March 21, 2018
Smt Manisha Nanda
Addl. Chief Secy. cum Principal Secy. to the Chief Minister
(Environment Science & Technology, Information & Public Relation, Tourism & Civil Aviation)
Government of Himachal Pradesh
We are writing to you on the Day of Action for Rivers across the world on behalf of the concerned citizens of the State. We are drawing your attention to the massive crisis being faced by the precious Himalayan Rivers of our state in the wake of unprecedented pollution. More than ever before the rivers are under threat due to the five major developmental activities
- Hydropower Projects
- Urbanisation and Tourism
- Sand Mining
- Climatic Changes
The above activities are being carried out in the absence of proper planning, impact assessment and carrying capacity studies and monitoring by the environment regulatory agencies of the State.
The key threats that the Himalayan rivers face are the burgeoning pollution with sewage, industrial effluents and the absence of water in the rivers. These are the urgent problems that have had several ecological, social, cultural and economic impacts that are becoming irreversible. In the attached report a detailed analysis has been carried out of the threats faced by the five major rivers of the state. Each of the rivers and the threats they face have been examined. This report is not comprehensive but we hope that it will urge the government to take steps in the right direction.
WE believe that until and unless a larger policy change occurs there is little hope to save the Himalayan rivers. For immediate action here are 10 points, our demands, that we want the government should start working on seriously:
- Declare Wild, Free flowing Rivers: Of the major rivers it is now the Chenab and Satluj in Upper Kinnaur as well as Spiti that remain free flowing. Given that these are high altitude regions and are ecologically fragile and more at risk due to climatic variations, these should also be declared as ‘Eco sensitive zones’ and no-go for major construction activity. On Yamuna, the Tons and Giri both are important life lines of the local community and the only non polluted sections of the river basin upstream these need to be conserved as well given the impending threat of two large dams (Renuka and Kishau) in this region. In fact a review of the Upper Yamuna Basin Agreement is warranted given that 5 states are involved and a Cauvery like situation would mean increasing tensions amongst the riparian states and communities
- Protect small streams and tributaries: Some of the smaller streams and tributaries of the major river basins need to be marked for their fragility not just from a single view point but given that they support ecological diversity and livelihoods. The Tirthan is a brilliant example of this. Thriving fish farms on the river, small home based eco tourism initiatives and cultural preservation all becomes possible in such an environment. Similarly some of the other streams on Ravi – like the Hul streams in the Saal valley which also feed into the drinking water needs of the valley as well as Chamba town, needs to be declared as a no-go zone not just for hydro projects but also for large scale sand mining, polluting industries and unplanned construction of both roads and buildings. List of such streams/tributaries on each of the rivers needs to be drawn up. Other examples are Kerang, Ropa, Spiti (Satluj).
- CIA mandatory for all Hydropower Projects before new projects: Cumulative Impact Assessment studies for Hydropower Projects on the river basins need to be undertaken in a, independent, thorough and multi-disciplinary fashion. While the studies for Satluj, Chenab and Beas are already complete – there has been little local consultation in carrying out these studies. Further, these studies have become a mere formality as the process of giving environment and forest clearances for hydroprojects has been de-linked from the CEIA process. Environmental groups have been demanding that until the complete studies are carried out there must be a moratorium on further hydro development in Himachal
- Strict Actions on illegal Sand Mining: As far as Sand mining is concerned if the orders of the NGT and High Court are strictly implemented, and the mining is regulated or even stopped in the streams and rivers, the revival would take place in a short period of time. The regional regulatory bodies need to start acting immediately on this, especially for the small streams
- Controlled and regulated construction: Tourism and Urbanisation need serious policy measures that strengthen the role of regulatory agencies as well as work towards models that are not large and commercial in nature but small scale and community owned and managed. Urban bodies as well as Panchayats need to involve community representatives in development plans where health of the river is placed as the central concern. Four laning projects and blind road widening are not just damaging the forests but also increasing erosion and the siltation on our rivers. These need to be reviewed thoroughly.
- Book violators dumping industrial effluents in rivers: Special attention needs to be paid to monitoring and regulation of industrial pollution in areas like Baddi Barotiwala Nalagarh and Paonta Sahib. Common Effluent Treatment Plants have failed miserably and an effort needs to be made to monitor pollution at the source as well as treat the effluents there. Industries violating norms should face closure as well as punitive action rather than just false threats and show cause notices. The Himachal Pollution Control Board needs to be well staffed and held accountable.
- Involve local community in river protection, regulation to support PCB and other bodies: Beas, Ravi, Satluj and Lower Stretches of the Yamuna (tributaries) – or already critically polluted – that are in the red, can be at least monitored strictly by the Pollution Control board again in consultation with communities. At present the Pollution Control Board and the Irrigation and Public Health department’s roles have either been made redundant or they have been working to ensure least hindrance to ‘developers’. In this regard the Amendments in the Hydropower Policy of 2006, which were made in 2014 and 16, need to be withdrawn as they dilute the process of NOCs from these departments prior to approval of hydro projects. The role of these regulatory agencies needs to be strengthened with community involvement in ensuring compliance to existing legislations that protect rivers and riparian rights.
- Monitor disharge and environmental flows: In the context of e-flows when main rivers have been plugged with projects, there is a need to do following: Where there are cascade of projects the projects they should discharge sufficient amount of water and all the small streams joining the river should be kept free of projects so that fish can migrate in these small for streams for spawning. As mentioned earlier, the rivers which don’t have projects should be kept free of the project so that all the biodiversity present can be protected. In recent years, the Expert Appraisal Committee on River Valley projects of MoEFCC has proposed a minimum eflow of 25 to 30% in some cases. To ensure that this is implemented for all hydropower projects that are functioning.
- Rivers and Forests are to be protected together: Rivers will be under threat if the entire ecosystem is not protected. This also means working harder to protect the biodiversity and quality of our forests. Increasing deforestation by diversion of forests for large development projects is a huge threat. Further, forest forest due to the proliferation of Chir Pine have deteriorated the quality of soil and led to more erosion. These forests need to be converted back to mixed forests. There needs to be more community involvement in management of forests. The Forest Rights Act 2006, if implemented in full spirit will strengthen community control and ownership over forests around river basins (which mostly fall under the category of ‘Forest lands’). This would also mean having the responsibility of conserving and protecting these resources. Unfortunately, the Himachal government has the poorest track record in FRA implementation with the State government and forest bureaucracy impeding rather than facilitating the filing of claims process. The focus has been on ‘individual rights’ rather than CFR (Community Forest Rights).
- Prepare an action plan for all the rivers of the State: The State environment department should carry out regional consultations and prepare action plans for each of the river basins with the involvement of local community representatives, citizens groups, environmentalists and experts along with chosen government departments.
It is only through a policy shift as well as a new initiative in environment governance can we protect the natural heritage of the State, on which our survival entirely depends.
Looking forward to your response
Ranjit Singh Negi, Him Lok Jagriti Manch, Kinnaur
Abha Bhaiya, Jagori Grameen, Kangra
Ratan Chand, Saal Ghati Bachao Sangharsh Morcha, Chamba
Subhash Mendhapurkar, SUTRA, Solan
Kulbhushan Upmanyu, Himalaya Bachao Samiti and Himalaya Niti Abhiyan, Chamba
Dr. Mohender Salariya & Manuj Sharma, Chamba Rediscovered, Chamba
Ishan Marvel, Samgh Foundation, Kullu
Prem Katoch & Vikram Katoch, Save Lahaul Spiti, Keylong
Takpa Tenzin & Sonam Targay, Spiti Civil Society, Kaza
Rigzin Hyerappa, Jispa Bandh Sangharsh Samiti, Darcha
Subodh Bhod, Lara-Sumata Sangharsh Samiti, Tabo
Shanta Kumar, Hangrang Ghati Sangharsh Samiti, Nako
Rishi Bhalaik, Satluj Bachao Jiven Bachao Abhiyan Samiti, Rampur
Sumit Mahar, Himdhara Collective
Prakash Bhandari, Himachal Van Adhikar Manch