Sagar Samel

Before Pune Flooded in July, On 27 May i had emailed the commissioner Shri @navalMH Naval Kishore Ram, his bosses the PMO and the CM @Dev_Fadnavis along with the Principal Secretary MOEF, @SVYadwadkar and some other volunteers amongst us. This was about the risks of the RFD and what it poses to a city like Pune. A technical document which evidences the scientific and hydrological inconsistencies of this project was also attached, it can be made available to whoever wants to see it, DM me. The full text of the email is as below. To, The Municipal Commissioner, Pune Municipal Corporation Shivajinagar, Pune – 411005 Date: 27 May 2026 Subject: Serious Hydrological, Hydraulic and Public Safety Concerns Regarding Pune Riverfront Development (RFD) Project Sir, I write to formally place on record grave concerns regarding the hydrological and hydraulic basis of the ongoing Pune Riverfront Development Project and to call attention to apparent negligence in proceeding with large-scale river channelization and associated civil works despite substantial technical uncertainties and unresolved flood-risk issues documented within the project’s own reports. Felling trees is killing the climate resilience of the city. The recent hearings only show that the administration wants to ride roughshod over established science and the will of the intelligent people in Pune who have established through scientific enquiry that this project will prove to be a disastrous endeavour. None of the SEIAA and SEIAC clearances have been completed or adhered to, all data of their respective compliance has been withheld. The floodlines were to be freshly demarcated in light of the new rainfall data, that’s not done either. Your own municipal corporation established a committee which published a study report after analysing the after effects of the past floods under your predecessor and that’s been conveniently ignored. The Hydrology and Hydraulics Report dated 19 January 2018 itself admits a “serious lack of adequate and authentic data” relating to historic flood levels and observed flood profiles, further acknowledging that the studies relied upon assumptions “which could not be verified for authenticity.” Proceeding with irreversible river engineering interventions in a densely populated urban area despite such admitted data deficiencies raises serious concerns regarding public safety, administrative prudence, and compliance with established engineering standards. The MERI & TERI study data and predictive analysis hasn’t been incorporated into the work on ground. That said, there is nothing to establish that change in cross sectors along the run of the river hasn’t been done. It’s within plain sight that this will become an unmitigated disaster of epic proportions as so much water which otherwise the floodplains used to carry will now remain within the city. Further, the “your HCP consultants” report acknowledges the absence of reliable gauging data for the Mula and Mutha rivers individually, while the Bund Garden gauge data used extends only up to approximately 2014, despite rapid urbanisation and increasing climate-induced extreme precipitation events thereafter. 100 mm plus rainfall.  The use of outdated hydrological datasets for a project of this magnitude appears fundamentally inadequate. The project documents additionally state that the Riverfront Development is “not a flood control scheme,” and that it is only expected not to aggravate existing flood conditions. However, channelization and embankment modifications undertaken without robust contemporary hydrological validation inherently carry the risk of amplifying flood velocities, altering floodplain behaviour, and transferring flood risk downstream. Several serious technical discrepancies also arise from the project’s own HEC-RAS outputs and design assumptions, including: Apparent inconsistencies in upstream and downstream water surface elevations between disconnected model reaches; Selection of lower 100-year flood discharge estimates despite higher estimates being available from alternative methods; Failure to demonstrate goodness-of-fit validation for adopted statistical flood-frequency methods; Apparent failure of the adopted Gumbel distribution under Anderson-Darling goodness-of-fit testing for Mula-Mutha discharge estimation; Absence of any visible risk analysis assessing probable loss of life, flood damages, or consequences of hydraulic failure in a densely populated urban region; Failure to properly incorporate climate-change amplification effects into design flood calculations despite acknowledging such impacts; Reliance upon freeboard assumptions in lieu of revised hydrological design standards. These concerns assume even greater seriousness in light of IS 5477 (Part IV), which explicitly requires a very high degree of safety where failure may result in loss of life and widespread property damage. In view of the above, you are requested to: Immediately suspend all further river channelization, embankment modification, and tree-felling activities connected with the RFD project until an independent technical review is completed; Constitute an independent expert committee comprising hydrologists, flood-risk experts, IIT/NIT specialists, and independent river scientists; Release all raw hydrological data, HEC-RAS models, calibration files, flood-frequency analyses, assumptions, and risk assessment studies into the public domain; Conduct an updated climate-resilient flood-risk assessment using contemporary rainfall and discharge datasets; Undertake a cumulative impact assessment concerning urban flooding, floodplain loss, and downstream flood amplification risks; Fix accountability for proceeding with large-scale river engineering interventions despite acknowledged deficiencies in hydrological certainty. Considering the potential implications for public safety, urban flooding, and irreversible ecological damage to the Mula-Mutha river system, this matter requires urgent intervention. There is certain and absolute risk to human life with this project. That’s the math. Pune will flood and you and your administration will have blood on your hands. We are willing to meet and openly discuss our findings with regard to this project. Preferably in full public view. It must be mentioned, We reserve our right to prosecute you and your offices for criminal negligence of your duties. Kindly treat this representation as extremely urgent and acknowledge receipt. Yours faithfully, Ameet Singh Economist & Founder ChaloPMC P.S. A document containing our technical studies with regard to the matter is attached for your reference below. One attachment  •  Scanned by Gmail Mail Delivery Subsystem Thu, May 28, 4:19 PM Address not found Your message wasn't delivered to [email protected] because the address couldn't be found, or is unable to receive mail. The response from the remote 📷 Shri. Devendra Fadnavis (Chief Minister) <[email protected]> 📷Wed, Jun 3, 5:07 PM to Govinda, me 📷 प्रिय अर्जदार, आपला ई-मेल या कार्यालयास प्राप्त झाला असून, सदर ई-मेल योग्य त्या कार्यवाहीसाठी नगर विकास (2) विभाग यांना ( ०२२-२२८२४१११)  पाठविण्यात आला आहे. तरी आपल्या या ई-मेलबाबत यापुढे उपरोक्त विभागात चौकशी करण्यात यावी. मा. मुख्यमंत्री सचिवालय मंत्रालय, मुंबई Thread Continued..... Suffice to say we never heard from Mr. Naval Kishore Ram and Pune flooded last month. Huge losses have been experienced across the board due to the floods. Since no data is available from the administration we are working on our own survey to figure out all that has gone wrong, its a lot of work... if you would like to participate in the survey, write to us and we will be happy to include your feedback Since you have read this far; Below Here is the text of the attachment which we sent as a technical document. for those who want to read the tables, send me an email on ameetgsingh@gmail and ill try and send you the detailed pdf. its just one of many research areas i am working on. Critique: Pune RFD Project 27 May, 2026 References: 1. Ref1: “Final Hydrology and Hydraulics Report, Pune River Rejuvenation Project”, Pune Municipal Corportation, Pune; HCP Design, Planning & Management Pvt. Ltd. Ahmedabad, 19 January, 2018. adc-ecos.enlightcloud.com/11… port.pdf 2. Ref2: “Final Detailed Project Report, Pune River Rejuvenation Project”, Pune Municipal Corportation, Pune; HCP Design, Planning & Management Pvt. Ltd. Ahmedabad, February, 2023. adc-ecos.enlightcloud.com/11… %20DPR-V2%202_compressed.pdf 3. Link to “Project Activities” webpage of Pune Municipal Corporation, Pune. Note that this links to various project documents such as DPR, Hydraulics Report, Environmental Clearances etc: pmc.gov.in/en/b/project-acti… 4. Indian Standard IS5477 (Part IV) Hydraulics: General 1. Admission of “Serious lack of adequate and authentic data” ○ Sec 1.5 Assumptions (p14) of Hydraulics Report (Ref1): “During the site visits and subsequent reviews, however, it was found that there was serious lack of adequate and authentic data about the continuous observation of water levels in past floods especially for determination of observed flood profiles. Therefore, we had to depend on certain rational assumptions using available data, which could not be verified for authenticity. Our studies have been based on these assumptions.” 2. Gauge Data not available ○ See Sec 2.3: “2.3 GAUGE DATA AVAILABILITY There are two discharge gauging station located in the catchment area 1) Dhond 2) Pune Bund Garden . Dhond gauging station of CWC (Central water commission) is located at confluence of Bhima River with Mula Mutha River. This gauging data is not used in study as total discharge measured is from both the river catchment i.e. Mula Mutha and Bhima river. Gauging station data located on Mula Mutha river at Pune Bund garden are available from year 1974 to 2015.Also Rainfall gauging data are available from Khadakwasla Dam , Mulshi Dam. These data will be used in present Hydrologic study. ○ Summary of above: No gauging data available for Mula, Mutha ○ Even bundgarden Mula-Mutha gauging station data used is only up to 2014. ○ Recent gauging data has to be used since: i. Pune is undergoing heavy urbanisations ii. Climate change is causing increased occurrences of precipitation extreme events 3. Riverfront is NOT a “Flood Control Scheme”, p25: ○ “Riverfront is not a flood control scheme and as such it is not supposed to provide greater protection to the areas on the river banks which have even otherwise been damaged by floods. In principle, therefore, it should be acceptable that Riverfront Development works for Mula, Mutha and Mula-Mutha River are so planned that they do not aggravate the situation compared to what occurred in past.” Design Flood Discharge Issues 1. [VVIMP] “Table 7 : Comparative Statement of Design Flood Discharge For 100 Year Return Period Flood as per various methods.” 2. The issues: a. Goodness of fit estimates not demonstrated in the hydraulics report b. Mula-Mutha 100 year return period discharge estimate based on Gumbel method fails Anderson-Darling Goodness of fit test To be sorted / elaborated 1. Higher estimates of 100y discharge discarded 2. Mula1 25y and 100y discharges almost identical. How? (1206 & 1232 cumec; also see later reaches downstream of Devnadi / ramnadi?) 3. Climate change effects ignored: Climate change effects were assumed arbitrarily at 20% and the design DID NOT INCORPORATE THESE EFFECTS. The hydraulics report strangely says that the 20% effects are considered within the IS specification of 1 m of freeboard! This is in violation of the standard. 4. IS 5477 (Part IV) mentioned by hydraulics report (on p25, sec 3.2.1): a. See this part: “4 GENERAL 4.1 A prerequisite essential to the safety of the dam is a decision in regard to the standard of security that should be provided against possible failure of the concerned structure during extraordinary floods. In case, failure of the structure is likely to result in loss of life or widespread property damage in addition to the damage of the structure itself as in the case of spillways of large reservoirs, a very high degree of security shall be provided against failure under the most severe flood conditions considered reasonably possible. But when loss of life is not involved, economic considerations would prevail to govern the selection of the design flood.” 5. No Risk Analysis carried out? a. See for reference, Chow, sec 13.5 on Risk Analysis b. ELV: Estimated limiting value (ELV) is defined as the largest magnitude possible for a hydrologic event at a given location, based on the best available hydrologic information. c. ELV and Chow on why design based on “Estimated Limiting Value” is important for densely populated urban regions: “For a densely populated area, where the failure of water-control works would result in loss of life and extensive property damage, a design using the ELV might be justified.” d. Doubt: Are ‘loss of life’ and ‘damage to property’ estimates done? HEC-RAS Issues 1. Upstream reach entrance water surface elevation lower than downstream reach exit value. The hydraulics report details the results of HEC-RAS simulations, which have been done over 4 separate disconnected sections, viz, Mula1, Mula2, Mutha and Mula-Mutha. The boundary conditions seem inconsistent as follows: 1. Entrance water level of Mula-Mutha higher than exit levels of both Mutha and Mula2: The WS Elevations of Entrance / Exits of the channelized river reaches for 100 year return period of flood discharge are as follows a. Mula-Mutha entrance: 546.65 m b. Mutha exit: 544.1 m c. Mula2 exit: 545.85 these tables couldnt be posted here and we are happy to share them over other media. Thank you for your time Sincerely Ameet