evaluationofthe environmental impact assessmentforthe（环境影响assessmentforthe评审）.docVIP

Evaluation of the Comprehensive Environmental Impact Assessment study for the Proposed Athirappilly Hydroelectric Project Prepared by: Mark Chernaik, Ph.D. Staff Scientist Environmental Law Alliance Worldwide April 2005 This document expresses the opinion of its author and not necessarily the opinions of the U.S. office of the Environmental Law Alliance Worldwide or other individuals or oganizations affiliated with the Environmental Law Alliance Worldwide.At the request of P.B. Sahasranaman, I reviewed the comprehensive Environmental Impact Assessment (EIA) for the Athirappilly hydroelectric project proposed by the Kerala State Electricity Board (KSEB). This EIA contains the following flaws. 1. The EIA fails to justify the need for the project Page 1.3 of the EIA states the following: “By the year 2004-2005, the demand for power will be of the order of 3593 MW. Considering 20% outage for maintenance, the above requirements can be met only with an installed capacity of at least 4312 MW. Thus, the state would face a shortfall of at least 36% vis-à-vis power generation capacity by the year 2004-2005.” A shortfall between energy demand and energy generation capacity does not justify another hydroelectric project in the State of Kerala; it only justifies a project that would manage energy demand or augment energy capacity generally. What this EIA lacks is a rationale for public expense on another hydroelectric project instead of investing limited public funds in an alternative project that might eliminate the shortfall between energy demand and energy generation capacity in a more economical and ecological manner. 1.1 The EIA fails to consider whether investments in improving the efficiency of existing energy generation and transmission infrastructure is a more important priority than construction of another hydroelectric dam According to international experts: “[T]he debate over large dams is moving on in the contex