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Damning our Wildlife
By Neeraj Vagholikar
It was late morning on May 4, 2004, when Manju Menon and I drove
up to the dam site of the proposed 2000-megawatt Lower Subansiri
(LS) Hydel Project. The project is on the Assam-Arunachal Pradesh
border in one of the world’s biodiversity hotspots. Looking across
the gorge towards the right bank, we saw a huge pile of muck and
debris in the river. This was a clear violation of environment
and forest laws and Supreme Court (SC) orders on the project.
Local forest department staff had told us earlier that huge quantities
of muck had already been washed down the river, affecting downstream
stretches.
The spectacular landscape of the area had changed considerably
since the first time we had visited it in August 2002. Although
final clearance under the Forest (Conservation) Act (FCA), 1980,
was yet to come through at that time, construction work at the
project headquarters was on in full swing. As we already knew,
the National Hydroelectric Power Corporation (NHPC) is the only
law here. In its quest to build large dams in the fragile Northeast,
respecting environmental and social concerns (and laws) is not
a priority. The NHPC has an unusual ally – the Ministry of Environment
& Forests
(MoEF) itself!
Subansiri: river, forests, wildlife
For the last three and a half years, we have tracked the clearance
process of this project, planned on the river Subansiri, one of
the main tributaries of the mighty Brahmaputra. While the project
has raised a range of environmental and social concerns, this
article focuses primarily on its impact on wildlife. The proposed
dam site is 2.3 km. upstream of the Gerukamukh village in the
Dhemaji district of Assam, around 70 km. from North Lakhimpur.
The LS dam is the first project in a three-stage cascade plan,
Upper Subansiri and Middle Subansiri being the other two.
The project proposes to use around 4,000 hectares (ha.) of forestland,
out of which 3,436 ha. will be submerged, largely in Arunachal
Pradesh, by the 116 m. high dam. Renowned naturalist Dr. Anwaruddin
Choudhury says: “The submergence area is in the midst of a rich
biodiversity zone and part of contiguous forests comprising Kakoi,
Dulung and Subansiri Reserved Forests (RFs) in Assam and the Tale
Valley Sanctuary, Tale RF and Panir RF of Arunachal Pradesh.”
The Subansiri and Dulung RFs have been listed by the Bombay Natural
History Society (BNHS) as Important Bird Areas (IBAs). The project
office complex, labour colonies and boulder mining in the river
will have a serious impact on an important elephant-corridor immediately
downstream of the dam site. Dr. Choudhury says: “Other notable
endangered species that I have recorded in the last decade or
so in the vicinity of the dam site and submergence area are tiger,
leopard, clouded leopard, marbled cat, golden cat, wild dog, gaur,
serow, capped langur, slow loris and gharial. A skin recovered
from the Dirpai village in the region proved to be the world’s
largest known specimen of the marbled cat.”
According to Bikul Goswami, angler and naturalist associated
with the north Lakhimpur-based Green Heritage: “The Subansiri
is one of the most crucial rivers in India for the long-term conservation
of the golden mahseer. The dam will permanently obstruct the migration
of the three mahseer species found here. It will have detrimental
impacts on riverine and beel (wetland) fisheries downstream, because
the water flow regime will be affected. The seasonal inundation
of the beels by the river, which helps in the nutrient cycle of
the local aquatic ecosystem will be interrupted. The altered flow
regime will also affect downstream dolphin habitats.” On our visit
in May 2004, Bikul took us to see the river dolphins Platanista
gangetica at Khabolu-Noali, in the downstream stretches of the
Subansiri.
Shoddy environmental assessments
The Environmental Impact Assessment (EIA) report is a vital document
in the process of environmental decision-making. In the LS project,
the report is inadequate on a number of issues: biodiversity,
environmental risks, downstream impacts and impact on livelihoods
of local communities such as the Mishing tribe. It is ironic that
for a project proposed in a global biodiversity hotspot, one of
the weakest links in the EIA report is the biodiversity aspect!
There are several serious anomalies that have come to light based
on inputs from natural history experts such as Dr. Choudhury and
others.
Sample these:
* The EIA lists just 13 species of birds in an area, which has
over 200, and there are serious mistakes in this listing too.
* The EIA lists 55 species of fish even though recent records
of biologist Lakhi Hazarika indicate at least 118, including some
endemic to the Subansiri and one that is entirely new to science.
An expert committee of the Indian Board for Wildlife (IBWL) noted
in September 2002: “The EIA and project documents reveal several
shortcomings in the analysis of the project’s impacts on biodiversity.
Before taking a decision of such magnitude, it is essential that
we are provided with accurate, detailed, scientific information
from reputed sources.” Based on the recommendations of the IBWL
expert committee, the MoEF commissioned the Zoological Survey
of India (ZSI) and the Botanical Survey of India (BSI) to do an
additional study. But while the expert committee had asked for
the complete impact zone to be studied, the MoEF asked for only
42 ha. of the Tale Valley Sanctuary to be studied, a miniscule
part of the project area!
The content of these government-sponsored reports also had serious
shortcomings. For example, the ZSI report says: “It is envisaged
that the auqa (sic) fauna of the project area will be highly benefited
by acquiring the vast and long water body. The dam reservoir may
serve for fisheries development. The long and vast water body
thus created by the reservoir will be happy haunt for aquatic
creatures.” It is well known that native aquatic species whose
habitats are fast flowing rivers do not find the still waters
of a reservoir to be a “happy haunt”! While reservoirs may benefit
exotic species that are introduced for fisheries, frequently such
introduction has proved to be detrimental to native species.
Clearances and violations
Some of the permissions the Lower Subansiri dam required were:
environmental clearance under the EIA notification, 1994; forest
clearance under FCA, 1980 and clearance from the IBWL since a
portion of Tale Valley Sanctuary is to be submerged. The additional
biodiversity studies done by ZSI/BSI were presented to the Standing
Committee of the IBWL on May 6, 2003. Several members highlighted
the fact that the studies did not fulfill the IBWL expert committee
recommendations and moreover were poor in quality. They argued
that clearance could not be granted in this case.
A subsequent application in the SC by conservationist Dr. L.M.
Nath, referring to the May 6, 2003 meeting of the IBWL, had the
following to say of the MoEF’s response: “...during the deliberations
of the meeting of the IBWL, the non-official members were informed
that if the Lower Subansiri proposal is not cleared, a reconstituted
IBWL would be able to clear it in six weeks.” Under severe pressure,
the IBWL cleared the project on certain stringent conditions.
However, the minutes of the IBWL meeting were manipulated by the
MoEF to reduce the effectiveness of some of these conditions.
The project was then granted Stage I forest clearance in June
2003 and environmental clearance in July 2003. These clearances
were challenged in the SC in August 2003 as stated earlier and
some of the conditions, which had been left out by the MoEF, were
reinstated by an April 2004 order of the SC.
The IBWL was dissolved to be reconstituted as the National Board
for Wildlife as per the amended Wildlife (Protection) Act, 1972,
in September 2003. It is certainly more than just a coincidence
that all the members who had opposed the clearance of the Lower
Subansiri were dropped! These include renowned conservationists
like Valmik Thapar, Bittu Sahgal and M.K. Ranjitsinh, as well
as institutions like the BNHS, one of the country’s most reputed
organisations working on biodiversity conservation and a founder
member of the IBWL in 1952.
As mentioned earlier, an elephant corridor exists downstream
of the dam site and the project site office and ancillary construction
has already disturbed this. To add to the problem, NHPC erected
a long fence in the surrounding Subansiri RF in late 2003 to ‘protect’
its site from elephants! Not only was this completely illegal,
the fence also blocked the path taken by the elephants and increased
the possibility of human-elephant conflict in surrounding areas.
The fence was only removed by May 2004 after the Assam Forest
Department had served the company a notice.
As described earlier, we observed a huge pile of muck and debris,
which had been illegally dumped in the river instead of the prescribed
area. This despite the following SC condition: “Under no circumstances,
the excavated material will be dumped either in the river or any
other part of the National Park/Sanctuary or the surrounding forests.”
We reported this violation to the concerned authorities at the
state and central level.
NHPC has clearly regarded environmental and forest clearances
and laws as mere formalities, or at best, a necessary evil. To
add to this is the dubious role played by the MoEF, the ministry
in charge of safeguarding the country’s environment. Several organisations
from the Northeast and around the country have repeatedly written
to the MoEF about the serious problems in the clearance process
of the Lower Subansiri Hydel Project. Yet these issues have been
ignored and the clearances have continued to be granted, subverting
the letter and spirit of environmental governance in the country.
On June 23, 2004, the MoEF changed a condition in the Stage I
forest clearance letter according to which a sanctuary/national
park needed to be declared before granting Stage II (final) forest
clearance. The new condition asked for this declaration after
the granting of final forest clearance with no specified time
frame. The very next day, June 24, 2004, the MoEF issued the final
forest clearance, though some other important conditions of Stage
I clearance were yet to be fulfilled! This violation was apparently
pointed out to the MoEF by the SC-appointed Central Empowered
Committee (CEC), following which the illegal clearance was withdrawn
on July 2, 2004. Finally, the Stage II clearance was reissued
on October 12, 2004, after the conditions of Stage I clearance
were apparently satisfied.
After clearing the project based on shoddy studies, the MoEF
has asked NHPC to conduct a few detailed studies. One of the conditions
of the environmental clearance granted in July 2003 was that a
detailed biodiversity study, including the identification of wildlife
migratory routes, be submitted within one year. A year and a half
later, the study is yet to even begin.
The ‘six monthly monitoring report for the period ending September
2004’ states that the NHPC has written to the ZSI and BSI to undertake
these studies.
A multi-disciplinary committee, including wildlife and ecology
experts, set up to oversee the effective implementation of the
environmental clearance conditions has not met a single time in
the 18 months since clearance was granted! Obviously the NHPC
and MoEF are in no hurry now that the project has received all
necessary clearances.
The manner in which the fate of a critical wildlife habitat has
been decided in the Lower Subansiri case, with no respect for
either the spirit or letter of the law of the land, is shocking
to say the least. The message is clear: “Damn wildlife”.
Stop Press!
Bikul Goswami, Honorary Wildlife Warden, North Lakhimpur, reports
on the latest from the dam site:
“Blasting operations for road construction are being accompanied
by extensive muck and debris disposal in the river. Vital breeding
grounds of two mahseer species (Tor tor and Tor putitora) and
catfish Bagarius bagarius are already badly affected.
The disturbance to the elephant corridor due to a number of project
activities (including halogen lighting) has led to serious human-elephant
conflict in the villages surrounding Dulung and Kakoi RFs. Three
people were recently killed near the latter by elephants.
Illegal timber felling is on in full swing. A large number of
country and speed boats are currently involved in felling in the
upstream stretches. Handsawn illegal timber from the Dulung and
Panir RFs is being used for the project. This has been facilitated
by the new road through Dulung RF. The nesting of many bird species
such as the Hill Myna and the Great Pied Hornbill has been badly
affected in the Subansiri and Dulung RFs, due to heavy disturbance.
Mammals and nocturnal birds have been seriously impacted by the
halogen lighting.” Monitoring and enforcement of forest and environmental
laws, including Supreme Court directives, is very poor and needs
to be urgently stepped up.”
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