Guest post: Ramaswamy R Iyer

This is in response to the comments made by Rahul Banerjee (“National Water Policy”, 13 August 2011) and Chetan Pandit (“Alternative National Water Policy: A Critique”, 10 September 2011) on my article “National Water Policy: An Alternative Draft for Consideration” (25 June 2011).

Epigrammatic Style

I have no serious disagreements with Rahul Banerjee, but I offer a few clarifications here. Rahul Banerjee has observed that some important matters are referred to late in the policy draft. The order in which issues or aspects appear in the Alternative National Water Policy (ANWP) does not indicate their relative importance. Data and information are, of course, relevant and important for several of the other sections, but instead of repeated references in several sections, data and information are discussed fairly elaborately in one section, which necessarily had to come at the end after all the physical and other aspects had been dealt with.

High consumption, high demand for water, waste: these are referred to not merely in the section on water pollution, but also in the Sections 5 and 6.

Rahul Banerjee wishes that some issues had been discussed more elaborately. That would have made the policy document much longer. Besides, I deliberately adopted an epigrammatic and not a discursive style. I thought that this would be the appropriate style for a policy document as distinguished from an essay or academic paper.

Not ‘My Axiom vs Yours’

I am grateful to Chetan Pandit (CP) for taking the trouble of commenting in detail on my draft policy. It is not for me to question his overall adverse judgment on it. I leave it to the readers to form their own views. However, there are some specific points that I must answer.

(1) I had clearly stated that I was not putting forward a programme or action plan or strategy, but CP faults the policy draft precisely on that ground. I wish he had made an effort to understand what was being attempted and why.

In our quasi-federal system, there could be some differences of policy and principle in relation to water among the States, but a degree of convergence seems desirable. The recognition of a need for a national consensus on certain basic aspects and issues relating to water led to the National Water Policies of 1987 and 2002; and my draft policy belongs to that lineage, but is offered as an alternative to the official draft under preparation,  because it is driven by the feeling that a transformation in our thinking about water is called for. Once a national consensus on basics is brought about, strategies, programmes, action plans, etc, at the central, state and local levels, can follow; and these must be governed by the policy.

(2) That explains the absence of numbers in the policy draft, which in CP’s view is a grave defect. The starting point of the policy draft was a diagnosis of past and present ills, of which a summary statement is given in Section 1. It was not my diagnosis but the gist of what many commissions and committees have said in their reports over the years. All the numbers that one might want will be found in those reports. Incidentally, there can be both rigorous and non-rigorous thinking with numbers and without numbers. I venture to claim that the draft policy is a rigorous document.

(3) It is not a question of “my axiom versus yours”; I was not putting forward a set of dogmas, but making statements that were definitional and/or likely to find a resonance in many minds. I was also stating certain propositions that had been forgotten or ignored, but would be instantly recognised once they were stated. For instance, when I say “a river must flow; if it does not flow, it is not a river” it is both a definitional statement and one that is likely to be widely accepted; and it is meant to remind us of a truth that we have forgotten. When CP offers the counter-statement that a river is not a river if it does not feed a reservoir or provide water for irrigation, it is neither a self-evident statement nor one that will be widely accepted.

(4) When he says that “there are many instances all over the world, including many in India, where rivers have been turned in different directions, yielding huge benefits, and no calamity has befallen” (my italics), he takes my breath away. I refrain from comment. Let me merely say that there is plenty of material on what human intervention has done to rivers. I cannot give a reading list here.

(5) CP refers to my “ideological” approach. I put ecology, social justice and harmony first, subordinating engineering and economics to that triad. If that is “ideology”, so be it. May I add that putting engineering and economics first is also ideology.

(6) CP seeks to educate me on hydrology. I am not a hydrologist or an engineer but have indeed heard of the concepts hydrological cycle and hydrological unity, and of the distinction between consumptive and non-consumptive uses of water. What follows? That economy in non-consumptive water use is of no consequence? CP himself does not say so.

The fact is that water returned to the hydrological cycle after non-consumptive use is not always readily  accessible or usable, though efforts need to be made to recover and use as much of that water as possible. Despite such efforts, a part of that water will be virtually unavailable for further use.

Economy in non-consumptive uses of water is therefore not meaningless. It makes sense to talk of reducing the agricultural, industrial, municipal or domestic demand for water. All over the world thinkers have been pointing to the looming water crisis and urging improvements in water use and resource-conservation.

Why do they do so if nothing that we do is going to affect total demand? If indeed we simply cannot restrain the growth of demand for water, and if CP’s hydrology tells us that it is not important that we should do so, then I have nothing further to say.

Quantity and Quality

(7) CP says that with industrial use, the problem is not one of quantity but of quality. I should have thought that it was both. In Plachimada, Palar and Tirupur, both quantity and quality issues have figured. It is not necessary to argue this, because industries themselves in many cases are aiming at a long-term goal of both zero effluent and zero net water budget.

(8) CP considers the idea of large projects as projects of the last resort nebulous and ill-defined. It is, in fact, quite simple. What I meant was that in each case the objective should be clearly formulated, all available options to meet that objective identified, and a large project chosen if it is the unique option or the best available option in a given case. Of course, dubious efforts may be made to prove that the proposed option is in fact the best option in a given case, but a good, rigorous appraisal procedure will take care of this.

(9) CP has completely misunderstood the proposal of a professional, independent environment impact assessment (EIA). He assumes (in knee-jerk fashion) that by “independent” I mean “independent of the Government” and magisterially pronounces that “civil society lingo” unacceptable. Once again, I have to say “Understand before you pass judgment”. (May I add that while he is free to disagree and criticise, impolite language is, in his own words, unacceptable?) “Independent” in the EIA context means “independent of the proposers, approvers and implementers of projects”. What I had in mind was the following. If an EIA profession is instituted with a statutory charter, a professional council, a code of conduct, etc, as in the case of medicine or chartered accountancy; if the (proposed) National Environment Protection Agency (NEPA) maintains a panel of approved EIA agencies (on the analogy of the panel of charted accountants maintained by the comptroller and accountant general for nominating auditors to public enterprises) and nominates an agency for doing the EIA in each case; if payment to the EIA agency is made after approval by the NEPA; and if NEPA maintains quality control; then we will have objective EIAs of good quality.

(10) CP repeats the familiar statement that there will be more evaporation from a large number of small storages than from one large reservoir. I have heard this many times over the years but it is not a self-evident proposition. Let me put forward, in a tentative, exploratory spirit, a different hypothesis for consideration. The estimated “available” water resources (1953 BCM of surface water + 436 BCM of groundwater, according to the National Commission on Integrated Water Resource Development Plan – there may be some double counting here) are substantially lower than the precipitation over the Indian landmass (4000 BCM) because of evapotranspiration. (The late T N Narasimhan thought that we were underestimating evapotranspiration and overstating the availability of water.) However, the available surface water flows are measured at certain points of river systems, after evaporation has taken place over a part of the length of the river and from the reservoirs that exist on the river. (There will also be evaporation from the canals flowing to considerable distances from the reservoirs.) Instead of a few large centralised reservoirs, if we were to capture the rainwater extensively in a decentralised manner at earlier points (i e, as the rain falls, or at early points of the run-off) would not the loss by evaporation be less?

On the other hand, capturing the rain as it falls may slightly reduce the runoff to the river. Taking both factors into account, would we perhaps be able to achieve some net additionality? (Kanchan Chopra and Biswanath Goldar estimated “additional runoff capture” at 140 BCM.) This hypothesis may turn out to be untrue, but perhaps some work on this required. When I put this possibility to Narasimhan, he was not dismissive; he thought that there could be something in it.

Minimum Flows

(11) With reference to “minimum flows”, CP says: “Whether a maximum is prescribed for abstraction, or a minimum is prescribed for river flow, it amounts to allocation of water to the environment”. In terms of numbers the two approaches may yield the same figure, but there is a world of difference between (a) thinking of abstraction as the norm and leaving water in the river as an unfortunate necessity, and (b) thinking of natural flows as the norm and abstractions as interventions to be carefully and minimally resorted to. Similarly, there is a world of difference between (a) giving primacy to ecology (nature) that gives us water, and (b) thinking that we should put our “demands” first and then “allocate” some water to nature. It seems to me that the way we think is a matter of some importance. CP may not agree.

(12) CP says: “At any point of time, there exists a land acquisition and rehabilitation policy, and also relevant laws. There is no justification for a separate policy for water resources projects...” (p 79). I entirely agree. The idea is not to prescribe a separate land acquisition (la) and rehabilitation policy for water projects, but to bring in the elements of the LA and rehabilitation and resettlement (RR) policies by reference. Section 17.9 of the draft mentions the various laws and policies that will govern water resource projects. If the LA and RR Bill gets enacted by the time the new national water policy is approved, reference will have to be made to that Act, and of course, the two will have to be harmonised.

(13) With his last sentence (“The targets should determine the policy, and not the other way round”) (p 79) I do not agree at all. Without certain assumptions and principles, we cannot set targets. There are implicit policies behind targets. What we need to do is to make them explicit and change them where necessary. That is what the ANWP has tried to do.

Ramaswamy R Iyer (ramaswamy.iyer@gmail.com) is with the Centre for Policy Research and has written extensively on issues related to water.

Related content:

Alternative National Water Policy by Ramaswamy R Iyer - A critique by Chetan Pandit in EPW

Alternative National Water Policy by Ramaswamy R Iyer – Comments by Rahul Banerjee

National Water Policy - An alternative draft for consideration by Ramaswamy R Iyer in EPW