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 A  Critique  of  the  Nyamjang  Chhu  Hydro-­‐electric  power  project  Environmental  Impact  Assessment  (EIA)  and  Environmental  Management  Plan  (EMP)    Working  Paper  No.  2,    Nature  Conservation  Foundation,  Mysore    Introduction  The Nyamjang Chhu hydro-electric project is designed as a run-of-the river project, which will harness the hydropower potential of the Nyamjang Chhu river with a diversion barrage near the Zemithang village and a powerhouse near the confluence of the Tawang Chhu with the Nyamjang Chhu (Figure 1). The total potential of the basin is around 900 MW. The project proposes to generate 780 MW in an underground powerhouse. It will consist of a 11 m high barrage, 175 metres in length and a tunnel of 20 odd kilometres diverting the water to the powerhouse downstream near Lumla. The Government of Arunachal Pradesh awarded the work of development of the hydropower potential in the Nyamjang Chhu river valley (also known as the Pangchen Valley) in Tawang district to Bhilwara Energy Limited (BEL) in 2006. WAPCOS Ltd. and RS Envirolink Technologies Private Ltd were commissioned to carry out the EIA and EMP for the proposed project. They undertook the EIA studies in 2007-2008. As biologists/ecologists who have undertaken research and field surveys in the area and are familiar with the wildlife values of the area in which this hydropower project is located, we assessed whether the Environmental Impact Assessment (EIA) and Environmental Management Plan (EMP) documents prepared by these agencies had adequately studied or considered the ecological and environmental aspects of this proposed project. We also referred to past and current research work by other institutions and organizations in the area. We note with concern that there are numerous omissions, errors and flaws with the EIA and EMP documents. However, this is not an exhaustive critique. We outline below our major comments on the EIA and the EMP that deal with mainly the wildlife and environmental aspects and impacts. Our comments on the EIA report are with reference to 1) sections in Chapter 3 that relate to the methods adopted for floral and faunal studies, 2) Chapter 6 – Baseline setting for Ecological Aspects and on sections of Chapter 8 – Prediction of impacts with respect to impacts on wildlife, habitat and environment. We make a few additional observations on a section of Chapter 7 – Baseline setting for socio-economic aspects based on our prior experience in the area and familiarity with the socio-economic conditions, culture and lifestyle of the people.  Chapter  3.  Methodology  adopted  for  the  EIA  study  The EIA report has mainly relied on secondary data from the Forest Department for the study of ecological aspects and some unclear reference to “research institute forest and wildlife department’. Under the methodology chapter for ‘Ecological

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aspects of Terrestrial Ecology’ for Flora – they state that ‘field studies were conducted to collect data on various aspects in the study area”. There is no information given as to what exactly these studies were, how they were conducted, over which time period and when. This chapter only states that sampling sites were selected based on topography and floristic composition and density, frequency and abundance of trees, shrubs, herbs and grasses were made and that plants of economic and medicinal value and endangered species were identified. The subsequent chapter on floral studies however, does provide methods and some details and primary data appears to have been collected for flora and vegetation studies, and for aquatic ecology and socio-economic & demographic aspects.   The faunal assessment is inadequate with almost total reliance only on secondary data and on confirmation from local inhabitants. As an afterthought, there is a statement on ‘sightings of faunal population during survey and then field studies were also recorded as a part of the data collection exercise’. There are no detailed methods outlining what the studies did, how was sampling done, what data was recorded, when and over what time period it was carried out and what the effort was. The purpose of an EIA on the ecological aspects or value of an area is not simply to compile a list of species that are known to occur there, but also to assess the impacts and threats and evaluate how the proposed dam might affect these species and their habitat. In that regard, while the EIA would necessarily have to rely on some past secondary data, they would also need to do a critical evaluation of what might be the effects of the dam on different species, and whether there are any important threatened species that use the project-affected area and surrounding areas and what the consequences of that permanent habitat loss might be. Even if the EIA relied on secondary data, these need to be reliable and exhaustive and the sources need to be mentioned in detail. It does not appear that for this EIA study, any extensive literature review or secondary sources were referred to, as the reference list does not include a number of publications, reports based on the ecological studies/surveys carried out by a number of organizations like WWF and NCF apart from other research institutions such as NERIST, GBPHIPED, Arunachal University, SFRI and other government and non-government organizations. The primary data that was collected for the EIA was initially done by one agency (WAPCOS) for 3 seasons (Aug-Sept 2007, Dec-Jan 2008, Apr-May 2008) and then was later given to another agency (RS Envirolink Technologies Private Limited) for 3 seasons (Apr-May 2008, Jul-Aug 2008 and Nov-Dec 2008). It is not clear which agency collected data on what aspects and whether they both followed the same protocols and methods. Later in a table it is mentioned that floral and faunal diversity were the parameters monitored and that the field studies were carried out over 3 seasons. For aquatic ecology, it is stated that presence and abundance of various species were monitored. Chapter  6.  Baseline  setting  for  ecological  aspects  COMMENTS  ON  THE  FLORA  SECTION   The EIA states that no rare and threatened plants of the region occurred at the site. While the exact project site may not be species-rich in terms of flora, the immediate

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surrounding area harbours high floral diversity including many rare threatened plants including economically important plants, medicinal plants, orchids and rhododendrons (Choudhury 1996, Chowdhury 1998, Mahanta & Tiwari 2005, Paul et al. 2005) and given the additional direct and indirect negative impacts of a large migrant population and road construction and several other project activities, the project would have high levels of impact on native flora and habitats. Arunachal Pradesh is known to have 61 rhododendron species, of which 30 different Rhododendron species have been identified in different areas of West Kameng and Tawang districts (1500-4000 m). Out of these 4 are rare and 1 threatened (Paul et al. 2005). From a short survey, Mishra et al (2004) had recorded 140 plant species from the survey in Tawang which itself is not an exhaustive list. In fact, the Zemithang Valley has trees of Taxus wallichiana an Endangered species that has medicinal value and is commercially important, which were being protected by the Monpa people of Lumpo village. Some specific comments on the floral studies:

1. There are several factual/calculation errors in the basic data analysis with proportions calculated from their own data.

2. Standard vegetation study protocols were not followed for sampling by the 1st agency WAPCOS Ltd. For example: tree density was measured for only trees > 8 m, while usually the criterion used is to consider trees with GBH ≥ 25 or 30 cm.

3. In the section presented by RS Environlinks, they talk about species accumulation curves but they have not presented the data.

4. The results given by WAPCOS and RS Environlinks are not comparable. For example, in the submergence area, the tree density given from data by WAPCOS is 270/ha (a possible consequence of counting only trees > 8m) while that of RS Environlinks is 620/ha as they considered individuals with > 31.5 cm to be trees. In addition, the list of dominant species for the submergence area between the two studies gives different results.

COMMENTS  ON  THE  FAUNA  SECTION    A survey carried out in 2004 by ecologists from the Nature Conservation Foundation reported 35 mammal species from 6 areas in Tawang (Lower Nyamjang Chhu, Upper Nyamjang Chhu valley, PTSO, Mukto, Mago Chu). While 35 species were confirmed from the entire area, at least 21 mammal species (including 3 endangered and 4 vulnerable species) were recorded either through direct sightings or reliable local evidence in the Lower & Upper Nyamjang Chhu Valley (Mishra et al. 2004, Mishra et al. 2006). Even though the rest of the species was not confirmed, most of these other species are likely to occur in the Nyamjang Chhu valley. Several of these species are not listed by the EIA. These include otters, Himalayan marmot, orange-bellied squirrel, serow, bharal, and pikas apart from some other species. It is clear that the EIA team had failed to even carry out a proper documentation of secondary data/literature on past ecological work in the area. During the same survey, 150 bird species were recorded from Tawang district (Mishra et al. 2004) which itself does not include all the potential bird species likely or known

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to occur in the area which is extremely rich in bird species. The bird lists provided by the two agencies are incomplete and include some species that are unlikely to be found there.   Singh (1999) reported 118 species in the Tawang-Zemithang area between 1,770 and 4,900 m above msl. They recorded the following species from this site: Peregrine Falcon Falco peregrinus, Upland Buzzard Buteo hemilasius, White-browed Tit-Warbler Leptopoecile sophiae and Streaked Rosefinch Carpodacus rubicilloides which were new records for Arunachal Pradesh (Islam & Rahmani 2004).  

The EIA report mentions that there is no Wildlife Sanctuary, National Park or Biosphere Reserve within the study area and that there is no ‘wildlife corridor’ in the project area. There is no discussion of the wildlife values of the area. While the Nyamjang Chhu valley does not include any national park or sanctuary, the area has significant wildlife values. It is close to an area earlier designated as a biosphere reserve (Mishra et al. 2006). The Zemithang-Neyla area is also listed as an Important Bird Area (IBA code: IN-AR-28) in which several bird species listed as Vulnerable and Near Threatended by the IUCN are reported (Islam & Rahmani 2004). These include species such as Satyr Tragopan Tragopan satyra, Wedge-billed wren-babbler Sphenocichla humei and Ward’s Trogon Harpactes wardi, which are categorized as Near Threatened, while species such as the Black-necked crane Grus nigricollis, Beautiful Nuthatch Sitta formosa and Mishmi Wren-babbler Spelaeornis badeigularis are listed as Vulnerable. The site is included in the Eastern Himalayas Endemic Bird Area (Stattersfield et al. 1998). Species such as the White-naped yuhina Yuhina bakeri, Brown-throated fulvetta Alcippe ludlowi, Broad-billed warbler Tickellia hodgsoni, Hoary-throated barwing Actinodura nipalensis are reported and are some of the important endemic area species. This site is also important for biome-restricted species. Of these, some other interesting species found in this IBA are the Himalayan Griffon Gyps himalayensis, Snow Partridge Lerwa lerwa, Ibisbill Ibidorhyncha struthersii, Snow Pigeon Columba leuconota, Grey-backed Shrike Lanius tephronotus, and Blood Pheasant Ithaginis cruentus. Secondly, there are two recently established Community-Conserved Areas (CCAs) which have been set aside and is being protected by the community with assistance and advice from WWF in the Nyamjang Chhu Valley (also known as the Pangchen Valley. The Monpa people in this area have banned hunting and fishing and regulate collection of the other produce strictly (Mishra et al. 2006, Aiyadurai et al. 2010). They fear that with the influx of a huge migrant population there will be greater pressures on forest resources and increased poaching and fishing. In addition, the Nyamjang Chhu river valley is one of the few wintering sites in the world visited by the black-necked crane (about 7 birds) listed as Vulnerable by IUCN and BirdLife International (2001). The valley suitable for the Black-necked crane is from Brokenthang (27°43’ 38.47” N, 91° 42’ 51.08” E) to Zemithang (27 ° 42’ 38.47” N, 91° 43’ 39.69” E), a 3 km stretch at an average altitude of 2000 msl (Dutta 2010, Rahmani 2012). The average width of the valley is 0.30 and water flow in this stretch of the river is gentle with small seasonal islands and grasslands on both sides. Locals who call the bird ‘Thung-thung Karmo’ revere the bird and report that the cranes have

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visited the valley since time immemorial. This crucial wintering area overlaps with the project site (see Fig. 1). Apart from the black-necked cranes, the valley is also home to other Schedule 1 species such as the red panda (Ailurus fulgens) in the Zemithang- Lumpo area, and the snow leopard (Panthera uncia) in the Nelya-T Gompa area, musk deer (Moschus sp.) and takin (Budorcas taxicolor) in the higher reaches and the Arunachal macaque Macaca munzala, a newly described primate species in the area (Sinha et al. 2005). There are several troops of the Arunachal macaque in the Zemithang Valley and is one of the primary habitats for this species (Kumar et al. 2007, Mendiratta et al. 2009). The EIA report does not record any of these facts nor does it refer to any of this extensive literature in its report. This is a serious omission and it incorrectly states that the area and its surrounding areas harbor no rare or endangered wildlife. On page 51, in Table 6.27, the 11 mammals, 25 birds, 8 reptiles and 10 amphibians ‘reported’ by WAPCOS is listed. The other agency RS Envirolink Technologies Pvt Ltd again provides two tables listing 17 species of mammals and 109 species of birds in the area. Some specific comments on the species lists provided are below:

1. It is not clear whether they have reported this based on primary or secondary data or from local information.

2. If it is based on primary data, some details or clear statements on date, location and other notes on the sightings should have been provided.

3. If it is based on secondary data or local information, again the source and other details of the type of evidence should be provided.

4. The scientific and even common names of some species are wrongly given. 5. In both the lists there are various errors regarding the mammal species

recorded. Some of the mammal species listed (eg. Jungle cat, hoary-bellied squirrel, Crab-eating mongoose), although possible, is very unlikely to occur in the area (based on their known distribution or elevation and habitats used). Details of the record should be provided, if direct evidence was obtained or if from a reliable source and the type of evidence so that the information can be verified.

6. Hog deer (Axis porcinus), listed by RS Envirolink in Table 6.28 is a grassland species in lower altitude areas does not occur here.

7. The species of porcupine (Hystrix indica) listed by the 2nd agency is unlikely to occur here. The porcupine species that occurs here is Hystrix brachyura.

8. Several of the bird species listed are low-altitude tropical forest species (for example: purple sunbird, olive bulbul, pied crested cuckoo, wire-tailed swallow) and are unlikely to occur here. Again, it is not clear whether these lists are based on primary data or some secondary information from the site as no details are given on observation periods/methods or sources.

9. RS Envirolink listed 109 bird species in Table 6.29, which includes Eurasian Griffon (Gyps fulvus), Himalayan Griffon (Gyps himalayensis), Golden eagle (Aquila crysaetos), and two restricted-range bird species White-naped yuhina (Yuhina bakeri) and Broad-billed warbler (Tickellia hodgsonii), but these are not noted to be of any significance.

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10. Several of the scientific names and common names of birds, reptiles, and amphibians are wrongly written/spelled.

11. It is not clear whether the survey team have the requisite expertise to correctly identify all the snakes and amphibians listed. Herpetofaunal identification usually requires some expert knowledge. It is not clear whether specimens were sighted directly, captured, photographed and measured for obtaining identification or this list is based on secondary sources and if so, what is the source. In addition, the amphibian and reptile list is far from comprehensive.

12. Given all this, the authenticity and competence of the agencies to undertake floral and faunal surveys and their ability to correctly identify several of these species is questionable.

13. Surprisingly, no reference is made to the legal protection status of the species recorded by the 2nd agency (RS Envirolink Private Ltd) which includes species like the red panda, takin, musk deer, Himalayan black bear and the snow leopard, while a table is provided by the 1st agency (WAPCOS Ltd) states that out of 65 faunal species, only 6 species fall under various Schedules of the Wildlife Protection (Act) 1972! This carefully omits any reference to some of the Schedule I species listed in Table 6.28 by RS Envirolink Private Ltd.

14. In addition, they have ignored butterflies, which is a diverse group, which they have not sampled, and possibly harboring some of the rare species.

There is no further discussion based on faunal values and possible impacts based on any primary data which according to the methods chapter have been collected over 3 separate visits of ca. 1 month across all 3 seasons. There is no critical evaluation of how various construction activities, waste disposal, noise levels, increased vehicular movement and influx of migrant labor population can have various kinds of negative impacts on biodiversity, both short-term and long-term.  Aquatic  ecology  The EIA report lists 16 fish species by WAPCOS and 16 by the other agency. Surprisingly, only 3 fish species are common to both lists. The fish list includes several threatened and endangered species. Important fishes like snow trout (Schizothorax spp.) and mahseer (Tor spp.) endemic to the Himalaya and listed as Vulnerable under the IUCN Red list of Threatened species occur in the area. The National Bureau of Fish Genetic Resources, Lucknow, has also assessed the conservation status of several of these species as threatened. The EIA report itself acknowledges that the proposed dam may obstruct the migratory route of the mahseer and snow trout which migrate upstream along the Nyamjang Chhu river during summer and monsoon for breeding (May-June) and comes downstream in winter. The EIA and EMP makes suggestions for fish ladders, which they suggest, will take care of the problem. However, fish ladders have questionable value in helping fish migrate as many scientific studies have shown (see References) and it is also unlikely that these can or will be implemented.    Road  construction  

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The Environmental Impact Assessment has grossly underestimated the negative effects of the roads that will be constructed for the project. NCF's background paper 'Framing Ecologically Sound Policy on Linear Intrusions Affecting Wildlife Habitats' has shown with summarized evidence that 1 km of road directly affects 10 ha of a habitat. With 100 km roads being built for the project (new roads to be constructed: 60 km, road to be constructed to the much dumping yard: 40 km) and about 140 km road to be widened, the project will affect at least 1000 ha or 10 sq. km. In addition, the tremendous increase in vehicular movement is likely to cause loss of wildlife due to roadkills, which has not been mentioned.    

Chapter  7.  Baseline  setting  for  socio-­‐economic  aspects  Socio-­‐economic  aspects  and  demography  Although 75% of locals interviewed are hoping to get jobs according to survey, but most skilled labour is from outside as major works are contracted out and they get their own skilled labour from outside. The EIA itself acknowledges that very few locals will get employment even in the unskilled category in the temporary construction phase. The EIA states that 75% people were aware of the proposed project, while 80% were interested in cash compensation. Yet only 11% were aware of the displacement of 47 project-affected families. While the EIA states there are only 47 families that will have to lose their land, and the rest is not private land. The fact is that most of this other land is community forestland or areas used by the entire community as common property resources. It is not clear who will be compensated for the rest of the land that has to be acquired. At one place, the EIA states that increase in immigrant population maybe around 3500-5000. At another place, they estimate that increase in immigrant population is estimated to be around 11, 200! The total local population in five circles of the study area is 11, 445, while Zemithang circle itself only has a population of 647 people. This will lead to a huge influx of migrant population who may reside in the area for at least six years, if not more. This one fact itself negates any imaginary benefits that people may obtain from the project in terms of employment and/or ‘development’. Chapter  8.  Prediction  of  impacts  Impacts  on  Terrestrial  flora    Increased  human  interferences    The impact expected on the habitat by the EIA report’s own estimates is huge (> 2-3 ha of additional forest loss for just meeting fuel needs of migrant labor force) and the mitigatory solutions offered to minimize impacts such as community kitchens to use LPG or diesel are not practical and likely to be implementable given many logistic factors and the poor supply and distribution of LPG/diesel in these areas. The EIA states that in addition to cutting fuelwood for energy needs, the workers may also cut more trees for construction of houses etc. Then it avers that labour camps would be constructed and therefore these adverse impacts are not expected. The construction of labor camps will need additional materials – are the materials going to be sourced locally or transported from outside? If so, who will ensure that these guidelines are followed in practice and not only on paper? Who will monitor the work during the

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construction phase to ensure that the EMP is followed? If in practice, these alternate fuel sources are not available, this means that the local population will have to share existing limited forest resources with the migrant workforce, which will lead to additional social conflicts and hardships for the local population apart from the considerable damage to the forest. IMPACTS  ON  BIOLOGICAL  ENVIRONMENT    Construction  phase    Acquisition  of  forest  land  A ‘good’ forest can also have 300-400 trees per ha – indeed many lower altitude tropical evergreen forest sites in Protected Areas in Arunachal Pradesh have tree densities which are between 300-500 trees per ha, so it is incorrect to say that just because 2 of the sampled sites had < 300 trees per ha, that it is not important. Indeed, a few of the sampled sites had tree densities higher than 300 trees/ha. In any case, the sampling protocol followed by the two agencies for enumerating trees was different resulting in very different estimates of tree density for the same site (while the 1st agency reports 270 trees/ha for the submergence area, the 2nd agency records 670 trees/ha. In addition, this area is a subtropical to temperate ecosystem, which is unlikely ever to have 1000-1200 trees per ha, even in a dense forest. While evaluating the ecological importance of an area, the composition of herbs and shrubs and overall species diversity is also important. The area has a number of important medicinal plants (Choudhury 1996, Choudhury et al. 2007, Namsa et al. 2011) and is rich in various species of alpine herbs, rhododendrons and orchids (Chowdhury 1998, Paul et al. 2005).

Impacts  on  Terrestrial  fauna    Construction  phase    Disturbance  to  wildlife The EIA states that no major wildlife is reported in the submergence area (39.3491 ha) and that the project area and its surrounding area are not reported to serve as wildlife habitat and are not on any known migratory route. As has been commented elsewhere this is not true. The area is habitat for a number of wildlife species and two endemic fish species migrate upstream for breeding as has been mentioned by the EIA report itself. It is also a wintering site of the black-necked crane. The total land area to be affected is not just the submergence area but is 255 ha. The EIA report glosses over the various construction phase disturbances (movement of machinery and large number of workers, blasting, noise and siting of equipment, godowns, labour and construction camps) by suggesting that if certain measures followed as laid down in the EMP, there will be no problem. They suggest that to prevent poaching by immigrant labour population, “strict anti-poaching surveillance measures need to be implemented”. Who will ensure that no poaching occurs, who will undertake this strict vigilance and compliance? Given that the Forest Department is under-staffed and does not have a significant presence here and is often unable to enforce compliance in normal instances inside existing Protected Areas, it is highly unlikely that project authorities will ensure that strict anti-poaching measures are taken. They also suggest that blasting and other impacts due to noise can be mitigated

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by controlled blasting and strict surveillance regime and that this will be followed by the project authorities. Most of these mitigatory solutions are unlikely to be practically implemented. Once the project is granted clearance, what is the guarantee that guidelines in the EMP are followed? And if not, who will penalize violations? Impacts  on  migratory  routes  The EIA states that faunal species observed in the project area are not migratory and that the construction and the reservoir is not on any migratory route of any major faunal species. They fail to mention the two species of fish whose migratory routes are likely to be obstructed. Fish are also fauna! Species like black-necked crane are migratory and are winter visitors. The other point here is that while earlier they state that the area to be submerged is 39.3491 ha, here it states that the reservoir will be 41.268 ha. Impacts  on  avifauna  The EIA statement that the project sites does not harbor any significant avifauna is wrong. The project area and its surrounding area harbors rich avifauna. The area is the natural habitat for subtropical, temperate and alpine bird species and not necessarily only for water birds. So the contention that by creating a reservoir, the project will result in better conditions for water birds and hence result in increased birdlife is flawed and not based on a sound ecological understanding. In any case, the area does naturally harbor several aquatic and/or riverine bird species, which are adapted to that environment, and is visited by some migratory species including the black-necked crane. Operation  phase  impacts  Increased  accessibility    The EIA states that due to the project, accessibility to the area will increase with road construction, which can increase anthropogenic pressures leading to impacts on the terrestrial ecosystem. But again, this is glossed over by saying that no significant wildlife is found here and that adverse impacts will be marginal. With the influx of such a large migrant population that will be resident for up to 6-7 years in the area, there are going to be severe impacts on the surrounding forests with requirements of fuel wood, poaching of wildlife is likely to increase along with collection of high-value medicinal plants and greater links to outside traders. Apart from the effects on the habitat and wildlife, this will lead to potential conflicts with the Buddhist Monpa population in this area who has had a tradition of protecting wildlife and regulating harvest and natural resource extraction. It is unlikely that any agency or authority will be able to monitor or regulate all these adverse impacts of a large labour force over an extended period of time. Impacts  on  Aquatic  Fauna  Construction  phase  Impacts  due  to  excavation  of  construction  material  from  riverbed  The EIA report states that during the construction phase a large quantity of construction material like stones, pebbles, gravel and sand would be needed and that this would be extracted from the riverbed. The EIA states, “The extraction of construction material may affects the river water quality due to increase in the turbidity levels.”

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They further state that “Almost all the cold water fish breed in the flowing waters. The spawning areas of these fish species are found amongst pebbles, gravel, sand etc. The eggs are sticky in nature and remain embedded in the gravel and subsequently hatch. Any disturbance of stream bottom will result in adverse impacts on fish eggs. Even increase in fine solids beyond 25 ppm will result in deposition of silt over the eggs, which would result in asphyxiation of developing embryo and also choking of gills of young newly emerged fry. Thus, if adequate precautions during dredging operations are not undertaken, then significant adverse impacts on aquatic ecology are anticipated.” The EIA also states that the proposed hydro-power project will result in construction of a project colony at Sherbang village and labour camp and colonies at Kyaleyteng, Kherteng, and Sherbang. They state “This would result in emergence of domestic waste water which is usually discharged into the river.” The EIA also states that presence of a large migrant labour force in the project area might result in enhancement in indiscriminate fishing including use of explosives. They further state, “The use of explosive material to kill fishes in the river in the project area would result in complete loss of fishes and other aquatic life making a river stretch completely barren.” Thus while the EIA itself acknowledges several significant negative impacts on aquatic fauna and the riverine habitat, yet it largely glosses over these by suggesting that units for treatment of domestic sewage would be set up before discharge into the river or by unclear statements that adequate precautions should be taken during dredging operations or that concerns regarding over-fishing by the labour force has been taken care of in the EMP. Impacts  due  to  discharge  of  sewage  from  labour  camp/colony  Impacts  due  to  human  activities  Operation  Phase  Impacts  due  to  damming  of  river  The EIA itself acknowledges that the damming of the river will result in significant changes to the riverine ecosystem and result in transforming a fast-flowing mountain river into a slow lacustrine environment. They state “The creation of a pond will bring about a number of alterations in physical, abiotic and biotic parameters both in upstream and downstream directions of the proposed barrage site. The micro and macro benthic biota is likely to be most severely affected as a result of the proposed project.” Yet, they gloss over all these impacts by saying that the creation of an artificial water body will help in growing fish stocks and that commercial fishing could be started to meet local protein requirements. This does not in any way compensate for the alterations and damage due to change in the water flow regime and natural environment. In any case, local people do not harvest fish at that scale for commercial purposes here and it cannot be pre-supposed as a positive impact or beneficial to people. People in fact have banned fishing in several parts of this area. They meet their local protein requirement without such perceived ancillary benefits from projects. In the same section, later on, the EIA states “The reduction in flow rate of river Nyamjanghhu especially during lean period is likely to increase turbidity levels downstream of the dam. Further reduction in rate of flow may even create condition

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of semi-dessication in certain stretches of the river. This would result in loss of fish life by poaching. Hence, it is essential to maintain minimum flow required for well being of fish life till the disposal point of the tailrace discharge.” However, there is no further discussion of how and whether these negative impacts can or will be mitigated. Impacts  on  migratory  fish  species  The EIA makes an important point that the dam would result in hindering the migration of fishes like the mahseer (Tor spp.) and the snow trout (Schizothorax sp.). Yet again, they gloss over this by suggesting mitigatory measures like fish ladders that are unlikely to be constructed and which have actually been shown to be harmful in several studies (cited later in the comments on the EMP). Artificial seed production in hatcheries is also unlikely to happen and does not really compensate for obstruction of wild fish migratory routes! IMPACTS  ON  SOCIO-­‐ECONOMIC  ENVIRONMENT  The EIA report highlights and lists the possible negative impacts of the influx of the migrant labor populations. For the local people of the area and in terms of their projected impact on forest resources and wildlife, this is one of the main primary negative impacts of the project. Past experience in many such development projects in remote sites shows that migrant populations have high negative impacts on forests and wildlife apart from the negative impacts for local people. Despite this, the EIA largely glosses over these concerns and does not address the issue critically. Economic  impacts  of  the  project  The EIA speculates that local people will benefit through indirect employment such as small shops, food and tea stalls and that the business community as a whole will be benefitted. This is highly speculative and not borne out by past experience in other such projects. As stated earlier in the report, the benefits stated for direct employment will not accrue to locals, the benefits of indirect employment stated are notional and marginal. In terms of costs to local people it is much greater. In any case, the local people here are agro-pastoralists and while some few individuals may benefit from temporary shops etc, this cannot be projected as a positive impact. People are not only concerned about marginal ephemeral monetary benefits. Impacts  due  to  land  acquisition  The total land requirement for the dam is 254.55 ha, of which 10 ha is private land, which needs to be acquired from 5 hamlets/villages from 47 project-affected families. Most of the land to be acquired is community land. Land in this hilly terrain is at a premium and it is not clear what is the compensation and whether it is adequate. It is not clear from the EIA whether this is acceptable to the community and the particular families. In a recent survey of nine villages (Lumpo, Muchat, Brokenthang, Shoktsen, Kalenteng, Kharman, T Gompa and Zemithang)  and in the impact area (of < 10 km0 from the site in Zemithang circle by NCF, all respondents were firmly against the proposed hydel project. Loss of fertile grazing and farming grounds was also one of the frequently cited reasons. Other reasons varied from setting in of cultural decay due to the incoming migrant labour population believed to be around 1000-5000 (in

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reality it is estimated to be up to 11,200 plus as indicated in the EIA) to concerns about increased landslides due to the tunnelling work. The Zemithang landscape is geologically unstable with frequent landslides during the monsoon months and any large-scale project might lead to more landslides thereby affecting the local population, their agriculture and movement. These were the concerns highlighted by local people during the course of a rapid survey conducted by NCF in 2012. Impacts  on  cultural/religious/historical  monuments  The EIA states that apart from village temple, there are ‘no monuments of cultural, religious, historical or archaeological importance’. This is not correct. Zemithang is one of the pillars of ancient Buddhism and the Gorsam Stupa, which is nearly 800 years old, too is located close to the proposed dam site and might be adversely affected by the construction activities such as blasting and tunnelling. There are also some small monasteries in the area and other areas of cultural/ religious significance to the Buddhist Monpa community. The proposed dam site encompasses community land/ common property grounds where events like the Republic day, Independence Day, and local festivals have been celebrated for a long time and this would be hampered if the project is allowed to progress. Nearly 60 kms of roads need to be constructed during the construction of the hydel project, which would destroy forest area, and result in increased soil erosion during the monsoons. The project would need around totally 255 hectares of land of which 89 ha is forest land, apart from the 40 hectares of forest land that is going to be submerged. These are some of the concerns that need to be addressed before embarking on the hydel project.  As per the short NCF field survey in 2012, the local population is clearly against any such project in the Pangchen valley that interferes with their beliefs, tradition, religion and ecology. Comments  on  the  Environmental  Management  Plan We make most of our observations and comments on Chapter 1, which is about the Compensatory Afforestation and Biodiversity Conservation Plan, where we find that the plan reflects a very poor understanding of ecology and the local socio-economic context. A quick reading of the other chapters also leads to similar conclusions about the rest of the EMP. The activities proposed all appear to be ad-hoc and proposed without much thought. Several are unnecessary, while others can be potentially more harmful and have additional impacts on forests. Most others are impractical and unlikely to be implementable or implemented. We are also concerned that while some activities seem desirable and doable on paper, rarely do these get implemented properly during and after such hydro-power projects. There is no timeline or schedules given as to when the EMP activities will be initiated and completed and who will ensure follow-up and monitoring. There is no independent competent agency that will evaluate and monitor whether the EMP is actually put into place in practice.      

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Chapter  1    Compensatory  Afforestation  and  Biodiversity  Conservation  Plan  The total land required for the project is 254.5526 ha spread across 11 villages of which 10.0829 ha is to be acquired from private individuals while the rest is community land. The EMP claims that as compensatory afforestation, double the area affected (i.e. 509 ha) will be afforested. They assert that the afforestation work will be done by the Forest Department and that the total expenditure required for afforestation of 509 ha of area will be Rs. 35.63 million. “In addition to above the project proponent will pay NPV and cost of trees to the Forest Department, which shall be estimated by the Forest Department.” The compensatory afforestation plan appears to be very vague, cursory and not scientific. There is no mention of where this afforestation will be done and no detailed plan and on what native species will be used. Without a scientific approach, the afforestation may increase the negative effects of the project; for instance, if areas that are open and grasslands are planted with 'fruit bearing trees' it will lead to a further loss of natural habitat. It is also not clear whether the afforestation is being undertaken for biodiversity conservation or for 'improvement' of the habitat for providing fuelwood and fodder for the livestock and the communities. The afforestation needs to be very well planned since it will affect a relatively large area of 509 ha. It is not clear whether the area of 509 ha will be located in the same area and the ownership status of this land. It appears that all compensation will be paid only to the Forest Department and only the Forest Department would be involved in this plan. Most of the area is community land, therefore afforestation plans would have to be in concordance with existing land-use patterns of the local people and should be carried out in consultation with local people. In addition, experience from many other places shows that compensatory afforestation is rarely carried out properly and usually does not help restore the value and functionality of the original biodiversity values of the site. Biodiversity  Conservation  The EMP erroneously states that the project area does not have any threatened species as classified by the IUCN. As mentioned earlier, the project site and its surrounding areas harbor a number of important wildlife species, including the black-necked crane and the Arunachal macaque (Macaca munzala), which have completely overlooked by the EIA. Habitat  improvement  program  Afforestation Apart from the compensatory afforestation plan for which 35.63 million rupees is allocated, and additional 1 million rupees is set aside separately for afforestation under ‘Habitat improvement program’. The EMP states that “Area under forest and tree cover will be expanded through systematic planning and implementation of afforestation and rehabilitation programme in degraded and open forests and available non forest lands.” Again, it is not clear what the ownership status of these additional areas are and it only says it will be done in consultation with the Forest Department. Given that much of the land is community-owned here, such afforestation plans need to factor in local institutions

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and can be successful only if implemented with local consent and participation. Avifauna  The plan to provide artificial nest boxes for avifauna is also not scientific, and provides no reference while mentioning that these nest boxes are very 'successful'. The EMP assumes that breeding sites for hole-nesting birds are limited and require to be augmented. The EMP in this section makes completely incomprehensible statements that show absolute lack of any ecological knowledge such as “Therefore, first strategy of improvement of habitat for birds is avoiding nest predation or brood parasitism through maintenance of large contiguous forest tract.” Without any prior understanding of bird communities and their ecology in the area and an assessment of the needs of specific hole-nesting bird species in the area, there can be no purpose to suddenly introducing artificial nest boxes in the area. In addition, only some forest bird species are hole-nesters and scientific studies show that often forest-dwelling bird species may not use artificially introduced nest boxes and most such programs have been failures or seen limited and mixed success. Artificial nest boxes are normally used for augmenting breeding sites for particular endangered bird species in some countries with specific planning that is done after detailed ecological studies and with continuous monitoring. It is not carried out in an ad-hoc manner as suggested by the EMP. Lastly, even if artificial nest boxes were at all necessary, nest boxes have to be designed with specific bird species in mind according to their size and individual habitat requirements. This activity will also possibly lead to further habitat destruction/modification since the nest boxes, several in number (1000) is proposed to be built using native trees in the project site. Conservation  and  cultivation  of  medicinal  plants    It is not clear what the medicinal plants are being grown for; for local use (which is not necessary) or for commercial purposes, the latter being impractical in the area, since there is poor access to the market. This activity also seems like one being undertaken with very poor understanding of the socio-economic conditions and needs of the local population and without any consultation with local communities. An amount of 0.5 million rupees is earmarked for this and land requirement is stated to be 5 ha. Again, it is not clear where this land will be located and whose land will be used for this purpose. Eco-­‐development  works  Under this section too, there are vague plans without any consideration or understanding of local needs and conditions. There is no plan for consultation with communities before suggesting ad-hoc ‘eco-development’ activities. For example, under ‘Publicity and Awareness’ for which 0.5 million rupees is allocated, there are plans to ‘educate’ communities about fire hazards. This is simply ridiculous in the local context of communities in Arunachal Pradesh. It is also not clear who will undertake the activities proposed. Anti-­‐poaching  The EMP allocates a large sum of money for anti-poaching activities and for hiring guards. Firstly, it is not clear if anti-poaching camps are essential since there seems to be no prior assessment of hunting in the area. In fact, the local people who are

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Buddhist Monpas have their own institutions and mechanisms to ban/control hunting as mentioned earlier in our comments on the EIA and this is being actively done for the past several years through the creation and declaration of community-managed CCAs. So, by planning on setting up a separate anti-poaching squad, this would result in an unnecessary external intervention, which can be resented by local people. Secondly, it is not clear who will be appointed as guards for this anti-poaching squad and the EMP even talks about a ‘range officer’ who will be appointed on a salary of Rs. 15,000. This is simply ridiculous. Under whose supervision and monitoring will all these appointed staff function and for what purpose? Thirdly, the EMP talks about purchase of anti-poaching kits and equipment “to capture and translocate wild animals out of human habitations or agricultural lands, various trapping equipments pertaining to anti-poaching activities are needed. In the absence of these the staff faces difficulties and all efforts made on this behalf are futile.” This does not make any sense – the purpose of anti-poaching kits is to prevent poaching and not to capture and translocate wild animals! The plan to 'capture and translocate wild animals out of human habitations and agricultural lands' in any case is completely baseless, unscientific and is absolutely unnecessary and dangerous. The EMP also seems to make some unspecified provisions for firearms for self-defence to be used by these ‘hired’ guards. This has the potential to be misused in an area that is largely governed by local community institutions especially as there is no clear plan for this ‘ad-hoc’ anti-poaching squad. The EMP also talks about various construction activities like building of check posts, huts, shelters, watchtowers and residence quarters of forest guards. All these activities will require construction material and land, which would mean further clearing of land and felling of trees. Under the same ‘anti-poaching plan’, the EMP also talks of purchasing equipment including laptops, GPS units, video, altimeters –firstly, some of these are not needed specifically for anti-poaching and even not in use in existing anti-poaching measures in use in India’s Protected Areas – one wonders how will these be used for anti-poaching by hired guards with no prior training and what their purpose is. Fish  ladders  for  migratory  fish  Unless the fish ladders are precisely designed taking into consideration the migratory species and their precise needs, they may lead to high mortalities. In fact, most literature points to the inefficiency of fish ladders and of how they can be a death trap for migrating fish (Agostinho et al. 2002, 2007a, b, Roberts 2001).  Monitoring  and  cost  estimates  The total cost of biodiversity conservation and management plan is estimated to be 53.15 million. The EMP states that the project proponent and officers of Forest Department will closely and regularly monitor all the activities of BMP in terms of physical, financial progress and quality. Monitoring is to be done by setting up a Biodiversity Conservation Committee under the chairmanship of the Principal Chief Conservator of Forests (PCCF). The committee shall review and oversee the conservation work undertaken. No further details are provided as to the mechanisms and process and under what time

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frames these activities will be monitored. The Forest Department has limited manpower, resources and capability to monitor this EMP throughout the duration of this project. There is no suggestion of any independent agency monitoring this.  Chapter  5  Environmental  Management  in  Labour  camps  The total construction time for the project is about 6 years with an estimated increase in population by 11,200. The EMP states that ‘to ensure that the sewage from the labour camps do not pollute the river water, it has been estimated that about 560 community latrines and a sewage treatment plant shall be constructed for treatment.’ Our concern is that firstly, the direct and indirect environmental impact of such a huge immigrant population in a sparsely populated area will be immense. Secondly, the idea of 560 community latrines and a sewage treatment plan while sounding good on paper is unlikely to be properly implemented given the difficult logistics in the area and past experience with such projects in India. Thirdly, these additional constructions will require further supply of construction material and potentially, even additional land for housing these structures, which means further loss of forests and/or land area owned by communities. Where will this additional land come from? It is not clear whether all these ancillary land requirements are included in the 255 ha, which the EIA talks of for the powerhouse and submergence area. The EMP further states that they estimate about 2.24 tonnes of solid waste/day will be generated and that this would be taken care of by constructing designated landfill sites and that waste would be segregated into biodegradable and non-degradable in each labour colony and that a solid waste collection truck would collect this waste. This is simply impossible to implement in that remote area logistically with a migrant population of workers in labour colonies. Under whose supervision and monitoring, will all these activities be ensured. Secondly, when we fail in our cities and smaller towns to segregate and dispose of waste properly even with many implementing agencies and municipal authorities, we find it difficult to believe that such a plan will actually be implemented or indeed be implementable on the ground only by the project proponents with no external monitoring or supervision. The EMP talks about establishing LPG godowns to provide LPG cylinders for community kitchens and establishing kerosene oil depots to ensure supply of kerosene oil at subsidized rates. This is very commendable, but not feasible and practically impossible to carry out in such a remote site in Arunachal Pradesh. LPG and kerosene is often in short supply in most areas in Arunachal and local people struggle to get these and the distribution systems are not adequate in entire Arunachal, so it is unlikely that this can be put into practice for migrant workers at a hydro-power project site. There again is no mention of a follow-up or monitoring by independent agencies to see if this plan is being implemented. In another place, the EMP talks about central heating to be provided to workers in winter – to minimize cutting of trees. They suggest that a ‘contractor’ would do this. While all these measures sound commendable on paper, it is again not clear who will ensure that this is provided and how a contractor will undertake this without any mechanism for proper monitoring.  

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References  cited  Aiyadurai, A., Singh, N. J. & Milner-Gulland, E. J. 2010. Wildlife hunting by indigenous tribes: a case study from Arunachal Pradesh, north-east India. Oryx 44(4): 564-572. Agostinho A. A., Gomes L. C., Fernandez D. R. and Suzuki H. I. 2002. Efficiency of fish ladders for Neotropical ichthyofauna. River Research and Applications 18: 299-306. Agostinho A. A., Marques E. E., Agostinho C. S., de Almeida D. A., de Oliveira R. J. and de Melo J. R. B. 2007a. Fish ladder of Lajeado dam: migrations on one-way routes? Neotropical Ichthyology 5: 121-130. Agostinho C. S., Agostinho A. A., Pelicice F., de Almeida D. A. and Marques E. E. 2007b. Selectivity of fish ladders: a bottleneck in Neotropical fish movement. Neotropical Ichthyology 5: 205-213. Choudhury, S.D. 1996. Arunachal Pradesh District Gazetteers: East Kameng, West Kameng, and Tawang Districts. Gazetteers Department, Government of Arunachal Pradesh, Shillong, India.

Choudhury, B. I., Khan, M. L., Arunachalam, A. & Das, A.K. 2007. Population status of Gymnocladus assamicus, a critically endangered tree species in Arunachal Pradesh. Current Science93(11): 1489-1491.

Chowdhury, H.J. 1998. Orchids of Arunachal Pradesh. Bishen Singh Mahendra Pal Singh, Dehra Dun, India.

Dutta, P.K. 2010. Status of Black-necked crane in Arunachal Pradesh. Unpublished report. WWF-India, New Delhi. BirdLife International 2001. Threatened Birds of Asia: The BirdLife International Red Data Book. BirdLife International, Cambridge, U.K

Islam, Z. and Rahmani, A. 2004. Important Bird Areas in India- Priority sites for Conservation. Arunachal Pradesh, pp. 229-230. Editors: M. Zafar-ul Islam and Asad R. Rahmani, Bombay Natural History Society. 1133 pp.

ICAR 2010. Threatened freshwater fishes of India. National Bureau of Fish Genetic Resources. IUCN (2004) IUCN Red List of Threatened Species. IUCN, Gland, Switzerland (http://www.redlist.org). Khan, M.L., Arunachalam, A. and Barbhuiya, A.R. 2007. Web-GIS Digital Atlas of the Sacred Groves of the North-East India: Pilot study with Sacred Groves of Arunachal Pradesh. Technical Report. Department of Scientific & Industrial Research, Ministry of Science & Technology, Govt. of India (Sanction No. DSIR/ Web/TIF026/2004-2005 Dated 31.12.2004).

Khan, M.L., Khumbongmayum, A.D. and Tripathi, R.S. 2008. The sacred groves and their significance in conserving biodiversity: an overview. International Journal of Ecology and

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Environmental Sciences 34:277-291. Kumar, R.S., Mishra, C. and Sinha, A. 2007. Foraging ecology and time-activity budget of the Arunachal macaque Macaca munzala – a preliminary study. Current Science 93 (4): 532-539. Mahanta, D. and Tiwari, S.C. 2005. Natural dye-yielding plants and indigenous knowledge on dye preparation in Arunachal Pradesh, northeast India. Current Science 88: 1474-1480. Mendiratta, U., Kumar, A., Mishra, C. and Sinha, A. 2009. Winter ecology of the Arunachal macaque Macaca munzala in Pangchen Valley, western Arunachal Pradesh, northeastern India. American J. Primatol. 71: 939-947. Mishra C., Datta A. and Madhusudan M. D. 2004. The High Altitude Wildlife of Western Arunachal Pradesh: A Survey Report. CERC Technical Report No. 8. Nature Conservation Foundation, International Snow Leopard Trust & Wildlife Conservation Society India Program, Mysore, India. Mishra C., Madhusudan M. D. and Datta A. 2006. Mammals of the high altitudes of western Arunachal Pradesh, eastern Himalaya: an assessment of threats and conservation needs. Oryx 40: 1-7.  Mishra, C., Datta, A. & Madhusudan, M.D. 2004. The High Altitude Wildlife of Western Arunachal Pradesh: A Survey Report. CERC Technical Report No. 8. Nature Conservation Foundation, International Snow Leopard Trust & Wildlife Conservation Society India Program, Mysore, India.

Namsa, N., Mandal, M., Tangjang, S. and Mandal, S.C. 2011. Ethnobotany of the Monpa ethnic group in Arunachal Pradesh, India. Journal of Ethnobiology and Ethnomedicine. 7:31, doi:10.1186/1746-4269-7-31. Paul, A., Khan, M.L., Arunachalam, A., and Arunacahalam, K. 2005. Biodiversity and conservation of rhododendrons in Arunachal Pradesh in the Indo-Burma biodiversity hotspot. Current Science 89: 623-634. Rahmani, A.R. 2012. Threatened Birds of India, their conservation requirements. Oxford University Press, 870 pp. Roberts, T. R. 2001. On the river of no returns: Thailand’s Pak Mun dam and its fish ladder. Natural History Bulletin of the Siam Society 49: 189-230. Sinha A., Datta A., Madhusudan M. D. and Mishra C. 2005. Macaca munzala: a new species from western Arunachal Pradesh, northeastern India. International Journal of Primatology 26: 977-989. Singh, P. 1999. Bird survey in selected localities of Arunachal Pradesh, India. Report, Wildlife Institute of India.

Stattersfield, A. J., Crosby, M. J., Long, A. J. and Wege, D. C. (1998) Endemic Bird Areas of the World: Priorities for Biodiversity Conservation. BirdLife Conservation Series No. 7. BirdLife International, Cambridge, U.K.

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Figure 1. Map showing the locations of the barrage site and powerhouse for the proposed Nyamjang Chhu HEC project. The wintering site of the Black-necked crane Grus nigricollis is on the stretch between Brokenthang and Zemithang and overlaps with the location of the barrage site. The project-affected area also includes two designated Community-Conserved Areas and is an Important Bird Area and Endemic Bird Area.