MoEF Experts committee concludes serious non-compliance on SSP & ISP

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Please find below the Executive Summary and Major findings of the Second Interim Report by Dr. Devender Pandey Committee of Experts to study and assess the environmental safeguard measures of the Sardar Sarovar, Indira Sagar and Omkareshwar Projects.

The Report, which is pre-dominantly based on official data and submissions brings forth many instances of gross violations and serious non-compliance by the concerned state governments of Madhya Pradesh, Gujarat and Maharashtra (particularly M.P.) on various environmental aspects including catchment area treatment, command area development, flora, fauna and carrying capacity, compensatory afforestation and health impacts and recommends that there shall be no further reservoir-filling either at SSP or ISP and no further canal construction and irrigation from network till compliance.

The Report is an important vindication of the people’s struggle in the valley that has been questioning these giant projects at the cost of people and nature. Kindly do write to the authorities, including the Environment Minister and the Prime Minister to use the truthful findings in this Report to take just decision on these projects – ensuring full environmental compliance, compensating the losses and guaranteeing full and lawful rehabilitation.

With regards
Narmada Bachao Andolan



February 2010

Submitted to Ministry of Environment and Forests
New Delhi


This is the second interim report of the committee constituted by the Ministry of Environment and Forests (vide O.M. No. 3-87/80-IA-I, dated 09.7.2008 superseded by O.M. of even number dated 02-09-2008 ) for assessing the status of compliance of environmental conditionalities and requirements to be fulfilled by project authorities of Sardar Sarovar Project (SSP) and Indira Sagar Project (ISP). The first interim report submitted in Feb 2009 mainly dealt on the issue of raising of the piers and overhead bridge of Sardar Sarovar Project and back water level calculations. The issues dealt in this report cover status of compliances on catchment area treatment (CAT), flora and fauna and carrying capacity up stream, command area development (CAD), compensatory afforestation, human health aspects in project impact areas.

The committee has carried out the assessment on the basis of various documents of SSP and ISP including those of study groups, action taken reports and presentations by the project authorities / State governments and by the Narmada Control Authority (NCA) and field visits. The committee also examined the monitoring mechanism and verification exercises carried out by those entrusted 
with such duties. The status and level of compliance has been examined on the basis of the stipulations contained in the order of clearances issued by the Central Govt. & directions given by the Ministry of Environment and Forests (MoEF) and the Environment Subgroup (ESG) of the Narmada Control Authority, from time to time.

Catchment Area Treatment:

The conditionality of catchment area treatment was made integral part of all River Valley Projects as decided by the Committee of Secretaries and the submission of Action Plan on CAT was made mandatory vide order dated 28 Oct 1985 by the Planning Commission. This became a very important condition while granting environmental and forest clearance in 1987 by the Ministry of
Environment and Forests for Sardar Sarovar and Indira Sagar Projects. The total critical area of catchment identified for treatment and demarcated on maps for SSP in 1991 and ISP in 1993 was 1.501 million ha (SSP-0.526 m ha ISP- 0.975 mha) by All India Soil and Land Use Organization (AIS & LUSO). This was slightly higher than the estimate (1.367 million ha) of Inter Departmental Committee of Planning Commission of 1985. State wise, Gujarat had only 29,000 ha, Maharashtra 67,000 ha and the rest 14, 04,360 ha in Madhya Pradesh.

As per the conditions of clearance these areas were to be treated ahead of filling of reservoirs. Gujarat prepared the CAT plan and  treated the full area during 1990-1995 where as Maharashtra has treated about 46,000 ha (68% of its area) during 1992 to 2002. There after no progress has been reported. The compliance by the Narmada Valley Development Authority (NVDA) in Madhya Pradesh
has been highly unsatisfactory. Against an area of 4,29,000 ha in SSP only 161,000 ha (38%) has been treated whereas against 9,75,000 ha in ISP only 87,000 ha (9%) has been treated. On the other hand NVDA (MP) has completed the impoundment of reservoir at ISP in 2006 to almost 100% level by constructing the dam to its full height. In SSP, the impoundment of reservoir is more than 80% where as the total CAT work carried out by three concerned states is reported to be 45 %.

The project authorities, specially the NVDA have grossly violated the conditions of clearance on CAT. The construction schedule of dam and physical works on treatment of catchment area, which should have been linked has not been done. The condition on monitoring mechanism of CAT works has been partially fulfilled by Gujarat and Maharashtra, but grossly violated by MP. 

Fauna, Flora and Carrying Capacity of upstream:

Narmada river basin has been considered as a rich biodiversity area and home to a large number of rare and endangered plants and wild animals. The river is also rich in aquatic fauna including fisheries resource. The key concern in SSP and ISP has been the loss of habitats and biodiversity due to submergence of 128,500 ha land of which 54,498 ha was forests. The Ministry of Environment and
Forests at the time of clearance, stipulated that flora and fauna including rare and endangered species likely to be affected be surveyed first. A Master Plan showing all protected areas be prepared so that areas to be taken up for reservoirs, roads, canals, settlement colonies, etc exclude such protected areas. Further, carrying capacity of the surrounding areas where the wildlife would disperse from the submergence area be studied.

The ESG during its various meetings directed project authorities for declaring Sanctuaries / National Parks as per the recommendation of EIA Study Groups, ahead of impounding. Provisions were required to be made for migratory corridors for movement of wildlife from submergence to safer zones. Islands being formed during impoundment were required to be declared as wildlife habitat. Systematic felling of trees in forest / non forest areas were to be carried out, through approved plan to avoid possibility of animals being trapped in submergence zone and to prevent organic loading to safeguard against eutrophication due to submergence. These environmental safeguards were required to be put in place prior to the commencement of impacts due to construction activities.
The committee has observed that though identification of rare and endangered species has been completed for SSP and ISP, wildlife census of the area has been inadequate. Further, a Master Plan integrating project wide information of the all relevant aspects, which should have been ready well before the commencement of project activities, has not been prepared till now. MP has not yet notified the three areas identified by the Wildlife Institute of India (WII) as protected areas for rehabilitation of wildlife, involving a total
75,888 ha area of ISP. However, impoundment at ISP was almost complete by 2006. This is a very serious lapse by NVDA (MP). Gujarat has partially complied by improving habitat in one of the wildlife sanctuaries. None of the states for either of the projects have created migratory corridors to avoid trapping of wild animals prior to tree felling in the submergence area. This is gross violation of the prescribed conditionalities.

Though, tree felling in the submergence area was reported to be complete by project authorities, but field visits and latest satellite imagery revealed many standing trees under water in the reservoir resulting in non compliance. Further, MP has violated the stipulations by not declaring identified area of the Indira Sagar reservoir as wildlife sanctuary to protect the threatened aquatic species including otters and rather allowed commercial fishing in the entire reservoir.

Command Area Development:

The command area of an irrigation project experiences a major change in water environment by way of a shift from rain-fed to irrigated agriculture wherein large quantity of water is routinely added to the land on a regular basis, to which the land was not used to. To make irrigation sustainable, the Ministry of Water Resources has brought out guidelines for scientific Command Area Development (CAD). The MoEF (1987), Planning Commission (1988) and ESG Meetings (1988-2005) stipulated that there be an approved Environmental Action Plan (EAP) for the Command area, and implementation of the plan and monitoring the impact of irrigation on environment be ensured.

The total cultural command area initially identified in Gujarat was 2.124 m ha, in Rajasthan 75,000 ha and in Madhya Pradesh 0.123 m ha. As per conditionalities of the clearance, EAP should have been ready before the start of construction of the canal and should have been implemented ahead of the start of irrigation. But this has not happened in both the projects (SSP &ISP) and in all the three states.

In Gujarat the drainage plan has not been formulated yet whereas, canal network has been completed in Phase-I covering 0.4712 million ha and unplanned irrigation started in 2003. Micro level planning is available only for 5 blocks comprising 41,306 ha in phase-I, out of 52 blocks, thus covering only 6.5 percent area of phase I. In Rajasthan, the EAP is not yet finalized though the canal network is nearly completed and irrigation started in 2008. Similarly in Madhya Pradesh, the draft EAP is reported to be submitted to MoEF only recently (October 2009) where as canal construction is progressing and unplanned irrigation has started since 2007. This establishes that all the three states have violated the stipulations and not complied on EAP.

For implementation of environmental safeguards in accordance with approved plans, Gujarat and Rajasthan have notified Water User’s association for part of the area which may be construed as partial compliance. But there is no verifiable action taken by MP in this regard which amounts to total non-compliance. Further, in monitoring the impact of irrigation on environment, no monitoring report is available for any of the projects. In SSP, only in Gujarat a few parameters such as water released, area irrigated, soil and ground water quality and water table depth are reported to be monitored. Hence there is non-compliance by Rajasthan (SSP) and MP (ISP) partial compliance by Gujarat (SSP) on the monitoring aspect. 

Compensatory Afforestation:

Under the Forest Conservation Act 1980, the Ministry of Environment and Forests approved the SSP and ISP in 1987 by diverting forests lands to both the projects. In total 13,386 ha forest land was diverted for SSP in addition to 357 ha forest land already used by Gujarat for construction prior to approval. Similarly 41,112 ha forest land was diverted for ISP which included about 622 ha forests land used by Madhya Pradesh for construction of roads and residential colonies of the project. In addition, an area of 2,700 ha in 1990
and 1500 ha forest lands in 1994 was diverted in Maharashtra by the MoEF for the resettlement and rehabilitation (R&R) of people displaced by the SSP project.

The stipulations of the clearance was to prepare plan for afforestation on equal area in non forest land and on double the area in degraded forest land and implement the same, declare non forest compensatory afforested land as reserve or protected forests and transfer them to state forest department, the project authorities should supply firewood to their labours on the project cost and monitor the afforested areas to find the success rates and ensure maintenance of such afforestation/ reforestations.

The committee has found that all the three states for both the projects prepared the compensatory afforestation (CA) plans on time; for 13, 950 ha by Gujarat, 23,668 ha by Maharashtra and 89,682 ha by Madhya Pradesh and have implemented the same within the given time frame. Thus they have complied fully, so far as afforestation targets are concerned. However, these states have not yet notified all the non-forest CA lands as reserve or protected forests thus complying only partially. Final notification of Gujarat for 4,650
ha is still not done and Maharashtra and MP have notified only about 90% of their CA. Regular monitoring for assessing the success or failure of the CA has not been satisfactorily complied and the reports of such monitoring not presented to MoEF/ESG. Thus it is difficult to confirm as how much of the CA areas have successfully established. Further, Gujarat has complied on impact assessment studies for the new eco-system for the areas being away from the Narmada Ecological zone but not by Maharashtra and Madhya Pradesh.

Human Health:

The construction of dams and water projects leads to alteration of water distribution patterns which brings a lot of environmental change impacting health of the people who live around due to water related diseases spread by insect vector. Creation of facilities for prevention of the water born diseases and screening of migrant workers and immigrant influx have been key concerns of SSP and ISP projects.

While clearing SSP and ISP in 1987, the Ministry of Environment and Forests stipulated that baseline studies and surveys of water borne diseases and health delivery system be conducted by 1989 and then project specific approved environmental action plans on health aspects to be prepared by the project authorities prior to implementation of the projects. It was also stipulated that implementation of approved Environmental Health Action Plan which included screening arrangement for the workforce, surveillance of diseases and reporting various surveillance programmes under a single format, reinforcement of the existing health delivery system, water quality monitoring of identified parameters, construction of sanitary latrines and IEC campaign and creation of project specific health cell, be done pari-passu. The implementation works be monitored and evaluated through project specific health cells and progress be reported periodically to MoEF/ESG and the data and reports related to health be put on the website regularly. The committee has found that compliance of the various stipulations has been only partial and in many cases delayed and negligible.

Gujarat conducted the baseline studies on time but MP and Maharashtra delayed by two years and all the three states did not follow common protocol. Environmental Health Action Plan for ISP was approved by the ESG / ICMR in 2003 where as for SSP similar plans are still lacking for Gujarat, MP and Maharashtra. The plans have been prepared on piecemeal approach were also revised from time to time but only to accommodate the shortfalls. Though screening facility has been created in SSP but no data are available. Credible evidence for comprehensive surveillance is lacking and integrated reporting formats not developed for collating data from other national programmes. Though partial infrastructure (buildings etc) for Public Health Centers has been created, but reliable information on their functioning is not available. It is reported that Doctors and dispensary staff are either absent or inadequate. Water quality monitoring (SSP and ISP) reports that were required to be submitted regularly to MoEF/ESG are mostly lacking except for some bacteriological testing. Effectiveness of IEC activities has not been reported. Project level health cells have not been created, though some such arrangement exists in MP and Gujarat only.


The foregoing paragraphs reveal that project authorities of SSP and ISP have not taken due care of the environmental safeguard measures as stipulated during clearance of the these projects. In most of the cases the Pari-Passu clause focusing simultaneous actions on environmental safe guard measures has not been respected. The compliances have been either partial or delayed and in a few cases not complied till today. Of the five parameters discussed in this report, the project authorities (SSNNL and NVDA, Government of Maharashtra) have grossly violated stipulations in respect of catchment area treatment, flora, fauna and carrying and command area development causing irreversible loss to the environment. 

The committee therefore recommends that no further reservoir filling either at SSP or at ISP be permitted till the catchment areas of both SSP and ISP are fully treated and all the outstanding requirements to protect and conserve flora and fauna including preparation of master plan and creation of wildlife sanctuaries are put in place. No further construction work on the canal network and no irrigation from even the existing network should be permitted till the various environmental parameters in the command area other than water management becomes Pari-Passu.



Dr. Devendra Pandey,
Formerly Director General,
Forest Survey of India
C-91, Millennium Apats,
E-10A, Sector 61, Noida, UP


Prof. Dr. C. K. Varshney,
88, Vaisali, Pitampura,
Delhi. Dr. B. P. Das,
717, Sahid Nagar
Bhubaneshwar-751007, Orissa.

Dr. A.K Bhattacharya
Flat No. 805
Pocket-3, Akshardham Apartments
Sector-19, Dwarka, New Delhi- 110075.

Dr. Shekhar Singh,
Somouya, Centre for Equity Studies
C-17 A, DDA Flats, Munirka, New Delhi-110067.

Dr. Pawan Kumar, Director (Environment),
Narmada Control Authority,
Narmada Sadan, Sector B,
Scheme No. 74, Vijay Nagar, Indore-452010.

Shri S.B. Ota,
Director on Monument and Antiques,
Archeological Survey of India,
24, Tilak Marg, New Delhi- 110 001

Dr. V. B. Mathur,
Dean, Faculty of Wild Life Science,
Wildlife Institute of India,
P.O. Box No. 18, Chandrabani, Dehradun–248006 (U.T.)

Prof. (Dr) Nandini Sharma,
Department of Community Medicines,
Maulana Azad Medical College,
New Delhi- 110 002

Shri S. Bhowmik,
Addl. Director,
Ministry of Environment & Forests,
Paryavaran Bhawan, CGO Complex,
Lodi Road, New Delhi-110003

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