From: Shankar Sharma <shankar.sharma2...@gmail.com>
Date: Fri, 23 Feb 2024
Subject: Are our forests at credible risk?



To
The Chairperson and Members
The National Green Tribunal (NGT), New Delhi

Dear Madams and Sirs,

Greetings from Sagara, Western Ghats, Karnataka.

May I draw your kind attention to a recent news item, as in the weblink
below, on the topic of credible threats to our forests?
------------------------

*Our forests are at risk*
https://bangaloremirror.indiatimes.com/bangalore/others/our-forests-are-at-risk/articleshow/107923009.cms

----------------------------------------------------------------------------------

The report says that the National Green Tribunal (NGT) has accused the
Forest, Ecology and Environment department of Karnataka,  and Karnataka
Forest Department (KFD) of large-scale encroachment of forest land in the
state, subsequent to the principal bench of the tribunal registering a suo
motu case on the basis of various media reports highlighting the issue.

While it is a great development that the continued and/or wanton
destruction of our forest wealth has been taken cognisance of by the NGT,
the tribunal may kindly appreciate the fact that such diversion/
destruction of forest lands has been going on for decades, and is being
reported from the other states of the Union also.  Whereas,
large-scale encroachment
of forest land has been a major concern, what is even more worrisome is
that the forest lands even within the protected areas (PAs), such as
Wildlife Sanctuaries, are being allowed to be diverted by the state/
Central government agencies in the guise of developmental projects.

In the state of Karnataka alone, at least three such project proposals
seeking to divert more than a total of 10,000 acres of original forest
lands of unimaginable ecological value, within three different Wildlife
Sanctuaries, are reported to be under the consideration of the state govt.
A long list of about 20 such destructive projects in the Western Ghats of
Karnataka is as in the file attached to this representation. It is
estimated that a total of more than 20 lakh mature trees within these
Western Ghats alone are facing the risk of cutting, if these projects are
implemented.  Items 21, 22 and 23 in this table of proposed projects have
huge implications to three different Wildlife Sanctuaries.  It is highly
unfortunate that the very need for the three power project proposals
(under Items
21, 22 and 23 in this table) within Wildlife Sanctuaries has not been
established, as they can be unambiguously challenged on credible grounds;
and there are multiple and benign alternatives to achieve the stated
objectives.

Similarly, other linear project proposals for roads, railways, power lines
etc. through such WLS or the ESZs of these WLS, or elsewhere in WGs, OR in
other ecologically sensitive areas are guilty of not undertaking due
diligence process in evaluating all the costs and benefits to the
environment and to the society, and failing to objectively explore suitable
alternative options to realise the stated goals.

The concerned civil society groups have no regulatory/ governance mechanism
to officially record such multiple concerns, and to recommend credible
alternatives.  It is in this context that civil society groups are elated
to know about the latest decision of NGT to register a suo motu case on the
basis of various media reports highlighting the issue of large-scale
encroachment
of forest land.  Whereas the NGT can and should cancel such
large-scale encroachment
of forest land all over the country, it may also kindly consider  taking
urgent action/s to subject every project proposal within PAs to rigorous
examination, even if it comes from the state/ Union govt.

It should be highlighted here that in the case of every power sector
project proposal, which may demand diversion of forest lands, the credible
option of renewable energy sources, such as solar and wind power
technology, has a huge scope of preventing/ minimising the loss of forest
wealth.  Our country can minimise such destruction of natural resources to
a great extent, if the professional experience and knowledge available in
civil society are optimally utilised.  Many civil society groups and
individuals with the necessary professional experience and knowledge will
be happy to render their modest service in this regard without seeking any
financial/ commercial benefits in return.  Kindly consider and mandate how
such services are effectively made use of by the state/ central govt.
agencies in such cases.

Whether it is EAC under MoEF&CC, or State Wildlife Boards, or National
Wildlife Board, none of them are known to give adequate or any opportunity
to the concerned civil society groups and/ or individuals with the
necessary professional experience and knowledge, even in case of specific
project proposals, and even when the same is requested for.  NGT may kindly
deliberate on this issue, and pass suitable instructions to EAC, or State
Wildlife Boards, or National Wildlife Board to act diligently before
permitting the diversion of forest lands within PAs.

As far as items 21, 22 and 23 in the attached table of project proposals in
Karnataka's Wildlife Sanctuaries are concerned, I, as an electrical
engineer and a power sector professional of over 43 years of experience in
India, Australia and New Zealand, will be happy to depose before NGT, and
establish much better alternatives to prevent diversion of forest lands, if
so desired by NGT.

Since I live far away from Delhi, and since I have no resource base to hire
a competent advocate to file a PIL on my behalf, kindly consider this
representation as a PIL in the larger interest of the entire country.

With kind regards
Shankar Sharma
Power & Climate Policy Analyst
“Lahari”, 17/1, 8th Cross, 2nd Main road, Vijayanagara
*Sagara, *Karnataka, India - 577 401
Phone: ++ 91  9880048901 AND 94482 72503
shankar.sharma2...@gmail.com
shankar.sharma2...@hotmail.com <shankar_sharma1...@hotmail.com>

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