UPSC Darpan

Environment & EcologyGS326 September 2026

Expert Panel Recommends Clearance for 1,605 MW Subansiri Upper Dam Despite 1,35,733 Trees Marked for Felling

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The news

New Delhi. The Expert Appraisal Committee (EAC) of the Union Environment Ministry has recommended environmental clearance for the Subansiri Upper Hydroelectric Project (SUHEP), a run-of-the-river project on the Subansiri basin in Arunachal Pradesh, even as it expressed concern over the felling of a “substantial” number of trees, The Indian Express reports from the minutes of the EAC meeting. An environmental clearance is the Centre’s permission for a large project to proceed after its effects on air, water, land and people are studied. The final clearance will be subject to a Stage-1 forest clearance — an in-principle approval given by the Centre under the Forest Conservation Act — because the project requires the diversion of 2,733 hectares of forest land and the felling of approximately 1,35,733 trees. The EAC observed that the felling may affect forest structure, habitat continuity, biodiversity, wildlife movement and associated ecosystem services, and advised the project proponent, National Hydroelectric Power Corporation Limited (NHPC), to prepare a comprehensive, site-specific and time-bound Ecosystem Restoration and Biodiversity Management Plan. Compensatory afforestation — new planting to make up for forest lost — has been proposed across as many as 14 districts of Madhya Pradesh, on about 5,466 hectares of degraded forest land. Normally, an equivalent patch of non-forest land must be found locally, but since Arunachal Pradesh already has high forest cover, Ministry guidelines allow it to meet the obligation on non-forest land in lower-cover States; where no equivalent non-forest land is available, the Act requires a plantation twice the size of the diverted land on degraded land. The Indian Express had reported in February that until February 2026 Arunachal Pradesh had not complied with compensatory afforestation conditions for the Subansiri Lower project, also built by NHPC downstream, and the Ministry had sent six reminders. The standing committee of the National Board for Wildlife had cleared Subansiri Lower on condition that no upstream projects would follow, but the Supreme Court modified this on Arunachal Pradesh’s plea; its August 2009 directive says any upstream proposal “would be considered independently on its own merit by the Standing Committee”. The EAC noted assessments of glacial lake outburst flood discharge, peak flood discharge and dam-breach impacts on Subansiri Lower. Power generation and flood moderation are the stated objectives of the 1,605 MW plant near Menga, which envisages a 237 m-high storage dam. The syllabus link is GS3 on infrastructure, conservation and environmental impact assessment.

The chain in one line: Arunachal Pradesh’s steep, high-discharge rivers draw a push for hydropower → Subansiri Lower cleared on condition of no upstream dams, then the Supreme Court in 2009 allows upstream proposals to be judged on their own merit → Arunachal Pradesh still has not met compensatory afforestation conditions for Subansiri Lower by February 2026 → NHPC seeks clearance for the 1,605 MW, 237 m Subansiri Upper project needing 2,733 ha of forest → EAC recommends environmental clearance, leaving forest clearance and compensatory afforestation in Madhya Pradesh as the next test

Static syllabus linkage

  1. The EIA Notification, 2006 sends large hydropower projects to the Centre’s Expert Appraisal Committee. The Environment Impact Assessment Notification, 2006, issued under the Environment (Protection) Act, 1986, classifies projects into Category A, appraised by the Centre, and Category B, appraised by State-level authorities. River valley projects with hydroelectric capacity of 50 MW or more fall in Category A and are examined by a sectoral Expert Appraisal Committee, which recommends grant or rejection to the Ministry. The process runs through four stages: screening, scoping (fixing the terms of reference for the study), public consultation and appraisal. The EAC’s recommendation is advisory; the clearance itself is issued by the Ministry, often with conditions.
  2. Forest clearance is a separate, two-stage approval under the 1980 forest law. Section 2 of the Forest (Conservation) Act, 1980 requires the Central Government’s prior approval before forest land is used for any non-forest purpose. In practice approval comes in two stages: Stage-1 is in-principle approval with conditions such as compensatory afforestation and payment of the net present value of the forest, and Stage-2 is final approval once those conditions are met. The 2023 amendment renamed the law the Van (Sanrakshan Evam Samvardhan) Adhiniyam, 1980, and exempted certain categories such as strategic linear projects within 100 km of international borders. The amendment’s narrowing of which land counts as ‘forest’ has been challenged before the Supreme Court.
  3. Compensatory afforestation money is held in statutory funds. The Compensatory Afforestation Fund Act, 2016 created a National Compensatory Afforestation Fund and a State fund for each State in the public accounts, into which user agencies deposit money for compensatory afforestation and the net present value of diverted forest. Most of the money collected for a State goes to that State’s fund, with a smaller share to the National Fund, and it is administered by authorities known as CAMPA. The general rule is afforestation on equal non-forest land, or on degraded forest land of twice the area where non-forest land is not available. Critics have long argued that a young plantation elsewhere cannot replace the ecological functions of an old, contiguous natural forest.
  4. The Subansiri is the Brahmaputra’s largest tributary and runs through a seismically active, glaciated basin. The Subansiri rises in the Tibetan Himalaya, flows through Arunachal Pradesh and joins the Brahmaputra in Assam, and is its largest tributary by discharge. The region lies in the highest seismic zone and has many glacial lakes, which is why glacial lake outburst floods (GLOFs) — sudden releases of water when a moraine or ice dam holding a glacial lake gives way — are now part of dam appraisal. The October 2023 GLOF from South Lhonak lake in Sikkim destroyed the Chungthang dam of the Teesta-III project, showing how a single event can cascade down a river with several dams. Run-of-the-river projects use the river’s flow with limited storage, whereas storage dams hold large volumes behind high walls.

Why UPSC loves this

  1. GS3 pairs infrastructure with environmental impact assessment. The syllabus lists infrastructure (energy) alongside conservation and EIA. Mains questions have asked about the EIA process’s weaknesses, the environmental costs of Himalayan hydropower, and disasters such as the Chamoli and Sikkim floods. A single project with numbers for forest area, trees and afforestation lets a candidate make those arguments concretely.
  2. Prelims tests the institutions in the clearance chain. UPSC has asked about the National Board for Wildlife, the CAMPA framework, and which projects need Central environmental clearance. The EAC, Stage-1 and Stage-2 forest approvals and the rule of twice the area on degraded land are all direct statement material.
  3. The Northeast’s hydropower is also a strategic and water-security question. China’s dam building on the Yarlung Tsangpo upstream has led India to push projects in Arunachal Pradesh for power and as a buffer, as seen in the Siang Upper project carded on September 24. Questions on India–China relations and water security in the Brahmaputra basin can draw on the Subansiri projects as evidence.

Prelims nuggets

  • Under the EIA Notification, 2006, river valley projects with hydroelectric capacity of 50 MW or more are Category A projects appraised at the Central level by an Expert Appraisal Committee.
  • The four stages of environmental clearance under the EIA Notification, 2006 are screening, scoping, public consultation and appraisal.
  • Section 2 of the Forest (Conservation) Act, 1980, now titled the Van (Sanrakshan Evam Samvardhan) Adhiniyam, 1980, requires prior approval of the Central Government for diversion of forest land for non-forest purposes.
  • When non-forest land is not available for compensatory afforestation, plantation is required on degraded forest land of twice the area diverted.
  • The Compensatory Afforestation Fund Act, 2016 established a National Compensatory Afforestation Fund and State Compensatory Afforestation Funds in the public accounts.
  • The National Board for Wildlife is constituted under the Wild Life (Protection) Act, 1972 and is chaired by the Prime Minister.
  • The Subansiri, which rises in Tibet and flows through Arunachal Pradesh into Assam, is the largest tributary of the Brahmaputra.

Analysis

  1. Planting in Madhya Pradesh to replace a forest in Arunachal Pradesh compensates the national accounts, not the ecosystem. The EAC itself lists what the felling will damage: forest structure, habitat continuity, wildlife movement and ecosystem services in the Subansiri basin. A plantation on 5,466 hectares of degraded land in 14 districts of Madhya Pradesh restores none of these locally; it only restores a number in the national forest-cover tally. The rule allowing high-cover States to afforest elsewhere was a practical answer to land scarcity, but in a biodiversity hotspot it converts a local loss into a paper gain. The counter-view is that Arunachal genuinely lacks non-forest land and that a well-run plantation in central India still sequesters carbon, which is a real, if different, benefit.
  2. The Subansiri Lower record is the best predictor of how Subansiri Upper’s conditions will be met. The Indian Express reports that compensatory afforestation conditions for the downstream project were still unmet in February 2026 after six reminders. A clearance regime that grants new approvals while earlier conditions remain unfulfilled signals that conditions are negotiable. The EAC’s demand for a time-bound Ecosystem Restoration and Biodiversity Management Plan is sensible, but its value depends on monitoring and penalties, which the clearance system has historically lacked. The Ministry could make compliance on the earlier project a precondition for Stage-2 approval of the new one.
  3. A 237 m ‘run-of-the-river’ storage dam is a contradiction the appraisal should resolve. The report describes the project both as run-of-the-river and as envisaging a 237 m-high storage dam for flood moderation. Run-of-the-river projects are usually presented as low-impact because they store little water, but flood moderation requires storage, and storage changes downstream flows, sediment and fisheries. The distinction matters for Assam, where downstream communities opposed Subansiri Lower precisely over altered flows and dam safety. The appraisal should state plainly how much water the reservoir will hold and how releases will be managed in the lean season and in floods.
  4. Project-by-project clearance cannot capture what a chain of dams does to a river. The Supreme Court’s 2009 direction to judge upstream proposals ‘on its own merit’ was meant to be fair to each project, but rivers do not work project by project. With Subansiri Lower downstream and more projects planned across the basin, the relevant question is the cumulative effect on flows, sediment, fish migration and flood risk. The EAC has taken a step by assessing dam-breach effects on Subansiri Lower and GLOF discharge, which is more than many appraisals do. A basin-wide carrying-capacity study, updated before each new dam, would make that step systematic rather than occasional.
  5. The case for the dam is real and should be stated honestly. The Northeast has large untapped hydropower potential, hydropower is a firm, non-fossil source that can balance solar and wind, and a storage dam can moderate floods in Assam. There is also a strategic argument given China’s dam building upstream on the Yarlung Tsangpo. None of this makes 1,35,733 trees irrelevant; it means the trade-off should be made openly, with the costs to forests and downstream communities priced in and the benefits delivered, rather than hidden behind the language of compensation.

Possible Mains question

“Large hydropower projects in the Eastern Himalaya are appraised one at a time, while their impacts accumulate across the river basin.” Critically examine this statement with reference to the Subansiri projects in Arunachal Pradesh, and suggest reforms to India’s environmental and forest clearance process. (15 marks, 250 words)

Model approach

  1. Introduction. State that the Environment Ministry’s Expert Appraisal Committee has recommended environmental clearance for NHPC’s 1,605 MW Subansiri Upper project, which requires 2,733 ha of forest and the felling of about 1,35,733 trees, with a 237 m-high dam near Menga.
  2. Body — the clearance chain. Explain Category A appraisal under the EIA Notification, 2006, the two-stage forest clearance under the Van (Sanrakshan Evam Samvardhan) Adhiniyam, the compensatory afforestation rules and the CAF Act, 2016, and the role of the National Board for Wildlife.
  3. Body — the cumulative problem. Use the NBWL’s original no-upstream-projects condition, the Supreme Court’s 2009 modification, the unmet afforestation conditions on Subansiri Lower, and the GLOF and dam-breach assessments to show how basin-level risks are handled piecemeal. Mention the Teesta-III destruction of 2023 as an example of cascade risk.
  4. Body — reforms. Propose mandatory basin-wide cumulative impact and carrying-capacity studies, afforestation within the same landscape wherever possible, compliance on earlier projects as a condition for new approvals, independent post-clearance monitoring, and genuine consultation with downstream communities in Assam.
  5. Conclusion. Conclude that India’s energy transition needs Himalayan hydropower, but its legitimacy depends on appraising rivers as systems and on enforcing the conditions attached to clearances.

Administrator's brainstorm

You are the Deputy Commissioner of a district in Assam downstream of the Subansiri projects. Residents fear sudden water releases. What steps do you take?

I would ask NHPC and the State Water Resources Department for the dam’s release protocol and insist on a written early-warning system with sirens, SMS alerts and village-level contact points. I would include dam-release and dam-breach scenarios in the district disaster management plan and hold mock drills with the District Disaster Management Authority. I would also set up a grievance channel for fishers and farmers affected by changed flows. Communities trust a dam more when they know exactly what will happen and when.

As the Member Secretary of the Expert Appraisal Committee, how would you handle a proponent whose earlier project has unmet clearance conditions?

I would place the compliance report of the earlier project before the committee as part of the new appraisal. I would recommend that final approval for the new project be linked to demonstrable progress on the pending conditions, including compensatory afforestation. I would specify measurable milestones in the new clearance, with periodic compliance reports reviewed by the Ministry’s regional office. Clearances lose credibility when conditions are routinely ignored without consequence.

An interview board asks: is it right to fell over a lakh trees in Arunachal Pradesh for hydropower when India needs clean energy?

Both goals are legitimate, so the question is how the trade-off is made. Hydropower gives firm, low-carbon electricity and flood moderation, but old-growth Himalayan forest and downstream river systems cannot be recreated by planting elsewhere. I would support the project only if cumulative impacts are studied, the design minimises forest loss, restoration is done as close to the site as possible, and downstream communities are protected. Clean energy that destroys a biodiversity hotspot without full accounting is not truly clean.