Discussion:
Re: ENDORSEMENT RELEASE (National Wildlife Week, October
(too old to reply)
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




NATURE ENVIRONMENT SOCIETY AND TRANSFORMATIONS
(NEST)
DONGAR GHAR, HILLTOP RESIDENCE, CHORAO ISLANDS, TISWADI, GOA. PH:(0832)2492014.

31/A, IGREJ VADDO, MARNA, SIOLIM, BARDEZ, GOA. 403517 PH: (0832)2272164

FOUNDER: Dr. Bikram Dasgupta.
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




NATURE ENVIRONMENT SOCIETY AND TRANSFORMATIONS
(NEST)
DONGAR GHAR, HILLTOP RESIDENCE, CHORAO ISLANDS, TISWADI, GOA. PH:(0832)2492014.

31/A, IGREJ VADDO, MARNA, SIOLIM, BARDEZ, GOA. 403517 PH: (0832)2272164

FOUNDER: Dr. Bikram Dasgupta.
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




NATURE ENVIRONMENT SOCIETY AND TRANSFORMATIONS
(NEST)
DONGAR GHAR, HILLTOP RESIDENCE, CHORAO ISLANDS, TISWADI, GOA. PH:(0832)2492014.

31/A, IGREJ VADDO, MARNA, SIOLIM, BARDEZ, GOA. 403517 PH: (0832)2272164

FOUNDER: Dr. Bikram Dasgupta.
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




NATURE ENVIRONMENT SOCIETY AND TRANSFORMATIONS
(NEST)
DONGAR GHAR, HILLTOP RESIDENCE, CHORAO ISLANDS, TISWADI, GOA. PH:(0832)2492014.

31/A, IGREJ VADDO, MARNA, SIOLIM, BARDEZ, GOA. 403517 PH: (0832)2272164

FOUNDER: Dr. Bikram Dasgupta.
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




NATURE ENVIRONMENT SOCIETY AND TRANSFORMATIONS
(NEST)
DONGAR GHAR, HILLTOP RESIDENCE, CHORAO ISLANDS, TISWADI, GOA. PH:(0832)2492014.

31/A, IGREJ VADDO, MARNA, SIOLIM, BARDEZ, GOA. 403517 PH: (0832)2272164

FOUNDER: Dr. Bikram Dasgupta.
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




NATURE ENVIRONMENT SOCIETY AND TRANSFORMATIONS
(NEST)
DONGAR GHAR, HILLTOP RESIDENCE, CHORAO ISLANDS, TISWADI, GOA. PH:(0832)2492014.

31/A, IGREJ VADDO, MARNA, SIOLIM, BARDEZ, GOA. 403517 PH: (0832)2272164

FOUNDER: Dr. Bikram Dasgupta.
nest nest
2004-10-06 21:17:09 UTC
Permalink
On the Occasion of Willdlife week in India;pointers to Goa.
Seby.


Dear Mr. Saldhana,
Thanks for your e-mail. Please include in the letter bio-degradation of the
Goa landscape and the waters which is threatening wildlife and lowering the
potential of the Peoples of Goa. We at NEST (ne_st at rediffmail.com ) held a
series of conferences in February 2004 and had discussed on Neurological
deseases affecting the humans which have direct bearing on Environment. We had
also discussed about the threat to the Western Ghats Forest due to iron ore
and Manganese mining within the territory of Goa. We also touched on the
potential of the Dudhasagar waterfalls for hydro-electric power generation as
well as for the irrigation of the farms. We have been sensitive to the plight
of the villagers inhabiting the lowlying areas of the waterfalls. The forest
reserves of this tiny territory and it's ecological balance of the land and
the water; and the plants and animal settlement is being disturbed. Tourism is
one of the main industries of this place. If look at the canary islands in the
Southern atlantics, although tourism has brought prosperity to those islands,
these islands have been subjected to natural climate change. Although we in
Goa feel such things like rainstorms, unseasonal rains, cyclones and tornados,
drying up of some of our rivers, these may be the warning signs of the greater
danger that may befall us in this tiny territory.we may be sitting on Powder
keg if we ignore this deliberate ignorance of the life processes which is true
even for this small territory Goa as it is true for the Upper reaches of the
Indo-Gangetic plains. I suspect therefore although we have good rains this
year as compared to last year, the water table of this region is drying up.
And we may have to take corrective measures with human ingenuinity to bring
water table to a level which can sustain life, and therfore correct some of
the imbalances in the degraded landscapes and human, plant and animal
settlements. This is the task for all of us; to highlight to the ministry of
Environment and Forest.

On behalf of NEST we wish to inform you of our 8th annual NEST conference on
Indigenous People to be held at Social development Cenre, Ranchi, Jharkhand
from 16-18 November 2004. You are invited to participate in the same and
present the paper. Formal invitation will posted to you shortly.

Dr.Rajendra B. Kenkre, MD.FRS
Neurologist


ESG India S2L <esg at esgindia.org> wrote:
ENDORSEMENT RELEASE
National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?

OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS

In commemoration of National Wildlife Week, it has become ritualistic for
Government agencies to organise a variety of events. One hopes that the
commitments renewed and the new commitments made would be lived through in
the weeks and months that follow, and the country's wildlife populations
would be more secure.

Recent decisions of the Ministry of Environment and Forests, and thereby
those of all agencies connected with its decisions, however, hardly give us
the confidence that the country is adopting a mature and progressive policy
on wildlife protection. Instead we are confronted with expedient decisions
that aim to support industrial development at any cost, excellent
biodiversity enclaves are threatened with interference by such developments,
and in some cases large scale submergence by dams, and the involvement of
public at large is considerably weakened by pursuing policies that make
agencies stronger and their decisions increasingly in-transparent.

Keeping this in view, it has become imperative for groups and individuals
across the country to come together to make a strong statement on how our
wildlife protection laws and policies are simply being wished away by the
very actions of the State.

Highlighting significant concerns a letter addressing many problems and
weaknesses in the system of decision making, and its implications to
wildlife populations and their habitats has been sent to the Union Ministry
of Environment and Forests and is enclosed.

We request you to kindly endorse this letter and send a copy to the Union
Ministry of Environment and Forests. Please mark a copy to Neeraj
Vagholikar of Kalpavriksh (nvagho at vsnl.net) for archiving and follow up
requirements.

Your effort would help pressurize the Ministry to genuinely reform its
ongoing thoughtless programme of decimating wildlife habitats, even as it
continues to ignore the excellent range of expertise that is consistently
addressing such issues. We fear the result of current attitudes
demonstrated by the Ministry can only further threaten our already stressed
wildlife habitats in the country.


Leo F. Saldanha
Environment Support Group ?
S-3, Rajashree Apartments, 18/57, 1st Main Road, S. R. K. Gardens,
Jayanagar, Bannerghatta Road, Bangalore 560041. INDIA
Telefax: 91-80-26534364/26531339/26341977 Fax: 91-80-51179912
Email: esg at esgindia.org or esg at bgl.vsnl.net.in Web: www.esgindia.org

Released in Bangalore, 4th October 2004

Encl.: As above

Addresses to Mail/Email:

Mr. A. Raja
Union Minister
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 1727, 2436 3958
Fax: 011-24362222
Email: mef at menf.delhi.nic.in

Mr. Namo Narain Meena
Minister of State
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
Tel: 011-2436 2131, 2436 4791
Email: mosef at menf.delhi.nic.in

Dr. Prodipto Ghosh
Secretary
Government of India
Ministry of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi - 110 003.
(INDIA).
Telephone:+91-11-2436 1896, 2436 0721
Fax: 91-11-24362746
E-mail: secy at menf.delhi.nic.in or prodipto_ghosh at nic.in


OPEN LETTER TO THE MINISTRY OF ENVIRONMENT AND FORESTS
October 4, 2004

National Wildlife Week, October 2-8, 2004

WHY IS THE GOVERNMENT CONTINUING TO 'CLEAR' CRITICAL WILDLIFE HABITATS?


Even as the nation celebrates National Wildlife Week, critical wildlife
habitats continue to be 'cleared' for dams, mines, roads, ports, industries
and other 'development' projects. Shockingly, this is being done by the
Ministry of Environment & Forests (MoEF), the central agency in charge of
protecting India's wildlife.

Wildlife in India continues to suffer serious threats, with over 5% of
species being in danger of extinction, and many threatened species going
further into decline. Clearly MoEF and other agencies need to take drastic
action to save these species. Yet, and despite claims that it has improved
its wildlife conservation performance, the MoEF's record in protecting
wildlife from destructive 'development' and commercial pressures has gone
from bad to worse.

Poor environmental impact assessments and a disregard for citizens inputs
are key aspects of this decline. As civil society groups we the undersigned
are deeply concerned with this trend, which poses a grave threat to India's
wildlife habitats, and simultaneously to the lives and livelihoods of tribal
and other communities that depend on such habitats. We demand the urgent
steps to be taken to arrest this trend, and to guarantee the security of
critical wildlife habitats against destructive development.

Wildlife habitats and populations continue to be under serious threat from
'development' projects across India. Non-transparent decision-making by the
Ministry of Environment and Forests (MoEF) is aiding this process. Some
specific issues of concern are given below (please see annexure for details
of examples given below):

1. Clearing projects despite poor Environmental Impact Assessment
(EIA)
Several kinds of development projects require clearance from the MoEF under
environment and forest laws. MoEF is supposed to protect critical wildlife
habitats, by vetoing or otherwise amending projects, which would entail
significant environmental losses. However, in several instances, such
clearances have been granted despite extremely poor environment impact
assessment, including blatantly plagiarized studies. Most of these are
particularly weak on wildlife and biodiversity aspects. In situations where
additional environment and wildlife impact studies have been asked for, they
are either 'rapid' assessments which are inadequate to aid decision-making,
or are detailed studies to be conducted after the clearance has already been
granted! There is little logic in first 'clearing' the destruction of
wildlife habitats and then doing a detailed assessment as a formality after
project work and environmental destruction has commenced. An EIA is
primarily a decision making and planning tool, but it has been reduced to a
procedural formality to clear projects and hence cannot be utilized to its
optimum for safeguarding the environment.


Eg. environmental clearances granted to:
* Lower Subansiri hydroelectric project (Assam - Arunachal Pradesh)
impacting the Tale Valley sanctuary and adjacent wildlife habitats, home to
species such as the clouded leopard, elephant, golden mahseer and river
dolphin.
* Barh Thermal Power Plant (Bihar) impacting the Taal wetlands, which
are extremely rich in avifauna.
* Human irrigation project (Maharashtra) impacting critical tiger
corridors bordering the Tadoba-Andhari Tiger Reserve.

1. Allowing destructive development projects inside protected areas
In the past few years, several destructive development projects have been
allowed inside or immediately bordering protected areas (sanctuaries,
national parks, tiger reserves, elephant reserves etc.) by the MoEF.

Eg.
* Permission for oil prospecting in the Desert National Park
(Rajasthan)
* Clearances to several iron ore mining projects in the Sarai Kela
Kharsawa Elephant Reserve (Jharkhand) seriously impacting the elephant
habitat.
* Permission for mining in the Valmiki Tiger Reserve (Bihar)
* Clearance for uranium exploration bordering the Nagarjunsagar
Srisailam Tiger Reserve (Andhra Pradesh

3. Ignoring citizens' inputs
In several instances, peoples' groups, wildlife and social NGOs, have made
submissions to the MoEF about the serious impacts of specific projects on
wildlife habitats as well as the livelihoods of local communities, yet
clearances have been granted completely ignoring these inputs.

Eg.
* Bodhghat hydel project (Chhattisgarh) impacting critical wild
buffalo habitat and resisted by local villagers for years.
* Parbati Stage - II hydel project (Himachal Pradesh) impacting the
Great Himalayan National Park.



3. Weakening the National Board for Wildlife (NBWL) and Expert
Committees for environmental clearance
In 2003 the Indian Board for Wildlife (IBWL), set up in 1952 as the national
advisory body on wildlife matters, was converted into the National Board for
Wildlife (NBWL) under the amended Wildlife (Protection) Act, 1972. It seems
more than just a co-incidence that all the members who had opposed the
clearance of destructive development projects (for example the Lower
Subansiri hydel project) were dropped while reconstituting the body. Those
dropped include India's oldest wildlife NGO, the Bombay Natural History
Society.
Simultaneously, the Expert Committees assisting the MoEF in evaluating
projects for environmental clearance, have shown little or no sensitivity to
protecting wildlife habitats. Not a single national NGO working on wildlife
is on these Expert Committees.

Eg.
* The MoEF Expert Committee on River Valley projects recommended the
Lower Subansiri hydel project for environmental clearance, just three weeks
after a meeting of the then IBWL had decided that fresh biodiversity impact
studies were required as the existing studies were grossly inadequate. The
same River Valley Committee readily recommended the clearance of the Human
dam although it will have serious impacts on a tiger corridor bordering
Tadoba-Andhari Tiger Reserve, Maharashtra.

3. 'Compensating' wildlife losses
Increasingly, MoEF is clearing projects destroying critical wildlife
habitats based on poor assessments, and then claiming to compensate the
losses by requiring the relevant state government to declare a protected
area (sanctuary or national park) somewhere else. Often both the land used
for the project as well as the new land to be declared a protected area is
critical for supporting the livelihoods of local communities who end up
getting doubly deprived. Compensatory mechanisms cannot be a
substitute for sound decision making based on comprehensive environmental
and social impact assessment. Due to the cleared projects already having
negative environmental and livelihood impacts on local communities,
alienation of additional lands to declare them protected areas, only
antagonises them further and is counterproductive to wildlife conservation
in the long run. This practice is unacceptable.

6. Dilution of notifications under the Environment Protection Act (EPA)
Repeated dilutions of notifications under the EPA, such as the Environment
Impact Assessement (EIA) notification and the Coastal Regulation Zone (CRZ)
have made wildlife habitats and sensitive ecosystems more vulnerable to
development pressures.
Eg.
* A few of the dilutions of the EIA notification, 1994, making
sensitive habitats vulnerable include: no EIA report required for pipeline
projects; a substantial increase in the investment limit of projects
requiring environmental clearance; no public hearings required for mining
projects (major minerals) with lease area up to 25 hectares, although Indian
Bureau of Mines data indicates that almost 50% of leases for major minerals
are less than 25 ha!
* The CRZ notification, 1991, was amended in 1997 to delegate powers
to the Ministry of Surface Transport (MoST) to grant environmental clearance
to port projects. In 2000 the MoST promptly cleared the Dhamra port just
north of Gahirmatha Marine Sanctuary (Orissa), one of the most important
nesting sites of the endangered olive ridley turtle in the world. The
decision was based on a poor environmental impact assessment, and the
proposed port will be a major threat to the future of the endangered
turtles. While the MoEF has subsequently withdrawn the delegation of powers
to the MoST for environmental clearance of such ports, undermining the CRZ
notification on various other counts continues.


Keeping the above scenario in mind, we demand that the Government takes the
following urgent steps:

1) Draw up a list of critical wildlife and biodiversity habitats in
India that are not open to large-scale development projects.

2) Make public the precise reasons and justification when it is
considering granting environmental and forest clearance to a project, before
such clearance is granted, and ask for public response to such proposals.
Evolve appropriate mechanisms to inform citizens on what action has been
taken on submissions made by them during the clearance process.

3) Make public the minutes of meetings of the Expert Committees and the
National Board for Wildlife deciding on clearances of development projects.
This should be done for all future projects, as well as projects cleared in
the last 10 years, to enable public scrutiny of the basis of recent
clearances.

3) Make public the status of compliance of conditions of environment
and forest clearance by all projects being monitored by the MoEF. This is
critical since earlier exposes have indicated that most projects are not
complying with the conditions under which they were granted clearance.
Despite this, the MoEF has taken very little punitive action and is even
granting fresh clearances often to the same project proponents. A glaring
example is the National Hydroelectric Power Corporation (NHPC), which has
been guilty of flouting clearance conditions on several projects (for
example Teesta Stage-V hydel project in Sikkim), yet continues to be granted
clearances for new projects.

3) Provide a legally mandated and explicit role for citizens in the
decision-making process within MoEF. This can be done by including
independent and credible representatives of communities and civil society
including gram sabhas/tribal councils in the various expert committees;
ensuring that citizens' inputs in draft notifications and legislation are
considered through a transparent process; strengthening the public hearing
process for 'development' projects; constituting an independent monitoring
and evaluation agency to assess compliance of environmental conditions and
regulations; and by adopting other such measures.

3) Have the MoEF commission environmental impact assessments (EIAs)
using an independent fund set up for the purpose through contributions from
project authorities. An independent mechanism to assess the quality of such
EIAs, including through public inputs, needs to be simultaneously setup.
This is essential because at present project proponents themselves
commission agencies to carry out the EIA. It is consequently very rare for
such agencies to be objective and unbiased, as they seek to please their
employer for ensuring similar contracts in the future. Similarly no
mechanism is currently available to independently review the quality of the
EIAs.



Neeraj Vagholikar / Ashish Kothari (Kalpavriksh)
Apartment 5, Shree Dutta Krupa, 908 Deccan Gymkhana, Pune - 411004. Tel:
020-35675450; Tel/Fax: 020 - 25654239; Email: nvagho at vsnl.net
; ashishkothari at vsnl.com




Ravi Agarwal (Toxics Link)
H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax:
24321747; Email: ravig at ndf.vsnl.net.in


Shekhar Singh (Centre for Equity Studies)
C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email:
shekharsingh at vsnl.com


Bittu Sahgal / Ashish Fernandes (Sanctuary Asia)
602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 -
22830061/22830081; Fax: 020 - 22874380; Email: cree at sanctuaryasia.com


On behalf of:

Samir Acharya, Society for Andaman and Nicobar Ecology, A&N Islands
Aarthi Sreedhar, Environmental Activist, Bangalore
Himanshu Thakkar, South Asia Network of Dams, Rivers and People
P.K. Aditya, Green Hearts Nature Club, Kokrajhar, Assam
Soumitra Ghosh, NESPON, Siliguri
G.Ananthpadmanabhan, Greenpeace India, Bangalore
Bulu Imam, Sanskriti, Hazaribagh, Jharkhand
Dr.A.Latha,Chalakudy River Protection Council, Kerala
Sujit Patwardhan, Parisar, Pune
Madhu Sarin, Independent consultant, Chandigarh
Ashish Kothari/Neeraj Vagholikar, Kalpavriksh, Pune and Delhi
Bittu Sahgal/Ashish Fernandes, Sanctuary Magazine, Mumbai
Shekhar Singh, Centre for Equity Studies, New Delhi
Ravi Agarwal, Toxics Link, New Delhi
Kartik Shanker, Wildlife Biologist, Bangalore
Bhaskar Borah, Green Heritage, North Lakhimpur, Assam
Leo Saldanha, Environment Support Group, Bangalore, Karnataka
Ritwick Dutta, Lawyer, Supreme Court, New Delhi.
Ashok Kumar, Wildlife Trust of India, New Delhi
Harry Andrews, Madras Crocodile Bank Trust & Andaman & Nicobar Environment
Team, Chennai
M.K. Prasad, Kerala Sastra Sahitya Parishad, Kochi, Kerala
K.M.Chinnappa/ Praveen Bhargav, Wildlife First, Bangalore
Romulus Whitaker, Draco Films, Chengalpattu, Tamil Nadu
Achyut Das, Agragamee, Orissa
Thomas Mathew, South Asian Conservation Foundation
Dilip Gode, Vidarbha Nature Conservation Society, Nagpur
Dr. Asad Rahmani, Bombay Natural History Society, Mumbai
Bandu Sane, Khoj, Maharashtra
Michael Mazgaonkar, Paryavaran Suraksha Samiti, Gujarat
Dr. Bibhab Talukdar, Wildlife Conservationist, Guwahati, Assam
Debi Goenka, Bombay Environmental Action Group, Mumbai
Gautam Bandopadhyay, Peoples Alliance for Livelihood Rights, Raipur,
Chhatisgarh
Mahesh Pandya, Centre for Social Justice, Gujarat
Salam Rajesh, Manipur Nature Society, Imphal
Tushar Pancholi, Paryavarniya Vikas Kendra, Rajkot, Gujarat
Arun Jindal, Society for Sustainable Development, Karauli, Rajasthan
Pradyumna Sahasrabhojanee, Vidarbha Nature and Human Science Centre, Nagpur
C.P. Geevan, Centre for Environment and Social Concerns, Bhuj, Gujarat
Arun Mani Dixit, Gujarat Institute of Desert Ecology, Bhuj, Gujarat
Partha Das, UNNATI Organisation for Development Education, Rajasthan

Annexure:
A FEW EXAMPLES OF CLEARANCES OF PROJECTS BASED ON A POOR IMPACT ASSESSMENT
PROCESS WHICH ARE AFFECTING WILDLIFE HABITATS

* Lower Subansiri hydel project (Assam and Arunachal Pradesh)
This 2000 MW hydel project will have a huge impact on wildlife: submergence
of almost 4000 ha of biodiversity rich forests in the Eastern Himalayas
including a portion of the Tale Valley sanctuary; an important elephant
corridor will be obstructed by project site; rich fish diversity of the
Subansiri river including the golden mahseer will be impacted; downstream
impact on ecology of wetlands (beels) and habitat of the river dolphin.

The environmental impact assessment studies done for the project have been
extremely poor, particularly on wildlife and biodiversity aspects. This had
also been clearly pointed out by an expert committee of the then Indian
Board for Wildlife. Several wildlife and social organisations have raised
serious concerns about the project with the MoEF. There have also been
violations of environment and forest laws by the project authorities.
Inspite of all this, the project was granted environment clearance in July
2003.

* Uranium exploration on the border of Nagarjunasagar Srisailam Tiger
Reserve (Andhra Pradesh)
The EIA was found to be of a very poor quality. Despite a report from the
Bombay Natural History Society (BNHS) raising serious concerns about the
project's impacts on the forest, wildlife movement and the possible
radioactive pollution of the Nagarjunsagar reservoir, as well as the
quality of the EIA, the uranium exploration was cleared by the NBWL and
the MoEF. Subsequently, the Andhra Pradesh Pollution Control Board has
objected to the proposed uranium prospecting.

* Coalmining and allied activities in the North Karanpura valley,
Jharkhand
This valley forms a vital elephant corridor connecting the forests of
Palamau to the Konar forests and is threatened by coalmining and allied
activities. The expansion of the Ashoka coalmine in the valley was cleared
inspite of its impact on the elephant corridor. Other projects undergoing
clearance procedures in the same valley include new coal mines, thermal
power projects and dams, destined to completely destroy this habitat.




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