Small Hydro, MNRE and environmental impacts: Nero’s fiddle playing

Ministry of New and Renewable Energy (MNRE), Government of India recently published a report on ‘Developmental Impacts and Sustainable Governance Aspects of Renewable Energy Projects’. Around the same time, Karnataka High Court upheld Elephant Task Force’s recommendation about impacts of Small Hydro Projects (SHPs) on Elephant habitats and directed Karnataka Government to review clearances of all such projects affecting elephant habitats[i]. SHPs are hydel projects between 2 MW-25 MW installed capacity. Looking at the unaddressed impacts of SHPs, such a report by MNRE was sorely needed and was looked at as a welcome initiative.

Unfortunately, the MNRE Report has entirely excluded the small hydel sector from its assessment.

Agitation against 4.5 MW Hul HEP in Himachal Pradesh as it is affecting forests, irrigation channels, mills and drinking water sources of villagers. Source: Sal Ghati Bachao Andolan

SHPs can have and are having severe impacts on communities and ecosystems. They fall under the MNRE and are exempt from environmental impact assessment, public hearing, and environmental management plan as EIA Notification 2006 restricts itself to projects above 25 MW. They get subsidies, tax rebates, tax holidays from the MNRE, apart from other benefits and preferential tariffs from states. Most of the SHP sector is crowded with private investors, wanting to make a quick buck from rivers, without any regulations. The rush is most prominent in Uttarakhand, Himachal Pradesh, Karnataka, Odisha and now Kerala, where cascades of such dams are coming across pristine rivers.

Despite MNRE’s supposed intention, most SHPs are not supplying electricity to any “remote and inaccessible areas”.[ii] Most projects are grid connected, so the local communities do not get electricity from the projects in their backyards, across their rivers which have significant impacts on local water availability, habitat loss, submergence and fraudulent practices.

Following a petition from Western Ghats Forum, Karnataka High Court has ordered a ban on SHPs in Western Ghats, Uttarakhand High Court had cancelled as many as 56 SHPs. In Himachal, communities fought a long and lonely struggle against the 4.5 MW Hul project affecting drinking water security and irrigation of 6 villages, as well as ancient oak forests. [iii]Projects like 24.75 Kukke I in Dakshin Kannada can submerge a massive 388 hectares, including extremely biodiverse forests, plantations and houses.[iv] Greenko’s Perla and Shemburi Projects[v], Basavanna and Mauneshwara SHPs in Karnataka are examples where two 24.75 MW SHPs are fraudulently shown as separate projects, but are single projects on the same river with a common dam. Maruthi Gen projects, also in Karnataka were not only clubbed together, but also hid their significant impact on forest land[vi] . Submergence data of SHPs is routinely hidden & affected communities are kept in dark till water actually floods their lands.

The issues are serious and have been raised by many. As the projects are outside the purview of EIA Notification, none of their impacts are studied; neither do the communities get a platform to record their protests. Hence, a study on the environmental impacts of renewable energy projects was needed to address these issues.

Considering these serious aspects, it is very surprising that MNRE Report on impacts of Renewable Energy projects has chosen not to look at this sector at all.  The report does not assess impacts of any such projects, neither does it offer any recommendations for this sector under MNRE. It only makes a sketchy study of wind and solar energy projects. The report makes incorrect statements like: “All hydroelectric power projects have to get environmental clearances which under two categories: category B if capacity of projects is between 50 to 25 MW”, effectively refusing to acknowledge hundreds of SHPs, under the purview of MNRE not requiring any environmental regulation.It states incorrect facts like “There are institutions and processes governing every operational aspect of RE project development and local institutions, in the form of democratic bodies, to safeguard micro level ecological and social concerns.” This is patently untrue for SHPs, which are highly unregulated and non-participatory.

The TORs of the study stress assessment of impacts of solar and wind projects, but do not exclude hydel projects. While TORs should have stressed on impacts of SHPs, looking at the number of protests and inherent problems, that does not warrant report writers’ complete neglect of this sector. Executive Summary states that this study has been done in response to WGEEP and HLWG report recommendations. Despite the fact that WGEEP specifically banned SHPs in Ecologically Sensitive Zone I, this report has chosen to turn a Nelson’s eye to the sector.

Even with regards to solar and wind projects, the report seems inadequate. For primary data, the authors visited 6 wind energy farms and 1 solar energy site. At the solar energy site, interaction was exclusively with project management and engineers. Social and environmental impacts cannot be understood through interviews with project management alone. While the report documents the devastation around wind energy farms in Maharashtra, it is not reflected in conclusions and recommendations.

The report is entirely silent on Clean Development Mechanism applications of SHPs, which are routinely full of lies and incorrect information. CDM credits give project additional pocketable profits, while the affected communities get only unaddressed impacts. Considering the forest land submerged by Small hydel Projects, and their impacts on adaptation and mitigation potential of local communities, they are also problematic from perspective of climate change.

The report ends with unacceptable conclusions and recommendations, most surprising being: “The RE project development is regulated by environmental and social governance system. The current regulatory mechanism is strong… No new changes are required in the legal framework or the governance structure to mitigate environmental and social impacts.” It even pushes for a “fast channel for quick clearances”.

The report says that environmental impacts of RE projects “are not significant” and social impacts of are “not negative”. Report writers need to visit SHPs in Himachal, Uttarakhand and Karnataka where people have lost irrigation channels, water mills, plantations and even lives, when sudden water was released from projects like Perla-Shemburi in Bantwal[vii], Karnataka.

Sweeping conclusions and recommendations for the entire RE sector is highly problematic, especially when there are several examples of unaddressed impacts, which depend on specific site and project.

The report does include some welcome recommendations. These include: siting policy for projects including zonation and increased participation of local communities in planning and decision making about natural resources, affected by the projects. It recommends issuing clear guidelines such that community welfare is not compromised due to RE projects and about proponent’s responsibilities in the zone of influence of the RE project. The report recommends zonation of projects in go-green (no objection), go slow and no go areas for RE project development. These need to be implemented by the MNRE. If the report would have looked at the entire RE sector, it could have made some valuable observations and recommendations.

There is a very urgent need to bring projects between 1 – 25 MW under the purview of EIA Notification 2006. Several representations and evidences later, it is clear that MoEF does not have the will to do so. It was expected that MNRE will raise these issues, but if this report is an indication, MNRE too is not willing to accept the challenges of SHP development, or regulating the impacts.

Lower installed capacity does not always mean lower social or environmental impacts. Targeted efforts are needed to assess, address and mitigate impacts. For this, the first step will be to acknowledge impacts, not brush them under the carpet. World over, impacts of small hydro projects are being highlighted.

As India is looking at expanding its renewable energy sector, it needs to be truly sustainable and clean, not just an assumption. Hence, MNRE’s effort at addressing environmental and social impacts of renewable energy projects is a welcome move. But by refusing to acknowledge the impacts of Small Hydel Projects in its report, MNRE reminds one of Nero, playing his fiddle, when the forests around are being submerged or destroyed in the name of clean energy.

Parineeta Dandekar