The biodiversity significance of the Vazhachal Forests in the Southern Western Ghats
Part I: he project in brief and the sequence of legal and people’s resistance to the project
1. The 163 MW Athirappilly Hydro Electric project is planned 35 km east of Chalakudy town, along the Chalakudy - Anamalai Inter State Highway in Charpa Forest Range of Vazhachal Forest Division. According to KSEB, the 23 m high 311 m wide Dam project would require the diversion of a total of 138.6 ha of forest land. It is envisaged as a peak load station according to KSEB and water would be diverted via two penstock pipes to the power house (80 x 2 MW) along the banks of the Kannankuzhi thodu 7 km downstream of the dam site. A dam toe power house is also proposed immediately downstream of the dam (2 x 1.5 MW) to maintain the Athirappilly and Vazhachal waterfalls according to KSEB.
2. Five dams constructed in this river namely Parambikulam, Thunacadavu, Peruvarippallam, Tamil Nadu Sholayar and Kerala Sholayar is part of the historic Parambikulam Aliyar Inter State Inter Basin Water Transfer Treaty, named the Parambikulam Aliyar Project in operation since 1970s. Except for Kerala Sholayar dam, Tamil Nadu owns all the others. Around 40% of stream flow is diverted by this Treaty to Tamil Nadu. The proposed Athirappilly project has to entirely depend on the dam discharge from the 48 MW Poringalkuthu HEP commissioned in 1957 immediately upstream of the dam site for its operation since most of the streams in the own catchment of 26 sq.km dry up immediately after December.
3. A major irrigation project (Chalakudy River Diversion Scheme, CRDS) 15 km downstream of the dam site irrigates an ayacut of 14,000 ha (official figures) in 20 odd grama panchayaths in Chalakudy, Periyar and Karuvannur river basins spread in Thrissur and Ernakulam districts .The CRDS commissioned since 1957 is presently the main source of drinking and irrigation water for atleast 22 grama panchayaths. More than 30 drinking water schemes and 700 odd lift irrigation schemes directly take water from the river. A population of about 10 lakh and 28 local self governments directly depend on the river for various uses.
4. Two famous waterfalls namely the 45 m Athirappilly waterfalls (5 km downstream of the dam site) and Vazhachal (400 m downstream of dam site) attract lakhs of tourists to the river every year. The Athirappilly waterfalls alone have attracted more than 7 lakh tourists in 2006 alone.The MoEF has granted Environmental Clearance to the proposed Athirappilly project subject to the condition that “KSEB should sacrifice its power generation if warranted, by giving priority to maintenance of 7.65 m3/sec over Athirapally fall and provide full release from Poringulkuthu dam without diverting into the HRT of the proposed Athirapally HEP. This will serve the apprehension of the people that Athirapally waterfalls would cease to be waterfall depriving of their livelihood.”
5. The Chalakudy river basin is the only home of the primitive hunter gatherer endangered tribal group Kadar numbering just around 1500 like the Jarawas of Andamans. They have been displaced and scattered several times for the dam projects in the upstream and have never been provided any eligible compensation or resettlement and rehabilitation package all these 45 years of dam building history in the river basin. The present settlements at Vazhachal and Pokalapara are relatively stable and they are trying to establish in the main river valley through Vana Samrakshana Samithi activities with the Forest Department and fishing and NWFP collection, their traditional livelihood options. The project authority claims that not a single family will be evicted due to the Athirappilly dam project. These two settlements namely Pokalapara (23 families) in the upstream and Vazhachal (58 families), 400 m downstream of the dam site would eventually be smoked out by the proposed project.
6. The proposed project has a long history of violations of the EIA Notification 1994 and its Amendments as cited in the chronology of events. The Stage II Forest Clearance to the project was given on 16th December, 1999 vide F. No.8-12/97-FC. The people in the River valley came to know about the project only in December 2000 when the stone laying of the project was announced through news papers.
7. The High Court Judgment on 17th October 2001 based on the PILs filed by Chalakudy Puzha samrakshana Samithi and a downstream organisation called ‘Nilanilpu’ ( as cited in the chronology) directed the MOEF to reconsider the Clearance granted in 1998. To quote the judgment,” We direct the Board to comply with the requirements of Environment Impact Assessment Notification, 1994 as amended by the notification of 1997 in so far as it relates to public hearing and direct the Board to send up to the Authority concerned the report of public hearing also as mandated by the amended notification. We direct the Central government to reconsider the question of grant of environmental clearance in terms of the Environment Impact Assessment Notification, 1994 as amended by notification dated 10-4-1997 on the basis of all the materials including the report of public hearing……Since we are concerned with public interest in these proceedings, we think it is just and proper to issue a direction to the Board to take all the necessary steps to repair and restore to full capacity, all the existing Hydro Electric Project to ensure that the generation of power as envisaged is obtained and also to take steps to ensure that transmission losses are minimized and that theft of energy is prevented and to the extent possible eliminated altogether”.
8. At the 6th February 2002 High Court Ordered Public Hearing, around 500 people attended, 63 people spoke, out of which just 5 supported (KSEB officials and their Union representatives) the project and majority of the written representations were against the project. Except for the officials of the KSEB the project was opposed by the Kodungallur Municipality, Chalakudy Block Panchayath, five Gram Panchayaths in the river basin, Scientists, farmers, tribals, research students, and environmental groups.
9. Meanwhile, KSEB engaged WAPCOS for an REIA on 22nd January 2002. However, this fact was concealed from the public at the Public Hearing by KSEB. The 2002 EPH panel recommended a comprehensive river basin level EIA covering all seasons, including water budgeting and incorporating various departments, local bodies etc. A fresh public hearing on the CEIA was also recommended before taking a final decision on the project. The KSEB requested WAPCOS to extend the study to a CEIA based on 6th February 2002 PH panel recommendations vide Ltr No.IELA/EMC/AHEP/2002/1039 dated 10-07-02.
10. WAPCOS engaged Environmental Resources Research Centre (ERRC) based in Thiruvananthapuram to conduct the survey for ecological aspects and has indicated ERRC as the local NGO or local expert on environmental matters. ERRC has taken a dual role of being part of the EIA team and representing the local NGO as well. Meanwhile, ERRC also cannot qualify as a local NGO since it is based in Thiruvananthapuram and not in Thrissur. It may please be noted that ERRC is the EIA Agency that carried out the REIA for the proposed Pathrakadavu during 2003.
11. There has been no comprehensive river basin level environment impact assessment carried out by the WAPCOS - ERRC - TBGRI team during 2002 as claimed by the MoEF and WAPCOS. The Kadar tribals in Vazhachal and Pokalapara settlements who are the immediate impacted, the DFO, Vazhachal Forest Division under whose jurisdiction the project area falls, , the Athirappilly grama panchayath within which the project area falls, the Irrigation Department in charge of the Chalakudy River Diversion Scheme, have all stated that they were not contacted by any member of the EIA team for collection of data or details during the study period claimed between January-December 2002.
12. As per the information obtained through RTI (vide Ltr. No. WAP /RTI /Admn/19/108/ REQ -1/ 2006 dated 19.07.2006), “the study related to Tribal Population in the Impact Zone was carried out by TBGRI, Thiruvananthapuram, who were engaged by KSEB for the study and they visited the above mentioned tribal settlement during their social survey”. However, Geetha, the Kadar tribal community leader and tribal Anganwadi teacher who had filed the PIL in 2005 (OP No.9542/2005) challenging the Clearance granted in 2005, had pointed out in her PIL that “WAPCOS did not visit the settlements or contact the Vana Samrakshana Samities constituted under the forest department for any details regarding the Kadars”. Geetha as Petitioner had also pointed out that the Rapid EIA by TBGRI carried out in 1996 had wrongly prescribed the Kadar settlement as 4 Km away from the dam site whereas the actual distance was less than 400 mt. Geetha also publicly stated the same at the High Court ordered Public Hearing held on 15th June 2006 at Chalakudy .
13. Geetha, the petitioner submitted a complain on the problems that would be created by the project on the primitive and endangered Kadar tribes to the Hon’ble Forest Minister when he visited the area during August 2006. As per instructions from the Minister, The Tribal Rehabilitation Commissioner made a site visit and took evidence from Geetha and other Kadar tribals from Vazhachal and Pokalapara settlements. The report of the Tribal Rehabilitation Commissioner on the site visit clearly admits that the grievances raised by Geetha are justified and states that the construction of the dam will have social, economic and ecological effect on their lives which must be suitable addressed. Moreover, the Commissioner has also pointed out the need to view the petition in the light of the new law enacted by the Government of India viz,” The Scheduled Tribes and Traditional Forest Dwellers ( recognition of Forest Rights) Act, 2006”.
14. When the five member River Valley Expert Committee visited the project site and important places in the river basin during 12th and 13th April 2007, the tribals at Pokalapara and Vazhachal led by Geetha had categorically stated that since they live within the immediate impact area of the project, they would be eventually smoked out once the dam is constructed though the KSEB says that not a single family would be displaced and both the settlements are not technically project displaced. They had also positioned their strong objection to the implementation of the project before the Committee. They also pointed out the dismal track record of the KSEB and the Government in providing rehabilitation. Displaced several times for the six dams upstream from the river valley over the last 45 years and never given the eligible compensation or resettlement or rehabilitation package, they have lost all faith and trust in KSEB or the Government and hence are not willing accept any package and just wanted to be left alone. None of these genuine sentiments expressed by the tribals has been reflected in the Site Visit Report of the Expert Committee clearly raising doubts over the integrity of the Committee’s objectives of site visit!!
15. The Athirappilly Grama Panchayath in which the project is proposed had filed a PIL in the Hon’ble Kerala High Court challenging the Clearance granted in 2005 (OP No. 11254/2005). Chalakudy River is the life line of the residents of Athirappilly GP. The entire 489 sq.km area of the GP is within the catchment of the river. The residents of the panchayath have been facing acute drinking water shortage and the panchayath has therefore implemented several drinking water projects including the Jalanidhi Scheme of the State Government which is located just below the Athirappilly waterfalls. Tourism and related livelihoods is the main revenue source for the grama panchayath. They pointed out in the 2005 PIL itself that “the officials of the WAPCOS team who allegedly conducted the CEIA did not even visit the Panchayath office for enquiry or data collection” contrary to the claim by WAPCOS EIA agency in the reply to RTI filed. The grama panchayath governing body of 2002 was not even aware of the conduct of any EIA study though it is alleged to have taken place over a period of one year within their jurisdiction. Sri. Pushpangadan, the GP President who had filed the PIL in 2005 has also submitted before the High Court Ordered second Public Hearing Panel on 15th June 2006 that WAPCOS had not contacted the panchayath while conducting the studies.
16. WAPCOS is claimed to be an internationally reputed EIA agency by both KSEB and MoEF. According to WAPCOS CEIA, the total land area under the grama panchayath in is depicted as 50.66 ha and the total agricultural land area as 49.35 ha! The income from agriculture is depicted as Rs. 2, 20,000! (Chapter 3 Environmental Base Line Status, page 3.19 of WAPCOS CEIA). As per official records with the grama panchayath, the total land area of the grama panchayath is 489 sq.km. As per panchayath records, the area under agricultural plantations alone is 1853.15 ha; the area under paddy land converted is 20.32 ha. Forest area leased out to Plantation Corporation of Kerala for agri- plantations comes to another 3545.50 ha. It is clearly evident that the EIA team has neither visited the Agricultural office (Krishi Bhavan) nor the grama panchayath in connection with basic data collection.
17. Both KSEB and MoEF claim that all the issues raised at the PH 2002 have been fully addressed in the WAPCOS CEIA. According to the Comprehensive river basin level WAPCOS CEIA, just two lift irrigation schemes exist below the project site lifting water from the river. (Chapter 4, section 4.4.2, page 4.37-4.38 of WAPCOS CEIA). More than 19 drinking water schemes have been implemented by the Athirappilly GP alone .A total extent of 976 ha of agricultural land is irrigated by the river waters in the Athirappilly grama panchayath alone. There are atleast 28 local bodies depending on the river for irrigation and agricultural and other needs. A comprehensive EIA as claimed by KSEB and MoEF should have included the impact of the project on the drinking and irrigation needs of these local bodies as well.
18. As a minimum official requirement, the EIA team has to contact the Vazhachal Forest Divisional Forest Officer (DFO) either before they start the data collection or during the study phase or atleast after the study since they are collecting data within the jurisdiction of the DFO. The Vazhachal DFO has clearly stated in reply to RTI (vide ltr No.C2-4818/90 dated 14-06-2006) that he was not aware of any study being carried out by WAPCOS within his jurisdiction, the agency has not taken any permission to carry out the study, no officials from the Forest Department have accompanied or assisted the study team and finally, the study team has not even shown the minimum courtesy to provide the DFO with the study report or relevant parts of the same. This throws doubts on whether any year round data collection on ecological aspects as claimed by WAPCOS and KSEB has taken place regarding the project impacts!!
19. The most important query raised at the 2002 High Court Ordered Public Hearing by the people was the impact of a seventh dam in the Chalakudy River on the downstream users and the Chalakudy River Diversion Scheme (CRDS).Six downstream local bodies namely, Puthenvelikkara, Methala, Meloor, Mala, Mookkannur grama panchayaths and Kodungallur municipality specifically submitted resolutions raising concerns on the same at the PH.. Meanwhile, the Executive Engineer, Edamalayar Irrigation Project who is in charge of the CRDS, has stated in a reply to RTI (vide Ltr .No. A3-1036/06 dated 07-06-06) that this office was not contacted by anybody including WAPCOS officially for any data collection on the proposed Athirappilly HEP, nor any discussions held. However, WAPCOS CEIA has categorically stated that, “Adequate water is available for the LBC and RBC systems of the Chalakudy River Diversion Scheme. Thus no conflicts with the downstream water users are anticipated” (Chapter 4, section 4.4.2, page 4.37-4.38 of WAPCOS CEIA). Statements like “Major rivers such as the Chalakudy are not tapped by individuals as considerable effort and money would be required for lifting water.” have been used in the CEIA which clearly bring out the reality that no proper downstream impact study has been carried out. There are hundreds of private lift Irrigation schemes along both the river banks in the river basin apart from the Minor Irrigation Department implemented and Grama Panchayath implemented ones that are the main source of drinking and irrigation water during summer.
20. A major Drinking water scheme at Vynthala in Kadukutty Grama Panchayath lifts water from the river to cater to the drinking water needs of six grama panchayaths including coastal panchayaths like Eriyad, Methala and Edavilangu. It may please be noted that unlike the KSEB and the MoEF, it is the Grama Panchayath elected representatives who have a grip over the ground realities in their administrative jurisdiction. They are the ones who are constantly facing the voters and the most important problem always highlighted by the people is drinking and irrigation water scarcity. The grama panchayaths have clearly brought out the present inadequacy of the CRDS project to meet their drinking and irrigation water requirements and the plight of the river in their resolutions submitted at the Public Hearings. Hence their apprehensions on the impacts that would be created by a seventh project are fully justified. The ‘Panchayath resolution’ being a powerful tool indicative of the sovereign rights and powers vested with the local self governments to safeguard and preserve their natural resources granted through the Panchayath Raj Act, have not been either given any consideration nor treated with due respect by the MoEF while arriving at a decision to grant Environmental Clearance to the project.
21. The Project was granted Environmental Clearance for a second time based on the WAPCOS EIA on 10th February, 2005 without any public hearing. KSEB did not comply with the EIA notification Amendment dated June 13, 2002, and did not make available the executive summary containing the salient features of the project both in English and local language along with the EIA to the affected panchayath. They did not advertise in two local newspapers widely circulated in the region around the project, one of them in the vernacular language of the locality concerned informing that the project has been accorded environmental clearance and they did not earmark a copy of the clearance letter to the concerned panchayath /local NGO, if any, from whom any suggestions/ representations have been received while processing the proposal either, violating the requirements in the Clearance Letter.
22. The Athirappilly Grama Panchayath and Geetha, the Kadar tribal representative from Vazhachal Kadar settlement, hence filed PILs in the Kerala High Court challenging the Environmental Clearance granted in 2005. The Hon. High Court quashed the Environmental Clearance granted in 2005 and ordered a fresh Public Hearing agreeing to the Violations in the EIA Notification 1994 and its Amendments. To quote the Judgment on 23rd March 2006,….”environmental clearance now given by the 1st respondent is liable to be quashed. We do so and hold that the Electricity Board is bound to apply for environmental clearance by the 1st respondent afresh after publishing the Environment Impact Assessment Report stated to have been got prepared by the KSEB, and conducting a public hearing after publication of the report. Such application shall be accompanied by the proceedings of the public hearing to be so held….”
23. In protest against the project a River Walk for four days followed by a Water Rights Convention attended by around 500 people was organised during 22nd to 26th November 2005. An indefinite Satyagraha was also launched from 23rd December 2005 onwards at Athirappilly by the Chalakudy River Protection Forum, a network of organisations and individuals from the entire river basin. The Satyagraha continued till 23rd March 2006 when the judgement of the PIL was delivered.
24. At the 15th June 2006 HC ordered Public Hearing, atleast 1200 people attended and rejected the proposed project from environmental, social, economic and technical angles. Even five local self governments in the river basin and one MLA (Mala Constituency) also submitted resolutions against the project. Moreover, the public pointed out that the issues and environmental impacts related to the project raised at the 2002 public hearing have not been addressed in the WAPCOS EIA.. Inspite of all this, the PH report prepared by KSEB and the Kerala State Pollution Control Board did not truly reflect the unanimous public opposition to the proposed project at the hearing. The project was recommended for Clearance. The panel met on July 8th at Alwaye and majority of the panel members did not agree to the proceedings of the EPH and a second meeting was decided. However, the second meeting did not take place and the panel members were forced to sign the proceedings individually. The unusual manner in which the minutes of the Public Hearing Panel got signed from the members without holding any meeting of the panel is itself self explanatory. The signatures are in 6 sheets; the Member Secretary and the District Collector have signed in all the sheets. Other panel members have put their signature in different sheets! Two of the panel members (Chalakudy Block Panchayath President and Athirappilly Grama Panchayath President) submitted an alternate report that reflected the actual happenings at the EPH and one member (senior citizen) presented a dissent note as well. The Panel Members are yet to receive a copy of the report! The petitioner could manage to obtain the panel report through Right to Information Act.
25. The 15th November 2006 Meeting of the Expert Committee on River Valley and Hydro Electric Projects recommended Environmental Clearance to the project subject to certain conditions. However, a memorandum submitted to the PMO and the fax and email submissions sent to the River Valley Committee by people in the river valley and all over the country, forced the Expert Committee to rethink its decision and five members of the expert committee decided to make a site visit during April second week at its February 2007 sitting.
26. The Expert Committee made the site visit during 12th and 13th of April 2007. During the field visit on the 12th, the Expert Committee visited the CRDS project area, Kannankuzhy area where the power house is proposed, the Athirappilly and Vazhachal waterfalls area, the Vazhachal tribal settlement, the dam site, the Pokalapara tribal settlement and the Poringalkuthu project area. There were people at all locations except the Poringal dam area to submit their grievances and opposition to the project. Atleast 250 people attended the Public Meeting on the 13th at Thrissur Town Hall organized by the KSEB and River Valley Committee at which most of the representatives reiterated their stance against the project. Inspite of the unified opposition to the project on economic, social and environmental grounds, the River Valley Expert Committee Site Visit Report has recommended Environmental Clearance to the project with not even a single word in the entire report mentioning anything about the possible environmental impacts! It is understood that the Expert Committee Sitting in June 2007 has recommended Environmental Clearance to this project for a third time based on the Site visit report, whose environmentally destructive nature, technical and economic unfeasibility has been pointed out by experts and people alike in several forums and has been ridden by consistent public opposition, constant environmental notification violations and manipulations.
27. Delegations from the river valley including tribals have met the Chief Minister and submitted representations. Several organisations across the state and the country (SANDRP, Kalpavriksh, Environment Support Group, Nature Conservation Foundation etc.) have joined hands with the movement against the dam. Conventions were held at Chalakudy, Kozhikode and Thiruvananthapuram in support of the struggle.
PART II :Biodiversity significance of the Project area and the surrounding forests
1. Since the Forest Clearance granted in 1999 to the proposed Athirappilly HEP, several study reports indicating the biodiversity richness of the project area and surroundings has been published. None of these study reports are found to be quoted in the WAPCOS EIA alleged to be carried out during 2002 casting doubts on the credibility of the EIA study. None of these aspects have been considered by the MoEF and the Expert Committee on River Valley Projects while deciding to grant Environmental Clearance to the project.
2. There is lot of published study reports on the exceptionally high fish diversity of Chalakudy river basin, unique to India. Of the 104 species of fish reported from it, 5 species new to Science have been discovered, ( Horabagrus nigricollaris, Travancorea elongata, Osteochelichthys longidorsalis, Puntius chalakkudiensis and Garra surendranathanii) 9 sp. are critically endangered, 22 sp. are endangered and 11 sp. are vulnerable as per the IUCN norms in a CAMP workshop held at NBFGR, Lucknow ,1997.. Even Periyar, the 244 km longest river in Kerala, only has 77 species recorded and its threatened status is lower than that in Chalakudy River. Endemic fishes in Chalakudy River are as high as 54.3%, the highest among all the rivers in Kerala and it is a declared ‘Mahseer Bank’. The river stretch lying within 75-500 m msl altitude range holds the maximum fish diversity in this river. Atleast 68 sp have been recorded from this stretch within which the project area falls.The National Bureau of Fish Genetic Resources (NBFGR) has recommended the declaration of the upstream areas of Chalakudy River as potential fish sanctuary taking into consideration the endemic and endangered fish populations inhabiting there..
3. In a paper presented by Kurup B.M. Radhakrishnan K.V. and Manojkumar T.G. titled “Biodiversity status of fishes inhabiting rivers of Kerala (S. india) with special reference to endemism, threats and conservation measures “ the authors have pointed out that Horabagris nigricollaris is a critically endangered species (CR) restricted to a single location in the upper reaches of Chalakudy river, out of six Critically endangered species restricted to a single river in Kerala, two namely Osteochelichthys longidorsalis,and Tor mussallah have been located at Vazhachal , out of the endangered species of fishes restricted to a single location inhabiting Kerala rivers, Travancorea elongata is restricted to Vazhachal . It may please be noted here that the out of the five species new to science discovered from the river, two are found at Vazhachal. Examination of fish diversity from various altitudes of six rivers in Kerala by the authors revealed that Chalakaudy river has the highest diversity index ranging from 1.76-3.9 followed by Kabani and the altitudinal range where the dam is proposed has a high index of 3.28.
4. Chalakudy River has been recognized as unique in India with respect to fish diversity, fish abundance, endemism, endangered status of fish sp, recommendation for fish sanctuary, Mahseer Bank to name a few. The WAPCOS study has not even mentioned any of these most significant aspects needed for the long-term conservation of fish sp. Just listing of 30 sp and quoting the list from Ajithkumar, C.K. 2001 (whose reference is not attached) does not justify the needs of a comprehensive EIA. Even the IUCN status of the fish sp is not indicated in the WAPCOS list. (Chapter 3, section 3.13.8, table 3.53 and 3.54 of WAPCOS EIA). The exceptionally rich fish diversity of the impact area is clearly evident from the above study reports. Ironically, the Expert Appraisal Committee for River Valley and Hydro Electric Projects meeting held on 18th October 2006 seems to be highly concerned about the protection of the five endangered species of fish in the Kunthi River where the Pathrakadavu HEP is planned. Meanwhile, the uniqueness of Chalakudy river system in terms of the extremely rich fish diversity and the project area in particular are completely ignored by the WAPCOS CEIA, the Site Visit Committee and the Expert Committee which granted Environmental Clearance to the project based on the allegedly carried out WAPCOS CEIA.
5. The WAPCOS CEIA alleged to be carried out during 2002 has failed to convey that the proposed project area is a part of the Anamalai Elephant Reserve No.9 under the Project Elephant of the GOI. Among the 11 Elephant Reserves notified in India, four are in South India and amongst these Elephant Range 9 is known for its genetically more diverse and distinct elephant population and rich biodiversity. The Elephant Population density estimation in the Range has revealed that Malayattoor Forest Division has the maximum density 0f 2.1 / sq.km followed by Vazhachal (2.0) and Anamalais (1.9). The record of human - elephant conflicts in 2005 in the Range revealed that out of the 19 Divisions, four divisions have recorded elephant damage caused in the form of crop/ property loss and human casualties out of which in Vazhachal Division, Rs.1, 05, 00 has been paid towards crop/ property damage and Rs.60, 000 towards human casualties. Dr. Bhaskaran, Scientist, Centre for Ecological Studies , Bangalore has pointed out that elephant habitat in Vazhachal Division is exceptionally high and the habitat in the entire range has been fragmented into many patches and contiguity has been lost in some locations. Human elephant conflict is higher in areas with human activities. Thus further developmental activities in this area would affect survival of this umbrella species and biodiversity of the landscape. The construction of the new dam project would mean heavy movement of workers and vehicles in the elephant movement path along the Anamalai Inter State Highway creating conducive situations for increased Human Elephant conflict and related casualties.
6. The 16th May 2007 River Valley Committee has cited that world renowned scientist Dr. R.Sukumar and Dr.P.Kannan deputed by the MoEF have opined that the proposed project shall not cause any problem to movement of elephants while justifying the Clearance granted. It may please be noted that in the same letter Dr. P.Kannan has also opined in section i of the letter that “It could however be a severe alteration of the riparian forest (into a reservoir) which may affect the fish and other aquatic fauna”. Similarly in section ii, “We need expert assessment and possible impact of this ecological change on biodiversity of the area other than elephants” Dr. Sukumar in his report has also pointed out that the proposed dam site is located at the first elephant crossing point conceding the presence of elephant movement. He also warns that ‘elephants may however take several years before they accept the new situation and traverse the reservoir…..” The significance of the project area for elephant movement is clearly evident from the above facts. It may also be please noted that an elephant habitat cannot be preserved in fragments since these largest mammals on earth need vast contiguous areas for foraging and feeding and the existing biodiversity of Vazhachal Forest Division is very important for elephants.
7. Further, the Asian Nature Conservation Foundation led by the same Dr. Sukumar in its Asian Elephant Research and Conservation Centre project has recommended the upgradation of the status of Vazhachal Division to a Wildlife Sanctuary or National Park as it has very good elephant habitat. The AERCC have reported a population of 947 Asian Elephants (census 1993) in this area (http://www.asiannature.org/vazha.html.
8. The project area is a rich habitat of birds. Atleast 185 avian species have been identified in the project area alone in two separate studies along with their threat status. In the 2007 bird survey carried out by the Kerala Forest Department, atleast 70 species were spotted in just half an hour, indicative of the diversity and richness of the area (http://www.thehindu.com/2007/01/20/stories Meanwhile the alleged one year study carried out by WAPCOS could identify just 98 species of birds belonging to 31 families. Vazhachal Division is also a declared Important Bird Area (IBA), (IN 253) with A1 (Red Data Book sps.), A2 (Restricted Range sps.), A3 (Biome Restricted Assemblages), birds being found here.Several bird surveys in Kerala reveal that probably the only available nesting site of the Malabar Pied Hornbill in Kerala is found in the low altitude riparian forests of Vazhachal area. Even the nests of the Great Pied Hornbill have been found in this area at an altitude of 180 m near Vazhachal. Since 2003, a joint effort by the Vazhachal Forest Division, the River Research Centre and Kadar tribals to survey and protect the nesting and breeding sites of hornbills has been going on indicating the importance of the area for hornbills. A combined list of the bird species found in Athirappilly- Vazhachal region found as high as 264 bird species in the impact area of the project. A survey report on the birds of Vazhachal – Athirappilly area published by Waders and Warblers in 2001 could locate 134 birds specifically in the project impact area.
9. Exceptionally high fish diversity, high bird diversity and rich elephant habitat concentrated in the project area and its impact zone are indicative of the unique and rich biodiversity significance of the area for the Vazhachal Forest Division as a whole. Hence if the Vazhachal Forest Division is considered as the most important in terms of biodiversity potential with a very high conservation value of around 75 % (floristic species richness, floristic endemic zone, unique eco systems, faunal endemic zone and mammal density together gives a composite picture of conservation value) only second to Mankulam Forest Division in Kerala among the 23 non protected areas in the state, (Biodiversity Conservation Strategy and Action Plan for Kerala prepared by French Institute of Pondicherry for the Kerala Forest and WLD, 2000) it is also due to the essential link provided by the rich biodiversity potential of the submergible and impact area of the proposed Ahtirappilly project though small. The extent of submergence rather than the area of submergence are significant for the forests of Western Ghats unlike in other parts of peninsular India. The Expert Committee on river valley projects has diluted the significance of the project area for the conservation of the entire region justifying the grant of Environmental Clearance to the project.
