Submission by environmentalists Parineeta Dandekar and Himanshu Thakkar of the South Asia Network on Dams, Rivers and People (SANDRP), to the Chairperson and Members of the Expert Appraisal Committee, River Valley Projects, Ministry of Environment, Forests and Climate Change, Government of India, against 1500 MW Warasgaon Warangi Pumped Storage Project by Adani Green Energy:
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We see that Adani Green Energy’s 1500 MW Warasgaon-Warangi Pumped Storage Project is being considered for fresh TORs in the upcoming meeting of the EAC. We have gone through the documents uploaded by the proponent (AGEL) on MoEF CC’s Parivesh Website.[1]
We are disturbed by the callousness of the proponent. Adani Green Energy Limited (AGEL) has not addressed any of the issues raised by the EAC, has turned a blind eye towards submissions and has not tried to amend any of the ecological impacts of cutting down forests, blasting, tunneling and muck disposal in Western Ghats or the disaster implications of its project in a landslide-prone area.
We earnestly request the EAC to reject the TOR application at this phase to set an example.
Our objections are noted below:
No effort to follow EAC’s recommendations:
The project has been considered by the EAC twice before. In its 16th meeting (27th October 2024), the EAC had asked the proponent to apply afresh for TORs. This was an opportunity for the proponent to resolve two important issues raised by EAC in the 16th meeting:
1. Fresh alternative site analysis modifying the project layout with no obstruction of small rivulets in the area as the small rivulets are the key source of water for the perennial rivers in the western ghats.
2. Change in project profile i.e. change in project layout, reduction in forest land and private land requirement.
Unfortunately, there has been absolutely no change in the siting or the basic parameters of the project. The location of the Upper and Lower projects, FRL, land required, Forest to be submerged, all remain the same. In effect, it is the same PFR as submitted in the 16th EAC Meeting.
The proponent has simply attached the Options Assessment it had done previously. This Options Assessment is a purely economic exercise which does not even address the impacts on community conservation areas, Forest lands, Eco-sensitive zones or disaster-prone regions of the Western Ghats. This is clearly not what is required for environmental considerations.
It is disturbing to see the PP submit the same project parameters after the EAC specifically asking for steps to be taken to reduce the impact on Western Ghats ESZ Area and rivulets. We therefore request the EAC to reject the project at TOR stage itself.
Adani Project threatens an important Community Conserved Fish Sanctuary and Sacred Pool:
As we had stated in the earlier submission, Adani project is barely a kilometer upstream of a spectacular and important community conserved area called Varadayini Goddess Fish Pool. The “minor nalla” which the proponent plans to block is in fact the only source of water for the fish. It is a place greatly revered and protected by the dwellers.
The five kms radius of Adani and JSW Pumped storage projects includes Dapsare Sacred Grove, Varadayini Sacred Grove and the famous Mangaon Sacred Grove ( just 2.9 kms as the crow flies from Upper Adani Dam). All of these gems of community conservation will be affected by blasting, tunneling, roads and muck disposal. These are some of the last remaining intact forest patches of Pune region.
This project location is remarkably bad for ecologically sensitive regions and needs to be profoundly altered. Letter by the Chief Wildlife Warden has also raised important issues which need to be addressed.
Please read our original submission which was endorsed by over 150 people here.
Cumulative Impacts unaddressed:
· Upper Adani Dam is barely 3 kms from the proposed Upper Dam of 1500 MW Pane Pumped Storage by JSW.
· Lower Adani dam is about 3.5 kms away from Lower JSW Dam.
· Both the lower dams are about 5 kms away from Walen Kondh Fish sanctuary.
· In addition, Government of Maharashtra’s infamous Kal Hydropower Project has been ongoing on the Kal River[2]. This destructive and corrupt project is barely 2.3 kms away from Lower Adani Dam. We have visited this project and have written in detail, see: https://sandrp.in/2015/07/20/white-elephant-black-fish/.
· All the three lower dams will together sound a death knell for on the Walen Kond Fish Sanctuary.
Villages of Tekpowale (No. 1106) and Warangi (No.1169) are notified as Ecologically Sensitive Zone (ESZ) through the Western Ghats ESZ Notification dated 31st July 2024.[3]
The Notification regulates Hydropower Projects in the ESZ as below:
“New Hydropower projects shall be allowed as per the Environment Impact Assessment notification, published vide number S.O. 1533 (E), dated the 14th September, 2006, subject to the following conditions, namely: -
(i) uninterrupted ecological flow of at least thirty percent of the rivers flow in lean season, till a comprehensive study establishes individual baselines for each project;
(ii) a cumulative impact assessment study which assesses the impact of each project on the flow pattern of the rivers and forest and biodiversity loss; and
(iii) the minimum distance between one project and the other is maintained at three kilometer and not more than fifty percent of the river basin is affected at any time.”
All of the above-mentioned clauses are being violated by Adani Project.
1. There is no mention of ecological flows in the project parameters or PFR. Even smaller rivulets are lifelines for ecologically critical areas like the Varadayini Sacred Pool or Walen Kondh Fish Sanctuary and cannot be ignored.
2. Cumulative Impact Assessment of the Pumped Storage projects in Western Ghats of Maharashtra in general and Kal River in particular is not done, not even announced.
3. Distance between the partially-completed 15 MW Kal Hydropower Project (undertaking of Government of Maharashtra) and Adani Green Energy Lower Dam is 2.3 kms. The Distance between AGEL Lower Dam and JSW Lower dam is just about 3 kms.
Hence all the norms for hydropower projects in the ESZ are being violated.
We cannot help but add that this looks like a mockery of sustainable development in Western Ghats.
Blasting and tunneling in a Disaster-Prone area:
In 2021, Tailye village on the slopes of Kal Basin (much the same location as the slopes where Adani Dams are to be built), suffered a devastating landslide leading to the death of over 84 people. The landslide was mainly a mudslide following incessant, extreme rainfall. Taliye village is just about 33 kms from Warangi village where the lower dam is planned. [4]
In 2021, landslide also occurred in a settlement called Hirkaniwadi which is just 3.7 kms as the crow flies from Warangi.[5]
In 1995, a landslide occurred in Parmachi Wadi causing death and destruction. Parmachi Wadi is about 20 kms from Warangi.[6]
The Disaster Management Department of Raigad District and Geological Survey of India has studied and published a list of landslide-prone villages in Raigad District. Mahad Taluka, where the lower dams are planned, has the maximum number of villages marked as disaster prone (49 villages).[7] Considering the real and urgent threat to human lives, tunneling and blasting should be avoided in this region.
Extreme weather events are becoming more common, and rainfall is becoming increasingly erratic globally. In such a changing climate, is it wise to consider two projects with four dams and kilometers of blasting and tunneling in a region that has experienced so many landslides and is clearly landslide prone?
Suspected Tiger presence:
Not only is the area extremely rich in biodiversity and Forest cover, dhangars of the area maintain Tiger presence near the Upper Dam site and mountain slopes towards the lower dam. We have photos of pugmarks and scat. Camera trapping is strongly requested to establish the presence of Tiger in this region beyond doubt.
MOUs uploaded by Adani Green Energy flex money power:
We noticed that in place of uploading documents which show how the proponent is trying to protect the forest land and Rivers of Western Ghat on the MoeFCC Environment Clearance Website, Adani Green Energy has uploaded two MOUs. One is with the Department of Energy, Government of Maharashtra and the other is with the Water Resources Department, Government of Maharashtra. Neither mentions environmental issues even in passing.
These MOUs are objectionable in the context of MoEFCC as they only highlight the hefty investment of thousands of crores through which Adani Project is luring the state. The MOU with WRD does not mention water requirement of the projects nor does the proponent make Water Availability Certificates available for perusal.
A PFR which does not even consider the Western Ghats and MOUs which flex money power of the proponent should not find a place in the deliberations and decision making of the EAC.
Need for site visit before any further consideration of Pumped Storage Projects in Western Ghats:
In the 16th EAC Meeting, the EAC had rightly expressed concerns about TORs that have been granted for more than 15 PSP projects in Western Ghats. With new MOUs being signed by the state each month, the number of PSP schemes is exponentially rising. The EAC had recorded that it plans to conduct a site visit to these places.
We earnestly request the EAC to conduct site visits prior to making any further recommendations or decisions on PSP projects in the Western Ghats.
In conclusion:
We hope that the EAC appreciates our submission as raising specific issues. Pumped Storage Projects, because of their limited land and water-use have a vast potential in being set up areas without ecological and disaster consequences and being truly sustainable.
That can happen only when the proponents with massive investment potential also pay attention to ecological issues and set an example in Green Energy. In the absence of this, there is nothing Green about these initiatives.
EAC has already sanctioned TORs for PSPs far in the access of what Central Electricity Authority considers viable or required in the next decade and more. (See: https://sandrp.in/2023/03/03/comments-on-power-ministry-draft-guidelines-on-pump-storage-projects-in-india/ and https://cea.nic.in/pumped-storage-plants/?lang=en, particularly: https://cea.nic.in/wp-content/uploads/pumpedstorage/2024/10/11._List_of_Pumped_Storage_Projects_granted_ToR_by_MoEFCC_1-1.xlsx.
We therefore request the EAC not to grant TOR clearance to Adani’s Warasgaon Warangi Pumped Storage Project. The location is too valuable for such destruction. We also request the MoEF and EAC to urgently consider a Policy for Pumped Storage Projects, in consultation with local communities and experts.
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End Notes:
[1] https://parivesh.nic.in/newupgrade/#/proposal-summary/proposal-document?proposal=111370981&proposal_no=IA%2FMH%2FRIV%2F505573%2F2024&proposal_id=111370968
[2] https://sandrp.in/2015/07/20/white-elephant-black-fish/
[3] https://mahaforest.gov.in/writereaddata/grs_file/Draft%20Notification%20WGESA%2031-7-2024.pdf
[4] https://blogs.agu.org/landslideblog/2021/07/27/taliye-1/
[5] https://www.mahamtb.com/Encyc/2021/7/24/At-Hirkaniwadi-the-pain-has-subsided-again.html
[6] https://www.esakal.com/mumbai/todays-latest-marathi-news-mah23b08621-txt-raigad-20230626114545
[7] https://www.esakal.com/mumbai/todays-latest-marathi-news-mah23b08621-txt-raigad-20230626114545
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