JAMMU: A performance audit of Jammu and Kashmir by the Comptroller and Auditor General of India (CAG), covering the period 2017–18 to 2021–22, which noted that 697 natural lakes, of which 315 have disappeared and 203 have shrunk, erasing thousands of hectares of water spread, has flagged a major systemic failure.
Jammu and Kashmir has no law dedicated to protecting them, no single authority responsible for their conservation, and active conservation programmes for only six.
A Draft Law Ignored for Over 22 Years
The report's most damning institutional finding concerns a piece of legislation that was never passed. A draft bill to establish a dedicated Development and Regulatory Authority for lake conservation was prepared in April 2000 by the J&K Lakes Conservation and Management Authority. Due to what the CAG describes as "the indifferent approach of Government of J&K,” the proposed legislation had not been approved as of March 2022, marking a lapse of over 22 years.
In the absence of this law, responsibility for 697 lakes is fragmented across five departments: Forest, Revenue, Agriculture, Housing and Urban Development, and Tourism. The Forest Department was formally assigned responsibility for all 697 lakes in October 1989.
In practice, administrative control of 402 lakes is vested with District Commissioners, and six lakes were transferred between 1997 and 2012 to three separate Development Authorities. The CAG found that this arrangement produced "diffused functions across various institutions, inadequacies in institutional arrangements for discharge of environmental functions related to Lakes, lack of cross-sectoral institutional convergence, monitoring and evaluation."
Nine Institutions, All Falling Short
The CAG examined nine institutions with responsibilities relating to lake conservation and found inadequacies across all of them.
The Ecology, Environment and Remote Sensing Department (EE&RSD) was assigned in October 1989 to conduct a detailed survey of all 697 lakes, study their physical, chemical, and biological dynamics, and prepare development plans for each.
It stated in February 2021 that it was "deficient in technical manpower such as environmental and hydrological engineers, ecologist, limnologists, biologists, remote sensing and GIS specialist," and that proposals for manpower resources had been submitted to the Forest Department "time and again (latest in August 2019)."
EE&RSD further stated it did not have "a laboratory and technical wing for devising strategy for planned development and maintenance of Lakes." The CAG noted that EE&RSD had failed to carry out the detailed survey of 697 lakes, and that development plans had been prepared "only in respect of six Lakes."
The UT Wetland Authority (UTWA), established in November 2020, was required to meet at least three times a year. It held its first meeting in March 2021, more than a year after its establishment. It set a timeline between April and July 2021 for preparing geographic delineation documents for 12 lakes.
No such document had been prepared as of March 31, 2022. No posts or staff had been sanctioned for UTWA by the government. The CAG concluded that "J&K UTWA had remained non-operational" and noted with dismay that the UTWA’s reasoning of delays due to Covid were “not convincing” as all government business continued during this time with standard protocols.
The J&K Biodiversity Board (BDB) was established in February 2013, over 11 years after the Biological Diversity Act, 2002 was enacted. Board members appointed in February 2013 for two years were not replaced for over three years up to August 2018. After reconstitution in September 2018, the Board met only twice up to December 2020, and even then discussed only staff and budget matters rather than biodiversity policy.
The BDB had not carried out any survey of biodiversity in respect of any of the 697 lakes, had not created the mandatory Biodiversity Fund, and its affairs were being run by staff of the Director, Research Institute of Forest.
The J&K Pollution Control Board conducted water quality testing in only five of the 697 lakes — Dal, Surinsar, Mansar, Hokersar, and Wular — and even those tests were confined to physico-chemical parameters only, with no testing for zooplankton or phytoplankton. It had not prepared plans or programmes for prevention and control of water pollution in lakes, as mandated under the Water (Prevention and Control of Pollution) Act, 1974.
The Principal Chief Conservator of Forests, holding jurisdiction over 255 lakes, had prepared no comprehensive conservation or management programme for any of them. Divisional Forest Officers from Lidder, Kulgam, Mahore, and Bhaderwah divisions stated in February 2021 that the Forest Department "did not have clear responsibility for Conservation and Management of Lakes and that due to lack of technical/scientific manpower and laboratory, the Conservation and Management of Lakes could not be carried out."
The Rakhs and Farms Department, in violation of Wetland Rules 2010 and 2017, transferred land appurtenant to three lakes — Rakh-i-Rabtar, Gangbug, and Rakh-i-Arth — measuring 712.30 hectares to other departments for construction activities. A further 210 hectares were under transfer as of March 2022. These transfers caused shrinkage of the affected lakes and the complete disappearance of Gangbug Lake.
The Water Resource Regulatory Authority (WRRA), established in October 2012, saw its first committee lapse in October 2015 and a second appointed in October 2017, after a gap of over two years. When the committee met in July 2019, it discussed conservation works for Wular Lake only, rather than all 697 lakes as required under the Water Resources (Regulation and Management) Act, 2010.
No plans were prepared for protection of water sources or prevention of encroachment on water bodies.
The Forest Department and other departments were found to have themselves constructed roads through the lake areas of Hokersar, Rakh-i-Arth, and Devpursar, in contravention of the Wetland Rules and the Environment (Protection) Act.
518 Lakes Diminished or Gone
The consequences of this dismal performance are documented in satellite data. Analysis of records from EE&RSD, using 1967 as the base year, with 2014 as the reference for Kashmir Division and 2020 for Jammu Division, revealed that 315 of J&K's 697 lakes, with a total water area of 1,537.07 hectares, had completely disappeared. A further 203 lakes had experienced a decrease in water area of 1,314.19 hectares.
In total, 518 lakes, 74 per cent of J&K's total, had either disappeared or shrunk. (Pages 8–9, Table 2.1)
Among the 63 lakes selected for detailed examination by auditors, a sample covering 87 per cent of total lake area, 11 had completely disappeared and 30 had experienced reductions in water area. Of these, four had lost more than 50 per cent of their water extent, placing them at risk of extinction. (Pages 10–11, Table 2.3)
When auditors plotted the GPS coordinates of 63 sampled lakes on Google Earth Pro in October 2022, seven were either no longer visible or had almost dried up: Rakh-i-Arth, Sethergund Numbal, Marhama, Devpursar, Mahtan, Chandargar Numbal, and Galwal Talao.
Physical verification with tehsildars confirmed these lake areas were covered with weed, plantation, and vegetation, and that roads had been constructed through them.
Analysis of remote sensing data for 63 test-checked lakes between 2014 and 2020 showed that open water area had decreased by 2,003.52 hectares, a 25 per cent reduction, while built-up area within lake zones increased by 116 per cent, and agriculture, horticulture, and plantation expanded by 19 per cent.
In 10 of 48 test-checked lakes located outside forest areas, 765.30 hectares of water area had been transferred by District Administration to government departments for construction of residential quarters, office buildings, universities, and schools. Encroachments were reported in 39 of those 48 lakes.
In five lakes where the extent was quantified, 712.55 hectares of lake area had been encroached upon by construction of roads, structures, plantation, and paddy fields. No action had been taken to clear these encroachments.
Only 1% of Budget for Six Lakes
Of the 697 lakes in J&K, the government had conservation and management programmes for only six: Dal, Wular, Hokersar, Manasbal, Surinsar, and Mansar. For the remaining 691, the concerned departments had neither identified eligible lakes nor formulated any plans to access central government funding available under the Ministry of Environment, Forest and Climate Change.
Not a single lake in J&K had been delineated, demarcated, or formally notified under the Wetland Conservation and Management Rules. Of 295 lakes falling within forest areas, only 14 had been notified by the Forest Department, and those notifications dated to 1945 and 1981. The 402 lakes outside forest areas had no notification at all.
Across the 63 test-checked lakes, the CAG found: water carrying capacity had not been evaluated in any of them; water budgeting had not been carried out in 62; no flushing system was in place in 62; the expected life of the lakes and sediment accumulation rates had not been evaluated in 62; de-weeding and dredging had not been carried out in 57; no public awareness programmes had been held in 62; and no research studies had been carried out by the concerned authorities in 62.
Sewage was entering 50 of the 63 test-checked lakes without any treatment. Of these, sewage from 0.91 lakh households, with a human population of 4.55 lakh and animal population of 2.75 lakh, was entering 34 lakes. In 29 of these, 69 identified source-point pollution locations were confirmed. The J&K Pollution Control Board took no action against violators of environmental laws causing pollution in the lakes.
The funds allocated to conservation during 2017–22 for all six detailed-checked lakes amounted to ₹560.65 crore, approximately one per cent of J&K's total CAPEX disbursement of ₹50,228.11 crore during the same period. No funds were allocated for the remaining 691 lakes.
Open Water Falling, STPs Malfunctioning
Even Dal Lake, described in the report as the "liquid heart of Srinagar", and among the most beautiful national heritage sites of the country, tells a troubled story despite decades of directed conservation effort.
Between 2007 and 2020, the open water area of Dal Lake fell from 15.405 sq. km. to 12.907 sq. km, a decrease of 10.15 per cent of the total area of the lake, while floating vegetation expanded from 5.262 to 6.796 sq. km. and built-up area grew from 0.743 to 1.025 sq. km.
The lake was included under the National Lake Conservation Programme (NLCP) in September 2005 with a project approved at ₹298.77 crore, with a target completion date of 2010. That date was extended multiple times. The project had not been completed as of March 2022.
Despite the project having been sanctioned in September 2005, no Project Management Consultant had been appointed by LC&MA as of December 2022, over 17 years later.
Five Sewage Treatment Plants were installed at a cost of ₹45.01 crore. The report found they were not treating sewage to the required parameters. Ammoniacal nitrogen, required to be removed at a rate exceeding 90 per cent, was being removed at only 14 to 65 per cent across the five plants. Nitrate nitrogen showed an average increase ranging from 13 to 161 per cent.
One research paper cited in the audit found that the STPs were "not only malfunctioning but are exacerbating the problem of Lake pollution."
A Vision Document for land acquired from Dal Lake dwellers, ordered by the High Court in August 2013, had not been finalised as of December 2022. ₹1.26 crore paid to IIT Roorkee for its preparation had produced no approved output.
The CAG noted this constituted unproductive expenditure, and that 2,299 kanals of land already acquired could neither be added to the lake's water area nor developed as planned.
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