·     River Narmada has been converted into a seasonal river and the downstream stretch of the River is being killed. The River now suffers polluted seawater ingress, untreated sewerage, as well as solid waste pollution. Narmada River’s water at Bharuch has TDS 19,928 mg/l and Dissolved Oxygen less than 5 mg/l as opposed to acceptable standards of 300-500 mg/l and more than 5 mg/l, respectively.

·     Our investigation regarding the quality of water flowing in Narmada River downstream of Sardar Sarovar Dam, dated 6 April 2019 between 11.00 a.m. to 4.00 p.m. reiterates what is commonly known now, that ‘Sardar Sarovar Project’ (SSP) was planned without considering its impacts on the 161 kilometres long downstream stretch of the Narmada River system, its ecology, biodiversity, fishery, and lakhs of people living close to and dependent on the River directly or indirectly.

·      Notice dated 12 April 2019 was sent to Narmada Control Authority, The Environment Subgroup of Narmada Control Authority, Executive Member and Member (E&R) of Narmada Control Authority, Sardar Sarovar Narmada Nigam Ltd, The Chief Secretary of Gujarat State, The Chairman and Member Secretary of Central Pollution Control Board, The Chairman and Member Secretary of Gujarat Pollution Control Board, etc. by ParyavaranSuraksha Samiti.

COD (Chemical Oxygen Demand), DO (Dissolved Oxygen), TDS (Total Dissolved Solids)

Investigation Dated 6 April 2019

Sr. NoPARAMETERTDSmg/lDOmg/lCODmg/lChloridemg/l
 River Norms500 mg/l> = 5 mg/lNilNil
1Nand VillageLat:  21°51’27.87″NLong:  73° 8’2.93″E6476.7440Not Done
2GWSSB Intake WellLat: 21°51’8.09″NLong:  73° 7’47.57″E8007.87100Not Tested
3Dharamshala VillageLat:  21°48’37.98″NLong:  73° 8’14.86″E24916.74152Not Tested
4Nikora Village, 100 meters from River Bank, Ground WaterLat:  21°46’53.92″NLong:  73° 8’4.48″E1610Not TestedNot TestedNot Tested
5Shuklatirth Village Lat:  21°46’2.37″NLong:  73° 8’17.04″E50474.94116Not Tested
6Bharuch Lat:  21°40’37.67″NLong:  72°58’36.53″E199284.93569996
7Kukarwada VillageLat:  21°40’32.90″NLong:  72°56’4.54″E215064.94599996
8Bhadbhut VillageLat:  21°40’41.37″NLong:  72°50’48.41″E255644.498313995

12 April 2019

To:

1.         The Chairperson

           Narmada Control Authority

           Secretary, Ministry of Water Resources River Development & Ganga Rejuvenation, Government of India,

           Shramshakti Bhawan, Rafi Marg,

           New Delhi 110 001

2.         The Chairperson

The Environment Subgroup of Narmada Control Authority

          Secretary, Ministry of Environment, Forests and Climate Change

          Government of India

          Indira Paryavaran Bhavan, Jor Bagh Road, New Delhi – 110 003

3.         Dr. (Mrs.) Susane George Karumanchery

           The Nodal Officer (CETP/STP/ETP)

           Ministry of Environment, Forests and Climate Change

           Government of India

           Indira Paryavaran Bhavan, Jor Bagh Road, New Delhi – 110 003

4.         Executive Member and Member (E&R)

Narmada Control Authority,

Narmada Sadan, Sector B, Scheme No 74,

Vijay Nagar, Indore 452 010, Madhya Pradesh

5.         The Chairman

           Central Pollution Control Board

           Parivesh Bhawan, CBD-cum-Office Complex,

           East Arjun Nagar, DELHI – 110 032

6.         The Member Secretary

           Central Pollution Control Board

           Parivesh Bhawan, CBD-cum-Office Complex,

           East Arjun Nagar, DELHI – 110 032

7.        Mr. Ajay Aggarwal

           The Additional Director & The Nodal Officer (CETP/STP/ETP)

           Central Pollution Control Board

           Parivesh Bhawan, CBD-cum-Office Complex,

           East Arjun Nagar, DELHI – 110 032

8.         The Chief Secretary

           Government of Gujarat

           1st Block, 3rd Floor, Sachivalaya, Gandhinagar – 382 010

9.         The Principal Secretary (Narmada)

           Narmada, Water Resources, Water Supply & Kalpsar Department

           9th Block, 2nd Floor, Sachivalaya, Gandhinagar – 382 010

10.     The Chairman & Managing Director

           Sardar Sarovar Narmada Nigam Ltd.

           Block No. 12, 1st Floor, New Sachivalaya Complex

           Gandhinagar – 382 010

11.     The Additional Chief Secretary

           Forest and Environment Department

           14th Block, 8th Floor, Sachivalaya, Gandhinagar – 382 010

12.     The Chairman

           Gujarat Pollution Control Board

           Paryavaran Bhavan, Sector-10 A, Gandhinagar-382 010

13.     The Member Secretary

           Gujarat Pollution Control Board

           Paryavaran Bhavan, Sector-10 A, Gandhinagar-382 010

14.     The Zonal Officer

           Central Pollution Control Board

           Parivesh Bhawan, Opp. VMC Ward Office No. 10, Subhanpura,

           Vadodara – 390 023

Subject:                   

1.    Perennial River Narmada has been converted into the Seasonal River and Downstream River Narmada being killed and she now suffers polluted seawater ingress and untreated sewerage as well as solid waste pollution.

2.    Implementation of the Supreme Court Order, dated 22.02.2017, in Writ Petition (Civil) No. 375 of 2012 (Paryavaran Suraksha Samiti & Anrs V/s Union of India & Ors) and National Green Tribunal, Principal Bench, Delhi, Order, dated 03.08.2018 and 19.02.2019, in Original Application No. 593 of 2017, (Paryavaran Suraksha Samiti & Anrs V/s Union of India & Ors) in letter and spirit.

Reference: The investigation dated 6 April 2019 between 11.00 a.m. to 4.00 p.m. between Village Nand, latitudes Lat:  21°51’27.87″N, Long: 73° 8’2.93″E to Village Bhadbhut, Lat:  21°40’41.37″N, Long: 72°50’48.41″E.

Sirs/Madams:

Our investigation regarding quality of water flowing in Narmada River downstream of Sardar Sarovar Dam, dated 6 April 2019 between 11.00 a.m. to 4.00 p.m. reiterates, what is commonly known now, that ‘Sardar Sarovar Project’ (SSP) is planned without considering its impact on the downstream Narmada River stretch of 161 Kilometre, its ecology, biodiversity and fishery, and lakhs of people living close to and dependent on the river directly or indirectly. This, in turn, has led to its present disastrous state. It has affected the fisheries in the immediate surrounding areas, livelihoods of fisher folk in its downstream, as well as affected the downstream river, its biodiversity, and other related aspects.

As if this was not enough, the Garudeshwar Weir (GW) is planned and under construction without any impact assessments, public consultations, appraisals and clearances including from NCA or NCA-ESG. The Statue of Unity Project is built in the middle of the river without any impact assessments, public consultations, appraisals or clearances and now huge tourism related projects unfold around this statue. The combination of SSP, GW, SoU Project and the Tourism Project have created a situation where apparently Narmada River is now ending at Village Garudeshwar instead of at the Arabian Sea further down, 161 Kilometres away.

River Narmada flows 1077 Kilometres stretch in Madhya Pradesh, the next 35 Kilometres stretch of the river forms the boundary between the States of Madhya Pradesh and Maharashtra, the next 39 Kilometres forms the boundary between Maharashtra and Gujarat, and the last stretch of 161 Kilometres in Gujarat. It is important to note that we are talking about Narmada River, a Perennial River, now in its worst condition across its Gujarat stretch and does not have fresh water in downstream and is reduced to carrying sewage, industrial wastewater and sea ingress. There are industrial effluent discharged from Ankleshwar, Jhagadia, Panoli, and Dahej industrial cluster near Narmada River into the sea. This cluster are known for non-compliance of prescribed standard for effluent discharges.

The 161 Kilometres downstream River now is prone to only these realities; that of either floods and flash floods, a dry river bed stretch, release of mostly untreated and some semi treated sewage and industrial effluents, solid waste, and/or sea ingress with untreated sewage and industrial effluents. The Narmada, a perennial river, now stands converted into a dry river in the Gujarat Stretch of 161 Kilometres. In fact, the SSP and Garudeshwar Weir are controlling the flow of water and silt downstream. The concerned authorities assumed, without any credible study, that 600 cusecs (Cubic Feet per Second) water release would be enough for the downstream river. NCA, NCA-ESG, MoEF&CC and MoWR strangely agreed to this assumption and allowed water release, that too from Godbole Gate and NOT the dam, as it should be. Moreover, the authorities agreed that this quantum would not be from Gujarat’s share for Narmada Waters, contrary to what the NWDT had clearly stipulated. Which means Gujarat Government, today is releasing NO WATER for the downstream river and goes through the motions of writing letters to MoEF&CC asking for more water, rather deciding to release water from its own share, as it should have been. There is also not credible and transparent mechanism to show, if at all, Gujarat Government is releasing the claimed 600 cusecs of water from Godbole Gate. Thus, now, the Government of Gujarat writes to the Narmada Control Authority that it should increase the release to 1500 cusecs to ensure survival of the downstream river. In fact, both 600 cusecs and 1500 cusecs figures are ad-hoc figures, without doing any scientific or technical studies.

We demand that an expert committee is formed to assess the sustainable ecological flow required in the river for different seasons, thus ensuring that it does not dry up in the downstream stretch up to the Gulf of Khambhat.

Present reality indicates over exploitation and destruction of downstream Narmada River and her Ecology, Ecological-Flow, Tribals, Downstream Villagers, Livelihood, Social and Environment Justice, Democracy, Natural and Cultural Resources, Valuable Human Resources, and the Wildlife Sanctuary.

The downstream impacts of the SSP, GW, SoU Project and Tourism Projects would include not only destruction of downstream fisheries, one of the most important ones in Gujarat on which thousands of people are dependent, but will also result in sea water ingress. These projects now have grave adverse impacts on the Narmada Estuary and unless all the possible impacts are properly studied and if the State fails to have mitigation plans; we stare at a grim situation of a dying Narmada that we killed with our apathy and greed. The rich scenarios for fisheries downstream of the dam, including the famed Hilsa, stands destroyed. The salinity ingress threatens the water supply and irrigation use of over 210 villages and towns and Bharuch city. All these have not only had serious economic and other impacts but also had also directly destroyed the livelihoods of at least 10,000 fishing families.

The Government of Gujarat has repeatedly claimed that number of studies have been carried out for downstream of the Sardar Sarovar Dam. The present reality on ground clearly indicates the Environmental Sub-group of Narmada Control Authority (NCA) has accepted various studies and progress report at the face value and without any serious scrutiny and verification.

Nobody can dispute that the alteration of a river’s flow and sediment transport downstream of a Sardar Sarovar Dam often cause the gravest and sustained environmental impacts. Life in and around a river evolves and is conditioned on the timing and quantities of river flow, which includes water flow, silt flow, nutrient flow, biodiversity connectivity, longitudinally and laterally.

Our present investigation reveals that the Government of Gujarat and the Ministry of Environment, Forests and Climate Change have grossly abdicated their responsibilities. The repeated abdication of their responsibilities by the Government of Gujarat, Narmada, Water Resources, Water Supply & Kalpsar Department, Sardar Sarovar Narmada Nigam Ltd., Environment Sub-group of Narmada Control Authority, and the Ministry of Environment, Forests and Climate Change clearly indicates that they were not taking the whole issue with the seriousness it deserves and demands.

We, on 6 April 2019 carried out an investigation of Narmada waters within downstream of the Sardar Sarovar Dam. The investigation area is between Village Nand, latitudes Lat:  21°51’27.87″N, Long:  73° 8’2.93″E to Village Bhadbhut, Lat:  21°40’41.37″N, Long:  72°50’48.41″E. The following table indicates the water quality findings – which are grim, denoting criminal apathy and requiring immediate punitive and remedial actions.

COD (Chemical Oxygen Demand), DO (Dissolved Oxygen), TDS (Total Dissolved Solids)

Investigation Dated 6 April 2019

Sr. NoPARAMETERTDSmg/lDOmg/lCODmg/lChloridemg/l
 River Norms500 mg/l> = 5 mg/lNilNil
1Nand VillageLat:  21°51’27.87″NLong:  73° 8’2.93″E6476.7440Not Done
2GWSSB Intake WellLat: 21°51’8.09″NLong:  73° 7’47.57″E8007.87100Not Tested
3Dharamshala VillageLat:  21°48’37.98″NLong:  73° 8’14.86″E24916.74152Not Tested
4Nikora Village, 100 meters from River Bank, Ground WaterLat:  21°46’53.92″NLong:  73° 8’4.48″E1610Not TestedNot TestedNot Tested
5Shuklatirth Village Lat:  21°46’2.37″NLong:  73° 8’17.04″E50474.94116Not Tested
6Bharuch Lat:  21°40’37.67″NLong:  72°58’36.53″E199284.93569996
7Kukarwada VillageLat:  21°40’32.90″NLong:  72°56’4.54″E215064.94599996
8Bhadbhut VillageLat:  21°40’41.37″NLong:  72°50’48.41″E255644.498313995

The above table, clearly indicates TDS 647 – 5,000 – 20,000 – 25,500 mg/l, COD 40 – 100 – 150 mg/l and DO of 4.49 to 7 mg/l of the Narmada River. Narmada River in this stretch is in a seriously grim condition and all the concerned authorities are to be blamed for this state of abject neglect.

The groundwater sample at 110 feet below the ground surface was measured. It has TDS of 1610 mg/l. This sample was taken near Nikora Village, just 100 meters from the Narmada River bank. This indicates sea ingress in the Narmada that does not have any fresh water in the River. This condition now adversely impacts the groundwater of the wells and bore wells of the surrounding downstream areas of the Narmada River.

The Narmada River now stands:

1.    Instead of a Perennial River, converted into Seasonal River.

2.    Dry and carries seawater with some industrial pollutants and untreated sewerage.

3.    With High COD, TDS, Chloride and low DO.

4.    Deteriorated quality of groundwater.

At outset, we would like to make it very clear that Bhadbhut Barrage Project, proposed to stop salinity ingress, will add further problems and destroy the entire estuary and livelihoods of even more people. The ostensible objective of achieving navigation is also unlikely to be achieved with so little flow from the SSP. 

The Narmada Control Authority (NCA) has been setup under the final orders and decision of the Narmada Water Disputes Tribunal (NWDT) as a machinery for implementation of its directions and decision. The authority started functioning from 20th December 1980. The authority is a body corporate with representatives of the four States of Madhya Pradesh, Gujarat, Maharashtra, Rajasthan and representatives of Government of India. The authority is funded in equal proportions by all the four states. Secretary (Water Resources), Government of India is the ex-officio Chairman of the Authority. The routine administration is the responsibility of Executive Member of the Authority. The Narmada Control Authority, with its headquarter in Indore, Madhya Pradesh, presently has six subgroups. Environment Subgroups under the Chairmanship of Secretary, MOEF&CC, include:

  1. Resettlement and Rehabilitation Subgroup under the Chairmanship of Secretary, Ministry of Social Justice and Empowerment, Government of India.
  2. Resettlement Committee for SSP under the Chairmanship of Secretary, Ministry of Social Justice and Empowerment, Government of India.
  3. Hydromet Subgroup under the Chairmanship of Executive Member, NCA.
  4. Narmada Main Canal Committee under the Chairmanship of Executive Member, NCA.
  5. Power Sub-Committee under the Chairmanship of Member (Power), NCA.
  6. Sardar Sarovar Reservoir Regulation Committee under the Chairmanship of Executive Member, NCA.

Functions of Environment Subgroup under the Chairmanship of Secretary, MOEF are:

a)    To work out the environmental safeguard measures to be planned and implemented for the entire Narmada Basin so that environmental safeguard measures are executed and remain fully in consonance with the clearance accorded to the Narmada Sagar and Sardar Sarovar Projects.

b)   To determine the terms of reference of required surveys and studies necessary for implementation of environmental safeguard measures inclusing the data base required, the methods by which the data base is to be prepared, as well as to identify the institutions/individuals to undertake the preparation of such documents.

c)    To prepare – for clearance by the Ministries and NCA – the action plans with regard to all environmental safeguard measures and the assessment criteria thereof.

d)   To devise a suitable monitoring and evaluation mechanism so that the action plans are effectively implemented in consonance with stipulations at the time of clearance of the projects.

e)    To assess the necessary organisation with management capability being set up for adequate implementation and monitoring of environmental safeguard measures.

f)     To undertake all measures necessary to assist Narmada Control Authority in the planning, and implementation, and periodic evaluation of the environmental safeguard measures.

The reality reveals that all these sub-groups, including NCA-ESG have failed to carry out their mandated duties with diligence and are functional merely on paper.

We demand:

(1)         All the concerned authorities immediately release 4000 cusec water from the SSP in the downstream Narmada River till final independent, credible studies are conducted for Ecological Flows in the downstream of the Narmada River. This water may be counted from Gujarat’s share of Narmada Water. We believe that this is the minimum quantity of water that the river needs to continue to perform all the tasks, social functions and ecosystem services that the river needs to perform.

(2)         Immediately stop discharge of untreated sewage and industrial effluents into the Narmada River.

(3)         All the concerned authorities appoint a high level and empowered committee of the MoEF&CC, CPCB, GPCB, local state authority, representatives of affected villagers and the representatives of the voluntary organisations working in this area on environment, and independent expertise for ecological restoration and rejuvenation of Narmada River.

(4)         Appoint a high level and empowered committee of the MoEF&CC, CPCB, GPCB, local state authority, representatives of affected villagers and the representatives of the voluntary organisations working in this area on environment, and independent expertise for day to day monitoring and evaluation of the quality of the 161 Kilometers downstream stretch of the river and the groundwater of surrounding areas.

(5)         Ensure Ad-hoc Exemplary Monetary Compensation to the farmers, villagers, and fishing folks who are suffering from the degradation of downstream river quality.

(6)         Appoint a competent and empowered committee to assess the ongoing and past damages to quantify the real compensation payable to the farmers, villagers, and fisher folks for the damages done.

(7)         Implement the Order, dated 22.02.2017, of the Supreme Court in Writ Petition (Civil) No. 375 of 2012 (Paryavaran Suraksha Samiti & Anrs V/s Union of India & Ors) and National Green Tribunal, Principal Bench, Delhi Order, dated 03.08.2018, in Original Application No. 593 of 2017, (Paryavaran Suraksha Samiti & Anrs V/s Union of India & Ors) in letter and spirit.

(8)         Direct Government of Gujarat to ensure that work on Garudeshwar Weir, Bhadbhut Weir and Tourism Projects related to SoU be stopped immediately till a credible independent assessment of all the impacts is done, to be followed by public consultations and appraisals. The study should include the assessment of carrying capacity and limits of acceptable change of the downstream river.

We expect and look forward to your prompt and positive response in the interest of life, livelihoods, and environment in the affected areas of Narmada River and lakhs of people dependent upon the many services she provides. If no timely and required actions taken all the concerned authorities, we may be left with no other options except take further action, including legal action.