The amicus curiae Jacob P. Alex appointed by the Kerala High Court to assist it in flood-related cases has submitted the report to the Kerala High Court. The report makes the following observations:
- The sudden release of water simultaneously from different reservoirs during the heavy rain in August 2018 had aggravated the damage during the floods.
- High reservoir storage and sudden release of water had resulted in worsening the floods.
- It appeared that dams in the State did not have an effective flood control zone and flood cushions. The flood cushion or flood control zone is a temporary storage space for absorbing high flow for alleviating downstream flood damage.
- None of the 79 dams in the State were operated or used for the purpose of flood control and moderation, despite the obligation to utilise them for flood control as per the stipulations under the National Water Policy, National Disaster Management Authority guidelines on the flood.
- Various alerts (blue/orange/red) were issued not in accordance with the EAP (Emergency Action Plan) guidelines.
- No proper follow-up action and effective precautionary steps, especially for evacuating people and accommodating them in safe locations, were taken after the issue of red alert.
- None of the dams had EAP (Emergency Action Plan) despite the mandate of the National Disaster Management Authority to have it by 2009.
- Most of the major reservoirs were almost full before the extreme rainfall and they did not have the capacity to accommodate the additional flow, compelling the authorities to release a substantial amount of water from reservoirs in a short span of time at the peak of the rainfall.
- Almost all dams released water only after the water level crossed the FRL (Full Reservoir Level) or reached the MWL (maximum water level).
- Dam managers should not have solely relied on the IMD prediction for dam management and variation in India Meteorological Department forecast could not be a justification for delayed release of water from dams.
Emergency Action Plan
Emergency Action Plan is a written document prepared by the dam operator and it contained plans to prevent or lessen the impact of a failure of the dam or appurtenant structure.