From: aparna@mipos2.intel.com (Aparna Krishnan)
Newsgroups: soc.culture.indian,soc.culture.tamil,soc.culture.indian.telugu,sci.environment,soc.human.rights,alt.activism
Subject: Bradford Morse's letter to the World Bank ...
Date: 16 Oct 92 22:50:55 GMT
Organization: Intel Corporation, Santa Clara, CA

On Oct 13th, 1992, The Independant Review Commission sent
out this VERY STRONGLY WORDED letter to Mr. Lewis Preston.

Preston went to lengths to persuade them not to write this.

I wonder if they have sabotaged their future as regards the
Bank. Men of integrity. of committment ...

This letter was leaked out. Here, ...

			Sardar Sarovar Projects
	                Independant Review





Oct 13, 1992


Dear Mr. President,

On June 18th 1992, we delivered the report of the Independant 
Review to you. This completed our task. As we said in our report,
the future of the Sardar Sarovar Projects is for India to decide; 
whether the Bank continues to support Sarar Sarovar Projects is
for the Bank to decide.

Nevertheless we feel that we have an interest in seeing that
our report is not misinterpreted. We have been deeply concerned 
therefore on reading the "Current Status and Next Steps" document, 
dated Set 11th, 1992, sent to the Executive Directors. We beleive 
that this "Next Steps" document, along with its Annexe, is misleading. 
It ignores or misinterprets the main findings of the Review.

Our report is extensive, detailed and technical. Given the many proj-
ects before the Bank we cannot expect you of the Executive Directors
to have the familiarity with the Sardar Sarovar Project issues  that 
we gained  durinf the course of our work. But we do want to ensure that 
the senior decision members of the Bank are not left with an account of 
our findings that is at variance with what we wrote.

It would therefore be a disservice to you and to the Executive Direc-
ctors to allow Next Steps to pass without apropriate comment.

Resettlement and Rehabitilation

The Next Steps documant ignores our conclusion that the Bank's
incremental strategy undermines prospects for acheiveing successful 
resettlement and rehabitilation. This conclusion is central to our 
report an bears on many of its findings. Next Steps not only ignores 
our conclusion on the failure of the incremental strategy, but even 
seeks to enlist our report in furthering the strategy. We beleive 
that unless the Bank recognizes tha failure of this incremental 
strategy, the well being of tens of thousands of people will continue 
to be at risk.

Our report pays careful attention to the very real differance 
between resettlement, on the one hand, and rehabitilation on the 
other.  A resettlement time table does not constitute a rehabitilation
plan. This issue is disregarded in the Next Steps statement.

This is not the place to go into the subject of resettlement and
rehabitilation at length, but it may be useful to illustrate the way in
which Next Steps purports to deal with resettlement issues without
addressing the problem obscured by its incremental strategy, i.e the
Bank's failure to adhere to its own requirements as set forth in its
Operational Directives and in the credit and loan agreements.

Gujarat: The Canal

Next Steps fails to make referance to the Gujarat government's
reluctance to deal fairly with the problem of the canal oustees.
Next Steps says that "only about 24,000 will lose more than 25%
of their land", but 24,000 families comes to al least 120,000
people. To assess the nature of the problem, and how to deal
with it is not a question of doing a quick survey between now and 
March 31st 1993 and purpoting that the new survey will be used to
devise a sound policy. The assessment of the canal impacts has not
been done; it needs to be done and will take time. Meanwhile the 
construction of the canal continues without adequate compensation
for those displaced. This was our point, and it seems to have been
ignored.

Madhya Pradesh: Land

Next Steps identifies some of the Madhya Pradesh problems of
both policy and implementation. MP is supposed to have come
up with plans to deal with these problems. These include provision 
of one hectare of land to landless oustees and the provision of
money in controlled bank accounts that can only be used for land
purchase. In this way a basis for rehabitilation is supposed to be
put in place, and the gap between Madhya Pradesh and Gujrat policies 
is said to be sufficently narrowed.

Our report explains that one hectare of land is inadequate; in 1979 
in India the Narmada Water Disputes Tribunal itself found two
hectares to be minimum. Our report also points out that cash 
cannot provide alternative comensation. Madhya Pradesh has been reluctant 
to make land available for its oustees, if only because it hopes that
they will go to Gujarat. Undertakings set out in the Next Steps
and designed to meet the Banks concerns, offer no more land and
indicates that the hope continues to be thatMP oustees who qualify for 
land will go to Gujarat. We beleive that the gap between Madhya
Pradesh and Gujarat policies are continuing, and that, as our report
explained, this erodes the right in choice by the oustees in MP.

There are many other examples we could give of ways in which the
resettlement and rehabitilation findings of our report are being
misrepresented or disregarded in Next Steps.

Environment

Next Steps omits any referance to those parts of our report
describing how the project continues to disregard the environ-
mental requirements of both India and the Bank.  Most of
these have been in place for a decade or more. To continue
to ignore these standards places the environment at risk. the risk 
becomes greater, the further along construction proceeds.

It is a non sequiter to suggest as Next Steps does, that delays 
in studies  have not yet resulted in "dire ecological impact" or 
"severe environmental consequences" as implied by our report. Of 
course, there has so far been no "dire ecological impact". The 
Sardar Sarovar Dam is yet to impound any water and the canal is not 
yet functional. Next Steps indifferance to the proper place and utility 
of environmental work is astonishing, especially given the Bank's
own undertakings as set out in the project documents and the Bank's
Operational Directives.

Pari-Passu andd Environmental Work Plan

On the environmental side, we found that the pari-passu principle - 
the idea that envitronmental impact studies would be done as
construction proceeds - undermines the prospect for acheiveing
environmental protection. Yet the substantive issues of environmental
planning and impact have been reduced in Next Steps to yet another
listing of studies - something that our review found was never lacking
and rarely meaningful. The Executive directors are invited 
to continue the pari paasu approach without any mention of the fact
that we found the pari passu approach had frustrated the meaningful 
defination of environmental impacts and the implementation of
appropriate mitigative measures. You will note that something
as basic as the Environmental Work Plan is still not available 
(legally required by the Bank before the end of 1985, and by 
India's 1987 conditional environmental clearance). Next Steps 
indicates that something will be available by January 1st, 1993.
It says that a plan is under consideration by the
Environmental Sub Group of the Narmada Control Authority." This
kind of "consideration" has been underway in one way or the other
to no avail for the last six years. As our report makes clear,
most of these were found to be seriously flawed. many were only
marginally relevant. Few will be of significance in developing
and implementing proper measuresa to protect the environment.
The way in which these are now placed before the Executive Directors
fails to take into account the substance of our work and is
misleading as to almost every component of the environmental
preperations in all three states.  the hydrology and seddimentation
issues as they are presented in Next Steps illustrates the point.

Hydrology

The executive directors are given assurance in Next Steps that the 
hydrology issues raised in our report have been addressed. This is 
not true. The data, it is said were "discussed at length with
specialists from the Independant Review". These " at length"
discussions consisted of consisted of three telehone conversations 
from July 30th to Aug 17th. During the  first call it was appearent
hat the person maing the call had no previous familiarity with the 
studies for the Sardar Sarovar projects, and that he had not read the
summary report prepared by our consultant and was unaware how our
analysis had incorporated daily streamflow data in a computer
assessment. In the second call he said that he was working
on a written reply for the Director of the Indian Department to be
sent to us on this subject. ( which we never received.) He had by
then read our consultant's report but he still did not have any
daily streamflow data to work with. He had mae incorrect assumptions
based on monthly or ten day averages and was speculating about the
possibility of leaving spillway gates open as the one way to meet some
of the concerns raised by previous oversights in the calculations. He
was tol by our consultant that the assume power and irrigation benefits 
would be shown to be wrong if proper calculations were made an he was
directe to the relevant sections of our consultant's summary report. 
During the third phone call he agreed that he could not get thro' to 
the heart of the matter without data. He still did not have the 
hydrologic data that we had used. From
what he said it was clear that the Bank had not done its 
own calculations.Our consultant told the Bank staff person that
the data and deailed information upon which we relied were
available if he contacted the office of the review. We never heard
from him again. 

Next Steps says that it agrees with the view in our report that the
hydrological information needs " to be periodically updated
to reflect changing conditions in the Narmada Basin". This is
misleading. What our report does say is that there are problems with
data, there are problems with the analyses done to date such that 
"there is no appropriate understanding of the hydrology of the Sardar 
Sarovar with or without tha Narmada Sagar". This has nothing to do with 
a periodic update. Our report says that a "comprehensive evaluation 
is needed including a complete systems analysis".  On these substantiv
ematters the Next Steps is silent.

Next Steps disagrees with our conclusion that the water delivary system
will not function as planned. It says that this is not supported by
the analysis done in India, an that the Bank staff concurs with these
analyses. These are he very analyses that we reviewed; we found that
they misconstrue the way in which the project will function. Without
their own assessmant, how can Next Steps dismiss what has been documented 
in  our report.

Sedimentation

Two sedimentation problems are raised in our report. The first
issue has to do with the deposition in the reservoir  generally.
The second and more serious problem deals with the build up of 
sediment which would form a delta at the upstream end of the reservoir.

Next Steps mentions only the sedimentation in the reservoir. It says
that "Bank staff reviewed the Indepenant Review's claims that the rate 
of sediment depletion in the reservoir has been underestimated." It goes 
on to say that the Bank does not know if the "claim" was based on any 
detailed review of the data and methodology of India's Central Water 
Commission. Yet on the phonecall to our consultant the Bank staff person 
was told that we had done the calculations ourselves based on the daily 
streamflow and raw data on sediment provided to us by India. Our report 
also states that we not only obtained the data and analyses from India's 
Central Water Commission, but that we also went to the Nigam and the 
Ministry of Water Resources for the best information they had. only  
As noted in our report, the experts we engaged were unable to replicate 
the results claimed by the project proponents. We explain why there is an 
error in what has been done by the others and suggest the likely order of 
magnitude of the underestimation.

Our report emphasizes that there is another compelling and immediate
problem related to seimentation - the backwater effect that will be caused 
by the build up of sediment in a delta at the upstream end of the resorvoir.
This sedimentation problem is not mentioned at all in  Next Steps. We had
calculations done to establish the general magnitude and position of this
delta related seimentation problem. There is nothing that the Bank or
India is roposing that will address this issue.

Next Steps ignores the fact that there has never been a proper environmental
impact assessment of the Sardar Sarovar Projects.  Because there was no impact
assessment we had to do an enormous amount of work that was not originally
seen to be part of our terms of referance in order to create a database.
In the rocess we uncovere data that has been overlooked or misrepresented
in the work done before for the Bank and India.


Concluding Observations

We are concerned that it has become necessary to write this letter. The 
bank may choose to reject our findings. India may choose to ignore our 
report. It is clear, however, that the Bank's Next Steps document has 
sought to present a version of our report that is at variance withe the 
report itself.

The findings in our report are based on project aprisal requirements
as well as human rights and environmental standards to which the Bank
and India have both subscribed. Yet Next Steps purports to give an 
account of our report without referring to the central iece of these
requirements and standards in our findings.

The Bank may reject our finding that its incremental strategy
has failed. the Bank may reject our findings that the pari paasu
approach is unsound. The Bank may decide tha overriding
political an economic considerations are so compelling that its
Operational Directives are irrelevant when decisions have to be 
made about the Sardar Sarovar Projects. But it should not seek
to reshape our report to support such decisions.

To properly address and correct Next Steps is a large undertaking
because it is so inaccurate in many respects. The examples provided
above are illustrative only. To set all this right on paper is
a task that would take more time than is available, and i may not
be efficent of effective to do so if it were to perpetuate a paper 
chase as a substitution for a frank dialogue supported with the careful 
analyses with which we sought to inform our report.

We find it surprising that apart from the phone calls on hydrology
mentioned earlier, no one from the Bank has called or written to
obtail any of the submissions, analyses or other documents referred
to in our report.

We are prepared to meet with you andd the Executive Directors if
you wish to discuss our report. We think it would greatly assist if
Mr. Gamble an Mr. Brody, who worked closely with us, and whose 
contribution we acknowledged in our report, were to attend such a
meeting

Our Review no longer has any formal existance. All of us have
returned to our private lives. We make this suggesstion, however, 
because we wish to preserve the integrity of the Independant review's 
findings.


Yours sincerely,


( Bradford Morse )				(Thomas Berger )
Chairman				        Deputy Chairman


cc Executive Directors
   The World Bank