BUNGLING OF POLAVARAM DAM

Notice from Union Ministry of Environment to AP State on Bungling of Polavaram dam

http://www-wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2000/07/28/000094946_00071805314844/Rendered/PDF/multi_page.pdf
(World Bank report on Dam Safety  in India finds that several states  and the Central Water Commission do not seriously specialise in estimating the critical parameters for Dam safety  as in other countries like USA)Forest Clearence Questioned:
http://www.hindustantimes.com/52-Andhra-villages-give-Polavaram-a-red-signal/Article1-629031.aspx

CWC Chairman from India,Mr. Bajaj refers to dam safety in India where there are more than 4000 large dams, with many more planned. The authors present some interesting fi gures  for large dams worldwide, showing that in the period 1930 to 1965 there were 81 failures, or about 2·3 failures per year. If we assume that there are about 50 000 large dams in the world, this implies an average return period for failure of about 22 000 years, although it is probable that this return period has increased since 1965. It seems from the paper that there have been 26 failures in India in the period 1951–2002. Using the present number of dams (4000) this implies a return period for failure of about 8000 years in India.

http://www.thomastelford.com/journals/DocumentLibrary/18-39BDS145933.pdf

Hundreds of dams failed all over the world

Many ignorant people and even engineers blindly believe that the dams do not fail at all.It is wrong.

Infact hundreds of dams failed in several countries including about 45 dams in India.  Among the dams are the concrete dams, masonary dams, earth dams and rockfill dams.  For details see the following websites.

http://www.usbr.gov/pmts/hydraulics_lab/pubs/DSO/DSO-98-004.pdf (See pages 56 to 60)

https://sites.google.com/site/ayyagaribhujangarao/damcollapses

http://nptel.iitm.ac.in/courses/IIT-MADRAS/Hydraulics/pdfs/Unit41/41_2.pdf

SECTION-I :  INTRODUCTION

http://tshivajirao.blogspot.com/2010/07/why-dr-klrao-warned-about-collapse-of.html

While there is an urgent need to harness the surplus Godavari waters that are wastefully flowing annually into the Bay of Bengal the officials and Engineers of the AP State Government and the Government of India are utterly mishandling the Planning, Designing and execution of the Polavaram project by employing the wrong methods of development in place of the right methods of development.  The former Prime Minister Mrs.Indira Gandhi while commenting on the Tehri dam project after visiting the project site and holding discussions with the local people, realised that major projects are usually carelessly planned  to benefit the vwested interests at any cost and   sent  a warning note on the inherent hazards of  hastily  planned major irrigation  projects  without taking the public into confidence(See page 13 of the Guidelines for Environmental Impact Assessment of River Valley Projects, Ministry of Environment and Forests, January, 1985)

 Prime Minister  sent her views to the Secretary, Department of Science and Technology in March, 1980:

“There are several proposals which were agreed to earlier but would need to be looked into again.  Amongst them are Silent Valley, the Dam in Tehri Garhwal and the Dam in Lalpur, Gujarat.  It seems that larger areas of very fertile land are being submerged without any commensurate gains.  There may be other such cases also.  It is true that these decisions have been taken over a period of time, but there is great local distress and feeling that contractors and other such groups will be the main gainers.  Hence it is necessary to have another look in depth.”

In the present case of polavaram dam project  almost all the old-generation experts of the Central Water Commission and others suggested for Godavari water diversion into Krishna river by constructing a reservoir dam at Inchampalli and other storage reservoirs  on the tributaries like Indravati and Pranahita.  Since 1978 the  moral attitude of politicians, bureaucrats and engineers shifted from  public interest towards   immoral  and money- making attitude.  Consequently the Polavaram barrage which costs less and  so provides normal money returns to the people behind development was changed  from the conventional project into  a money spinning mega project  under some pretext and in the process the Polavaram project was artificially converted into a  big storage dam in August 1978 when the officials, engineers and contractors under the leadership of Dr.M.Chenna Reddy virtually forced the Karnataka state with a vested interest to enter into agreement on Polavaram project by insisting that subject to the condition that the full reservoir level of the project is fixed at +150ft above Mean Sea Level, 80 TMC of Godavari water will be transferred into Krishna river obviously for free utilization by Karnataka and Maharashtra.  Particularly when   such an agreement  adversely effects the interests of Orissa and Madhya Pradesh (Chattisgarh) .Although Orissa and Chattisgarh Chief Ministers insisted that the submersion in their states at Konta and Motu shall not exceed +150ft MSL the AP state Government  managed to argue in February, 1980 before the Bachawat Tribunal that unless the FRL for Polavaram dam is fixed at +150ft there is no question of transferring Godavari water into Krishna river and further insisted that the submersion levels in Orissa and Chattisgarh must be permitted upto +174.22ft. for a peak flood of 36 lakhs  cusecs and  the award stipulated that if any changes were to be made in the conditions of the Bachawat Award the consent of the upper states must be obtained.

After a lapse of 26 years of the Bachawat Tribunal Award isome critical conditions were changed by the AP State unilaterally without obtaining the consent of the upper states  as per rules particularly when the spillway design flood was changed from 36 lakh cusecs in April 1980 to 50 lakh cusecs in August 2006 and consequently the submersion levels in Orissa and Chattisgarh got changed from +174.22ft. to +182 ft. as stated by the AP State in February 1997.or to +195 ft.as per independent expert's assessment  The spillway gate operation schedules also have to be correspondingly changed after obtaining the consent of the upper states.  For ensuring the safety of the project the spillway design has tobe changed to handle the outflow discharge of 50 lakh cusecs and the corresponding changes have to be made to accommodate for the flood flow downstream of the dam by increasing the heights of the downstream river flood banks for hundreds of kilometers length from Polavaram to Bay of Bengal to avoid breach of the existing flood protection works

First of all as per International standards the design of the dam should not be considered only from the structural safety  as perceived by Civil Engineers but also from Environmental safety  angle based upon the hazard potential downstream of the dam .The eastimation of Hazard Potential which has not been done as per rules for polavaram dam has to bebased upon the results of the Disaster Management Plan orEmergency Action Plans [EAP]to be put in operation due to a dam break and risk analysis consequent to extreme floods, earthquakes, construction defects and human failures in operation of the flood gates during a cyclonic storm. These Reports were never prepared forPolavaram Dam although they form crucial components of Environmental Impact Assessment[E I A] report fto get Environmental clearence.see  web site:[May 2006]
which contains allprocedures to be followed to ensure safety of the dam and the people to be benefitted
http://www.cwc.gov.in/main/downloads/EAPChapters.pdf
The experts if they are genuine must take into consideration whether the proposed storage reservoir can handle the inflow design flood based upon the spillway design flood of 50 lakh cusecs because the inflow design flood will be about 75 lakh cusecs and based upon the rugosity of the downstream area if the peak floods can be contained within the flood banks or they will get washed away killed about 50 lakhs people in the delta region and causing an economic loss of more than one lakh crores of rupees.  The arguments by the irrigation Minister and Secretary to the Irrigation Department of AP State Government show that they don’t have adequate knowledge on the Planning and design of spill-way floods based on hydrological and environmental safety as per International design standards propounded by Prof.L.Berga.president of ICOLD[see pages 1099 to 1104 of the following  web site  on Int'l symposium]
:http://books.google.co.in/books?id=3JWS_gHcFt4C&pg=PA1050&lpg=PA1050&dq=Berga+on+Dam+safety,1998,vol.2&source=bl&ots=p0y0LI69CH&sig=PUjYut6fluJC5vQmxyED9GW2oMY&hl=en&ei=9dWxTOXtFIHCcbOxobsL&sa=X&oi=book_result&ct=result&resnum=4&ved=0CCAQ6AEwAw#v=onepage&q&f=false
Similarly the A.P.state Government and Union Government officials have never debated  as per rules on the
alternate proposals like the multiple barrages suggested by Sri.T.Hanumantha Rao, former Engineer-in-Chief of the Irrigation Department of Government of Andhra Pradesh which will be not only safe but economically cheaper, socially acceptable and technically sound for ensuring sustainable development of the different regions of the AP State.   state and Central Government officials and Engineers fignored the   international norms for dam safety as reflected in the following extracts from the U.S. publication on Dam safety.

Selecting and Accomodating Inflow Design Floods for Safety of Dams April 2004

http://www.fema.gov/library/viewRecord.do?id=1828  [ Down Load from this web site pages ,19-21]

There have been about 200 notable dam failures resulting in more than 8,000 deaths in the Twentieth Century. Dam failure is not a problem confined to developing countries or to a compilation of past mistakes that are unlikely to occur again

The consequences of dam failure may not be acceptable if the hazard potential to these habitations is increased appreciably by the failure flood wave or level of inundation. When a dambreak analysis shows downstream incremental effects of approximately two feet or more, engineering judgment and further analysis will be necessary to finally evaluate the need for modification to the dam. In general, the consequences of failure are considered acceptable when the incremental effects (depth) of failure on downstream structures are approximately two feet or less. However, the two-foot increment is not an absolute decision-making point. Sensitivity analyses and engineering judgment are the tools used in making final decisions.

For example, if it is determined that a mobile home sitting on blocks can be moved and displaced by about six inches of water, then acceptable incremental impact would be much less than two feet.

As a second example, if a sensitivity analysis demonstrates that the largest breach width recommended is the only condition that results in an incremental rise of two feet, then engineering judgment becomes necessary to determine whether a smaller breach having acceptable consequences of failure is more realistic for the given conditions, e.g., flow conditions, characteristics of the dam, velocity in vicinity of structures, location, and type of structures

In addition, the selection of the appropriate magnitude of the IDF may include consideration of whether a dam provides vital community services such as municipal water supply or energy. Therefore, a higher degree of protection may be required against failure to ensure those services are continued during and following extreme flood conditions when alternate services are unavailable. If losing such services is economically acceptable, the IDF can be less conservative. However, loss of water supply for domestic purposes may not be an acceptable public health risk.

Flood frequency and risk-based analyses may be used to hold operation and maintenance costs to a reasonable level, to maintain public confidence in owners and agencies responsible for dam safety, and to be in compliance with local, state, or other regulations  applicable to the facility.

Generally, it would not be an appropriate risk to design a dam having a potential for failure at a flood frequency of less than once in 100 years.

When determining the effect flood inflows will have on dam safety, a hydrologic approach may be used. Simply stated, when determining the effect flood inflows will have on dam safety, the following approach establishes the IDF for the project, and either:

•                      determines whether an existing project can safely accommodate the IDF; or

•                      determines how a new project will be designed to safely accommodate the IDF.

 Following extracts of the articles by different  Qualified  scientific and technical experts  and the objections raised by  experience and qualified environmentalists against the environmental clearances given to the project show that both the state and Central Government are creating confusion by mishandling the project for benefiting more the politicians, officials, engineers and contractors while simultaneously greatly harming the interests of the lakhs of tribals, poor people and farmers of the state.That is why the  intellectuals have to study the web site below to grasp how the design of polavaram is defective
 http://books.google.co.in/books?id=3JWS_gHcFt4C&pg=PA1050&lpg=PA1050&dq=Berga+on+Dam+safety,1998,vol.2&source=bl&ots=p0y0LI69CH&sig=PUjYut6fluJC5vQmxyED9GW2oMY&hl=en&ei=9dWxTOXtFIHCcbOxobsL&sa=X&oi=book_result&ct=result&resnum=4&ved=0CCAQ6AEwAw#v=onepage&q&f=false

An NGO organization SAKTI of Hyderabad with the collaboration of World Wildlife Fund (India) and WWF Project Dialogue on Water, Food and Environment, C/o ICRISAT, Hyderabad organized a workshop on Perspectives on Polavaram at Hyderabad on 7^th August 2006 and the connected papers were published in a book entitled “PERSPECTIVES ON POLAVARAM” published by Economic Foundation, New Delhi.  The points of view presented by the proponents of the dam and opponents of the dam are presented here briefly to show how the proponents of the dam blindly spent more than Rs.3000 crores of public funds without getting the basic permissions for the project as required by the rules and regulations.  The opponents of the dam highlighted the various blunders being committed by the state Government officials, engineers and the Ministers in Planning, Designing and execution of the project even though it proved to be not only a killer dam but also ecologically unsound and economically unviable    and ultimately unproductive resulting in economic disaster not only for people of Andhra Pradesh but the people of the Indian Nation.
For more details see the following website:
http://tshivajirao.blogspot.com/2010/07/why-dr-klrao-warned-about-collapse-of.html 

http://tshivajirao.blogspot.com/2010/06/why-inevitable-collapse-of-polavaram.html
EIA NOTIFICATION OF 2006:        http://envfor.nic.in/legis/eia/so1533.pdf

WHY STATE AND CWC EXPERTS FAILED TO ADOPT SAFETY STANDARDS IN DESIGN ?
http://www.usbr.gov/gp/ecao/horsetooth_carter/horsetooth_safety_dams/mod/chapter3.htm
http://sites.google.com/site/profshivajirao/polavaramdam-0

CWC Guide Lines For Spill-way Design Floods For Safety of Dams

http://www.cwc.gov.in/main/downloads/Safety%20inspection%20of%20dams.pdf

The Indian Standard IS : 11223 – 1985 “Guidelines for fixing spillway capacity” gives the criteria for inflow design flood as under:

The dams may be classified according to size by using the hydraulic head (from normal or annual average flood level on the downstream to the maximum water level) and the gross storage behind the dam as given below.

The overall size classification for the dam would be greater of that indicated by either of the following two parameters:

----------------------------------------------------------------------------------------

Classification                  Gross Storage                                         Hydraulic Head

Small                 Between 0.5 & 10 million m3                                         Between 7.5 m & 12 m.

Intermediate       Between 10 & 60 million m3                                        Between 12 m & 30 m.

Large                   Greater than 60 million m3                                           Greater than 30 m.

-------------------------------------------------------------------------------------------------------

The inflow design flood for safety of the dam would be as follows:

---------------------------------------------------------------------------------------------------                                                               

 Size as determined                      Inflow design flood

                                                          for safety of dam

Small                                            100 year flood

Intermediate                                  SPF

Large                                            PMF

--------------------------------------------------------------------

Floods of larger or smaller magnitude may be used if the hazard involved in the eventuality of a failure is particularly high or low.

The relevant parameters to be considered in judging the hazard in addition to the size would be:

(i) distance to and location of the human habitations on the downstream after considering the likely future developments.

(ii) Maximum hydraulic capacity of the downstream channel at a level at which catastrophic damage is not expected.

For more important projects, dam break studies may be done as an aid to the judgement in deciding whether PMF needs to be used.

Where the studies or judgement indicate an imminent danger to present or future human settlements, the PMF should be used.

 Any departure from the general criteria as above on account of larger or smaller hazard should be clearly brought out and recorded.

Each site is individual in its local conditions and evaluation of cause and effects. While, therefore, the norms mentioned above may be taken as general guidelines, the criteria could be varied in special cases where the same are justifiable on account of local conditions and keeping in view the hazard potential.

When a dam capable of impounding large quantity of water is constructed above an area having extensive community, industry and agriculture, a distinct hazard from a possible failure is created. The failure of a dam so located would have disastrous effects. In addition to loss of life, loss to property, loss of revenue from the project, the deliberate acceptance of a

calculated risk in the spillway design and free board would reduce the public confidence in the safety of similar structures.

The spillway capacities and free board allowances of such a dam should be adequate to insure against failure of the dam during the most severe flood or sequence of floods considered reasonably possible, irrespective of the apparent infrequency of occurrence of controlling conditions.

In determining the spillway capacity of relatively low dams and which do not have large storage capacity, where possible failure would not result in serious danger to life and property, (taking into account future development) a less severe condition may be adopted.

 The selection of spillway capacity would be governed by overall economic considerations, such as cost of replacing the dam, maintenance and loss of revenue when the project is impaired. The margin of safety may be made consistent with economic analysis.

Experience data

In some cases where design data are lacking, an evaluation of overtopping potential may be based on watershed characteristics and rainfall and reservoir records.

 An estimate of the probable maximum flood may also be developed from a conservative,generalized comparison of the drainage area, size and the magnitude of recently adopted probable maximum floods for dam sites in comparable hydrologic regions.

Where the review of such experience data indicates that the recommended spillway design flood would not cause overtopping, additional hydraulic and hydrologic determinations will be unnecessary.

SECTION-2 : ARGUMENTS FOR AND AGAINST THE POLAVARAM DAM

I.  Hon’ble Sri.Ponnala Lakshmaiah, Minister for Irrigation, Government of Andhra Pradesh in his presentation traced historical developments on Polavaram project.

The disastrous floods in 1953 prompted formulations for construction of the dam near Ippur situated 56km u/s of Polavaram and a diversion structure near Polavaram so that the storage component will be at Ippur and the irrigation component will be at Polavaram.

In November, 1965, a technical committee headed by AC Mitra examined the question of new barrage at Dowlaiswaram versus a barrage at Polavaram .  The committee also stressed as an obligatory that another barrage at Polavaram would be required for irrigating the uplands.

To avail the agreed share of water to Andhra Pradesh an investigation was taken up in 1976 for Polavaram project by forming a new circle at Rajahmundry.  On examination of various alternatives, two proposals were crystalised.  1) barrage/diversion gated structure on permeable and adorable foundations, and 2) spillway on rocky foundation in the flank saddle.

The barrage with 10ft and 12ft height gates did not serve the purpose at Polavaram, as waters to serve upland had to be raised by 100ft and as such it was deferred.  It was opined to go for spillway of adequate height fitted with gates.

Andhra Pradesh, Madhya Pradesh and Orissa entered into an agreement in April 1980 on design and operation of Polavaram project.  This has been filed before the CWC.  Based on it, a project report was first submitted to the CWC in 1983.  A comprehensive detailed project report (DPR) was submitted to CWC in 1987.  The DPR has been updated and submitted to the CWC in 2000.  A total 73 sets of comments have been received from the CWC and all the comments have been attended and replies submitted from time to time.  A primary report was submitted to the CWC in June 2005.  A certificate to the effect of non requirement in principle consent was issued by the CWC on August 29,2005.

Project Benefits:

a.       The project provides irrigation to the command area of 2.91 lakh ha (7.194 lakh acres) in 54 mandals of Krishna, West Godavari, East Godavari and Visakhapatnam districts.

b.      Sustainable increase in agricultural production

c.       Assured drinking water supply to Visakhapatnam city, steel plant and enroute villages.

d.      Diversion of 80 TMC of Godavari water into Krishna river benefiting 45 TMC of water in Andhra Pradesh

e.      Provides recreation facilities and enhances pisciculture etc.

II. Dr.Biksham Gujja et.al International Environmental Expert in his paper ON COSTS EXCEED BENEFITS” established that the cost of the Polavaram dam far exceeds the benefits to be conferred by the hazardous dam. The extracts from his paper are presented here to show how the farmers are going to be burdened with the costs of this dam---
Taking into consideration of the following figures and the costs quoted in the document, the cost of water delivery for 1000Mcum has been calculated

• Dam (headworks) : Rs.3532.91 crores (Rs.35,329 million)

• Left main canal : Rs.1268.26 crores (Rs.12,682 million)

• Right main canal : Rs.1613.01 crores (Rs.16,101 million)

• Rehabilitation : Rs.4500.00 crores (Rs. 45,000 million)

Further analysis of the figures given in project document is presented below:

a. Cost of irrigation as per all the figures in the proposal

Total project Cost : Rs.10,900 crores
Cost of irrigation component : Rs.7,300 crores (two-thirds of the total cost)
Area to be irrigated : 2,91,000 ha (as indicated in the proposal)
Cost of per ha. irrigation : Rs. 2,50,000 (Taking 2,90,000 ha)

b. Cost of irrigation by taking into consideration of revised budget and actual area to be irrigated based on additional land available in 54 mandals for irrigation.
Total Project cost : Rs.14,000 crores
Cost of irrigation component : Rs.9,330 crores
Actual Area to be irrigated : 1,00,000 ha (This is far higher than by many studies)
Real cost of irrigation per ha. : Rs.9,33,000
c. Cost of water delivered to irrigation
Total water project is estimated :8130 Mcum(287 TMC)
to provide for all uses

Water allocated for irrigation :5,000 Mcum (187 TMC)
Capital cost of water with
Revised budget :Rs.1860 crores/1000 Mcum
Capital cost of water per TMC : Rs. 40-50 crores.
This is again without considering the following aspects:
• Loss of production due to submergence.
• Loss of production on the area lost to the canals
• Loss of production I the downstream due to salinisation, etc.
• Reduced water capacity of the dam due to sedimentation.
• Loss of production due to other ecological consideration.

So it is essential to recalculate the cost of this project while taking into consideration of the final decision on the dams. With existing data, the basic cost calculations suggest that it is going to be one of the most expensive irrigation projects in the country and in the world even. One would question – is it wise enough to spend Rs.9,33,000 to irrigate one ha of additional land? Even the lower estimate of Rs.2,50,000 per ha seems to be too high.
 III. Sri.R.Vidyasagar Rao, former Chief Engineer and Member of the Central Water Commission, Government of India in his paper published in the Perspectives of Polavaram under the title “VIOLATION OF NORMS”as proved that Polavaram dam is not only abnormally costly but its economic impacts are very negative.---
The Polavaram project envisages providing irrigation to 7.2 lakh acres besides providing power generation of 960 MW and diverting 80 TMC of water to Krishna basin and supplying 23.44 TMC of water to Visakhapatnam city and enroute villages. But, Polavaram project is not the only way to achieve all these things. Already, there are a few schemes namely, Chagalnad Lift Irrigation Scheme, Yeleru scheme, Torrigadda scheme which provide for irrigation to an extent of 1.26 lakh acres to the same ayacut of Polavaram. Apart from these, the government has recently launched two new schemes –Pushkara Lift Irrigation Scheme and Tadipudi Lift Irrigation Scheme to provide irrigation to 3.92 lakh acres of the same ayacut. These two schemes are being executed at a cost of Rs.685 crore. Further, one more scheme, Venkatapurm pumping Scheme is also under construction at a cost of Rs.97 crore to provide irrigation to 36,000 acres. Thus , all these schemes put together provide irrigation to 6.54 lakh acres of Polavaram ayacut. A balance of 67,000 acres is remaining to be provided with irrigation water. This can easily be covered by another lift irrigation scheme at an additional cost of Rs.300 crore. The canal at Tadipudi is designed to carry flows upto 12.6 TMC of water presently . This can be widened to carry an additional flow of 80 TMC required for Krishna delta. This may require another Rs.500 crore.
On the same lines, Pushkara scheme too can be widened suitably to carry additional flow of 24.44 TMC of water required for Visakhapatnam city and this may call for an additional expenditure of Rs.300 crore. Thus, a mere Rs.1900 crore would be adequate to cater to the irrigation, drinking water and industrial water and other diverse requirements. So easily the government can save about Rs.14,100 crore of public money, by restoring to these measures in lieu of executing the present mega project at Polavaram.
IV. Sri.Nagendranath Yerneni, former Chairman of the Krishna District Drainage Board of AP Government and Sri. Venkat Naagesh, a young US educated Environmental Activist in their paper in Perspectives on Polavaram published under the title “MODIFICATION NEEDED” have emphasized that the Polavaram dam project has serious economic and environmental backlashes particularly in the delta areas and that the project is economically unviable and ecologically destructive----
DUPLICATION OF AYACUT DUE TO TAKING UP TADIPUDI AND PUSHKARAM LIS PARALLEL TO POLAVARAM CANALS:
The government is implementing the Tadipudi and Pushkaram lift irrigation schemes to irrigate 3.92 lakh acres of the proposed 7.2 lakh acres total ayacut of Polavaram. The cost of these schemes is Rs.700 crores and their cost benefit ratio is 6.64:1 as opposed to Polavaram’s 2.8:1 after 10 years. The canals are proposed to be dug parallel to the Polavaram canals with an FSL of 3 m and a capacity of 1,500 cusecs as opposed to the FSL of 5m for Polavaram canals and a capacity of 17,500 cusecs. Unnecessarily excavating two parallel canals instead of one is going to crease more drainage problems, seepage problems damaging the lining of the Polavaram canals, and resulting in more wastage of valuable land and loss of crop. It will also result in severe water logging and flooding upstream of the canals and is an unnecessary wasteful expenditure.
http://saiindia.gov.in/cag/sites/default/files/andhra/rep_2009/civil_chap1.pdf  
(See Pages 73 to 75)
Comptroller and Auditor General faulted AP State Government for including the about 2 lakh acres of  land coming under Pushkara Lift Irrigation scheme sanctioned by Planning Commission at a huge cost is again included under the Polavaram command area.  When the State government was questioned about this irregularity the state Governsment replied that they will disband the pumping units and pipelines and use them elsewhere after polavaram project is completed but the Auditor General refused to accept such lame excuses and did not accept the reply.  Similarly another 2 lakh acres to be covered by Polavaram project is also under irrigation by the lift scheme at Tadipudi on Godavari river thus 4 lakh acres already being cultivated under 2 major lift irrigation schemes is again shown under the catchment of Polavaram project to mislead the central Government agencies to manipualte the figures to show a favourable cost benefit ratio without which the project will become economically very unviable and cannot be sanctioned by the planning commission or other Ministries of the Union Government.
 

V. Sri.B.V.Raghavulu , a highly educated political leader and Politbureau member and state Secretary of Communist Party in his paper under title “A Thorough Review Needed” presents the facts on how the Government has bungled on Polavaram dam.

1.       The government has not undertaken any studies on alternative models that obviate this bigger submersion.  In fact may eminent engineers have suggested alternative designs, which would not cause any loss of scheduled areas.  But the government would not consider any of them and stick to an old design conceived way back in 1980-1982.

2.       Moreover, for reasons best known to it, the state government has furnished inaccurate information to the Government of India on various aspects of the project.  For instance, the number of displaced people as per the site clearance (September, 19, 2005) was 1,17,034.  But according to an environmental clearance (October, 24, 2005) it was 1,93,357.

3.       Likewise, the land to be acquired for the project according to the GO No.93, (dated May 24, 2005), was 75,177 acres.  But under an environment management plan (EMP) submitted to the Government of India later the area was shown as 1,55,182 acres.

4.       So is the  case with the ayacut .   According to a G.O.No.93 issued in May 2005the ayacut was shown as 23 lakh acres. In the Environmental clearance it was shown as 7.2 lakh acres.  But again, in anaffidavit submitted to the High Court the figure was mentioned as 23 lakh acres.  As the ayacuts of Pushkaram (1.86 lakh acres), Tadipudi (2.06lakh acres) and Chagalnadu(0.50 lakh acres) are part of the ayacut of Polavaram there is no reason to show the same area twice.  So, even while calculating the cost benefit analysis it is clear that the total 7.20 lakh acres of ayacut are that of 4 projects. Not just that of Polavaram alone.

5.       It appears that the Department of Environment and Forest, Government of India has not granted the Environmental clearance to this project with due diligence.  The proposal for clearance was submitted on Oct.19, 2005 and an experts committee considered and cleared it on Oct.25, 2005 – in just 6 days.

6.       The Government policy speaks of exploring not displacing or least displacing alternatives to minimize displacement.  In addition as per schedule-II of Ministry of Environment and Forests notification dated April 10, 1997 examination of alternatives before selecting a specific proposal is required.

VI.  Sri.Sana Maruthi is a reputed former Chief Engineer for Irrigation to the Government of Andhra Pradesh and is a spokesman for one of the major political party Telugu Desam on Irrigation projects and he demanded for better alternatives for Polavaram dam:

To suit the interests of the displaced, any modifications, including change of the project site, can be taken up.  However, we are also keen that the basic objectives of irrigating 7.2 lakh acres and diverting 80 TMC of water to Krishna delta cannot be compromised, by these modifications.

Coming to the canal works of the Polavaram project, the government is not providing satisfactory answers to many questions.  Originally, both right and left canals were supposed to be built with the size of 10,000 cusecs each (with minor variation).  But, without consulting anyone, the government has increased the canal capacity to 17,500 cusecs on each side, this is nothing but doubling the size of canals.  The TDP is strongly opposed to this unilateral increase in the canals size and capacity.  There shall not be any increase in the proposals already submitted to the CWC.  When we pointed this out, the government gave a feeble answer that these canals were meant to cater to eight lakh acres of ayacut on either side which would be created in future.  This was in fact, mentioned in the last assembly budget session (2005).  In the scope of the works section of Polavaram project the government showed the total ayacut as 23.22 lakh acres.  This is all the more preposterous and completely goes against the basic objectives of the project.   These kind of actions on the part of the government fuel regional animosities and imbalances.  Moreover, this increase in ayacut is totally uncalled for as there is no land to be converted into ayacut, even in future. 

Anyone who visits Tadipudi and Pushkaram lift irrigation schemes on either side of Godavari river, that run parallel to left and right canals of Polavaram project would notice that the government has been wasting huge sums of public money on canal excavation works.  In fact these two lift schemes were initiated a few years ago as then it was thought that Polavaram project  might take a lot of time in view of interstate objections and the displaced issue.  But as now the government is gearing upto launch the Polavaram project works, there is no need to spend a lot of money, at least Rs.750 crore, on these two lift scheme canals.  The governsment’s answer that the canals of these lift schemes would be utilized in future, as distributaries of Polavaram canal are absolutely foolish.  The width of these canals is also so huge that the water carried by them would meet the requirements of double the projected ayacut.  If Tadipudi canal carries 1 TMC of water to irrigate 11,000 acres, the same left canal of Godavari carries 1 TMC  of water to irrigate 3,500acres.  These Polavaram canals take away two to threefolds of the actual requirement of the ayacut.  This is highly objectionable.  The government says that these canals require carrying more water because there is a possibility that the saline water from sea may maroon the fields.  This is utterly false.

When about the 15 lakh acres of ayacut in downstream Godavari delta does not face the problem of saline water, how will this upland ayacut face it?  The government seems to be hiding facts or it does not have proper answers to provide.  Either way, it is highly irresponsible and atrocious, on the part of the officialdom and the political leadership that execute the project.

VII.  Sri.Satish Chandra, IAS, Secretary for Minor Irrigation and CAD, incharge of Polavaram project, Government of Andhra Pradesh in his paper on “Doubts unfounded” presented his views for justifying the actions of the State Government which are based

1.       To a major question whether Andhra Pradesh is following the letter and spirit of Bachawat Award in constructing Polavaram project, the official asserted that the this is yes.

2.       An inter-state agreement with the basin states was reached in 1980 on the project.  Salient features of this agreement are 1) to build a dam with +150ft height, 2) to maintain water levels in Godavari river while constructing the reservoir, 3) to pay compensation to the submerged areas in neighbouring states, and 4) to ensure protection to the areas above 150ft level in other states either by constructing a protection wall of by paying compensation.

3.       This agreement has been incorporated in the Bachawat Tribunal award and this was taken note by the Central Water Commission (CWC).  As now there are no fresh interstate disputes on the Polavaram project there is no necessity to obtain clearance from any of these states.  So it is beyond doubt that the Polavaram project is being taken up in tune with interstate agreements and Bachawat Tribunal Award.

4.       Another question is whether the CWC has approved the design and operation schedule of Polavaram project?  The Spillway of Polavaram project has been designed as per the interstate agreement in 1980 between Andhra Pradesh, Madhya Pradesh and Orissa.  There is no violation of either interstate agreement or Bachawat Tribunal award in this regard.

5.       There seems to be some confusion on the state of clearances to the Polavaram project.  So far, we have obtained three clearances.  First is the site clearance.  The state government has applied for site clearance to the Union environment and Forest Ministry on March 23, 2005.  Subsequently, the Ministry sent a committee of experts to visit the site and submit a report.  Based on the committee’s report, the Ministry has granted site clearance on September 19, 2005.

6.       Second is the environmental clearance.  Andhra Pradesh Pollution Control Board has conducted public hearing at five places in Krishna, West and East Godavari, Vizag and Khammam districts on Oct.10, 2005.  The Board has granted the no-objection certificate on Oct.18, 2005.  For environmental clearance, the environmental Impact Assessment , (EIA) and Environmental Management Plan (EMP) were prepared by Andhra Pradesh Agriculture Finance Corporation.  After seeking several explanations, the Union environment Ministry has sanctioned environmental clearance on Oct.25, 2005.

7.       As already a detailed project report was with the CWC, the commission has granted in principle clearance to the project on September 28, 2005.

8.       We should not forget that some extent of submergence is inevitable when such a huge reservoir on a major river like Godavari is planned.  The present dam design was prepared only after examining all options and proposals to achieve the desired results.  A dam with the height of +150ft and storage capacity of 75 TMC  is a must in this case.  No other site is suitable than the proposed site for Polavaram reservoir.

SECTION-3 : IMPROPER ENVIRONMENTAL CLEARENCES FOR POLAVARAM DAM

PART-1 : DEMAND FOR CANCELLING EITHER ENVIROMENT CLEARANCE(2005) OR FOREST CLEARANCE

From: Himanshu Thakkar
Date: Thu, Sep 2, 2010 at 5:06 PM
Subject: URGENT: Polavaram Dam: Concerns about Forest and Environment clearances
To: Jairam Ramesh
Sept 2 2010
From:
Himanshu Thakkar
South Asia Network on Dams, Rivers & People,
c/o 86-D, AD block, Shalimar Bagh,
Delhi, himanshuthakkar@iitbombay.org, ht.sandrp@gmail.com www.sandrp.in Ph: 27484655/ 9968242798
To: Shri Jairam Ramesh
Union Minister of State for Env and Forests (IC), New Delhi

Respected Sir,

I have just seen your letter dated Aug 18, 2010 to Orissa Chief Minister on the aboves subject, uploaded yesterday on MEF website.

1. Your letter says that the Forest Clearance has been given to the Polavaram Project on July 28, 2010 is subject to the condition, "... no submergence and displacement of people including STs take place in Orissa and Chhattisgarh...". However, this condition is in complete contradiction with the environment clearance given by your ministry on Oct 25, 2005, which says in para 2, "Total 1,93,35 persons are likely to be affected by this project, out of that 1,75,275 persons in Andhra Pradesh and 6,316 persons from Orissa and 11,766 are from Chattisgarh." It is clear the condition of no submergence and displacement on Orissa and Chhattisgarh, stated in your letter, in the Tribal Development Ministry's condition, and in the forest clearance letter is in complete contradiction with the environment clearance given by you. One of them have to be cancelled due to this contradiction, we would like to know, which one would be cancelled.

2. This condition of no submergence or displacement in Orissa or Chhattisgarh is based on the proposal to construct embankments along the respective rivers in Orissa and Chhattisgarh. However, the proposal to construct these embankments was not part of the project that was given clearance by your ministry on Oct 25, 2005. This change in scope of the project came to light when the project went for CWC clearance (given on 23.01.2009 following flawed in principle forest clearance given by your ministry on Dec 26, 2008). Following letter from MEF, the Govt of AP applied for concurrence of the MEF for building embankments on 29.01.2009. The issue came up for discussion in the meeting of EAC of River Valley committee on Feb 16-17, 2009. Prior to this EAC meeting, we had sent a detailed letter on 13.02.2009 to the EAC, explaining the implications of the proposal, lack of EIA or public consultation process, how this changes the scope of the project and so on, the same is attached. It is clear from details of this letter that hundred of ha of land would be required in Orissa and Chhattisgarh for the building of embankments, for mining of materials for building of embankments, for leaving land on the banks of the river on both sides, for building approach road, for building cross drainage channels and so on. A very large portion of this land would be forest land and it would also imply displacement of the people and their livelihoods. This itself is sufficient ground to show that MOTA condition, Orissa HC condition, your condition and FC condition of no submergence and displacement in Orissa and Chhattisgarh is impossible to adhere to, and this should again be sufficient ground to cancel both the priliminary and final FC given by your minister.

3. After the EAC meeting of Feb 16-17 2009, the EAC decided on this issue, "The EAC therefore directed the project proponent to initiate suitable action requesting the appropriate authorities in Orissa & Chattisgarh for conducting public hearings in the respective states of Chattisgarh & Orissa in respect of embankment proposal and report back to the committee." I am attaching the minutes of this EAC meeting for ready reference. This decision of the EAC implies that the project needs fresh clearance for this component and since project without this component would violate the various legal norms and conditions the project also cannot go ahead without that. However, the project is yet to take these steps and if it were to take this steps it would violate your conditions of no submergence and displacement in Orissa and Chhattisgarh.
It is clear that your condition of no submergence and displacement in Orissa and Chhattisgarh is impossible to adhere to and hence the FC of the project has to be cancelled.

4. Here we would like to add that the EAC decision in Feb 16-17 2009 meeting was flawed since it is clear that this was changing the scope of the project cleared earlier. So EAC should also have asked that the earlier EC be cancelled till this decision is followed.

5. The Forest clearance given by your ministry, incidentally, has a condition, namely no (x), which says, "The project authority shall maintain flow of water in the down-stream course of river equal to the normal flow of water existing in pre-dam condition". I am at a loss to understand if this condition is to be adhered to (and I assume it needs to be adhered to all round the year, in all years, since there are no qualifications in the condition), how can the dam be built or operated at all? It seems there has not been sufficient application of mind while according the final FC dated 28.7.2010, which is sufficient reason for its cancellation.

These objections to the final FC and narration of the contradictions in your letter actually gives an opportunity to revisit the project and look for better options in achieving the irrigation and water supply in project areas. Hope you will take necessary steps in that direction after cancelling the flawed Environment clearance of Oct 25, 2005 (which was also quashed by NEAA in Dec 2007) and the forest clearances of Dec 26, 2008 and July 28, 2010.

I would be happy to explain these issues if necessary and will look forward to your early response.

Thanking you,
Himanshu Thakkar
South Asia Network on Dams, Rivers & People,
c/o 86-D, AD block, Shalimar Bagh,
Delhi, India himanshuthakkar@iitbombay.org, ht.sandrp@gmail.com
www.sandrp.in

PART-1 (APPENDIX ON EAC MEETING FOR EMBANKMENTS PROJECT CLEARENCE )
Government of India, Ministry of Environment and Forests(IA-I Division)

Sub: Summary Record of discussions of the twenty-third (23rd) meeting of Expert Appraisal Committee for River Valley and Hydroelectric Projects constituted under the provisions of EIA notification 2006, held on 16th & 17th February, 2009 in New Delhi.
The list of participants is appended.
At the outset Chairman welcomed all the members of the committee. The committee was informed that Prof. J.K. Sharma is unable to attend the meeting on 16.2.2009 due to unavoidable circumstances. However, he will attend the meeting on the 2nd day i.e. 17.2.2009. The Member Secretary also informed the committee that Ministry has instructed that the recommendation of the committee should be in clear terms i.e. either cleared/ rejected/ further additional information. Project should not be recommended for clearance seeking further information which is to be examined by the Ministry. As such all the projects which are recommended in this fashion are to be put up to the committee.

2.10 Polavaram Multipurpose Project in Andhra Pradesh by Government of Andhra Pradesh Reconsideration for EC (No. J-12011/74/2005-IA.I).

This project was accorded environmental clearance during October, 2005. On a petition filed by Shri Laxman Munda in the High Court of Orissa the Hon’ble High Court in its order dated 22.3.2006 directed that it is open to the State of Andhra Pradesh to proceed with the construction of Indira Sagar (Polavaram) Multipurpose Project after complying with the requirements of all laws applicable in this regard, in such manner that no land/ village/ area situated within the territory of the State of Orissa is submerged?. Following the above order of Hon’ble High Court of Orissa MoEF communicated to the Government of Andhra Pradesh vide letter dated 25th April, 2006 that the direction of Hon’ble High Court of Orissa also may be treated as an addendum to the above environment clearance letter dated 25th October, 2005. Academy for Mountain Environics filed a petition in the National Environment Appellate Authority (NEAA) against environment clearance to this project. This project involve submergence in Chhattisgarh and Orissa also. NEAA quashed the environmental clearance as public hearing was not conducted in these two States. Andhra Pradesh Government challenged the order of NEAA in the Andhra Pradesh High Court. Andhra Pradesh High Court granted stay on the order of NEAA and allowed the construction work on the project.

The proposal was referred by Central Water Commission to this Ministry for comments for consideration by the Technical Advisory Committee (TAC) on irrigation, flood control and multipurpose projects.
The TAC note circulated for this project, stated on page 15 that the State Government of Andhra Pradesh has reassured vide letter No.42137/Maj.Irrgn.I(1)/2008 dated 10th January, 2009 that by undertaking adequate measures through bunds/ embankments, drainage sluices and pumping arrangements, no land will be submerged in Orissa and Chhattisgarh and there will be no displacement of any population.

As construction of bund on the river was not considered by the then Expert Appraisal Committee, neither details were given in the EIA/ EMP report, the Ministry wanted to examine the impacts on surroundings for construction of the proposed bunds etc. As such the details of construction of bund was submitted to the Ministry for appraisal.

Shri S. Joshi, Secretary (I&CAD) gave a detailed presentation on the proposal. He stated that the scope of the project has not been changed because the height of the dam, FRL, benefits contemplated and all other project parameters remain same and unaltered. The project works are in progress and an expenditure of Rs.2239 crores has already been incurred so far on various components. The project authority has proposed embankments on Sabri river and Sileru river. Length of protective embankments is 30.20 km in Orissa and 29.12 km in Chhattisgarh. The embankments are broadly divided into three reaches depending upon the height of embankment. Under reach I (river Sileru), 0-10.472 km will be covered with varying height upto 10 m, reach -II (river Sileru and Sabri) the length will be 10.472-16.43 km and the height of embankment will be between 10 m to 15 m, for reach -III (river Sabri) the length will be from 16.43-30 km and the height of embankment will be up to 10 m. Total quantity of muck will be generated due to excavation of cut-off trenches is likely to be to the tune of 5.4 lakh cum. Out of which 2.623 lakh cum will be in Orissa side and 2.77 lakh cum in Chhattisgarh side. This muck will have useful soil for embankments to an extent of 3.48 lakh cum. The muck generation due to topsoil removal is estimated to be 4.64 lakh cum in Orissa and 5.36 lakh cum in Chhattisgarh.

Shri Joshi further stated that expenditure for construction of embankment would be costing the Government an estimated expenditure of about Rs. 600 . 00 crores, whereas the best of R & R package for few affected village population would have been only about Rs. 60.00 crores. This huge infructuous expenditure has been planned due to opposition of both the States of Orissa & Chattisgarh which would have immensely benefited the affected villages and people of Orissa & Chattisgarh.

Dr. B.P. Das has made the following observations on the proposal submitted by the Govt. of Andhra Pradesh
(i) The reservoir to be created is likely to back up along the two major tributaries, Sabari and Sileru submerging the overbank low lands in the States of Chhattisgarh, Orissa and also in Andhra Pradesh.
(ii) No reservoir in India has embankments in its periphery to restrict the spread, which in turn creates stagnation of water during monsoon and also deprives the reservoir of its natural yield.
(iii) The area of submersion to be protected by embankments be indicated with their elevation from the deepest point to FRL of Polavaram (+150 Ft.)
(iv) Although pumping is proposed, it can not be considered full proof because of the cyclonic storms. Chhattisgarh, Orissa and Andhra Pradesh experience (in May, 1990 A.P. got 1000 mm in Kakinada in 3 days, Orissa in September, 1980 got 500 mm in 2 days) cannot be pumped out even 7?8 days.
(v) The most important issue is large reservoirs with high spillway capacity have been constructed on Kolab (Saberi), Balimela and Lower Sileru on Sileru. These reservoirs will be required to spill design overflow in September-October during cyclones that will impinge on FRL of Polavaram. This will create much larger backwater rise, not anticipated now.
(vi) Public hearing is mandatory in upper States for an inter-State project. No information is available in this regard.
(vii) A lower FRL at Polavaram vis--vis the demerits of submersion in Chhattisgarh/ Orissa need examination.

In this connection the committee noted that CWC which is the highest competent authority of the Govt. of India has already approved the proposal of the Govt. of Andhra Pradesh for construction of embankments after taking the various relevant technical factors into consideration and after the approval given by the CWC, the Govt. of Andhra Pradesh approached the Ministry of Environment and Forests for environmental clearance for construction of Embankments.

The committee also noted that the present proposal is for the construction of protective embankments along the Rivers Sabari and Sileru with a view to avoiding any land submergence in the states of Orissa and Chhattisgarh, as directed by the Hon’ble High Court of Orissa. It also noted the project was already given environmental clearance for the other components during 2005 and construction of embankments now proposed does not change the scope of the project which was cleared earlier.
It was also noted that the concerned authorities of Government of Chattisgarh and Orissa have not been informed about construction of embankment on Sabri and Sileru River on the banks located in these two States. It was not clear to the committee, how the construction of embankment is possible without co-operation from the concerned authorities of Governments of Chattisgarh & Orissa,.However the Committee noted the submission made by the Secretary (I&CAD) that earlier efforts made by the Govt. of Andhra Pradesh with the concerned authorities in Orissa and Chattisgarh to conduct public hearings in the respective states did not yield any responses in the past.
After critically examining all the environment related issues, the committee agreed with the technical content and contentions of proposal to construct embankments in Orissa and Chhattisgarh over small sections of tributaries (Sabri and Sileru river and their tributaries.). This is also the requirement of the decisions taken by various Courts of Law and to avoid submergence in Orissa and Chhattisgarh by other competent authorities. The Expert Appraisal Committee while agreeing to the proposal, however, finds the statutory requirement of public hearing as mentioned in the EIA Notification, 2006 was not conducted in Chattisgarh & Orissa. The EAC therefore directed the project proponent to initiate suitable action requesting the appropriate authorities in Orissa & Chattisgarh for conducting public hearings in the respective states of Chattisgarh & Orissa in respect of embankment proposal and report back to the committee.
Item No.3
Any other item with permission of the Chair.
It was decided that next meeting will be held on 19th and 20th March, 2009.
The meeting was ended with thanks to the chair.
The minutes of 23rd EAC meeting are confirmed.
(P. Abraham)
Chairman
PART-2 : TRIBAL VILLAGES THAT REJECTED POLAVARAM DAM
September 28 2010
To
Members of Forest Advisory Committee, Union Ministry of Environment and Forests
i Director General of Forests Ministry of Environment & Forests, Paryavaran Bhavan ,New Delhi 110003 :: Chairman
ii Additional Director General of Forests
Ministry of Environment & Forests, New Delhi 110003 :: Member
iii Additional Commissioner (Soil Conservation)
Ministry of Agriculture,New Delhi 110 001 :: Member
iv Prof. Amita Baviskar,Institute of Economic Growth,Delhi 110 007 :: Member
v Dr. Ullas Karanth,Centre for Wildlife Studies, 1669, 31st Cross, 16th Main, Bana Shankari, Second Stage, Bangalore-560070. Email: karanth@blr.vsnl.net.in
:: Member
vi Mr. Mahesh Rangarajan24, Samachar Apartments, Mayur Vihar Phase-I (Extn.), New Delhi-110091.Email: mahesh3@del6.vsnl.net.in
:: Member
vii Inspector General of Forests (Forest Conservation)
Ministry of Environment & Forests,New Delhi 110003 :: Member Secretary
Subject: Documents for FAC consideration in view of the forest clearance given for the Polavaram project
Respected members,
On the above subject, I am attaching the following documents, soft copies of which have been mailed to you earlier.
Sr No Description No of pages Running page nos
1 Letter from SANDRP to FAC members dated Sept 3, 2010, attaching the letter from SANDRP to Union Ministry of Environment and Forests, the Environment clearance given to Polavaram project in Oct 2005, SANDRP letter to EAC in Feb 2009 and relevant extracts of EAC meeting of Feb 2009 15 1-15
2. Forest clearance letter dated July 28, 2010 5 16-20
3 Letter from Gramya to FAC dated Sept 20 2010 1 21
4 Gram Sabha Resolution of village Kotarugommu (Original Telugu) 5 22-26
5 Gram Sabha Resolution of village Kotarugommu (English Translation) 4 27-30
6 Gram Sabha Resolution of village Pochavaram (Original Telugu) 4 31-34
7 Gram Sabha Resolution of village Pochavaram (English translation) 3 35-37
8 Gram Sabha Resolution of village Gommukoyagudem (Original Telugu) 3 38-40
9 Gram Sabha Resolution of village Gommukoyagudem (Eng Translation) 3 41-43
10 Gram Sabha Resolution of village Pusugudem (Original Telugu) 2 45-46
11 Gram Sabha Resolution of village Pusugudem (English Translation) 2 47-48
12 Gram Sabha Resolution of village Regulapadu (Original Telugu) 2 49-50
13 Gram Sabha Resolution of village Regulapadu (Eng Translation) 2 51-52
14 Gram Sabha Resolution of village Venkatayapalem (Original Telugu) 2 53-54
15 Gram Sabha Resolution of village Venkatayapalem (Eng Translation) 2 55-56
16 Gram Sabha Resolution of village Mulagalapalem (Original Telugu) 3 57-59
17 Gram Sabha Resolution of village Mulagalapalem (English Translation) 2 60-61

As described in the attachments, the Forest Clearance given to Polavaram project is in violation of the Forest Rights Act.

As pointed out in attached letter to Shri Jairam Ramesh, the Forest Clearance has been given to the Polavaram Project on July 28, 2010 (see document no 2 listed above) is subject to the condition, "... no submergence and displacement of people including STs take place in Orissa and Chhattisgarh...". This condition of no submergence or displacement in Orissa or Chhattisgarh is based on the proposal to construct embankments along the respective rivers in Orissa and Chhattisgarh. However, the proposal to construct these embankments will require hundred of ha of land in Orissa and Chhattisgarh for the building of embankments, for mining of materials for building of embankments, for leaving land on the banks of the river on both sides, for building approach road, for building cross drainage channels and so on. A very large portion of this land would be forest land. However, no assessment has been done, as to how much forest land would be required for embankments, what is certainly known is that substantial part of forest land will be required in both states for embankments. No clearance for such use of forest land has been sought or given.

Moreover the land requirements for the embankment proposal in Orissa and Chhattisgarh would also lead to displacement and impact on the people in the two states, most of whom are likely to be tribals. The use of such forest land would also mean violation of their forest rights. But no assessment of any of these aspects has been done based on ground survey, but is it clear that there will be significant impacts, including displacement of large number of people. Thus the condition that the project will lead to displacement and submergence in Orissa and Chhattisgarh is impossible in practice. This is additional ground to show FC condition of no submergence and displacement in Orissa and Chhattisgarh is impossible to adhere to.
In view of all this, we request you to reconsider the Forest clearance and suspend or cancel it pending resolution of all these issues. It may be noted that the date of Forest Clearance is July 28, 2010, and we request this committee to take urgent cognizance of this matter.
Looking forward to your early response, Thanking you,
Yours Sincerely,
Himanshu Thakkar For SANDRP

PART-3 : FOREST CLEARANCE FOR DAM BY MINISTRY OF ENVIRONMENT,JULY 2010
Environment Ministry gives green signal to Polavaram dam, ,
New Delhi: Wednesday, July 28, 2010: The Environment Ministry has given its nod to divert over 3,000 hectares of forest land for the construction of mega Polavaram dam in Andhra Pradesh but made it clear that no submergence of land would be allowed in adjacent Orissa and Chhatisgarh.
"The approval for diversion of 3,731 hectares of forestland is based on the clear understanding that the state government will take all steps to ensure that no submergence of forest land on account of the proposed dam, also known as Indira Sagar Multi-purpose project would take place in Orissa and Chhattisgarh.
"Further, it (clearance) is also based on the assurance of the state government that there are no forest rights that need to be settled under the Tribals Act and that the approved rehabilitation would be implemented in a time-bound and transparent manner," a statement issued by the Ministry said today.
It also said the ministry would carry out strict monitoring of all conditions under which the Polavaram project on Godavari river is being cleared.
The proposal got the green signal after the Andhra Pradesh government submitted a compliance report last year followed by a final report last month as per satisfaction of the Forest Advisory Committee (FAC) of the Environment Ministry. http://www.zeenews.com/news644139.html
PART-4
No.J-12011/74/2005-IA.I 25th October 2005

Government of India, Ministry of Environment & Forests
The Secretary (I & CAD), I&CAD Department,Hyderabad.
Subject – Indira Sagar (Polavaram) Multipurpose Project in West Godavari District
Andhra Pradesh - Environment Clearance regarding.
Sir,
This has reference to your letter No. CE(Hydrology)/EE-IV/DEE-II/AEE/1866/Vol-III-1, dated 10.10.2005 & subsequent letter dated 20.10.2008 on the subject.
2. The above referred proposal was considered by the Expert Committee for River Valley & Hydroelectric projects at its meeting held on 19.10. 2005. The project is a intended to provide Irrigation facilities to 2.91 lakh hectares in Visakhapatnam, East Godavari under Left Main Canal and West Godavari and Krishna Districts under Right Main Canal. The project is across the river Godavari. This project besides providing Irrigation facilities in the aforesaid manner will also generate hydel power of 960 MW, divert 80 TMC of Godavari water to Krishna River for stabilizing the existing command under Prakasam barrage and provides drinking facilities to 540 enroute villages covering 25 lakhs population together with water supply to Visakhapatnam city and to industries enroute. Total land requirement for the project is 46060 hectare and out of that 3279 ha. is forest land. Forest clearance yet to be obtained. Total 1,93,35 persons are likely to be affected by this project, out of that 1,75,275 persons in Andhra Pradesh and 6,316 persons from Orissa and 11,766 are from Chattisgarh. Public hearing was held on 10.10.2005. The capital cost of the project is Rs. 9072 Crores.
3. The Ministry of Environment and Forests hereby accords environmental clearance as per the provision of Environmental Impact Assessment Notification-1994, subject to the strict compliance of the terms and conditions mentioned below –
Part – A: Specific conditions
Recommended Treatment 1st
Year 2nd
Year 3rd
Year 4th Year 5th
Year Total
Biological Treatment (In ha.)
a. Afforestation and revegetation 750 1500 2250 1500 1500 8500
b. Social Forestry 1500 1500 1500 2250 2250 9000
c. Vegetative barriers 3600 3600 3600 3600 3600 18000
Engineering Treatment
(In number)
a. Gully plugs 700 600 600 600 600 3100
b. Rock fill dam 440 440 440 440 440 5000
c. Percolation tank 20 20 20 20 20 100
d. Check dams 60 60 60 60 60 300
e. Continuous contour benches 70 70 70 70 70 350

i) 34500 ha. degraded area shall be brought under CAT (Biological) . In addition to this, gully plugs, check dam, percolation tanks etc. will also be done under engineering measures. The action plan for Catchment area treatment s proposed in the EMP report is reproduced below:

ii) iTotal 1,93,357 persons are likely to be affected by this project, out of that 1,75,275 persons in Andhra Pradesh and 6,316 persons from Orissa and 11,766 are from Chattisgarh. The project-affected families will be rehabilitated as per Andhra Pradesh Government’s R & R policy –2005 and same package also should be provided for the project affected persons from the Orissa and Chattisgarh State.

iii) A monitoring committee should be constituted which must include representatives of project affected persons from SC/ST category and a women beneficiary. The committee would also attend the Grievance Redressal of the affected peoples.

iv) Commitment made during Public hearing by the project authority on different issues should be fulfilled.

v) Forest Clearance should be obtained for acquiring 3279 hectare forest land & submitted.

vi) As proposed a fish ladder would be constructed for migration of fishes.

vii) Occurrence of stagnant pools/slow moving water channels during construction and operation of the project providing breeding source for vector mosquitoes and other parasites. The river should be properly channelised so that no small pools and poodles are allowed to be formed. Even after taking precaution, due to unforeseen situations, breeding of mosquito and resultant malaria or mosquito borne diseases can increase. If such a situation arises, it will be the responsibility of project authorities to take all corrective steps i.e. residual insecticidal spray in all the project impact area and surrounding 3 Km. area, keeping the flight range of mosquitoes in consideration.

viii) Any other clearance from any other organization if required should be obtained.

Part –B. General conditions

i) Provision of supplying kerosene or cooking gas / Pressure Cooker to the labourers should be kept instead of supplying fuel wood.

ii) Fuel depot may be opened at the site to provide the fuel (kerosene/wood /LPG). Medical facilities as well as recreational facilities should also be provided to the labourers.

iii) iAll the labourers to be engaged for construction works should be thoroughly examined by health personnel and adequately treated before issue the work permits.

iv) Restoration of construction area including dumping site of excavated materials at dam site & power house site should be ensured by leveling, filling up of borrow pits, landscaping etc. The area should be properly afforested with suitable plantation.

v) A multidisciplinary committee should be constituted with representative from the disciplines of forestry, ecology, wildlife, soil conservation, NGO etc. to oversee the effective implementation of the suggested safeguard measures.

vi) Financial provision should be made in the total budget of the project for implementation of the above suggested safeguard measures.

vii) Six monthly monitoring reports should be submitted to the Ministry and its Regional Office, Bangalore for review.

4. Officials from Regional Office MOEF, Bangalore would be monitoring the implementation of environmental safeguards should be given full cooperation, facilities and documents / data by the project proponents during their inspection.

5. The responsibility of implementation of environmental safeguards rests fully with the Irrigation Department and Government of Andhra Pradesh.

6. In case of change in the scope of the project, project would require a fresh appraisal.

7. The Ministry reserves the right to add additional safeguard measures subsequently if found, necessary and to take action including revoking of the clearance under the provisions of the environmental (Protection) Act, 1986, to ensure effective implementation of the suggested safeguard measures in a time- bound and satisfactory manner.

8. This clearance letter is valid for a period of five years from the date of issue of this letter for commencement of construction work.

9. A copy of the clearance letter will be marked to concerned Panchayat, if any, from whom any suggestion/representation has been received while processing the proposal.

10. State Pollution Control Board / Committee should display a copy of the clearance letter at the regional office, district industries centre and collector’s office / tehsildar’s office for 30 days.

11. The project proponent should advertise within seven days from the date of issue of the clearance latter, at least in two local newspapers widely circulated in the region around the project, one of which shall be in the vernacular language of the locality concerned informing that the project has been accorded environmental clearance and copies of clearance letters are available with the State Pollution Control Board/Committee and may also be seen at Website of the Ministry of Environment and Forests at http:// www.envfor.nic.in/.

(Dr. S. Bhowmik)

Additional Director

PART-5: GOVT WANTS FRESH APPRAISAL OF POLAVARAM DUE TO PROPOSED EMBANKMENTS TO AVOID SUBMERSION IN ORRISA

No.J-12011/CWCT/TAC/09-IA.I

Government of India,Ministry of Environment and Forests

To Paryavaran Bhawan

Shri.U.K.Ghosh, Chief Engineer (PAO) CGO Complex, Lodhi Road

Central Water Commission, New Delhi-110 003

Sewa Bhawan, RK Puram, Telefax: 24362827

New Delhi-110 066. Dated 20-1-2009

Subject: 95th meeting of the Advisory Committee on Irrigation, Flood Control and Multipurpose projects.

Sir,

1. This has reference to your communication No.16/27/2008-PA(N)47-78 dated 15th January, 2009 on the above mentioned subject. Out of the 6 projects, medium irrigation project at Sl.No.4 and flood control projects at Sl.No.5 & 6 do not require environmental clearance under the provisions of EIA Notification, 2006

2. Environmental clearance has already accorded to Teesta Barrage project in West Bengal in 1994. In respect of restoration of Kosi Barrage in Bihar it may be noted that we have not received any proposal in this regard.

3 Regarding Indira Sagar (Polavaram) Multipurpose project it may be noted that environmental clearance was accorded to this project on 25th October, 2005 based on the information submitted in the EIA/EMP report which was examined by the Expert Appraisal Committee (EAC) for River Valley and Hydroelectric Projects.

4. The TAC note circulated for this project, states on page 15 that the State Government of Andhra Pradesh has reassured vide letter No.42137/Maj.Irrgn.I(1)/2008 dated 10-01-2009 (Appendix XVII) that by undertaking adequate measures through bunds/embankments, drainage sluices, and pumping arrangement no land will be submerged in Orissa and Chattisgarh and there will be no displacement of any population.

5. In this regard it may be noted that construction of bund on the river was not considered by the then EAC, neither details were given in the EIA/EMP report. As such, if bunds are proposed on the river to stop submergence in Orissa & Chattisgarh, it will be treated as change of scope of the project and as per condition No.6 of environmental clearance letter dated 25-10-2005 the proposal needs fresh appraisal.

6. Further it may be noted that a Transfer Petition (Civil) No.1159 of 2008 has been filed in the Hon’ble Supreme Court for the transfer of the Writ Petition No.27767 of 2007 pending before the High Court Judicature of Andhra Pradesh at Hyderabad.

Yours faithfully,

(Dr.S.Bhowmik)

Additional Director

PART _6 -APPENDIX- MINISTER'S LETTER.ON FOREST CLEARENCE TO POLAVARAM



PART-7: OBJECTIONS  TO EMBANKMENTS PROJECT BEFORE ENVIRONMENT MINISTRY
SOUTH ASIA NETWORK ON DAMS, RIVERS AND PEOPLE
Project office: 86-D, AD block, Shalimar Bagh, Delhi 110 088. India
Ph: 0091 11 2748 4654/ 5. Email: cwaterp@vsnl.com www.sandrp.in
February 13, 2009
To:
Mr. P. Abraham, Chairman, & All the members,
Expert Appraisal Committee on River Valley & Hydroelectric projects,
c/o Dr Bhowmik,, Impact Assessment Division,Ministry of Environment and Forests,
New Delhi 110 003
Sub: Objections to EC for Polavaram Multi Purpose Project

Dear Chairman and members of the EAC on River Valley and Hydroelectric Projects,

We have come to know from the agenda notes of the 23rd meeting of MoEF’s Expert Appraisal Committee for River Valley and Hydroelectric Projects to be held on Feb 16-17, 2009 that the committee will be considering Polavaram Multipurpose Project in Andhra Pradesh by Government of Andhra Pradesh (No. J-12011/74/2005-IA.I) for the proposal for the construction of the embankments to protect the lands in Orissa and Chhattisgarh from going under submergence due to the proposed Polavaram project.

We strongly oppose this application and request the EAC to reject the proposal on following grounds.

1. Change in scope of the project The proposal to build this huge length of embankments was clearly not part of the original proposal for clearance for the project. The EIA and EMP used for the public hearing and also the ones submitted before the clearance given by MEF on 25.10.2005 and 25.4.2006 did not include the proposal to build the embankments now proposed to be built in Orissa and Chhattisgarh. The proposal to build the embankments changes the basic scope of the project. Hence the new project proposal must go through fresh EIA and EMP and also public hearings in all affected districts including in Orissa and Chhattisgarh as per the EIA notification of 2006, before the project can be reconsidered for EC. Hence the current application should be rejected.

2. Land required in Orissa and Chhattisgarh A very large area of land will be required for the embankments, which includes:

For Embankment For the land on which the embankment is to be built, including freeboard, we estimate that at least 425 ha of land will be required in the two states of Orissa and Chhattisgarh

For mining of materials required for the embankments over 10 million cubic meters of homogenous soil of suitable quality and at least 1.1 million cubic meters of metal (coarse and fine) is required. The mining sources for these materials are yet to be identified. However, it will require large quantity of land for mining of this material, which will be over 100 ha.

For muck disposal The process of building the embankments will create huge quantity of muck, which will be in several lakh cubic meters. A very large area of land will be required for the disposal of this muck, which is yet to be identified.

For drainage channels Drainage channels will have to be constructed on land side of the embankments to ensure that the seepage water and also the local rainwater is diverted to the next available stream/ rivers. Land will also be required for this.

However, there has been no process of survey, identification of the land required for all these purposes. The brief EIA note that has been submitted with the current proposal has been prepared without any ground survey. It is not known how much of this private land, how much is forest land, how much is gazing (and other common property) land and so on and what will be required and the what all will be the impacts of acquisition of use of this huge quantity of lands along the river banks. Hence the proposal needs to be rejected on these grounds also.

3. Maximum floods and disaster management The proposal includes having gates and pumping arrangements at some 36 places to ensure that the water from the tributaries, stream meeting the Sabari and Sileru rivers are drained into these rivers. However, this is not based on the 1-100 year High flood and probable maximum precipitation for these streams and their catchments. The assessment must include the simultaneous possibility of 1-100 year flood in the Sabari/ Sileru/ Godavari and also the tributaries meeting them. Without such assessments, the worst floods scenarios for these streams cannot be built, nor can the embankments and the drainage/ gate structures properly designed. The proposal also does not include the disaster management plans in case of a breach of embankment or non functioning of the gates/ pumps, which is very frequent, wherever embankments have been built. The proposal should also be rejected on these grounds.

4. Social impacts No assessment of the social impacts of building the embankment have been done. The building of embankments are bound to cause huge social impacts in terms of loss of hundreds of Ha of land (private, forest, common property lands) for the various purposes described above, in terms of flooding when the gates/ pumps do not function, in terms of lack of access to the river, in terms of additional siltation and stagnation of the river, in terms of loss of navigation to the other side and so on.

Any clearance without assessing all the social impacts would also be in violation of the clearance from the Ministry of Tribal Affairs (MOTA) dated 17.4.2007, which clearly states, “The Government of Andhra Pradesh, under the technical guidance of the Central Water Commission shall ensure that no submergence and displacement of people including Scheduled Tribes (STs) takes place in the territories of States of Orissa and Chhattisgarh and the population of these two States including STs does not get adversely affected in any manner, either by changes in drainage regime or by any kind of primary/secondary displacement.” Since the huge area of land required for the embankments and other aspects will have very substantial impacts on the tribal people staying in the area, any clearance without such assessment and consent of the affected people will be in violation of the MOTA condition and also in violation of the rights of the people, National R&R policy and also the EIA notification of 2006.

5. Public hearings in Orissa, Chhattisgarh This proposal will entail significant social and environmental impacts in the lands of Orissa and Chhattisgarh, and a public hearing for such impacts is mandatory under the EIA notification 2006 and such public hearing has never happened. Hence the proposal does not qualify for consideration.

6. Consent of the states of Orissa and Chhattisgarh The embankments are to be built on the soils of these states, but there is no consent from these states for this proposal. In fact the reports of the public hearing in the states are supposed to come to the MoEF from the respective state govts, which is not the case currently. Hence the proposal does not qualify to be considered.

7. Violation of High Court order The proposal would also be in violation of the Orissa High Court order in WP 3669 of 2006, where the High Court has said that the AP can take up the project without any impact on any land/ village/ area of Orissa. The proposed embankments are to be built on the lands of Orissa and will have huge impacts on the areas, people and lands of Orissa. Hence the embankments would also be in violation of the orders of High Court of Orissa and the proposal should be rejected on that count too.

8. Violation of the FCA Since the consent of the state govts of Orissa and Chhattisgarh is not available, it is not even clear if some of the hundreds of Ha of land required for the proposed embankment would be coming from forest land. The Forest clearance for the project has clearly stated that “In no case, there should be any submergence of forest land in Orissa and Chhattisgarh”. Use of forest land for building of embankment would also be violation of the forest clearance letter and FCA. The forest clearance may be separate from the environmental clearance, but the environmental impact assessment is at least supposed to make an unequivocal statement about how much forest land would be required and impacts thereof, which is not the case in current situation. Hence the proposal does not qualify to be considered for EC as it would violate the EIA notification 2006.

9. Impacts in Andhra Pradesh The building of embankment will also have additional impacts within Andhra Pradesh, particularly on the area along the opposite bank of Sileru river from Orissa, where the proposal is to build the embankment on Orissa side, but not on AP side. As the brief desk top EIA note (which cannot be considered an EIA by any stretch of imagination) attached with the proposal states, the embankments can have a number of impacts, including, change in flow velocity, changes in riverbed levels due to silt deposition and consequent flood levels and so on. These changes will be experienced by the AP portion along the Sileru River, on the opposite bank from Orissa right from the beginning of impoundment and these impacts also need to be assessed, which has not been done either by the earlier EIA or the brief note attached with the current application.

10. Efficacy of Embankments Experience from other places (including Bihar, UP, Assam, Orissa, among others) shows that embankments are at best temporary measure for protection of the area that they are supposed to protect and also they create more problems than solve. There are serious questions if the proposed embankments are the best options for protecting the lands and people of Orissa and Chhattisgarh. There is no application of mind on this issue on the part of the project proponent (Andhra Pradesh) or others concerned at any stage. More importantly, the very people for whose protection this are supposed to be are not part of this process, or the state where these are to be created are part of this process. In this situation it would indeed be very shocking and in complete violation of the rights of the people and constitution of India if the EAC gives clearance to this proposal.

Under these circumstances, the current application should be rejected and the project authorities should be asked to redo the whole EIA, hold public hearings in ALL the affected districts and than get back with an application for fresh clearance. In the meantime, the earlier clearance granted to the project should stand revoked in view of the change in scope of the project.

We would be happy to come and explain these issues before the EAC if necessary. We will also look forward to your response on this.

I would like to request Dr Bhowmik to ensure that all the members of the expert committee gets a copy of this before the meeting of the River Valley EAC committee On 16-17 Feb 2009.

Thanking you,

Sincerely,

Swarup Bhattacharya

For SANDRP