CORE Comments on Project Design Document for the Jorethang Loop Hydroelectric Project, Sikkim, India
Submitted to Det Norske Veritas (DNV)
We have perused the PDD as obtained from the website, and found it seriously deficient in key aspects. Our comments below are brief and not comprehensive in addressing every aspect of the PDD.
The project cannot be taken as an additionality, as many viable alternatives exist. Moreover, the region is chock-a-block with hydrolectricity project proposals and projects that have been under consideration for many years. The project has been under proposal for some years too, and by 2003-4, was alloted to private sector developers by the Central Electricity Authority of India.
We recommend that this project in its present formulation be not awarded certification as a CDM.
1. A2: The project proposes a barrage on the Rangit River, creating of a reservoir of 10.1 Ha area for generation of zero emission electricity. The claim that the project will not generate any greenhouse gases is contrary to evidence available that reservoirs do emit GHGs that vary considerably seasonally and that generation activities of the turbines also emit GHGs. Further, it is not clear how this project will in fact “reduce” airborne pollutants though a reduction of combustion of fossil fuels, as combustion activities underway are in no way being replaced by this project.
2. A2: Temporary local employment cannot contribute to sustainable development. Also, the nature of the temporary employment is not specified.
3. A2: The assertion that there will no appreciable flow changes downstream of the proposed barrage/dam is not credible or acceptable. Flow change figures in the PDD do not give more details other than a simplistic figure of 15%. Similar projects such as the Ranganadi Phase I HEP on the Ranganadi River in Arunachal Pradesh, India have evidenced considerable downstream flow changes with unpredictable seasonal fluctuations that have led to the loss of human lives, massive erosion of livelihood generating and homestead lands on the river banks. The Rangit River is a glacier fed river. Glacial changes, mainly retreating glaciers and formation of GLOFs, due to rapidly increasing warming in the Himalayas has been documented by WWF as early as 2001-2002. Tremendous seasonal as well as year to year flow fluctuations are anticipated. The simplistic assertion that downstream flow and access will not be affected is unsubstantiated and cannot be accepted as contributing to sustainable development.
4. A2: This section also claims that the project is in compliance with the future plans of the Ministry of Non Conventional Energy Sources (MNES) of the Govt of India. This is false claim as the MNES only deals with hydroelectrtic projects that have less than 25MW installed capacity. The proposed project has an installed dcapacity of 96MW.
5. A2: There is also a claim that the 12% generated electricity royalty to Sikkim State – approximately 50 GWh (net) per annum – will in some way contribute to shifting away the local population’s use of wood-fuel. We do not see any linkage between these two notions. How does this happen?
6. A2: We also do not see how establishing hatcheries in the vicinity of the river can contribute to local indigenous Himalayan river fish and other riverine species, as what these hatcheries will actually hatch is not elaborated. The Environment Impact Assessment Report is not available to determine the nature and extent of the impact of this project on the aquatic life-forms of the Rangit River. Merely building hatcheries cannot be assumed to mitigate any adverse changes in the aquatic life of the river.
7. G1: We have reliable evidence that the local population (not described in detail in the PDD) hasn’t a clue regarding this project’s details or its envisaged impacts on the social and natural environment. The project proponent claims that a local public hearing was held in Piple. According to our information, the local population did not have access to any of the core documents required under the EPA (1986) of India and therefore could not have have had an opportunity to scrutinise the EIA/EMP and ive their considered comments and opinions about the project.
According to our information, the project applicant (DANS) has not responded to a formal request to share the full and detailed reports of the public hearing or the EIA/EMP.
8. F2(iii): It is established that the use of “fish-ladders” is not conducive to the survival of every kind of fish species found in rivers. In fact, fish ladders have found limited success only. The commenter visited a hydrolectricity project site in eastern Thailand where the fish ladders had totally failed to function.
9. F2(iv): We have evidence that non-indigenous labour force inflow into the fragile and small Himalayan communities has had some quite dramatic impacts on the local public health scenario. One serious problem is that of sexually transmitted infections (STIs) among the labour force. India is presently in the middle of a widespread high incident HIV/AIDS epidemic. Primary Health and Public Health measures to tackle STIs and related behavioural changes are not clearly described.
10. F2(x): The R&R plan is vaguely described in the absence of a detailed plan as per the EIA/EMP document. No clear picture emerges from the PDD regarding the nature and extent of displacement as a consequence of the project, or the nature of the Rehabilitation and Resettlement package being offered to the affected families. Is land for land being offered? How? What can be concluded from the assertion that “No family will become landless as a result of the project”? The social impacts and mitigation measures are not credible, nor in line with the claimed contribution of the proposed project to sustainable development.
11. The commenter has lived in Darjeeling (on the Rangit River) for six years, in the immediate neighbouring District of West Bengal State of India. Familiarity with the Rangit River valley has led to the belief that one serious flaw in the environment impact assessment and mitigation measures described in the PDD is the total lack of mention of the frequent landslides, mudslides and seismicity of this young and frangible mountain region. There is no mention of a Disaster Management Plan in the PDD.
12. G3 mentions a number of measures to be taken up in response to concerns expressed at the pubic hearing held in Piple. Included among them are (4) Provisions shall be made to address the potential problems of slips and landslides, as outlined in the EMP. What these measures are actually have not been elaborated upon. As these are a serious concern in the region, the EMP must be very closely examined first to establish their credibility beyond reasonable doubts.
In view of these observations regarding the PDD, which is surfeit of unsubstantiated and incredible claims and assertions, we cannot recommend that this project be certified.
CORE Centre for Organisation Research & Education
(Indigenous Peoples’ Centre for Policy and Human Rights in India’s North East)
NGO in Special Consultative Status with the Economic and Social Council of the United Nations
Nongmeibung Nambam Chuthek
Tel: +91 385 244 48 45/ 244 13 19
Telefax: +91 385 222 81 69