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Under the National Water Mission, the Government of Karnataka conducted a consultation workshop on 24 March 2026 on “Climate Change Adaptation and Mitigation Strategies for the Water Sector in Karnataka.” Mapping Malnad attended the session and, along with SAPACC, subsequently submitted three separate written responses to the presentation, all of which are attached on this page.
The first is a broader policy submission examining issues such as Cauvery streamflow projections, non-revenue water (NRW) reduction, tank-filling schemes, ethanol-driven sugarcane expansion, pollution prevention, Yettinahole, KC Valley, and the proposed Mekedatu project.
The second submission focuses specifically on wastewater reuse, the circular water economy, pollution risks, and public-health implications.
The third examines the financial and economic architecture of Karnataka’s proposed climate-resilient water strategy, including operational financing, ecological economics, regulation, and long-term governance under climate stress.
The general submission also appears in full as text on this page.
Scroll down for submission links
Under the framework of the National Water Mission (NWM), Ministry of Jal Shakti, the State Specific Action Plan on Climate Change (SSAPCC) for the water sector has been developed in three stages: (i) assessment of water availability and usage, (ii) assessment of climate change impacts on the water sector, and (iii) formulation of adaptation and mitigation strategies.
At present, Stage 1 has been approved, Stage 2 is pending approval, and Stage 3 is in the draft final stage. As part of the Stage 3 process, the Advanced Centre for Integrated Water Resources Management (ACIWRM), Government of Karnataka, conducted a consultation workshop with selected individuals and organisations on 24.03.2026 at Open Hotel by Olive, Shivajinagar, where a presentation was made. Following the workshop, participants were invited to submit written comments and suggestions based on the presentation.
The Submission Contains the Following Sections
- Climate Adaptation Planning Must Be Participatory and Decentralised
- Reconsider Cauvery Streamflow Projections and Adopt the Best Available Science with Periodic Review
- Misplaced Priorities: NRW Reduction vs Mekedatu Reservoir
- Tank-Filling Schemes Are Hydrological Maladaptation, Not Climate Adaptation
- KC Valley & HN Valley Projects are not climate adaptation in the current form
- V-Wires Cannot Solve an Ethanol-Driven Groundwater Crisis
- Mekedatu Dam/Power Project Is Not Climate Adaptation
- Climate Resilience Requires Pollution Prevention
- Yettinahole Is Not Climate Adaptation, but a Textbook Case of Hydrological Maladaptation
- Commercialising Public Water in an Age of Climate Crisis is Maladaptation
- Conclusion
One of the fundamental concerns with the present process is that it cannot meaningfully be described as participatory climate adaptation planning. The consultation workshop conducted by ACIWRM involved only a limited set of selected individuals and institutions, which is inadequate for a plan that will shape water governance across Karnataka.
Climate adaptation in the water sector cannot be designed solely through top-down technical consultations that too by a private consultant (Grant Thornton Bharat LLP) in Bengaluru. As demonstrated by Porto Alegre’s globally recognized participatory budgeting model, meaningful citizen engagement leads to more effective and equitable governance, versus a single workshop conducted by a private consultant in Bengaluru.
Water stress, drought, groundwater depletion, pollution, floods, and drinking water insecurity vary significantly across districts, taluks, and river basins of Karnataka. At a minimum, consultations should be conducted district-wise and taluk-wise under Deputy Commissioners, involving citizens, farmers, industries, gram panchayats, urban local bodies, district health officials, pollution control authorities, water resource officials, researchers, environmental groups, and elected representatives including MLAs and MPs
Without such broad-based participation grounded in local hydrological realities and lived experience, climate adaptation risks becoming a top-down technocratic exercise disconnected from the people and ecosystems it is meant to protect.
As presented in the SSAPCC workshop, the Cauvery Basin is projected to show a streamflow increase of 12% (2021–2040, RCP 4.5) and 18% (2041–2060, RCP 8.5). We find that these figures originate from the 2021 report Karnataka State Action Plan on Climate Change prepared by EMPRI, based on VIC model simulations for the Upper Cauvery driven by CORDEX climate projections.
However, a more recent peer-reviewed study by IIT Gandhinagar, “Observation-Constrained Projections Reveal Robust Streamflow Increases in Indian Rivers” (21 March 2026), uses an observation-constrained VIC–CMIP6 framework and presents a contrasting assessment for the Cauvery. For the Cauvery at Kollegal, the study indicates a near-term decline of approximately 3.5% in mean annual flows (2026–2050), followed by only marginal increases thereafter.
Most importantly, the study finds that the Cauvery at Kollegal has already experienced a statistically significant 28% decline in annual flows since the 1950s, indicating that the basin is entering the future from an already depleted baseline.
We suggest that the Government consider the data from the IIT Gandhinagar study as it uses the latest CMIP6 climate models that underpins the IPCC AR6 assessments. Reliable data is where all decision‑making must start, and at present this study represents the most up‑to‑date and robust assessment of future streamflow in the Cauvery.
It is also important to note that the study isolates the climate signal by excluding future changes in land use, groundwater abstraction, and water management. As a result, these projections are likely to underestimate, rather than overestimate, real-world water stress in the basin.
Taken together, the evidence supports treating the Cauvery as a water‑stressed basin under current and future conditions, and this must be immediately reflected in the State’s climate planning. Failing to do so risks mischaracterising the Cauvery as a basin with increasing streamflow in State’s climate planning, when the best available science shows it to be a stressed and already depleted system.
Additionally, even the IPCC AR6 assessments rely substantially on datasets extending only up to around 2020. Given the wide uncertainties associated with climate models, together with the rapidly worsening climate situation observed globally, it is essential that climate planning rely on the most up-to-date observational and scientific data available.
Accordingly, the State Action Plan should not be treated as a static document, but should mandate periodic—preferably annual—scientific review and updating of hydrological, climate, groundwater, and water-demand assessments. This becomes even more important in the context of emerging extreme climatic events, including the formation of major El Niño conditions, which could further intensify droughts, water stress, and hydrological variability across Karnataka.
The draft SSAPCC presentation merely mentions “reducing non-revenue water (NRW)” as one among several adaptation measures, without quantification, targets, or prioritisation. In contrast, the presentation projects the Mekedatu Balancing Reservoir as a climate adaptation strategy and devotes an entire slide to it, thereby placing greater emphasis on new supply-side dam infrastructure on the already stressed Cauvery than on reducing losses within existing urban water systems. Every unit of water saved through NRW reduction is effectively a new supply—without the ecological and financial burden of building a dam.
While Bengaluru’s Cauvery NRW has reportedly improved from 48% (2017) to 30% (2024), even the lower figure remains 1.5 times higher than the GOI Service Level benchmark of 20%, and significantly above global best practice—approximately 10% in Israel and 7.5% in Denmark. Critically, the CPHEEO Manual (2023) itself explicitly states that “the challenges posed by climate change are expected to require further reduction in this acceptable level”.
Israel and Denmark have achieved low NRW levels through systematic measures that Bengaluru has yet to adopt at scale: universal metering, financial incentives and penalties linked to NRW performance, precision leak detection, continuous digital pressure monitoring, and integrated data management systems. Moreover, the CPHEEO Manual (2023) already provides detailed guidance on measures to reduce NRW.
We recommend that NRW be assessed across all city corporations in Karnataka, not just Bengaluru, and that time-bound reduction targets be established—first to meet the GoI Service Level Benchmark of 20%, and subsequently to move towards global best practice (<10%). Such priorities are explicitly emphasised in both the Draft National Water Policy 2020 (Mihir Shah Committee) and the Karnataka State Water Policy 2019 (Karnataka Jnana Aayoga, 2019, Chapter 5)
Without quantified baselines, clearly defined targets, and accountability mechanisms, the SSAPCC’s reference to NRW reduction remains aspirational rather than operational, and is therefore misaligned with the urgency of climate adaptation in an already water-stressed state.
The presentation describes tank-filling schemes as a climate adaptation strategy. This could not be further from the truth.
Over the past few years, the various Water Nigams under Karnataka’s Water Resources Department have implemented massive tank-filling projects across the state in the name of drought relief and drinking water security. In principle, one would expect such interventions to reduce drinking water vulnerability, strengthen groundwater resilience, and provide buffers during drought years. Yet, in several regions that we have seen, the opposite appears to be unfolding.
Consider Belagavi district, much of which is classified by the Karnataka State Disaster Management Authority (KSDMA) as highly drought-vulnerable. In 2023, all 13 taluks in the district were declared severely drought-affected.
In terms of ground water, the district is in a deep crisis. In 2017, the Central Ground Water Board (CGWB) classified six taluks as “non-safe” categories (Critical, Semi-Critical, and Over-Exploited). By 2020, the situation had worsened further, with nine taluks falling under the non-safe category.
Yet, sugarcane cultivation expanded dramatically. The cultivated area more than doubled from 221,086 hectares in 2017–18 to 513,499 hectares in 2022–23 — a 132.3% increase in just five years (Insights drawn from District wise sugarcane cultivation data from Karnataka Directorate of Economics and Statistics). By 2022–23, Belagavi alone accounted for nearly 44% of Karnataka’s total sugarcane cultivation area. The district today hosts 28 sugar factories, of which at least 20 are integrated with ethanol distilleries feeding India’s Ethanol Blending Program (Cane Directorate, Karnataka).
A significant part of this expansion appears to have been enabled by large-scale tank-filling schemes. Over the past few years , the Karnataka government has implemented multiple projects in Belagavi district, diverting water from the Krishna, Hiranyakeshi, Vedganga, and Malaprabha river systems into tanks and local water bodies — ostensibly for drought relief and drinking water security (Data from Water Resources Department’s annual reports and field investigations).
However, neither drought vulnerability nor drinking water insecurity appears to have reduced in any meaningful way. In fact, by 2025, seven taluks in the district continued to remain in the “non-safe” group as per CGWB assessment and even today the farmers of the region are fighting aggressively for Mahadayi River water through Kalasa & Bandura projects.
This raises a deeper and insufficiently examined policy question: are these tank-filling schemes actually functioning as climate adaptation measures for drinking water security, or are they subsidising the expansion of water-intensive agriculture and the ethanol economy in already water-stressed regions?
Most importantly, these tank-filling schemes are being implemented in a largely haphazard manner, without consideration of river-basin hydrology, downstream users, ecological flows, or existing water demands. In many cases, they effectively amount to robbing Peter to pay Paul — transferring water stress from one region or community to another while creating an illusion of drought-proofing.
Unless tank-filling schemes are accompanied by basin-scale planning based on actual water availability, strict regulation of water-intensive agriculture, groundwater extraction controls, and clear prioritisation of drinking water and ecological security, they cannot meaningfully be described as climate adaptation strategies.
In fact, under current conditions, they have become the very opposite — mechanisms that deepen long-term hydrological vulnerability in already water-stressed regions.
Treated wastewater reuse is the way forward, but not in its current form. We examine this issue in greater detail in our upcoming report, Treated Wastewater, Untreated Risk.
The present project design — centred on secondary treatment, pumping, and conveyance — fails to adequately address contamination risks to drinking water & irrigation water, which is the groundwater. It also does not address the contamination risks to food crops grown from contaminated ground water, along with the resulting public health implications.
The risks extend beyond microbes and heavy metals to emerging contaminants and antimicrobial-resistant bacteria (“superbugs”), many of which are poorly monitored and inadequately understood.
Our research finds that the widely touted concept of Soil Aquifer Treatment (SAT) has been fundamentally misapplied when compared to practices followed in Israel and guidelines recommended by the Food and Agriculture Organization (FAO). As a result, we conclude that the projects pose a significant risk of groundwater contamination with potentially serious public health consequences.
Most importantly, due to project design fallacies, the projects may not be adequately recharging groundwater as claimed — a concern already reflected in Central Ground Water Board (CGWB) data for Chikkaballapura district and Kolar district, which is discussed in our report.
Also discussed in detail in the report are several urgent measures must be undertaken, including ensuring strict source control of wastewater entering treatment plants, particularly with respect to industrial discharges, fats, oils and grease (FOG), triclosan, and phosphates — as practiced in several developed countries. The projects must also incorporate tertiary treatment and undertake large-scale public awareness campaigns on flushing and farming practices
Additionally, cultivation of food crops in reuse zones should be restricted. Long-term, independent research must be commissioned to assess public health impacts, including chronic exposure to emerging contaminants. Finally, coordinated governance and regulatory action are essential to address antimicrobial resistance risks associated with wastewater reuse.
The presentation’s groundwater management section largely reproduces the same failed framework that has dominated groundwater governance in Karnataka and India for decades—characterised by weak enforcement, poor accountability, and fragmented governance. New element is V-wire technology, which is given an entire slide and presented as an innovative groundwater recharge measure.
There is nothing inherently wrong with V-wire technology. The concern lies in the disproportionate emphasis placed on such smaller technological interventions while ignoring the elephant in the room: the deepening groundwater crisis driven by the ethanol-linked expansion of water-intensive sugarcane and paddy cultivation, which finds no mention in the presentation.
Sugarcane cultivation in Karnataka more than doubled from 533,084 hectares in 2017–18 to a peak of 1,167,916 hectares in 2022–23 — a 119% increase driven largely by ethanol feedstock demand, based on district-wise sugarcane cultivation data from the Directorate of Economics and Statistics, Government of Karnataka.
We have already presented the situation in Belagavi district in Section 4 as an example of how ethanol blending programme (EBP)-driven expansion is intensifying groundwater stress in already drought-prone and groundwater-overexploited regions.
Unless these structural drivers of groundwater depletion are addressed, climate resilience in the water sector will remain largely an illusion.
The presentation dedicates an entire slide to falsely portraying the Mekedatu Dam-Power Project as a climate adaptation strategy. We would like to point out that this framing runs contrary to the direction recommended by key water policy documents in Karnataka and India.
The Karnataka Jnana Aayoga Task Force, in the Karnataka State Water Policy 2019, explicitly states:
What is required is a paradigm shift in how water resources are managed in Karnataka State. From an era when building more dams and drilling more borewells so as to increase water supply infrastructure was the goal, the State needs to shift to a paradigm of managing water within the available water budget.
A similar position is echoed in the Draft National Water Policy (2020) prepared by the Mihir Shah Committee, which calls for moving away from endless supply-side expansion towards demand management.
Moreover, the proposed 67.16 TMC Mekedatu Dam-Power project and its associated 400 MW powerhouse infrastructure that would submerge approximately 12,056 acres of the Cauvery Wildlife Sanctuary and 486 acres of its Eco-Sensitive Zone violates Section 29 of the Wild Life (Protection) Act, 1972. Section 29 explicitly prohibits any activity that is not in the interest of wildlife, which includes the proposed dam-power project as a whole. (Note: The land numbers do not include additional sanctuary land that would be required for transmission lines, which are themselves major land-consuming infrastructure).
One of the central objectives of climate change adaptation and mitigation is to address biodiversity loss, especially at a time when the planet is scientifically widely recognised to be on the cusp of a sixth mass extinction.
The Cauvery Wildlife Sanctuary, with nearly 100 km of the Cauvery River flowing through its core, is bordered by the Malai Mahadeshwara Wildlife Sanctuary to its north and east, the Sathyamangalam Tiger Reserve to its south, and the Biligiri Ranganathaswamy Temple Tiger Reserve to its west. Together, these form part of one of India’s largest contiguous protected landscapes spanning Karnataka and Tamil Nadu. The sanctuary and the larger connected landscape support extraordinary biodiversity, including numerous rare, endangered, threatened, endemic, riverine, and wide-ranging species, making it one of southern India’s most ecologically significant forest-river systems.
There is little doubt that the Mekedatu Dam-Power project will push many species and ecosystems closer to extinction. As a result, Climate change adaptation and mitigation strategies within the water sector cannot be pursued in conflict with biodiversity conservation.
In such a context, presenting large-scale ecological destruction of the Mekedatu Dam-Power Project as climate adaptation is illogical and demands far greater scrutiny.
We urge the government to reduce non-revenue water( as discussed in the section above), improve urban water-use efficiency, and desilt existing reservoirs upstream, as they may offer far more immediate and cost-effective adaptation benefits than constructing new large dams.
We also urge the government to seriously examine groundwater replenishment models adopted in Israel and California’s Orange County Groundwater Replenishment System (GWRS) using treated wastewater, as discussed in sections above. Even preliminary back-of-the-envelope calculations suggest that implementing a comparable groundwater replenishment approach could be an economically more viable way of augmenting water for Bengaluru.
Most importantly, one needs to understand the rapidly escalating water demand driven by the sugarcane- and rice-based ethanol economy. Similar to Belagavi district, sugarcane cultivation in Mandya district—which lies entirely within the Cauvery basin—has more than doubled between 2017 and 2023, intensifying pressure and conflict over water within the Cauvery River Basin (Sugarcane data from the Directorate of Economics and Statistics, Government of Karnataka). In line with UNFCCC climate adaptation principles, the transition towards drought-resilient agriculture, as mentioned in the presentation, must therefore be undertaken urgently.
Climate-friendly, people-friendly, and wildlife-friendly alternatives exist for augmenting Bengaluru’s water supply. Similarly, peaceful approaches exist for managing water-sharing issues with Tamil Nadu, where large dams and power projects do not take centre stage. We urge the Government to take a visionary approach and seriously consider these alternatives.
One of the most striking omissions in the presentation is the near complete absence of pollution as a climate adaptation and mitigation concern. It seems to us that this is not by accident but a political choice. Enforcing pollution controls would inconvenience industrial, real estate, and agricultural interests that wield significant influence. However, omitting pollution makes every proposed adaptation measure fragile.
This is deeply problematic because pollution is not merely an environmental issue — it directly undermines climate resilience, drinking water security, ecosystem health, groundwater sustainability, food systems, and public health. Furthermore, climate change amplifies and accelerates pollution, making the omission even more dangerous.
Pollution reduces the very freshwater base that adaptation strategies depend upon. A polluted river is not climate-resilient, nor is a contaminated aquifer drought-resilient. We have generated extensive literature on river pollution over the years, including our recent report State of the Vrishabhavathi River (2016–2025), which illustrates the scale and persistence of the problem.
At the same time, even the ecological protections historically provided by natural systems are being steadily eroded. The recent dilution of lake buffer norms through amendments to the Karnataka Tank Conservation and Development Act (KTCDA) is one such example, as is the reduction of buffer zones for raja kaluves in Bengaluru, not to mention the reduction of buffer zones along the Arkavathi River in the Thippagondanahalli Reservoir catchment. These buffers are not mere planning formalities; they are critical hydrological and ecological safeguards that help absorb floods, filter pollutants, recharge groundwater, and protect water bodies from encroachment and contamination.
Weakening both regulatory institutions and reducing ecological buffers simultaneously is fundamentally incompatible with any serious climate adaptation strategy.
One only has to look at models in countries such as the United States. For instance, New York City protects its drinking water by conserving and strictly regulating the Catskill–Delaware watershed. Instead of relying mainly on expensive filtration plants, the city invested heavily in watershed protection, including buying riparian lands to utilise the natural filtration capacity. The principle is simple: protecting catchments is often more effective and economical than cleaning polluted water later.
Preventing the pollution of rivers, wetlands, aquifers, and catchments is fundamental to climate adaptation and mitigation, yet it is almost entirely absent from the presentation.
As we have discovered through our work so far, meaningful river basin planning is largely absent. Simple, data-driven decision-making at the basin scale appears not to exist. This raises fundamental questions: how are water allocations actually being made? On what scientific or hydrological basis is it decided that water can be lifted from one river system and transferred to another basin?
More importantly, how are the needs of existing downstream users being assessed? Where are environmental flows accounted for? Where is the recognition that rivers themselves require water to remain ecologically functional?
These are not peripheral questions. They lie at the heart of climate resilience, ecological sustainability, and water justice. However, projects continue to be planned and implemented without transparent basin-scale hydrological assessments, cumulative impact evaluations, or meaningful public debate on the long-term consequences of altering river flows.
The Yettinahole Project — presented in the report as a climate adaptation strategy — is in fact a textbook example of a project that has ignored nearly every principle of Integrated Water Resources Management (IWRM).
The project has resulted in the destruction of thousands of acres of forest land in Hassan district as documented by MoEFCC, increased landslide risks as we have seen ourselves which is covered in the local kannada media, and locked the state into massive long-term energy infrastructure for pumping and conveyance.
At the same time, the project has largely ignored downstream water requirements, including the needs of communities and ecosystems dependent on the Netravathi River, particularly in and around Mangaluru. This includes impacts on fisheries, estuarine systems, livelihoods, and environmental flows.
Moreover, the projected water benefits of the project appear to have been significantly overstated — an issue that has itself been discussed and acknowledged within the Karnataka Legislature.
So, Yettinahole is not from any angle, a climate adaptation project, but continuation of ecologically destructive, economically destructive, energy-intensive, supply-side water management.
The Karnataka government has quietly prioritised bulk water supply to drinking water packaging industries. In Hubballi–Dharwad, which already depend on the depleting waters of the Malaprabha and where water from the controversial Kalasa–Banduri project is being aggressively pursued to address urban water scarcity, PepsiCo’s Dharwad drinking water packaging plant was receiving over 2 lakh litres of Malaprabha water per day at a tariff far lower than that paid by ordinary consumers, even during periods of severe drought and water scarcity.
Such allocation is not only inconsistent with Karnataka’s own water policy priorities, but also runs contrary to climate policy frameworks such as Karnataka’s State Action Plan on Climate Change, which emphasise equitable, efficient, and sustainable water use.
As we have discovered through our work so far, meaningful river basin planning is largely absent. Simple, data-driven decision-making at the basin scale appears not to exist. This raises fundamental questions: how are water allocations actually being made? On what scientific or hydrological basis is it decided that water can be lifted from one river system and transferred to another basin?
The Hubballi–Dharwad case is not an isolated one. Similar drinking water packaging industries are thriving in the Cauvery basin as well. One such plant, operated by Hindustan Coca-Cola Beverages in the Bidadi Industrial Area, has been functioning for decades. The plant receives approximately 9.36 lakh litres per day of Bangalore Water Supply and Sewerage Board (BWSSB) Cauvery water for packaging and sale for profit. At 50 LPCD, this quantity of water could meet the basic daily water needs of approximately 18,720 people.
These corporations also rely heavily on groundwater extraction. The Hindustan Coca-Cola Beverages plant in Nelamangala, near Bangalore, is one stark example. The concern is not merely extraction, but also contamination.
Communities around such plants have raised concerns regarding impacts on groundwater quality and agricultural livelihoods. The most widely known example remains the Plachimada case in Kerala, which became nationally significant due to allegations of excessive groundwater extraction and contamination linked to soft drink bottling operations.
A Parliamentary Standing Committee has previously examined these concerns and made recommendations that remain on paper. The issue acquires even greater significance in the context of declining freshwater availability due to climate change, and increasing competition over water resources. The issue also raises serious concerns regarding the privatisation of public resources that the government is constitutionally expected to hold in public trust. This issue must be explicitly considered.
Climate resilience in the water sector is not achieved by labelling already existing unsustainable projects as adaptation. It requires honest accounting of hydrological reality and a clear distinction between genuine adaptation and maladaptation dressed in climate language.
A genuine climate adaptation strategy for Karnataka must begin with a fundamentally different philosophy: living within ecological and hydrological limits. This requires basin-scale planning, protection of rivers and catchments, pollution prevention, groundwater governance, demand-side management, reduction of non-revenue water, restoration of wetlands and ecological buffers, transitions towards drought-resilient agriculture, and transparent science-based decision-making.
Most importantly, rivers must be treated not as pipelines for extraction and diversion, but as living ecological systems with downstream users, environmental flow requirements, and intrinsic ecological value.
Measured against this standard, the current draft of the SSAPCC falls short on nearly every count. The projection of increasing Cauvery flows contradicts the best available science. The prioritisation of Mekedatu, Yettinahole, and tank-filling schemes reflects a continued commitment to supply-side expansion rather than demand management. The total absence of pollution prevention and the complete silence on ethanol-driven sugarcane expansion are not minor gaps — they are fundamental failures to confront the structural drivers of water stress in the state.
We therefore urge the Government of Karnataka to undertake an institutionalised participatory consultation process befitting a democracy, as demonstrated by Porto Alegre’s globally recognized participatory budgeting model, and to make the fundamental revisions that the science, the data, and the people of Karnataka demand.
