Miyar Hydroelectric Project
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Host party(ies) India
Methodology(ies) ACM0002 ver. 12
Standardised Baselines N/A
Estimated annual reductions* 412,176
Start date of first crediting period. 01 May 18
Length of first crediting period. 7 years
DOE/AE Bureau Veritas India Pvt. Ltd.
Period for comments 01 May 12 - 30 May 12
PP(s) for which DOE have a contractual obligation Miyar Hydro Electric Power Company Limited
The operational/applicant entity working on this project has decided to make the Project Design Document (PDD) publicly available directly on the UNFCCC CDM website.
PDD PDD (665 KB)
Local stakeholder consultation report: N/A
Impact assessment summary: N/A
Submission of comments to the DOE/AE Compilation of submitted inputs:
Comment (320 KB) submitted by: sandrp on behalf of Samantha Agarwal, SANDRP

Objections: CDM to 120MW Miyar HEP, Himachal pradesh, India

1. Social Well being ((Page-2 of PDD document): 

The project is coming up in
Lahaul and Spiti district of Himachal Pradesh which is inhabited mostly by
tribal people and sparsely populated . The claim of the project proponent
that the project will lead to employment generation intensively during
construction phase is highly objectionable.
It is quiet evident from all the hydro projects being constructed in
Himachal that during construction phase most of the labour force
comes from outside and not from the loca area. These projects not
only destroy the locl economy but also social and cultural fabric of
the area. In case of Lahaul Spiti the impacts are going to be more
severe as the poulation density is less than 2 persons per square kms
and this kind of projects will destroy the unique culture and
tradition of the local populace.
Lahaul and Spiti district has the highest irrigation intensity for
the area under cultivation in the State. This means that the entire
area under cultivation is irrigated, without which no agriculture
would be possible in such harsh dry cold desert climatic conditions.
The village settlements are supported by the community owned and run
kuhls (irrigation channels). The area is known for cultivation of
high quality Potatoes, Hops, Kuth (Saussurea costus) and and off
season vegetable cultivation. Due to this small fertile agriculture
fields along the stream will submerge and the sources of irrigation
for the fields in higher altitudes will dry up due to the the under
ground construction activites of the project which will hamper
agriculture badly.
The district has the highest per capita income of all the districts
of Himachal and all tribal districts have seperate allocation from
the total budget of the district and many a times due to limited
working season (6 months) the allocated budget has remained unspent.
This indicates that there is no lack of resources in the area
There is strong local opposition against the forcible acquisition of
the private land (page 38) for the project Please see the following
news coverage to know the ground reality:
http://hillpost.in/2012/05/12/tribals-in-lahaul-up-against-moser-baer-hydropower-project-over-land-acquistion/45039/people/dutta

2. Economic Well Being (Page-3 of PDD document):

Lahaul remains cut off from other parts of the state for six months
and now with construction of the Rohtang tunnel, the area will remain
connected with other parts for the whole year creating a huge
potential to promote tourism as a major economic activity. But with
the construction of Miyar like 20 hydro eletric projects on Chenab
basin, the whole Chenab river and the ecology of river will be
destroyed. Miyar HEP is the first project and will open the floodgate
for other HEPs in this valley. Miyar will have more negative impacts
on local economy than benefits.
The claim of project proponent that the electricity generated will go
to small scale industries is objectionable as most of the electricity
is going to big cities and urban centres like Delhi, Chandigarh etc
and not for electrification of poor households nor to small scale
industries.
Almost all the households in Himachal are electrified and Himachal is
supplying surplus electricity to other state in summer season. For
this all 3 other major rivers (Satluj, Ravi and Vyas) are flowing in
tunnels and local population is paying huge environment and eonomic
cost. Now Chenab is the only river left in Himachal which is flowing
in its natural course.

3. Environmental well being (Page-3 of PDD document):

As already mentioned the project is coming up ecology sensitive and
fragile area and according to a study conducted by Indian
Meteorological Department and Central Water Commission the Permanent
Snow Line has changed from 4500m to 4600m. Due to this the rainfed
area has increased over snow bound area. Due to same reason the
capacity of projects like Miyar and Seli coming up in Chenab has
increase the HEPs capacity from 90 MW to 120 MW and from 320 MW to
400 MW. With introduction of these projects huge reservoir areas will
be created in cold desert region (leading to more green house gas
emissions) and will accelerate the process of climate change.
Artificial Regeneration of the species found in the area is extremely
difficult. There are no nursery techniques for species like Juniperus
recurva

and in cold desert area the most forests occurred along the banks of stream
and are natural. Drying up of Miyar stream due to diversion of stream for
electricity generation will cause immense damage to the natural forests of
the area.

4. Prior CDM Consideration

It will be wrong to register the project under CDM at this point. As
the project is in the process of obtaining necessary permission in
the form of final environment clerance and forest clerance from the
Ministry of Environment and Forest (MoEF). If the project proponents
fail to receive any of the clearances then the project may be delayed
indefinately.

5. Value at which each Sensitivity Scenario Hits the Nom

initiated Benchmark

(Page 16 and 17 of PDD)

The initial capacity of the project was 90 MW (during bidding process
and as approved by Himachal cabinet). During preparation of DPR the
capacity of the project was increased to 120 MW. It means the project
was feasible during bidding when it was 90 MW which took place in
2008 and after that the project capacity has increased by 33% which
means the project is financialy viabile and doesn't need any CDM
support.

An important factor which project proponet has not included in PDD is
the construction of one more project i.e. Seli 400 HEP in Chenab
basin in vicinity of Miyar project, which will be constructed along
the Miyar HEP. In this process the project proponent are going to
share many costs which ultimately will reduce the civil construction
cost drastically.

Further, Rohtang tunnel is under construction and scheduled to be
completed by 2015 which will make the area accessible for the whole
year and will reduce the project cost.
Submitted by: Prakash Bhandari


The comment period is over.
* Emission reductions in metric tonnes of CO2 equivalent per annum that are based on the estimates provided by the project participants in unvalidated PDDs