11th November 2013

To

The Member Secretary

EAC River Valley Projects

Ministry of Environment and Forests

New Delhi

Subject: Objections related to extension of Terms of Reference for the 520 MW Nakthan Hydropower Project

Sir,

This is in reference to the reconsideration of the TOR for the 520 MW Nakthan hydropower project. We would like to place in front of you some critical issues with regard to this project.

  1. The main affected Panchayat of the project area – Barshaini and its Gram Sabha of 8 villages has passed multiple resolutions opposing the project on the grounds that it will affect the local religious and cultural site of the Rudra Nag water fall. The diversion tunnel of the project runs underneath the source of the waterfall. The proposed tunnel for diverting the Tosh stream into the Parbati river is also going to endanger the Nakthan village and the locals apprehend destabilisation of slopes and landslides as a result of this.
  2. The project is proposed in the Parbati Valley, which is a valley of multiple significance – cultural, ecological and socio-economic. The Parbati River is a perrinial glacial river that is the life line of this valley with pristine forests and locations that attract trekkers from across the world which in-turn contributes to the local livelihoods.
  3. Beyond Rudra-Nag, there is a trail that ascends through thick mixed forests to the spiritual site of Kheerganga, a meadow at 2960m where Shiva is said to have meditated for 3000 years. The hot springs at Khirganga are extremely important for Hindu and Sikh pilgrims as well as many others who believe the waters have sacred healing properties.
  4. HPPCL has claimed that they have re-aligned the tunnels to address local concerns. However, we believe that a project of this scale which will require heavy blasting for tunneling, construction of roads and underground power house is bound to cause significant damage to the landscape as is evident in all such projects within the state. The proposed diversion tunnel site is at an altitude of almost 3000 m which is ecologically extremely fragile.
  5. The 800 MW Parbati-II project which is being built just downstream of the proposed Nakthan project has already altered the landscape significantly. While the project would virtually dry up the Parbati river downstream of the dam site at Barshaini, the tunneling operations have done immense damage to the drinking water sources in the Sainj valley. According to the data supplied by the State Irrigation and Public Health Department, 12 natural springs have completely dried up and water discharge has significantly diminished in at least 10 others due to the project. The project, besides using more than 90 Ha. of forest land, has damage much more forest wealth by illicit dumping of muck, for which the State Forest Department imposed fines worth more than Rs. 4 crores.
  6. We have also seen the earlier TOR granted to the project in August 2011 as well as the minutes of the EAC. In its meeting dated 20th August 2010, the EAC raised several issues with the shortcomings in the PFR and the data presented to the Ministry by the project proponents. In the following meeting in December 2010, the EAC reccommended the TOR without discussing the clarifications or whether the project proponents had addressed any of these issues.
  7. Despite the villagers having conducted 11 meetings in total till date with the HPPCL authorities, the project proponents have carried out the work without any NOC from the affected Panchayat, Barhsaini. It also needs to be noted that the survey works are going on in Forest lands, where the local people have community rights that have yet to be recognised under the Forest Rights Act 2006. Yet the project proponents have carried out the work without any NOC from the affected Panchayat, Barhsaini.
  1. We appeal to the EAC to assess the project keeping in mind the following issues:

·  Building of the project bumper to bumper with the Parbati-II hydropower project means the end of the free flowing Parbati river

·  The religious sentiments of the local people, infact the cultural identity, is closely linked with the Rudra Nag waterfall and the Parbati river, any damage and disturbance in the area will directly affect the local sentiment

·  The linkages between heavy blasting for tunnel construction and disappreance of water springs has already been established with data from the government’s own Irrigation and Public Health department. Therefore, any tunneling activity for this project is likely to have the same impact

·  The deforestation caused due to diversion of close to 100 hectares of forest land is also going to have an adverse impact of the rich local floral and faunal habitat

·  The defacing of the valley is likely to impact the tourism based livelihoods as trekkers prefer to visit this valley due to its pristine nature and wilderness.

·  No carrying capacity studies have been done in the valley so far to assess the impact of a project of this size and magnitude in addition to the existing Parbati II hydroproject

The EAC should consider making a site visit and studying these issues before granting the TORs to the project.

We are attaching here the relevant documents to support our submission

Sincerely

Om Prakash and Lal Chand, Gaon Vikas Samiti, Nakthan, Kullu

Lal Chand Katoch and Pushpal Thakur, Jan Jagran Evan Vikas Samiti, Kullu

Manshi Asher and Rahul Saxena, Himdhara Environment Research and Action Collective, Himachal Pradesh