Tuesday, 10 May 2011

Dr.M.K.Ranjithsinh's Dissent Note to MoEF

Dear Smt. Prakriti Srivastava,

You would recollect that during the course of the 22nd meeting of the Standing Committee on 25.04.2011 during which some fifty proposals were hurriedly discussed and most approved, I had said that I would like my dissent / observations to be recorded in the minutes and the Chairman had agreed that it would be done.  I am therefore, sending my dissent / observations,  as follows:

1.  As was mentioned in the meeting itself by some members, the agenda items must be sent well in advance and that in future additional agenda items must not be given in the meeting for the first time.  Unlike in the past, maps are now being provided with the proposals but not in all cases.  However, crucial information such as the opinion of the state wildlife advisory boards without which the Standing Committee cannot consider the proposals, must be clearly stated in the project format prepared for each proposal.  It was noticed that in a number of cases, especially in the case of Madhya Pradesh, the number of trees to be felled was simply not given.  This is a very important requirement and proposals which lack this data should not be considered.

2.  There was far little time allotted for the meeting with the agenda that it had, as a result of which items on conservation suggested by the members were not discussed.  This has frequently occurred in the past.  In view of the very infrequent meetings of the full NBWL, the Standing Committee is the only fora where conservation issues can be raised by the members and if even this opportunity is denied, then the Standing Committee would only be a project clearance committee and nothing more.  The matter could be resolved by having  longer duration meetings and more frequent meetings, which the Chairman has acknowledged and agreed to.

Apart from these general observations above, I would like to make some specific mention in relation with certain agenda items;

A)  The Parvan major irrigation project, Rajasthan, which will submerge 81.67 sq.km. of the Shergarh Wildlife Sanctuary and what is more, will result in the destruction of approximately 186443 trees, in a tree deficit state like Rajasthan. Furthermore, even though 25cusecs of water is proposed to be continuously released into the Chambal from the proposed dam, this project will result in a major diversion of water from the Chambal, which has already been identified as deficient in water flow to support the last viable populations of the endangered Gharial and the Dolphin, in the April 2011 report prepared by the Wildlife Institute of India at the instance of the MoEF.  The report specifically recommends that no further diversion of water from the Chambal should take place if the future survival of the endangered aquatic species  mentioned above, is to be secured.  There is also no EIA of the project, with regard to the impact upon the aquatic life and ecology of the downstream Jawahar Sagar Sanctuary, Rana Pratap Sagar Sanctuary  and the National Chambal Sanctuary.

In view of the above, the undersigned would wish to record his dissent to the approval given to the above project.

B)  Items 2[4(2)] : Construction of fencing and patrol road along the Indo-Bangladesh Border in Damp Tiger Reserve, Mizoram; 4.1(3) denotification of Trikuta Wildlife Sanctuary, Jammu and Kashmir, and others : The Standing Committee has always followed the norm that where a substantial portion of a national  park or sanctuary is to be denotified, it would have to be compensated by having at least an equivalent area added elsewhere to the same protected area and if this be not possible, by the creation of another PA or by addition to an existing PA within the state.  An excellent example was Himachal Pradesh, where an additional area larger in size was notified and only thereafter the MoEF, on the recommendation of the Standing Committee, gave permission for the denotification of various parts of PA's in the state.  I would like to very emphatically reiterate, as I mentioned in the meeting itself, that this practice must continue, for otherwise the Standing Committee and hence the NBWL, would only be party to the reduction of the PA's with no areas ever to be added in the future, which cannot be the mandate of these two august bodies, especially in view of the fact that, as we all know, the only hope for the long term survival of India's natural heritage lies in our protected area system.

I would like this dissent note / observation to be recorded in both the above mentioned items where a total denotification of the Trikuta Sanctuary in Kashmir and a large scale secession of the Dampa Tiger Reserve, are envisaged.  Would also wish to mention that the alternate notification adding to a PA or creating a new one to compensate for the denotification of any PA, must precede the propose denotification, as was done in the case of Himachal Pradesh.

These may kindly be incorporated at the appropriate places in the minutes of the meeting.