Why the Western Ghats?

The geography of the Western Ghats is particularly advantageous for PSP projects, because the elevation is conducive to generating power by passing water from one reservoir to another, with turbines located at the lower one.

‘The Western Ghats is one such location in peninsula India, where the elevation difference makes it viable for constructing PSPs,’ said  Himanshu Thakkar, Coordinator for South Asia Network on Dams, Rivers and People (SANDRP). These projects are coming up in relatively high rainfall districts— making water availability another reason why the Ghats were chosen, he adds.

Project-related work has begun at Satara district, as opposition from the public resulted in the temporary pause of the project at Kolhapur and only preliminary assessments are ongoing at Pune. At Satara, the project is proposed near the two villages of Murud and Nivade, connecting the existing Tarali lake at Murud as a lower reservoir and entailing the construction of an upper reservoir in Nivade.

‘When there is a surplus of energy generated from solar, wind and other sources, water will be pumped from the lower to upper reservoir, for storage,’ said Shishir Rao, a PhD student from the University of Georgia (USA). ‘Whenever there is a demand from the power grid, the water is then released from the upper reservoir to generate power.’

As per the draft, this will meet Maharashtra’s peak electricity demand for about 6.47 hours, with an estimated annual energy generation of 3365.48 million units. According to the MoU signed between the Maharashtra government and AGEL, the power will be sold to the state-owned distribution companies (DISCOMs) once power-purchase agreements (PPAs) are signed.

This process necessitates a daily fluctuation in the water level of the reservoir. ‘Such a fluctuation is not found in nature and can potentially have significant impacts on the fish and other aquatic flora and fauna,’ activists have claimed in a letter addressed to the Maharashtra Pollution Control Board (MPCB) that Adani Watch accessed. They further argued that even if this impact is small, it needs to be investigated and the impact described in the EIA.

‘A continuously changing reservoir level could impact fishing incomes,’ stated Shripad Dharmadhikary, founder of Manthan Adhyayan Kendra.

The letter to the MPCB criticising the EIA was signed by Dharmadhikary, Bharat Patankar, President of Shramik Mukti Dal (a social movement), and KJ Joy, a Senior Fellow with Society for Promoting Participative Ecosystem Management (SOPPECOM). It asked officials from MPCB, local and state environmental departments to cancel a scheduled public hearing. 

Nevertheless, the MPCB arranged for the public hearing on 12 March 2024. After this mandated hearing, the MPCB can issue a No-Objection certificate for the project.   

Despite local demands for the pollution control board to conduct another hearing after revising the EIA, the MPCB officials are proceeding with the submission of the final report to the central government.  

EAC’s green light raises concerns

While on the surface it looks like the procedure has been followed, those on the ground highlight several procedural violations.

Under the Environment Impact Assessment (EIA) Notification 2006, Expert Appraisal Committees (EAC) are constituted to review the potential impact of the projects and the Ministry of Environment, Forests and Climate Change (‘the ministry’) can then grant environmental approvals based on the committee's recommendations.

However, in a clear conflict of interest, an advisor to AGEL was one of the seven non-institutional members of EAC. As per this Indian Express report, the advisor attended the meeting on 17 October 2023, the day that AGEL’s Tarali PSP was up for consideration.

‘The problem is with the regulator (EAC and the ministry). The central ministry defended the position of the advisor which shows how poorly the EAC functions,’ SANDRP’s Thakkar stated, adding how the committee lacks members with an independent track record who are not retired government officials or allied with the government.

For the second project, the minutes of the EAC meeting held in June 2023 for river-valley and hydroelectric projects say that this PSP in the Satara Marathwada village area is a Schedule- 1 (Category-A) project that requires approval from the central government. This project is the Koyna-Nivakane PSP with a capacity of 2450 MW.

Shortly after AGEL put forward a proposal for Terms of Reference (ToR) for the project, the EAC in the aforementioned minutes granted those ToR for conducting the EIA study. 

Despite a 2013 notification from the ministry prohibiting mining, quarrying, sand mining, thermal power plants, township and allied developmental projects and polluting industries in the Western Ghats, apparently hydro-electric projects are permitted.

The experts claim this is not surprising. Thakkar alleged that the EAC has become a mere ‘rubber stamping body’.

The proponents acknowledge that the proposed dams for this PSP will be located across two minor rivulets draining into the Kera River in the Satara area. The EAC’s acknowledgement in the minutes that ‘survival of small freshwater streams and rivulets is significant especially in the Western Ghats’ did not prevent it from greenlighting ToR for the project.

The Western Ghats are a chain of mountains with elevations ranging from 300-2700 metres. Nearly 30 west-flowing rivers originate here and join the Arabian Sea. In the seven years that Rao has spent studying hydropower projects and rivers in India, he has observed that several smaller hydropower dams have been established on these rivers.

He attributes this to the assumption that they do not have as much on-ground impact as large dams.

‘To say that something has no impact, it is always compared to something that has a higher impact, like building a large dam on a large river as opposed to building a smaller dam on a smaller river,’ he explained to AdaniWatch. ‘But when you build multiple small dams on a single river, those effects might cumulatively scale up to be comparatively similar to building bigger dams.’

Discrepancies in the EIA

The signatories of the letter to the MPCB have alleged that the ‘Environment Impact Assessment is shoddy and inaccurate and does not address important issues of the region’.

In a mockery of the standard procedure, the EIA summary stated that the project requires drawing water from Pendekallu reservoir, which is located over 600 km from the Tarali project.

‘This is clearly copied and pasted from another assessment,’ the letter said.

As per Page 6 of the summary, the Tarali PSP is said to require 150.7 hectares of non-forest land. The same paragraph also mentions that ‘the land submerged under the upper reservoir area entirely falls within the forest area’.

This is a direct contradiction in the EIA, drafted by RS Envirolink Pvt Ltd, a company that has prepared EIAs for many projects of Adani Group.

‘There is no forest land involved in this project,’ declared a representative from RS Envirolink who did not wish to be named. When asked about the contradiction, he admitted it to be a mistake in the EIA that would be corrected in the revised report.

The signatories to the letter to the MPCB have noted that the above statement regarding forests goes against the Terms of Reference (ToR) document, a precursor to the EIA, which mentions the project needing 63.10 hectares of forest land.

‘The information about flora and fauna is wrong,’ Bharat fumed, while pointing out multiple errors in the EIA summary. ‘It (the EIA) is making a mockery of the process.’

While two reservoirs are proposed to be constructed, the document makes mention of a preset study Catchment Area Treatment Plan being prepared only for the lower dam.

CAT plans address ‘issues such as prevention of gully erosion, enhancing forest cover for increasing soil-holding capacity, and arresting total sentiment flow in the reservoir and flowing waters’. The lack of such a study might thwart any remedial measures to reduce soil erosion.

‘It is clear that the Summary has not been checked and vetted. It should not be the responsibility of the public to check which part of EIA is correct and which is inaccurate,’ the signatories said.

The Summary’s lack of information on the examination of alternative sites is in violation of the ToR.

Additionally, the ministry’s attempts to introduce a star-rating system for states depending on the ‘promptness to grant environmental clearances to industrial or infrastructural projects’ fails to inspire confidence in the environmental-impact assessment process.

Signatories to the letter to the MPCB have asked for a fresh, comprehensive, scientific and participatory EIA to be commissioned. In response to this, the RS Envirolink representative admitted that there are ‘mistakes’ and said that this is ‘not the final document’.

‘The older version was corrected. We are waiting on the minutes of the Pollution Control Board to come out, based on which the final report will be prepared and submitted for the central government’s appraisal,’ he said, when contacted on 8 April 2024.

Biodiversity and ecology affected

The Western Ghats rank amongst the world’s eight hottest biodiversity hotspots out of 34 identified hotspots, which also makes the range an important source of livelihood for local communities whose residents harvest nearly 150 uncultivated food plants and 500 medicinal ones.

Recent research conducted by the Indian Institute of Science (IISc) has revealed alarming findings about the Western Ghats. According to the study, the Ghats have experienced a 5% loss in evergreen forest cover and a corresponding 4.5% increase in built-up areas in the past century.

The Maharashtra Forest Department’s working plan for Satara forest division from 2010 to 2020, on page 19, flags ‘loss of contiguity of forest areas’ and an ‘extensive road network’ as among the major reasons for the depletion of populations of wild animals.

‘The forests of the Western Ghats have become more and more fragmented with these projects coming in,’ said Rao, who believes that the impacts of such projects are being viewed in isolation by decision-makers.

‘These impacts interact with each other and they are not looking at the cumulative impact,’ he argued.

Given that the projects fall within the Satara Forest division, it's important to note that the majority of the project area is covered by forests. The EIA draft mentions that 250 plant species have been identified, which is inclusive of 112 species of trees, 44 shrub species, 40 species of herbs, 30 species of climbers and 24 grass species. Further, the draft also asserts that no endemic or Rare, Endangered or Threatened (RET) species were recorded in the study area.

As per the report of the Western Ghats Ecology Expert panel submitted to the ministry in August 2011, a few areas falling in Satara district (where the Tarali project is proposed) are categorised as Eco Sensitive Zones – areas requiring protection by restricting developmental and other anthropogenic activities.

Activists are concerned that the construction of the PSPs will affect the biodiversity of the region, especially causing fragmentation of wildlife corridors that enable wild animals to move across ecosystems, forage for food and make contact with different populations for mating.

‘The majority of the species are not mentioned (in the draft EIA); there is no mention of panthers, bison or even that it is a wildlife corridor,’ Bharat pointed out.

In India, forest corridors are not defined or legally sanctioned for protection.

Experts warn that these wildlife corridors will be dissected by a network of temporary and permanent roads built as part of the project, which they believe will increase the incidence of roadkill and lead to erosion of wildlife habitat.

This is stated in the findings of a 2017 paper co-authored by Rao which shows a strong relationship between construction of small hydropower projects and increasing human-elephant conflict in the Ghats.

‘Our research has shown that there is a correlation between the increase in the number of small hydropower projects being established and the number of compensation claims by villagers for elephants raiding their crops,’ Rao highlighted. A likely reason for this is that with each project, the forests are further fragmented, posing a barrier to the movement of long-ranging species such as elephants.

The draft mentions that the nearest protected areas are the Sahyadri Tiger Reserve and Koyna wildlife sanctuaries, which are located 1.5 km and 3.2 km respectively from the project components. ‘The forest patches surrounding the protected areas of the Koyna sanctuary are essential wildlife corridors for the movement of large animals,’ the letter to the MPCB states.  

While the draft claims that all the ‘components are outside the notified eco-sensitive zones’, Rao says that buffer zones bordering the reserve warrant protection.

To make the Tarali PSP a reality, an upper reservoir will be constructed to link it with the existing Tarali (lower) reservoir. For this, a 61.5 m high dam for creation of Tarali PSP Upper Reservoir with 11.36 MCM (0.40TMC) gross storage capacity will be constructed.

The excavated material resulting from construction, termed as ‘muck’, requires disposal in designated areas, as stated earlier in muck management plans.

The EIA says the construction would involve about 3,669,903 cubic metres of soil and rock. The total quantity of muck to be disposed is worked out as 819,680 cubic metres. Two dumping sites have been identified covering an area of 35 ha area with a total capacity of 1,777,530 cubic metres of muck.

‘Muck generation, transportation and disposal can significantly impact the environment, if not managed properly,’ said Thakkar. ‘Typically, when millions of cubic meters of muck are created, they dump it into local rivers,’ adding that such practices will further exacerbate the environmental vulnerability of the region.

Exacerbated regional vulnerability

The Ghats, in addition to being a biodiversity reserve of endemic species, are also responsible for southwest rainfall — the principal monsoon season— over India’s western coastal belt. Nearly 90% of the region’s annual rainfall occurs in this June-September season.

But the rainfall patterns in the Ghats have experienced a deviation from the norm, Rao said.

‘According to rainfall data over the past 15-20 years, the monsoon would begin in June and go on for three months, but now we are experiencing the same amount of rainfall, but within a period of 30 to 40 days,’ he said. Because of this, he said, the soil will experience difficulty in absorbing the deluge of rainwater.

‘The rainwater might just flow off the surface instead of reaching the groundwater aquifers,’ Rao stated.

For the PSPs, the forests will be cleared to make way for a reservoir, and as this is equivalent to a big well, the groundwater remains unaffected. But forests will also be cleared for peripheral structures of the project such as transmission lines, grid construction, access roads etc. With increased construction in the peripheral areas, the water run-off in those areas will be pronounced. This, Rao believes, will translate into increased soil erosion.

In their letter, the activists have accused the EIA of having failed to examine the project’s impact on irrigation. ‘We consider this to be a very serious omission. The EIA states that it will use 10.42 million cubic metres of water from the lower reservoir and that this would not be consumptive, implying that there will be no impact of this.’

That it will ‘not be consumptive’ means that the water will not be consumed or removed from the reservoir, Shripad clarified, saying how it will circulate between the two reservoirs.

‘But the EIA says "this implies there will be no impact”, which is far-fetched,’ he said.

‘In addition, the projects will require significant interventions in terms of deforestation, tunneling, blasting and construction of huge transmission lines,’ said Thakkar.

The summary also notes that the groundwater in the project area is fit for drinking purposes. ‘It is a miscalculation when they said the project will not affect the use of water in Tarali. They are going to pump the water, fill the reservoir that they are going to use to generate power, which reduces the minimum water that is available in the Tarali reservoir,’ explained Thakkar.

Further, existing research (here and here) has shown that changes in water ‘drawdown’ levels could emit high levels of methane —a potent greenhouse gas— into the atmosphere.

As per the weekly bulletin issued by the Central Water Commission responsible for monitoring the status of 150 reservoirs in the country, their storage capacity is currently only 38% of total capacity. This figure is less than the previous decade’s average. Thakkar warns that the disposal of muck into the rivers can also reduce the storage capacity of reservoirs downstream.

Further, in 1967, the region’s largest earthquake (magnitude 6.3) occurred in the Koyna Warna Seismic Zone (KWSZ). ‘The mountain areas, including the Western Ghats, are vulnerable to disasters like landslides, erosion, floods, etc. One of the projects is located in KWSZ, which is a seismic zone IV,’ said Thakkar.

Zone V is seismically the most active region with Zone II being the least.  Researchers have attributed the seismicity in the region to the ‘impoundment of the Koyna and Warna reservoirs’. The first micro earthquakes in Koyna were recorded soon after the initial impounding of the reservoir in 1961, which led to a burst of seismicity around the reservoir which persists to this date.

‘Annual cyclic variations in the Koyna reservoir levels from 1968 to 2013 showed persistent earthquake peaks during the loading cycle,’ the study mentioned, casting a worrying shadow over the upcoming projects which will be located in this sensitive region. 

The authors sought responses from Adani Green Energy Ltd and the Maharashtra Pollution Control Board but no comments had been received by the time of publication.