The Ministry of Environment, Forest and Climate Change (MoEFCC) has released the Environmental Impact Assessment (EIA) report for the proposed Sharavathi Pumped-Hydro Energy Storage Project for public comments. Public hearings on the project are scheduled for 16th September in Sagara and 18th September in Gerusoppa, Honnavar Taluk.
This page presents an analytical review of the EIA document, highlighting its critical gaps and shortcomings. Citizens are encouraged to use the content here to frame their email submissions to the MoEFCC. Emails are also provided. For convenience, pre-formatted submissions are also available and can be attached to the email.
Analytical review of Environmental Impact assessment (EIA) of Sharavathi Pumped-hydro Energy Storage project shows serious and systematic omissions, including lapses in biodiversity impact assessment, hydrological studies, mapping of project context, and compliance with statutory requirements, as well as its superficial treatment of critical threats such as habitat fragmentation, landslide vulnerability, hazardous material management, and cumulative basin-wide effects.
For a 2,000 MW project located in the evergreen forests of the Sharavathi Lion-Tailed Macaque Wildlife Sanctuary, home to numerous endangered species, the scope is shockingly superficial. Instead of a rigorous, site-specific assessment, the document reads like a recycled template—sections lifted from generic literature, and at times resembling a tourist brochure rather than a scientific study.
The analytical review of the EIA, is after Call to Action.
Call to Action: Submit Your Objections
The Ministry of Environment, Forest and Climate Change (MoEFCC) has released the Environmental Impact Assessment (EIA) report for the proposed Sharavathi Pumped-Hydro Energy Storage Project for public comments. Public hearings are scheduled for: 16th Sep in Sagara (near Jog Falls) and 18th Sept in Gerusoppa, Honnavar Taluk. Citizens are urged to participate in the public hearing.
This page offers an analytical review of the EIA, highlighting its critical gaps and shortcomings. Citizens are encouraged to use these points to prepare for public hearing and also to make written submissions to the concerned authorities.
For convenience, pre-formatted PDF reviews are also available: one page review and Detailed Review—you can download and attach them directly to email.
Objections in Kannada written by Dr. Sadananda Heggadal Math can be found here
Email MoEFCC : monitoring-ec@nic.in secy-moef@nic.in rosz.bng-mef@nic.in ccf_fc@yahoo.co.in
Email Karnataka State Pollution Control Board (KSPCB): chairman@kspcb.gov.in. ms@kspcb.gov.in. shimoga@kspcb.gov.in karwar@kspcb.gov.in (KSPCB is conducting the public consultation process)
Email District Commissioners (DCs): Deo.shimoga@gmail.com dckarwar@gmail.com (DCs will preside over the public hearings)
In addition to sending emails, citizens can also sign change.org petition
Below is the analytical review of the EIA:
1. Failure to provide project justification
While the section is titled “Need for the Project”, what it actually provides is a technical description of how the project works, not a justification of why it is necessary. It reads more like a project brochure than a need assessment.
2. Failure in Baseline Scoping
The baseline scoping itself is fundamentally flawed. By omitting core risks—such as hazardous materials management, muck disposal, chemical leachate, drilling and blasting impacts, hydrological changes, landslide susceptibility, seismicity, biodiversity loss quantification, sand mining impacts, and cumulative basin-level effects—the entire EIA exercise is rendered inadequate and effectively meaningless.
3. Failure to Map Project Context
The EIA fails to provide a single integrated map that situates project activities within the ecological, hydrological, and social context of the study area. For a project located inside the Sharavathi Lion-Tailed Macaque Wildlife Sanctuary and its Eco-Sensitive Zone, the maps should have clearly shown the Sanctuary and ESZ boundaries, the hydrology of the Sharavathi including perennial streams, natural springs, drinking water wells, and 100- and 500-year flood zones, along with the points of water abstraction for the project.
They should also have overlaid all project components—roads, labour sheds, contractor offices, reservoirs, tunnels, powerhouses, transformer halls, muck dumping sites, and sand and stone quarry locations—against existing human settlements, villages, temples, sacred groves, and archaeological sites such as Basti.
Equally critical omissions include mapping of landslide-prone zones, Lion-Tailed Macaque habitats, hornbill nesting sites, pangolin burrows, leopard sightings etc. Such maps are fundamental for any credible assessment, and their absence reveals that the EIA conceals the project’s massive impacts, rendering any evaluation of ecological and social consequences scientifically meaningless.
4. Failure to Assess Habitat and Species Impacts
The EIA reduces wildlife assessment to a species inventory, listing the Lion-Tailed Macaque, Malabar Civet, endemic amphibians, King Cobra etc as endangered, without analysing how the project will affect their habitats, breeding, or movement. Merely recording presence does not amount to biodiversity impact assessment.
More troubling still, after cataloguing endangered and vulnerable species, the EIA concludes that “major impacts are not anticipated.” The document recognizes the presence of highly sensitive species yet denies that they will face any consequences. By this flawed reasoning, even habitat fragmentation,one of the gravest threats to Lion-Tailed Macaques, the very species for which the sanctuary is named, is dismissed as inconsequential.
Also Read | Western Ghats is NOT a Power Plant
5. Failure to Propose Adequate Mitigation Plans
The so-called mitigation plan is reduced to superficial measures and vague promises such as ‘controlled blasting,’ ‘anti-poaching surveillance,’ and afforestation on degraded lands. None of these can replace the ecological functions of old-growth evergreen forests or the continuity of intact canopies. Proposals for nurseries, botanical gardens, awareness programmes, and eco-development committees are cosmetic at best and do nothing to offset the destruction of legally protected habitats.”
6. Failure to Disclose and Assess Construction Materials Programme
The quantity of construction material required is given only for the tunnels, power house and surge chamber. The construction material required for roads, bridges, contractor offices, labour camps, and fabrication yards are entirely omitted.
The inadequate and incomplete construction material lists only end-product volumes like “concrete” without breaking them down into their raw components—cement, sand, and aggregates, whose extraction has major ecological consequences not to mention legal compliances.
7. Failure to Disclose and Assess Hazardous Industrial Explosives.
The environmental impact of 18,000 tons of industrial explosives (HS Code 3602001, LD50 toxicity 1,510 mg/kg)—explicitly documented in the Form 1 application—represents an unprecedented contamination threat to the Western Ghats ecosystem, yet is entirely omitted from the EIA. This omission constitutes a fundamental breach of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
Blasting and tunnelling on this scale will generate millions of cubic meters of muck contaminated with explosive residues that require specialized classification, handling, and disposal protocols. Yet the EIA provides no management plan whatsoever. Even more critically, it fails to assess the risk of chemical leachate entering the Sharavathi River, its perennial streams, and groundwater systems—posing direct threats to aquatic life, irrigation, drinking water, and public health.
8. Failure to Disclose and Assess Sharavathi River Sand Mining Impacts
Sand is the project’s most destructive resource, yet the EIA provides no quantitative estimate of the volumes required or the scale of daily extraction. The proposed quarries fall within the Eco-Sensitive Zone (ESZ) of the Sharavathi Lion-Tailed Macaque Sanctuary, where all mining is explicitly prohibited under the ESZ Notification of 16 November 2023, making this a clear violation of law.
The EIA also fails to meet mandatory requirements, including preparation of a District Survey Report (DSR), sediment replenishment calculations under the Sustainable Sand Mining Management Guidelines, 2016, and compliance with the Enforcement & Monitoring Guidelines for Sand Mining, 2020.
Beyond these legal breaches, the report ignores the impacts of sand mining on water quality, aquatic biodiversity, agriculture, and drinking water sources, as well as the cumulative damage when combined with muck dumping and erosion. In reality, sand mining irreversibly alters rivers—changing flows, destroying habitats, and undermining both ecosystems and community water security.
A change in the Sharavathi River’s course due to sand mining is already visible at the project site. Sand extraction for constructing the Nagarbastikeri Bridge—the main access bridge to the project site—has altered the river, as evident from satellite imagery. Ecological and environmental recklessness linked to the project is therefore not a future risk but a reality already underway.
9. Failure to Map and Assess Landslide Vulnerability
The proposed project site lie within moderate to high landslide susceptibility zones, as identified by the Karnataka State Natural Disaster Monitoring Centre (KSNDMC). Project activities include blasting with 18,000 tons of hazardous explosives, tunneling an 11.6 km water-conducting network (9–10 meters in diameter), stone quarrying, and muck dumping. Together, these will inevitably block or reroute subsurface and surface water. In the Western Ghats’ high-rainfall conditions, such disruptions raise soil moisture and pore-water pressure, destabilizing already fragile slopes.
The Western Ghats has seen this before,most notably the Kodagu landslides of 2018 and the Wayanad disaster of 2024,both worsened by interference with stream networks and drainage patterns. Yet the EIA neither maps nor assesses this risk. It does not even acknowledge it.
This is not a question of if a disaster will occur, but when. And when it does, it will not be an “Act of God”—it will be an “Act of KPCL”: the wholly foreseeable consequence of forcing infrastructure into ecologically unstable and legally protected landscapes, in open defiance of scientific evidence and the precautionary principle.
10. Failure to Assess Impacts of Drilling and Blasting
Drilling and blasting the mountains, with 18,000 tons of Hazardous Industrial Explosives, for underground tunnels pose severe environmental and safety risks that the EIA fails to assess. The image below shows the mountains that will be blasted. The concept of a blast radius—the zone of vibration and fracturing around each blast—is entirely omitted.
Blasting damages houses, destabilizes slopes, disrupts groundwater flows, and damages vegetation and forest cover, with serious consequences for Lion-Tailed Macaques, Pangolins, King cobras, and other sensitive species. It also heightens risks of slope instability and dam safety, particularly with quarry blasting near the Gerusoppa Dam.
Blasting further threatens local hydrology. Streams such as Begodi Halla and Kalkatte Hole, which sustain perennial flows, could dry up or be depleted—undermining agriculture, drinking water and aquatic biodiversity. Yet the EIA neither evaluates these risks nor considers safer alternatives such as Tunnel Boring Machines (TBMs), which minimize geological disturbance. By ignoring both impacts and alternatives, the EIA conceals a critical threat to the integrity of the Western Ghats, its rivers, and the communities who depend on them.
11. Failure to Acknowledge Hydrological Impacts
Taken together, these activities will obliterate habitats for fish and birds, strip riparian vegetation, and render waters too turbid to sustain aquatic life. Conservation experts point to the likely presence of the small-clawed otter in these waters—a Schedule I species under the Wildlife Protection Act—that would almost certainly have been recorded had a baseline aquatic biodiversity assessment been conducted.
River and spring waters, vital sources of drinking water, will be contaminated. Betel leaf farmers—who rely on clean, high-quality water—will face crippling losses, and estuarine fishing communities downstream will also be severely impacted. None of these consequences are acknowledged in the project’s environmental assessment.
12. Failure to Consider two Legally Protected National Monuments
The EIA records: no monuments of cultural, religious, historical, or archaeological importance are reported in the project area. This is factually incorrect. Two monuments – #1242 Chaturmukh Basti, and # 1243 Inscriptions are located in Nagarbastikeri, Gerusoppa. They are protected under the Ancient Monuments and Archaeological Sites and Remains (AMASR) Act, 1958, as amended in 2010. Moreover, it is important to note that there are numerous heritage monuments, inscriptions that are yet to be studied by the Archaeological Survey of India in the project area. These, when encountered, during protect construction, can potentially end up landfilled, along with other waste from the project.
As per the AMASR Act, each protected monument is surrounded by a Prohibited Area of 100 meters, where construction is not permitted a Regulated Area extending a minimum of 200 meters, where development requires mandatory NOC from the National Monument Authority. Official verification by ASI/NMA is essential before any clearance is considered.
According to the markings of prohibited areas and regulated areas as shown in the image below , it is clear that the project roads that will need to be widened and concretized is passing through the prohibited area.
Adding to these lapses, the EIA completely fails to assess the impacts of drilling, tunnelling, and blasting on these fragile heritage structures. Ignoring the presence of nationally protected monuments not only invalidates the cultural heritage section of the EIA but also places the project in direct violation of the AMASR Act.
13. Failure to Comply with NBWL Road Design Conditions and to Assess Road Impacts
In its 84th meeting on 26 June 2025, the Standing Committee of the National Board for Wildlife (NBWL) imposed binding conditions requiring that the road from Nagarbastikeri to Begodi, as well as the surge tank, be constructed underground. The EIA, however, makes no reference to these statutory requirements, nor does it indicate whether the project intends to comply. This omission raises critical questions: will the mandated conditions be implemented, and if not, on what basis can non-compliance be justified?
In addition, the proposed road alignment runs directly alongside Begodi Halla, a perennial stream fed by springs in summer and swollen during the monsoons. At present, this is only a narrow mud track, rarely used, and often rendered impassable during floods. Converting it into a wider concrete road without accommodating the floodplain or riparian zone will cause irreversible damage to the stream, its hydrology, and its associated wildlife—impacts the EIA entirely ignores.
The alignment also falls within the prohibited and regulated areas of legally protected monuments, making the current design legally untenable. In this context, the EIA’s failure to disclose the quantity of raw materials—sand, concrete, and other inputs—required for road construction may appear secondary, but it underscores a broader pattern of omissions and evasions. Taken together, these failures render the present EIA incomplete and meaningless, as it disregards statutory conditions and critical environmental safeguards.
14. Failure to Comply with Eco-Sensitive Zone Notification and Extreme Impacts of Muck Disposal
Figure 4.2 of the EIA document, which identifies muck dumping areas, is not legible and fails to show the boundaries of the Wildlife Sanctuary, its Eco-Sensitive Zone (ESZ), or the drainage of the Sharavathi River. Without this context, neither citizens nor regulators can meaningfully assess the impacts of muck disposal.
Our analysis reveals that the identified muck dumping sites fall squarely within the ESZ of the Sharavathi Lion-Tailed Macaque Sanctuary. The ESZ Notification (16 November 2023) explicitly prohibits the disposal of inorganic waste—which is what the muck generated from drilling, blasting, and tunneling is—within the ESZ. Locating muck dumps within the zone is therefore a direct violation of the notification.
The Construction and Demolition Waste Management Rules, 2016 further mandate that all debris must be processed, recycled, or disposed of only at designated, government-approved sites. Waste generators producing more than 20 tons per day must also segregate waste into four streams (concrete, soil, steel/wood/plastics, bricks/mortar). The EIA provides no evidence of compliance with these requirements.
The scale of disposal is staggering: 4.8 million cubic meters (MCM) of muck generated using 18,000 tons of industrial explosives (HS Code 3602001, LD50 toxicity 1,510 mg/kg) is proposed to be dumped as close as 124 meters,from the Sharavathi River, as shown in the google earth image below. Given the region’s intense rainfall, contaminated leachate will inevitably enter the river, polluting its waters, potentially altering its course, and irreparably damaging aquatic ecosystems, drinking water quality, and irrigation sources such as betel nut cultivation, which depends on high-quality water.
Yet the EIA provides: no toxicological assessment of explosive residues, no groundwater contamination modeling, no health risk assessment for local populations, no long-term monitoring protocols, and no remediation contingency planning. In a nutshell, the EIA has no Environmental Contamination Scale Analysis, again rendering it useless.
The same muck is also proposed to be disposed of upstream near streams feeding the Sharavathi above Gerusoppa Dam. Leachate and sediment from these sites are likely to be carried into the reservoir, leading to siltation and a reduction in storage capacity. Such impacts on dam performance and downstream water security have not been assessed in the plan.
Since disposal sites are located adjacent to the main Sharavathi River and its streams, it is virtually certain—given the region’s intense rainfall—that contaminated leachate will enter the river. This will pollute the river, potentially alter its course, and irreparably damage aquatic life, drinking water quality, and irrigation sources such as betel nut cultivation, which depends on high-quality water. None of these risks are identified or assessed in the plan.
The hydropower industry has a long record of illegal and unscientific dumping of muck into river valleys. It is common practice for project proponents to leave excavated debris along riverbanks, relying on the monsoons to wash it away. Equally troubling, the Ministry of Environment has repeatedly turned a blind eye to such violations. Recognizing these dangers, the Uttarakhand High Court in 2018 stayed all construction activities near riverbanks statewide until proper muck disposal sites were identified at least 500 meters away from rivers. The same safeguard must be applied in the Sharavathi case, given the ecological fragility and the intense monsoon rainfall of the Western Ghats.
15. Failure to Conduct Cumulative Impact Assessment and Carrying Capacity Study
In its 7th meeting held on 30 July 2025, the Forest Advisory Committee (FAC) directed the KPCL to carry out a Cumulative Impact Assessment study and a Carrying Capacity study as part of the EIA report. These are critical requirements for a project of this scale, located in a legally protected and ecologically fragile landscape. Yet, the submitted EIA contains neither. This omission represents not only non-compliance with FAC directions but also a failure to evaluate basin-wide and landscape-level impacts that are central to informed decision-making.
16. Failure to Include and Assess the Transmission Line Component
Both the Forest Advisory Committee (FAC) in its 7th meeting on 30 July 2025 and the Standing Committee of the National Board for Wildlife (NBWL) in its 84th meeting on 26 June 2025 explicitly noted that the transmission line component must be considered. The Terms of Reference for the EIA also requires assessment of transmission lines. Yet, KPCL continues to claim that “a network of power evacuation lines is already existing”—a statement that is demonstrably false.
Our analysis, including discussions with KPTCL engineers, confirms that the existing lines are inadequate. A new 400 kV double-circuit bi-lateral line running approximately 60 km in length and 100-meter-wide corridor, is will be required. An RTI response from KPTCL further reveals that this line would necessitate approximately 145 acres of sanctuary and forest land.
Transmission lines are not a separate or optional element—they are integral and interdependent with the tunnels, powerhouses, and other project components. Regardless of whether they are executed by different agencies (KPCL and KPTCL), their environmental impacts must be assessed collectively, not in isolation. By failing to include the transmission line, the EIA conceals a major source of deforestation, fragmentation, and ecological impact, rendering its assessment incomplete and misleading.
17. Other Critical Failures
Beyond the above, several additional lapses further undermine the EIA’s credibility.
- The EIA fails to disclose that the Masthihalli stone quarry lies within the notified Wildlife Sanctuary, where quarrying is a prohibited activity under the Wildlife (Protection) Act, 1972. Its significant impacts on forest cover, habitat integrity, hydrology, and noise disturbance are entirely absent from the report, further exposing the document’s evasive character.
- The EIA does not specify the satellite data source used—an omission that amounts to a serious methodological lapse.
- The Terms of Reference (TOR) require a drainage pattern and catchment map up to the proposed project site. This is absent. Similarly, the TOR mandates a map of the project boundary showing protected areas within a 25 km radius. This too has not been provided, leaving out critical information on surrounding ecological sensitivities.
- The EIA categorically states that no recent hydrographic survey has been carried out for the existing dams, even though a Central Water Commission study was completed in 2021.
- On seismicity, the EIA merely notes that the area is tectonically active, offering no analysis of the risks this poses for a project of this scale.
- Throughout, the document reduces impacts to mere words such as “localized,” “temporary,” or “not significant”—subjective assertions unsupported by scientific assessment.
In conclusion: The Sharavathi PSP EIA fails not by accident but by design. It systematically conceals or downplays catastrophic ecological, hydrological, social, and cultural impacts. It makes false factual claims, ignores statutory requirements, and omits critical assessments mandated by the Terms of Reference, the Forest Advisory Committee, and the National Board for Wildlife. Instead of providing a scientific basis for informed decision-making, it reads like a project brochure—prioritizing approval over accuracy.
WAPCOS, a Government of India undertaking, appears to have applied its mind not to rigorous assessment, but to assiduously scrubbing the document of any meaning—while padding it into 500 pages of words, just words.
Proceeding with such a defective document would constitute environmental assessment malpractice and undermine citizens’ trust in environmental governance and democracy.
We therefore demand that the government withdraw this flawed and meaningless EIA and require a fresh, scientifically rigorous, and legally compliant assessment—one that genuinely evaluates alternatives, respects ecological limits, and upholds the statutory protection of sanctuaries, eco-sensitive zones, rivers, and heritage sites. Only then can the project return for a meaningful public hearing.
Frontline Hindu covered the Sharavathi Pumped Storage Project, featuring some of our work in its reporting. Click image for the article
