Small hydropower projects (SHPs) or mini hydels are propagated as an environmentally friendly and socially beneficial option to meet our rising energy demands. Hence, according to the EIA notification, SHPs (capacity not more than 25MW) do not require an environmental clearance, and are legally exempt from environmental impact assessments and public hearing in India. In fact, the government usually grants substantial subsidies and financial incentives to such ‘green initiatives’. However, this notion of SHPs having minimal or no adverse impacts is incorrect and widely disputed by scientists.
Urge the Ministry of New and Renewable Energy (MNRE) to include environmental and social safeguards in the revised policy by adding your signature to our letter.
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- Studies indicate that SHPs severely alter water and nutrient flow, impede animal movement, cause declines in fish populations, and cause deforestation and habitat fragmentation.
- Proliferation of SHPs and their associated structures within elephant habitats can obstruct the free movement of elephants, leading to increased Human-Elephant conflict.
- The World Commission on Dams defines large dams as those that have a height of 15m or more. Surprisingly, numerous SHPs exceed this 15m limit, but are still considered small due to the fact that they produce less than 25MW electricity.
- The largest densities of proposed SHPs fall within the ecologically and culturally diverse landscapes of the Western Ghats and the Himalayas.
- Since Public Hearings are not required, SHPs can strongly infringe upon the rights of local communities. They have been known to directly disrupt culturally important sites, traditional irrigation cycles, watermills and drinking-water sources.
- Until 2012 India’s MNRE had commissioned 1266 SHPs and identified 6474 sites for SHP development, all without any impact assessments or public consultations. Due to these reasons numerous scientists and even government-appointed committees have recommended that SHPs should be better regulated in India. The MNRE is now drafting a revised policy for SHPs.
Add your signature via the form above, or write your own letter using the information from our template below, to urge the MNRE to include environmental and social safeguards in the revised policy.
See a short film on the rising concerns of small hydropower projects (SHPs) in India:
Dr Pradeep Chandra Pant
Director (Small Hydro Power, REINVEST, DBT Cell & Vigilance) & Executive Director (AREAS)
Ministry of New and Renewable Energy, Government of India
June 24, 2017
Sub: Inputs for the revised SHP policy
A growing volume of scientific studies and governmental assessments indicate that small hydropower projects (SHPs) have numerous adverse environmental and social consequences. For example, SHPs are found to severely alter the structural integrity of rivers, affect water and nutrient flow, reduce habitat availability and quality, impede animal movement, alter riverine biotic communities, and cause deforestation and habitat fragmentation. The proliferation of SHPs and their associated structures within elephant habitats also obstruct the free movement of elephants, and this leads to increased Human-Elephant conflict – the costs of which need to be borne by the Forest Department, local communities and the elephants. Since Public Hearings are not required, SHPs also strongly infringe upon the rights of local communities. They have been known to directly disrupt culturally important sites, traditional irrigation cycles, watermills and drinking-water sources. Despite such mounting scientific evidence, the MNRE has continued to propagate SHPs as green initiatives that cause no adverse environmental or social impact.
Due to the false presumption that SHPs have minimal or no adverse impact, they have been exempt from requiring Environmental Clearances thus far. Massive subsidies and financial incentives are also offered to make these projects viable to the private sector. Hence, over 1266 SHPs have been commissioned and an additional 6474 sites have been identified for further SHP development, most of which fall within the ecologically sensitive Western Ghats and Himalayan landscapes. In light of the overwhelming scientific evidence, we suggest that the MNRE make the following changes to the revised policy:
- It should be mandatory for all SHPs above 2 MW capacity to obtain prior Environmental Clearances. Additionally, all SHPs above 100 KW in the forested areas – within and outside Protected Areas (PAs) — and headwaters of the Western Ghats and Himalayas should be required to obtain prior Environmental Clearances in addition to forest and wildlife clearances as necessary.
- In order to incentivise least damaging projects, financial incentives given to SHPs should be re-evaluated based on the environmental costs of the project. For example, financial incentives should be higher for the augmentation of SHPs in existing projects (such as large dams, canals, sewage treatment plants etc. where there are no hydro components, but there is potential for such components) and the revival of dysfunctional projects. Conversely, financial incentives should be withdrawn for SHPs in forested regions, based on their overwhelming ecological impact as established by science.
- While most countries have rigorous regulations to prevent river dewatering, SHPs in India are allowed to regularly dewater vast stretches of our rivers, for as long as 7 to 8 months a year. This has disastrous consequences. Environmental flow requirements of at least 50% of the mean lean season flow should be mandatorily enforced and monitored. This is the limit recommended by MoWR-MoEF report and Allahabad High Court.
- A system of monitoring needs to be implemented. Due to the lack of effective monitoring, SHPs are making tall claims in their CDM-Project Design Documents without adhering to them. They also flout existing regulations. For example, benefits of local employment, stakeholder consultation and socio-economic development are rarely realised. In Himachal Pradesh, where a 15% mandatory minimum flow is stipulated, it is almost never maintained.
- Since most SHPs are being commissioned in dense clusters, States should be asked to conduct basin-wide cumulative impact assessments of all existing and proposed SHPs and include all the major interventions in the basins. For example, the 108-km long Netravathi River in Karnataka has 10 SHPs commissioned on it along with numerous irrigation projects. An additional 44 SHPs, a major water diversion project, a dredged waterway and a river interlink have all been proposed on the same river as well. Cumulative impact assessments, considering parameters such as percentage free flow and inter-SHP distances, should be used to better plan projects in each basin.
- MNRE should ensure that the local communities have the priority in developing and owning SHPs in their area.
We trust that you will take into account the scientific information on the subject, and acknowledge the adverse social and environmental impacts of SHPs. In light of increasing evidence, the basic premise of SHPs having nil or insignificant environmental impacts and having multiple social benefits does not hold true. Given that little consideration is given to the cumulative impact of the uninhibited growth of dams in critical biodiversity areas, which can result in disastrous consequences to both people and wildlife, the situation demands immediate action.
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