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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 ([EMAIL PROTECTED] ) 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 <[EMAIL PROTECTED]> 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 ([EMAIL PROTECTED]) 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: [EMAIL PROTECTED] or [EMAIL PROTECTED] 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: [EMAIL PROTECTED] 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: [EMAIL PROTECTED] 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: [EMAIL PROTECTED] or [EMAIL PROTECTED] 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: [EMAIL PROTECTED] ; [EMAIL PROTECTED] Ravi Agarwal (Toxics Link) H2 Jangpura Extension, New Delhi - 110014. Tel: 011-24321747, 24328006; Fax: 24321747; Email: [EMAIL PROTECTED] Shekhar Singh (Centre for Equity Studies) C 17A Munirka, New Delhi - 110067. Tel: 011 - 26178048, 26162831; Email: [EMAIL PROTECTED] Bittu Sahgal / Ashish Fernandes (Sanctuary Asia) 602 Maker Chambers V, Nariman Point, Mumbai - 400021. Tel: 022 - 22830061/22830081; Fax: 020 - 22874380; Email: [EMAIL PROTECTED] 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.