Demand for a moratorium on construction work of Lower Subansiri Hydro Power (LSHP)

December 12, 2013

Krishak Mukti Sangram Samiti (KMSS)

To
The Prime Minister
Government of India
New Delhi

Through
The Additional Secretary, Power
Ministry of Power
New Delhi (Camp: Guwahati)

Sub: KMSS Stand on LSHP’s present status

Dear Shri ManmohanSinghji,

You might be aware of the fact that the Thatte and Reddy Committee appointed by the Planning Commission had submitted its report in July, 2012. As you know due to the extra ordinary popular movement against the construction of the Lower Subansiri Hydro Power your office formed a Technical Expert Committee in 2011. Two former secretaries of the Ministry of Water Resource of the Government of India were appointed as members of this committee. The Assam government on several occasions had publicly claimed that they will go by the report of this committee. The Report of Group of Ministers on Hydro Power Projects of the Brahmaputra Basin, also refers to this report and said that ‘the GOM would like to refer to the report of the Dr. C.D. Thatte Committee, which was yet to be submitted, to address the concerns relating to the Dam safety’, (page, 6, para 1). This committee was supposed to report on various issues related to the safety of Lower Subansiri Dam, geological and earthquake related issues, and downstream impacts. The committee was also to examine the report of the Expert Committee report on the Lower Subansiri project formed by the Government of Assam.

1. Their report clearly agrees that ‘transferring the work of Subansiri Basin from Brahmaputra Board to the public and private sector’ is in breach of the Brahmaputra Board Act of 1980. The committee categorically sums up that the present hydro power works on Subansiri is contravention of the ‘basic premise of the Brahmaputra Board Act viz. flood control, other benefits. The report agrees that present planning for the SLP (Lower Subansiri Project) ignores the flood control aspect’. “The SLP became a Hydro Power Project with only incidental benefits of flood protection”. Thatte and Reddy agree that flood regulation ‘is the single most important aspect of project planning that has got ignored by the planners while converting single high dam to a cascade scheme of dams (from downstream to upstream)… the very purpose of the Brahmaputra Board Act is defeated and the mandate of the Brahmaputra Board diluted by this action’.

2.We would also like to point out that the Committee also condemns the NHPC for its inability to verify whether embankments in the downstream have been verified or not which is very crucial for flood moderation. (p. 4)

3. The people in the downstream have been consistently arguing that Assam and other regions of the North Eastern India come under the extremeearthquake sensitive zone. Assam in the last hundred years has experienced two massive earthquakes (1897 & 1950). The Expert Committee formed by the Government of Assam has warned against the construction of dams in the foothills of the Himalaya. The committee pointed out that the parameter used for the construction of the dam (PGA .38 g) was of much lower value than it should have been (PGA 0.5 g).

The Thattee committee agrees on this very important point. Thattee committee agrees that earthquake science is an emerging science. ‘There is some uncertainty, which is natural, about the seismotectonic environment of the project’. The committee than agrees that ‘there is a case for considering increase of SDP from 0.38 g to 0.5 g.’ It is pertinent to mention here that for long after the submission of Expert Committee report (Government of Assam) the NHPC has consistently argued against the use of PGA value of 0.5 g as suggested. Thatte and Reddy agree that Expert Committee (Government of Assam) recommended ‘PGA value of 0.5 g can not be sidestepped unless so proven by scientific assessment, in the overall context of the various responses from experts’.

4. The Thattee Committee further discusses the dam safety question. The Report agrees that the question of the ‘weak foundation rock’ is ‘by far that most important and critical aspect’ of the Lower Subansiri Project It sums up

‘The sandstone, which really looks and behaves like a sand rock, on which the dam is founded, has all through the SLP (Lower Subansiri Project) planning been considered very weak. Its adequacy and competence to support the concrete gravity dam is not established satisfactorily.’

The committee further agrees that ‘the geology of the foundation rock and its engineering properties reveal that innovations are required to enable it to support a 123 meter high concrete dam, especially in view of the seismic environment’. The committee especially emphasises that ‘The 800 mm thick upstream concrete cut-off (diaphragm) wall under the sluice blocks is not considered to be adequate by itself to improve the competency of foundation’. Also, “no evidence is available to show efficacy of the conventional blanket grouting done for dam foundation in improving its competency’. In the words of the Committee, ‘assessment of the foundation rock leads to some concern about the stability’ of the lower Subansiri Project’ as planned and as under construction’. The report also indicated that ‘the frequency of land slides could grow’ after project is completed.

5. The Committee pointed out that maintenance of minimum flow is an important issue. This point has been raised by the people in the downstream for long. The Committee agrees that ‘minimum continuous release from dam may have to be about 110’ cubic meter per second. The committee also agrees that flood control objective of the Subansiri basin projects have already been diluted by converting multi-purpose dam into hydro-power projects and by handing over projects from Brahmaputra Board to private and public sector. Now the Committee agrees that ‘considerable flood control would be possible if the operational control of the reservoir is vested in an independent authority… with appropriate mandate and adequate powers and if flood control objective is not allowed to be further diluted’.

6. The Committee also warns that the present Dam Break Analysis is not adequate. This analysis is important to estimate warning time for sudden flood and thus to enable preparation of emergency plan. The Committee agrees that in case of the Dam Break Analysis ‘the work so far needs to be reviewed’ by Central Water Commission and ‘firmed up’.

7. The Committee finally agreed that ‘There will be noticeable fluctuations of water levels in the river upto about 30 KM from the dam’ which will require ‘security precautions’ to caution people’. ‘It is the river course from SLP upto Majuli that needs attention to avoid accidents due to fluctuations in water levels caused by peaking operations…precautions will be required to ensure safety of people using the river bed, like fishermen, children playing, cattle grazing or drinking water, people bathing and washing, cultivators in the river bed, sand mining people etc’

Essentially, the Thatte Report is full scale expression of doubt about the safety and other aspects of the Lower Subansiri Project. It reaffirms that concern of the people of Assam who all live in the downstream. After this report now we need to think should we have a right to live?

What the GOM said: We would also like to mention here that the Group of Ministers Report (Government of Assam) proposed that ‘once the Dr. C.D. Thatte Committee report is available, a full scale interactive session should be held within a fixed time frame’.

What about other expert committees said:We would also like to mention that couple of other expert committee reports have also agreed with this key report.

For instance, the report of the Expert Committee from IIT Guwahati, Gauhati University and Dibrugarh University has been a significant development. This was the first time that an impact assessment has been done in the region under public scrutiny and accountability to the public at large. Otherwise we have repeatedly seen New Delhi based consultants hired by power developers (with no accountability to the public at large) producing reports only to justify projects of their clients with no concern for the ecological or social security of our region. The scientific/technical recommendations of the Lower Subansiri expert committee clearly suggest the need for scrapping of mega dams in the Northeast, questioning the reports dished out by pro large dam technocracies on earlier occasions. This has further strengthened and reinforced the concerns of the people of the region who have been expressing concerns against the imminent dangers of mega dams. The Expert Committee’s report has been categorically endorsed by the Assam Legislative Assembly’s House Committee in its report on dams submitted to the Assembly in July 2010. The House Committee’s report embodies a clear political mandate against mega-dams in the region. The House Committee was set up after a major debate in the Assam Legislative Assembly in July 2009. We would also like to draw your attention to the fact that this committee has undertaken widespread discussions with different stakeholders while working on the report.

We are often told that trade-offs are required to meet our development and power needs. We would like to clearly point out here that such explanations cannot be used as a fig leaf to cover up for shoddy impact assessment and appraisal of projects, as well as the involuntary imposition of these mega projects on us in the region. We want comprehensive impact assessments by credible persons and institutions in consultation with local communities. Based on such studies and consultations, and an appraisal process which respects the precautionary principle, we can decide which projects need to be shelved and which can be allowed. It is only for the projects which are allowed to go ahead after careful scrutiny and public consultation that we will discuss issues related to trade-offs, appropriate compensations etc. We will not engage in discussions on trade-offs on projects which inherently carry major risk to the downstream people and the environment. Till such a process is in place for credible environmental governance involving free, prior and informed consent of the people of the Northeast, we demand a moratorium on clearances to all dams in Northeast India.

We reject DDRP for the following reasons:
1) We demand that the recommendation made by the Thatte and Reddy Committee which was formed by the Planning Commission to look into the issues raised by the Expert Group on LSHP be implemented in true scientific spirit. The DDRP formed by Ministry of Power failed to engage and respond to the very critical questions raised by the Thatte and Reddy Committee in true scientific spirit as DDRP had a pre-determined obligation to make ground for construction of LSHP.

2) We reject the Dam Design Review Panel (DDRP) which was constituted by the Ministry of Power, GOI as suggested by the Thatte and Reddy Committee. Our rejection is based on the fact that members of the DDRP are part of various committees formed earlier by NHPC. The DDRP panel was constituted with these following members: Chairman (CWC), Member (Hydro, CEA), Ramesh Grover (CWC), L.A.V Nathan (CWC), M. Raju (GSI), M.L. Sharma (IIT Roorkee), V.V. Bhosekar (CWRPRS), Director- Technical (NHPC) & P.K. Gupta (Chief Geologist, NHPC). This includes IIT Roorkee representative to look into question of earthquake which carried out wrote reports on the basis of which seismic parameter of the LSHP was decided. This clearly shows how MoP deliberately manipulated the Thatte & Reddy Committee recommendations by appointing a very biased DDRP.

3) The Thatte and Reddy Committee specially mentioned that ‘There is some uncertainty, which is natural, about the seismotectonic environment of the project’. The committee than agrees that ‘there is a case for considering increase of SDP from 0.38 g to 0.5 g.’. However the DDRP constituted by the MoP rejected this very important recommendation. The DDRP however opined: “The seismic design parameters as approved by NCSDP earlier shall remain the same. The geotectonic setup of the SLP site and in its surrounding cannot generate earthquake greater than what has been approved, as sufficient conservatism has been built into the approved seismic design parameters (SDP), to take care of any subjectivism in estimation of SDP’. Can NHPC say this is the true practice of science?

4) The Thatte and Reddy Committee, discussing the dam safety question, recommended that the question of the ‘weak foundation rock’ is ‘by far that most important and critical aspect’ of the Lower Subansiri Project. Their report sums up ‘The sandstone, which really looks and behaves like a sand rock, on which the dam is founded, has all through the SLP (Lower Subansiri Project) planning been considered very weak. Its adequacy and competence to support the concrete gravity dam is not established satisfactorily.’ The Committee recommended that ‘the geology of the foundation rock and its engineering properties reveal that innovations are required to enable it to support a 123 meter high concrete dam, especially in view of the seismic environment’. However, DDRP disagrees and suggests only cosmetic changes into the existing dam design. This approach is unscientific and does not show any willingness to address serious structural issues raised by the Thatte and Reddy Committee. The DDRP opined that ‘Though the sand has low compressive strength in saturated conditions and has the characteristics of slackiness, the rock mass behaves satisfactorily under undisturbed/confined conditions. Innovation in dam design process shall have to be undertaken to take care of these related aspects’. These are not only self-contradictory but also lacks deep engagement with the actual issue. Rather, DDRP response is sub-standard and lacks any ethical engagement with science and this is what the DDRP’s response was: ‘the length of the conveyance structure of spillway shall be increased so as to place the plunge pool at a distance that would not allow the scour to reach towards dam foundation on long term basis’. This is mockery of science!

The KMSS’s Charter of Demands:
1. There must be a serious and long term investigation of the geological framework, hydrological features of the Brahmaputra basin, seismological foundation of the eastern Himalayas (also taking into account of the paleo-seismology) and larger ecological connections with these aspects. These studies (considering the extra-ordinarily fragile geological nature of the region as well as complex geological history of the river Brahmaputra) must be conducted by very imminent international scientific bodies (experts from these regions must be part of these bodies) and these must be ratified by the people of Assam.

2. The question of downstream impacts along the river Brahmaputra must be recognised. Downstream impact assessments must be a pre-condition for all dam proposals.

3. There must be a cumulative impact assessments of all upstream dams in Arunachal Pradesh before clearance is given to construction of dams there.

4. The rights of the people of Assam over these water resources must be recognised by the GOI. Assam must have equal rights over the rivers which flow through Assam and this must be recognised by the GOI. Once these rights are recognised the share to be accrued from LSHP would be decided. (For instance, if Arunachal Pradesh can get 12 percent free electricity why not Assam is entitled for similar rights?)

5. We demand an immediate tripartite discussion with the Prime Minister of India, Government of Assam and Representative of downstream people of Assam who are agitating against the construction of Lower Subansiri Hydro Power Project. Such discussion must include the important question of rights of water and interstate Rivers.

6. Till all such issues are resolved, KMSS demands a moratorium on construction work of LSHP and other hydro power projects of the Brahmaptra basin.

We expect you to give these critical issues the importance it deserves. The Brahmaputra & Barak river basins are our lifeline and addressing these issues is essential to ensure the long-term social and environmental security of Assam.

(AkhilGogoi) (Kamal Kumar Medhi) (BedantaLaskar)
President (Joint General Secretary)

Krishak MuktiSangramSamiti Assam
5.12.2013