National Environment Protection Authority (NEPA) -Comments

At the outset, I would like to compliment the Hon'ble Minister for Environment & Forests, for putting the document in the public domain for comments & inputs.

Highlights in the Document

The document is frank enough to admit that there are gaps in the Institutional Mechanisms and implementation has not kept pace with the Legislative and Policy Evolution and the entire ambit of "Environmental Governance" needs to be reassessed.

It acknowledged that Judiciary has played a major role in matters related to enforcement of Environmental Laws. While this had a salutary impact, it has also brought into focus the weakness in the executive. Quite clearly while our Environmental Laws have been progressive, implementation by government agency has left much to be desired.

What has come out clearly that Government Agency ie MoEF, has failed to ensure Good Environmental Governance, by not ensuring the "Rule of Environmental Law" The Judiciary can only point out Bad Governance and highlight its adverse impacts, but it cannot bring in Good Governance.

Report of Parliamentary Standing Committee on S&T;E&F

The committee, in its 192 nd Report placed before the Parliament, expressed its anguish over the fact that the Central Pollution Control Board (CPCB) created for the purpose of control and abatement of pollution is being given such a raw deal so much so that it has virtually been reduced as a near defunct body.

If all the powers and functions were to be concentrated into the hands of the central Government/Ministry of Environment & Forests, the very need to have such an apex body is untenable. The Committee recommended that Environment Protection should be included as an item in the Seventh Schedule to The Constitution in the concurrent list and

Specific Comments

a)Basic Structure for effective Environmental Governance

i)Legislation and not Policy - To be the responsibility of MoEF

ii) Policy, Regulation, Monitoring and Enforcement to be the responsibility of the proposed NEPA

iii) Adjudication to be the responsibility of NGT

iv) Full -Fledged NEPA, subsumes CPCB and SPCBs

b) Key Principles for establishment of NEPA

While agreeing with the Key-Principles for establishment of NEPA stated in Item IV, the following are suggested:

i)Item 3- The method of appointment of Board Members and CEO should be clearly stated in the Parliament Legislation for creating NEPA .

ii)Item 5- The Polluter Pays Principle should be sensitive to Social Inequalities and Income Disparities, while being ruthless to the Corporate Polluters

c) Role of NEPA

While generally agreeing with what is stated under Item V, the main object of NEPA should be "To Protect, Improve and Safeguard Natural Environment-Air, Water, & Land- and to Protect Human Health". The NEPA should be independent and should exercise its executive functions outside MoEF. The environment protection should be included as an item in the Seventh Schedule to the Constitution in the concurrent list

d) Role MoEF and PCBs

The MoEF should confine its role to framing Legislation, related Parliamentary matters and executing centrally sponsored projects leaving all other aspects of Policy making, framing Acts, Making Rules, Coordination etc to NEPA

With the creation of an Independent and Full-fledged NEPA for effective enforcement of Environment Laws, there may not be a need to continue the top-heavy MoEF in its present farm and shape. This may be an opportune time to segregate Ministry of Forest from Environment which may be merged with Science and Technology, if its separate status cannot be justified

e) Options

The options 1, 3 & 4 are nothing but new vine in a new bottle with a cosmetic effect. The Option 2 alone some what resembles a real change and needs to go through a Sea -Change, before it is zeroed on

f) Why do we need another Institution?

Where is the question of having another Institution, when there is no suitable authority to comprehensively and effectively implement The Environment (Protection) Act, 1986, as admitted in Item II of the document?

We need an institution for providing "God Environmental Governance and Management", which is Transparent, Accountable, Sensitive, Responsive and involves the stake-holders in the decision making process.

Hope NEPA will be permitted to function the way it ought to and provide "Good Environmental Governance "which the country is in badly need off ?

Myth of Per Capita Energy Consumption

Syndrome of Per Capita Consumption

As per conventional thinking, the GDP of developed nations is closely linked with per capita consumption of energy. The per capita energy consumption of primary energy in India is one of the lowest in the world. India consumed only 439 kg of oil equivalent (kgoe) per person in 2003, compared to 7835 of USA, 4210 of Germany,4052 of Japan,3906 of UK, 1090 of China and 1688 of World average. If we get caught in the syndrome of per capita consumption, India, with its population explosion and its limited natural and financial resources, can never even dream of reaching the development levels of the developed countries.

High Energy Intensity is Symptomatic of Inefficiency

India's energy intensity (energy consumption per unit of GDP), is higher by 7% to 25% than that of Japan, UK, Denmark, Brazil etc. This indicates inefficient use of energy and cheap and abundant power supply will further encourage inefficiency and willful wastage, resulting in increased consumption not related with productivity or GDP growth.India must get out of the myth, that economic vitality requires steadily increasing energy consumption. In today's competitive global market, the country's energy programmes should focus on lower energy intensity, conservation of resources and protection of environment. The ultimate Goal for the Nation should be an "Industrial Ecosystem" which means an industrial process that minimizes both inputs of Energy and Materials and outputs of Waste Products and Pollutants.

Decouple Energy Supply from Consumption

But the planners & policy/decision makers, having been overtaken by the events and used to crisis management, tend to create more generating capacities to meet ever increasing demand and tide over the crisis situation. It is of utmost importance & urgency, to decouple the energy supply from consumption and link it with realistic demand based on efficient utilization and not on consumption. This approach alone can maximize India's economic competitiveness.

The oil shocks & sharp price hikes of the 1970s led America to promote energy efficiency & renewable energy sources. It was also realized that energy consumption and hence energy supply, need not rise in lockstep with economic growth & they could be decoupled. The real GNP grew at an average of 2.5% a year from 1973 to 1986, but energy use did not grow at all, avoiding an additional 150 billion dollars a year in higher energy bills. From 1979 to 1986 the United States was estimated to have got seven times as much energy from savings, as it did from net capacity expansions.

The Sweden is already among the world's most energy efficient countries, even though it is cold, cloudy and heavily industrialized. By doubling its electric efficiency and switching over power generation to natural gas and biomass fuels, it is planned to support a 54% increase in real GNP from 1987 to 2010, while phasing out all nuclear power plants. The costs of electrical services are expected to fall by nearly one billion dollars per year.

Potential for Electrical Energy Efficiency

The Electric Power Research Institute (EPRI), the utilities' think-tank of USA, estimated in early 1990s, that electricity use in USA could be reduced as much as 55%, through cost-effective means, at an average cost of three cents per kilowatt-hour (unit). It was also estimated that as much as four-fifths of all energy then being used for lighting and half of all energy used to run motors, could be saved by technical improvements. Thus better lighting and motor systems could save nearly half of all U.S electric power generation. What would be the potential for energy saving in India?

Indian Power Sector Scenario

India, with installed capacity of about 160,000 MW, is reported to have recorded per capita consumption of 533 units, against 13,066 of USA, 7816 of Japan, 6898 of Germany, 1379 of China etc. It is planned to increase the installed capacity to 800,000 MW by 2031-32, to cope with the growth rate of 8% The talk of increasing the per capita consumption and increasing the Installed capacities alone may prove to be expensive and counter productive for Indian economy.

Supply Side Management (SSM) Measures

Before planning any more additional capacities, the optimum utilization of the new capacities as well as the existing capacities, need to be given the highest priority by adopting the following SSM Measures:

a) Gross Fuel Conversion Efficiency of Coal Thermal Plants to be aimed more than 40%, by adopting advanced technologies

b) Plant Load Factor of Coal Thermal Plants be aimed beyond 75% against the present National average of about 68%

c) In many States the metered and billed energy is reported to be less than 50% of the energy purchased and supplied by the Utilities, incurring heavy losses. All Services, including those offered free power, should be metered, in accordance with Section 55(1) of The Electricity Act, 2003.

d) Transmission and Distribution (Technical) Losses be brought down to below 20%, by making Energy Accounting and Audit mandatory and bringing in accountability at all levels as per Section 55(2) of The Electricity Act, 2003.

Energy Conservation - DSM Measures

It is more than 7 years since The Energy Conservation Act, 2001, has come into force on 1 st March 2002, with avowed object to provide for efficient use of energy and its conservation. But, unfortunately, the impact of Energy Conservation has not been felt so far in suppressing the demand, at least to cope with the shortages of power. Neglecting this cheap and readily available source of power, the thrust seems to be on expensive and time consuming capacity additions alone. The emphasis seems to be more on "Conversation" than on "Conservation".
Hope the National Mission Plan for "Enhanced Energy Efficiency" will have some tangible impact?

The focus will have to be on, right energy policies, for implementation of SSM and DSM measures, for ensuring optimum utilization of the resources and the energy generated and to suppress the demand. The missing link is Efficiency and Sensible Energy Policy. The obsession of higher per capita consumption adds to the problem.

Extracts from Prime Minister's Speech
-On NEC Day, December 14, 2004

"Without an Economic Pricing Policy, albeit one that is sensitive to social inequalities and income disparities, it will not be possible for us to sincerely address, the challenge of Energy Conservation"

"Theft of Power is not getting captured and is instead being reported as 'Transmission & Distribution Losses' or as "Free Power" being supplied to Rural Areas---"

"The free supply of power in rural areas, has the effect not only on encouraging excessive use of power, when it is on offer, but also encouraging the wasteful use of Ground Water"

Dr.Man Mohan Singh

Prime Minister of India

Urban Land-Saving for Future Or Selling the Future?

Urban Land- A Commodity?

First the humanity must learn to acknowledge that a system of natural ecological infrastructure exists everywhere, that it functions with or without our presence, and that when we interfere with its functions, the resulting effects are cataclysmic-- despite our attempts to reconstruct, duplicate or mend it. Therefore, it is in our best long- term interests to keep as much of this natural infrastructure as healthy and as intact as possible.

Second, and perhaps the most important lesson to be learnt is that we did not fully realize, the powerful influence that sensible Urban-Land use planning has on the quality of our natural environment. As a result the urban land is simply regarded as a commodity and not part of larger continuum, intimately linked to the surrounding air, water, vegetation & life, inflicting environmental damage.

Impact of Unchecked Urbanization

The urbanization has long been seen as a necessary step, in economic development and cities have been referred to, as engines of development, that fuel economic progress. The well planned and managed cities of compact size, offer economy and efficiencies in the use of energy, water, and land for a large number of people in a limited area. But the cities are also increasingly being seen as the prime machines that pollute and degrade the environment, because of overcrowding. As cities grow beyond the sustainable limit, their adverse impact on health and the quality of life gets multiplied many fold.

Mega Cities Vs Smaller Cities

Therefore the Mega-Cities jeopardize the very hope for better living and quality of life for which the city dweller aspires. The concept of Mega Cities is a high-risk solution, with high-risk population, the combination of which spells danger. Smaller Cities or towns dispersed all over will provide lasting and cost effective solution for sustainable urban development. The well-thought out Land-Use planning, Environmental Regulation and Demand Side Management (DSM) measures can completely offset, concrete and steel solutions, saving thousands of crores of rupees and ensuring sustainable urban development

DSM Vs SSM Measures

The urban planners and the governments are driven to expand infrastructure and to create new facilities to meet ever increasing inadequacies and shortages created by growing urban population. The cumulative effect of this vicious pattern of "Supply Side Management" (SSM) has created financial obstacles and crisis. These hurdles are compounded by overuse and degradation of urban land, depletion and pollution of Water Bodies etc The administration is always overtaken by the events, which are being chased as part of crisis management. It calls for a paradigm shift in planning- from Supply Side Management to Demand Side Management, from Control measures to Precautionary measures, from Capital Investment to Innovative Cost effective solutions

Urban Master Plans

The Urban Master Plans are to ensure planned, balanced and sustainable development of the notified Urban Areas..The land uses normally proposed in the Master Plans, are Residential, Industrial, Commercial, Institutional (Schools, Hospitals, Public Bldgs. Utilities etc), Transport (Roads etc), Recreation (Parks, Playgrounds etc), Reserved Forests, Water Bodies, Conservation etc areas.

The Hillocks, Valleys, Lake shores and River Banks are normally earmarked as Recreation Zones, prohibiting development activity involving any material change in the land use. Therefore the commercial recreation activities such as Amusement Parks and others requiring structures should not be permitted in notified recreation areas such as Parks, Playgrounds, Water -fronts etc.

The Violation of the provisions of Master Plan or the regulations that accompany it, are like the violation of any other law. But the violations of Master Plan and Building Regulations, which can be compared with the Indian Penal Code, are not being dealt accordingly.

Govt. is the Main Culprit

The glaring aspect is that large chunks of recreational/conservation areas are being converted into residential/ commercial uses and being auctioned by Urban Development Authorities themselves, to mobilize funds for fancy projects like fly-overs, ring roads, necklace-road etc

The State Govt is also resorting to allotment of large chunks of Govt land, covered under reserved forests, water fronts etc to various private parties, camouflaged by fancy names such as Botanical Garden, Night Safari, IMAX Theater etc in the name of promotion of tourism, unilaterally modifying the land use notified in Master Plans.

As a result the Master Plans have become superficial as they are frequently modified to suit individual requirements and irrational Govt policies and decisions, with utter disregard to sustainable development and long term adverse environmental impacts. Most of the disaster causalities in India are reported to be a consequence of shoddy planning and non implementation of Land-Use plans.

AP Urban Scenario by 2020

As per 2001 Census, Andhra Pradesh recorded a total population of 7.57 crores with an urban population of 2.05 crores. Unlike some other States where several large cities and towns are spread all over the State, Andhra Pradesh has a distinction of Hyderabad Metropolitan Area (HMA) accounting for nearly one-third of the State's urban population, followed by Visakhapatnam (VMA) and other cities &towns that are much smaller.

By 2020, AP urban population is expected to be 50% of the total population. As a result the requirement of urban land for residential, commercial, institutional, transport etc uses gets more than doubled, reducing or converting more than 50 percent of the existing conservation areas. This phenomenal growth is going to be at the root of most problems of Urban Agglomerations.

At present, lured by bright lights, fly-overs, employment opportunities and other fancy projects concentrated in HMA and VMA or driven from the country side by political and economic turmoil, lack of basic necessities, neglect of rural areas etc, lakhs of people have been migrating. Therefore, there is an urgent need to curtail urban population growth rate, particularly in HMA &VMA, by arresting and reversing the migration of rural population, through intensive and all round development of the District towns and Mandal headquarters in the State,

Let Us, not SELL and SAVE HMA & VMA for Future Generations

The district towns will have to be developed, by an integrated urban development planning, as counter magnets, and not by development of HMA or VMA in isolation. This will have to be targeted through an integrated approach, by dispersal of administrative machinery, by providing basic civic amenities and by improving connectivity by reliable transport and communication networks. This will serve the dual purpose of developing the district towns bridging the gap between urban and rural divide and easing the pressure on major urban centers like Hyderabad, Visakhapatnam and Vijayawada.

Otherwise, the "Common Good" with a view to achieving urban areas that are safe, efficient, sustainable, clean, and economically vibrant and take care of the needs of all sections of the society, will remain a pipe dream. The important aspect to remember is that HMA & VMA alone is not Andhra Pradesh.

Hyderabad endowed with heritage and nature, Visakhapatnam blessed with deep blue of the Bay of Bengal, aesthetic eco-systems of Eastern Ghats will have to be saved for the future by Proper Land use Planning and management and not by treating it as a Commodity , which amounts selling their future.

India's Solar Energy Program- All Set for Lift Off

September 23, 2009
Analysis by: Gerson Lehrman Group (GLG) Expert Contributor
Analysis of: India warms up to Solar Energy
Published at: www.upiasia.com

Summary

The Indian government has unveiled the National Solar Plan and this promises to be the start of an fast and exciting ride into Solar energy for the country. It is blessed with abundant Solar Insolation as well as a power starved economy. The National Solar plan touches upon the right levers to galvanize the players and solar markets.

Analysis

India is a "Sunshine" country with most of the parts of the country enjoying more than 300 days a year of sunshine with an energy density between 4 to & Kwh/Sqm/day. This translates into 5000 trillion Kwh. Even if 1% of the Insolation falling on India is harnessed, it can meet most of India's power requirement. India is currently a power starved country with peaking demand exceeding its current installed capacity of 146000 MW by about 10 to 15%. Even worse, the growth in installed capacity(projected at 7000MW/year) will continue to fall short of the growth in demand for power due to high GDP growth rate of 6 -9% .Thus the gap between demand and conventional sources of power is bound to increase further.

India has seen some activity in the Solar PV area with companies like Tata BP Solar, Moser Baer PV, Titan Industries etc setting up solar module & Solar cell (Moser Baer) manufacturing plants. However, most of their production has been export oriented as there were no large scale in-country requirements. The government of India has also been in the wait, watch ,experiment mode with regard to Solar energy and had announced a pretty small, capped(Total 50MW) incentive program for Solar PV generated power. Certain states, like West Bengal, Karnataka, Maharashtra etc have utilized this opportunity and have set up or are in the process of setting up MW scale power plants.

The Government of India has recently unveiled the Draft National Solar Plan which lays down the road map for achieving Solar energy generation of 20,000MW by 2020 in 3 phases : Phase 1(5GW by 2012-13), Phase 2(6-7 GW by 2017), Phase3(20GW by 2020).

The following are the concrete steps that will enable this to happen :

1. Government mandate of Roof Top Solar PV power for all sizable government controlled
buildings throughout India.

2. Actively promote commercial scale Solar PV plants.

3. Mandate 5% of all new thermal power plants (Coal, Gas,Oil) to generate solar energy.
This will straight away add about 350MW per year of Solar energy.

4. Make necessary regulatory changes to enable net metering from Solar Plants.

5. Government will install a few "Technology Demonstration" Concentrated Solar Power plants
in the 50-100 MW capacity range.

The following incentives will be available :

1. Feed in Tariff (FIT) will be announced by State Electricity Regulatory Authorities based on
guidelines by the National Solar Mission & power purchase agreements for 20 years will be on.

2.10 year Tax Holiday

3. Exemption of Custom duty & Excise duty on Capital equipment.

Funding

About $25 billions will be required over the next 30 years. Government will levy cess on Coal($0.5/T),Petrol & Diesel to fund Solar program. Currently there is an installed capacity of about 20-25 GW of Diesel generated power (mainly privately owned) to meet the peaking power shortage. The cost of electricity generated from these DG sets is about $0.3/Kwh and Solar PV power is already in that range. With all the incentives and net metering etc, these polluting and uneconomic DG sets will be utilized less.

Clearly, this approach is modeled on the Wind Energy program that India adopted some time back and which led to India becoming one of the leading wind energy players with giants like Suzlon emerging from India. Watch this space for the Suzlon of Solar Energy to emerge from India

This author consults with leading institutions through GLG
Analyses are solely the work of the authors and have not been edited or endorsed by GLG.
Contributed by a Member of the GLG Energy & Industrials Councils

Shifting Pattancheru to Srikakulam?

North Coastal Districts of AP

The north coastal districts of AP-Srikakulam, Vijayanagaram & Visakhapatnam- in spite of their abundant natural resources and the vast coastline, have been lagging far behind in economic development, mainly because of neglect of medium and minor irrigation projects, for full & optimum utilization of available water resources. The industrial development of the area, based on the local resources, has also not received proper attention, except for the public sector industries concentrated in and around Visakhapatnam.

Even this development had taken place ignoring sensitive environmental issues. The haphazard industrial development and utter lack of control and enforcement of 'Land-Use' plan are mainly responsible for many of the environmental problems of Visakhapatnam area. Today an alarming stage has been reached, where long-term environmental management is a lesser issue than that of safety of life and property for the citizens of Visakhapatnam.

Ecological Disaster around Hyderabad

During Eighties and Nineties of the last century, large number of Bulk Drug and Chemical units were permitted to be set up in and around Hyderabad, in the name of rapid industrialization of backward Medak and Ranga Reddy districts. Due to lack of corporate commitment to the community and as the benefits of non-compliance are more attractive to the industry, irreparable and irreversible damage had been done to the life and livestock of large number villagers, polluting the air, land and water bodies including ground water, in these districts.

The presence of toxic substances beyond the permissible levels, have been detected in ground waters & blood samples taken in Pattancheru, downstream Musi& other industrial areas. These are mainly attributable to toxic metals & organic halogen compounds, which are highly toxic, carcinogenic, bio-accumulative and persistent, contained in the effluents discharged by the bulk drug units and others.

Failure of Regulating Agencies

The Supreme Court in 1998, directed Central and State Pollution Control Boards (PCBs) to take measures to control the pollution in the above industrial areas. But unfortunately, having failed to control the pollution, the PCBs have come up with the proposal of laying a pipeline (18 KM), for discharging untreated or under treated industrial effluents into municipal sewers, ultimately finding their way into Musi River.

This is nothing but shifting the pollution problem from Pattancheru and Jeedimetla, to the far of villages, down stream of Musi, that too cleverly camouflaged in the pipeline. The river is already highly polluted and contaminated, adversely affecting the quality of life of people in about 40 villages down stream, who are deprived of safe drinking water due to pollution of ground and surface water sources.

Shifting of Bulk Drug Units

As the villagers downstream of Musi are agitating against the discharge of effluents through pipelines, there seems to be another attempt to shift the pollution problem of Pattancheru &Industrial areas around Hyderabad, to another backward district of Srikakulam, in the name of its industrial development. The justification given is, that effluents generated by these units, containing predominantly dissolved inorganic salts, which are being discharged into water bodies in and around land locked Hyderabad, can safely be discharged into sea by laying a pipeline deep into sea. The Parwada Pharma City and many Bulk Drug and Chemical units set up around Pydi Bhimavaram are already discharging effluents into Bay of Bengal.

There is no guarantee that persistent and toxic wastes from the bulk drug units, which found their way into surface and ground water sources in and around Hyderabad, are not being discharged into sea, particularly when the detection is going to take much longer and becomes much more difficult. What needs to be remembered is, that the people of North Coastal districts should not be subjected to the misery and hardship, to which the large number of villagers around Pattancheru are exposed due to discharge of effluents by the bulk drug units.

Adverse Impacts on Marine & Coastal Environment

The discharge of toxic effluents into sea, even though they are diluted to some extent, is bound to have an adverse impact on aquatic life in the years to come. as the total pollution load being discharged remains the same.This is going to hamper the fish stock availability, affecting the livelihood of the large fishermen community in the area apart from health hazards for people consuming contaminated fish. It goes against the main objective of Coastal Area Development Regulations, which are aimed at integrated development of coastal areas, ecosystems and resources of the land-sea interface and to improve the quality of life of the communities dependent on coastal resources and helping coastal areas attain sustainable development.

Taking into consideration the fragile nature of coastline and the hinter land of north of Visakhapatnam, highly polluting and water intensive industries such as Bulk Drugs, & Chemicals, Air polluting Coal based Thermal Power Plants, Hazardous Nuclear Power Plants etc. are not to be permitted in this area. Stop shifting of pollution problems of Pattancheru to this area under the garb of development. Let us not create another Pattancheru in North Coastal districts.

Protect "City of Destination"

The industrial development of north coastal districts is to be confined to industries based on locally available minerals, marine and forest produce, agricultural and horticultural products. maintaining ecological balance of Eastern Ghats and Bay of Bengal.Then only we can hope to preserve and maintain Yellow Beach, coral growth and Deep Blue of the Bay of Bengal, aesthetic Eco-Systems of Eastern Ghats and make Visakhapatnam the "CITY OF DESTINATION".

Does Separate State Benefit Telangana People?

About Telangana

The ten Telangana districts, covering an area of 1, 15,000 Sq.km (AP 2, 75,000) and population of 310 Lakhs (AP 762) is about 40% of the Area and Population of AP State. The SC & ST population of Telangana is around 25% against the State average of 22%. The urban population of 30% in the region compared to the State average of 27%, highlights concentration of development efforts in and around Hyderabad and the Urban-Rural disparity. The percentage of literacy is around 41% against the State average of 44%.

The Telangana, with about 40% of the area and the population of the State, is rich in natural resources such as coal, lime stone and other mineral deposits, forest wealth etc apart from the fact that the main rivers Krishna and Godavari and their tributaries pass through the region. But unfortunately many parts of the region suffer from scarcity of safe drinking water, lack of assured source of water for irrigation, huge unemployment, large scale abject poverty, illiteracy, superstitions, exploitation, lack of basic civic amenities and deteriorating law and order situation.

Neglect of Telangana

No doubt, the present system of governance has failed to deliver the goods particularly in respect of Telangana, mainly because of lack commitment to the region, due to improper deployment and/or miss utilization of material and human resources. It has also failed to recognize the importance of irrigation water on agricultural production and rural employment and the land productivity in general.

The talk of major irrigation projects on Godavari/Krishna Rivers for the benefit of Telangana region was going on for the last 50 years or so but they have not materialized till to date mainly because of lack of political commitment. On the contrary the integrated and well established irrigation network of tanks and reservoirs developed by Kakatiya Rulers in the region, have been neglected and destroyed over the period.

The length of roads per 100 Sq.km of area in the State is much lower, when compared to three neighboring southern states and the road length in Telangana is even lower. Apart from the inadequacy of road network, the condition and the riding quality of the State and District highways in Telangana region are comparatively poor. The situation in respect of railway network is no different. The long talked about Peddapalli-Karimnagr- Nizamabad line is yet to be fully commissioned, while Badrachalam- Kovvur and Mahabubnagar-Munirabad lines remained non starters. The gauge conversion of Secunderabad-Nizamabad-Mudhked line has been unduly delayed, having its adverse impact on the development of the area.

Change for Better

The fundamental objective of any change proposed in the governance of the region should be to bring about rapid and sustained improvement in the quality of life of the people of the region. The only durable solution to the curse of poverty is sustained growth of incomes and productive employment in Agriculture, in Industry and in Services. Such growth requires investments in irrigation, in industry, in power, in road/rail network and, above all, in people. The important aspect is to ensure that material and human resources are deployed and utilized in the most productive manner.

Infrastructure services are critical for all sectors of economy namely agricultural, industrial and services, and they have emerged as the single most severe bottleneck to development of Telangana. The present day problem of law and order in the region, which is mainly due to unemployment, poverty, exploitation, inequitable distribution and concentration of wealth, will only subside with the overall economic development of the area and ensuring equitable distribution of wealth generated, bridging the wide gap between the "Haves" and "Have-Nots"

Questions Remain Unanswered

The separate state for Telangana provides the system of governance exclusively for the region but how is it going to bring about rapid and sustained improvement in the quality of life of the people of the region? Is it going to be any different from the present system of governance ie integrated Andhra Pradesh? Can't the objective of rapid development of the region be achieved in the present set up itself, by ensuring certain statutory safeguards, protections and budgetary allocations for the region?

Is Small Beautiful?

If the objective can be achieved in integrated AP itself, why go in for a separate state involving additional financial burden on the State which has already been faced with huge debt burden? Is it essential to go in for smaller states, in the name administrative convenience, when we are talking of Decentralization and Devolution of Powers and Responsibilities to Districts, Mandals and Panchayats, to function as Institutions of Self Government? Doesn't Information Technology help in ensuring better administration and control of even bigger states with much less establishment costs of having Smaller States?

Who are Going to be Real Beneficiaries?

Do we want separate Telangana State for the sake of a Smaller State, for the benefit of a few Select and Privileged Sections or for the Overall Uplift and Benefit of the Masses? Does a separate state really benefit the Rural Areas and Masses of Telangana? Who are going to be the real beneficiaries of a Separate State?.

Proliferation of Bureaucracy in India

Non-Productive Govt. Expenditure

While everybody in the Government agrees that the size of the bureaucracy is bigger than it should be and very little has been done to actually reduce its size. The reduction of non-productive government expenditure is linked with the question of downsizing bureaucracy and there is an urgent need to announce a timetable for each department, to reduce the sanctioned strength of the staff at least by 10% by 2012, through an attractive Voluntary Retirement Scheme (VRS)

The Prime Minister should take the initiative for reduction of non-productive government expenditure by drastic pruning of Council of Ministers and Departments. The recommendation on administrative reforms, that the strength of a Ministry should not exceed a tenth of the combined strength of two Houses, should be strictly implemented by the Centre and the States.

Redundancy & Inefficiency

With deregulation of Industry, Trade and Finance, as part of reform strategy, the role of the government will have to shrink to match the requirements of the post-reform era. If the liberalization required PSUs to be unloaded, on the logic of trimming redundancy and increasing efficiency, the same logic must apply to the gigantic bureaucracy, whose sole purpose appears to have become self-perpetuation.

Non-Productive & Unaccountable

Many developed and developing countries have focused so much on the renovation and restructuring of their governments, in the midst of their reforms, to be purposive, responsive, effective and accountable in the key functions they perform in society. This is a far cry, by what we see and hear, in our country. There are strong advocates in government for increased public spending, but hardly any that assure matching outputs or productivity or accountability from government.

A bureaucrat, who finds himself unequal to the task he is assigned and feels insecure, becomes an authoritarian, using his position than his ability, to assert himself. He would be obsequious before his superiors or benefactors and indifferent and inaccessible to those he is supposed to serve. Regrettably, the majority falls under this category. As a result the bureaucracy is perceived to be the single biggest obstacle to development.

Downsizing & De layering

The Fifth Pay Commission recommended that public services have to sub serve the new goals of the State in 21st century. From mere controllers and regulators, they have to get converted into catalysts, promoters and facilitators. Their numbers need to be right sized. The government itself needs to be restructured by closing down departments or amalgamating them, by transferring subjects and institutions to the State Govts and Panchayat Raj bodies and by encouraging autonomous bodies, to take over some of the functions of the state.

There has to be delayering, in order to reduce levels and consequent delays. Large, unwieldy sections have to give way to small business like desks and the vast number of ministerial staff may be gradually replaced by executive assistants.

Top Heavy- Too Many Chasing Too Little

The large bureaucracy has inherent disadvantage of slow response, low value addition and lack of accountability. The top-heavy administration ceases to be productive and reacts to situations only under pressure and political influence. The overcrowding at top levels of the civil services, too many chasing too little, results in personality clashes, making coordination impossible.

This is what is happening today, with too many Chief Secretaries/Principal Secretaries, DGPs/IGPs, Principal/Chief Conservators of Forests etc. The episode of latest Tragic Helicopter Crash of "YSR"of AP, is a classic example. Therefore what is needed is an exit policy for bureaucracy at the top, doing away with overcrowding at top levels latest by 2012, for the good of the service itself.

Tapered Pyramid Structure

Just as in Defense Services there should be drastically tapered pyramid structure, with a gradation in retirement ages at various levels. The job security and automatic promotion to top level posts based on years of service, irrespective of the sanctioned strength, are mainly responsible for non-performance and irresponsibility. The performance is to be reviewed every five years, restricting time scale promotions only up to first 15 years of service.

The merit promotions after 15 years of service should be selective based on competency, performance, knowledge acquired and of course the sanctioned vacancy. Those who do not qualify for merit promotion should be retired at the age of 45 years and others who do not make to the next merit promotion should be retired at the end of 4 or 5 years tenure in that position. This will ensure wide base at the field level where it is required and drastic reduction in numbers at top level, providing the necessary tautness and effectiveness to the administration.

Experts from Other Sources

The senior officials over 50 years of age, who are unlikely to be able to meet the new demands of service that will be made on them, be offered golden hand shake under VRS. The experts in fields, as diverse as Agriculture, Biotechnology, Informatics, Energy, Environmental Management etc, be brought in from the private sector, universities, technical and professional institutions, to modernize the bureaucracy and to run a lean administration which will have managerial and technical skills.

A good beginning has already been made by appointing Mr.Nandan Nilekani as Chairman of Unique Identification Authority of India. Many more required to follow.

Conclusion

The highest priority should be given to streamline the administration and free the Nation from the millstone of a Fat, Lethargic and Corrupt Bureaucracy. But no party seems to have the political will to do it. The bureaucracy too will resist it with all its might. The remedy, however slow it may be, lies with the public--People's Power--the Paymasters.

Patancheru is Unfit for Living

The Cyberabad Times
Friday,January 26, 2007

Source: Green Peace India, The Hindu, EPA United States

India's pharmaceutical industry is heavily concentrated in a few small areas, one of the most prominent and notorious being near the town of Pattancheru in the state of Andhra Pradesh. Over the past two decades, a growing chain of industrial estates has turned this 20-mile stretch of countryside into an Ecological

Sacrifice Zone.

A study in Pattancheru shows clinically confirmed Cancer was found to be 11 times higher. Respiratory diseases affected one in every 20 persons. Heart diseases were 16 times higher.

With some real estate firms trying to sell away land allotted for industries, amid highly polluting industries in the Pattancheru Industrial Estate, the Andhra Pradesh Industrial Infrastructure Corporation Limited (APICL) has asked investors to be cautious before venturing into any agreement.According to APIIC Zonal office in Pattancheru, the groundwater and ambient air in the industrial estate is highly polluted and one must be aware of the fact that only industries would survive in this locality.

While pointing out that one would need a 'No objection certificate' (NOC) from the APIIC before going to the Pattancheru sub-registrar's office for registering the site on one's name, it is sad that high land value in the twin cities is driving the middle class investor to the outskirts like Pattancheru.

The mere smell of the villages, water is enough to make you gag. Pollutant concentrations in area streams and lakes range from 12 to 100 times as high as those in an unpolluted lake just outside the contaminated zone, according to the 2004 report of a committee appointed by the state's High Court.

A 2004 survey by Greenpeace India compared villages and found high rates of these and other illnesses where water is shared with drug plants. Two major universities have launched studies of health problems in the area. Clinically confirmed cancer was found to be 11 times higher in the study group. Respiratory diseases affected one in every 20 persons. Heart diseases were 16 times higher. Congenital malformations and chromosomal abnormalities were 3.93 times higher. When it comes to systemic diseases it was no better. Diseases of the nervous system were three times higher and circulatory system two times higher. Those of endocrine, nutritional and metabolic systems were 1.84 times higher. Disorders of blood and blood forming organs were 2.9 times higher and those of skin and sub-coetaneous tissues 2.67 times more than in control group.

Thousands of acres of formerly good farmland around Pattancheru lie uncultivated during the dry season because groundwater has become unfit for irrigation. The court committee sampled 48 wells in the area and found 81 percent polluted beyond an international standard for irrigation water. The study was conducted by administering an open-ended exploratory questionnaire to document the health-related information of the people in the study villages of Bonthapally, Chitkul, Digwal, Gaddapotharamu, Kazipally, Kistareddypet, Pasha Mailaram, Pocharam and Sultanpur in Pattancheru, Jinnaram and Kohir Mandals of Medak district.

In accordance with court orders, drug companies are paying to have safe water piped into affected villages for drinking and cooking. But the polluted water is still used for other purposes in the home and on the farm. The court committee visited 40 "pollution potential" companies in the industrial estates. Of those, 30 were producing drugs or drug ingredients, and only five were complying fully with Patancheru's lenient pollution laws.

Despite repeated crackdowns by government authorities, some factories continue to pollute the Pattancheru area's air with sulfurous mercaptan compounds that smell like rotten fish ironically, during the production of stomach antacids.

Pattancheru area, where normally only the total quantity of pollutants is tracked, there's almost no information about specific toxic compounds. That's serious, because some of the drug industry's solvents, byproducts and ingredients can harm people even at low concentrations.

Transportation and Related Energy Use & Environmental Issues

Transportation & Development

Transport is the heart of all developmental activities and is essential to economic development and social welfare. Traditionally the goods are moved by Rail or Road or Inland Water transport. The age of Canals in the 19 th century was followed by Railway Era, which in turn was overtaken by Road Transport, as the dominant mode of transport, in the latter half of 20 th century. The most recent transport infrastructure development is Air Transportation.

The income and mobility have always progressed together and the mobility increases with income. But mobility tends to increase faster than income in the developing economies, mainly because of movements of population from rural to urban areas and of increasing movement of goods. The transport capacity has been far behind the demand and has become a constraint for economic growth.

Public Vs Private Transportation

Moreover the urban settlements are developing erratically, without adequate public transport system, resulting in the rapid growth of personalized vehicles at a faster pace than the availability of roads in urban areas. One of the main contributors is the diversion of highly subsidized Diesel in India, meant for Goods and Public Transportation, for personalized diesel vehicles. This trend needs to be arrested and reversed by heavily taxing personalized diesel vehicles.

Inefficient Road Transportation in India

In a fuel scarce economy of India, the petroleum products worth more than 10,000 million dollars had to be imported during 1999-2000 and about 30 percent of total energy consumed was utilized on transport. A part of this consumption is due to inappropriate choice of the mode of transport, bad roads and the inefficient vehicles. It has been well established that every year, fuel worth of Rs.500 Crores is being wasted due to bad roads apart from another Rs.4000 Crores on vehicle operating costs.

Rail Vs Road Transportation

The private passenger transport is estimated to consume about 20 times the energy required for public transport buses, per passenger kilometer. The rail systems which are the most powerful and energy efficient systems, having the highest hourly passenger carrying capacity, require much less energy than the buses. Similarly transporting a tonne of freight by road requires several times the energy required to transport the same tonne of freight by rail or inland water transport.

The Western Europe, China, India and Japan account for substantial share of passenger transportation by Rail--China 39.45%, Japan 30% and Western Europe15%. In contrast the passenger travel, in North America, by rail accounts for infinitesimal share of total passenger travel. Even though Rail passenger transport is generally considered to be much more energy efficient, than Road or Air passenger transport, the Rail's share of passenger transport is falling steadily all over the world. Similarly the share of freight hauled by rail and inland water transport, two relatively energy efficient modes, is sharply declining everywhere.

Highways Development at the Cost of Railways

In India the road transport has grown at the cost of the Railways. The road ways which carried 11% of freight and 26% of passenger traffic in 1951, handled 34% of freight and 60% passenger traffic in 1971. In the more recent years, the share of road is estimated to have gone up further. The manner in which the distortion has reached, can be gauged by the fact that bulk cargo such as Coal, Food grains, Fertilizers, Cement etc are moved by roads over long distances, even though it is more economical to carry them by rail. The four-laning of the National Highway network "Golden Quadrangle", with an overall investment of Rs.20,000 Crores, at the rate of Rs.4 crore per km, will distort further, to the disadvantage of rail transportation.

Road Transport & Environment

The most crucial issue that transportation planners face is to how to economize on transport costs. The energy costs should be the over riding consideration while determining an optimal mix of the country's transport system. It is possible to save substantial amounts of energy in the transport sector and to cut down transport related carbon emissions and other pollutants. Transport has significant effects on the environment. The Road transport is the dominant source of emissions that contribute to urban air pollution. The rail transport is relatively environmentally benign, although it contributes to noise.

A well-integrated, multimodal system relying increasingly on emerging technologies will be an essential element of sustainable transport scenario in the present millennium. Road transport should take care of bulk cargo over short hauls and in areas not covered by rail. The highest priority should be given for the development of rural roads and district roads, connecting to Rail head, Seaports and other main roads, instead of giving priority only to the National and State Highways.

Demand Suppression Approach Needed

Too much emphasis on converting National/State Highways into Expressways and building of flyovers and widening of urban roads, which is supply oriented, will only add more and more vehicles on roads, further increasing fuel consumption and adding to air pollution. What we need is the Avoidance-Oriented or Demand-Suppression approach, to bring down the number of vehicles on roads and to cut down fuel consumption and consequential pollution. This can be achieved better by developing and encouraging energy efficient modes like Railways, Electrification of Railway lines, Coastal Shipping, Inland Water-Transport and Product Pipelines for long distance movement of bulk commodities.

For the metropolises, an energy efficient urban planning to minimize the need for intra-city commuting (Demand Suppression) is the need of the day. This can be achieved by decongestion of city centers, decentralization of governance, development of self-supporting townships, etc. The Urban Land-Use Planning and its strict implementation are of vital importance for energy efficiency This is the right time to incorporate these measures in "Hyderabad Master Plan 2020" which is being debated since 1994. The debate about LRTS, MMTS, MRTS, BRTS etc, which is going on for so many years, will only lead to Supply Side Management(SSM) measures rather than Demand Side Management (DSM) measures.

YSR Memorial in Tiger Habitat

From the Press Reports it is learnt that the State Cabinet decided to erect a Memorial in honour of late Chief Minister Dr.Y.S.Rajasekhar Reddy at the Helicopter crash site in the Nallamalla forests. The place where helicopter crashed at Pavurala Gutta (Tippa ) is understood to be located in the Core Tiger Area known as "Gundla Brahmeswara (GBM ) Wildlife Sanctuary".

Creation of "Critical Tiger Habitat"

The proposal to create a consolidated core of "Tiger Reserve" by merging critical Tiger Habitats of "Nagarjunasagar-Srisailam Tiger Reserve" with entire "Gundla Brahmeswara (GBM) Wildlife Sanctuary" was discussed in the 2 nd meeting of the State Board for Wildlife, chaired by non other than late Chief Minister Dr.Y.S.Rajasekhar Reddy on 9-10-2007 and it was reviewed again in 3 rd meeting of State Board for Wildlife, chaired by Hon'ble Chief Minister Sri K. Rosaiah on 11-09-2009.

This consolidated "Core of Tiger Reserve" which will be notified as "Critical Tiger Habitat" along with the notified buffer of the Tiger Reserve, is expected to provide full landscape of more than 6,000 Sq.Kms, where the Tigers can safely survive for the next 200 years, with better chance to flourish.

No Activity will be permitted in the "Critical Tiger Habitat" including "GBM Wildlife Sanctuary". It will be "NO Activity Zone" after settling the cases of ROFR Act.

Ecological Impact of Memorial

The construction of proposed memorial at the site, associated approach roads /paths, infrastructure facilities, vehicular traffic, large number of visiting pilgrims to the memorial site etc, right in the protected "Critical Tiber Habitat", is bound to disturb the ecological balance and endanger the home for thousands of endangered animals, birds, rare medicinal and endemic plants, in the ecologically fragile area in the frightening and majestic Nallamalla Forests, the Flora and Fauna of which is pristine and beautiful.

The proposal of the State Government to erect a memorial for the late Chief Minister, Dr. Y.S.Rajasekhara Reddy at the helicopter crash site in the "Critical Tiger Habitat", where any activity including construction of roads is banned as per Wildlife Act `1972, is of very serious concern to every Citizen, whose Fundamental Duty is to "Protect & Improve the Natural Environment, including Forests, Lakes, Rivers and Wildlife, and to have Compassion for every Living Creature"

Appeal

The beloved late Chief Minister " YSR", whose loss is irreparable, demonstrated his love for Nature and Wild life by launching the bold "Operation Restoration of Kolleru" for dismantling fishponds encroaching into the Government lands in the notified Kolleru Wildlife Sanctuary. A fitting memorial to "YSR" will be to preserve nature and wild life and not to destroy them. The proposed memorial will, on the contrary, hurt YSR's values. We earnestly appeal to the State Government to change their decision.

In case the State Government does not change the decision, because of "Political Compulsions", the Ministry of Environment & Forests, Govt..of India, is requested not to accord Environmental Clearance for erection of the memorial in protected Tiger Habitat / Sanctuary

Pattancheru Pollution - 18 KM Pipeline?

Background of Pattancheru

The Pattancheru Pollution of Air, Water & Land is not something new, it has been an issue for over two decades, since W.P.No.1056 of 1990 was filed in the Supreme Court of India.

What is remarkable about this is the local population's complaints and environmentalists' lawsuits & protests, Supreme Court directives of 2000 and Supreme Court Monitoring Committee directives of 2004 and even the latest Joint Action Plan of CPCB & APPCB of 2-7-2007, could not do much to change anything at Pattancheru, leading to what it is today in 2009.

Denial Mode

All these years the Polluting Industries keep denying, disputing and challenging the findings and complaints against pollution and the Regulating Agency (APPCB) keep saying that Environment Protection laws are being enforced, ensuring the compliance of all specified standards. They seem to ignore the basic principle "The Proof of Burden is on the Polluter". Both the Polluter and the Regulator are on "Denial Mode" driving the pollution affected victims from pillar to post without any relief from the pollution.

But only, when the news item released by "Associated Press" on the state of pollution in Pattancheru area, based on the report of the Researchers from Goteborg University, Sweden and published in the American media, the PMO and MoEF seem to get into action mode, looking for answers.

What it proves to us, one again, is that the Govt. will hardly respond to people's needs, unless it could be embarrassed in the West.

Joint Action Plan for PETL & JETL

The Joint Action Plan of CPCB & APPCB dated 2-7-2007 in W.P.No.476/2005, W.P.No.441/2005 and Batch Cases, listed a number of measures, regarding Surface Water Standards, CETP Inlet and Out let Standards etc to be complied by PETL and JETL, stipulating maximum period of 18 months for meeting TDS (Inorganic) limit of 2,100 gm/l of Surface Water Standards. The present compliance status of the Joint Action Plan is not known.

18 KM Pipeline

The Joint Action Plan recommended the usage of 22.5 km pipeline (called as 18 km pipeline), provided for discharge of treated effluents from CETP Pattancheru (PETL) to K&S Main Sewer, be permitted to be commissioned, provided that the stipulated outlet standards of the CETP, (Surface Water Standards) are met by PETL.

If the outlet standards, applicable for discharge into inland surface waters are being met by PETL and "good enough for drinking" as reported to have been claimed by the representative of APPCB, why not the treated effluents from PETL, be utilized by the member industrial units in the area?

The utilization of the treated effluents will help reducing the depletion of ground waters and the demand on other scarce water resources in the area. What is the need to use the 18 Km pipeline, to convey the treated effluents, suitable for discharge into inland surface waters, all the way to STP at Amberpet, incurring considerable recurring expenditure for pumping?

The only reason for permitting the use of 18 Km pipeline by PETL appears to justify the earlier apparent misleading recommendation of CPCB & APPCB to Supreme Court, as the solution for solving the water pollution problems of Pattancheru area.

There is every danger of using 18 Km pipeline, as a clever camouflage, to dilute high TDS (inorganic) effluents and discharge the same into Musi river through Amberpet STP, as is being done by CETP Jeedimetla (JETL). The only way of ensuring compliance of the outlet standards by CETP, is by making the industries (polluters) to use the treated effluents, instead of transferring them some where else & to others, and by introducing 3 rd Party Monitoring.

CETP Jeedimetla (JETL)

The CETP at Jeedimetla (JETL), is diluting the effluents with domestic sewage and discharging its so-called treated (Diluted) effluents with high TDS, through a pipeline into Municipal Sewers, which is not permissible as per the Joint Action Plan. This should be stopped with immediate effect if the discharges do not conform to the stipulated Surface Water Standards

Conclusion

The representative of APPCB is reported to have stated that the discharges from PETL are in conformance with stipulated standards, but they have not been tested to detect antibiotics. This appears to be a blatant distortion of the facts and the ground realities.

Suggest that a thorough investigation be undertaken by an expert committee, which includes the representatives of CSE, New Delhi, Civil Society etc , to evaluate and asses the ground realities.

Also suggest that necessary action be initiated for proper and strict implementation of the Joint Action Plan of 2-7-2007, to ensure compliance of various measures recommended, by the Industries and PETL & JETL, keeping the public informed of the status of implementation on APPCB Website

Further suggest that Penal Action be initiated in accordance with Section 15 of The Environment (Protection) Act, 1986, against the Industries and CETPs, who fail to comply with the stipulated standards.

Naupada Swamps &Telineelapuram Destruction - Misleading Information ?

The following points about "Naupada Swamps and Telineelapuram", which were brought to the kind notice of Hon'ble AP High Court in W.P No.9360 of 2009, are highlighted below:

a) The "Wildlife Institute of India" Dehradun highlighted the importance of Naupada Lagoon in its Study Report on "Integrated Protective Area System ( IPAS)" for development of AP World Bank Forestry Project.

b) The Study on "Eco Restoration of Bhavanapadu Mangroves" carried out by Andhra University from March 2005 to April 2008, as part of the major research project sponsored by MoEF, G.O.I, highlighted the rich Flora and Fauna of the area. .The Study Area comprises of a cluster of villages/hamlets/habitations associated with a tidal creek that opens in to the sea through Bhavanapadu Creek, which is part of Naupada Wetland.

c) The Study Report of "Bombay Natural History Society" ( BNHS ) titled "Of Pelicans and Power Plants" highlighted that Telineelapuram is designated as an "Important Bird Area ( IBA)" by Birdlife International, in recognition of its global importance of avifauna. Also highlighted the importance of near by Naupada Swamps, rich in fish and other nutrients essential for breeding and survival of the visiting Pelicans and Storks.

d) India became a party to three international Conventions, namely, the Convention on Wetlands ( Ramsar, 1971) in 1982, the Convention on Migratory Species (Bonn, 1979) in 1983 and the Convention on Biological Diversity (Rio, 1992) in 1994. Conservation of endangered species of birds and other flora and fauna, associated with a marine-terrestrial ecosystem such as Naupada-Telineelapuram area thus comes within the ambit of the mandatory responsibility of conservation on the part of the Wild Life Authorities and Dept of E&F of the State.

e) State of Environment Report of AP has listed Naupada swamp as a wetland system to be conserved. The swamp forms part of the migratory route of birds and any construction activity in the area which is a nesting and feeding habitat for many endangered species will go against the spirit of conservation.

f) The draft Wetland (Management & Conservation) Rules 2008 prepared by the Department of Forests, for constitution of "Wetland Authority of AP", identified 7 Wetlands and "Naupada & Telineelapuram" is one of them.

g) The Handout issued by AP Forest Department on "Wetlands of Andhra Pradesh" refers to "Naupada Swamps" as one of the 55 Wetlands prioritized in the State.

h) Even though Telineelapuram is not notified as protected area, AP Forest Department purchased some land in the village and constructed Bird Observatory House and Watch Tower as a testimony to the importance of Telineelapuram. The plaque commemorating the construction of Bird Observatory House was revealed on the occasion Wild Life Week on 21-10-1986.

Clarification to MoEF, G.O.I

The E A C on Environment for Power Projects of MoEF, G.O.I in their meeting held on 16-12-2008, regarding proposed 2640 MW Power Plant of M/s East Coast Energy Private Ltd at Kakarapalli Village, Santhabommali Mandal, Srikakulam District, sought clarification on certain points with particular reference to the existence of the Ecologically Sensitive Area in the proximity of the plant site, drainage plan etc

But unfortunately, the Dept of E&F, Govt of AP, in its letter dated 9-2-2009 addressed to the Secretary, MoEF, GOI,giving clarifications seems to have ignored the fact that the plant site is in low lying area of well recognized Naupada Swamps itself and Telineelapuram is hardly 5 Km from the project site.

Misleading Information

It is stated in the letter, that, regarding Ecologically Sensitive Areas, the Principal Chief Conservator of Forests,AP, certified that there are no National Parks, Sanctuary, Elephant / Tiger Reserve / migratory path (existing as well as proposed) etc., within 10 KM radius of the proposed project site.

It is further stated in the letter that Environmental Ecology studies of the project site and the immediate neighborhood indicates that the area is not conducive for the visit and stay of large birds. The project area is neither a foraging ground nor nesting ground for large size migratory birds such as Pelicans & Storks.

Conclusion

In the light of information/facts mentioned in various references quoted above, the information furnished by Dept of E&F, AP appears to be suppression / distortion of facts, based on which EAC recommended and MoEF, G.O.I accorded Environmental Clearance for Power Project, which may have to be reviewed taking the facts and the ground realities into consideration.

Reduction of "Kolleru Wildlife Sanctuary" Boundary

At the out set, the Hon'ble Chief Minister, AP deserves to be complimented profusely, for not going ahead with the proposal to reduce the boundary of Kolleru Sanctuary from +5 to +3 contour.

The protection and restoration of Kolleru Wildlife Sanctuary to its pristine glory will be a befitting tribute to late Dr.Y.S.Rajasekhar Reddy, during whose earlier term as Chief Minister, the bold "Operation Restoration of Kolleru" was launched for dismantling fishponds encroaching into the Government lands in the notified Kolleru Wildlife Sanctuary.

If the present opportunity provided to restore Kolleru Lake of International and National importance, to its Pristine Glory is missed or lost, not only the chance to do a Good Thing, but the Kolleru Lake itself, one of Asia's most ancient and largest fresh water lakes, is lost forever and at what cost for generations to come?

Adverse Impacts of Reduction

The attempt to shrink the area of the Kolleru Sanctuary by about 25,000 acres will reduce the water holding capacity to the dead storage, defeating the very purpose of notifying as a Wildlife Sanctuary. The reduction of water holding capacity of the Sanctuary, which serves as a natural flood- balancing reservoir for Krishna- Godavari basins, will lead to submerging of thousands of acres of agricultural lands in the surrounding areas.

It will ultimately prove to be disastrous to the famous Wetland –Kolleru- of international repute, nullifying the results of all the good efforts made during the last 5 to 6 years, to revive, the clinically dead Kolleru fresh water lake. This will have serious long term adverse impacts on ecological balance of the water body and the surrounding area.

Acquisition & Compensation for Private lands

The reduction of Kolleru Sanctuary boundary is proposed, mainly on the grounds that private lands to the extent of15,000 acres between contours +5 and +3, are required to be acquired at an estimated compensation of Rs.655 Crores to be paid for the lands at valuation rates prevailing in the year 2008.

It is universally accepted principle that common properties like Land, Lakes, Forests etc are not allowed the change of Land-Use and forced to produce products/services according to landlords will, market demand or social demand. Therefore No person shall change the land use in the sanctuary area up to +5 contour, irrespective of the ownership of the land.

The G.O.Ms.No 120 dated 4-10-1999 notifying "Kolleru Wildlife Sanctuary" (KWLS) stipulates that traditional Agriculture without using chemical pesticides and fertilizers and traditional Fishing methods without causing environmental hazard shall be permitted in the private lands of the sanctuary, till the Government acquires such private lands. There is no immediate need to acquire the private lands in the Sanctuary area.

The total compensation amount of Rs.655 Crores for about 15,000 acres of private land, which works out to be more than Rs. 4 Lakhs per acre, appears to be very much on the higher side. The value of the land in the Sanctuary area will have to be worked out, taking into account that the land use cannot be changed, and it gets subjected to flooding for most part of the year.

Suggestions for Consideration

The following are suggested, in the order of priority, for kind consideration

Demarcation of Sanctuary Area up to +5 contour

a) The notified Sanctuary area up to +5 contour be identified as per Survey of India maps, to avoid any uncertainty/confusion between Revenue,Irrigation and Forest Departments and demarcated on the ground with light structures erected around the periphery for display of flags for easy identification of the boundary.

b) The "Operation Restoration of Kolleru" launched about 5 years back and seemed to have been left halfway , should be resumed immediately with full vigor and remove the half demolished fishpond structures and all other Obstructions / Structures which are prohibited in the sanctuary area.

c) The State level KWLS Monitoring Committee be constituted, including the representatives of civil-society, for periodic monitoring of the status.

d) The "Kolleru Wildlife Sanctuary Authority" be constituted under the Chairmanship of the District Collector, West Godavari, accountable for ensuring ground-level coordination and implementation of the provisions of G.O.120 of 4-10-1999, which are a casualty even after 10 years.

Restoration with "Human Face" and Rehabilitation

a) Essential that Kolleru Wildlife Sanctuary is restored, protected and preserved with a "Human Face" so that the original local Fishermen Community, the Migratory Birds and the Water Body live and let live in harmony, without the intrusion of Migratory/Local Fishpond Lobby and the Pollution form Industries & Urban areas.

b) The Fishermen and SC families in the Sanctuary area to be declared as project affected persons and offered help for rehabilitation with a special package ensuring Safe Drinking Water, Primary Health and Education facilities besides alternative livelihood practices.

Acquisition of Private Lands

a) The authentic and reliable data be compiled regarding the extent of Government and Private land holdings in the notified Sanctuary area up to +5 contour, taking into consideration the encroachments and fictitious transactions of government lands.

b) The particulars of genuine private land holders be classified under the categories of less than

5 acres, 5 to 10 acres and more than 10 acres.

c) The private land- holdings of less than 5 acres from small and marginal farmers, may be acquired by paying suitable compensation, taking into account the factors regarding land use change, frequent flooding etc

Prevention of Water Pollution of Sanctuary

a) The discharge, of untreated or under treated, Domestic Sewage from the towns in the vicinity and the Effluents from the Industrial Units around the area, into the Sanctuary or into the drains/channels discharging into it, should not be permitted. Strict action needs to be taken under Sections 24 and 25 of Water (Prevention and Control of Pollution) Act, 1974, as the bulk of pollution of the sanctuary is from these sources.

b)The Fish-Tanks outside the notified Sanctuary Area-beyond +5, are to be subjected to strict scrutiny for the Permission from competent authority, Land-Use change and the provisions of Section 25 of Water Act, 1974.

Other Measures

a) The channelization of the Sanctuary area should be undertaken cautiously, with the limited purpose of ensuring free flow of water from one basin of the lake to the other and not with the object of quick draining of water into sea.

b)The construction of Regulator on the channel connecting to Sea ,recommended by A.C.Mitra Commission, so as to maintain water level up to Contour +5 and to prevent ingress of Sea water and the lake from becoming saline.

c)The acquisition of private land-holdings between 5 to 10 acres and more than 10 acres may be considered , if the land owners have no other source of income and subject to availability of funds.

Conclusion

The Hon'ble Chief Minister is requested to consider and make use of the Life-time Opportunity for a "Good Deed", by restoring Kolleru Wildlife Sanctuary to its Pristine Glory, and be remembered for ever like "Asoka"