Date:17/10/2015

Honble Minister Mr. Prakash Javadekar,

Minister for Environment, Forests and Climate Change,
Government of India,
Paryavaran Bhavan, CGO Complex,
Lodhi Road,
New Delhi 110 003,
Dear Mr. Javedkar ,
Today we write to you in response to Draft notification S.O.2435(E) issued by the Environment Ministry on
4/9/2015.We hope that our concerns and propositions regarding the notification will be sincerely taken into account.
1. Draft notification S.O.2435(E) issued by the Environment Ministry on 4/9/2015 was put up online (in
English & Hindi) subjected to public discussion. However the large majority who happen to live deep
in the forests of the Westerns Ghats have no access to internet. Moreover this draft refers to the High
Level Working Group (HLWG) report and no where does take into account, a more holistic Western
Ghats Ecological Expert Panel (WGEEP) report. The (WGEEP) was not properly circulated among
the local communities . Even in cases when it was done, the report was widely misrepresented for
some reason or the other. The people were led to believe that they will face eviction, displacement
and loss of livelihood if ESAs were created. We strongly feel that it is a failure on part of the
government to clear the misconceptions among the people about the Madhav Gadgil Committee
report (WGEEP).The (HLWG) report that this draft notification refers to was also not circulated
among the communities.
In this context , we want the draft notification, along with both (HLWG) & (WGEEP) reports be
widely circulated and presented in an unbiased manner among these communities in their respective
languages ,discussed at grassroot levels and subjected to decisions taken by the gram sabhas. While it
is not always possible for the common man to be acquainted with all the prevalent aspects concerning
the issue , it is imperative that efforts should also be made to provide(and not impose) them with
scientific inputs on the issue. However after exposure to all the plural opinions it is the local
community that should be at the central character (and not as some consulting body) of all the policy
making relevant to this context. The Gram Sabhas through active participation of the local community
people should play the pivotal role in the decision making. Till then the verdict over the fate of
Western Ghats be withheld.
2. As a continuation of the previous point , we want a reassessment of (HLWG) report.Ecological
Sensitive areas need to be demarcated more holistically based on consultations of local communities ,
experts, civil society groups and other concerned citizens(exact procedures of which need to be
detailed and transparent enough).
3. We are currently entering the Sixth Mass Extinction Phase and the fault is entirely ours. As per the
new study in the journal Science Advances ,we have found that even with extremely conservative
estimates, species are disappearing up to about 100 times faster than the normal rate between mass
extinctions, known as the background rate. 477 vertebrates for instance, have gone extinct since 1900,
rather than the nine that would be expected at natural rates. Our Western Ghats- home to a diverse set
of life forms ; nearly 4000 species of flowering plants , 500 species of birds and 120 species of
mammals are known from this region many of which are endemic . At this juncture , we cannot
afford to let the existing scenario worsen. The intensity of exploitation and extent of encroachment is
increasing with each day. Declaring approximately thirty-seven percent the Western Ghats as
ecologically sensitive which covers an area of 59,940 square kilometre. of natural landscape of

Western Ghats is bound to accelerate these activities . The loss of biodiversity experienced thus will
be unprecedented.
4. Clause 3 sec 1 (a) of Draft-Notice S.O.2435(E) states a ban on mining, quarrying and sand mining in
Ecologically Sensitive Area this puts no restriction on mining, quarrying activities on the major 63
percent of the Western Ghats thereby adversely affecting the flora and fauna of the region . We
request you to revisit this point as this also happens to be against the national policy of protecting
65% in the hilly areas. In this context, we further suggest to take account of the section - Measures
for Mitigation/Improvement(Sec:2.7-Mining, page-264) of WGEEP report.
5. Clause 3 sec 1 (b) of Draft-Notice S.O.2435(E) states -No new thermal power projects and expansion of
existing plants shall be allowed in the Ecologically Sensitive Area - We appreciate this statement and at the
same time we want it to be implemented for the remaining 63 percent of the forests as well.
6. The ESA suggested by(HLWG) report covers in the larger part only the protected areas which are
already protected by various Acts and rules. The concept of ESA in their notion stands paradoxical
and hence requires reassessment
.
7. The notification effectively reduces the area of the Ecologically Sensitive Area (ESA) in the Western
Ghats by 17,000sq km as compared to the Ecologically Sensitive Zone 1 (ESZ1) recommended by
WGEEP report. This is a huge disparity and needs to be clarified on scientific grounds.
8. Clause 3- 3. Projects and activities to be prohibited or regulated in the Eco-sensitive area- Sec 2(b)
The Orange category of Industries as specified by the Central Pollution Control Board or State Pollution
Control Board shall be allowed with strict compliance of environmental regulations but all efforts shall be
made to promote industries with low environmental impacts. This is extremely dangerous for the part of

the forests that have already been declared in the report for preservation . Instead of eco-restoration
process of the region it will only invite ecocide in the region . The concerned ministry is requested to
revisit this point at the earliest and make necessary changes.
9.

A similar point was made in Clause3- Sec 1(c) - Industry: All new Red category of industries as specified
by the Central Pollution Control Board or State Pollution Control Board and the expansion of such existing industries
shall be banned. The list of Red category of industries shall be as specified by the Central Pollution Control Board:
provided that all existing Red category of industries including health care establishments shall continue in EcoSensitive Area under the applicable rules and regulations.

While we appreciate the conviction of the ministry in doing away with the upcoming new Red
category of industries , we fail to comprehend its stance with the existing Red category industries
being allowed to operate within the Eco-Sensitive Area. This is detrimental to the concept of ESAs
itself. We therefore want all existing Red category (highly polluting industries) should be phased out
apart from banning new ones from setting up.
10. Clause 3 sec 2 (a (3)) of the draft notice states the minimum distance between one project and the other is
maintained at three kilometre and not more than fifty per cent of the river basin is affected at any time,

The efforts of the ministry to promote renewable sources of energy in our country in this era of
Climate Change stands commendable. However that doesnt necessarily imply that the need to
generate power from renewable sources of energy should come at the cost of disrupting the
biodiversity of nature. Construction of multiple hydropower projects at three kilometre interval
without affecting fifty percent of the river basin at a time comes with large scale adverse
consequences of scarcity of forest produce, siltation of reservoirs, ecological imbalances, decimation
of biological diversity, mass displacement of communities.
In this regard , we still encourage the ministry to use clean renewable sources of energy for the
purpose of energy supply. But the ethics driving the actions should change. The mode of power
generation and the technologies involved should be integrated with the sustainability of the local
environmental conditions.
We strongly advocate the use of micro & mini hydel projects in eco-sensitive areas.
At present there are several damless hydroelectric technologies available . Extensive
research is also being carried out on improvement of capacities of the aforementioned technologies .

1.Underwater Electric Kite

2.Gorlov Helical Turbine -installation South Korea

'Dam'less hydroelectric technologies e.g. Gorlov Helical Turbine, Underwater Electric Kite , Open Hydro Turbines or
similar other technologies that can generate power from stream flows can be considered to meet needs of several
townships, villages.
However sufficient attention must be given on the fish mortality with the installation of these turbines and their
rotation speeds , design should be regulated accordingly . The idea is to meet local power demand and not to feed to
the grids, if we are so inclined to generate power in such an eco-sensitive area. Much focus should be given upon the
Energy Distribution issue. As the Gadgil report points out The need to revisit the concept of energy equity in the Indian context, wherein some groups of people in the Western
Ghats (and other) states are over-consuming energy, while others are energy poor. In the context not just of global
concerns, but local environmental and social issues linked to energy production and use, there is need for an energy
policy that clearly reflects sustainability and equity considerations. There is need to differentiate between luxury and
wasteful and reasonable and adequate energy consumption in all of our energy demand projections. The equitable
per capita energy consumption norms that are being demanded in the climate change debate across countries should
also be studied for their relevance across regions and groups domestically.
Much of our energy problems concerns- Energy demand & Energy Distribution. Adequate efforts should be given to
understanding the pertinent problems thereby shaping an Optimal and sustainable energy policy.
We are already in a point of no return phase. Nothing much can be done to revert(within a time scale of centuries)
the already aggravated situations as far climate change and such other factors are concerned. But what we can
definitely do is to retard the pace of this change. We must join hands to protect what we have instead of indulging in
the rat-race of exploiting the available resources. Talking and promoting Sustainability on one hand and following
something contradictory to the former on the other will not keep much for our future generations to thrive
sustainably.
You are in a capacity to set things right . Even if the government decides to move forward with the (HLWG) report ,
we request to include the salient progressive features from WGEEP report as well .
We look forward to your intervention and therefore humbly request you to ensure a transparent , scientific ,
democratic process for assessing the reports , making necessary changes and converge to a common minima.
Hope your good-self take into account our suggestions and remarks on the report .
Yours sincerely,
Students of Indian Institute of Science
Bangalore-560112