Objective Setting for Eflows

1. Objective Setting for Eflows “The flow regime that should be left in a river is a social choice and that the society should decide about the condition it wants a specific river to be in”, IUCN Flows, WWF Primer on Eflows When did we make these choices? Right: Dry Baspa River, downstream of the Baspa Dam

2. Society = Governments and private developers with agendas? • None of these reflect the societal choice about the river, lesser still the choice of the local communities • Involvement of local communities in objective setting • Basin studies, Cumulative Impact Assessment studies , EIAs do not involve communities, do not represent societal choice

4. Ecological Management Class (EMC): A number of methodologies depend on EMC to provide baseline for eflows allocation

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6. The Environmental Management Category (EMC) of the Alaknanda and Bhagirathi Basins was assessed as ‘C’ Class (as per Smakhtin et al., 2007). • Authors suggested that 28.9% of Mean Annual Runoff (MAR) as Environmental Water Required (EWR) for Ganga River to retain the similar status of the EMC of stretch if it is assessed as ‘C’ Class. • In the absence of larger animals such as dolphin, crocodiles, etc and with 76 species of fishes (in comparison to 143 species reported in the entire Ganges), it has been estimated that 14.5% to 21.8% of MAR may be the Minimum EWR for the aquatic biodiversity of Alaknanda and Bhagirathi basins as a conservative estimate during the lean season. WII Report:

7. Calculation of MEF should recognize that these releases are ensured specifically for environmental purposes especially to meet the requirements of different life history events of the aquatic biota. They should not include flows necessary for downstream commercial activities or for water supply purposes. • “Environmental Flows describes the quantity, quality and timing of water flows required to sustain freshwater and estuarine ecosystems and the human livelihoods and well-being that depend on these ecosystems’ (Brisbane Declaration 2007). • WII Eflows recommendations do not have this objective, AHEC IITR does not have this objective, so then how will it be addressed?

8. Consultants working on EIAs and cumulative Impact Assessment studies severely downplay the baseline to justify low eflows • Lohit Basin Study: EMC C to a free flowing, undammed river. All categories assume low river health. Same with Bichom Basin Study • CSOs and communities need to ensure that EIAs, CIAs, Basin Studies set an acceptable objective for eflows. • Reasoning behind the objective? • Does it respond to needs of livelihoods, ecology, sociology, transport, fish, cultural, spiritual, aesthetic needs?

9. How much is eflows? Methodologies for assessing eflows • River performs different functions for different stakeholders and varying flows respond to each of these needs, and that of the ecosystem. • Mimic components of natural flow variability, taking into consideration the magnitude, frequency, timing, duration, rate of change and predictability of flow events • Currently there exist more than 200 methodologies for assessing eflows across the world • In the absence of time, data and will, experts and water managers are quoting and working on simplistic, rule-of-thumb methodologies that recommend some guidelines, in spite of data constrains. (EAC: 20% Lean Season Flow, 30% monsoon Flow) • “Such simplistic guides have no documented basis and the temptation to adopt them represents a grave risk to the future integrity and biodiversity of the world’s riverine ecosystems.” Arthington, 2006

10. Methodologies for Greenwashing • The AHEC Report considered various methodologies including MAF (modified Tennant), WCD, EMC HMD, Q 95. For each, the baseline selected was low, lowest in some cases and unacceptable • 75% of Q95: “Compressing your life to five worst days, selecting consistently worse amongst them and prescribing them for the rest of your life” • WCD guidelines never claim 10% of MAF as eflows. • EMC HMD is poorly developed • The study recommends WCD, or EMC based Eflows • No consideration of livelihood needs, special ecosystemic needs, flood flows, spiritual or cultural needs • Random 5 methodologies and ranges are given, which do not mean anything • Lohit and Bichom Basins: • Building Block Methodology entirely misrepresented • “Fair and degrading condition for Tennant’s method” : recommendations for poor quality (10% AAF in Lean season and 30% wet season) • Impact of peaking releases not considered: Same in case of Alaknanda Bhagirathi • ALL baseline criteria for all methodologies used (WAPCOS in Lohit and Bichom Basin Studies) are assumed to be very low, leading to a highly compromised eflows regime • Eevn in best case scenarios of 100% implementation of regime: benefits are doubtful

11. Eflows assessment and recommendation using faulty or inadequate methodologies, in the absence of informed community involvement is a sure way of green washing environmentally and socially damaging projects. • Adaptive management ? Integral part of any agreement with the dam builders, with a clear clause that downstream flow allocations are liable to change if community based monitoring of e-flows so suggests. • This flexibility is also very important from the climate change point of view. • However, there are consultants who themseleves defend the govt, saying that eflows cannot be changed after PPAs are signed

12. EAC is still giving individual clearances to projects, though the AHEC report is not accepted and fate of WII report is unknown. In short, without any CIA, against the Supreme Court and CEC orders. • Shockingly, instead of sticking to precautionary principle and being strict about eflows norms, EAC and MoEF are giving clearances to dubious projects 300 MW Alaknanda HEP, rejected by FAC twice

13. CSOs don’t have to waste too much of their precious time and resources in trying to understand a methodology entirely. • What the communities should ensure is whether the adopted methodology integrates and responds to local challenges and if their view points on how a river should flow or not flow is considered in the objective setting, assessment and implementation. • Points to be considered while assessing a pre selected methodology or suggesting a new one: • Was the community/community representatives/CBOs a part of discussions while selecting the methodology and actually deciding e-flows through the methodology? If not, this is a strong reason to demand for community involvement at this stage. • Does it try to mimic the natural hydrograph or does it only deal with bulk figures for a year or two seasons? There should be 3 or 4 different e-flows figures for the 3 or 4 different seasons. There should be stipulations for releasing additional water to create flood like situations.

14. Does it respond to community needs like water for cultural and religious needs, water for transport, for riparian farming and drinking water needs (subsistence farming, not large scale irrigation). • Does it include a multidisciplinary team of experts not limited to government and dam proponents? • Does it provide a legitimate space for communities also in the objective setting (how the community views the river) and implementation and monitoring stage? • Does it have a clear mandate of adaptive management, through which e-flow regimes can change in face of changes in flow regimes over years, downstream monitoring and changes in climate?

15. However, any methodology is only as good as it is interpreted and implemented.Hence: • An unbiased external agency with requisite skills to implement and monitor the selected methodology •  Which is genuinely concerned about downstream impacts and • Which will not be pressurised in favour of the project proponent is an important pre requisite of this process. Advocating for such institutions or network of institutions and their democratic functioning is central for efficient and effective water management as well as for effective e-flows implementation.

16. Monitoring Eflows Allocations • Monitoring : assists in controlling river flows and demonstrate s contribution of e-flows towards enhancing the ecological, economic and social benefits of improved flow regime. • Reality: Checking whether the prescribed e-flows are actually being released or not! • Himachal Pradesh : High Court Directive for all dams to release 15% of the mean flow of the respective rivers downstream at all times as minimum flows. • The one member High Power Committee, of Avay Shukla, Additional Chief Secretary Forests constituted by the Himachal Pradesh High Court visited environmental compliance issues of 11 hydropower dams (only those under construction) above 100 MW in Himachal Pradesh • What this committee noticed, not surprisingly, NONE of the 11 dams release the meagre 15% of flow for the downstream.

17. The highly inappropriate estimate of 10 cumecs from Tajewala to Yamuna is not being followed. • The Allahabad High Court in a landmark decision in 2011, ordered State of Uttar Pradesh to release at least 50% of the water from the Narora barrage into the river channel and limit water withdrawal to 50% of the water release. • The High Court further opined that “there should not be withdrawal of water from main course more than 50 % and at best 50 % of the river water could be diverted for other purposes.” • Not much is happening on this, to the best of our knowledge. • These situations highlight the fact that just putting e-flows releases in conditions of sanction of reservoirs or even court directives are not serving the purpose. • Effective monitoring mechanisms are a pre requisite to ensure timely releases of minimum flows leave alone e-flows.

18. What can help: • Access to information on the e-flows releases from the upstream reservoirs to all the concerned riverine communities and monitoring committees. • Effective community monitoring can be ensured only if at least the most directly affected riverine communities are involved in all the different steps from objective setting, implementation to monitoring. • A monitoring committee should be instituted for each dam which includes community representatives, independent experts, local voluntary organisations, government officials responsible for monitoring and dam operators and authorities. • These should visit the dam site when the actual releases are being made ideally every month, or at least once in three months, when releases may change. They should certify that the agreed releases are actually being delivered.

19. Simple measures like poles with level markings and corresponding months should be set up on river banks, bridges or river beds to indicate the approximate level from where to where the water should reach when releases of a specific quantum are made. • This will not only help in monitoring e-flows, but can also be an effective safety measure in case of peaking projects. • The results of the monitoring should be communicated back to all concerned within the river basin on a timely / seasonal basis.

20. Eflows is not an end in itself • Environmental Flows releases from dams is only one part of the strategy for protecting rivers. • Maintaining free flowing rivers, linking their goods a and services with social well being, opposing destructive dams and cascades, protecting ecosensitive regions, options assessment and costs benefit analysis and good governance of existing dams and water infrastructure are the main goals • Eflows is not and cannot be an end in itself, but are an important part of Plan B

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