for drinking water and irrigation. A traditional, well developed Kuhl (irrigation channel) system exists in the Palampur area, whereby villages have channelized water of the Neogal river for irrigation purposes. Almost 40 such large and small kuhls, managed as common property resources, have catered to the irrigation needs of over a 100 villages in the watershed. Apart from this, Palampur town and villages upto 30 Kms downstream – close to 30000 population depend on the water of the Neogal river and Bohal spring (originating in the same watershed) for drinking. Close to twelve water supply schemes are being run by the IPH on the river.
The Beas river and its tributaries are considered to have the potential to generate 4500 MW of power, most of which is now being tapped by way of 23 Large, Small and micro hydel projects, on the river. These projects are in various stages of planning, construction and operation and will have far reaching impacts on the ecology as well as local livelihood systems of the region. Two of the projects, coming up on the Neogal river include the 15 MW project being developed by Om Power Corporation and another 4.5 MW project by the Astha group of companies. Both the projects are currently under construction but the 15 MW project has been in the centre of controversy for a long time for several reasons – Initially its inability to take off on time as planned and post construction because of the degree of damage done to local water supply systems and the Neogal riverine ecology.
The project is a run of the river scheme with a 3.5 km long headrace tunnel. The TEC to the project was first accorded in 1991-92 by the CEA. At the time the project was planned by the Himachal Pradesh State Electricity Board. The MoU was signed with M/S Om Power Corporation in Aug.1993. Implementation Agreement was signed in July,1998. Draft PPA between the company and the HPSEB has been signed in Dec.1993. According to news reports, the State Cabinet approved the termination of implementation agreement signed with the M/s OM Power Corporation Ltd as the company had failed to start the construction. However, it was through exercising influence in the upper echelons of the Central and State government that the company managed to get the project re-allotted to itself despite, a two time rejection of the re-allotment proposal.
Impacts and the Situation on the Ground:
Adverse Impacts on residents near project site: The location of the project site is in the lower slopes of the Dhauladhar range of the region. The area is significantly forested with Oak, kail, chir, pine and cedar trees. The forests are used by Gaddis for grazing their sheep, though habitation is sparse in the region. There are about seven households located close to the power house site with Surdi village being the most impacted as a result of the dust, landslides (due to construction of road), loss of grazing land (due to unapproved dumping of debris) and also due to the loss of some of their land for the road construction. While they were compensated for the land, there has been no compensation/mitigation for the various other impacts these 7 families have been facing. Some of these people, especially the household of Kamla Devi, live in constant danger of boulders rolling down the deep gully that has been formed due to unscientific dumping of debris and passes just next to the habitation. Another of the critical impacts was destruction of their water tank as a result of the debris from the road construction. Another 30 families in Saan Village (also part of Bundla Panchayat) are being affected by the dust.
Blockage of Irrigation Channels: The more serious impact of the road construction and the resulting landslides has been on the several irrigation channels and water supply schemes which have got blocked or damaged due to the debris and loose falling boulders. The Kirpal Chand kuhl and the Diwanchand kuhl have been the most affected. The two kuhls together meet the irrigation needs of over 100 villages. These have either become heavily silted or have been blocked or dried up. For the last three years the Irrigation and Public Health Department, which officially governs these channels, has billed an amount of Rs 3 crores as penalty to the project proponents, who have paid up only about 9 lakhs as of today which has been utilised for some repair work. The bigger question, however, will be of supply of water to these two major kuhls, which draw their water from the location between the two projects (Om and Astha). It remains to be seen if there will be enough water to cater to the Hydropower project requirements as well as those of the drinking and irrigation water supply schemes.
Impact on Drinking Water Quality and Supply: The Neogal river water is also supplied exclusively to ward No 6 and 7 of the Palampur municipal area. The damage of the water supply systems by the project, around last year and before that had caused a shortage in local supplies. But more crucial is the question of clean water. The waste from the workers colonies of the project at the power house as well as the tunnel site is flowing untreated into the Neogal river and contaminating the water. The heavy siltation and muck in the water, especially during the monsoons makes the river highly turbid and the water dangerous for drinking despite filtration. The forests of the Dhauladhar range and the Neogal river need to be protected and conserved to ensure clean and sustained water supply but the project has disturbed the balance of this area. The Palampur Citizens Environment Welfare Forum as well as residents of the Bundla Panchayat and users of the kuhls have raised these issues over the last three years
Deforestation and Muck dumping in forest areas: While the Forest Clearance granted to the project in 2004 gave permission for felling of 660 trees and diversion of 15 hectares of land, there has been a substantial amount of destruction as a result of unscientific debris dumping during the road construction by the project. The damage to the ecology is clearly visible as eyesores on a verdant landscape from tens of Kilometres away. In June 2009 the project was fined an amount of Rs 12,90,000/for the damages caused to the forest areas due to the muck dumping and land slides.
While several promises and tall claims of eco-restoration efforts have been made, on the ground there has been virtually no mitigation to ensure stabilisation of the land slides through check walls or vegetative measures.
Can such a Project claim CDM benefits?
While there is a general concern about Hydropower Projects being touted as “green and clean” by developers in a bid to claim CDM benefits, even as the social and environmental impacts loom large, in this particular case the concerns are graver. This is because the project is being built of a river that people are very strongly dependent upon for their drinking water and livelihood needs.
The Neogal river forms an integral part of the landscape and life of the Palampur subdivision of the Kangra Valley which the project proponents have completely ignored. In fact, in their Environment Impact Assessment report as well as the PDD they conceal very important facts about the environmental and socio-cultural importance of the river for the local people.
Some of the data and information presented in the PDD for CDM by the Project proponents that is seriously problematic:
The Project is not contributing to economic and social wellbeing as claimed
To establish that the project will contribute to the social well being of the region the proponents claim “Majority of the population in the project region depend on the agriculture and animal husbandry.Their economic earning is very low. Basic infrastructure such as roads, schools, hospitals, healthcare facilities, drinking water facilities are very poor”.
These claims are highly problematic. There is hardly any population at the project site itself. Most of the communities inhabit downstream areas of the site – they have substantially better standard of living and access to infrastructure than many other regions of Himachal Pradesh and India. Palampur town is the centre, with several education institutions like the HP Agriculture University, Institute of Himalayan Bio Resources and Technology, Indian Veterinary Research Institute, Indian Grass and Fodder Research Institute and many schools. The town has a vibrant economy with many of the villagers from the nearby areas, being employed in offices or business. The claim that the proponents will bring ‘development to the area is false and misleading.
The proponents state “1.5% of the project cost would be allocated for Local Area Development by the project proponent to take up improvement measures in education, healthcare facilities, welfare facilities, preservation of culture etc.” It needs to be stated that in the last three four years no such activity has been undertaken by the project proponents in the area. Local people have no idea about the Local Area Development Fund. Even the damages caused to the pipelines and irrigation channels, were paid by the company only after there were protests and agitations and the government was put under pressure. Despite the damages claimed by the Irrigation and Public Health Department to the tune of Rs. 300 Millions, the company has only deposited Rs. 900 Thousand with it.
The Project has adverse environmental implications
The project proponents to justify their claim for CDM state “Presently major portion of energy requirement of the region is met from fossil fuel based power generation”.
This is a blatant lie!! Palampur gets its electricity supply from the Dehan Grid station which in turn gets its supply from other hydropower projects situated in the state.
On the environmental impacts the PDD states “There would be minor environmental impacts due to the construction of the project activity. In order to offset environmental impacts associated with the project activity, various environmental mitigation measures are proposed in the EIA”. The extent of impact has already been spoken of in the section on impacts. There has been no effort by the Project proponent to carry out mitigatory measures.
In one section of the PDD the proponents claim that there are “No fish in the Neogal River”. This is another blatant falsehood. The Neogal river has been listed by the Himachal Pradesh Fisheries department under its ‘Negative list for Hydel Projects’ and for “insitu conservation”. Rich in oxygen, the cold and limpid water of this river and its minor tributaries used to abound with species like the schizothorax, locally called ‘Gungli’. Other species like the snow trout and minor carps were also abundant in the Neugal. Due to excessive soil erosion and unscientific muck disposal during the construction of this project the riverine ecology and benthic fauna has been severely impacted in the last four years. While the NOC has been granted by the department for the project – the decision is seemingly more subjective than based on environmental appraisal.
The project area is culturally rich
The Project Proponents also falsely claim that there are “No religious sites or places of cultural importance in the area” They seem to have completely missed the various religious sites and temples – like Jakhni Mata, Vindhyavasini temple, Bundlamata temple and Neugleshwar Devta that exist close to the river and are culturally very critical for the people of the region.
The Project is not Additional
Let us look at some of the important dates in the life of this project:
– 1991-92 The Techno Economic Clearance to the project was first accorded by the Central Electricity Authority. At the time the project was planned by the Himachal Pradesh State Electricity Board.
– Aug 1993 The MoU was signed with M/S Om Power Corporation.
– July 1998 Implementation Agreement was signed in.
– Dec 1999 Draft PPA between the company and the HPSEB has been signed. However, according to news reports, the State Cabinet approved the termination of implementation agreement signed with the M/s OM Power Corporation Ltd as the company had failed to start the construction. However, it was through exercising influence in the upper echelons of the Central and State government that the company managed to get the project re-allotted to itself despite, a two time rejection of the re-allotment proposal.
– 2004 Forest clearance obtained.
It is clear from the above timeline that the project was under planning, consideration and active implementation much before the possibility of CDM credits became a reality in mid 2005. At no stage during the project planning, appraisal, techno economic considerations was the issue of need for CDM credits to make the project viable was either considered or mentioned. The project from this point alone, is non additional. Moreover, the project uses business as usual technology, with no additional or new features, and scores of such projects are already being constructed and operated in India without CDM credits. Thus the project is clearly non additional.
It further needs to be emphasised that with changes in climatic conditions the water flow of the Himalayan rivers, especially, snow fed and rain fed rivers has been declining steadily over the years. The water flow measures used by these hydro projects have not taken into account these important realities while planning projects on rivers that already have a high level of dependence and are becoming a scarce resource. This places doubts on the technical feasibility of hydropower projects planned on Himalayan rivers. This needs to be also examined by the CDM approval Board.
Based on all of the above, the CDM proposal for the 15 MW Neogal Hydropower project should be rejected by the UNFCCC board as it is nothing but an effort to subsidise a project which is responsible for far reaching adverse environmental and social impacts.
The UNFCCC had put up the Project document on its website for public comments the whole of the last month, as a part of its validation policy for CDM projects.