Saturday, July 27, 2013

Critical evaluation of Kasturirangan Committee report on Western Ghats, in comparison with Madhav Gadgil Committee Report




The essence of WGEEP (Western Ghats Ecology Expert Panel which is commonly known as Gadgil Committee) Report, that the development and conservation can  go hand-in- hand, in a totally democratic and transparent way empowering the local people to decide upon their development options, has disappeared, totally, in the HLWG (High Level Working Group which is commonly known as Kasturirangan Committee) Report.  Economic exploitation of the resources of the Western Ghats has received maximum consideration while conservation and sustainable development have been totally sidelined and neglected, notwithstanding the various pretentious statements on conservation or sweet-coated words on conservation.

The methodology adopted by HLWG declares this agenda unmistakably clear and loud. According to this, only 37% of the Western Ghats, named as natural landscape, needs to be considered for conservation while the rest of the area, referred to as cultural landscape, is opened for any kind of development. In other words, of the 1, 64,280 sq km of the Western Ghats, as defined by the HLWG, some 60,000 sq km has only been set apart for conservation, to be declared as Ecologically Sensitive Area. And, it is to be noted this includes National Parks, Sanctuaries, Reserve Forests, World Heritage Sites and other protected areas.

Paradoxically, within this area also various development activities such as diversion of forests, laying railway lines, construction of roads, construction of  buildings up to but below 2,15,000 sq ft,  even larger  dams are permitted with conditions. The most polluting ‘red’ category industries can be established outside the ESA, i.e. 67% of the Western Ghats, while ‘yellow’ category industries can be set up anywhere in the Western Ghats.  The only bar inside the ESA is for mining, quarrying and sand mining. These activities are other-wise also banned in the protected areas. In effect, HLWG report prepares the ground to open up even the protected areas for development and in a way this amounts to opening up the entire Western Ghats for development. In a State like Kerala facing severe ecological problems (where most of the rivers have become drainage channels and acute scarcity is being experienced in meeting drinking water needs), such a move will destroy the remaining water storing areas of the Western Ghats with disastrous consequences.  It is paradoxical to accept such a report while the State Government is seeking Central assistance to mitigate drought.

Difference between the Ecologically Sensitive Areas recommended in the WGEEP and HLWG reports

      ESA determination

1.        HLWG report suggests division of the Western Ghats into two, namely (1) Natural Landscape consisting of existing Protected Areas, reserve forests and other forested area and, (2) Cultural Landscape consisting of human habitations including agricultural lands and plantations. Only Natural Landscape consisting of 37% of the Western Ghats is to be declared as Ecologically Sensitive Area and be protected. Even in this area which largely consists of forests, development activities are permissible under certain conditions. 

2.        It may be noted that the extent of area fixed as natural area does not conform to the National Forest Policy according to which the minimum forest cover required to be maintained in hilly areas is 66%. HLWG proposes only about half of it. While WGEEP proposes 75% considering the special features of the Western Ghats.

3.         WGEEP report considers the entire Western Ghats as an Ecologically Sensitive Area, considering its significance as source of water for the Western Ghats States and the biodiversity richness, being one of the 8 hottest hot-spots of biodiversity in the world. Further, it was obligatory on WGEEP to do so, since its mandate required that it consider the recommendations of earlier Government bodies on this issue and, the Pronab Sen Committee’s recommendations, accepted by Government of India specify several criteria on the basis of which the entire Western Ghats qualifies as Ecologically Sensitive.

4.         For sustainable development without affecting the environment and ecology, the WGEEP Report proposes a layered approach.   Areas with highest significance as ESA 1, moderately significant as ESA 2 and less significant as ESA 3. (Significance is in terms of biodiversity, cultural, geological, historical, climatic conditions especially quantum of rainfall and the number of rainy days, risk of landslide, and stakeholders' views). Activities that could be undertaken in each are given separately with controls and limitations.

5.        One striking feature of the WGEEP is that its recommendations, which include, inter-alia, finalizing the borders of ESA 1, 2 and 3 and the activities to be undertaken within each of them, are to be discussed at grass root level and decisions taken by the Grama Sabha and LSG. Whereas, the HLWG’s recommendations are final and there is no scope for any discussion.  It recommends 37% of the Western Ghats to be declared as ESA forthwith, without any discussion at any level.

6.         The map generated for ESA by HLWG used 24 meter resolution IRS data, whereas the WGEEP used 30 m resolution Landast- TM data which is spatially not significantly different from the 24 m IRS data.  In fact the spectral resolution of Landsat TM is much better than that of IRS data sets!

7.         WGEEP aggregated the data and put them in 9 sq km grid mainly for administrative convenience. It could have been presented in 5 sq km grid or even smaller size. For Kerala, it was worked out in 1 sq km, but finally presented in 9 sq km for uniformity. For Goa also it was done the same way. In wrongly comparing HLWG’s actual 24 meter resolution with the projected 9 X 9 km grid information, HLWG misleads people into believing that HLWG’s spatial data is far better while in reality the difference is very insignificant. Not only that HLWG failed to have a discussion with WGEEP to seek clarification, but instead went ahead to depict WGEEP data as coarse by incorrectly depicting the 9 sq km grid as the resolution.
Not holding such a discussion with the WGEEP is a clear violation of established scientific practice, indeed of scientific ethic.

8.        The ESA proposed by the HLWG is based mainly on the distribution of flora.  There is nothing on fauna, apart from considering the elephant and tiger corridors.  WGEEP has taken on board both flora and fauna, with details such as their rarity, endemism, abundance.

9.        The WGEEP created a comprehensive, spatially-referenced database on flora, fauna and a series of important ecological parameters based on the available data. The HLWG has not even considered it and ended up with an ESA which has not included the elements of fauna. At this point it is pertinent to mention that a specific request had been made to Dr Kasturirangan to take immediate steps to build further on this data-base on two separate occasions, prior to the setting up of HLWG, through the Report of the Working Group on Ecosystem Resilience, Biodiversity and Sustainable Livelihoods for the XII Five-Year Plan, Planning Commission – Environment & Forest Division, Steering Committee – Environment, Forests & Wildlife and Animal Welfare. The report has the following explicit statement: The Western Ghats Ecology Expert Panel of the Ministry of Environment and Forests has made excellent progress in the development of such a spatial database, for over 2200 grids of 5’x5’ or roughly 9 km x 9 km through compilation of all readily available information on topography, land cover and occurrence of biodiversity elements for the Western Ghats. XII FYP schemes should pursue vigorously further development of this database, and its extension to other parts of the country, by networking many available databases, such as the National Knowledge Commission endorsed Knowledge portals such as the India Biodiversity Portal (IBP),   and other portals such as the Indian Bioresource Information Network (IBIN), and that prepared in connection with Zonal Atlases for Siting of Industries, and Goa Regional Plan 2021. Having accepted such specific recommendations of the sub-group which were submitted to the Steering Committee Chaired by none other than Dr. Kasturirangan and, later rejecting them totally by the HLWG Chaired again by the same person, Dr. Kasturirangan is just unbelievable. Have we buried the ethics, ethics in science, so totally?

10.    HLWG report explicitly mentions that wildlife habitats are not included in the demarcation of ESA.

11.    Moreover, the HLWG has not considered the principles and practices in ecology and conservation biology while deciding the ESA. The ESA as elucidated for the Mudigere taluk in Chikamangalur district shows that they are in patches (according to HLWG), while it is a contiguous stretch of land with different layers (ESZ 1,2,3)  for development and conservation depending on the degree of significance of the area (according to WGEEP). See the figures from the HLWG report, given below:



                     

Note: Fig.A: ESA proposed by the HLWG (yellow) is superimposed on the ESZ 1 (red), ESZ 2 (grey) and ESZ 3 (green) proposed by WGEEP for Mudigere taluka in Chickamangalore
Fig. B: Vegetation map of the Mudegere Taluka (HLWG: pages 62, 61)

12.    Therefore, the ESA proposed by the HLWG does not reflect the landscape approach for conservation and development. It does not serve the purpose of biodiversity conservation. The only purpose that HLWG report achieved is to open up almost two-third of Western Ghats for the so called development with no checks and balances.

13.    Even in defining the Western Ghats area, which of course is not in the mandates of the HLWG, it has reviewed the past work and adhered to the old delineation given by the Planning Commission for WGDP. It was based, in nutshell, on altitude and, talukas and blocks. Those talukas having more than 20% of its area above 600 m is considered as Western Ghats. It may be noted that talukas and blocks are administrative units, based on various parameters. It could change also. And, these are not natural units. The WGEEP considered two main parameters which are natural, namely altitude and vegetation. There are no artificial elements in this.  Even with this scientific approach, WGEEP concludes that further discussion is required to fix the borders of Western Ghats and thus kept it open for further discussion and finalization. As far as HLWG is concerned nothing is left for discussion. Its decision is final!

14.    The HLWG, before plunging into the exercise of fixing a totally different ESA, made a comment that HLWG found the following limitations in the ESZs suggested by the WGEEP: (i) using incomplete backup information for designating the entire Western Ghats as ESA, (ii) identifying ESZs without taking into account the human cultural component which is part of biodiversity, livelihood, and development needs of human populations, and disturbance regime, and (iii) coarse grid size used for zoning. It is a case of clear misunderstanding of the report of the WGEEP or a deliberate attempt to discard the zones suggested by the WGEEP and to create a new report with a different ESA releasing maximum area for the so called development.

I.           It is not clear what is meant by ‘incomplete backup information’. One of the main criteria suggested by Pronab Sen Committee, which is accepted by the Government of India, to declare an area as ESA, is presence of endemic species. Endemics of different species would cover the entire geographical extent of the Western Ghats. WGEEP endorsed the recommendations of the Pronab Sen Committee. Moreover, protection of the ecological integrity of the Western Ghats is a must for the life of the people in six States who are depending on its resources. 

II.         The observation that “WGEEP had not considered the human cultural and development aspects while suggesting ESZs”, is totally wrong.  WGEEP has given maximum emphasis on these two aspects throughout the report. It appears the WGEEP report is either mistaken completely or read with pre-conceived perceptions.

III.         Corse grid size used for zoning: If the methodology used by WGEEP was understood properly, this misleading comment would not have been made, that too frequently in the HLWG report.  The often made statement in the HLWG report that it has used ‘fine resolution’, in reality is different from that used by the WGEEP only in 6 meter! The resolution used by the WGEEP is 30 meter and that by the HLWG is 24 meter which is not substantially different. WGEEP has aggregated the data to present the information in 9 km2 grids.

It should also be noted that WGEEP provided a broad framework for ESZ grouping,  underscoring the need for local involvement in refining the allocation of area under different ESZs giving due consideration for all aspects of land use, finally to be decided by LSGs and Grama Sabhas. In contrast to this, HLWG has adopted a highly top-down approach totally relying on very limited geo-spatial data. Notwithstanding very severe limitations, HLWG considers its classification as final and recommends to the Government to declare the ESZ without in any way giving an opportunity for any further discussion.  This is nothing more than a techno-centric arrogance.

15.    The ESA designated by the HLWG has considered village as a unit; those which have more than 20% of the area under natural landscape are considered as ESA.   Another factor said to be considered is the amount of fragmentation which has been graded as low, medium and high. Area with low and medium fragmentation with very high or high biological richness has been considered as ESA. But medium fragmentation with high biological richness is included only if the population density is less than 100/sq km. Area with high fragmentation is not included in the ESA. This indicates lack of understanding of conservation biology. Highly fragmented areas also should be given high importance for conservation. What is needed is to consider the entire area with low, medium and high fragmentation as one unit and declare them as ESA adopting a layered approach for development, so that the purpose of conservation and development needs of the people are well integrated.     It may also have to be noted that the cultural area is under greater human pressure and are under the grip of severe environmental problems and therefore, these areas should have been brought under the ESA to facilitate ecological restoration through more environment friendly practices.  By excluding the cultural landscape from the purview of ESA, HLWG has given a green signal for their continued destruction and degradation. The sharp distinction drawn between cultural and natural landscapes and the total exclusion of cultural landscapes from the purview of any regulation amounts explicitly and implicitly treating development and conservation as fragmented pursuits. It is surprising to note that the HLWG consisting of eminent persons have adopted such a fragmented approach. As such, areas requiring significant intervention to arrest further degradation and revival of vital life support systems are totally excluded from the purview of eco-sensitivity, while areas that are much better protected are included under ESAs. This clearly reflects the lack of understanding of the real development/ conservation issues in the Western Ghats.  In a way it reflects the distorted perception of what development is all about?

16.    One important question is what is the fate of small patches of forests within the Cultural Landscape? More importantly the sacred groves. It is our culture and tradition to preserve the sacred groves. HLWG has not even cared about the protection of these culturally important remnant forest patches within the Cultural landscape.  Is it not a paradox?

17.    The HLWG says that the ESAs developed by it could be used as a model and ‘replicated elsewhere at the national and regional level’. It would be a blunder, if the government accepts it. The ESA delineated using only the vegetation data ignoring the faunistic features is totally unacceptable and hence should be rejected outright.

18.    Again, it is vital to look at all aspects of biodiversity; and studies world-wide, including in India point to the fact that freshwater biodiversity is even under greater threat than forest biodiversity. WGEEP perspective considers this properly, including in its specific consideration of riverine forests, whereas the HLWG just ignores it.

19.    The statement that “forested and natural landscapes are the best available fine resolution and spatially consistent proxies in the absence of high resolution data on faunal distributions”’ (Page 97: HLWG) is totally incorrect.  Data on major faunal elements
       are available, but the HLWG did not use it for reasons best known to it. This act also reflects the negative approaches of the HLWG towards science.

20.    HLWG again states (page 97, xii) that “the conclusions on the delineation of ESA presented in the Report are based on the best of the contemporary analytical approaches and latest databases.”  By saying so it would not become. The latest database on faunal elements which is available has not been used. Hence the statement is totally incorrect.

21.    Whether the MoEF has asked the HLWG to examine the methodology adopted for Zoning, and if found unacceptable suggest an alternative methodology is yet another matter. It was not given in the terms of reference of the HLWG.  HLWG quotes some of the statements of those opposing the recommendations of the WGEEP and makes conclusions against the WGEEP while trying to make it appear as though the conclusions are of the planters and others.  It is unfortunate that the HLWG appears to have not taken the trouble of analyzing the recommendations in the light of specific objections. For example, it quotes the objection of the coffee planters. ”The Kodagu coffee growers and planters association made a strong representation to the High Level Working Group that the district should be kept out of the Gadgil Committee recommendations. Their argument was that they have a strong tradition of cultivation of coffee, cardamom and other crops. They practice techniques which protect the soil, recharge ground water through ponds and use organic manure. Their life is not harmful to the environment”

    In what way the WGEEP recommendations go against their interest is not given, nor did the HLWG ask them to specify. In fact WGEEP has strongly recommended such environment-friendly practices and even proposed financial assistance to such farmers.  HLWG should have explained the actual provisions in the report rather than taking it as yet another excuse for writing a totally different report with different agenda.

22.     Another classical example that explains itself that the HLWG was searching for excuses to thwart the recommendations of the WGEEP,  is a reported statement of somebody in Maharashtra “when officials explained that there was concern that WGEEP, if implemented could lead to complete halt of economic activity. “It would condemn people to live in stone age.” Instead of analyzing the issues more thoroughly HLWG opted to rely on such casual statements and this at best reflects the total lack of professional competence, or worst a hidden agenda to allow the vested interests to pursue what they have been doing. This is particularly evident that while HLWG quotes the various negative views, it deliberately opted to ignore positive responses in favour of the WGEEP report. For example the HLWG conveniently forgot to quote the resolution passed by   25 Grama Sabhas from Sindhdurg district of Maharashtra to include their respective areas also into the Ecologically Sensitive Zones.

23.    Basically, the HLWG has failed to understand that the WGEEP recommendations are tentative and that the final decision on demarcating the zones and, the activities to be undertaken in each of them has to be taken by the LSGs and Grama Sabhas. The WGEEP clearly states that it gives only a scientific background for the Grama Sabha and the LSGs to decide on the Ecologically Sensitive Zones and the activities to be undertaken in each of them.

24.     HLWG agrees (6.2; page 100) with the   WGEEP’s listing for sector level planning that it “is comprehensive and provides an important direction to what will constitute environmentally sound development in this ecologically rich region.” But it then questions how such a development plan will be implemented? The answer is given very clearly in the WGEEP Report. Even after reading, if it was not clear, the HLWG should have called a meeting with the WGEEP rather than giving its simplistic prescriptions, that too not for facilitating sustainable development but only for accentuating the pace of environmental destruction.

25.    HLWG, under the Sector Level Planning (6.3; page103) lists several points of disputes (with WGEEP report) related to environmentally sound and inclusive development. One among them (6.3 c), the most crucial one, is that “How can development be based on decentralized planning and decision making? In other words, how can local communities including tribals play a greater role in discussing and deciding on the economic future of the region, which is classified as economically sensitive?” How this can be achieved is what exactly WGEEP advocates throughout its report. Questioning the sagacity of decentralized planning and decision making is a direct attack on the devolution of democratic process visualized in the 73rd and 74th Amendments to the Indian Constitution. It certainly is not appropriate for a HLWG appointed by the Government of India, that too chaired by none other than a member of the Planning Commission, to attack the constitutional provisions. It also amounts to insulting the tribal   and local communities.

       Sector level planning in the ESA.

26.    Mining, quarrying and sand mining shall be banned and the existing mining should be closed within five years or till the lease period is over whichever is earlier.  WGEEP says illegal mining and quarrying should be stopped immediately all over the Western Ghats. Whereas, the HLWG allows mining and quarrying in 63% of the Western Ghats and the restrictions come only for 37% of the area.

27.     Forestry: HLWG allows forest diversion with additional safeguards, while WGEEP bans conversion of forest lands for any non-forestry operations. . Please note that Western Ghats now retains only just 7% of the original forest cover.

28.    Land use, agriculture, water and forestry: HLWG does not say anything on these vital issues, except making passing remarks that these should be incorporated in the green growth of the State Governments with adequate incentives and included in the regional plans.   WGEEP gives clear recommendations for all these which serve the interest of the poor and ecological integrity of the Western Ghats.

29.     Conversion of agricultural land: WGEEP recommends that agricultural land should not be diverted for non-agricultural purposes, except for raising forest and for construction of houses of the families which have grown larger. HLWG is silent on this. That means the agriculture land is open for conversion, irrespective of the purpose! Whom does it help in the era of land mafia?

30.    Conversion of government land to private land: WGEEP emphatically states that   there shall not be any conversion of Government land for private purpose. The HLWG cites objection from public, but does not make clear its own stand, as in many other cases.   Conveniently enough, it does not deal with this most crucial issue for the survival of Western Ghats. Reducing the area of ESA and non-banning of forest conversion for private uses would lead to, inter-alia, more encroachments in the Ghats.

31.     Settlements: Anybody could, according to HLWG, construct buildings up to but below 20,000 m2 (2, 15,000 sq feet)   inside the ESA and there are no restrictions outside the ESA, apart from the existing guidelines. That means the building construction can flourish in the entire Western Ghats.  This would make a boost for the construction lobby. WGEEP asks for a building Code and recommends that all houses should be environment friendly (meaning using less cement, steel and stones and with water harvesting systems and facilities for waste management). The HLWG did not attach any importance to this crucial issue.
   
32.    Building sites: WGEEP recommends that even sites for construction should avoid canals, wetlands, biodiversity pockets. HLWG does not mention these at all, thereby appears to have attached no importance to these life support systems.

33.    Larger dams are allowed in the ESA by the HLWG with a set of conditions, that too without any scientific backing, that it should be 3 km from the nearest dam, ensure 30% minimum flow in the lean season and, 50% of the river should be free from development activities. How did the Committee reach at these figures are not mentioned. WGEEP suggests that no check dams should be constructed in the first and second order rivers while permitting  hydroelectric project for 10 MW in ESZ 1, 10-25 MW in  ESZ 2 and larger dams in ESZ 3

34.    Power: According to HLWG, hydropower seems to have taken the centre stage; wind energy is also mentioned, suggesting that it should also require EIA as suggested by WGEEP. WGEEP emphasises more on solar power which, certainly, is the most environment – friendly alternative for power.

35.    Water conservation: There is no specific recommendation on water conservation in the ESA by HLWG. WGEEP has suggested measures for water conservation and, how decentralized the water distribution system should be.  It is all the more significant at a time when Government is going ahead with privatization of drinking water. Non-mentioning of water distribution system by HLWG at a time when the National Water Policy aiming at privatization of water assumes greater significance, especially when the Committee itself is chaired by none other than a Member of the Planning Commission.

36.    Agriculture: The HLWG excludes agriculture from the ESA. It does not speak of agriculture in totality, but does so specifically for plantations such as coffee, cardamom and tea. Promotion of organic cultivation and a certification system aiming at world market are suggested. Farming practices in rice, millets, vegetables, fruits and also the issues of marginal farmers are not touched.  Although the HLWG suggests promotion of organic farming, it appears as though it is not serious on its own recommendation, as there is no time limit for conversion. This is against the organic farming policy of the Kerala State. WGEEP recommends conversion to organic agriculture within 5 years in Zone 1, 8 years in zone 2 and 10 years in Zone 3. Compensation during the period of conversion is also suggested. This is almost in line with the organic farming policy of the Kerala State Government. Lifting the time – frame for conversion by HLWG is making the suggestion itself  ineffective and nullifying, but  certainly lead  to the  benefit of the manufacturers of the pesticides and fertilizers. The   opinion that conversion to organic farming would lead loss to the farmers reflects only ignorance of the development in organic farming or a definite approach in favour of the manufacturers of pesticides and fertilizers.

37.    Incentives to farmers:  WGEEP specifically recommends incentives to farmers who are involved in: a) adopting traditional varieties, b) organic farming, c) promoting traditional livestock, d) culturing indigenous species of fish, e) protecting sacred groves, f) growing indigenous species of trees, g) switching over to perennial crops in areas where the  slope is more than 300 . . It also recommends the government to pay for the soil Carbon  sequestered. Such recommendations having  direct benefits to the farmers  have no place in the HLWG Report.

38.    Decommissioning of dams: The suggestion for decommissioning of those dams which have crossed their viable life span, outlived their utility, silted up beyond acceptable standards as suggested by the WGEEP, is rejected since many people who have responded to WGEEP Report have objected to it.  It is unfortunate that the HLWG comprising various experts does not appear to have assessed merits and demerits of the suggestion. Dam “decommissioning” is not dam “demolition”.  As per the ICOLD, the following factors have to be assessed for deciding whether a dam is to be decommissioned or not:  Structural safety  due to age,  weakness, structural  problems, construction defects; Reservoir siltation  reaching a stage where it is unable to store water as envisaged; Reduction in  benefits   due to poor design, inefficient turbines; Economic costs  for maintaining the dam and the benefit that the dam  offers to the society - a balancing of the two;  Ecological damage  caused to biodiversity  and other economic loss.

         An expert committee for each of this should make an assessment and that has to be evaluated to take a decision whether the dam should be decommissioned or not and, it takes a minimum of 10 years. HLWG should have gone through the literature on decommissioning of dams before reaching a conclusion based on the immediate reaction of people. Or else, should have had a discussion with the WGEEP to clarify it.

39.         Roads and railway lines are recommended by both the Committees with a condition that there should be a Cumulative Impact Assessment. WGEEP restricts roads and railway lines to areas where they are very essential, whereas HLWG does not propose any restrictions.

40.          Railway projects do not require EIA clearance even when it goes through the ESA according to HLWG. That means there is no need for any clearance for railway lines in the whole of Western Ghats. The reason for this as given is very interesting: the proponents of railway projects would take care of the environmental safeguards, considering the major implications on wildlife, forestry, and biodiversity and, the incidence of accidents involving wildlife. How much the railways care about the biodiversity and wildlife is clear from their own past? It is on record that Konkan Railway completely ignored the recommendations of the Indian Institute of Science to make slight adjustments in its working to avoid destruction of mangrove and of Carambolim wetland in Goa!

41.         Industries: HLWG recommends ban on Red category industries in ESA and allows orange category industries, while WGEEP bans new polluting (red and orange category) industries in Zone 1 & 2; and, suggests that existing polluting industries switch over to zero pollution by 2016 and be subject to strict regulation and social audit. It also suggests new industries may be set up in Zone 3 under strict regulation and social audit.

         The point that should be considered here is that HLWG limits the polluting industries only in the ESA suggested by it which comprises only 37% of the Western Ghats, whereas the WGEEP speaks for restrictions in the entire Western Ghats. This should be read in the light of the recent studies reporting pollution of the rivers and other water bodies.

42.         Financial arrangements for   the Western Ghats States: The HLWG suggests the following major  financial arrangements for the Western Ghats States:

(a)          Compute forest ecosystem services to make payments for standing crops in Eco-sensitive Areas:  The suggestion is to provide additional funds to the States considering the ecosystem services of the forests inside the ESA. This is already in existence now as per the HLWG report. It has proposed for an increase in the amount. WGEEP has also asked for additional funds for the Western Ghats States for protecting the forests.

(b)          The HLWG suggests that the financial arrangements should be of the nature of a debt for nature swap. A part of the debt to be paid back to the Centre could be utilized for conservation activities, community projects, to improve forest productivity and to ensure sustainable forest based livelihood and, to that extent the State government’s outstanding debt will be released. While this concept borrows from some of the international initiatives where lending countries agree to write off outstanding debt (one way a conditionality), the practical feasibility of this in a federal set up like ours needs to be examined in detail, considering other priorities of the governments. Most governments are facing severe debt crisis and are unable to meet even salary obligations. Notwithstanding the narrow institutional differences between the State and Central governments, a public debt is a debt to be shouldered by citizens and, hence making debt-for-nature-swap is a meaningless instrument to encourage conservation. It is a pity that HLWG has borrowed a fashionable term without examining its relevance in the existing national context.

(c)           Hydrological service and local community: HLWG advocates computing hydrological service provided by forests and their livelihood benefits on local communities. There are some inbuilt dangers to it in the social context, especially when there is a move to privatize water. Water as air, can never be considered as a commercial commodity and assign a price to it. Once a price tag is attached, it would be misappropriated and water is unlikely to reach the poor section of the people and, if at all it does, it would cost dearly. However, the communities which are living close-by the forests should be given some additional benefits to fulfill their basic requirements. WGEEP suggests various ways and means to pay ecosystem service charges to the individuals, but not specifically for water.

43.         Western Ghats Ecology Authority: One of the mandates of the WGEEP was to propose guidelines for establishing a Western Ghats Ecology Authority which according to the Government of India should be ‘a professional body to manage the ecology and sustainable development of the region’. The decision to set up the same was already taken by the MOEF. WGEEP was asked to suggest modalities and guidelines. (HLWG projects it out, as though it was mooted by the WGEEP).  It proposed a democratic decision making system with the involvement of  representatives of line departments, civil societies, experts and local communities in a  three tier  administrative system consisting of a Western Ghats Ecology Authority (WGEA), a State Western Ghats Ecology Authority (SWGEA) and a District Ecology Commission (DEC). One of the vital roles of the WGEA and SWGEA and the DEC is to coordinate the activities of the various departments at different levels.  Absence of such a set up underlines the failure of projects from inception to execution. WGEA has to coordinate the activities in the Western Ghats part of the various states.   Such an authority will not be a ‘super authority’ and will not question the rights and powers of the States under the federal system as has been alleged and accepted, unfortunately,  by the HLWG.  It will be under the MoEF and will only help speed up the process of clearance to be obtained from the MoEF as per the present statutes. HLWG’s recommendation  that the existing High level Committee strengthened by incorporating the Chief Ministers of the six States would serve the purpose of the WGEA, reflects undoubtedly that the HLWG has  not taken the trouble of understanding  the role and functions of the WGEA.  The other suggestion as a substitute of WGEA that the existing set up of departments, Pollution Control Board and various other establishments including the State Western Ghats Cell will take care of the Governance and regulations of the ESA, shows only that the HLWG  is not serious about the ESA  and the ecological security of the Western Ghats. In this context it may be noted that the HLWG itself says (page 102) that “it is also a fact that permit based regulations are often open for misinterpretation and misuse.”  It is precisely because of this, the WGEEP suggested a very transparent three tier system involving both the line departments and civil society members to manage the affairs of the Ecologically Sensitive Zones.

44.          The suggestion that strengthening existing systems is adequate to protect Western Ghats indicates the lack of understanding of the reasons underlying the ongoing destruction in the Western Ghats and elsewhere.  Weak governance under existing institutional arrangements has been the basic cause of environmental destruction.  Most government departments function as fragmented sectors and the Planning Commission is well aware that this has been a basic cause of faulty development initiatives that in turn leads to poor environmental governance. To repose faith in existing departments indicate the inability to understand the ground reality. HLWG should have thought of how  did our forests get  shrunk, the rivers get dry,  the remaining  water  get polluted and, in Kerala alone 11.71 lakhs ha of wetlands got disappeared  from 2007 to 2011, paddy fields got shrunk just to 2.34 lakh ha from 8 lakh ha in 1975. These are to be answered by the existing set up and those who oppose the Union Government’s well meaning proposal to introduce a new set up.

45.         Decision Support and Monitoring Centre: It is rather curious to note that the HLWG which rejects the Western Ghats Ecology Authority stating that all the   States have rejected the proposal (only 0.63% of all the responses!)  on the ground that the existing set up would take care, proposes, in the same breath, a different   institution with a heavy load of geospatial activities!  It says that such a “centre will be the decision support for ensuring the environment and regulation of ESA”.  The WGEA covers all these purposes, and in addition a democratic set up to consider the aspirations of people. Maintaining data banks and periodical up-gradation of the same using geospatial technology wherever required is also envisaged under the WGEA. There are excellent records of ecologists working with geospatial experts. It may be noted that there is no substitute for field work. There is no doubt that the MoEF’s  professed welcome objective behind setting up the WGEA that it should be a  ‘professional body to manage the ecology and sustainable development of the region’ can never be met by the proposed  Decision Support and Monitoring Centre.  

46.         Vital issues not mentioned in the HLWG Report: It does not mention waste treatment, hazardous waste treatment processing units, incentives to the farmers, animal husbandry, fish and fisheries, water conservation and distribution, and introduction of Genetically Modified (GM) crops.  WGEEP recommends ban on GM in the entire Western Ghats.  The absence of GM in the sector-wise recommendations of the HLWG makes it more conspicuous, especially when a member of the Planning Commission of a Government that insists on introducing GM that too against the wishes of the people, presides over the Committee.

47.         The HLWG report violates the National Forest Policy which insists maintenance of 66% of forest cover in the hilly areas. That means only the remaining 34% of the area is left for other activities. Instead, HLWG recommends 37% for conservation as Natural Landscape and 63% for all kinds of development, contradicting the objectives of the 1988 National Forest Policy. Again in the Natural Landscape (ESA) also virtually most of the activities are permitted with conditions. In doing so, HLWG tramples upon the aspirations of the poor, and disregards the bare minimum requirements for ensuring the ecological security of the Western Ghats.  Ensuring water for the people is sacrificed for the ‘development’ of a few. It is to be noted that 52% out of the 81% of people who opposed WGEEP report comprises people involved in mining!  (See the figure given below from the HLWG report). Unfortunately, the HLWG not only goes in their favour, but advocates measures to protect their interest. Is it not curious to note that HLWG in its Report (Annexure 3) mentions that “34% of the responses from locals strongly support permitting mining.” Strangely enough, it avoids saying 64% of the locals were against granting permission for mining. And, since 34% wants mining, HLWG recommends lifting of moratorium! What a scientific analysis of data with total social commitment!

                                          Fig. 1 A of HLWG Report: page 10

                                

48.         The WGEEP stands for the poor and socially backward while preserving the ecological integrity of the Western Ghats with utmost importance to democratic process. On the other hand, the HLWG adopting an autocratic process lends its support behind the people who have been exploiting the resources of the Western Ghats with least importance to its ecological security. 
49.         The MoEF may also note that the HLWG Report is not in conformity with the mandates given to it. It was asked to examine, inter-alia,

(i) the Western Ghats Ecology Expert Panel Report in a holistic and multidisciplinary fashion in the light of the comments received from the concerned State Governments/Central Ministries/Stakeholders considering the following important aspects:

a)   the imperatives of equitable economic and social growth of the region in the most sustainable manner with special attention and importance to the preservation of the precious biodiversity, wildlife, flora and fauna of the Western Ghats and to prevent further degradation of the same;

b)   the rights, needs and development aspirations of local and indigenous people, tribal, forest dwellers and the most disadvantaged sections of the local community recognizing the importance of equitable economic and social growth being harmoniously balanced with sustainable development and environmental integrity.

(Ii) recommend further course of action to the Government with respect to the WGEEP Report and,

(iii) the Committee will submit an action Plan to implement the WGEEP Report in the most effective and holistic manner with in a period of two months.

50.    Violating all these mandates, the HLWG created a new report by making an excuse that majority of the responses received was against the WGEEP recommendations.

a)          The analysis of the response, as mentioned above, shows that majority of the objections are from the mining lobby (as much as 52% out of the 81%). As though to satisfy them and the building lobby, HLWG has opened up 67% of the Western Ghats confining the ESA only to 37% area. And there also constructions do not have any restriction as buildings less than 2, 15,000 sq ft are permitted.

b)          The HLWG formulated a new methodology which is totally inadequate and much inferior to that followed by the WGEEP.

c)           There is not even a modicum of substance in the HLWG report addressing the most crucial issues referred to it   such as equitable economic and social growth of the region; the rights, needs and development aspirations of local and indigenous people; and, preservation of the ecological integrity of the Western Ghats. On the contrary the report goes in a diagonally opposite direction, supporting unsustainable and irrational exploitation of the resources of the Western Ghats.

d)          HLWG has not given any action plan to implement the recommendations of the WGEEP report.

51.    To sum up, the HLWG report has erred on facts, analyses and experiences. It is devoid of any scientific content. Based on half-baked information, it has focused on undermining the recommendations of the WFEEP report catering to the demands of vested interests. It does not even conform to the most important mandates given to it, namely the development philosophy of the MoEF which was reflected in its terms of reference. It relied on the responses of a small segment of the population to castigate WGEEP report as anti-development.  Its recommendations will only help to accelerate the pace of destruction of the Western Ghats. Hence, the report should be rejected in toto and early action to be initiated to implement the recommendations of the WGEEP report. The points of discord as raised could be settled through discussions during implementation. After all, the Grama Sabhas and Panchayats have to take final decisions on most of the recommendations of the WGEEP. The best option, however, for the MoEF would have been to get the summary of the report of the WGEEP translated into local languages and send to the panchayats and Grama Sabhas of the Western Ghats and seek their comments/opinion.

Tuesday, October 23, 2012

ഇ.എഫ്.എല്‍ ഭേദഗതിക്കെതിരെ പരാതി

ബഹുമാനപ്പെട്ട മുഖ്യമന്ത്രിക്ക്,

പാരിസ്ഥിതിക ദുര്‍ബ്ബല പ്രദേശങ്ങള്‍ സംരക്ഷിക്കുന്നതിനും പരിപാലിക്കുന്നതിനുമായി സംസ്ഥാനത്ത് നിലവിലുള്ള ഇ.എഫ്.എല്‍ നിയമം-2003 ഭേദഗതി ചെയ്യാന്‍ സര്‍ക്കാര്‍ തീരുമാനിച്ചെന്നും അതിനായി ഭേദഗതികള്‍ സമര്‍പ്പിക്കപ്പെട്ടു എന്നും മാധ്യമങ്ങളിലൂടെ അറിയുന്നു. എന്നാല്‍ ഇപ്പോള്‍ നിശ്ചയിക്കപ്പെട്ട ഭേദഗതികള്‍ ചെറുകിട കര്‍ഷകരെ സഹായിക്കാനുള്ള യു.ഡി.എഫിന്റെ പ്രഖ്യാപിത ലക്ഷ്യത്തിനു വിരുദ്ധമാണ് എന്ന് മാത്രമല്ല മറിച്ച് വന്‍കിട തോട്ടമുടമകളെ സഹായിക്കാന്‍ ഉതകുന്നതും സര്‍ക്കാരിന്റെ  നിലവിലുള്ള ഇ.എഫ്.എല്‍ കേസുകള്‍ തോല്‍ക്കാനും ആയിരക്കണക്കിന് ഹെക്ടര്‍ പരിസ്ഥിതി ദുര്‍ബ്ബല പ്രദേശങ്ങള്‍ നഷ്ടമാകാന്‍ വരെ കാരണമായേക്കാവുന്നതും ആണ്.

ഇ.എഫ്.എല്‍ നിയമത്തിലെ 3 (1) പ്രകാരം വിജ്ഞാപനം പുറപ്പെടുവിക്കുന്നതിന് മുന്‍പ് ജില്ലാ കലക്ടര്‍ അധ്യക്ഷനായ, ജനപ്രതിനിധികള്‍ അടങ്ങിയ ഒരു സമിതി സ്ഥലം സന്ദര്‍ശിച്ച് കൃഷിഭൂമിയല്ലെന്നു ഉറപ്പു വരുത്തണം എന്നതാണ് ഭേദഗതിയിലെ പ്രധാന നിര്‍ദ്ദേശം. നേരത്തെ  ഇടതുപക്ഷ സര്‍ക്കാരിന്റെ കാലത്ത് കൊണ്ടുവന്ന ഇ.എഫ്.എല്‍ ഓര്‍ഡിനന്‍സ് പ്രകാരം മുന്‍‌കൂര്‍ പരിശോധനയില്ലാതെയാണ് നിരവധി ഭൂമികള്‍ സര്‍ക്കാര്‍ ഏറ്റെടുത്തത്. അതിനാല്‍ നിരവധി പരാതികള്‍ ഉയര്‍ന്നിരുന്നു. എന്നാല്‍ പിന്നീട് യു.ഡി.എഫ് സര്‍ക്കാര്‍ ഇ.എഫ്.എല്‍ നിയമമാക്കിയപ്പോള്‍ വനംവകുപ്പിലെ നിരവധി ഘട്ടങ്ങളിലുള്ള പരിശോധന കഴിയാതെ ഒരു ഭൂമി പരിസ്ഥിതി ദുര്‍ബ്ബല പ്രദേശമായി വിജ്ഞാപനം ചെയ്യാന്‍ പാടില്ലെന്ന് വ്യവസ്ഥ കൊണ്ടുവന്നിരുന്നു. നിലവില്‍ വനംവകുപ്പ് ഉദ്യോഗസ്ഥര്‍ വിവിധ ഘട്ടങ്ങളില്‍ ഭൂമി പരിശോധിച്ച് കൃഷിഭൂമിയല്ലെന്നു ഉറപ്പു വരുത്തിയ ശേഷമേ വിജ്ഞാപനം പുറപ്പെടുവിക്കുന്നുള്ളൂ. ഇനിയുള്ള വിജ്ഞാപനങ്ങള്‍ക്ക് മുന്‍പ് ഭൂമി ജില്ലാ കലക്ടര്‍ ഉള്‍പ്പെട്ട പുതിയ സമിതി മുന്‍കൂറായി പരിശോധിക്കണം എന്ന വ്യവസ്ഥ നിയമത്തില്‍ ഉള്‍പ്പെടുത്തിയാല്‍ അത് നേരത്തെ വിജ്ഞാപനം നടത്തിയ ഭൂമിയുടെ ഉടമസ്ഥരോടുള്ള വിവേചനമായി പരിഗണിക്കപ്പെടും. ഒരു നിയമത്തിനു കീഴില്‍ രണ്ടുതരം നീതി നടപ്പാക്കുന്നതിന് എതിരെയും, കമ്മിറ്റിയുടെ പരിശോധനയെന്ന പുതിയ വ്യവസ്ഥ തങ്ങള്‍ക്കു ലഭിക്കാത്തതിനാല്‍ നേരത്തെ നടത്തിയ വിഞാപനങ്ങള്‍ റദ്ദാക്കാനും തോട്ടമുടമകള്‍ കോടതിയെ സമീപിച്ചാല്‍ അത് സര്‍ക്കാരിനെ പ്രതികൂലമായി ബാധിക്കുമെന്ന കാര്യത്തില്‍ സംശയമില്ല. ഈ നിയമം തന്നെ ഭരണഘടനാവിരുദ്ധമാണ് എന്ന തോട്ടമുടമകളുടെ തെറ്റായ വാദം ശക്തിപ്പെടുത്താന്‍ പുതിയ ഭേദഗതി കാരണമാകും. അങ്ങനെയായാല്‍ ഇതുവരെ വിജ്ഞാപനം നടത്തിയ പരിസ്ഥിതി ദുര്‍ബ്ബല ഭൂമികള്‍ സര്‍ക്കാരിന് നഷ്ടപ്പെടാനും വന്‍കിട തോട്ടമുടമകള്‍ക്ക് ലഭിക്കാനും മാത്രമേ ഈ ഭേദഗതി നിര്‍ദ്ദേശം ഉതകൂ എന്നാണു നിയമവിദഗ്ദ്ധരും ചൂണ്ടിക്കാണിക്കുന്നത്. 14000 ഹെക്ടര്‍ പരിസ്ഥിതി ദുര്‍ബ്ബല പ്രദേശങ്ങള്‍ ഇതുവഴി നഷ്ടമായേക്കുമെന്ന് കണക്കാക്കുന്നു.

ഇ.എഫ്.എല്‍ നിയമപ്രകാരം നടത്തുന്ന വിജ്ഞാപനങ്ങള്‍ സംബന്ധിച്ച പരാതികള്‍ സ്വീകരിക്കാനും പുനപ്പരിശോധിക്കാനുമുള്ള അധികാരം ഇ.എഫ്.എല്‍.കസ്റ്റോഡിയനില്‍ നിക്ഷിപ്തമാക്കണം എന്നതാണ് മറ്റൊരു പ്രധാന ഭേദഗതി. നിരവധി പരിശോധനകള്‍ക്ക് ശേഷം കസ്റ്റോഡിയന് തന്നെ ബോധ്യപ്പെട്ട ശേഷമാണ് ഒരു ഭൂമി പരിസ്ഥിതി ദുര്‍ബ്ബല പ്രദേശമായി കസ്റ്റോഡിയന്‍ വിജ്ഞാപനം പുറപ്പെടുവിക്കുന്നത്. പ്രസ്തുത വിജ്ഞാപനം പുന:പരിശോധിക്കാനുള്ള അവകാശം വിജ്ഞാപനം ഇറക്കിയ ഉദ്യോഗസ്ഥന് തന്നെ കൊടുക്കുന്നത് നിയമത്തെ ദുര്‍ബ്ബലപ്പെടുത്തും എന്നു മാത്രമല്ല സ്ഥാപിത താല്പ്പര്യത്തിലൂടെ ചില ഭൂമികള്‍ ഒഴിവാക്കിക്കൊടുക്കാനുള്ള സാധ്യതയും ഉണ്ടാക്കും.  ഈ നിയമപ്രകാരം ഏറ്റെടുത്തതില്‍ 2 ഹെക്ടറോ അതില്ക്കുറവോ ആയ ഭൂമി കൃഷിഭൂമിയാണെന്ന് പരാതിയുണ്ടെങ്കില്‍ പരിഹാരത്തിനായി ചെറുകിട കര്‍ഷകര്‍ക്ക് നിലവിലെ നിയമതില്‍ത്തന്നെ വ്യവസ്ഥയുണ്ട്. പ്രസ്തുത വിജ്ഞാപനത്തിന് എതിരെ സെക്ഷന്‍ 10 എ പ്രകാരം നിയമിതമായ കമ്മിറ്റിയ്ക്ക് പരാതി നല്‍കിയാല്‍ കൃഷിഭൂമിയാണോ എന്ന് പരിശോധിച്ച് പരാതി ശരിയാണെങ്കില്‍ പ്രസ്തുത ഭൂമി ഒഴിവാക്കിക്കൊടുക്കാന്‍ വ്യവസ്ഥയുണ്ട്. എന്നാല്‍ നിയമപ്രകാരം വിജ്ഞാപനം ചെയ്തു ഏറ്റെടുത്ത വന്‍കിട ഭൂവുടമകളുടെ പരാതികള്‍ സെക്ഷന്‍ 9 പ്രകാരം അധികാരപ്പെട്ട ട്രിബൂണല്‍ മുന്‍പാകെ ഉന്നയിക്കാവുന്നതാണ്. നിലവില്‍ ട്രിബൂണലുകള്‍ക്ക് മാത്രം ഉള്ള അധികാരം ഒരുദ്യോഗസ്ഥനു നല്‍കുന്ന ഭേദഗതി ട്രിബൂണലിനെ നിരായുധമാക്കാനും, രാഷ്ട്രീയ സമ്മര്‍ദ്ദം ചെലുത്തി വന്‍കിട തോട്ടമുടമകള്‍ക്ക് പരിസ്ഥിതി ദുര്‍ബ്ബല പ്രദേശങ്ങള്‍ സ്വന്തമാക്കാനും കാരണമാവും.

ചെറുകിട കര്‍ഷകര്‍ക്ക് ഇ.എഫ്.എല്‍ നിയമപ്രകാരം നടത്തിയ വിജ്ഞാപനത്തിനെതിരെ പരാതിപ്പെടാന്‍ അനുവദിച്ച സമയം 2010 ഫെബ്രുവരി 19 നു അവസാനിച്ചിരുന്നു. അത്തരം പരാതികള്‍ക്ക് ഇനി ആറു മാസം കൂടി നീട്ടി നല്‍കണമെന്നാണ് മറ്റൊരു ഭേദഗതി നിര്‍ദ്ദേശം. ഇടുക്കി ജില്ലയില്‍ നിന്നും ആകെ മൂന്നു പരാതികളാണ് അവസാന തീയതി കഴിഞ്ഞ കാരണത്താല്‍ നിരസിച്ചത്‌ എന്നു കാണാം. എങ്കിലും അവസാന തീയതി കഴിഞ്ഞ് അപേക്ഷിച്ച ചെറുകിട കര്‍ഷകര്‍ക്ക് നിയമപ്രകാരം അപേക്ഷ നല്‍കുന്നതിന് ഒരവസരം നല്‍കുംവിധമുള്ള ഭേദഗതി സ്വാഗതാര്‍ഹം ആയിരിക്കും.

നിലവില്‍ നിര്‍ദ്ദേശിക്കപ്പെട്ട ഭേദഗതികള്‍ ആപല്‍ക്കരമാണെന്നു വനംവകുപ്പ് ആസ്ഥാനത്തെ നിയമവിഭാഗം തന്നെ സര്‍ക്കാരിനെ അറിയിച്ചിട്ടുണ്ട്. ഇപ്പോള്‍ നിര്‍ദേശിക്കപ്പെട്ട ഭേദഗതികളില്‍ ഇ.എഫ്.എല്‍ നിയമം തന്നെ അട്ടിമറിക്കപ്പെടുന്നതും നിലവില്‍ സര്‍ക്കാരിന്റെ കൈവശമുള്ള 14000 ഹെക്ടറോളം പരിസ്ഥിതി ദുര്‍ബ്ബല പ്രദേശങ്ങള്‍ കൈവിട്ടു പോകുന്നതും അതുവഴി സംസ്ഥാനത്ത് ഗുരുതരമായ പാരിസ്ഥിതിക ദുരന്തം ഉണ്ടാക്കുന്നതും ആണെന്ന് അങ്ങയെ അറിയിക്കുന്നു. ചെറുകിട കര്‍ഷകരെ സഹായിക്കാനുള്ള ഏതു നീക്കവും സ്വാഗതാര്‍ഹമാണെങ്കിലും അതിന്റെ മറവില്‍ വന്‍കിട തോട്ടമുടമകളെ സഹായിക്കുന്ന ഒരു ഭേദഗതിയും യു.ഡി.എഫ് സര്‍ക്കാരിന്റെ ഭാഗത്ത്‌ നിന്ന് ഉണ്ടാവരുതെന്നു അഭ്യര്‍ത്ഥിക്കുന്നു. അതിനാല്‍ ഇ.എഫ്.എല്‍ നിയമത്തില്‍ നിര്‍ദ്ദേശിക്കപ്പെട്ട പ്രസ്തുത ഭേദഗതികള്‍ തള്ളിക്കളയണമെന്ന് വിനീതമായി അഭ്യര്‍ത്ഥിക്കുന്നു.


Friday, March 30, 2012

Electricity Crisis in Kerala and Possible Options -2008

Electricity Crisis in Kerala and Possible Options - 2008.
'Athirappilly HEP is not the solution'

Conserving electricity is conserving nature and the community. It also means conserving the state's as well as our own financial resources

The state of Kerala is 'reeling under severe power shortage' according to the state electricity board. Apart from imposing 30 minutes of load shedding during evening peak hours, the board has now slapped 25% power cut on industries. It has recommended imposing heavy thermal surcharge on all consumers using more than 40 units per month. This is an extraordinary situation for a state having a total installed capacity of more than 3,500MW against a maximum peak demand of about 2,750MW and an annual generating capacity of about 19,000 million units (MU) against last year's consumption of about 15,500MU. The cumulative effect of three separate factors is given as the reason for this situation. The fatal accidents at Panniyar (30MW) and Moozhiyar (Sabarigiri project- 300MW) have kept these stations idle. Reduction in generation from some thermal stations has resulted in the state getting only about 700MW from central generating stations (CGS) against an allocation of 1041MW. To add to the woes, the south west monsoon is yet to pick up in the state even though it is half way through.

A section close to the KSEB has already started putting the blame for this situation on environmentalists suggesting that the controversial Athirappilly project would have solved this situation. Before jumping to any hasty conclusions, we feel that it is necessary to have a thorough analysis of the whole situation so that the public can take a learned stance on the issue.

Proposed Athirappilly project and the present crisis.

The KSEB sources are suggesting a shortage of 3500-4000MU for the current year (It is highly premature to make such an assessment at this stage and to make plans accordingly. This point will be discussed later). When the existing projects cannot produce targeted quantity of electricity, one cannot expect new hydel projects, if implemented, to produce much electricity.  At Athirappilly where almost 85% of electricity is produced during monsoons and which uses a portion of the spill also from existing upstream reservoir (Poringal kuthu HEP), the shortage in generation will be more than that in other stations. In case of a weak monsoon like the one being experienced now, the possible generation from Athirappilly will be as low as 100-150MU. This will be only about 3-4% of the total projected shortage.

The cost of Athirappilly project will be at least Rs. 1000-1200 crores even if one expects the KSEB to perform at its best.  The debt repayment and return on equity @ 80% debt and 20% equity: 15 year repayment alone will be between Rs.120-150 crores per annum. Maintenance cost and employee cost at the station should also be added. At this cost one can easily buy the costliest of thermal power.
Athirappilly project comes with a big list of social and ecological costs. Hence for the first time in the history of the state, people and organizations from all spheres of life are opposing a dam project. The loss of biodiversity rich forests, the loss of beauty of the famous Athirappilly and Vazhachal water falls and related livelihood issues, displacement of primitive tribal families, loss of existing irrigation facility and drinking water availability etc. are the major impacts of the project.

In economic terms, the annual loss of revenue from tourism due to drastic reduction in flow through the Athirappilly and Vazhachal waterfalls will be at least Rs. 12-15 crore rupees excluding the loss to tour and vehicle operators and water theme parks. The loss in agricultural production due to reduction in irrigation has not been estimated, but preliminary assessments suggest this to be at least Rs. 20-25 crores/ annum. The cost of drinking water shortage will only be known after the project is implemented. The ecological service value of the forest land that will be lost if the project is implemented, is worth hundreds of crores according to the State Biodiversity board. The cost of displacement of tribals cannot be calculated in monetary terms nor can the virtual loss of the river system be valued.

Load shedding and power cut- Is it avoidable?

An analysis of the present situation would suggest that even with the reduced availability, it is possible to avoid power cut. After a reduction in availability of 670MW due to accidents in hydel stations and reduced quota from CGS, the remaining installed capacity is about 2830MW. With this we should be able to produce at least 2500-2600MW during peak hours. (One generator at Moozhiyar has resumed operation from 16-7-2008. this provides an additional 50MW.) A sincere campaign with public participation can reduce the peak demand to this level. With a little care on the part of the consumer in avoiding wasteful use of electricity, the daily consumption can be brought to within 40-42MU/day.

This can be made available in the following manner;
CGS                -           14-15 MU/day
Hydel               -           15-16 MU/day
State Thermal   -           10-12 MU/day

The increase in the share of thermal stations in the state from the scheduled quantity of an average of 4.75MU/day to about 10-12MU/day will result in an additional financial burden of about Rs. 4-6crores/day. The consumer can justly demand that the KSEB should bear this additional expense for the time being as the excess rainfall received during last monsoon and this year's summer rains had made available at least about 2000MU of additional hydel power. In economic terms this was worth about Rs.800-1000 crores.

We have to question the rationale behind maintaining the thermal stations in the state if the board is not willing to use it fully even under emergencies. It has to be understood that the state has been scheduling only less than 5% of the capacity from these stations since June 2004 even as it was spending at least Rs.400 crores per annum just to maintain these stations (as fixed cost for NTPC Kayamkulam, BSES Kochi and KPCL Kasargod and salary and maintenance cost for state's own diesel plants at Brahmapuram and Nallalam).

It is the lack of proper planning and the practice of projecting unrealistically high future demands that has resulted in at least 4000-5000MU of production capacity remaining idle for years together, imposing heavy financial burden on the state electricity board.

There are options to tide over the crisis

Within the Box Options

The volume of power shortage for the whole year cannot be predicted at this stage. But the KSEB has gone for a worst case scenario and are trying to create panic among consumers. Looking at the haste with which the board had recommended tariff hike (in the form of thermal surcharge) one has to suspect a conspiracy in the board's projection of shortage.

It will be improper and premature to assess the rain pattern in the coming months as it is consistently defying all predictions. If the rain does pick up in the coming period then the shortage in hydel generation will be restricted to about 10-15%. Similarly the availability from central stations can improve if the production from these stations increases. The actual shortage on March 31st 2009 from hydel stations and CGS could be anywhere between 10-30%. It is possible to manage the situation with the help of the state's thermal stations and some demand side management steps even if the cumulative shortage from CGS and hydel stations goes up to 25%.

Then the availability will be as follows:

Hyde l+ CGS                           -           11,000 MU
State Thermal stations               -             4,100 MU
Total                                        -           15,100 MU (average 41.5 MU/day)
The average consumption in 2007-08 was about 42 MU/day

This scenario in turn would need an additional purchase of about 2400 MU (over and above the original target of 1700 MU) from state's thermal stations and the board may need an additional Rs.2000 crores.
If the cumulative shortage is limited to 20%, then the additional burden will be about Rs.1400 crores.
If it is 15%, additional burden will be about Rs.800 crores.
In addition the revenue from sale of power will be less by about Rs.325 crores due to reduced consumption.

  • If the wind projects under construction are completed on target, it can produce at least 50 MU for the remaining period of the year. Similarly the board must take immediate steps to start operating the new generator (25MW) at Neriyamangalam that was inaugurated by the Hon. Chief Minister in May. These steps can save about Rs.75-100 crores.
  • Transmission and distribution loss continues to be a major issue. The present average T&D loss is about 22% but the T&D loss in domestic and commercial sector during peak hours is more than 40%. The board proposes to bring down the T&D losses to 15% in the next 2 years. A three percent reduction this year will save more than 500MU. This can take care of the additional demand for new connections. (It may be noted that the demand for electricity had remained at almost the same level from 2000 to 2005 even though lakhs of new connections were given each year during that period.). The reduction in T&D loss will considerably bring down the peak demand too.

  • The board and the consumers can actually bring down the present consumption and bring down the additional burden considerably.  By just spending Rs.50-60 crores, the board can replace at least 50 lakh ordinary bulbs with CFL lamps. The peak demand can be brought down by at least 150MW and the energy saved will be more than 200 MU. (If LED lamps are used the savings can be still higher) This single step will lead to a saving of about Rs.125-150 crores.

  • A dedicated and participatory public campaign to avoid wasteful use, alone can save up to 5% of electricity without compromising on the actual needs. This will bring down the demand by about 750MU and the savings by way of avoiding costly thermal power will be about Rs.450 crores.

  • Installing solar power based lights for illuminating the thousands of bill boards dotting the entire state during night can also save on considerable power. The companies putting up the bill boards can easily bear the cost. A similar campaign had been launched in Maharashtra.

The State Government and KSEB should explore the following options too;

  • In case of the availability from CGS remaining at the present level, the state government should take up the matter with the center and demand for compensation from the center.

  • The cost of electricity from the thermal stations in the state includes 16% excise duty and 4% sales tax.  A 50% relaxation in this crisis period can save any where between Rs.150-350 crores (It should be noted that the government will still get the targeted revenue due to increased turn over.)

  • Options to buy electricity from other states at a lesser cost than that of our thermal stations should also be explored.



Outside the Box Options

In our state the dependence on hydroelectricity is to the tune of 45-50% (the national average is around 25%). Hence short fall in rains will seriously affect the power situation in the state. With the frequency of deficient rainfall years increasing considerably in the last 25 years, (this is the fourth such year in this decade itself) this short fall is likely to repeat frequently. We can only solve this by promoting other sources for new projects and there by reducing the share of hydro-power in the whole system. Non-conventional sources can play a big role here.

According to the State Planning Board, the potential for wind power in the state is for 600MW, that for mini-micro hydel projects is 1000MW and the potential from biomass is to the tune of 300MW. The state can target at least 50% of this potential during 11th and 12th Plan period. Many European countries are promoting solar energy in a big way. The cost of solar power has already come down to be on par with that of conventional sources. It is likely to reduce further as the efficiency of the solar panels slated to improve to about 35-40% from the present level of 15-20%. In a tropical country like ours, the future lies in solar power according to many experts.

Demands and actions required

The state electricity board that gets about Rs.1800 crores every year by utilising the waters of our rivers has to share the responsibility of catchment area re-forestation. Improved forest cover in the catchments of hydel projects will improve summer flows in to the reservoirs, thereby increasing both electricity generation and summer river flow. It will also help to improve the micro climate.

The economic and ecological costs of electricity are increasing alarmingly. Hence
optimising the efficiency of existing projects, minimising losses, promoting energy efficient devices and promoting end use discipline becomes extremely important.
Introducing time of the day metering and providing incentives for using less during peak hours and/or imposing penalties for using more at peak hours can help in bridging the peak-off peak difference.

Finally, the consumer and the general public have every right to know the details of the plan of action of the KSEB. The Government must come forward with a 'White Paper' on the electricity scenario including the activities of KSEB. The board should also make sure that informations regarding daily power generation and consumption, storage positions of reservoirs etc. are posted daily on its official website. Details of new projects, if and when they are proposed, must be subjected to thorough public scrutiny before they are finalised.

Sunday, August 21, 2011

Suspicious Bill

Hi ,

I just signed a petition asking Prime Minister Manmohan Singh to stop the Biotechnology Regulatory Authority of India (BRAI) Bill from being passed.

This bill will create a body which will single-handedly clear all genetically modified (GM) crops. Public opposition made the Karnataka government ban field trials of GM crops in the state recently. Now we need to get the national government to stop this bill.
You should ask Prime Minister Manmohan Singh to stop the dangerous BRAI bill too:

http://www.greenpeace.in/take-action/save-your-food/stop-the-brai-bill.php

Regards,



Click here to ask PM Manmohan Singh to save your food
Our government is working on a disastrous recipe. It’s a bill that will place genetically modified (GM) food on our plates, without our knowledge.

The Biotechnology Regulatory Authority of India (BRAI) bill can be tabled anytime in this monsoon session of Parliament. The bill, which is not even public, is being pushed in a hasty and secretive fashion. According to an earlier version leaked by the media, the bill will create a centralised non transparent body which will become the sole approver for GM crops. [1]

By being secretive, the government is only creating more suspicion about the intention of the bill. Public opposition helped stop Bt Brinjal, last year.[2] Now we need to get the national government to stop this bill and save our food.

You should ask Prime Minister Manmohan Singh to stop this bill because it is not transparent.

http://www.greenpeace.in/take-action/save-your-food/stop-the-brai-bill.php

Opposition from people against GM crops in Karnataka made the government declare a ban on the field trials of GM crops in the state. [3] This can be achieved again. Support from lakhs of people will help put pressure on the PM to stop this bill.

The last known draft of the bill had a clause which allowed BRAI to escape the purview of Right to Information.[4] If the bill is passed as is, we will not be able to stop genetic modification of 56 other crops in the pipeline.

Ask the PM to stop this bill now!

http://www.greenpeace.in/take-action/save-your-food/stop-the-brai-bill.php

Thanks a billion!

Photo of Kapil Mishra
Kapil Mishra
Sustainable Agriculture Campaigner
Greenpeace India

P.S. Want to support our campaigns? We don't take money from any corporation, government or political party! We never have, and we never will. Do help Greenpeace remain fiercely and proudly independent. We will send you a Greenpeace T-shirt as a thank you for showing support for our campaigns. Click here to chip in.

Sources:

  1. A law unto itself, www.outlookindia.com, March 8, 2010
    http://www.outlookindia.com/article.aspx?264454
  2. India says no to Bt brinjal, for now, www.rediff.com, February 9, 2010
    http://business.rediff.com/report/2010/feb/09/india-says-no-to-bt-brinjal-for-now.htm
  3. No GM trials in State: Katti, Deccan Herald, July 20, 2011
    http://www.deccanherald.com/content/177877/no-gm-trials-state-katti.html
  4. Biotech Bill: Sweeping powers, glaring omissions, www.rediff.com, March 11, 2010
    http://business.rediff.com/column/2010/mar/11/guest-biotech-bill-glaring-omissions.htm
madiyan@gmail.com

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Tuesday, July 5, 2011

Exclusive: ലൈസന്‍സ് ഇല്ലാത്ത 1500 തടിമില്ലുകള്‍ അടച്ചു പൂട്ടും.


കൊച്ചി: സംസ്ഥാനത്ത് ലൈസന്‍സ് ഇല്ലാതെ പ്രവര്‍ത്തിക്കുന്ന ആയിരത്തി അഞ്ഞൂറോളം തടിമില്ലുകള്‍ പത്തു ദിവസത്തിനകം അടച്ചു പൂട്ടാന്‍ ഹൈക്കോടതി ഉത്തരവ്. വനം കേസുകള്‍ സംബന്ധിച്ച സുപ്രീം കോടതി ഉന്നതാധികാര സമിതിയുടെ അംഗീകാരമില്ലാതെ പ്രവര്‍ത്തിക്കുന്ന മരാധിഷിത വ്യവസായങ്ങളും മില്ലുകളും പത്തു ദിവസത്തിനകം പൂട്ടി ആ വിവരം രേഖാമൂലം അറിയിക്കാനാണ് ഹൈക്കോടതി സിംഗിള്‍ ബെഞ്ച് ഉത്തരവ്.
ജൂണ്‍ 30 നാണ് ജസ്റ്റിസ് പി.ആര്‍ രാമചന്ദ്ര മേനോന്‍ ഈ സുപ്രധാന ഉത്തരവിട്ടത്. വെങ്ങോല പഞ്ചായത്തില്‍ അനധികൃതമായി പ്രവര്‍ത്തിക്കുന്ന പ്ലൈവുഡ് ഫാക്ടറികള്‍ അടച്ചു പൂട്ടണമെന്ന് ആവശ്യപ്പെട്ടു വെങ്ങോല സ്വദേശി കുര്യന്‍ സമര്‍പ്പിച്ച ഹരജിയിലാണ് സംസ്ഥാനത്ത് അനധികൃതമായി നിരവധി പ്ലൈവുഡ് ഫാക്ടറികള്‍ പ്രവര്‍ത്തിക്കുന്നു എന്ന വിവരം ഹൈക്കോടതിയുടെ ശ്രദ്ധയില്‍പ്പെട്ടത്. പത്തു ദിവസത്തിനകം മില്ലുകള്‍ പൂട്ടാനും അതിനായി വേണ്ടിവന്നാല്‍ പോലീസ് സഹായം ഉപയോഗിക്കണമെന്നും ഉത്തരവില്‍ പറയുന്നു.

എറണാകുളം ജില്ലയില്‍ മാത്രം നാനൂറിലധികം തടിമില്ലുകള്‍ ആണ് വനം വകുപ്പിന്‍റെ അനുമതിയില്ലാതെ പ്രവര്‍ത്തിക്കുന്നത്. തടിമില്ലി നുള്ള ലൈസന്‍സിനായി ആയിരക്കണക്കിന് അപേക്ഷകളാണ് ഇപ്പോള്‍ സര്‍ക്കാരിന് ലഭിക്കുന്നത്. പ്രസ്തുത വിധി നടപ്പാക്കി ജൂലൈ ആറിനകം റിപ്പോര്‍ട്ട് നല്‍കാന്‍ വനം വകുപ്പ് മുഖ്യ വനപാലകന്‍ ഉദ്യോഗസ്ഥര്‍ക്ക് നിര്‍ദ്ദേശം നല്‍കിക്കഴിഞ്ഞു.

Thursday, April 28, 2011

എന്‍ഡോസല്ഫാന്‍ ആഗോള നിരോധനത്തിലേക്ക്.

എന്‍ഡോസല്ഫാന്‍ ആഗോള നിരോധനത്തിലേക്ക്....
ഒരുപാട് വിളകള്‍ക്ക് ഇന്ത്യ 'ഒഴിവാക്കല്‍' ചോദിച്ചു... പക്ഷെ, രജിസ്ടര്‍ ചെയ്ത വിളകള്‍ക്കേ നിരോധനം നല്‍കാവൂ എന്ന് പരിസ്ഥിതി സംഘടനകളും വാദിച്ചു. ഒടുവില്‍ ഇന്ത്യ കീഴടങ്ങി. അല്‍പ്പ സമയത്തിനുള്ളില്‍ ജനീവയില്‍ എന്‍ഡോസല്ഫാനേ അനെക്സ് A യില്‍ പെടുത്താനുള്ള അറിയിപ്പ് ചെയര്‍മാന്‍ നല്‍കിയേക്കും. നിശ്ചിത വിളകള്‍ക്ക്, അതിലെ നിശ്ചിത കീടങ്ങള്‍ക്ക് എതിരെ അഞ്ച് വര്‍ഷത്തേക്ക് ഉപയോഗാനുമതി നല്‍കിയായിരിക്കും നിരോധനം ഉണ്ടാവുക. ഇന്ത്യ എതിര്‍ത്തില്ലെങ്കില്‍ വോട്ടിംഗ് ഇല്ലാതെ നിരോധനം പ്രഖ്യാപിക്കും.