The proponents of a mini-hydel project, who were asked by the authorities to halt work since the projected area of submergence had not been communicated to affected villages, have jumped the gun.

The Kukke Hydro Project Pvt Ltd (KHPPL) has requested for CDM credits with the United Nations Framework for Climate Change (UNFCC), without complying with the directive of the Karnataka Renewable Energy Development Limited (KREDL).

There were several serious issues with both the 214MW Kukke project itself as well as its validation, which had been highlighted by dna in June 2012. The report is among the set of documents submitted last week by stakeholders to the UNFCC, urging it to review the project and initiate action against the validator.

The most shocking aspect of the 24MW Kukke Stage I project was that once commissioned, it would have submerged the tail of an already operational 4.8 MW Hosamatha MHS (mini-hydel scheme) on the Kumaradhara river in Dakshin Kannada district. The Hosamatha MHS too had raised its objections with KREDL, the state government body whose sanction is required before any project can be undertaken. KREDL, which acts as the nodal agency of the Karnataka power ministry, issued a ‘stop work notice’ on February 25 last year. Thereafter, the project remained in a limbo. Till, of course, it filed for carbon credits under the clean development mechanism (CDM) with the UNFCC.

Though the Karnataka High Court asked for a halt to construction of mini-hydel projects in the ecologically-fragile Western Ghats earlier this year, the court’s decision would have been applicable only to new proposals. More than 200 mini-hydel projects are in various stages of implementation in the Western Ghats area.

This is where another catch lies—according to the EIA notification of September 2006, these projects are legally exempt from environment impact assessment, environmental clearance, public hearing and implementing an environment management plan and environmental monitoring. The Kukke dam is one such project.

A fact-finding report by the South Asia Network on Dams, Rivers and People (SANDRP) found that this aspect was not included in the project design document (PDD). Himanshu Thakkar of SANDRP, which has filed for a review on behalf of scientists and communities living in the area, described it as a breach of transparent practices. He said, “All this clearly shows that the project is unsustainable and faces huge local protests and does not qualify to receive carbon credits under the UNFCCC.”

The first objection is about transparency. According to Parineeta Dandekar, who submitted the review application, “The project has not disclosed information about submergence of the project in the PDD, local consultation or validation report. It did not assess submergence directly impacting social, environmental, sustainable development aspects of the project and economic and climate change viability of the project. This fact alone is sufficient for project to be rejected.”

Moreover, modelling studies done by government organisations indicate the project will submerge 388.71 hectares, including 110 hectares of forests. This fact too has not been mentioned by the project proponent. Not only that, though the project was ordered by KREDL to make submergence area details public, it had not done so till last week.

One of the biggest allegations against KHPPL is that it had all along ignored local communities. According to the review petition, “The notice for local consultation was pasted in the office of only one village, thought four villages are to be affected. Villagers directly impacted by the project even from opposite bank have not been informed and excluded from local stakeholder consultation.”

The villagers, obviously, are not aware of submergence details. “In the absence of a study about the submergence, the proponent does not know and has not cared to find out directly affected stakeholders,” Dandekar said.

The KHPPL is also alleged to have flouted Karnataka State Pollution Control Board rules. “The project has not carried out even rapid environmental assessment (R-EIA) as per rules laid by KSPCB. The validation report mentions a draft REIA ‘under preparation’. This was not shared with local and global stakeholders for their concerns. These consultations cannot be complete without R-EIA,” the applicant said.

This allegation assumes a serious note in view of the fact that the project would have severe impacts on critically endangered ecosystems, endangered fish and critical biodiversity corridor by submerging 110 hectares of forests of the Western Ghats.

There are technicalities involved here. According to Dandekar, “The average above-ground stored carbon per hectare ha of forests in the region, as per the samples studied, is to the tune of 427.27 tonens per hectare. The removal of 110 hectares of forests will amount to the emission of 46,999 tonnes of carbon. If we compare this with the emission reduction of the project at 61,382 tonnes of equivalents annually, the project cannot provide claimed emission reductions.”