SANDRP Comments on the Baglihar Hydropower Project in Jammu and Kashmir, India
Comments on the proposal to give CDM credits to "Substitution of Hydro-electric power in the National Grid" Or BAGLIHAR Hydropower project in Jammu & Kashmir, India
Having read the Project Design Document (PDD) and having been familiar with this project over the last few years, my comments on the proposal to CDM credits to this project are as follows.
Broadly, this project is not using any new or imported technology that is not already being used in the project area. This project is also not additional, as the project implementation has started many years before the CDM projects came into existence, and its technical, economic and other viabilities were certified without consideration of CDM credits, long before the CDM project started. Nor can the project be defined as sustainable development, as it is going to have significant social and environmental impacts, the local people would only the losers, because they would get no benefits from the project. Under the circumstances, giving CDM credits to such projects would be wrong for everyone.
Moreover, the PDD is also giving wrong and misleading facts on a number of points, as described below.
The PDD says (section A.2, page 7), "Construction of high voltage transmission line in inaccessible and high altitude mountain terrain, approach roads, dam across the river, power plant and other units of the hydro power plant in the mountainous region is a good example of the use of highly advanced technology for construction in adverse geological conditions." This statement is wrong and misleading and use of these structures cannot be called import or use of new technology. Such structures have been built for decades all over India, including in Jammu and Kashmir (e.g. the 480 MW Uri HEP and the 690 MW Salal HEP in J&K).
If J&K is facing such huge power shortages as described in PDD (section A.2, page 3), than why has it been decided to sell 50% of the power from the project to PTC (as stated in section A.4.3 of the PDD) to be sold outside the state? Since the home state of the project has such a huge power deficit, all the power from the project should be used in the state. Exporting the power in such a situation is inappropriate and would actually add to system losses.
The PDD states in section B.2 (page 12-13) that the Northern grid has been considered for the project, but at least 50% of the power is to go to Jammu & Kashmir, more should go considering the power deficit in the state, so it is not right to consider Northern grid for the project.
The PDD states in section B.2 (page 12-13), "the reservoir area for the project activity at full reservoir level is approximately 23 x 104 m2". This is totally wrong and misleading. The reservoir area, as per official website (see: http://doda.gov.in/others/hydro.htm) is 12994.17 kanals, and in Kashmir, 8 kanals equals 1 acre. So the submergence area would come to 6.58 million sq meter, the figure given in the PDD is gross underestimate.
The PDD states in section B.3 (p 15-16) that the methane emission is minor in the baseline area, when there has been no measurement of methane emission from reservoirs in the baseline area. It has also assumed that the methane emission from the project activity is nil, which is not correct. The project will also lead to contribution of emission due to submergence and cutting of forests/ trees, due to use of various materials and works for the project that would contribute emission.
The PDD states in section B.4 (page 16-17) that the only alternative to the project is no project scene. This is totally wrong. J&K itself has large number of options including taking up of small hydro projects, which has huge potential and also reducing the transmission and distribution system losses.
The section B.5 of the PDD, trying to demonstrate additionality, is totally wrong and misleading. The project has been under construction for many years before the first CDM project was considered under UNFCCC and as we write this, it is about to be completed. To claim that this project would not be possible without CDM credits is completely wrong. The project work is about to be completed, all the costs have been incurred, at no stage in the project, was CDM credit discussed, the project has been given all the clearances, including the technical and economic viability clearances without the CDM credit consideration. Hence for this project to be viable, CDM credit is not required.
The section D.1 on environmental impacts is giving an incomplete and misleading picture, but since CDM board has given no important to these issues in the past, we are not elaborating here. If CDM board so required, let us know, we would be happy to give detailed comments on this and subsequent sections.
Giving CDM credits to Baglihar project under such circumstances would be wrong for the whole world, since the world will think that a lot is being done for reducing the carbon emissions, when in reality, nothing, absolutely nothing is happening in this project in that regard. Moreover, this project would also contribute its share of emissions.
Himanshu Thakkar (firstname.lastname@example.org)
South Asia Network on Dams, Rivers & People (www.sandrp.in)