ToxicsWatch Alliance (TWA)
Dr. Amit Love,
Union Ministry of Environment & Forests (RE Division)
Government of India
Date: May 20, 2013
Subject-Comments on the report of High Level Working Group Report on Western Ghats
This is with reference to Office Memorandum, F.No. 11112010-RE (ESZ) dated April 30, 2013 issued by Union Ministry of Environment and Forests inviting comments on the report of High Level Working Group Report on Western Ghats.
I submit that the issue of watershed of Western Ghats states is very crucial for its survival.
In this regard it is quite sad that the recommendations of the High Level Working Group (HL WG) on Western Ghats in response to Western Ghats Ecology Experts Panel (WGEEP) Report poses a grave to threat rivers, wetlands and dependent communities in the Western Ghats.
I submit that at a time when Gujarat, Maharashtra, Goa, Karnataka, Kerala and Tamilnadu are facing multiple issues with respect to rivers, drinking water, irrigation, loss of biodiversity and livelihoods, dam-induced displacement, etc, the only issue HLWG report has commented upon is hydropower.
I submit that the WGEEP report has dealt with a number of issues related to the water sector from democratic community driven bottom up governance, watershed development, opposition to large dams in ESZ I and II, drinking water, fisheries, etc.
I submit that the HLWG has failed to comment on any of these recommendations of the WGEEP in regard. This creates a logic for MoEF to adhere to WGEEP recommendations.
I submit that recommendations of HLWGs are arbitrary and its claim that all hydropower is “renewable and clean” is misplaced. Such myths have been demolished after realizing how hydropower projects have huge impacts on environment, ecology, forests, rivers, biodiversity and livelihood security of the people.
I submit that each and every hydropower project has a finite life. Therefore, for the inhabitants of the basins in the Western Ghats and everyone else, hydropower cannot be deemed renewable. This creates a sound reason for avoiding large dams in the ecologically sensitive zones (ESZ) of
Western Ghats as has been recommended by the WGEEP report.
I submit that environmental clearance for mini hydro projects of less than 25 MW is not required as per the EIA Notification 2006. This is a grave omission. These projects must be brought under the ambit of EIA Notification 2006. There is a threat of these projects on river systems in Western Ghats and as a consequence the Karnataka High Court has banned any new mini hydel projects in Karnataka Western Ghats. The ministry should amend the EIA Notification 2006 and include all hydel projects above 1 MW in its purview.
I submit that unlike WGEEP Report that had recommended no large dams in ESZ I and II, the HLWG fails to deal with these dams. As a consequence, their impacts on forests and communities get entirely ignored.
I submit that the ministry should assess environmental flows with holistic and participatory methodology and recommend environmental flows for all dammed rivers in Western Ghats with immediate effect.
I submit that HLWG has failed to internalize the recommendations on dam decommissioning as has also been suggested by the Central Electricity Authority.
I submit that the biodiversity of Western Ghats creates a compelling logic for accepting Western Ghats Ecology Expert Panel’s graded approach in tune with the ecological connectivity of river ecosystems to ensure restoration and protection and not the truncated approach suggested by HLWG.
I submit that the environmentally sensitive and much talked about 522 page Report of the Western Ghats Ecology Expert Panel that was submitted to the Union Environment & Forests Ministry on 31 August 2011 is a rare report.
I submit that the ministry must re-read at least 7 pages of this report from page no. 61-67 wherein Western Ghats Ecology Expert Panel advocates a graded or layered approach, with regulatory as well as promotional measures appropriately fine-tuned to local ecological and social contexts within the broad framework of (1) Regions of highest sensitivity or Ecologically Sensitive Zone 1 (ESZ1), (2) Regions of high sensitivity or ESZ2, and the (3) Regions of moderate sensitivity or ESZ3.
I submit that while Western Ghats Ecology Expert Panel advocates this fine-tuning through a participatory process going down to gram sabhas, it has provided a broad set of guidelines as a starting point. It has attempted to arrive at such a set of broad guide-lines for the various sectors on the basis of extensive consultations with officials, experts, civil society groups and citizens at large. These proposed guidelines and summary recommendations for sector-wise activities are available in the report.
I wish to draw your attention towards the preface of the Western Ghats Ecology Expert Panel report. It reads: "The Western Ghats are naturally an important focus of sustainable development efforts. The protector of the Indian peninsula, the mother of the Godavari, Krishna, Netravathi, Kaveri, Kunthi, Vaigai and a myriad other rivers, Kalidasa likens the Western Ghats to a charming maiden; Agastyamalai is her head, Annamalai and Nilgiri the breasts, her hips the broad ranges of Kanara and Goa, her legs the northern Sahyadris. Once the lady was adorned by a sari of rich green hues; today her mantle lies in shreds and tatters. It has been torn asunder by the greed of the elite and gnawed at by the poor, striving to eke out a subsistence. This is a great tragedy, for this hill range is the backbone of the ecology and economy of south India."
I submit that the Western Ghats Ecology Expert Panel report referred to Goa's Regional Plan 2021 that took inputs from Gram Sabhas in deciding on land use policies. This report merits the serious attention of the ministry.
I have learnt that there is a Tamil saying that ‘sea begins in the mountains’ taking cognizance of this wisdom, I submit that Ganga River Basin Authority has proven itself to be too weak to act, the Report of the Western Ghats Ecology Expert Panel creates a compelling logic for a similar but a high powered panel on Himalayan Watershed to set matters right in the Ganga basin.
I submit that ministry should initiate the process of making at least one river in Western Ghats in a state of free flowing without any impediments and to assess its wealth generating potential vis-à-vis dammed rivers.
I submit that an anthropocentric approach towards Western Ghats and its rivers is a contrary to the interests of the present and future generation of all the species in the region.
In view of these observations, Western Ghats Ecology Expert Panel should be asked to review and respond to the report of the HLWG to facilitate structural intervention to set matters right in the Western Ghats.
ToxicsWatch Alliance (TWA)