‘The devil is in the detail’: Peer-review of the Wildlife Conservation Plan by the Wildlife Institute of India for the Etalin Hydropower Project, Dibang Valley Chintan Sheth1, M. Firoz Ahmed2*, Sayan Banerjee3, Neelesh Dahanukar4, Shashank Dalvi1, Aparajita Datta5, Anirban Datta Roy1, Khyanjeet Gogoi6, Monsoonjyoti Gogoi7, Shantanu Joshi8, Arjun Kamdar8, Jagdish Krishnaswamy9, Manish Kumar10, Rohan K. Menzies5, Sanjay Molur4, Shomita Mukherjee11, Rohit Naniwadekar5, Sahil Nijhawan1, Rajeev Raghavan12, Megha Rao5, Jayanta Kumar Roy2, Narayan Sharma13, Anindya Sinha3, Umesh Srinivasan14, Krishnapriya Tamma15, Chihi Umbrey16, Nandini Velho1, Ashwin Viswanathan5 & Rameshori Yumnam12 1Independent researcher, Ananda Nilaya, 4th Main Road, Kodigehalli, Bengaluru, Karnataka 560097, India Email: [email protected] (corresponding author) 2Herpetofauna Research and Conservation Division, Aaranyak, Guwahati, Assam. 3National Institute of Advanced Studies, Bengaluru, Karnataka. 4Zoo Outreach Organization, Coimbatore, Tamil Nadu. 5Nature Conservation Foundation, Bengaluru, Karnataka. 6TOSEHIM, Regional Orchids Germplasm Conservation and Propagation Centre, Assam Circle, Assam. 7Bombay Natural History Society, Mumbai, Maharashtra. 8National Centre for Biological Sciences, Bengaluru, Karnataka. 9Ashoka Trust for Research in Ecology and the Environment, Bengaluru, Karnataka. 10Centre for Ecology Development and Research, Uttarakhand. 11Sálim Ali Centre for Ornithology and Natural History (SACON), Coimbatore, Tamil Nadu. 12South Asia IUCN Freshwater Fish Specialist Group 13Cotton University, Guwahati, Assam. 14Indian Institute of Science, Bengaluru, Karnataka. 15Azim Premji University, Bengaluru, Karnataka. 16Department of Zoology, Rajiv Gandhi University, Itanagar, Arunachal Pradesh. *Contributors are listed alphabetically ABSTRACT conduct “a multiple seasonal replicate study on A group of Indian scientists including botanists, biodiversity assessment” of the 3097 MW Etalin entomologists, ornithologists, mammalogists, Hydro Electric Project (HEP) in Dibang Valley, herpetologists, aquatic fauna specialists, Arunachal Pradesh. The review has found hydrologists, geographers, and social that the study was conducted in under five scientists, many with research experience five months from February to June 2018 and in northeastern India, including the Dibang cannot be considered as a ‘multiple seasonal Valley in Arunachal Pradesh, have conducted replicate’ study as it does not represent a peer-review of the Technical Report prepared three seasons in Arunachal Pradesh. This by the Wildlife Institute of India’s (WII) titled survey period excludes seasonal migrants ‘Wildlife Conservation Plan for the impact zone and/or crucial breeding times for certain of Etalin HEP, Dibang Valley District, Arunachal species. Further, fieldwork was conducted Pradesh’ (the ‘Report’). The Report was in a very small area (‘Zone of Influence’, ZoI) prepared in response to the Forest Advisory compared with the area that will be directly Committee’s (FAC) recommendation to and indirectly affected by the impacts of Zoo’s Print Vol. 35 | No. 5 1 the HEP, with uneven sampling within the butterfly, reptile parks, and nest boxes cannot limited ZoI. While several groups of taxa be considered as well-designed ecologically were not surveyed, the Report outlines poor meaningful measures. There appears to be detectability for better studied taxa such as an underplay of the negative impacts of the birds, without statistically accounting for low HEP throughout the Report. The section that detections. Approaches and methods used relates to assessing socio-cultural impacts of to analyse field data, and produce results are the HEP suggests mitigation measures that inadequate, not clearly explained and, often, lack a nuanced understanding of socio-cultural not scientifically recognised. Commonly-used dynamics and interdependencies between methods (e.g., species accumulation curves) people and the natural environment. to analyse and report data on species richness and diversity were not applied to most taxa Overall, the Report assumes the project as fait (except fish). Because of methodological accompli implying that the Report’s findings and analytical deficiencies and exclusion of have no bearing on the FAC’s decision to highly diverse taxa such as insects and other approve the project, ultimately making this arthropods, comparisons with published exercise appear futile. Crucially, studies research from Dibang Valley shows that the that inform high-level decision-making on Report under-reports hundreds of species of historically significant projects, such as the butterflies and other insect groups and birds, Etalin HEP (which would be one the largest and tens of species of orchids, mammals, and hydropower projects in the country), must herpetofauna. The Report’s species checklists go through a transparent and scientifically contain repetitions, improper taxonomic recognised peer-reviewed process given the classifications, and incorrect distributions, pitfalls, numerous discrepancies, and gaps including 12 butterfly species not known to highlighted in this review. Such decisions have occur in northeastern India and a bat species irreversible impacts on lives, livelihoods, and found only in Africa. the environment. Despite short surveys conducted using biased INTRODUCTION AND BACKGROUND sampling methods, the Report provides direct On 28 February 2017, the Forest Advisory evidence of 230 bird, 159 butterfly, 112 spider, Committee (hereafter FAC) met to discuss the 51 moth, 31 reptile, 14 amphibian, and 21 3097 MW Etalin Hydropower Project (hereafter mammal species. Amongst these are several HEP, or ‘the project’) to be developed by endemic (e.g., seven species of birds), range- Jindal Power Limited (hereafter User Agency) restricted (e.g., six bird and three butterfly in Dibang Valley District. In the minutes that species), and threatened (e.g., eight mammal were released later (F.NO. 8- 20/2014-FC), species) species, many of which are included the FAC found the Environmental Impact in Schedule I of the Wild Life (Protection) Act, Assessment (EIA) submitted by the User 1972. However, the Report ignores its own Agency “inadequate” and recommended findings to outline mitigatory measures for that a “multiple seasonal replicate study some taxa while observing that “it was not on biodiversity assessment” of the 3097 possible to suggest any threatened species and MW Etalin HEP in Dibang Valley District be habitat specific conservation plan” for others conducted by “an internationally credible (e.g., mammals). Firstly, it is not clear how the institute”. The Wildlife Institute of India FAC’s singular mandate of conducting a study (hereafter WII), Dehradun, was chosen on ‘biodiversity assessment’ was converted to conduct the said study (vide letter no. into a Wildlife Conservation Plan. Secondly, FOR-279/CONS/2010/Vol-I/ 836-40, 23 the few mitigatory measures recommended June 2017 from APCCF and Nodal Officer for some specific faunal groups in the form of (FCA), Arunachal Pradesh). In 2019, the WII Zoo’s Print Vol. 35 | No. 5 2 produced an extensive Technical Report (TR biological information, including on the region’s No/2019/01, hereafter ‘the Report’) titled many seasonal bird migrants. Additionally, ‘Wildlife Conservation Plan for the impact zone multiple replicate sampling within seasonal of Etalin HEP, Dibang Valley District, Arunachal periods was not conducted. Therefore, this Pradesh’. The Report assesses the status of cannot be considered a ‘multiple seasonal various taxonomic groups including mammals, replicate’ study. avifauna, entomofauna, herpetofauna, and flora in the HEP site. It also documents the (2) The Report focuses its assessment within biodiversity value for and the natural resource an area (112km2) in the immediate vicinity of dependence of the local Idu Mishmi people in the project site, called the ‘Zone of Influence’ the project site. Finally, it evaluates the impacts (hereafter ZoI), and defines it as the farthest of the proposed project on the aforementioned influence of the HEP (page 35). It briefly taxa and natural resource needs of the local mentions the impact sources that were taken people and drafts a mitigation and conservation into consideration while delineating the plan along with a financial budget for its ZoI, pointing to ‘section 4.3’ for a detailed implementation. methodology used for the delineation (page 35). This section however does not exist, A group of Indian scientists, including making it impossible to assess whether the botanists, entomologists, ornithologists, ZoI adequately covers all the areas that will mammalogists, herpetologists, aquatic fauna experience the direct and indirect impacts of specialists, geographers, hydrologists, and the multiple components of the project. The social scientists, many of whom have multiple project has over 50 components which include years of research experience in northeastern two large concrete gravity dams, diversion India, including the Dibang Valley in Arunachal tunnels, penstock pipes, an underground Pradesh have conducted a peer review of powerhouse, a road network of over 50km, the Report. Overall, the review encountered and four new bridges. The construction phase considerable deficiencies and scientific biases of the project will involve extensive mining, in the Report which have compromised the quarrying, slope undercutting, and muck quality and the veracity of its findings and disposal, including